ML20212B684
| ML20212B684 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 12/12/1986 |
| From: | Carey J DUQUESNE LIGHT CO. |
| To: | Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| 2NRC-6-123, NUDOCS 8612290294 | |
| Download: ML20212B684 (5) | |
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2NRC-6-123 Beaver Valley No. 2 Unit Project Organization Telecopy 4e?)
Ext.160 S.E.G. Building
- o. Box 328 Dec. 12, 1986 Shippingport, PA 15077 United States Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406 ATTENTION:
flr. Steward D. Ebneter, Director Division of Reactor Safety
SUBJECT:
Beaver Valley Power Station - Unit No. 2 Docket No. 50-412 Inspection Report 50-412/86-28
REFERENCE:
Letter dated November 17, 1986 (S. D. Ebneter to J. J. Carey)
Gentlemen:
The above referenced letter transmitted a Notice of Violation as Appendix A.
Attachments 1 and 2 of this letter provide Duquesne Light Company's (DLC) response pursuant to the requirements of 10CFR2.201 and the NRC's Notice of Vio-1atton.
DUQUESNE LIGHT COMPANY By v
LJ. J./Carey Sr. Vice President LMR/ijr NR/IR/50412 Attachment cc:
Mr. P. Tan, Project Manager (w/a)
Ms. A. A. Asars, NRC Resident Inspector (w/a)
Mr. J. Beall, NRC Senior Resident Inspector (w/a)
NRC D0cument Control Desk (w/a) 8612290294 861212 PDR ADOCK 05000412
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s United Stat:s Nuclear R gulatory Commission Mr. Steward D. Ebneter, Director Inspection Report 50-412/86-28 Page 2 COMMONWEALTH OF PENNSYLVANIA )
1 SS:
COUNTY OF BEAVER
,/fh, before me, a On this,[ d_
day of..
//w Notary Public in and for said Commonwealth and County, personally appeared J. J. Carey, who being duly sworn, deposed and said that (1) he is Senior Vice President of Duquesne Light, (2) he is duly authorized to execute and file the foregoing Submittal on behalf of said Company, and (3) the statements set forth in the Submittal are true and correct to the best of his knowledge.
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Not'ary Public SHULA B. FATTRE. MTART PUBUC SHIPPIMPORT 0000, BEAVER CNf4V L1T COMM13310R EIPIRES OCT. 23.1989 M r.ter, F.ekt.h hnei-t:ca e me5s 1
ATTACHMENT 1 NOTICE OF VIOLATION 86-28-01 10 CFR 50, Appendix B,
Criterion VI requires in part that " Instructions, procedures, and drawings, including changes thereto, affecting quality are reviewed for adequacy and are distributed and used at the locations where pre-scribed activity is performed."
Contrary to the above, as initially identified on August 22, 1986, during perfor-mance of preoperational test P0-2.07.02, " Boric Acid System Test," changes made to the system in E&DCR D-0117-B02 were not properly reflected in the preoperational test.
This violation was a followup to an item initially identified during an inspection conducted on August 18 - 22, 1986.
A contributing cause to this vio-lation was a general lack of knowledge by test and operations personnel in the drawing and document control system.
This is a Severity Level IV violation. (Supplement II)
RESPONSE
P0 2.07.02, " Boric Acid Transfer System Test", steps VII.B.118 and 119 verify the auto start function of Boric Acid Transfer Pump (2CHS*P228).
When these test steps were attempted, 2CHS*P22B could not be started in auto.
Troubleshooting was conducted in the Auxiliary Relay Cabinet (RK*2 AUX-REL-B) and revealed a prob-lem with the installed modification, E&DCR D-0117-B02, requiring additinal engin-eering action prior to test continuance.
CORRECTIVE STEPS.TAKEN Test Deficiency Report No. 16 for P0 2.07.02 was generated to address the
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problems with the installed modi fic ation, E&DCR D-0117-B02.
Corrections were implemented under Work Authorization Request 5824 in accordance with the revised design information, E&DC4 0-0117-S02.
The portions of P0 2.07.02 related to the auto start function of 2CHS*P22B were perfonned satisfactorily and Test Deficiency Report No.16 is in the process of being closed.
Both Systems Test and Operations personnel have received additional training in the drawing and document control system.
This includes Enginearing and Design Coordination Reports, Nonconformance and Disposition Reports, and the computerized listing of project drawings which can be used in various formats to provide staus infor-mation.
Administrative guidelines for perfonning preoperational tests require that the test procedure be checked against current system design documents prior to authorization for performance.
Full compliance has been achieved.
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Notice of Violation 86-28-02 10 CFR 50, Appendix B, Criterion XI, requires in part, that " Test procedures shall include provisions for assuring that all prerequisites for the given test have been met.
Contrary to the above, as identified on October 1,1986, test personnel involved with the preoperation test P0 2.07.03, "Chenical Volume Control Systen", failed to check prerequisites prior to the test for the systen portion of valve No.137 and, again, for the systen portion of valve No. 460 B.
This is a Severity Level V Violation.
(Supplement II).
RESPONSE
The initial Conditions section of P0 2.07.03, "Chenical and Volume Control Systen Test", specifically states that the applicable portions of the Operating Manual Power Supply and Control Switch List shall be verified prior to perfonning the test.
1.
Ex_ cess Letdown Heat Exchanger Discharge Pressure Reducing Valve (2CHS*HCV137)
Applicable power supplies and control switches were verified prior to testing 2CHS*HCV137 with the exception of Circuit Breaker 3B-8 in Normal Vital Bus Panel (PNL-VITBS2-3B).
This breaker was not verified closed because all 45 VDC power supplies which were supplying Chenical and Volume Control Systen components had been energized from a temporary power source while PNL-VITBS2-3B was being Phase I tested.
Valve 2CHS*HCV137 had not been pre-viously available for testing, since it was on clearance as a boundary valve for several weeks prior to the test perfonnance.
Prior to the testing of 2CHS*HCV137, the 45 VDC power supply was returned to permanent power without the knowledge of the test engineer.
This did not create a problen for the Chenical and Volume Control Systen since it was not operational at the time.
The initial attenpt to stroke 2CHS*HCV137 from the Control Room was unsuc-cessful because of the change over in power supply.
Corrective Steps Taken:
PNL-VITBS2-3B was checked with a voltmeter to confirm it was energized.
Upon verification of power to PNL-VITBS2-3B, Breaker 38-8 was closed and the stroke test on valve 2CHS*HCV137 was satis-f actorily completed.
Since pennanent power is now available to the vital bus, all necessary circuit breakers for components powered from the vital bus are required to be verified prior to performing any test. All test engineers have been informed of this change in plant configuration.
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Regenerative Heat Exchanger Letdown Inlet Valve (2CHScLCV4.60B)
Applicable power supplies and control switches were verified prior to the initi al logic testing of. 2CHS*LCV4608.
During this ini ti al test, 2CHS*LCV460B did not operate from the Alternate Shutdown Panel (ASP). A test deficiency and work request were generated to resolve the deficiency.
The completed work request stated that 2CHS*LCV4608. had worked correctly.
A retest was then performed, but 2CHS*LCV460B again failed. to operate from the ASP.
It was determined that Power Supply-125 VDC (2PNL-RCPBP-06), Breaker No. 6, was open, preventing operation of 2CHS*LCV4608 from the ASP.
Corrective Steps Taken:
2PNL-RCPBP-06, Breaker No. 6, was closed and the test of valve 2CHS*LCV460B was perfonned.
It was recognized that a reverifi-cation of power supplies should have been performed prior to the retest of 2CHS*LCV460B.
The administrative guidelines for performing preoperational tests state that if there is any reasonable doubt that a particular condition or prerequisite may be applicable, it should be included in those items to be reverified prior to test resumption.
All test engineers have been advised of the importance of following the administrative guideline.
All test engineers h ave also been advi sed, that if a particular component has been verified operable by Maintenance, this does not preclude reverification of applicable conditions and prerequisites by the test engineer.
Full compliance has been achieved.
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RECEIVED-REGOIl 1 1985 EC 18 f;i 2: 23 I
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