ML20150C312
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| ML20150C312 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 06/30/1988 |
| From: | Caldwell J, Cantrell F, King L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20150C304 | List: |
| References | |
| 50-338-88-16, 50-339-88-16, IEIN-87-041, IEIN-87-41, NUDOCS 8807120429 | |
| Download: ML20150C312 (10) | |
See also: IR 05000338/1988016
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UNITED STATES
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NUCLEAR RECULATORY COMMISSION '
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101 MARIETT/. STREET, N.W.
/1! *- e . ATLANTA, GEoIIGI A 3032:s
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Report Nos.: .50-338/88-16-and 50-339/88-16
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[ Licensee: Virginia Electric ~and. Power Company -
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Richmond,.VA- 23261
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Docket'Nos.: 50-338 and 50-339 License Nos.: NPF-4 and NPF-7
e Facility Name: -North Anna 1 and 2
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Inspection Conducted: May 14 June 10, 1988
-Inspectors: [- lb b b> h'
J. L. Caidwell,_Sen or Reside 6t Inspector Date Signed
Okk ZDX%
L. P. King, Residdnt In ecy
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Date Signed
- Approved by: E [l,
F. Ca5trell, Section Chi ; ~0at6 Signed
Division of Reactor Pro cs
SUMMARY
Scope: This rcutine inspection by the resident inspectors involved the
following areas: plant status, review of inspector fol. lou-up items,
monthly _ maintenance observation, -monthly surveillance observation,
ESF walkdown, .and operator : safety verification. During' the
performance of this inspection, the reside. t inspectors conducted
reviews of the licensee's backshift operati'ns on the following days
- May 15, 19, 24, 26, June 1, 2, 3, 7, 8, 9 and 10.
Results: Two violations were identified: (1) failure to perform an adequat'e
10 CFR 50.59 safety- evaluation before placing the Recirculation
Spray Heat Exchangers.(RSHXs) in wet layup conditions --paragraph 4;
and, (2) violation of TS 3.8.1.1 for having two inoperable Emergency
Diesel Generators (EDG) paragraph 8.
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G807120429 880630
PDR ADOCK 05000338
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, REPORT DETAILS
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> 1.' _ Licensee' Employees Contacted- -
G.~E. Kane, Station Manager .
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~ *R.LC..Driscoll, Quality Control (QC) Manager
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*R. 0.' Enfinger, Assistant' Station Manager
*M. L. Bowling, Assistant Station Manager
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*J. A. Stal!, Superintendent, Operations
'*M. R. Kansler, Superintendent, Maintenance
*A. H. Stafford, Superintendent, Health Physics
*D. A. Haacock, Superi tendent, Technical Services-(Acting)
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J. L. Downs, Superintendent, Administrative Services
J.;R. Hayes, Operations Coordinator
E. S. Hendrixson,~ Engineering Supervisor-(Acting)
.g 0. E.. Thomas, Mechanica) Maintenance. Supervisor-
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P G. D. Gordon,' Electrical Supervisor
L. N.1Hartz, Instrument Supervisor
F. T. Terminella,.QA Supervisor
J. P. Smith, Superintendent, Engineering
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D. B. Roth, Nuclear Specialis+.
*J. H.-Leberstein,-Engineer
*T.-L. Po"ter, NSE Supervisor
*0. E. Quartz, Associate Engineer
Other licensee employees contacted include technicians, op_rators,
mechanics, security force' members, and. office personnel .
* Attended exit interv'iew
2. Exit' Interview-(30703)'
'The inspection scope and findings were summarized on June 10,.1988, with
those persons indicated in . paragraph 1 - above. The' licensee acknowledged
the incpectors findings'. The licensee did not identify as proprietary any:
of the material provided to or reviewed by the i nspectors .during this
inspection,
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(0 pen) Violation- 338,339/88-16-01: Failure to perform an adequate
1 10 CFR 50.59 safety evaluation potentially resulting in all of the RSHXs
being "inoperable" due to fouling of the heat transfer surface resulting
from wet layup conditions paragraph 4.
(0 pen) Violation 338,339/88-16-02: Violation of TS 3.8.1.1 for having 2H
and 2J EDGs ir. operable at the same time for approximately 38 hours. This
rest ited from an inadequate avaluation of an INP0 SER 14-87 and IEIN
87-41 paragraph 8.
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3. Plant Status
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. Unit'l
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Vnit 1 Lbegan and ended the inspection period operating' at approximately.
100% power.
Unit.2
Unit'2 began the. inspection period operating at_approximately 100% power.
On May 19,.the licensee discovered that both the 2J and 2H Emergency
y Diesel: Generators (EDG) had been inoperable for.approximately 38 hours. ' At the time of discovery, the. 2J EDG, which.-had been inoperable due to.
preplanned preventative maintenance, had just-completed the surveillance
test and was fully ' operable (see Section '8 for details). .The unit.
continued to. operate at approximately 100% power throughout the inspection
g period.
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# Both Units.
On June 18, a meeting ~ was conducted in Atlanta with .the' licensee
concerning the 'recent discovery of the heat transfer problems ' associated
with both - Units 1 and 2 RSHXs. The meeting concluded. with' the NRC
satisfied that the actions already performed and the ones committed-to be
performed by the licensee were sufficient _to permit _ continued operation of
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y, both Units 1 and 2. ,
4. Review of.. Inspector Follow-up Items (92701)
(0 pen) ~ URI 338,339/88-11-02: Potential Inoperable. Recirculation Spray
Heat Exchangers. l A review was conducted by the inspectors of 1-PT-210.1 .
and 2-PT-21011 "Valve Inseivice Inspection (Service Water MOVs to:RSHX)". l
The inspectors reviewed the microfilm of the procedures back to 1985. - The
procedures had been deviated to allo- the heat exchangers to _ remain full
of. water af ter' the surveillance test ntrary to the commitments ' of the.
'UFSAR. which r. equi. red then drained and oiown dry with air. The inspectors
:could not find any completed 10 CFR 50.59 safety evaluations that. allowed
deviation of the procedure until October 1987 when a 10 CFR 50.59 safety
evaluation'was performed'to allow the deviation-to PT-210.1. This safety
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evaluation was inadequate in that it did not address .the fouling of the
heat exchangers as a potential problem.
The licensee later provided the inspectors with a safety evaluation
performed in 1980 which allowed the heat exchangers to be filled with
. primary grade water following the heat exchanger draining sequences. This
safety evaluation also did not address the heat transfer capability
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reduction due to increased fouling from the heat exchanger being wet
instead of dry.
In May 1988, following the partial CDA signal on Unit 2, (as discussed in
" Inspection Report 338,339/88-11, Section 10) which resulted in service
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waterf flowing through the .RSHXs, the inspectors requested a copy of the .
licensee's .10 CFR 50.59 safety evaluation to allow. deviation from the-FSAR
commi.tments to maintain the RSHXs in dry layup. This safety evaluation
concluded' that the previous evaluations had been inadequate;because .they -
did not address the decrease in heat transfer capability due to the
increase fouling from the heat 'exchangers being exposec' to service water.
The May 1988, safety es aluation .also determined that the design fouling.
factor for the RSHXs was 'zero- and .that based on the Tubular Exchanger
Manufacturers Association (TEMA) manual the fouling factor was actually
approximately 0.002 for the type of service water at North Anna. With
this fouling factor, the licensee determined that the ' service water
temperature could not exceed 84 degrees F and still have the heat transfer
capability of the RSHXs comply with the design basis in that containment
pressure would not necessarily be subatmospheric within an hour following
a design based Lo:s of Coolant Accident (LOCA). An investigation of
previous service water temperature records indicates that it is not
uncommon for service wa' 2r temperatures to exceed 84 degrees F during the
, hot summer months. ,
10 CFR 50.59 states in part that 4 licensee may make changes in. the
procedures as described in the safety analysis report without prior
Commission approval unless the proposed change involves a change in the
TSs incorporated in the license or an unreviewed safety question.
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proposed change shall be deemed to involve an unreviewed safety question
if the margin of safety as defined in the basis for a TS is reduced.
Final Safety Analysis Report (FSAR), paragraph .6.2.2.2.5 states in part
that in order to ensure long-term reliability of the recirculation spray
heat exchangsrs, following each periodic test of the heat exchanger inlet
and outlet valves (e.g. PT 210.1), the heat exchangers .are put in dry
layup by draining water through the beat exchanger drain valves and' then
purging the heat exchanger with compressed air until there is no visual
indication of moisture f rom the drains. TS 3.6.2.2 states in part that
the containment recirculation spray system shall be operable with four
separate and independent containment recirculation spray subsystems, each
composed of a spray pump, associated heat exchanger and flow path.
The failure of the licensee to perform an adequate 10 CFR 50.59 evaluatior
l' when periodic tests 1-PT-210.1 and 2-PT-210.1 were deviated to allcw the
heat exchangers to remain filled with service water constitutes a
violation and is identified as violation 338,339/83-16-01.
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The licensee has flowed each of the heat exchangers with service water and
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has completed a special procedure involving the heat exchangers being
- injected with chemicals tr remove any biological fouling. The heat
exchangers have been flushed, drained and blown down with service air. l
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The licensee power. engineering service, has written a letter to plant
! engineering stating that once the recirculation spray heat exchangers are l placed in dry layup and the surveillance program is established to ensure l they remain in dry layup, a service water temperature administrative limit p of 92 degrees F. is applicable based on a Jry fouling factor of .00075. l L
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' The licensee informed the inspector that based on. chemical analffis of-
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RSHX's ; flush water, the visual inspection of the RSHX, and calculation by
their contractor, they will revise their previous' evaluation of the worst
case fouling ' factor and the maximum allowed service water temperature.
This item . will remain' open pending the inspector's review of the
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reanalysis. ,
5. Monthly Maintenance (62703) -
Station mainte ince activities affecting safety related systems and
components were observed / reviewed, to ascertain that the activities were
conducted in accordance with approved procedures, regulatory guides and
industry codes or standards, and in conformance with Technical
Specifications.
No violations or deviations were identified.
6. Monthly Surveillance (61726)
.The inspectors observed / reviewed technic 11 specification required testing
and verified that testing was performed in accordance with adequate
procedures, that test instrumentation was calibrated, that limiting
conditions for operation (LCO) were met and that any deficiencies
identified were properly reviewed and resolved.
The inspectors reviewed portions of 2-PT-213.1 for the in-service
inspection of containment isolation valves. The following valves failed to
indicate shut:
2-TV-SS-206B (Hot Leg Sampin Valve)
2-TV-SS-212B (Steam Generator, Surface Sample)
2-TV-SS-20SA (RHR Sample Header Inside Containment)
2-TV-SS-200B (Pressurizer Liquid Space)
In all cases, the action required by TS 3.6.3.1 was taken. The other
valve in the line was closed and de-energized and a work request was
-written to perform necessary corrective action on the valve. The licensee
will be evaluating the operation and maintenance of these valvos to
determine the root cause.
The inspectors also reviewed 1-PT-24.1, Calormetric. No problems were
identified.
On May 24, the inspectors witnessed portions of the Unit 2 survaillance
test 2-PT-34.3, Turbine Valve Freedom Test. This procedure' verifies that
each of the turbine isolation valves will go shut when the auto stop oil
is bled off of the valve. This ensures that steam will be isolated to the
turbine following a trip signal which bleeds off the auto stop oil
pressure, to prevent turbine overspeed. During the test, two of the low
pressure turbine isolation valves failed to go shut when the test solenoid
was de-energized. The licensee determined that the test solenoid had
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-stuck in the closed position. The test solenoids were uastuck and the
. valves, were successfully stroked. The . inspector was able to determine,
based on discussions with the licensee, that the test' solenoid failure has
- no affect on the normal flow path for the auto stop oil during.an-actual
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-overspeed trip ' signal . Ccnsequently, a failure of a test: solenoid will
cnot prevent =or hinder an-actual overspeed protection isolation.
No violations or deviations were identified.
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7. ESF System Walkdown (71710)
The following selected'ESF systems were verified operable by performing a
walkdown of the accessible and essential portions of the systems on
June 7, 1988. The inspectors performed a walkdown of Chemical and Volume
Contrcl System using 1-0P-8.1A.
No violations or deviations were identified.
8. Operational Safety Verification (71707)
By observations during the inspection period, the inspectors verified .that
the control room manning requirements were being met. In addition, the
inspectors observed shif t turnover to verify that continuity of system
status was maintained. The inspectors periodically questioned shift
personnel relative to their awareness of plant conditions.
Through log review and plant tours, tne inspectors verified compliance
with seiected Technical Specification (TS) and Limiting Conditions for
Operations.
In the course of the monthly activities, the resident inspectors included
a review of the licensee's physical security program. The perfcrmance of
various shif ts of the security force was observed in ~.he conduct of daily
activities to include: protected and vital areas . access controls,
searching of personnel, packages and vehicles, badge issuance and
retrieval, escorting of visitors, patrols and compensatory posta.
The inspectors kept informed, on a daily basis, of- overall status of both
units and of any significant safety matter related to plant operations.
Discussions were held with plant management and various members of tile
operations staff on a regular basis. Selected portions of operating logs
and data sheets were reviewed daily.
The inspectors conducted various plant tours and made frequent visits to
the Control Roem. Observations included: witnessing work activities in
progress; verifying the status of operating and standby safety systems and
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equipment; confirming valve positions, instrument and recorder readings,
annuciator alarms, and housekeeping.
The following comment was noted:
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t _ (' stu'ck in the closed position. .The ' test solenoids were unstuck and the
. v>1ves were successfully stroked. The inspector was able to determine,
based on discussiens with the licensee,-that:the test solenoid-failure has
"" no affect on the normal flow pa'th for the auto .stop oil during an actual
overspee Trip signal . Consequently, a failure of a' test solenoid will
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not prevent or hinder an actual overspeedl protection isolation.
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No violations or ds.viations were identified,
7. ESF System Walkdown (71710)
The following selected ESF syr tems were verified operable by performing a
walkdown of the accessible > 1d essential portions of the systems on
June 7,.1988. The inspector s performed a walkdown of Chemical and Volume
Control System using 1-0P-8.1A.
No violations or deviations were identified.
:8. Operational' Safety Verification (71707)
By observations during tha inspection period, the inspectors verified that *
the control room manning requirements were being net. In' addition, the
inspectors observed shift turnover to verify that continuity- of system
status was maintained. The inspectors periodically questioned shift
personnel relative to their awareness of plant conditions.
Through log review and plant tours, 'the inspectors verified compliance
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with selected Technical Specification (TS) and Limiting -Conditions 1 for
Operations.
In the course of the monthly activities, the resident inspectcrs included
a review of the licensee's physical security program. The performance of
various shifts of the security force was observed in the conduct of. daily
activities to include: protected and vital areas access controls,
searching of personnel, packages and vehicles, badge. istuance and
retrieval, escorting of visitors, patrols and compensatory posts..
The inspectors k'ept informed, on a daily basis, of overall status of both
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units and of any significant safety matter related to plant operations.
Discussions were held with plant management and various members of the
operations staff on a regular basis. Selected portions of operating-logs
and data sheets were reviewed daily.
The inspectors conducted various plant tours and made frequent visits to
the Control Room. Observations included: witnessing work activities in
progress; verifying the status of operating and standby safety systems and
equipment; confirming valve positions, instrument and recorder readings,
annuciator alarms, and housekeeping.
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The fo'llowing comment was'noted:
On May 19, 1988, wFile testing - the 2J Emergency Diesel Generator (EDG)
following preventative maintenance (PM), che licensee discovered an oil
leak in the governor servo booster and a lagging interference with the
governor , linkage. Both ' contributed to the EDG failure to_ operate
properly. Consequently, the licensee shutdown the 2J EDG and commenced
unplanned corrective maintenance to correct the problems. The maintenance
was completed and th)'2J EDG satisfactorily. tested on the same day. -
Technical Specification (TS) 3.8.1.1.b requires, with one EDG inoperable,
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the operable EDG be tested within 24 hours if .the inoperable EDG- is
inoperable due. to any cause other than preplanned PM or testing. Since
the 2J EDG PM_had changed to unplanned corrective maintenance, then the 2H
EDG was required to be tested within 24 hours. On May 19, following the
satisfactory testing of the ' 2J EDG, an attempt was made to test the 2H
EDG. The attempt was unsuccessful due to a failure of the 2H EDG output
breaker to close. The licensee determined that the breaker closing spring.
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had not been charged due to a failure of the charging motor. The failure
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of-the charging motor resulted from mounting bolts becoming loose allowing
the notor to become unmounted from the breaker frame rendering it unable
to charge the' closing spring. The licensee determined that the last time
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the EDG output breaker had been closed was May 6 and that procedures did
' not require the operator to verify the closing spring had recharged.
Consequentiv, following the breaker manipulation on May .6 the charging
motor-failed to recharge the closing spring and the 2H EDG was inoperable
> until discovered and repaired on May 19. Also, with the PM commencing on
the 2J EDG on May 18, rendering it inoperable, the licensee had both Unit
2 diesels inoperable for approximately 38 hours.
The licensee's diesel output breaker is a 4160 vs't breaker manufactured
by ITE. This breaker failure and problem associated with the loose
mounting bolts was identified in NRC Information Notice Number 87-41 dated
August 1987 and INP0 SER '4-87 dated May 1987. However, the Information
Notice and SER discussed iailures ass,ciated with Brown Boveri breakers
and the licensee has ITE breakers. This resulted in some confusion even
though the licensee eventually realized that Brown Boveri had purchased
ITE. The INP0 SER 14-87 made the following recommendations:
a. Breaker receipt and preventive maintenance inspections should include
a tightness check of charging motor mounting bolts. When loose or
missing nounting bolts are found during preventive maintenance
inspections, the interval between inspections should be decreased,
and the creaker should be tested to verify operability.
b. Plants with Brown Boveri Type HK circuit breakers that find loose
charging motor mounting bolts should consider the use of a thread
adhesive and consult with Brown Boveri to determine torquing
requirements for the bolts. If thread adhesive is to be used, the
manufacturer recommends Loc-Tite number 242 or equivalent.
c. Operations personnel daily rounds should include a check of charging
motor mechanical indicators where available on safety-related
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breakers. lhese indicators should also be checked following
scheduled maintenance or testing.
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The_ licensee ' informed the inspectors that their response to the INP0 SER
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- involved an undocumented visual inspection of approximately ten non-safety
related and four safety related.4160v AC. breakers. This visual inspection
as reported to the inspectors did not identify any problems with the
charging motors. However, no wrenches were actually placed on the
charging motor mounting bolts to verify tightness. Also, the licensee
informed the inspectors that they felt that the present .PM procedure
. EMP-P-PH-01, Electrical Checkout of 4160 Volt Load Center Air Circuit-
Breaker, had sufficient instructions to verify the tightness of the-
charging motor mourting bolts. The inspectors review of EMP-P-PH-01
1 revealed that the only step that would perform this check was step 7.7
which simply states "check mechanical tigh; ness of breaker". This step
would not require a technician to specifically check the tightness of the
charging motor mounting bolts. Recommendation "C" of the INPO SER was not
addressed at all by the licensee. Implementation of.this recommendation
would have prevented the 24 EDG from being inoperable for several weeks
without the licensee's knowledge. A requirement to check that the closing
springs were charged following each operation or a requirement to eneck
that the breakers are charged on the daily rounds would have identified
the inoperable 2H EDG output breaker on May 6. This would have prevented
the licensee from operating Unit 2 at 100% power for 38 hours on May 18
- and 19 with two inoperable EDGs.
The licensee's response to Information Notice 87-41 ranged from not
applicable to North Anna, to, verify if North Anna's ITE breakers are the
same as Brown Boveri breakers. However, the only action that was taken
was -to contact Brown Boveri. This discussion with Brown Boveri is
documer.ted by memo from K. S. Berger, VEPC0, to F. C. Prince, VEPCO, both
of the corporate office, dated January 4, 1988. The memo states that
Mr. Roland Wintenberger of Brown Boveri (BB) informed tte licensee that no
potentially defective breakers have been supplied to North Anna. There-
fore, the memo concluded that the Information Notice was not applicable to
North Anna. The licensee also informed the inspectors that BB stated that
these breakers art good for 1000 cycles and none of the licensee's safety
related breakers are close to 1000 cycles. Based on the above paragraph,
it is clear that the licensee's response to the INP0 SER and NRC Informa-
tion Notice was not adequate to address the problem.
Following the 2H EDG output breaker f ailure, all the emergency 4160 volt
breakers for both units were verified tn be charged. The licensee is
presently developing a program for future surveillances and inspections of
the breakers including checking for tightness of the charging motor
mounting bolts.
The licensee is presently in the process of inspecting as many 4160 volt
AC breakers as allowed with the units operations. Of the 137 total safety
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L 'and non-sa'nty related breakers, 22 have been inspected and fourlhave'been
c identified-with loose mount _ing bolts. . One of the .four defective . breakers "
had one.'of the.three mounting, bolts:which.no' longer'made thread engagement-
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with.the. breaker frame. A second bolt'.was . loose but the charging motor T
... .was 'still firmly. mounted'. witn the third bolt. This -breaker was -
~ associated with the Unit 1A low head safety. injection pump. _
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T.S. 3.8.1.1 states in part as a minimum,1 the .following- AC electrical.
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power. sources- shall be operable; two separate. and independent -diesel'
generators. The failure of-the licensee to takeithe necessary corrective
action: to prevent failure .of the .I EDG output' breaker resulting in both'
, EDGs being inoperable for approximately 38 hours will be identified as:-a
Violation 339/88-16-02.
'No other violations or deviations were identified.
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