ML20153G397

Discusses Insp Rept 50-334/88-12 on 880303-08 & Forwards Notice of Violation

ML20153G397
Person / Time
Site:	Beaver Valley
Issue date:	04/28/1988
From:	Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Sieber J DUQUESNE LIGHT CO.
Shared Package
ML20153G399	List: ML20153G397 ML20153G401
References
EA-88-083, EA-88-83, NUDOCS 8805110224
Download: ML20153G397 (4)

See also: IR 05000334/1988012

Text

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April 28, 1988

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Docket No. 50-334

License.No. DPR-66

EA 88-83

Duquesne: Light Company

ATTN: Mr.. .J. D. Sieber

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Vice President

Nuclear Group

, . Post Office Box 4

Shippingport, Pennsylvania 15077

Gentlemen:

SUBJECT: NOTICE OF VIOLATION

4

(NRC Inspection Report No. 50-334/88-12)

. This refers to the NRC special safety inspection conducted on March 3-8, 1988

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at the Beaver Valley Power Station, Unit 1, to review the circumstances

, ' associated with a violation of a technical specification limiting condition for

operation which was identified by your staff and reported to the NRC. The

>

inspection report was sent to you on March 10, 1988. During the inspection, a

failure to meet a commitment made in the Final Safety Analysis Report (FSAR)

was also identified. On March 24, 1988, an enforcement conference was conduc-

ted with Mr. J. Sieber and other members of your staff to discuss the violation

. and deviation, their caures, and your corrective actions.

The violation, which is described in the enclosed Notice, involved the inoper-

ability (for approximately eight days while the reactor was in either the hot

, shutdown, startup or operations mode) of two of four channels used to actuate

the Containment Spray Systems and Phase B Containment Isolation whenever high

containment pressure setpoints were exceeded. The channels were inoperable in

that their associated bistables were in the bypassed position, and therefore,

not capable of performing the intended automatic safety function. The bistables

were left in this condition after completion of maintenance surveillance tests

performed on February 22, 1988. As a result, although the safety function

1 remained available throughout the period since the other two channels were ,

operable, the "built-in" redundancy for automatic actuation of these systems

was lost. At the time the tests were performed, the reactor was in the cold

shutdown mode and being prepared for startup.

The procedure used to perform the maintenance surveillance test specified that

if the reactor was in the cold shutdown or refueling modes, the bistables were

to be returned to the bypassed position upon completion of the test. Apparently,

i it was envisioned that the startup checklist performed prior to entering the

hot shutdown condition would identify this bypassed condition and return the

bistables to the proper position prior to startup. However, the startup

i che:klist had been performed approximately six hours prior to the performance

.

OFFICIAL RECORD COPY DUP CP PKG BEAVER VALLEY 88-83 - 0001.0.0

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04/27/88

8805110224 880428 I.

PDR ADOCK 05000334

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Duquesne Light Company 2

of the maintenance surveillance test for those two channels. As a result, the

bistables were not placed in the bypassed position until after the startup

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checklist had been completed.

"

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The NRC notes that a similar maintenance surveillance test on the other two

channels had been performed just prior to performance of the startup checklist,

and those channels were left in the bypassed position, in accordance with the  !

-procedure, upon e mpletion of the test. However, those two channels were l

returned to the normal position when identified during the performance of that

startup checklist. If the checklist had been performed but a few hours

, earlier, all four bistables could have been left in the bypassed position,

which would have rendered all four channels inoperable.

The NRC is concerned that the specific maintenance survei'llance test pre-edure,

although requiring that the operations department be notified when the surveil--

lance was completed did not require that the operations department be informed

that the equip e nt was left, at the completion of the test, in a configuration

other than existed at the beginning of the surveillance. If the operations

department had been notified of this condition, additional cFecks could have

been performed at that time to ensure restoration of the bi, table to the normal l

position prior to entering the hot shutdown mode. Furthermore, when these

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channels were in the bypassed position, there was no indication in the control

room of this condition, contrary to a commitment in the FSAR. Apparently,

, although there was control room indication at the time the commitment was made  ;

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in the FSAR, this indication capability was lost during a modification made at

the facility in 1980. A change to the FSAR was never made. The failure to

satisfy this commitment, which is described in the associated inspection

report, is also of concern since the violation could have been prevented if

control room indications existed.

'

In accordance with the "General Statement of Policy and Procedure for NRC

Enfnecement Actions," 10 CFR Part 2, Appendix C (1987), the violation described

,

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in the enclosed Notice has been classified at Severity Level III A civil .

penalty is considered for a Severity Level III violation. However, after f

consultation with the Director, Office of Enforcement and the Deputy Executive

!. Director for Regional Operations, I have decided that a civil penalty will not

i be proposed in this case because (1) the violation was identified by your staff

and promptly reported to the NRC, and (2) your "root cause" analysis of this

event was very thorough, and corrective actions taken sutaequent to that

analysis were unusually prompt and extensive. By this action, the NRC does not

minimize the significance of the violation. Rather, your actions in response  ;

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to the violation and described in the enforcement conference demonstrate that  !

l you recognize the significance of this violation. It is clearly not accept 6ble ,

l to operate in a condition where the loss of one additional channel could defeat  :

! initiation of containment spray and automatic containment isolation. The NRC '

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emphasizes that any similar violations in the future will result in additional

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enforcement actions. ,

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l OFFICIAL RECORD COPY DUP CP pKG BEAVER VALLEY 88-83 - 0002.0.0 '

04/28/88 ,

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Duquesne Light Company 3

You are required to respond to this letter and should follow the instruc-

tions specified in the enclosed Noticas when preparing your response. In

your response, you should document the specific actions taken and any addi-

tional actions you plan to prevent recurrence. In addition, you should

describe the actions taken or planned to assure that FSAR commitments are

met, or if changed, are changed in accordance with the requirements of 10 CFR

50.59 and 50.71. After reviewing your response to this Notice, including

your proposed corrective actions and the results of future inspections, the

NRC will determine whether further NRC enforcement action is necessary to

ensure compliance with NRC regulatory requirements.

In accordance with Section 2.790 of the NRC's "Rules of Practice," Part 2,

Title 10, Code of Federal Reoulations, a copy of this letter and its enclo-

sure will be placed in the Nk? Public Document Room.

The responses directed by this letter and the enclosed Notice are not subject

to the clearance procedures of the Office of Management and Budget as required

by the Paperwork Reduction Act of 1980, PL No.96-511.

Sincerely,

Originn.1 Sicnnd By

CF ~ Y. ..J:ZLL

William T. Russell

Regional Administrator

Enclosure:

Notice of Violation

cc w/ encl:

J. J. Carey, Executive Vice President, Operations

J. O. Crockett, General Manager, Corporate Nuclear Services

W. S. Lacey, General Manager, Nuclear Operations

N. R. Tonet, Manager, Nuclear Engineering

T. P. Noonan, Plant Manager

C. E. Ewing, QA Manager

K. D. Grada, Manager, Nuclear Safety

Public Document Room (PDR)

local ?ublic Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector

Commonwealth of Pennsylvania

0FFICIAL RECORD COPY DUP CP PKG BEAVER VALLEY 88-83 - 0003.0.0

04/27/88

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Duquesne Light Company 4

bec w/ encl:

Region I Docket Room (with concurrences)

Management Assistant, DRMA (w/o enc 1)

DRP Section Chiof

Robert J. Bores, DRSS

SECY

J. Taylcr, DEDR0

J. Lieberman, OE

J. Allan, RI

D. Holody, RI

J. Goldberg, OGC

Enforcement Directors, RII-III

Enforcement Officers, RIV-V

T. Murley, NRR

F. Ingram, PA

J. Bradburne, CA

E. Jordan, AE00

B. Hayes, OI

S. Connelly, 0IA

P. Robinson, OE

R. Cunningham, NMSS

D.Nussbaumer, 0GP/SP

OE File (3 copies = ltrhd)

EDO Rdg File

DCS

R. B(nedict, NRR

B. Clayton, EDO

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Russ Miraglia Chandler Lieberman Taylor

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0FFICIAL RECORD COPY f DUP U PKG BEAVER VALLEY 88-83 - 0004.0.0

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