IR 05000412/1999007

Refers to Special Team Insp 50-412/99-07 Conducted from 990720-29 & Forwards Nov.Two Violations Identified.First Violation Involved Failure to Implement C/A to Prevent Biofouling of Service Water System

ML20217N142
Person / Time
Site:	Beaver Valley
Issue date:	10/21/1999
From:	Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Cross J DUQUESNE LIGHT CO.
Shared Package
ML20217N147	List: IR 05000412/1999007 ML20217N149
References
50-412-99-07, EA-99-212, NUDOCS 9910280122
Download: ML20217N142 (5)

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% * * .+ g October 21,.1999 EA 99-212 Mr. J. Generation Group . ,

Duquesne Light Company '

Post Office Box 4 Shippingport, Pennsylvania 15077 SUBJECT: NOTICE OF VIOLATION

. (NRC Inspection Report No. 50-412/99-07)

Dear Mr. Cross:

- This refers to the NRC special team inspection conducted from July 20 through July 29,1999, at the Beaver Valley ' Unit 2 Power Station, the results of which were discussed with you at an exit

- meeting on July 29,'1999. The inspection was conducted, in part, to review the macro biological fouling (biofouling) problems which affected the service water system supply to the heat exchangers for both emergency diesel generators (EDGs). The inspection report was forwarded to you on September 7,1999. During the inspection, three apparent violations of NRC requirements associated with the. biofouling problems were identified. In our September 7,

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1999 letter, we offered you the opportunity to either respond in writing to the apparent violations addressed in this inspection report or request a predecisional enforcement conference. In a letter dated October 7,1999, you provided a response to the apparent violations.

Based on the information developed during the inspection and the information provided in~your October 7,1999 response, the NRC has determined that two violations of NRC requirements occurred. The violations are cited in the enclosed Notice of Violation (Notice) and the circumstances surrounding them are described in detail in the subject inspection report. The violations involve: (1) the failure to implement corrective actions to prevent biofouling of the !

- service water system, despite prior opportunities to do so; and (2) the failure to provide l adequato acceptance criteria in the procedure for chemical treatment of the service water system. These violations resulted in fouling of the EDG heat exchangers.

The 2-2 EDG was declared inoperable during a surveillance test on July 14,190 - hen service water flow to the EDG's heat exchanger decreased to 1070 gpm, which was below the design

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basis of 1170 gpm set forth in your Updated Final Safety Analysis Report. Subsequent inspection revealed that service water flow to the heat exchanger was reduced because about 3

- gallons of biological fouling, primarily in the form of Zebra mussels, was blocking about 90' T

' percent of the heat exchanger's tube sheet.' The biological fouling was the result of a bulk chemical treatment of the service water system on July 7,1999, 9910280122 991021 #

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- Duquesne Light Company 2 i Although you were aware of the potential for biofouling of plant systems as ear:, as 1990, and developed a plan for preventive and corrective actions in 1995, the planned actions were not

- effectively implemented. The routine and bulk biocide treatments were not applied at an

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appropriate frequency to prevent infestation of Zebra mussels in the service water system. As a j result, when a bulk blocide treatment was applied to the service water system in July 1999, the ;

mussels in portions of the system accumulated in the 2-2 EDG heat exchanger during l surveillance testing of the EDG. The heat exchanger for the other EDG did not clog at the same time because the intended blocide concentra'tlon was not applied to the other service water train due to an error in implementation of the chemical treatment procedure. Subsequently, the procedure was reperformed for the other train and biofouling occurred in the heat exchanger for the other EDG. The plant was shutdown at the time of this occurrence. You had an additional opportunity to address the biofouling problem in 1998 when the zebra mussel population increased at the service water intake structure. However, no changes were made to the action plan and an opportunity was missed to identify the inadequate controls for preventing biofouling. i The failure to promptly identify and correct the biofouling of the service water heat exchangers constitutes a violation of 10 CFR 50, Appendix B, Criterion XVI, " Corrective Actions."

Further, your chemical treatment procedure did not contain quantitative or qualitative acceptance criteria to determine the adequacy of service water flow to the EDG heat exchangers following the blocide treatments. As a result, the degraded condition was not identified until 7 days after the blocide treatment when a surveillance test cf the EDG was conducted. The inadequacies in the procedure delayed the identification of the degraded condition and constitute a violation of 10 CFR 50, Appendix B, Criterion V, "Drocedures."

These violations are potentially risk significant because the heat exchangers for both diesel generators would have become biofouled if the planned chemical treatment procedure had been followed, in your October 7,1999 response, you provided the results of an analysis which indicated that EDG 2-2 was degraded but operable. Specifically, you concluded that the minimum expected flow through the EDG heat exchangers would have been sufficient for the EDGs to perform their safety function if called upon during the period !n question. Based on review of this information, the NRC agrees with your determination that the EDG was operable during the period in question. Therefore, there was no violation of Technical Specifications.

However, given the significance of the flow degradation, and the credible potential for simultaneous failure of both EDGs, it was not assured that the EDGs would have been able to perform their intended safety function under different circumstances (i.e., higher river water temperature). Therefore, these violations represent a Severity Level 111 problem in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG-1000, in accordance with the Enforcement Policy, a base civil penalty in the amount of $55,000 is considered for a Severity Level lli violation or problem. Because your facility has been the

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Duquesne Ligt t' Company .3'

subject of escalated enforcement action within the last 2 years', the NRC considered whether credit was warranted for identification and Corrective Action in accordance with the civil penalty assessment process in Section VI.B.2 of the Enforcement Policy. Credit is warranted for identification because the biofouling problem was identified during your surveillance test of the emergency diesel generator and, subsequently, you performed a root cause analysis which identified that your Zebra mussel control program was ineffective and the implementing procedures were inadequate. Credit is also warranted for corrective action because your

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actions, as described in your October 1999 letter, were considered prompt and comprehensive.

These actions included, but were not limited to: (1) restoration of the EDG heat exchangers and inspection of other heat exchangers for biofouling; (2) revisions to chemical treatment and surveillance procedures; (3) determination of the optimum frequency for blocide treatments and

- incorporation of the treatments into the work control scheoule; and (4) plans to review the effectiveness of the Zebra mussel control program.

Therefore, to encourage prompt identification and comprehensive correction of violations, I have been authorized, after consultation with the Director, Office of Enforcement, to not propose a

. civil penalty in this case. However, significant violations in the future could result in a civil penalty.

The NRC has concluded that information regarding the reason for the violations, the corrective actions taken and planned to correct the violations and prevent recurrence is already adequately

- addressed on the docket in your letter dated October 7.1999. Therefore, you are not required to respond to this letter unless the description therein does not accurately reflect your corrective actions or your position. In that case, or if you choose to provide additional information, you should follow the instructions specified in the enclosed Notice.

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in accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter, its enclosure will be placed in the NRC Public Document Room (PDR).

Sincerely, h

Hubert J. Miller Regional Administrator Docket No. 50-412 License No. NPF-73

- Enclosure: . Notice of Violation

'A Severity Level III violation and a $55,000 civil penalty was issued on January 6,1998 (EA 97-517).

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. Duquesne Light Company - 4 i

l cc w/ encl:

L F. von Ahn, Acting Senior Vice President, Nuclear Services Group l L. W. Myers, Executive Vice President, Generation Group l K. Ostrowski, Vice President, Nuclear. Operations Group and Plant Manager

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W. Pearce, General Manager, Nuclear Operations Unit W. Kline, Manager, Nuclear Engineering Department M. Pearson, Manager, Quality Services Unit M. Ackerman, Manager, Safety & Licensing Department 8. Davis, Acting Manager, System and Performance Engineering J. A. Huitz, Manager, Projects and Support Services, First Energy M. Clancy, Mayor, Shippingport, PA Commonwealth of Pennsylvania State of Ohio State of West Virginia

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[ Duquesne Light Cornpany 5

_ DISTRIBUTION:

'SECY CA-PUBLIC WTravers, EDO MKnapp, DEDMRS FMiraglia, DEDR RBorchardt, OE DDambly, OGC HMiller, Rl SCollins, NRR BSheron, NRR NOlsen, NRR Enforcement Coordinators Rl, Rll, Rlli, RIV BBeecher, OPA HBelt, OlG PLohaus, OSP GCaputo, 01 OE:EA OE:Chron NUDOCS Nuclear Safety Information Center (NSIC) >

DScrenci, PAO Ri NSheehan, PAO-RI NRC Resident inspector - Beaver Valley LTremper, OC S:

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