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EA-97-255 - Beaver Valley 1 & 2 (Duquesne Light Company (DLC)

July 3, 1997

EA 97-255

Mr. J. E. Cross, President
Generation Group
Duquesne Light Company (DLC)
Post Office Box 4
Shippingport, Pennsylvania 15077

Dear Mr. Cross:

This letter refers to the NRC inspections conducted between February 9, 1997, and April 26, 1997 at the Beaver Valley Power Station facility, the findings of which were discussed with you and members of your staff during exit meetings on March 27 and May 7, 1997. During the inspections, apparent violations of NRC requirements were identified, as described in the NRC inspection report sent to you with our letter, dated May 23, 1997. In a telephone conversation between you and Mr. Peter W. Eselgroth of my staff on May 21, 1997, Mr. Eselgroth indicated that it was not necessary to conduct a predecisional enforcement conference (conference) in order to enable the NRC to make an enforcement decision. However, you stated your preference to have a conference. On June 13, 1997, a conference was conducted with Mr. Ron L. LeGrand and other members of your staff to discuss the violations, their causes, and your corrective actions.

Based on the information developed during the inspections, and the information provided during the conference, six violations are being cited and are described in the enclosed Notice of Violation. The violations involve the failure to comply with Technical Specification (TS) requirements for surveillance testing of safety equipment, namely (1) emergency diesel generators (EDGs); (2) reactor coolant system (RCS) pressure isolation valves (PIVs); (3) hydrogen recombiners; (4) reactor protection system (RPS) and engineered safety feature actuation system (ESFAS) logic and interlocks; (5) control room emergency bottled air pressurization subsystem (CREBAPS) discharge trip valves; and (6) boron injection flowpaths.

The large number of inadequate surveillance tests identified within a relatively short period of time indicated weaknesses in your surveillance test program, particularly in the areas of scheduling, coordination, and procedural development. For example, a combination of procedural deficiencies and scheduling errors led to the failure to properly verify the integrity of the hydrogen recombiner heater circuitry. Additionally, after the improper testing was identified, the 24 hour time period allowed by TSs for completion of the missed testing was exceeded due to poor communications and coordination between operations, maintenance and engineering and a plant shutdown had to be initiated. At the enforcement conference, your staff acknowledged that inadequate management oversight and control of the TS surveillance program was the root cause of the violations, and that weaknesses in procedures, scheduling, coordination, and communications were contributing factors.

Surveillance testing requirements are designed to detect inoperable safety equipment and ensure the proper operation of the equipment within expected tolerances. Although all of the affected safety equipment was found to be operable during subsequent testing, the number of inadequate tests identified, as well as the program weaknesses that led to the inadequacies, represent a significant regulatory concern because surveillance tests and the interval for conducting them are designed, based on risk, to ensure that inoperable or degraded equipment is promptly identified. Given this potentially significant lack of attention toward licensed responsibilities, the violations have been classified in the aggregate as a Severity Level III problem in accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600.

In accordance with the Enforcement Policy, a base civil penalty in the amount of $55,000 is considered for a Severity Level III violation or problem. Your facility has been the subject of escalated enforcement actions within the last 2 years¹; therefore, 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 violations were identified by your staff. Important in this regard is the improved questioning attitude demonstrated by your staff in identifying these violations, most of which were longstanding issues, and some of which were subtle in nature. Credit is also warranted for corrective actions. In all cases, prompt action was taken to retest the affected equipment and, while the staff found that your initial root cause analyses for some of the individual violations were narrowly focused and did not adequately assess programmatic weaknesses, ultimately your corrective actions were comprehensive. These actions included, but were not limited to: (1) performing an assessment of TS surveillance sequencing; (2) reviewing existing surveillance test procedures to assure they adequately implement TS and other requirements; (3) ensuring that all new test procedures and procedure revisions are reviewed by the system and performance engineering department; (4) establishing a single point of contact for coordination and scheduling of surveillances; and (5) reemphasizing operations department accountability and ownership of the surveillance test program.

Therefore, to encourage prompt and comprehensive identification and correction of violations, I have been authorized, after consultation with the Director, Office of Enforcement, not to propose a civil penalty in this case. However, significant violations in the future could result in a civil penalty.

You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. The NRC will use your response, in part, to determine whether further enforcement action is necessary to ensure compliance with regulatory requirements.

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

                             Sincerely, 


                             Hubert J. Miller
                             Regional Administrator

Docket Nos. 50-334; 50-412
License Nos. DPR-66; NPF-73

Enclosure: Notice of Violation

cc w/encl:
S. Jain, Vice President, Nuclear Services
R. LeGrand, Division Vice President, Nuclear Operations
W. Kline, Manager, Nuclear Engineering Department
B. Tuite, General Manager, Nuclear Operations Unit
K. Ostrowski, Manager, Quality Services Unit
J. Arias, Director, Safety and Licensing Department
M. Clancy, Mayor
Commonwealth of Pennsylvania
State of Ohio

NOTICE OF VIOLATION

During NRC inspections conducted between February 9, 1997, and April 26, 1997, violations of NRC requirements were identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the particular violations are set forth below:

Unit 1 and Unit 2 Technical Specification (TS) 4.0.2 require that, each surveillance requirement shall be performed within the specified time interval.

1. Unit 1 TS 4.8.1.1.2.b.5 requires that each diesel generator shall be demonstrated OPERABLE at least once per 18 months during shutdown by verifying the diesel generator operates for greater than or equal to 60 minutes while loaded to greater than or equal to 2750 KW.

Contrary to the above, on April 11, 1996, and April 20, 1996, during emergency diesel generator (EDG) surveillance tests, the load test values used were inadequate to ensure that the EDGs achieved 2750 KW due to inaccuracies in the kilowatt meter instrument loop. Specifically, the EDGs had to be tested to at least 2875 KW to account for meter inaccuracies; however, EDG 1-1 was tested at 2850 KW on April 20, 1996, and EDG 1-2 was tested at 2800 KW on April 11, 1996. These were the only EDG surveillance tests performed to meet TS 4.8.1.1.2.b.5 during the 18-month period. (01013)

2. Unit 1 and Unit 2 TS 4.4.6.3.1 require, in part, that leakage testing of reactor coolant system (RCS) pressure isolation valves (PIVs) listed in Table 4.4-3 shall be accomplished prior to entering Mode 2 after every time the plant is placed in the COLD SHUTDOWN condition for refueling. Unit 1 TS Table 4.4-3 includes, in part, residual heat removal (RHR) system inlet isolation valves MOV-RH-700 and MOV-RH-701. Unit 2 TS Table 4.4-3 includes, in part, RHR system inlet isolation valves 2RHS-MOV701A, 2RHS-MOV702A, 2RHS-MOV701B, and 2RHS-MOV702B.

Contrary to the above, Unit 1 reactor coolant system (RCS) pressure isolation valves MOV-RH-700 and 701 were not leak tested prior to entering Mode 2, after placing the unit in cold shutdown on March 23, 1996. Additionally, Unit 2 RCS pressure isolation valves 2RHS-MOV701A(B) and 2RHS-MOV702A(B) were not leak tested prior to entering Mode 2, after placing the unit in cold shutdown on September 1, 1996. (01023)

3. Unit 1 and Unit 2 TS 4.6.4.2.b.4 require that each hydrogen recombiner system shall be demonstrated OPERABLE at least once per 18 months by verifying the integrity of all heater electrical circuits by performing a continuity and resistance to ground test immediately following the functional test required by TS 4.6.4.2.b.3.

Contrary to the above, on March 24, 1996, the integrity of Unit 1 hydrogen recombiner 1A and 1B heater circuitry was not verified immediately following the functional tests of the recombiners. On September 1, 1996, the integrity of Unit 2 hydrogen recombiner 21A and 21B heater circuitry was not verified immediately following the functional tests of the recombiners. (01033)

4. Unit 1 and Unit 2 TS 4.3.1.1.1 require that each reactor trip system instrumentation channel shall be demonstrated OPERABLE by the performance of the CHANNEL CHECK, CHANNEL CALIBRATION, and CHANNEL FUNCTIONAL TEST operations during the modes and at the frequencies shown in Table 4.3-1.

Unit 1 and Unit 2 TS 4.3.2.1.1 require that each engineered safety feature actuation system (ESFAS) instrumentation channel shall be demonstrated OPERABLE by the performance of the CHANNEL CHECK, CHANNEL CALIBRATION, and CHANNEL FUNCTIONAL TEST operations during the modes and at the frequencies shown in Table 4.3-2.

Unit 1 and Unit 2 TS 4.3.2.1.2 require that the logic for the interlocks shall be demonstrated OPERABLE during the at power CHANNEL FUNCTIONAL TEST of channels affected by interlock operation.

Contrary to the above, prior to March 24, 1997, and March 27, 1997, respectively, the Unit 1 and Unit 2 reactor coolant system loop stop valve position block signals were not tested during bimonthly channel functional testing for ESFAS instrumentation, and channel functional testing for reactor trip system instrumentation. In addition, an ESFAS P-4 interlock logic diode in the Unit 1 and Unit 2 solid state protection system logic circuits was not tested during channel functional testing. These testing omissions resulted in failure to demonstrate the interlock logic and the interlock function operable. (01043)

5. Unit 1 and Unit 2 TS 4.0.5.a.2 require that inservice testing of ASME Code Class 1, 2, and 3 pumps and valves shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50.55a(f).

Unit 1 TS 4.7.7.2.b.1 requires that the bottled air pressurization system shall be demonstrated OPERABLE at least once per 18 months by verifying that a chlorine/control room high radiation/containment phase B isolation test signal from either Unit will initiate system operation. Unit 2 TS 4.7.7.1.e.6 requires that the Control Room Emergency Air Cleanup and Pressurization System shall be demonstrated OPERABLE at least once per 18 months by verifying that a chlorine/control room high radiation/containment phase B isolation signal will initiate operation of the bottled air pressurization system.

Operating Surveillance Test 1/2OST-44A.11, "Chlorine Actuation of Control Room Isolation/CREBAPS Systems," implements the surveillance requirements and requires that the stroke times for the discharge trip valves do not exceed a prescribed ASME limiting stroke time. The test also requires that, if the discharge trip test valves exceed their previously recorded stroke times by greater than 50%, the test frequency will be increased to monthly.

Contrary to the above, CREBAPS discharge trip valves TV-VS-101B, D, and E were not stroke time tested between January 29 and March 22, 1997, following a 50% stroke time increase measured during performance of 1/2OST-44A.11 on January 28, 1997. (01053)

6. Unit 1 TS 4.1.2.2.b and Unit 2 TS 4.1.2.1.b require that at least one of the required boron injection flow paths shall be demonstrated OPERABLE at least once per 31 days by verifying that each valve (manual, power operated or automatic) in the flow path that is not locked, sealed or otherwise secured in position, is in its correct position.

Contrary to the above, prior to March 25, 1997, the monthly boron injection flowpath operability verifications were not satisfactorily completed. Specifically, position verifications for boron injection flowpath valves MOV-1CH-289 and 310 and 1CH-83 and 86 on Unit 1 and 2CHS-MOV289 and 310 on Unit 2 (valves which were not locked or secured in position) were not performed. (01063)

These violations are classified in the aggregate as a Severity Level III problem (Supplement I).

Pursuant to provisions of 10 CFR 2.201, Duquesne Light Company (DLC) is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region I, and a copy to the NRC Resident Inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a "Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response. If an adequate reply is not received within the time specified in this Notice, an order or Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other actions as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.

Under the authority of Section 182 of the Act, 42 U.S.C. 2232, this response shall be submitted under oath or affirmation.

Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

Dated at King of Prussia, Pennsylvania
this 3rd day of July 1997

1. e.g., a Notice of Violation was issued to Duquesne Light Company on March 24, 1997, for a Severity Level III problem related to configuration control (EA 97-76).

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