ML20082M329
| ML20082M329 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 08/26/1991 |
| From: | Sieber J DUQUESNE LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9109050146 | |
| Download: ML20082M329 (3) | |
Text
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U. S. Nuclear Regulatory Commission Attn:
Document Control Desk Washington, DC 20555
Subject:
Boavor Valloy Power Station, Unit No. 1 and No. 2 BV-1 Docket No. 50-334, Licenso No. DPR-66 BV-2 Docket No. 50-412, Licenso No. NPF-73 Combined Inspection Report 50-334/91-14 and 50-412/91-14 In response to NRC correspondence dated July 29, 1991 and in accordance with 10 CFR 2.201, the attached reply addresses the Notice of Violation transmitted with the referenced inspection report.
If there are any questions concerning this response, please contact Mr.
F.
D. Schuster at (412) 393-5111.
Sincerely, d.
D. Sieber jpVice President Nuclear Group Attachment cc:
Mr. J.
Beall, Sr. Resident Inspector Mr. T.
T. Martin, NRC Region I Administrator Mr.
C. W. Honi, Director, Division of Reactor Projects Mr.
E. C. Wenzinger, Chief, Reactor Projects Branch No.
4, Division of Reactor Projects, Region I Mr. A. W. DeAgazio, Project Manager Mr. M.
L. Bowling (VEPCO)
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1 DUQUESNE LIGHT COMPANY Nuclear Group r
Boavor Valloy Power Station Unita 1 and 2 l
Repiv to Notico of Violation i
Combined NRc Inspection 50-334/91-14 and 50-412/91-14 Lotter dated July 29, 1991 L
Violatipn (Severity Lovel IV, Supplomont I-D) i Description of Violation (50-412/91-14-03)
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Technical Specification 6.8.1.C requires that written proceduros be established, implemented and maintained covering surveillanco and test activities of safety related equipment.
Contrary to the above, survoi)1anco proceduros woro not established to cover operation of both Unit 2
diosol generators with the i
following safoty related components:
i 1)
Valvo 2 EGO-115, strainer 2 EGO *STR24A, and valve 2 EGO-117 which constituted the alternato lubo oil flow path for the 2-1 EDG.
j 2)
Valvo 2 EGO-114, strainer 2 EGO *STR24D, and valvo 2 EGO-116 which constituted the alternato lubo oil flow path for the 2-2 EDG.
Reason for Violation During extended Emergency Diosol Generator (EDG) operation, the alternato lubo oil strainor-may be placed in service if the main lubo oil strainer becor' clogged and exhibits high differential
[
pressure.
The alte r nato strainer was added to the EDG during the
~
1ater stages of pre-operational acceptance testing as a result of the i
main strainer developing a high differential pressure.
The alternato strainer. providos the ability to perform maintenance on the main strainer without shutting down the EDG.
When the EDG is tested, the support systems such as cooling water, air
- start, fuel oil, and lubricating oil are tested with the unit in i
normal system arrangement.
The alternato lubo oil strainers were r
considered to be in a functional standby condition but isolated and not routinely ve.lved-in.
The alternato strainers were periodically maintained through I
l performance of an 18 month proventative maintenanco procedure which
- isolated, inspected, and cleaned the strainer.
Following this
- cleaning, the strainer remained isolated and clean in a standby configuration.
This practico was considered adequato.
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deply to Notico of Violation (50-412/91-14-03)
Page 2 Corrective Stens Taken and Results Achieved The monthly Operating Surveillance Tests (OST) for the EDGs were revised on a
one time basis to allow operation of the EDG with the alternato lubo oil strainer in service in place of the main lube oil strainer.
On June 20, 1991, and on July 11, 1991, EDG 2-2 and EDG 2-1, respectively, were tested with the lube oil flow path aligned to the alternate strainer.
The OST stroked all valves through one omplete cycle.
Lubo oil flow was established through the strainers und all valves were fully stroked resulting in all components functioning as expected.
Corrective Stens to Avoid Further Violations The valve stroke test, OST 2.47.3A, will be revised to exerciso the inlet and outlet isolation valves for the alternate lubo oil strainers, 2 EGO-114,
-115,
-116 and -117, and the isolation valves for the main lube oil strainers, 2 EGO-106, -107
-108 and -109 on a quarterly frequency.
Those valves will also be added to the BV-2 IST program = as Category B valves.
As such, they will be required to be exercised quarterly and to have appropriate corrective action taken if they fail to exhibit the required change of valvo stem or disk position.
Preventative Maintenance Procedure 2-36EGS-EG2-1+2-1M will be revised to ensure that the alternate lube oil strainers are properly filled and vented prior to placing them in service and will be upgraded to a Maintenance Survoillance Procedure (MSP) to be performed on a
refueling frequency.
In
- addition, the MSP will valve in the alternate strainer with the EDG running on a refueling frequency to demonstrate that the strainer will operate from an on-demand condition.
Date When Full Comn13ance Will Be Achieved The quarterly valve stroke
- test, OST 2.47.3A, will be revised to include the alternate and main lube oil strainer isolation valves before the next performance of the OST scheduled for September 30, 1991.
The alternate and main lube oil strainer isolation valves will be i
included in the next revision of the BV-2 IST Program document which is scheduled to occur by December 31, 1991.
PMP 2-36EGS-EG2-1-2-1M will be revised by the BV-2 third refueling outage presently scheduled to begin March 13, 1992.
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