Information Notice 1979-35, Control of Maintenance & Essential Equipment
ML031180205 | |
Person / Time | |
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Site: | 05000000 |
Issue date: | 12/31/1979 |
Revision: | 0 |
From: | NRC/OI |
To: | |
References | |
IN-79-035, NUDOCS 7910250510 | |
Download: ML031180205 (10) | |
UNITED STATES SSINS No.: 6870NUCLEAR REGULATORY COMMISSION Accessions Mo.:OFFICE OF INSPECTION AND ENFORCEMENT 7910250510WASHINGTON, -D.C. 20555December 31, 1979IE Information Notice No. 79-35CONTROL OF MAINTENANCE AND ESSENTIAL EnUIPMENT
Description of Circumstances
- Enclosed is a copy of a recent enforcement action against Duquesne Light Company.A coDy of this action is being forwarded to all utilities with a power reactoroperating license or a construction permit. This is being done to apprise you ofa serious condition which revealed an apparent weakness in facility control ofmaintenance and essential equipment.You should review your existinq procedures and control for independent verificationof operability of redundant counterpart equipment when an essential component,subsystem, or system is determined inoperable. Operability is defined as follows:A system, subsystem, train, component or device shall be OPERABLE or haveOPERABILITY when it is capable of performing its specified functionts).Implicit in this definition shall be the assumption that all necessaryattendant instrumentation, controls, normal and emergency electrical powersources, coolinq or seal water, lubrication or other auxiliary equipmentthat are required for the system, subsystem, train, component or deviceto perform its function(s) are also capable of performing their relatedsupport function(s).If you have any Questions reqardina this matter, please contact the Director ofthe NRC Regional Office in which your facilities are located. No written responseto this IE Information Notice is required.
Enclosures:
1. Letter to Duguesne Light Companyfrom V. Stello, Jr., dtd. 12/5/792. Recently Issued IE InformationNotices IE Information Notice No. 79-35December ,31 1979EnclosureRECENTLY ISSUEDIE INFORMATION NOTICESInformationNotice No.SubjectDateIssuedIssued To79-3479-3379-3279-3179-3079-2979-28Inadequate Desiqn ofSafety-Related HeatExchangersImproper Closure ofPrimary ContainmentAccess HatchesSeparation of ElectricalCables for HPCI and ADSUse of Incorrect AmplifiedResponse Spectra (ARS)Reportinq of Defects andNoncompliance, 10 CFR Part 21.Loss of NonSafety-RelatedReactor Coolant SystemInstrumentation DuringOperationOverloading of StructuralElements Due to Pipe SupportLoadsSteam Generator TubeRuptures At Two PWRFacilitiesAttempted Damane To NewFuel AssembliesBreach of ContainmentIntegrityReactor Trips At TurkeyPoint Units 3 And 412/6/79All power reactor facilitiesholding OLs and CPs andvendors inspected by LCVIP11/16/79 All power reactor facilitiesholding OLs or CPs11/16/79 All power reactor facilitieswith an OL or CP11/16/79 All power reactor facilitiesholdinq OLs and CPs11/9/79 All Fuel Facilities,research reactors, andpower reactors with anOL or CP12/27/79 All holders of power reactorOLs and CPs12/21/79 All power reactor facilitiesholdinc OLs and CPs12/21/79 All power reactor facilitiesholding OLs and CPs12/13/79 All holders of power reactorOLs and CPs79-2779-12A79-2679-2511/5/7910/1/79All power reactor facilitiesholdina OLs and CPsAll power facilities withan nL or a CP Docket No. 50-334December 5, 1979Duquesne Light CompanyATTN: Mr. Stanley G. SchaefferPresident435 Sixth AvenuePittsburgh, Pennsylvania 15219Gentlemen:On November 27, 1979, the Beaver Valley Power Station, Unit 1, was operatedfor about two (2) hours in a condition which exceeded the Limiting Conditionsfor Operation.This matter was brought to the attention of our inspector at your facility ina timely fashion, and your subsequent action to correct the condition wasexpeditious. Nevertheless, this condition rendered a part of the emergencycore cooling system (ECCS) unavailable for automatic start and injection ofcoolant into the reactor coolant system (RCS) if the need had occurred concur-rent with the loss of offsite power (the design basis). This unavailabilityof ECCS constitutes a serious matter which reveals an apparent weakness inyour control of maintenance and essential equipment. Therefore, we proposeto impose a civil penalty for the item of noncompliance set forth in Appendix Ato this letter in the amount of $5,000. Appendix B is a Notice of ProposedImposition of Civil Penalties. You are required to respond to this letter andin preparing your response, you should follow the instructions in Appendices Aand B.In addition to the civil penalty, we are issuing the enclosed Order (Appendix C)effective Immediately. This Order requires that your administrative controlof licensed activities involving operating and maintenance of safety equipmentverifies availability of all required equipment when a counterpart is removedfrom an operable status. This Order further requires that you formally reviewand report your actions to prevent recurrence: It also requires that you meetpublicly on January 25, 1980, with the Director, Office of Inspection andEnforcement, at a location near the Beaver Valley Power Station, to discussyour evaluation of this conditon and your corrective actions to preventrecurrence. We will inform you of the location and time of the meetin Duquesne Light Company-2 -In accordance with Section 2.790 of the NRC's "Rules of Practice", Part 2,Title 10, Code of Federal Regulations, a copy of this letter and its enclosureswill be placed in the Commission's Public Document Room.
Sincerely,Victor Stello, Jr.DirectorOffice of Inspectionand Enforcement
Enclosure:
1. Appendix A, Notice of Violation2. Appendix B, Notice of ProposedImposition of Civil Penalties3. Appendix C, Order Modifying Licensecc: C. N. Dunn, Vice President, Operations DivisionF. Bissert, Technical Assistant NuclearR. WIashabaugh, QA ManagerJ. Werling, Station SuperintendentG. Moore, General Superintendent,J. J. Carey, Nuclear Technical AssistantR. Martin, Nuclear Engineer APPENDIX ANOTICE OF VIOLATIONDuquesne Light Company Docket No. 50-334Pittsburqh, Pennsylvania 15219 License No. DPR 66This refers to the inspection conducted by the NRC Resident Inspector at theBeaver Valley Power Station, Unit 1, of activities authorized by NRC LicenseNo. DPR 66.During the inspection conducted on November 27, 1979, the following item ofnoncompliance was identified.Technical Specification 3.5.2 states that with the plant in Mode 1 (PowerOperation), two separate and independent ECCS subsystems shall be operable, andfurther states in section 3.5.2.c that each subsystem shall include an operableflow path caoable of taking suction from the refueling water storage tank uponinitiation of a safety injection signal.Technical Specification 1.6 defines "operable" to include the assumption that allnecessary attendant instrumentation, controls, electric power, cooling or sealwater, lubrication or other auxiliary equipment that are required for the system,subsystem, train, component or device to perform its function(s) are also capableof performing their related safety function(s).Contrary to the above, on November 27, 1979, from approximately 8:30 a.m. to10:30 a.m., maintenance activities rendered both ECCS subsystems inoperable inthat a) refueling water storage tank isolation valve MOV-CH-115D was closed andincapable of automatic opening in response to a safety injection signal, andb) refueling water storage tank isolation valve MOV-CH-115B, in the redundantsubsystem, was closed, had no emergency power available, and thus was incapableof automatic opening In response to a safety injection signal if there had beena condition of loss of offsite power.This violation had the potential for causing or contributing to an occurrencerelated to health and safety (Civil Penalty $5,000).
APPENDIX BNOTICE OF PROPOSED IMPOSITION OF CIVIL PENALTIESDuquesne Light Company nocket No. 50-334Pittsburgh, Pennsylvania 15219 License No. DPR-66This office has considered the enforcement options available to the MRCincluding administrative actions in the form of written notices of violation,civil monetary penalties, and orders pertaining to the modification, suspensionor revocation of a license. Based on these considerations, we propose toimpose civil penalties pursuant to Section 234 of the Atomic Energy Act of1954, as amended, (42 USC 2282), and to 10 CFR 2.205 in the cumulative amountof Five Thousand Dollars ($5,000) for the specific items of noncompliance setforth in Appendix A to the cover letter. In proposing to impose civil penal-ties pursuant to this section of the Act and in fixing the proposed amount ofthe penalties, the factors identified in the Statements of Considerationpublished in the Federal Register with the rule-making action which adopted10 CFR 2.205 (36 FR 16894) August 26, 1971, and the "Criteria for DeterminingEnforcement Action," which was sent to NRC licensees on December 31, 1974,have been taken into account.Duquesne Light Company may, within twenty (20) days of the receipt of thisnotice pay the civil penalties in the cumulative amount of Five ThousandDollars ($5,000) or may protest the imposition of the civil penalties in wholeor in part by a written answer. Should Duquesne Light Company fail to answerwithin the time specified, this office will issue an order imposing the civilpenalties in the amount proposed above. Should Duquesne Light Company electto file an answer protesting the civil penalties, such an answer may (a) denythe items of noncompliance listed in the Notice of Violation in whole or inpart, (b) demonstrate extenuating circumstances, (c) show error in the Noticeof Violation, (d) show other reasons why the penalties should not be imposed.In addition, to protesting the civil penalties in whole or in part, suchanswer may request remission or mitigation of the penalties.Any written answer in accordance with 10 CFR 2.205 should be set forthseparately from the statement or explanation in reply pursuant to 2.201, butmay incorporate by specific reference (e.g., giving page and paragraph numbers)to avoid repetition.Duquesne Light Company's attention is directed to the other provisions of10 CFR 2.205 regarding, in particular, failure. to answer and ensuing orders;answer, consideration by this office, and ensuing orders; requests forhearings, hearings and ensuing orders; compromise, and collection.Upon failure to pay any civil penalty due which has been subsequently determinedin accordance with the applicable provisions of 10 CFR 2.205, the matter maybe referred to the Attorney General, and the penalty, unless compromised,remitted, or mitigated, may be collected by civil action pursuant to Section234.c of the Atomic Energy Act of 1954, as amended (42 USC 2282).
APPENDIX CUNITED STATES OF AMERICANUCLEAR REGULATORY COMMISSIONIn the flatter of )DUOUESNE LIGHT COMPANY Docket No. 50-334(Beaver Valley Power Station, Unit 1) )ORDER MODIFYING LICENSEEFFECTIVE IMMEDIATELYIThe Duquesne Light Company (the "licensee") is the holder of Operating LicenseDPR-66 (the "license") which authorizes operation of the Beaver Valley PowerStation, Unit 1, at steady state reactor core power levels not in excess of2652 megawatts thermal (rated power). The license was issued on January 30,1976. The facility consists of a pressurized light water moderated and cooledreactor (PWR), located at the licensee's site in Beaver County, Pennsylvania,on the southern shore of the Ohio River.ItOn November 27, 1979, from about 6:30 AM to 1:20 PM while the reactor wasoperating at about 30% of rated power, Emergency Diesel Generator (EDG) 1 wasout of service for routine maintenance. This EDG supplies emergency power tosuction valve, MOV-CH-115B, in the line from the refueling water storage tank(RWST) to the High Pressure Safety Injection System (HPSIS) pumps. In additionto the EDG being out of service, resulting in loss of one Emergency CoreCooling System (ECCS) flow path, as described above, the redundant suctionvalve, MOV-CH-115D, was removed from service for maintenance which resulted inloss of the redundant ECCS flow path from the RWST from 8:30 a.m. to 10:30 a.m.During this time the facility was operated in noncompliance with the LimitingCondition for Operation specified in Technical Specification 3.5.2.c. Thiscondition resulted from inadequate control of maintenance activities and its Appendix C-2 -occurrence suggests that the licensee has not adopted appropriate controlsto assure that maintenance activities do not defeat required safety features.This in turn undermines the basis for determining that there is reasonableassurance that redundant safety features will function under design basisconditions. In view of the significance to safety of adequate controls to assurethat maintenance activities do not defeat required safety features, I have deter-mined that the public health, safety, or interest requires, effective immediately,modification of License No. DPR-66 as stated in Part III of this Order.IIIAccordingly, pursuant to the Atomic Energy Act of 1954, as amended, and theCommission's regulations in 10 CFR Parts 2 and 50, License DPR-66 is modifiedas follows:(1) Administrative Procedures shall be adopted and implemented to requireredundant independent verification of the operability of the remainingengineered safety features whenever any safety system, or subpartthereof, is intentionally removed from service.(2) A detailed review of existing procedures and controls shall be performedto assure that limiting conditions for operation are not defeated bymaintenance or other activities.(3) A report of the administrative procedures required by paragraph (1) aboveand the detailed review required by paragraph (2) above shall be submittedby January 11, 1980, to the Director of NRC's Region I offic Appendix C-3 -(4) The licensee shall meet with the Director, Office of Inspection andEnforcement, on or before January 25, 1980, in a meeting open to thepublic in the vicinity of the Beaver Valley site to describe how theabove requirements will be implemented. The Director, Region I, willinform the licensee at least one week in advance of the specific time andlocation of the meeting.IVThe licensee, or any other person who has an interest affected by this Order,may, within twenty-five days of the date of this Order, request a hearing. Arequest for a hearing shall be addressed to the Director, Office of Inspectionand Enforcement, U.S.N.R.C., Washington, D.C. 20555. If a hearing is requestedby the licensee or an interested person, the Commission will issue an Orderdesignating the time and place of hearing. Such a request for hearing SHALLNOT STAY THE IMMEDIATE EFFECTIVENESS OF THIS ORDER.Resumption of operation on terms consistent with this Order is not stayed bythe pendency of any proceeding on this Order. In the event that a need forfurther enforcement action becomes apparent, either in the course of anyproceeding on this Order or at any other time, the Director will take appro-priate action.VIn the event the licensee or any other interested person requests a hearing asprovided above and a hearing is held, the issues to be considered at such ahearing shall be:
Appendix C -4 -(1) whether the facts set forth in Part II of this Order are correct;and,(2) whether this Order should be sustained.FOR THE NUCLEAR REGULATORY COW2IISSIONVictor Stello, Jr.DirectorOffice of Inspection andEnforcementDated at Bethesda, Marylandthis 5th day of December, 1979.