IR 05000412/1987045

Insp Rept 50-412/87-45 on 870601-05.No Violations Observed. Major Areas Inspected:Preoperational Test Program,Including Reviews of Preoperational Test Repts,Status Review of Deficiencies & of Activities in QA Interface

ML20235S825
Person / Time
Site:	Beaver Valley
Issue date:	07/15/1987
From:	Dev M, Eselgroth P, Hunter J, Vankessel H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20235S803	List: IR 05000412/1987045 ML20235S800
References
50-412-87-45, NUDOCS 8707210790
Download: ML20235S825 (12)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No'. - 50-412/87-45 Docket No. 50-412 License N NPF-64'

Licensee: Duquesne Light Company P. O. Box 4 Shippingport, Pennsylvania 15077 Facility Name: Beaver Valley Unit No. 2

. Inspection At: Shippingport, Pennsylvania

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.InspectionConductp: June 1-5, 1987 f1 '

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Inspectors: G]h/ k M_dbd 7 #7 i F. vanKes el

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H eactor Engineer, DRS date As A Medan Dev, Reactor, Engineer, DRS

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-( e l T gn Hdirtei, Reactor Engineer, DRS '

bate Approved by: A 7 87 Peter EseTgropy, Chief, Test Program ' date

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Section, Op#ations Branch, DRS Inspection Summary: Inspection on June 1-5, 1987 (Inspection Report N /87-45)

Areas Inspected: Routine unannounced insp'ection of the Preoperational Test Program, including the review of preoperational test reports, the status review of Test Deficiencies, the review of activities in the QA interface, and the review of unresolved items identified by the inspector in previous

. inspections. The. inspector also reviewed the fuel oil system cleaning history of the Emergency Diesel Results: No violations were identifie NOTE: For acronyms not defined, refer to NUREG 0544, " Handbook of Acronyms and

'Initialisms",

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DETAILS 1.0 Persons Contacted Duquesne Light Company R. C. Callaway, Test Supervisor, Phase-2

• D. Claridge, Compliance Engineer

• N. Daugherty, Director Systems Testings J. Dusenberry, Assistant Director QA Surveillance

• J. Godleski, Senior Test Engineer

• J. Johns, Supervisor QA Surveillance J. Kasunick, Director Maintenance

• F. J. Lipchick, Sr. Licensing Supervisor

• T. Noonan, Assistant Plant Manager

• L. Rabenau, Lead Compliance Engineer J. Stark, Supervisor Flush / Hydro J. Starr, Supervisor Engineering Management Services

• R. Swiderski, Manager Nuclear Construction

• S. Verma, Assistant Director Phase-1 Testing

• J. Wolfe, Coordinator QC Committee

• T.G. Zyra, Director Site Test and Plant Performance U. S. Nuclear Regulatory Commission

• J. Beall, Senior Resident Inspector

• L. Prividy, Resident Inspector 2.0 Licensee's Action on Previously Identified NRC Concerns (Closed) Unresolved Item (50-412/86-41-02): Administrative program for the control of electrical modification BVPS-2 design changes and modifications are being conducted in accordance with Stone and Webster Procedure 2 BVM-186, Procedure for SWEC Interface with the DLC Operations Design Change Control Program. This procedure and other Stone and Webster procedures, such as 2BVM-56A, Configuration Control; 2BVM-87A, Management Plan for Project Quality for the Operational Phase of BVPS-2; and 2BVM-185, Procedure for Performing 10 CFR 50-59 Safety Evaluation are utilized by Stone and Webster when the licensee determines that the modifications will be performed by Stone and Webste In addition, the licensee has established Administrative Procedures UAP-2.2, Design Change Control; UAP-2.4, Safety Evaluation; and UAP-2.6, Design Concepts for conducting design changes and modifications activities at BVPS- Based on the review of these procedures, the licensee action is considered complete. This item is close (Closed) Unresolved Item (50-412/87-03-02): Review and approval of procedure _ . - _ _ _ _ -

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The licensee's proposed Technical Specifications Section 6.8.2 required I that the Onsite Safety Committee (OSC) will review all procedures which are established, implemented and maintained in accordance with Section 6.8.1. The earlier NRC inspection identified that these procedures were being reviewed by the plant review committee instead of OSC before forwarding them for the plant manager's approva The licensee indicated that the OSC had reviewed the PRC meeting minutes and recommendation for approval of the procedures to the plant manager, or an OSC quorum had attended such meetings which recommended the l approval of the procedures, prior to April 8, 1987. Currently, all I Technical Specifications related procedures and changes thereto are reviewed by the OSC and recommended to the plant manager, or his designee, for approva By Nuclear Operations Unit Memorandum NDISSI: 3122, dated j April 6, 1987, the licensee revised the facility procedures Review and Approval Authorizations, and established delegated alternates to the plant manage !

Based on the review of the licensee's documentation and verification of j the procedural implementation, the licensee action is considered complet This item is close '

l (Closed) Unresolved Item (50-412/87-15-01): BVPS-2 Station / Site Admin-istrative Procedures Updat The licensee has established, revised, and upgraded the majority of the  !

site Administrative Procedures to support Beaver Valley Power Station i Unit-2 activities. The remaining procedures are currently in the station review cycle for updat Review of the licensee's completed action and ongoing activities to complete Station Administrative Procedures for BVPS-2 operation indicated that the licensee action is adequate. This item is close '

(Closed) SDR-87-11; 10 CFR 50.55(e) Deportability: Copes-Vulcan Elec-trohydraulic Actuated Atmospheric Steam Dump Valve During initial setup and testing of a Copes-Vulcan E/H Model-300 Control Valve 2SV*PCV101A, the licensee discovered that the valve stem and inner plug were pulled apart and the roll pin sheared off due to excessive closing thrust provided by the Borg-Warner hydraulic operator. The failure of the valve stem / inner plug joint could have prevented the atmospheric steam dump valves from stroking due to the plug jamming in the bod The licensee initiated N&DR 29862 and contacted the vendor, Copes-Vulcan.

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The vendor redesigned the stem / inner plug threaded joint by increasing the L length of threaded engagement, and changed the material of construction to

! meet the maximum required thrust, during different operational condition The redesigned spare parts were obtained to modify control valve l

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2SV*PCV101A per E&DCR D-5145-501. The scope of this corrective action was extended to the other . Atmospheric Steam Dump Valves, 2SV*PCV1018,

'2SVS*PCV101C and 2SVS*HCV104 and similar modifications were made to these-

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The review of the licensee completed' work and associated documentation

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indicated that the licensee action was adequat This item is close (Closed) SDR-87.-12; 10 CFR 50.55(e) Deportability: No Control! R6om Indicating Light Provided for HVAC Test Switche This item pertains to test switches associated with BVPS-2 HVAC Circuits HVCAP, HVCBP, . CESAM and CESBM which could . cause the following equipment to be inoperative for certain evaluated test conditions. The system design did not include. indication of the non-operating status of the equipment in the control room,. and it was determined that failure of various safety" functions could go unnoticed by the control room operator .

(1) Control Room Air Supply Fans 2HVC*FN241-1A & IB (2) Control Room Air Intake Dampers 2HVC*M00201A & B (3) Contro1' Room Air Exhaust Dampers 2HV*M00201C & D The111censee initiated ACN D-0068 to remove the test switch contacts from the affected circuits without affecting equipment safety functio Review of the licensee's - documentation indicated ' that the licensee's corrective action to resolve the deficiency was adequate. This item i close (Closed) SDR 87-08; 10 CFR 50.55(e) Deportability: CIB-Initiated Timers-for Control Room Emergency Depressurization Fan This item pertains to the significant design deficiency identified in the control circuitry design of the control room emergency depressurization fan timer The timers required uninterruptable power to prevent resetting on a loss of offsite power subsequent to a containment isolation Phase B signal. The licensee verified that these timers were powered from an emergency AC distribution panel, fed from an emergency MCC. Loss of power to the distribution panel and MCC would cause the timer to reset to the beginning of the timing cycle- and would not begin its cycle until power had been restored to the emergency AC buse This could have prevented the fans from starting 60 minutes after containment isolation ,

Phase B initiatio The licensee. reported this to the NRC as a significant deficiency in accordance with the requirements of 10 CFR 50.55(e). Subsequently, the licensee analyzed the safety implication of this deficiency and concluded that loss of offsite power coincident with any postulated event was identified in the FSAR. Within this design basis, the emergency diesel generators start either on a safety injection signal, or a loss of preferred power to the emergency buses, thereby providing a backup power source to safety-related loads. Accordingly, the original design provided

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adequate assurance for the safety function 'of the timer However, the-licensee initiated "an E&DCR D-5169-506 and modified the timer's ' control circuitry _ to be supplied .from an uninterruptible DC power source to enhance system reliabilit This design change, modification' installa-tion,. and the retest were completed during May 1987 In' the final report letter, 2NRC-7-145, dated May 28,1987, .the licensee substantiated that'

y the' condition, reported initially as a 10 CFR 50.55(e) condition, was evaluated to be "not reportable".

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The adequacy of the licensee's disposition was verified by review of the l

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design change and modification documentation and physical verification of certain aspects of . the completed wor It was determined that th licensee' action was complete. This item is close .(Closed) 50-412/87-03-01 Completion of Implementing Procedures for' the

' Design Change Progra ,

The licensee's program for design changes, _ consisting of approved . and l draft procedures, was reviewed in Inspection Report 50-412/87-22. and it was determined that adequate measures had been established to control the -

design change and modification program. The item, however, remained open pending NRC review of the final approved procedures, SAP-45, UAp 2.2, 2BVM-186, 2BVM-189 and 2BVM-191 that were reviewed in draft for The inspector reviewed the final approved ' versions of SAP-45, UAP 2.2, 2BVM-186, 2BVM-189.and 2BVM-191 and determined, based on the review, that the approved procedures are adequate to implement the design change and modification program in accordance with the licensee's commitments and the NRC requirements. This item is close (0 pen) Unresolved Item (86-38-01), " Emergency Diesel Generator Discrepancies" The review of the test results for the Phase-1 tests of Emergency Diesel Generators, EDG2-1 and 2-2, identified 6 open items as listed in Inspection Report No. 50-412/86-11, Section Five of these open items have been addressed by the license References Inspection Report 50-412/87-38, for inspection completed. on May 20, 198 . Letter from Pittsburgh Applied Research Corporation to Duquesne

. Light Company,' dated May 26, 1987 Further information (ref. 2) was received from the laboratory which analysed the samples as identified in their first report (see ref. 1).

The new information of reference 2 stil) does not clarify how much carbon had been found in the samples of the oil strainer deposits and how much t __ ._ - _ _______ _ _________________

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carbon ~ was expected to be found on . account of ' the known presence of Tectyl. The basic question is whether the experienced excessive delta P on the twin lube . oil strainers, as found during the EDG test runs, i caused by the plating out of the lube oil system preservatives (Tectyl)

only or by the deposit of other contaminants such as carbo Tectyl, 'a lube oil system preservative, is expected to dissolve in the

. lube oil during initial EDG operation when the lube oil heats up above room temperatur This' Tectyl will plate out on the . lube oil strainer after the lube oil has been cooled in the oil cooler upstream o? the oil strainer. It is- a one time occurrence. The second contaminant, carbon, may come from sources other than the Tectyl such as from poor combustion of the fuel oil in the engine's cylinders. This type of lube oil contami-nation is not normally anticipated in a new diesel engine but if this is the case here then such contamination may not be a one time occurrence but could repeat :itself in the future when the same combustion conditions re-occu The licensee again will try to obtain the sample analysis to determine what is causing the strainer differential pressure increas .0 Preoperational Test Program 3.1 Preoperational Test Result Evaluation Scope The Test Result Reports (TRRs) for the test procedures listed in Attachment A were reviewed to verify that adequate testing was

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accomplished in order to satisfy regulatory guidance and licensee commitments and to ascertain that uniform criteria were being applied for evaluating completed preoperational tests to assure their technical and administrative adequac Discussion The TRRs were reviewed for the attributes listed in Inspection Report 50-412/87-19. Each TRR was reviewed together with the file containing the completed original of the procedure and the correspondence associa+ed with completed work and retesting for identified test deficiencie All of the reports (TRRs) of Attachment A appeared to be complete and were arranged in a logical format in accordance with SUM requirements. No unacceptable conditions were noted in any of these report Findings No violations or deviations were noted by the inspector within the scope of this revie . - __

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3.2 -Test Deficiencies:

Scope L' The TRRs discussed under paragraph 3.1 above were reviewed for test deficiencies. (TDs) and the corrective action planned or taken by the licensee ~ to resolve. them. Open TDs, including retests, were added -

to the list of all open TDs with safety significance. as prepared by the inspector during this inspection perio The test deferral letter (see ref.1), as prepared by the licensee for all preoperational tests which were to be completed prior to core loading, was reviewed by the inspector against the FSAR requirement ~

Reference Letter 2NRC-7-143- from Duquesne Light to the U.S. Nuclear Regulatory Commission, "BVPS N o'. 2, Plant Readiness for Fuel Loading", dated May 25, 198 Discussion' I None of. the TRRs reviewed ' during this inspection period show the - ;

need for retests or have open test. deficiencies (TDs). All of the !

TDs:: were . reviewed for. adequacy of the corrective actio All of these corrective actions were acceptabl The test deferral letter (ref. 1) was reviewed against the FSAR requirements for preoperational test- completion and the acceptability of the new schedule for each test completion and/or retes Test completions and retests were found to be rescheduled based on the used for 'the system in operable status for the various operational ' modes' of the startup phase as guided by the Technical Specification It was found that the questions raised by the inspector during the preparation of reference 1 had been addressed adequately by the license The inspector has no further questions on the test deferral lette .

The inspector will continue to follow the completion of tests and l the performance of retests for the preoperational test progra Findings l No unacceptable conditions were found by the inspector within the scope of this inspectio '

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t 4.0 Independent Inspection Effort Scope l The adeq' u acy of the flushing and ~ cleaning performed under phase 1. of the preoperational test program for the fuel oil . system of the diesel engines of the' Emergency Diesel Generator (EDG) sets (2).was reviewe References Proc. No. 2T-EGF-36B-1-01B, " Diesel Gen. ' Fuel 011", Revision 1, ' test completed on; December 10, 1985, approved by Director-SOV Test Section on January 13, 1987 (applies to EDG2-2). Proc. No. 2T-EGF-368-1-01G, " Diesel Gen. ' Fuel Oil", . Revision 0, ' test completed : March 25,- 1986, approved by Director Construction Proof Test Section on September 20, 1986 (applies to EDG 2-2). Proc. No. 2T-EGF-368-1-01F, " Diesel Gen. Fuel Oil",-Revision 1, test-completed March 14, 1986, approved by Director - Construction Proof Testing.Section on April-11, 1986 (applies to EDG 2-1). Proc. No. 2T-EGF-368-1-01E, " Diesel Gen. Fuel 011", Revision 0,e test completed on Novembe'r 14, 1985, reviewed by Flush Program Supervisor on November 18, 1985 (applies to injector cleaning for 24 injectors for units EDG 2-1 and'2). Proc. No. 2T-EGF-36B-1-010, " Diesel Gen. Fuel Oil", Revision 1, test completed on December 5,1985, approved by Director S0V Test Section on January 13,'1986 (applies to EDG 2-1). Proc. No. 2T-EGF-36B-1-01C, " Diesel Gen. Fuel Oil", Revision 0, test completed on November 20, 1985, ' no approvals (applies to EDG 2-2). j . Proc. No. 2T-EGF-36B-1-01A, " Diesel Gen. Fuel 011", Revision 0, test completed on November 20, 1985, no approvals (applies to EDG 2-1). Cleanliness Verification Form (CVF) Report No. 9544. Applic. Dw No. 2003.280.054-035, dated September 4,1985, pre-Turnover, Class C for cleanness (applies to 2EGF-TK21B). Cleanliness Verification Form (CVF) Report No. 9545. Applic. Dw No. 2003.280.054-035,- dated September 4,1985, Pre-Turnover, Class C for cleanness (applies to 2EGF-TK21A).

Discussion All of the available phase-1 flushing and cleaning reports pertaining to the fuel oil systems of EDG 2-1 and 2 (ref. 1-9) were collected and i reviewe The following observations were made: mesh strainers were used in the flushing circuits of the flushing tests. This strainer would retain particles greater than 74 microns.

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' In two' instances (see ref. I and 5) the flushing. circuit '(flow path)

included the fuel oil filters. Normally the , filter cartridges and internals are removed during flushing. . There was . no record that .

these filter internals were removed prior to the flushin These

. filters will. catch particles greater than.3-5 micron,

_ Class- C acceptance criteria were specified in the procedures (ref.1-8) for the flushing. -These criteria. apply to water system . .The. fuel oil storage tanks were accepted ~ from ' Construction via a-cleanliness verification inspection as recorded on a cleanliness verification form (CVF) (ref. 8 and 9). This was a " white glove" type visual 1nspection.

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The CVF Reports for the two storage tanks 2 EGF-TK21 A and B were available. The CVF reports for the two day tanks were not available.

. The . North and South fuel oil supply headers of the two EDGs were l

hydrolased separate from the . system. Attention was paid to the drying of the headers after the flushin There was,- however, . no record for the cleaning of the 12 individual supply lines from the fuel header to the fuel injector . Flushing of the systems would be stopped after the 200 mesh strainer would no longer contain particles larger than 1/32 inch (in the major dimension). .The. fuel oil filter, howevert will' retain particles larger than 3-5 micron This raises the question how

.long it would take to remove all the ~ remaining ~ dirt particles

.between 5 and 74 microns with normal fuel oil flow velocities in the system, during normal operatio . After review of all available flushing aid cleaning documentation it became apparent that the documentation .for the two day tanks and the piping between the headers and the fuel injectors was missin The above observations contain the following questions which need to be answered: Since the fuel oil filter itself has a 3-5 micron particle size capability, and the 200 mesh screen can only remove 74 micron particles, is the 200 mesh strainer an adequate means to establish the desired cleanliness of the fuel oil going to the engiae? How long would it take to clean the accepted system (74 micron) to the 5 micron level? Would not the 5 micron filter clog rather rapidly? What occurs when the filter cartridges of the twin filters are expended? Were the filter cartridges removed during the tests of ref.1 and 5?

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'r 10 What isLthe basis for using.the acceptance criteria of a water system;

.in an oil system? Is not water a contaminant in an oil system? WhatJ

' oes d class "C" stand for in~an oil 1 system? Where are'the CVF reports for.the.two' day _ tank's?-

. Where~ are . the cleaning ' reports for the .12 individual supply line ~from the fuel header to the. fuel injector The inspector will. pursue' answers to these questions in- a > future inspection under Unresolved Item 50-412/87-4 Findings No violations or deviations were observe .0 QA/QC Interface

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The participation of the. Duquesne Light _ QA Surveillance . Group ' in - the preoperational test program was evaluated by: the inspector. A number of-

. surveillance checklists and Surveillance Deficiency Reports (SDRs) were reviewed for. adherence to the requirements of the Startup Manua Discussion SDR-1 of Surveillance No, MIS-01-87 " deals with a housekeeping problem. ' salt shaker and spilled salt were found on 1the motor housing for pump .

2 SIS *P21B, -In addition metal filings, probably from grinding operation .!

were found ~ near 'the same pum Metal filings and salt were remove l promptly by constructio The response to this SDR was evaluated and '

discussed. The SDR was closed on May 29, 198 In SDR-1'of S0V-74BH-87, a jumper was used for starting the Aux. Boiler in apparent violation of the control for' Temporary Jumpers and Lifted Leads in SUM 3.4.14. The-jumper was not recorded -in this -log nor was it a part of an approved procedure. No response has been received to date by QA.

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A copy of the surveillance checklist for the second test of the Electrical Independence -Test, P0-2-36A-02, was reviewed. No unacceptable conditions were noted during this test by.the QA Enginee Findings I The inspector has no questions on the QA documents within the Scope  :

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Unresolved items are matters about which more information is required 'in order to determine whether they are acceptable, an item of noncompliance, or a deviatio New unresolved items in this report are identified in -

paragraph 4, 7.0 Exit Intervie At the conclusion of the site inspection, on June 5, 1987, an exit interview was . conducted with the licensee's senior site representatives (denoted in Section 1). The findings were identified and previous inspection items were discusse At no time during this inspection was written material provided to the licensee by the inspector. Based on the NRC Region I review of this report and discussions held with licensee representatives during this i inspection, it was determined that this report does not contain information subject to 10 CFR 2.790 restriction l

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ATTACHMENT A l to IR 50-412/87-45 Test Results Evaluation

Approval Date l Proc. N Title Rev. N TRR by JTG P0-2.02.01 Nuclear Instrumentation System 0 4-3-87 P0-2.06.03 Reactor Coolant Pump Seal Water 0 4-24-87 Injection Test PO-2.07.01 Charging Pumps and Controls Test 0 4-24-87 P0-2.15A.01 Primary Component Cooling Pumps 0 5-16-87 PO-2.26B.01 Turbine Runback Control System 0 5-11-87 Test P0-2,06.02 Reactor Coolant Pump Initial 0 5-15-87 Performance PO-2.06.10 Pressurizer Containment Spray, 0 6-4-87 Section B PO-2.07.03 CVCS, Section C 0 4-24-87 PO-2.24B 01 Motor Driven Auxiliary Feedwater 0 6-4-87 Pumps and Controls

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