ML20141G997

Notice of Violation from Insp on 970209-0426.Violation Noted:During EDG Surveillance Tests,Load Test Values Used Were Inadequate to Ensure That EDGs Achieved 2750 Kw Due to Inaccuracies in Kilowatt Meter Instrument Loop

ML20141G997
Person / Time
Site:	Beaver Valley
Issue date:	07/03/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20141G995	List: ML20141G991 ML20141G997
References
50-334-97-01, 50-334-97-02, 50-334-97-1, 50-334-97-2, 50-412-97-01, 50-412-97-02, 50-412-97-1, 50-412-97-2, EA-97-255, NUDOCS 9707140236
Download: ML20141G997 (4)

Text

_ _ . , . .m. __.m_ _ _ ._ _ _ - _ .__ _ .._. _ _ ... _ _- _ _ . . _ _ _ _ _ _ -

~

ENCLOSURE NOTICE OF VIOLATION '

Duquesne Light Company (DLC) Docket Nos. 50-334; 50-412 Beaver Valley Power Station License Nos. DPR-66; NPF-73 EA 97-255 During NRC inspections conducted between February 9,1997, and April 26,1997, violations of NRC requirements were identified. In accordance with the " General Statement of Policy .

and Procedure for NRC Enforcement Actions," NUREG-1600, the particular violations are set forth below:

l Unit 1 and Unit 2 Technical Specification (TS) 4.0.2 require that, each surveillance requirement shall be performed within the specified time interval.

1. Unit 1 TS 4.8.1.1.2.b.5 requires that each diesel generator shall be demonstrated OPERABLE at least once per 18 months during shutdown by verifying the diesel generator operates for greater than or equal to 60 minutes while loaded to greater than or equal to 2750 KW.

Contrary to the above, on April 11, 1996, and April 20, 1996, during emergency diesel generator (EDG) surveillance tests, the load test values used were inadequate to ensure that the EDGs achieved 2750 KW due to inaccuracies in the kilowatt meter instrument loop. Specifically, the EDGs had l to be tested to at least 2875 KW to account for meter inaccuracles; however, l EDG 1-1 was tested at 2850 KW on April 20,1996, and EDG 1-2 was tested l at 2800 KW on April 11,1996. These were the only EDG surveillance tests performed to meet TS 4.8.1.1.2.b.5 during the 18-month period. (01013) l 1

(

2. Unit 1 and Unit 2 TS 4.4.6.3.1 require, in part, that leakage testing of reactor i coolant system (RCS) pressure isolation valves (PlVs) listed in Table 4.4-3 shall l be accomplished prior to entering Mode 2 after every time the plant is placed l in the COLD SHUTDOWN condition for refueling. Unit 1 TS Table 4.4-3 includes, in part, residual heat removal (RHR) system inlet isolation valves MOV-RH-700 and MOV-RH-701. Unit 2 TS Table 4.4-3 includes, in part, RHR system inlet isolation valves 2RHS-MOV701 A, 2RHS-MOV702A, 2RHS-MOV701 B, and 2RHS-MOV7028.

Contrary to the above, Unit 1 reactor coolant system (RCS) pressure isolation valves MOV-RH-700 and 701 were not leak tested prior to entering Mode 2, I after placing the unit in cold shutdown on March 23,1996. Additionally, Unit 2 RCS pressure isolation valves 2RHS-MOV701 A(B) and 2RHS-MOV702A(B) were not leak tested prior to entering Mode 2, after placing the unit in cold

! shutdown on September 1,1996. (01023) l Official Record Copy I

A: PROP-BV.SUR I 9707140236 970703 PDR ADOCK 05000334 G -- PDR

- .- ~ .- _ , , . _

l  !

.. i l' .

l

. Enclosure 2 l l

1

3. Unit 1 and Unit 2 TS 4.6.4.2.b.4 require that each hydrogen recombiner system shall be demonstrated OPERABLE at least once per 18 months by verifying the  !

integrity of allheater electricalcircuits by performing a continuity and resistance  ;

to ground test immediately following the functional test required by TS l l 4.6.4.2.b.3.  :

!- I Contrary to the above, on March 24,1996, the integrity of Unit 1 hydrogen )

recombiner 1 A and 1B heater circuitry was not verified immediately following l

the functional tests of the recombiners. On September 1,1996, the integrity l l _ of Unit 2 hydrogen recombiner 21 A and 21B heater circuitry was not verified {

l immediately following the functional tests of the recombiners. (01033)  !

4. Unit 1 and Unit 2 TS 4.3.1.1.1 require that each reactor trip system l l instrumentation channel shall be demonstrated OPERABLE by the performance l l of the CHANNEL CHECK, CHANNEL CALIBRATION, and CHANNEL  !

l FUNCTIONAL TEST operations during the modes and at the frequencies shown j

! in Table 4.3-1. i i

j Unit 1 and Unit 2 TS 4.3.2.1.1 require that each engineered safety feature {

actuation system (ESFAS) instrumentation channel shall.be demonstrated i

[ OPERABLE by the performance of the CHANNEL CHECK, CHANNEL l CALIBRATION, and CHANNEL FUNCTIONALTEST operations during the modes j and at the frequencies shown in Table 4.3-2. l Unit 1 and Unit 2 TS 4.3.2.1.2 require that the logic for the interlocks shall be  :

demonstrated OPERABLE during the at power CHANNEL FUNCTIONAL TEST ,

of channels affected by interlock operation. l

! l l Contrary to the above, prior to March 24,1997, and March 27,1997, respectively, the Unit 1 and Unit 2 reactor coolant system loop stop valve position block signals were not tested during bimonthly channel _ functional . ,

i.

testing for ESFAS instrumentation, and channel functional testing for reactor  !

i trip system instrumentation in addition, an ESFAS P-4 interlock logic diode in l the Unit 1 and Unit 2 solid state protection system logic circuits was not tested i during channel functional testing. These testing omissions resulted in failure to demonstrate the interlock logic and the interlock function operable. (01043)

5. Unit 1 and Unit 2 TS 4.0.5.a.2 require that inservice testing of ASME Code Class 1,2, and 3 pumps and valves shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50.55a(f).

i i

I Official Record Copy

' A: PROP-BV.SUR d

l l

l . ^'

1 o Enclosure 3 l Unit 1 TS 4.7.7.2.b.1 requires that the bottled air pressurization system shall be demonstrated OPERABLE at least once per 18 months by verifying that a chlorine / control room high radiation / containment phase B isolation test signal from either Unit will initiate system operation. Unit 2 TS 4.7.7.1.e.6 requires that the Control Room Emergency Air Cleanup and Pressurization System shall be demonstrated OPERABLE at least once per 18 months by verifying that a j chlorine / control room high radiation / containment phase B isolation signal will initiate operation of the bottled air pressurization system.  ;

L l Operating Surveillance Test 1/2OST-44A.11, " Chlorine Actuation of Control Room isolation /CREBAPS Systems," implements the surveillance requirements and requires that the stroke times for the discharge trip valves do not exceed a prescribed ASME limiting stroke time. The test also requires that, if the discharge trip test valves exceed their previously recorded stroke times by greater than 50%, the test frequency will be increased to monthly.

i' Contrary to the above, CREBAPS discharge trip valves TV-VS-101B, D, and E  :

l were not stroke time tested between January 29 and March 22,1997, I l

following a 50% stroke time increase measured during performance of 1/2OST- 1 44A.11 on January 28,1997. (01053) ,

l

6. Unit 1 TS 4.1.2.2.b and Unit 2 TS 4.1.2.1.b require that at least one of the i l required boron injection flow paths shall be demonstrated OPERABLE at least  !

l once per 31 days by verifying that each ' valve (manual, power operated or

! automatic) in the flow path that is not locked, sealed or otherwise secured in l

position, is in its correct position. .

t Contrary to the above, prior to March 25,1997, the monthly boron injection l l

flowpath operability verifications were not satisfactorily completed. I Specifically, position verifications for boron injection flowpath valves MOV-1CH-289 and 310 and 1CH-83 and 86 on Unit 1 and 2CHS-MOV289 and 310 on l Unit 2 (valves which were not locked or secured in position) were not l performed. (01063) i These violations are classified in the aggregate as a Severity Level lli problem (Supplement 1).

Pursuant to provisions of 10 CFR 2.201, Duquesne Light Company (DLC) is hereby required l to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission,

ATTN

Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region I, and a copy to the NRC Resident inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" i and should include for each violation: (1) the reason for the violation, or, if contested, the

' Official Record Copy A: PROP-BV.SUR

_ . _ ._ _ ~- ___ . _. ._ _ ._ _ _ -

l

!

• l Enclosure 4 basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the ,

date when full compliance will be achieved. Your response may reference or include previous ,

docketed correspondence, if the correspondence adequately addresses the required response. .

If an adequate reply is not received within the time specified in this Notice, an order or

! Demand for information may be issued as to why the license should not be modified, suspended, or revoked, or why such other actions as may be proper should not be taken.

Where good cause is shown, consideration will be given to extending the response time.

Under the authority of Section 182 of the Act, 42 U.S.C. 2232, this response shall be submitted under oath or affirmation. l l

Because your response will be placed in the NRC Public Document Room (PDR), to the extent I possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such l material, you must specifically identify the portions of your response that you seek to have  ;

withheld and provide in detail the bases for your claim of withholding (e.g., explain why the i disclosure of information will create an unwarranted invasion of personal privacy or provide l the information required by 10 CFR 2.790(b) to support a request for withholding confidential ,

commercial or financial information). If safeguards information is necessary to provide an I acceptable response, please provide the level of protection described in 10 CFR 73.21.

Dated at King of Prussia, Pennsylvania this 3rd day of July 1997

)

l l

I l

1 l

l Official Record Copy A: PROP-BV.SUR