ML20151H677

Notice of Violation & Notice of Proposed Imposition of Civil Penalty in Amount of $40,000.Noncompliance Noted: Applicant Approved Diesel Generator Preoperational Tests Results Even Though Acceptance Criteria Not Satisfied

ML20151H677
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	04/12/1983
From:	Allan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:
Shared Package
ML20151H663	List: ML20151H661 ML20151H667 ML20151H677
References
EA-83-020, EA-83-20, NUDOCS 8305040790
Download: ML20151H677 (3)

Text

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NOTICE OF VIOLATION AND ' ~~ ~~

pR0p0 SED IMPOSITION OF CIVIL PENALTY Long Island Lighting Company Docket No. 50-322 Shoreham Nuclear. Power Station -

EA 83-20 During an inspection conducted between November 30 and December 31, 1982, a violation of NRC requirements was identified involving approval of a preopera-tional test of a diesel generator, even though test results indicatcd that one of the test criteria had not been met.

On May 26, 1982, a part of the preoperational test for Diesel Generator 102 was performed to verify the diesel generator's capability of running at its two hour rating. Although th.e procedure acceptance criterion specified this rating to be '3,900 KW (Kilowatts), the procedure step used to verify that this criterion was met specified that the diesel generator be run at a load between 3,850 KW and 3,900 KW for two hours, and that data be recorded at 15 minute intervals. When the test was performed on May 26, 1982, load values did not neet either the acceptance criterion or the precedure step in that data recorded at 15 minute intervals for the two hour' period indicated a range of load values from 3,500 KW to 3,850 KW. Nonetheless, the Test Engineer and Operational Quality Assurance (0QA) inspectors signed. and accepted the re:ults on May 26, 1982.

On October 11, 1982, after completion of the entire preoperational test for Diesel Generater 102, the Test Engineer completed a " Test Analysis Report" which indicated that the two hour load run test was successfully completed on May"26, 1982. Also, on October 12, 1982, these preoperational test results were approved by the Lead Startup Engineer, the Startup Manager, and the Joint Test Group. .

In order to emphasize the need for more attention to detail during the review and approval of test results involving safety related systems, to assure that tests. have verified the systems are capable of meeting design requirements, the Nuclear Regulatory Commission proposes to impose a civil penalty in the 4

amount of Forty Thousand Dollars (540,000) for the violation set forth in this licy, 47 FR 9987 (March 9, 1982),

Notice. In accordance and pursuant to Sectionwith 234the NRC of the Enforcement Atomic Energy Po.Act of 1954, as amended, 42 U.S.C. 2282, PL 96-295 and 10 CFR 2.205, this particular violation and its associated civil penalty is set forth below.

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e e , Notice of Violation 2 FSAR paragraph 17.2.11 and the LILCO Quality Assurance Manual, Section 11 which implement the requirements of 10 CFR 50, Appendix B, Criterion XI, require that a test program be established to assure that all testing required to demonstrate that systems will perform satisfactorily in service is identified and performed in accordance with written test procedures, which incorporate the requirements and acceptance limits contained in applicable design documents. Test results shall also be documented and evaluated to assure that test requirements have been satisfied.

Shoreham FSAR paragraph 14.1.3.7.24, Test Method, Item 8 states that during the preoperational test program, the diesel generators shall be tesLwd in eccord4nce with paragraph C.2.a of Regulatory Guide 1.108, Rev. 1, which requires that the preoperational test program demonstrate the full-load-carrying capability of the diesel generators for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, of which 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> is at a load equivalent to the 2-hour rating of the diesel generator. ..

Specification SH1-89, Rev.1, " Diesel Generator Sets," in Section 2, Design Data, Item 1.d specifies the 2-hour rating as 3,900 KW (kilowatts).

pT.307.0038, " Emergency Diesel Generator 102 Electric Preop Test," para-graph 10.4, acceptance criteria, specifies the diesel generator be capable of carrying a rating of 3,900 KW for at least two hours. Paragraph 8.5.4 of Procedure PT 307.0038 specifies running the diesel generator at a load between 3,850 and 3,900 KW for at least 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. Data to demonstrate that the criteria are satisfied is logged every 15 minutes for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, resulting in nine readings.

FSAR paragraph 14.1.1.1 states that the Joint Test Group reviews and approves completed preoperational tests.

Contrary to the above, the test p,rogram, as implemented, did not assure that testing was performed in accordanew with procedures or that test requirements had been satisfied. On May 26, 1982, a preoperstional test was performed to demonstrate the 2-hour rating of Diesel Generator 102.

The tesulla of thin LusL were appruvwd by the Joint Test Group on October 12, 1982 even though the test was not conducted in accordance with the test procedure requirements and the test results did not demon-strate this rating. Of the nine readings recorded at 15 minute intervals during the performance of the test, all nin'a readings were below 3,900 KW and six of the readings were below 3,850 KW. Specifically, one reading .

was 3,500 KW, two readings were 3,700 KW, three readings were 3,800 KW and three readings were 3,850 KW.

This is a Severity Level III Violation (Supplement.II).

Civil Penalty - 540,000

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l Hotice' of Vinlation 3 Pursuant to 10 CFR 2.201, Lot.g Island Lighting Company is hereby required to submit to the Director, Office of Inspection and Enforcement, USNRC, Washington, D. C. 20555, with a copy to this office, within 30 days of the date of this Notice, a written statement or explanation, including: (1) admission or denial of the alleged violation; (2) the rossons for the violation if admittyd; (3) the corrective steps which have been taken and the results achieved; (4) the corrective steps which will be taken to avoid further violations; and (5) the date when full compliance will be achieved. Consideration may be given to extending the response time for_ good cause shown. Under the authority of Section 132 of the Act, 42 U.S.C. 2232, this response shall be submitted under oath or affirmation.

Within the same time as provided for the response required above under 10 CFR 2.20), Long Island Lighting Company may pay the civil penalty in the amount of Forty Thousand Dollars (540,000) for the violation, or may protest impositio.n of the civil penalty.in whole or in part by a written answer. Should Long Island Lighting Company fail to answer within the time specified, the Director, Office of Inspectiu and Enrurt.ement, will issue an order 1mposing the civil penalty in the amount proposed above. Should Long Island Lighting Company elect to file an answer in accordance with 10 CFR 2.205 protesting the civil-penalty, such answer may: (1) deny the violation listed in this Notice in whole or in part; (2) demonstrate extenuating circumstances; (3) show error in this Notice; or (4) show other reasons why the penalty should not be imposed.

In addition to protesting the civi1 penalty .in whole or in part, such answer may request remission or mitigation of the pen'alty. In requesting mitigation of the proposed penalty, the five factors contained in Section IV(B) of 10 CFR Part 2, Appendix C, shodd be addressed. Any written answer in accordance with 10 CFR 2.205 should be set forth separately from the statement or explan-ation in reply pursuant to 10 CFR 2.201, but may incorporate by specific reference (e.g. giving page and paragraph numbers) to avoid repetition. Long Island Lighting Company's attention is directed to the other provisions of 10 CFR 2.205, regarding the procedure for imposing a civil penalty. -

Upon failure to pay the c"vil p9nalty due, which has been subsequently deter-mined in accordance with the applicable provisions of 10 CFR 2.205, this matter may be referred to the Attorney General; and the penalty, unless compromised, remitted, or mitigated, may be collected by civil action pursuant to Section 234c of the Act, 42 U.S.C. 2282.

FCR THE NUCLEAR REGULATORY COMMISSION O r m_. wr, &L Ja es M. Allan ting Regional Administrator Dated at King of Prussia, Pennsylvania this f 2 day of April 1983.

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• i BOARD NOTIFICATION DISTRIBUTION: BN No. 83 53

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ASchwencer Project Manager R. Caruso " '

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. JYoungbicod GKnighton EAdensam .

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.RMattson T.Speis ._-

HThompson Attorney, OELD Bordenick ELJordan, DEQA:IE" ~

JMTaylor, DRP:IE _

Regional Administrator, Region I Resident Inspector WJDircks, EDO (3) -

EChristenbury, OELD JScinto, GELD AB,ennette, OELD (w/-enc'losures) cc: Board / Licensee Service List s - n ea ,

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