ML20044D285
| ML20044D285 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 05/10/1993 |
| From: | Edison G Office of Nuclear Reactor Regulation |
| To: | Sieber J DUQUESNE LIGHT CO. |
| References | |
| IEIN-93-015, IEIN-93-15, TAC-M86129, NUDOCS 9305180441 | |
| Download: ML20044D285 (5) | |
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't UNITED STATES
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NUCLEAR REGULATORY COMMISSION
- - :s I k..v / f WASHINGTON, D C. 20555 0001 4 8 May 10, 1993 j
Docket Nos. 50-334 and 50-412 Mr. J. D. Sieber, Senior Vice President and Chief Nuclear Officer Nuclear Power Division Duquesne Light Company Post Office Box 4 Shippingport, Pennsylvania 15077-0004
Dear Mr. Sieber:
SUBJECT:
BEAVER VALLEY ATOMIC POWER STATION, UNIT N05. 1 AND 2, REQUEST FOR ADDITIONAL INFORMATION RELATED TO CHANGE REQUEST NO. 75 AND NRC INFORMATION NOTICE 93-15 (TAC NO. M86129)
Duquesne Light Company (DLC), by letter dated April 14, 1993, requested an exigent Technical Specification (TS) change for Beaver Valley, Unit 2, regarding reactor trip breaker surveillance testing. The proposed exigent Technical Specification (TS) change adds a one-time footnote to the Technical Specification Surveillance Requirement 4.3.1.1.1, Table 4.3-1, Table Notation 10, which defines the schedule for complete verification of operability of the shunt trip circuitry for the manual reactor trip function.
The surveillance procedure utilized by DLC for testing the manual trip function is being revised to adequately verify that the reactor trip breakers and reactor trip bypass breakers have electric continuity between the shunt trip coil and manual reactor trip switches located on the main control board.
This is in response to DLC's evaluation of NRC Information Notice (IN) 93-15,
" Failure to Verify the Continuity of Shunt Trip Attachment Contacts in Manual Safety Injection and Reactor Trip Switches."
On April 6,1993, the NRC ctaff authorized discretionary enforcement for Unit 2 until the next shutdown to MODE 3, with the understanding that procedural corrections and re-testing would be completed for Unit I during the current outage.
During a conference call on May 3,1993 with Mr. S. Sovick, et al., of your staff, the NRC staff learned that you have identified no action to be taken for either unit for that portion of IN 93-15 dealing with the safety injection (SI) switches, and your staff was uncertain of the status of such an evaluation.
In addition, several apparent errors were discovered in Figure 1 of your April 6,1993 request for discretionary enforcement.
Therefore, we are requesting additional information related to your Unit 2 amendment request dated April 14, 1993. However,yourresnonseshouldalsoaddresstheadequacy[
of manual testing of SI switches for thit 1.
I 1300g Please provide your response to the encice.d questions within 2 weeks ofreceipt
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Mr. J. D. Sieber May 10, 1993 i
l The requirements of this letter affect fewer then 10 respondents, and, therefore, are not subject to the Office of Management and Budget review under PL 96-511.
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Sincerely, l
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l Gordon E. Edison, Senior Project Manager l
Project Directorate I-3 l
Division of Reactor Projects - I/II Office of Nuclear Reactor Regulation -
Eaclosure Request for Additional Information cc w/ enclosure:
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Mr. J. D. Sieber May 10, 1993 The requirements of this letter affect fewer than 10 respondents, and, therefore, are not subject to the Office of Management and Budget review under PL 96-511.
Sincerely, Gordon E. Edison, Senior Project Manager Project Directorate I-3 Division of Reactor Fiojects - I/II Office of Nuclear Reactor Regulation
Enclosure:
Request for Additional Information cc w/ enclosure:
See next page P
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Mr. J._D. Sieber Beaver Valley Power Station Duquesne Light Company Units 1 & 2 cc:
k Jay E. Silberg, Esquire Bureau of Radiation Protection Shaw, Pittman, Potts & Trowbridge Pennsylvania Department of i
2300 N Street, NW.
Environmental Resources Washington, DC 20037 ATTN:
R. Barkanic i
Post Office Box 2063 Nelson Tonet, Manager Harrisburg, Pennsylvania 17120 Nuclear Safety Duquesne Light Company Mayor of the Borrough of Post Office Box 4 Shippingport Shippingport, Pennsylvania 15077 Post Office Box 3 Shippingport, Pennsylvania 15077 t
Commissioner Roy M. Smith West Virginia Department of Labor Regional Administrator, Region I Building 3, Room 319 U.S. Nuclear Regulatory Commission Capitol Complex 475 Allendale Road Charleston, West Virginia 25305 King of Prussia, Pennsylvania 19406 John D. Borrows Resident Inspector Director, Utilities Department U.S. Nuclear Regulatory Commission Public Utilities Commission Post Office Box 181 l
180 East Broad Street Shippingport, Pennsylvania 15077 l
Columbus, Ohio 43266-0573 i
Director, Pennsylvareia Emergency Management Agency Post Office Box 3321 Harrisburg, Pennsylvania 17105-3321 Ohio EPA-DERR ATTN: Zack A. Clayton Post Office Box 1049 Columbus, Ohio 43266-0149 i
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Enclosure RE00EST FOR ADDITIONAL INFORMATION 1.
Please provide a copy of the procedure (s) revised to address the test inadequacy determined as a result of your evaluation of NRC Information Notice (IN) 93-15, " Failure to Verify the Continuity of Shunt Trip Attachment Contacts in Manual Safety Injection and Reactor Trip Switches." Please include those drawing (s) which describe the circuit operation associateo with the procedural change (s).
2.
Please describe the scope and conclusions of the your internal review of NRC IN 93-15. Discuss the technical basis for your decision agt to revise the manual safety injection switches surveillance procedures (s) to provide an independent test of the shunt trip and undervoltage trip circuitry from the Main Control Board to the Reactor Trip Breakers and Reactor Trip Bypass Breakers.
3.
Table 4.3-2, Notation (1) for Technical Specification 4.3.2.1.1, Functional Unit 1 - SAFETY INJECTION AND FEEDWATER ISOLATION, Item a, Manual Initiation requires that the manual actuation switches be tested at least once per.18 months during shutdown by a CHANNEL FUNCTIONAL TEST.
Please provide a copy of the procedure (s) which performs the channel functional test for the subject technical specification requirement.
4.
Please provide a corrected Figure 1, " Beaver Valley Power Station Unit 2 Auto / Manual Reactor Trip Circuit" listed in your April 6, 1993 Request for Discretionary Enforcement letter to the NRC in order to reflect the proper operation of the trip switch contacts.
5.
Discuss bow the present test methodology, which does not verify the reactor trip function from the manual safety injection switches at the Main Control Board independently for each final actuation device (i.e.
shunt trip circuitry, undervoltage trip circuitry), satisfies your Updated Final Safety Analysis Report (UFSAR) Commitment as stated in Section 7.1.2.4 to meet Regulatory Guide 1.22 and IEEE Standard 338-1977, Criteria for the Periodic Testing of Nuclear Power Generating Station Class IE Power and Protection Systems for the ESFAS. The staff notes that IEEE Standard 338-1977 states for functional tests in Section 6.3.2 (6) " Verification of manually initiated safety functions. Where it is not possible to perform during plant operation, test may be performed during reactor shutdown (for example, manual reactor trip)." Further, IEEE 338-177 requires per Section 6.4(1) that "the test, or a combination of tests, shall check each protection channel or load group in its entirety (for example, include the sensor and the final actuation device or initiation device to all connected loads)."
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