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EA-97-517 - Beaver Valley 1 & 2 (Duquesne Light Company, DLC)January 6, 1998 EA 97-517 Mr. J. E. Cross, President
Dear Mr. Cross: This letter refers to the NRC inspection conducted between August 31, 1997, and October 4, 1997, at the Beaver Valley Power Station, Units 1 & 2, the findings of which were discussed with you and members of your staff during an exit meeting on October 14, 1997. During the inspection, an apparent violation of NRC requirements was identified involving the failure to take adequate action to correct a significant condition adverse to quality at the facility. The specific adverse condition involved voiding in the high head safety injection (HHSI) suction lines which could lead to gas binding of the HHSI pumps and consequent failure to operate. The related NRC inspection report was sent to you on November 7, 1997. This also refers to an NRC inspection conducted between October 5, 1997, and November 15, 1997, the findings of which were discussed with you and members of your staff during an exit meeting on November 21, 1997. During that inspection, the NRC documented a related unresolved item with respect to whether the venting of the HHSI pumps immediately prior to its surveillance test invalidated the test causing a violation of NRC requirements. On December 10, 1997, a Predecisional Enforcement Conference was conducted with you and members of your staff to discuss the apparent violation, its causes, and your corrective actions, as well as the related unresolved item. Based on the information developed during the inspections, and the information provided during the conference, one violation is being cited and is described in the enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Notice). The violation involves your failure to take adequate action to correct this significant condition adverse to quality regarding gas binding of the HHSI pumps. This condition was identified at Unit 2 on September 12, 1997 when operators observed that the differential pressure for one of the Unit 2 HHSI pumps was below its Technical Specification limit. Previously, your staff had encountered repeated instances of gas binding of this specific HHSI pump. However, on each occasion, adequate corrective actions were not taken, as more fully described herein. These repeated instances of gas binding of the pump likely caused the degradation of the pump below Technical Specification differential pressure limits. This finding is significant because the gas binding of the pump created the potential for interruption of HHSI flow to the reactor during design basis accident conditions. The violation is particularly risk significant because the issue affected both units over a long duration and affected the only safety related high pressure source of injection to the reactor vessel for several accident scenarios. At the conference, you recognized the seriousness of this problem, noting that in not taking adequate corrective actions sooner, you operated outside the design basis for the facility. You also indicated that the failure of your staff to display a more questioning attitude on this matter was one of the root causes of the problem. This was evident during testing of the pump in August 1997 when indications of degraded pump performance were not fully evaluated following surveillance testing on August 20 and after extensive venting on August 28, or prior to returning the pump to operability following the August 28 gas binding event. This finding is also significant because the prior indications of gas binding of this pump provided clear opportunities to correct this condition sooner. In March 1988, your staff discovered excessive gas accumulation on a Unit 2 HHSI pump. This gas accumulation was large enough to prohibit the pump from operating. Your investigation in 1997 has shown that the corrective actions taken from 1988 to 1997 for Unit 1 and Unit 2 were ineffective to prevent possible gas binding events due to inadequate engineering evaluations and a failure to evaluate the effectiveness of the corrective actions. For example, you attributed the gas binding of a Unit 2 HHSI pump (the same pump that failed in September 1997) in June 1993 to the accumulation of excessive gas because of inadequate manual venting of the charging lines to the volume control tank (VCT). Although corrective actions were planned to install a continuous venting design, this action was never implemented and the item was closed in your tracking system. In addition, in November 1996, that same pump again experienced gas binding. While the planned corrective action at that time was to modify the vent path to improve the manual venting of the system, this action was not scheduled for completion until January 15, 1998, and there were no interim actions taken to prevent recurrence of gas binding. Further, in August 1997, the pump again experienced gas binding even after the lines had been vented for over three hours, which was much longer than the normal venting period of less than 10 minutes. This type of violation is similar to the failure to correct a condition adverse to quality at Unit 1 involving the operation of the reactor with two of the three pressurizer power operated relief valve (PORV) block valves shut for an extended period of time (from 1981 until 1996). As you know, on March 10, 1997, the NRC issued to Duquesne Light Company a Notice of Violation and Proposed Imposition of Civil Penalty in the amount of $160,000 for, in part, the failure to correct that adverse condition related to the PORV block valves. In that case, your staff also missed several opportunities to identify and correct the incorrect valve lineup. Given the risk significance of the failure to correct the HHSI gas binding phenomena, despite the prior opportunities to do so, the violation has been classified at Severity Level III in accordance with the "General Statement of Policy and Procedures for NRC Enforcement Action, (NUREG-1600) (Enforcement Policy). In accordance with the Enforcement Policy, the base civil penalty amount for this Severity Level III violation is $55,000. Your facility has been the subject of escalated enforcement actions within the last two years, as already noted herein; 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 not warranted for identification since the violation was identified as a result of an event, and it should have been identified sooner given the prior opportunities. Credit is warranted for corrective action because your corrective actions, which were described during the conference, were considered prompt and comprehensive after the September 12, 1997 event. Those actions included, but were not limited to: (1) initiation of a multi-discipline team to review events leading to the pump's failure to meet the technical specification; (2) plans to install six 22-stage recirculation line orifices in order to eliminate the vast majority of the generation of hydrogen gas; (3) plans to perform more frequent ultrasonic measurements to determine gas accumulation; (4) detailed engineering evaluations and establishment of gas accumulation limits for Unit 1 and Unit 2; (5) conduct of safety culture training to focus on improving questioning attitude; and (6) plans to establish a Critique Process to promote earlier identification and resolution to deviant conditions. Therefore, to emphasize (1) the importance of a questioning attitude to ensure prompt and comprehensive identification and correction of conditions adverse to quality when they exist, and (2) aggressively looking for and pursuing anomalous conditions at the facility, I have been authorized, after consultation with the Director, Office of Enforcement, to propose a $55,000 civil penalty in this case. Given the high risk significance of this condition, as well as the period of time it existed, I considered exercising discretion to increase the civil penalty. However, I have decided not to do so in view of the overall comprehensiveness of your corrective actions. With respect to the unresolved item discussed during the second inspection, the NRC is still evaluating this matter and resolution will be handled by separate correspondence at a later date. 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,
ORIGINAL SIGNED BY
WILLIAM L. AXELSON for
Hubert J. Miller
Regional Administrator
Docket Nos. 50-334; 50-412 Enclosure: Notice of Violation and Proposed Imposition of Civil Penalty cc w/encl:
NOTICE OF VIOLATION
During an NRC inspection conducted between August 31, 1997, and October 4, 1997, for which an exit meeting was held on October 14, 1997, a violation of NRC requirements was identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the NRC proposes to impose a civil penalty pursuant to Section 234 of the Atomic Energy Act of 1954, as amended (Act), 42 U.S.C. 2282, and 10 CFR 2.205. The particular violation and associated civil penalty are set forth below: 10 CFR Part 50, Appendix B, Criterion XVI, states, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action is taken to preclude repetition. Contrary to the above, between 1988 and September 12, 1997, a condition adverse to quality existed at Unit 1 and Unit 2, when excessive gas accumulation in the HHSI pumps suction lines resulted in the potential operation of both units outside the design basis. The excessive gas accumulation resulted in repeated gas binding of the Unit 2 high head safety injection (HHSI) pump 2CHS-P21C. During that time, measures were not established to ensure that the condition adverse to quality was promptly identified and corrected until after September 12, 1997, when the differential pressure for the pump was observed to be at 2341 psid which was below the limit of 2437 listed in Technical Specifications 4.1.2.4.1 and 4.5.2.b.1. Specifically, 1. In March 1988, the licensee discovered excessive gas accumulation on the HHSI Pump 2CHS-P21A. This gas accumulation was large enough to prohibit the pump from operating. The licensee identified that Unit 1 also experienced gas accumulation in the HHSI system. Corrective actions taken in 1988 to 1990 to install manual venting systems and establish venting frequencies were inadequate to prevent possible gas binding events due to inadequate engineering evaluations and failure to evaluate the effectiveness of the corrective actions.2. In June 1993, HHSI Pump 2CHS-P21C experienced gas binding which the licensee attributed to an accumulation of excessive gas due to inadequate venting of the charging lines to the volume control tank. While the corrective actions stated in response to this event were to install the design for continuous venting, this action had not been implemented as of September 12, 1997 even though the item had been closed in the licensee's tracking system.3. In November 1996, HHSI Pump 2CHS-P21C again experienced gas binding which was again attributed to inadequate venting of the charging lines to the VCT. While the corrective action stated in response to that event was to modify the vent path to improve the manual venting of the system, this action was not scheduled for completion before January 15, 1998, and there were no interim actions taken to prevent recurrence of gas binding.4. In August 1997, HHSI Pump 2CHS-P21C again experienced gas binding due to inadequate venting of the charging lines. However, corrective actions taken prior to the pump start and following that event were deficient in that indications of degraded pump performance were not fully evaluated following surveillance testing on August 20 and after the extensive venting on August 28, or prior to declaring the pump operable following the August 28 gas binding event. (01013) This violation is classified at Severity Level III (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 Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, within 30 days of the date of this Notice of Violation and Proposed Imposition of Civil Penalty (Notice). This reply should be clearly marked as a "Reply to a Notice of Violation" and should include for each alleged violation: (1) admission or denial of the alleged violation, (2) the reasons for the violation if admitted, and if denied, the reasons why, (3) the corrective steps that have been taken and the results achieved, (4) the corrective steps that will be taken to avoid further violations, and (5) the date when full compliance will be achieved. If an adequate reply is not received within the time specified in this Notice, an Order or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked or why such other action as may be proper should not be taken. Consideration may be given to extending the response time for good cause shown. Under the authority of Section 182 of the Act, 42 U.S.C. 2232, this response shall be submitted under oath or affirmation. Within the same time as provided for the response required above under 10 CFR 2.201, the Licensee may pay the civil penalty by letter addressed to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, with a check, draft, money order, or electronic transfer payable to the Treasurer of the United States in the amount of the civil penalty proposed above, or may protest imposition of the civil penalty, in whole or in part, by a written answer addressed to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission. Should the Licensee fail to answer within the time specified, an order imposing the civil penalty will be issued. Should the Licensee elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalty, in whole or in part, such answer should be clearly marked as an "Answer to a Notice of Violation" and may: (1) deny the violation(s) listed in this Notice, in whole or in part, (2) demonstrate extenuating circumstances, (3) show error in this Notice, or (4) show other reasons why the penalty should not be imposed. In addition to protesting the civil penalty in whole or in part, such answer may request remission or mitigation of the penalty. In requesting mitigation of the proposed penalty, the factors addressed in Section VI.B.2 of the Enforcement Policy should be addressed. Any written answer in accordance with 10 CFR 2.205 should be set forth separately from the statement or explanation in reply pursuant to 10 CFR 2.201, but may incorporate parts of the 10 CFR 2.201 reply by specific reference (e.g., citing page and paragraph numbers) to avoid repetition. The attention of the Licensee is directed to the other provisions of 10 CFR 2.205, regarding the procedure for imposing civil penalty. Upon failure to pay any civil penalty due that subsequently has been determined in accordance with the applicable provisions of 10 CFR 2.205, this matter may be referred to the Attorney General, and the penalty, unless compromised, remitted, or mitigated, may be collected by civil action pursuant to Section 234c of the Act, 42 U.S.C. 2282c. The response noted above (Reply to Notice of Violation, letter with payment of civil penalty, and Answer to a Notice of Violation) should be addressed to: James Lieberman, Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, One White Flint North, 11555 Rockville Pike, Rockville, MD 20852-2738, with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region I, and a copy to the NRC Senior Resident Inspector at the facility that is the subject of this Notice. 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. If redactions are required, a proprietary version containing brackets placed around the proprietary, privacy, and/or safeguards information should be submitted. In addition, a non-proprietary version with the information in the brackets redacted should be submitted to be placed in the PDR. Dated at King of Prussia, Pennsylvania |
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