ML20117K109
| ML20117K109 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 04/03/1985 |
| From: | Carey J DUQUESNE LIGHT CO. |
| To: | Wenzinger E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8505150315 | |
| Download: ML20117K109 (5) | |
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Shippingport. PA 15077-0004 April 3,1985 U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement
~ Attn: Mr. Edward C. Wenzinger, Chief Reactor Projects Branch No. 3 Division of Project and Resident Programs Region 1 631 Park Avenue King of Prussia, PA 19406
Reference:
Beaver Valley Power Station, Unit No. 1 Docket No. 50-334, License No. DPR-66 Inspection Report 85-02 Gentlemen:
In response to your letter of March 7,1985, and in accordance with 10 CFR 2.201, the attached reply addresses the Notice of Violation which was included with the referenced report.
If you have any questions concerning this response, please contact my office.
Very truly yours, M
y e President, Nuclear Attachment cc: Mr. W. M. Troskoski, Resident Inspector U.S. Nuclear Regulatory Comission Beaver Valley Power Station Shippingport, PA 15077 U. S. Nuclear Regulatory Commission c/o Document Management Branch Washington, DC 20555 Director, Safety Evaluation & Control Virginia Electric & Power Company P.O. Box 26666 One James River Plaza Richmond, VA 23261 0505150315 50403 PDR ADOCK 05000334 0
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DUQUESNE LIGHT COMPANY.
Beaver Valley Power Station Unit No. I 1
Reply to Notice of Violation i
Inspection 83-02 Letter dated March 7, 1985 VIOLATION A (Severity Level IV; Supplement I)
DescriptionofViolation(85-02-02) t Technical Specification 6.8.1 requires the establishment and implementation of procedures covering surveillance and test activities of safety related equip-ment.
Technical Specification Limiting Conditions for Operation 3.1.2.7 (Modes 5 and i
- 6) and 3.1.2.8 (Modes 1 thru 4) specify minimum volume and boron concentration requirements for the boric acid storage system.
10 CFR 50, Appendix A, General Design Criteria, requires that structures, systems and components important to safety such as the reactivity control t
systems, shall be designed, fabricated, erected and tested to quality stan-dards commensurate with the importance of the safety functions to be per-formed.
These structures, systems and components are required to withstand the effects of natural phenomena such as earthquakes and are to be designed to assure an extremely high probability of accomplishing their safety functions in the event of anticipated operational occurrences such as a loss of offsite power.
L The BVPS Unit 1 Quality Assurance Program defines quality assurance Category 1 as plant equipment vital to a safe shutdown of the plant, or necessary to mitigate the consequences to the public of a potential accident.
Appendix B, Category 1 Structures, Systems and Components, Revision 3, lists the boric acid tank CH-T6.-1A and IB but excludes the boric acid tank BR-TK-7.
t Contrary to the above, as of January 27,1985, OST 1.7.8, Boric Acid Storage Tank and RWST Level and Temperature Verification, allowed the use of boric acid hold tank BR-TK-7, a non-seismic structure and associated delivery pumping system of BR-P-11A and 118 which are not powered from a Class 1E emergency power source, to be used to meet the minimum volume requirements of the boric acid storage system.
l Corrective Action Taken A review of the past 5 years of data from OST 1.7.8 was conducted to determine past compliance with Technical Specification Limiting Conditions for Operation 3.1.2.7 and 3.1.2.8.
This review showed that the Technical Specification requirement for the inventory was met without relying on the volume in BR-TK-7.
Therefore, we have been in compliance with the requirements of s
Technical Specifications 3.1.2.7 and 3.1.2.8 during this period.
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Reply to N tice of Violation Inspection 85-02 Letter dated March 7,1985 Page 2 Actions Taken to Prevent Recurrence Operating Manual Change Notice (85-50) has been implemented to eliminate the potential for using the BR-TK-7 inventory for Technical Specification compli-ance.
A review of other safety related systems' tanks that have specific volumetric requirements addressed in the Technical Specifications was conducted by the NSOS. Thi. review included the following:
Refueling Water Storage Tank Chemical Addition Tank Primary Plant Demineralized Water Storage Tank Boric Acid Tanks Boron Injection Tank SIS Accumulators Diesel Generator Fuel Oil Tanks Diesel Fire Pump Fuel Oil Tank This review concluded, with the exception of the Boric Acid Tanks, that there were no other system configurations within these tank subsystems that had the potential to provide a similer procedural problem.
Date on Which Full Compliance Will be Achieved Full compliance has been achieved ot this time.
('
R: ply to Notice of Violation i
Inspection 85-02 Letter dated March 7,1985 l
Page 3 VIOLATION B (Severity Level IV; Supplement I)
Description of Violation (85-02-01) l Technical Specification 4.0.5 requires that components which are classified as ASME Code Class 1, be tested to the criteria of Section XI of the ASME Boiler j
and Pressure Vessel Code and Addenda.
Subsection IWV-3420 of the Code re-i quires that when check valves are leak tested at pressure differentials lower than the function pressure differential, then the observed leakage must be adjusted to the function maximum pressure differential value by calculation appropriate to the ratio between the test and function pressure differential assuming leakage to be directly proportional to the pressure differential to the one-half power.
IWV-3420 further requires that valve seat leakage should be determined during pressure testing by measuring leakage through a down-stream telltale connection or by measuring feed rate required to maintain pressure.
Contrary to the above, valve leak rate tests performed during the Fourth Refueling Outage were performed incorrectly as follows:
l 1.
RCS pressure isolation valve leak tests in accordance with OST 1.11.16 were performed using pressures lower than the function maximum pressure differential without adjustment of the observed leakage.
2.
Accumulator check valve tests in accordance with OST 1.11.4 were performed without measuring leakage through a downstream telltale connection or by measuring feed rate required to maintain pressure.
Corrective Action Taken 1.
In order to comply with Subsection !WV-3420 of the Code, an Operating Manual Deficiency Report (OMOR) was written to revise OST 1.11.16 to include the correction factor needed to adjust the results to function maximum pressure differential.
In addition, the results of previous runs of OST 1.11.16 were adjusted to the function maximum pressure differen-tial and then compared with the Acceptance Criteria.
These results were within the Acceptance Criteria range.
2.
Subsection IW'l-3420 of the Code states that valve seat leakage may be determined by measuring Itakage through a downstream telltale connection or by measuring feed rate recuired to maintain pressure.
OST 1.11.4 determines the valve seat lea (age of the Accumulator check valves by measuring leakage flow through the 3/4 inch " Accumulator Test Line" with a 05 gpm flow noter.
This arrangement allows any leakage to be measured.
An OMDR was also written for OST 1.11.4, to require the trapped pressure to be bled off before measuring the leakage flow, to require the RCS and Accumulator pressures to be recorded and to re-emphasize the toro gpm Acceptarce Criteria.
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R: ply to Notice cf Violation
. Inspection 85-02 Letter dated March 7, 1985 Page 4 Page 4 Action Taken to Prevent Recurrence The methods of leak testing the Category A valves in the IST Program will be reviewed to ensure that they are according to the code, Subsection IWV-3420.
Date on Which Full Compliance Will Be Achieved Changes to OST 1.11.6 and 1.11.4 will be reviewed and needed revisions will be completed by June 30, 1985.
The review of the leak test methods for Category A valves and any subsequent revisions to the tests or the IST Program will be completed by Octo-ber 1, 1985.
Incorporation of the above procedure changes will be completed prior to the next expected performance in the Fifth Refueling Outage.
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