ML18153C390
| ML18153C390 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 10/08/1990 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 90-568, NUDOCS 9010180281 | |
| Download: ML18153C390 (5) | |
Text
VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 October 8, 1990 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D. C. 20555 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS l. AND 2 Serial No.
NO/ETS Docket Nos.
License Nos.90-568 R1 50-280 50-281 DPR-32 DPR-37 NRC INSPECTION REPORT NOS. 50-280/90-22 AND 50-281/90~22 We have reviewed your letter of September 6, 1990, in reference to the NRC inspection which was reported in Inspection Report Nos. 50-280/90-22 and 50-281/90-
- 22. Our reply to the deviation described in the Notice of Deviation is provided in the attachment.
We have no objections to this correspondence being made a matter of public disclosure.
If you have any further questions please contact us.
Very truly yours,
&.L~
W. L. Stewart Senior Vice President - Nuclear Attachment cc:
U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, N. W.
Suite 2900 Atlanta, Georgia 30323 Mr. W. E. Holland NRC Senior Resident Inspector Surry Power Station 9010180281 901008 PDR ADOCK 05000280 Q
.:reo1 1/1
ATTACHMENT Reply to Notice of Deviations Reported During the NRC Inspection Report No. 50-280/90-22 and 50-281 /90-22 NRC comment:
During an NRC inspection conducted on July 9-19, 1990, a deviation from a written commitment was identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 1 O CFR Part 2, Appendix C (1990), the deviation is listed below:
Virginia Electric and Power Company responded to their compliance to RG 1.97 (NU REG 0737, Supplement 1) in letters dated January 31, 1984; May 10, 1985; June 21, 1985; August 2, 1985; April 21, 1986; and August 12, 1987 (RG 1.97, Revision 3).
RG 1.97, Revision 3, Table 1, Design and Qualification criteria for Instrumentation, lists the twelve criteria and specifically defines the requirements for each criteria. Criterion 1, Equipment Qualification, states that qualification applies to the complete instrumentation channel from sensor to display. It furthers states that the seismic portion of qualification should be in accordance with RG 1.100, Seismic Qualification of Electrical Equipment for Nuclear Power Plants. Seismic qualification applies to the instrumentation for the Category 1 variables. Criterion 9, Interfaces, states that the transmission of signals for other use should be through isolation devices that are designated as part of the monitoring instrumentation arid that meet the provision of RG 1.97. Interface requirements apply to instrumentation for Category 1 and 2 variables.
Contrary to Criteria 1 above, during July 9-19, 1990, unqualified commercial grade indicators and recorders were installed in RG 1.97 instrumentation loops to monitor Category 1 variables.
Contrary to Criteria 9 above, during July 9-19, 1990, instrumentation loops for Category 1 and 2 variables did not have isolation devices between the RG 1.97 displays and the non-Class 1 plant computer.
Please provide to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington.DC 20555, with a copy to the Regional Administrator, Region II, and if applicable a copy to the NRC Resident Inspector Surry, in writing within 30 days of the date of this Notice of Deviation, the reasons for the deviation, the corrective steps which have been taken and the results achieved,the corrective steps which will be taken to avoid further deviations, and the date when your corrective actions will be completed. Where good cause is shown, consideration will be given to extending the response time.
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REPLY Reply to Notice of Deviations Reported During the NRC Inspection Report No. 50-280/90-22 and 50-281 /90-22 (1)
ADMISSION OR DENIAL OF THE ALLEGED DEVIATION:
The deviation is correct as stated.
(2)
REASONS FOR DEVIATION:
- 1.
- 2.
Criterion 1 (Seismic Qualification)
Both the Westinghouse Optimac 101 Recorders and the Hagan 107 Indicators were installed during plant construction in accordance with the original plant design criteria including quality assurance requirements.
The basis for our 1984 submittal was that the indicators and recorders that were originally installed in the plant were acceptable for compliance with RG 1.97 requirements.
Specifically, the submittal noted in Attachment I (Indicators) that certain indicators were qualified ih accordance with IEEE 344-71 and implied that the remainder of the indicators were qualified to the original licensing basis requirements. A similar notation should have been included for the qualified PAM recorders listed in Attachment 2, but it was inadvertently omitted. During review of these devices during the inspection, specific seismic documentation for the Hagan 107 Indicators and the Optimac 101 Recorders could not be located.
Criterion 9 (Isolation)
Original Westinghouse design criteria and IEEE 279-1968 provided for a safety-related boundary between "Protection" and "Control" circuits. We incorrectly assumed in our submittal for RG 1.97 that the RG 1.97 Variables were in the "Control" category and therefore were properly isolated from protection circuitry. This interpretation was not specifically identified in our 1984 submittal. The existing computer interface devices do not meet isolation per IEEE 279-1971 although they provide buffering against normally expected faulted conditions.
(3)
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:
- 1.
Criterion 1 (Seismic Qualification)
A seismic test report for the Hagan 107 Indicators that were installed at Beaver Valley Station has been obtained and is being evaluated to determine if the Surry Power Station seismic spectra are enveloped by Page 2 of 4
the test report consistent with initial licensing design basis. A preliminary review of the test reports indicates that the Beaver Valley test report will envelope the seismic spectra for Surry.
No seismic test data has been located for the Hagan Optimac 101 recorders. The recorders are being evaluated to determine if they may be qualified utilizing Seismic Qualification Utility Group (SQUG) methodology.
Preliminary indication is that it* should be possible to seismically qualify the existing equipment with the SQUG methodology.
Safety-related equipment not designed to recent seismic criteria is an unresolved safety issue. As indicated in the Generic letter (GL) 87-02 and NUREG-1211, Surry station is one of 70 plants that are to be reviewed to the NRC Unresolved Safety Issue (USI) A-46 Criteria.
- 2.
Criterion 9 (Isolation)
- Alternative methods of providing qualified isolation for RG 1.97 variables have been identified to resolve this deviation. Some of these methods include:
. a.
Add additional isolators to isolate the plant computer inputs.
- b.
Obtain a new isolator which will have multiple isolated outputs to replace the present isolators.
- c.
Add digital to analog converters on the current ERF multiplexer signal line and use the regenerated analog signals to supply the plant computer.
(4)
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER DEVIATIONS:
- 1.
Criterion 1 (Seismic Qualification)
The evaluation of the Beaver Valley test report for the Hagan 107 Indicators will be completed to establish seismic qualification of the Surry indicators. The Westinghouse Optimac 101 Recorders and the Hagan 107 Indicators, as required will be evaluated as part of the *seismic qualification verification process developed by the SQUG.
Upon completion of this program, these items will be either seismically qualified or replaced with qualified devices.
This will establish the seismic qualification for the affected components using an acceptable alternative to the requirements of RG 1.97 for Category 1 instrumentation.
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Any future RG 1.97 Category 1 indicator and recorder replacements will be documented as seismically qualified.
- 2.
Criterion 9 (Isolation)
An engineering evaluation to resolve this deviation will be completed and plant modifications will be initiated,. as necessary, to provide qualified isolation of RG 1.97 displays from non-1 E circuits. Applicable standards and procedures will be modified to incorporate the results of the isolation study.
(5)
THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
- 1.
Criterion 1 (Seismic Qualification)
The evaluation of the Beaver Valley test report to support seismic qualification of the Hagan 107 Indicators will be completed by November 30, 1990. The seismic verification of the Optimac 101 Recorders and the Hagan 107 Indicators will be completed within 120 days of receipt of the NRC SER for the seismic qualification verification process. The NRC SER is currently expected to be issued in early 1991.
If physical modifications or replacements are required, changes will be completed for both units by the end of the Unit 1 1993 refueling outage.
- 2.
Criterion 9 (Isolation)
The engineering study and implementation of the required modifications will be completed in conjunction with the plant computer replacement project. Consistent with the Corporate Five-Year Plan the plant computer is currently scheduled for replacement during the 1994 and 1995 refueling outages for Unit 2 and Unit 1 respectively.
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