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HomeNRC LibraryDocument CollectionsGeneric CommunicationsInformation Notices1979

# Information Notice No.79-34 - Inadequate Design of Safety-Related Heat Exchangers

```
                              UNITED STATES                SSINS No.: 6870 
                       NUCLEAR REGULATORY COMMISSION        Accession No:  
                   OFFICE OF INSPECTION AND ENFORCEMENT     7910250517     
                          WASHINGTON, D.C. 20555

                             December 27, 1979

                                            Information Notice No. 79-34

INADEQUATE DESIGN OF SAFETY-RELATED HEAT EXCHANGERS

Tennessee Valley Authority (TVA) submitted an initial 50.55(e) report on 
October 25, 1979, that identified defects in the four Containment Spray (CS)
heat exchangers at the Sequoyah facility. 

The heat exchanger tube bundles were damaged by excessive vibrations of the 
tubes against each other. These vibrations were caused by a support 
arrangement that allows excessive unsupported tube lengths. The large 
amplitude tube vibration has resulted in reductions in wall thickness and 
some tube leakage. The CS heat exchangers at Sequoyah had only been in 
operation for a short period of time prior to the failure being detected. 

These heat exchangers were manufactured by Industrial Process Engineers, 
Inc., (IPE), a vendor now out of business. The Component Cooling Water (CCW)
heat exchangers at the Sequoyah facility were also made by IPE. TVA has 
identified some reduction in wall thickness and minor tube leakage in the 
CCW heat exchangers. The licensee plans to plug the damaged tubes on the CS 
heat exchangers and "stake" (support) the tube bundles to prevent further 
damage. Further corrective action is under review by the licensee. The 
following data applies to the CS heat exchangers: 

     Manufacturer:  Industrial Process Engineers, Inc.
     Type:          CFU (Special)
     Size:          55-342
     Serials:       6662-1; 6662-2
                    6663-1; 6663-2

This Information Notice is provided as an early notification of a possibly 
significant matter that is still under review by the NRC staff. It is 
expected that recipients will review the information for possible 
applicability to their facilities. No specific action or response is 
requested at this time. If NRC evaluations so indicate, further licensee 
actions may be requested or required. 

No written response to this Information Notice is required. If you have any 
questions regarding this matter please contact the Director of the 
appropriate NRC Regional Office. 
.

                              UNITED STATES 
                       NUCLEAR REGULATORY COMMISSION
                          WASHINGTON, D.C. 20555

Docket No. 50-334

Duquesne Light Company
ATTN:Mr. Stanley G. Schaeffer
     President
435 Sixth Avenue
Pittsburgh, Pennsylvania 15219

Gentlemen:

On November 27, 1979, the Beaver Valley Power Station, Unit 1, was operated 
for about two (2) hours in a condition which exceeded the Limiting condition
for Operation. 

This matter was brought to the attention of our inspector at your facility 
in a timely fashion, and your subsequent action to correct the condition was
expeditious. Nevertheless, this condition rendered a part of the emergency 
core cooling system (ECCS) unavailable for automatic start and injection of 
coolant into the reactor coolant system (RCS) if the need had occurred 
concurrent with the loss of offsite power (the design basis). This 
unavailability of ECCS constitutes a serious matter which reveals an 
apparent weakness in your control of maintenance and essential equipment. 
Therefore, we propose to impose a civil penalty for the item of 
noncompliance set forth in Appendix A to this letter in the amount of 
$5,000. Appendix B is a Notice of Proposed Imposition of Civil Penalties. 
You are required to respond to this letter and preparing your response, you 
should follow the instructions in Appendices A and B. 

In addition to the civil penalty, we are issuing the enclosed Order 
(Appendix C) effective immediately. This Order requires that your 
administrative control of licensed activities involving operating and 
maintenance of safety equipment verifies availability of all required 
equipment when a counterpart is removed from an operable status. This Order 
further requires that you formally review and report your actions to prevent 
recurrence. It also requires that you meet publicly on January 25, 1980, 
with the Director, Office of Inspection and Enforcement, at a location near 
the Beaver Valley Power Station, to discuss your evaluation of this 
condition and your corrective actions to prevent recurrence. We will inform 
you of the location and time of the meeting. 

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 
enclosures 
.

Duquesne Light Company            - 2 -                                   

will be placed in the Commission's Public Document Room. 

                                        Sincerely,

                                        Victor Stello, Jr.
                                        Director
                                        Office of Inspection
                                          and Enforcement

Enclosures:
1.   Appendix A, Notice of Violation
2.   Appendix B, Notice of Proposed
       Imposition of Civil Penalties
3.   Appendix C, Order Modifying License

cc:  C. N. Dunn, Vice President, Operations Division 
     F. Bissert, Technical Assistant Nuclear
     R. Washabaugh, QA Manager
     J. Werling, Station Superintendent
     G. Moore, General Superintendent
     J. J. Carey, Nuclear Technical Assistant
     R. Martin, Nuclear Engineer
.

                               APPENDIX A                                 

                            NOTICE OF VIOLATION

Duquesne Light Company                                   Docket No. 50-334 
Pittsburgh, Pennsylvania 15219                           License No. DPR-66

This refers to the inspection conducted by the NRC Resident Inspector at the
Beaver Valley Power Station, Unit 1, of activities authorized by NRC License
No. DPR-66. 

During the inspection conducted on November 27, 1979, the following item of 
noncompliance was identified. 

Technical Specification 3.5.2 states that with the plant in Mode 1 (Power 
Operation), two separate and independent ECCS subsystems shall be operable, 
and further states in section 3.5.2.c that each subsystem shall include an 
operable flow path capable of taking suction form the refueling water 
storage tank upon initiation of a safety injection signal. 

Technical Specification 1.6 defines "operable" to include the assumption 
that all necessary attendant instrumentation, controls, electric power, 
cooling or seal water, lubrication or other auxiliary equipment that are 
required for the system, subsystem, train, component or device to perform 
its function(s) are also capable of performing their related safety 
function(s). 

Contrary to the above, on November 27, 1979, from approximately 8:30 a.m. to
10:30 a.m., maintenance activities rendered both ECCS subsystems inoperable 
in that a) refueling water storage tank isolation valve MOV-CH-115D was 
closed and  incapable of automatic opening in response to a safety injection
signal, and b) refueling water storage tank isolation valve MOV-CH-115B, in 
the redundant subsystem, was closed, had no emergency power available, and 
thus was incapable of automatic opening in response to a safety injection 
signal if there had been a condition of loss of offsite power. 

This violation had the potential for causing or contributing to an 
occurrence related to health and safety (Civil Penalty $5,000). 
.

                               APPENDIX B                                 

             NOTICE OF PROPOSED IMPOSITION OF CIVIL PENALTIES

Duquesne Light Company                                   Docket No. 50-334  
Pittsburgh, Pennsylvania 15219                           License No. DPR-66

The office has considered the enforcement options available to the NRC 
including administrative actions in the form of written notices of 
violation, civil monetary penalties, and orders pertaining to the 
modification, suspension or revocation of a license. Based on these 
considerations, we propose to impose civil penalties pursuant to Section 234 
of the Atomic Energy Act of 1954, as amended, (42 USC 2282), and to 10 CFR 
2.205 in the cumulative amount of Five Thousand Dollars ($5,00) for the 
specific items of noncompliance set forth in Appendix A to the cover letter. 
In proposing to impose civil penalties, the factors identified in the 
Statements of Consideration published in the Federal Register with the 
rule-making action which adopted 10 CFR 2.205 (36 FR 16894) August 26, 1971, 
and the "Criteria for Determining Enforcement 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 this 
notice pay the civil penalties in the cumulative amount of Five Thousand 
Dollars ($5,000) or may protest the imposition of the civil penalties in 
whole or in part by a written answer. Should Duquesne Light Company fail to 
answer within the time specified, this office will issue an order imposing 
the civil penalties in the amount proposed above. Should Duquesne Light 
Company elect to file an answer protesting the civil penalties, such an 
answer may (a) deny the items of noncompliance listed in the Notice of 
Violation in whole or in part, (b) demonstrate extenuating circumstances, 
(c) show error in the Notice of Violation, (d) show other reasons why the 
penalties should not be imposed. In addition to protesting the civil 
penalties in whole or in part , such answer may request remission or 
mitigation of the penalties. 

Any written answer in accordance with 10 CFR 2.205 should be set forth 
separately from the statement or explanation in reply pursuant to 2.201, but
may 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 of 10
CFR 2.205 regarding, in particular, failure to answer and ensuing orders; 
answer, consideration by this office, and ensuing orders; requests for 
hearings, and ensuing orders; compromise, and collection. 

Upon failure to pay any civil penalty due which has been subsequently 
determined in accordance with the applicable provisions of 10 CFR 2.205, the
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 234.c of the Atomic Energy Act of 1954, as amended (42 
USC 2282). 
.

                               APPENDIX C

                         UNTIED STATES OF AMERICA
                      NUCLEAR REGULATORY COMMISSION 

In the Matter of                      )
                                      )
DUQUESNE LIGHT COMPANY                )                   Docket No. 50-334
(Beaver Valley Power Station, Unit 1) )

                          ORDER MODIFYING LICENSE
                           EFFECTIVE IMMEDIATELY

                                     I

The Duquesne Light Company (the "licensee") is the holder of Operating 
License DPR-66 (the "license") which authorizes operation of the Beaver 
Valley Power Station, Unit 1, at steady state reactor core power levels not 
in excess of 2652 megawatts thermal (rated power). The license was issued on
January 30, 1976. The facility consists of a pressurized light water 
moderated and cooled reactor (PWR), located at the licensee's site in Beaver
County, Pennsylvania, on the southern shore of the Ohio River. 

                                    II

On November 27, 1979, from about 6:30 AM to  1:20 PM while the reactor was 
operating at about 30% of rated power, Emergency Diesel Generator (EDG) 1 
was out of service for routine maintenance. This EDG supplies emergency 
power to suction valve, NOV-CH-115B, in the line from the refueling water 
storage tank (RWST) to the High Pressure Safety Injection System (HPSIS) 
pumps. In addition to the EDG being out of service, resulting in loss of one 
Emergency Core Cooling System (ECCS) flow path, as described above, the 
redundant suction valve , MOv-CH-115D, was removed from service for 
maintenance which resulted in loss 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 Limiting Condition for Operation specified in 
Technical Specification 3.5.2.c. This condition resulted from inadequate 
control maintenance control of maintenance activities and its 
.

Appendix C                        - 2 -

occurrence suggests that the licensee has not adopted appropriate controls 
to assure that maintenance activities do no defeat required safety features.
This in turn undermines the basis for determining that there is reasonable 
assurance that redundant safety features will function under design basis 
conditions. In view of the significance to safety of adequate controls to 
assure that maintenance activities do not defeat required safety features, I 
have determined that the public health, safety, or interest requires, 
effective immediately, modification of License No. DPR-66 as stated in Part 
III of this Order. 

                                    III

Accordingly, pursuant to the Atomic Energy Act of 1954, as amended, and the 
Commission's regulations in 10 CFR Parts 2 and 50, License DPR-66 is 
modified as follows: 

(1)  Administrative Procedures shall be adopted and implemented to require 
     redundant independent verification of the operability of the remaining 
     engineered safety features whenever any safety system, or subpart 
     thereof, is intentionally removed from service. 

(2)  A detailed review of existing procedures and controls shall be 
     performed to assure that limiting conditions for operations are not 
     defeated by maintenance or other activities. 

(3)  A report of the administrative procedures required by paragraph (1) 
     above and the detailed review required by paragraph (2) above shall be 
     submitted by January 11, 1980, to the Director of NRC's Region I 
     office. 
.

Appendix C                       - 3 - 

(4)  The licensee shall meet with the Director, Office of Inspection and 
     Enforcement, on or before January 25, 1980, in a meeting open to the 
     public in the vicinity of the Beaver Valley site to describe how the 
     above requirements will be implemented. The Director, Region I, will 
     inform the licensee at least one week in advance of the specific time 
     and location of the meeting. 

                                    IV

The licensee, or any other person who has an interest affected by the Order,
may, within twenty-five days of the date of this Order, request a hearing. A 
request for a hearing shall be addressed to the Director, Office of 
Inspection and Enforcement, U.S.N.R.C., Washington, D.C. 20555. If a hearing
is requested by the licensee or an interested person, the Commission will 
issue and Order designating the time and place of hearing. Such a request 
for hearing SHALL NOT STAY THE IMMEDIATE EFFECTIVENESS OF THIS ORDER. 

Resumption of operation on terms consistent with this Order is not stayed by
the pendency  of any proceeding on this Order. In the event that a need for 
further enforcement action becomes apparent, either in the course of any 
proceeding on this Order or at any other timer, the Director will take 
appropriate  action. 

                                     V

In the event the licensee or any other interested person requests a hearing 
as provided above and a hearing is held, the issues to be considered at such
a hearing 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 COMMISSION


                                        Victor Stello, Jr.
                                        Director
                                        Office of Inspection and
                                          Enforcement

Dated at Bethesda, Maryland
this 5th day of December, 1979.
```

*Page Last Reviewed/Updated Friday, May 22, 2015*

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