ML20087A096
| ML20087A096 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 02/14/1984 |
| From: | Carey J DUQUESNE LIGHT CO. |
| To: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20087A094 | List: |
| References | |
| NUDOCS 8403070344 | |
| Download: ML20087A096 (4) | |
Text
.
o
'A@
Telephone (412) 393-6000 P.O. B x Shippingport, PA 15077-0004 February 14, 1984 ynited States Nuclear Regulatory Commission
.' Office of Inspection and Enforcement Attn: Mr. Richard W. Starostecki, Director Division of Project and Resident Programs Region I 631 Park Avenue King of Prussia, PA 19406
Reference:
Beaver Valley Power Station, Unit No.1 Docket No. 50-334, License No. DPR-66 IE Inspection Report No. 83-29 Gentlemen:
In response to your letter of January 16, 1984, and in accordance with 10 CFR 2.201, the attached reply addresses the Notice of Violation which was included as Appendix A with the refcrenced Inspection Report.
If you have any question concerning this response, please contact my office.
Very tru y yours,
. J. Car Vice Presi..cnt, Nuclear Attachment cc: Mr. W. M. Troskoski, Resident Inspector
- 11. S. Nuclear Regulatory Commission Beaver Valley Power Station Shippingport, PA 15077 U. S. Nuclear Regulatory Commission c/o Document Managment Branch Washington, DC 20555 Director, Safety Evaluation & Control Virginia Electric a Power Company P.O. Box 26666 One James River Plaza Richmond, VA 23261 8403070344 840228 PDR ADOCK 05000334 G
1
?
DUQUESNE LIGHT COMPANY Beaver Valley Power Station Unit No. 1 Reply to Notice of Violation l
Inspection 83-29 Letter dated January 16, 1984 VIOLATION A (Severity Level IV:
Supplement I)
Description of Violation (83-29-02)
Technical Specification 6.8.1 requires the establishment, implementation, and maintenance of written procedures that cover surveillance and testing of safety-related equipment. Technical Specification 4.0.5 requires
(
inservice inspection and testing of ASME Code Class 1, 2, and 3 components I
at the surveillance intervals specified in Section XI of the ASME Boiler and Pressure Vessel Code and applicable addenda, except where specific relief has been granted by the Commission pursuant to 10 CFR 50, Section 50.55a(g)(6)(1).
Subsection IWV-3400, Inservice Inspection, Category A, Category B Valves, of the ASME Code, requires each valve to be exercised once per three months.
By letter dated March 17, 1980, Duquesne Light Company submitted a proposed inservice-testing program description with request for relief from testing requirements for the Category B component cooling water to reactor coolant pump (RCP) trip valves (TV-CC-107 A, B, C). The safety evaluation of the Office of Nuclear Reactor Regulation, dated June 29, 1982, granted specific relief fran the three month full stroke exercise, provided testing is conducted during any cold shutdown that the RCPs are secured and at least once each refueling outage.
Contrary to the above, OST 1.1.10, Cold Shutdown Valve Exercise Test, Revi-sion 46, established to conduct ASME Section XI valve testing, did not in-clude a full stroke exercise of valves TV-CC-107 A, B, C, nor_ was such testing performed duri-g the third refueling outage (June thru September, 1983).
Corrective Action Taken Valves TV-CC-107A, B and C were added to the valve table to be stroke tested in OST 1.1.10 in Revision 47 which was effective on December 14, 1983.
Action Taken to Prevent Recurrence To ensure that this event will not recur,' the OSTs and the Inservice Testing (IST) Program were compared against each other.
During this -
review, it was discovered 'that valves RS-100 and RS-101 were not included in OST 1.1.10 as stated 'in the IST Program. These valves were stroked, however, as part of the " Containment Isolation Check Valve Test" BVT 1.3-1.47.5, Revision 47 to OST'l.l.10 also includes RS-100 and RS-101. No other discrepancies were found.
Date on Which Full Compliance Will Be Achieved Full compliance has been achieved at this time.
j l
1
~
__a
B
[-
Reply to Notice of Violation Inspection 83-29 Letter dated January 16, 1984 Page 2 VIOLATION B (Severity Level IV; Supplement I)
Description of Violation (83-29-04)
Technical Specification 6.8.1 requires the establishment, implementation, and maintenance of written procedures that cover surveillance and testing of safety-related equipment.
ANSI N18.7-1972, Administrative Controls For Nuclear Power Plants, endorsed by Appendix A, Quality Assurance, of the BVPS Unit 1 Updated Final Safety Analysis Report, requires that surveil-lance and test procedures contain limiting conditions and prerequisites for performing the tests.
Contrary to the above, Maintenance Surveillance Procedures (MSP 36.41 thru 36.56), used to perfonn Technical Specification 3.3.2.1 required channel functional testing and calibration of the Engineered Safety Feature (ESF)
Actuation System - Loss of Power Instrumentation Relays, did not:
Contain or identify the limiting conditions that apply during the performance of relay testing as contained in the Technical Specifi-cations, Table 3.3-3, Section 6.
Provide instructions to implement such Technical Specification limiting conditions by placing the appropriate channel in the tripped condition, or take other actions for the specific relay as specified in the Technical Specification.
Corrective Action Taken Procedures for testing and calibration of relays providing grid degraded voltage protection have been revised to remove only one of the two series relays at a time and to immediately jumper in the trip at the time the relay is removed. This approach eliminates concern for fulfilling the requirements of action statement 34 in the one-hour time limit and maintains degraded voltage protection during the test / calibration. These changes affect the following procedures: MSPs 36.41, 36.42, 36.43, 36.44, 36.51 and 36.52.
hSPs 36.49 and 36.50 which are 18-month calibration procedures-for the 4160 Volt Degraded Voltage Relays have been restricted to performance in modes 5 and 6 only. These procedures in addition to calibrating the undervoltage relays, test the time delay relays to which the undervoltage relays supply their signal. As there is no way to test these time delay relays without removing all degraded voltage protection these calibrations may not be perfonned in modes 1, 2, 3 or 4 which are the applicable modes for Table 3.3-3 Item 6.b.
Appropriate steps have been added to the two associated monthly tests to provide for adjustment of the undervoltage relays should they fail to meet the test's tolerance.
l l
Reply to Notice of Violation Inspection 83-29 Letter dated January 16, 1984 Page 3 VIOLATIONB,(Continued)
Procedures for testing and calibration of relays providing loss of voltage I
feeder trips and loss of voltage diesel start protection have been revised l
to refer to the one-hour time limit that relays may be out of service in j
the Precautions Section of the procedure. This change affects the follow-i f
ing procedures: MSPs 36.45, 36.46, 36.47, 36.48, 36.53, 36.54, 36.55 and j
36.56.
j In addition further revisions have been initia';ed to these procedures to
[
add a precaution referring to Limiting Condition for Operation 3.8.1.1 if the relay is not returned to service within one hour.
Also an initial condition has been added for the performance of OST 1.36.7 prior to removing the relay.
Performance of this OST is one of the required actions of LC0
- 3. 8.1.1.
A note to the performer has been added stressing the need to infonn the NSS immediately if the calibration is unsatisfactory or if for any reason the relay cannot be returned to service within one hour.
Recor-ding of the time the relay is removed has been added to the Data Sheet to track the one-hour limit. These changes were incorporated into MSPs 36.45, 36.46, 36.47, 36.48, 36.53, 36.54, 36.55 and 36.56.
Action Taken to Prevent Recurrence The reviews and revisions of. OSTs 36.41 through 36.56 as described above have added the appropriate administrative ' controls to assure compliance with the applicable technical specification limits and action statements.
Date on Which Full Compliance Will be Achieved Full compliance has been achieved at this time.
1