ML20207L808

Safety Evaluation Supporting Amends 219 & 219 to Licenses DPR-32 & DPR-37

ML20207L808
Person / Time
Site:	Surry
Issue date:	03/12/1999
From:	NRC (Affiliation Not Assigned)
To:
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ML20207L788	List: ML20207L786 ML20207L808
References
NUDOCS 9903180281
Download: ML20207L808 (4)

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UNITED STATES

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NUCLEAR REGULATORY COMMISSION t

WASHINGTON, D.C. 20555-0001 SAFETY EUALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 219 TO FACILITY OPERATING LICENSE NO. DPR-32 AND AMENDMENT NO. 219 TO FACILITY OPERATING LICENSE NO. DPR-37 VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION. UNIT NOS.1 AND 2 DOCKET NOS. 50-280 AND 50-281 j

1.0 INTRODUCTION

By letter dated September 24,1998, the licensee, Virginia Electric and Power Company (VEPCO), proposed an amendment to the operating license of Surry Power Station, Units 1 and 2, to revise the plant Technical Specifications (TS). The proposed changes modify the testing sequence requirements for the reactor trip bypass breaker.

2.0 BACKGROUND

On July 8,1983, the NRC issued Generic Letter (GL) 83-28, " Required Actions Based on Generic Implications of Salem ATWS Events." Item 4.3 of GL 83-28 became the subject of

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GL 85-09, " Technical Specifications for Generic Letter 83-28, item 4.3." GL 85-09 specified i

additional maintenance and testing of the reactor trip and reactor trip bypass breakers.

On October 30,1997, a compliance issue was identified concerning the testing sequence of the reactor trip bypass breakers at Surry. The reactor trip circuit breaker elements have three designated positions (Disconnect. Test, and Connect) in the switchgear cell, in order to

' accommodate seismic qualification, the reactor trip bypass breaker is normally physically racked into the Connect position with contacts open. From approximately June 1986 until October 1997, the manual undervoltage trip test at Surry was performed immediately after closing the bypass breaker. Thus, when the bypass breaker was closed to perform the test, the breaker was actually in-service for that very short period of time. This testing sequence was identified in Deviation Report S-97-3167 as not being in compliance with the TS Surveills.nce Requirement of Table 4.1-1, item 36, Note 1, which requires a remote manual undervoltage trip of the bypass breaker prior to placing the breaker in service. Licensee Event Report S1-97-011-00 dated November 26,1997, and Non-Cited Violation 50-280, 281/97012-04 were also issued to I

address this noncompliance.

In response, the licensee modified the manual undervoltage testing sequence. The modified test sequence requires the reactor trip bypass breaker to be racked from the Connect position to the Test position. The bypass breaker is then closed and tripped manually using the 9903190281 990312 PDR ADOCK 05000200 P

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I undervoltage device. After the undervoltage test, the bypass breaker is returned to the Connect position and closed, thereby placing the breaker in service for testing and maintenance.

In order to implement the modified test sequence, the licensee notes that moving the reactor trip

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bypass oreakers to the Test position and then back to the Connect position increases wear on breaker components and increases chances of mishandling since the 340-pound circuit breakers are awkward to move. The licensee points 'out that the Westinghouse Vendor Technical Manual reports damage due to mishandling including bent positioning stop brackets, element positioning levers, release latches, miscellaneous brackets, pins, and stops as well as misalignments of the cell rails and the breaker elements.

The licensee has addressed the above concem in the proposed TS change discussed below.

3.0 PROPOSED CHANGE

AND EVALUATION The reactor trip switchgear consists of two teactor trip breakers and two bypass breakers in a series / parallel arrangement. The bypass bmakers are connected in parallel with their respective l

reactor trip breaker and they are interlocked so that caly one bypass breaker can be closed at a time. In addition, licensee procedural controls prevent closing of both reactor trip bypass l

breakers at the same time.

Proposed Chanoe: Revise Note 1) for item 36, " Reactor Trip Bypass Breaker," in Table 4.1-1 as j

follows:

1) Remote manual undervoltage trip immediately after placing the bypass breaker into service, but prior to commencing reactor trip system testing or required maintenance.

Evaluation:

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in its submittal, the licensee stated that the proposed change to the TS notation will return the test sequence to the original testing sequence which was followed until October 30,1997. In addition, the proposed change will clarify that the bypass breaker manual undervoltage test is coordinated with the trip breaker functional test to ensure that the bypass breaker is tested prior to its associated trip breaker.

The proposed change clarif.es the bypass breaker testing sequence regarding Note 1) for item 36 and resolves the " noncompliance" state identified in October 1997. Testing without racking the breaker to its test position eliminates unnecessary movement, thus reducing wear of components and alignment problems caused over time due to repeated rack-in and rack-out operations. The licensee stated that although the proposed test sequence will render the bypass breakers in service status for a short time before the remote manual test, the operability of the breaker is established by a satisfactory test conducted during the previous surveiitance interval.= The word "immediately" in the Note will reduce test time to a practical minimum to reestablish the bypass breaker's operability prior to beginning reactor trip system testing or

- maintenance activMies. The proposed revision to the Note is acceptable to the staff, as it meets the intent of the TS-required testing for the reactor trip bypass breakers.

1 g... Based on review of the licensee's submittal, the staff concludes that the proposed TS modification for the test sequence and the mised notation for the reactor trip bypass breaker testing will ensure that proper breaker testing is conducted per TS-required surveillances. In addition, the proposed changes will provide clarification for coordinating the trip breakers and bypass breakers functional tests as originally intended in the TS. Therefore, the staff finds the proposed TS change acceptable.

4.0 blATE CONSULTATION in accordance with the Commission's regulations, the Virginia State official was notified of the proposed issuance of *.he amendments. The State official had no comment.

5.0 ENVIRONMENTAL CONSIDERATION

These amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that these amendments involve no significant hazards consideration and there has been no public comment on such finding (64 FR 6715). Accordingly, these amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact statement or

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environmental assessment.ieed be prepared in connection with the issuance of these amendments.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such cctivities will be conducted in compliance with the Commission's regulations, and (3) the ssuance of these amendments will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: A. Bryant Date: March 12,1999 i

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5 DATED: March 12,1999 AMENDMENT NO. 219 TO FACILITY OPERATING LICENSE NO. DPR SURRY UNIT 1 AMENDMENT NO. 219 TO FACILITY OPERATING LICENSE NO. DPR SURRY UNIT 2 (Dochet FNeb PUBLIC PDll-2 Rdg.

J. Zwolinski E. Dunnington G. Edison H. Berkow.

OGC G. Hill (4), TWFN,5/C/3 W. Beckner ACRS A. Bryant, DRCH R. Haag, Ril C. Norsworthy (e-mail RCN - SE only) 1 l

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