ML20244C721
| ML20244C721 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 06/09/1989 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8906150112 | |
| Download: ML20244C721 (4) | |
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VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 June 9, 1989 U. S. Nuclear Regulatory Commission Serial No.89-433 Attention:
Document Control Desk NO/SEC/JDH R3 Washington, D.C. 20555 Docket Nos. ' 50-338 50-339 License Nos. NPF-4 NPF-7 VIRGINIA ELECTRIC AND POWER COMPANY l
NORTH ANNA POWER STATION UNITS 1 AND 2 l
CEMENI ESF SLAVE RELAY TESTING On June 9,1989, a conference call was held between NRC Region ll, NRR, the North Anna senior resident inspector, and Virginia Electric and Power Company staff to discuss North Anna Unit 2 Technical Specification 3/4.3.2.1 regarding Engineered Safeguards - Features (ESF) slave relay testing on-line.
The discussion was a followup to a June 5, 1989, meeting in Rockville, MD, held between NRC and Virginia Electric and Power Company to discuss our May 8,1989, license amendment request on this issue.
The license amendment request addressed a discrepant condition we discovered between UFSAR statements regarding on-line testing of slave relays and our interpretation of the Technical-Specification.
North Anna has not performed on-line slave relay testing as described in the UFSAR since the initial startup of each unit in 1978 and 1980.
The May 8, 1989 submittal requested a license amendment to clarify the requirement for testing slave relays and provided justification for the elimination of the on-line testing requirement in the UFSAR.
Based on the June 5,1989 meeting and the June 9,1989 call, we are revising our interpretation of the requirements for meeting Technical Specification 3/4.3.2.1 to be consistent with NUREG 0452, Rev.
4, Standard Technical Specifications for Westinghouse Pressurized Water Reactors.
However, in order to develop the
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1 necessary procedures and assure minimum impact on the operation of the unit during testing, we need additional time to prepare for l
implementing the test program.
The additional time will also allow-L us to more fully check out the Unit 1 Safeguards Test Cabinet, since Unit 1 is currently in its refueling outage.
Therefore,.we intend to i
take the following actions no later than August 11, 1989:
i Develop a comprehensive list of those relays that can be tested j
l on-line, and provide a basis for not testing the remaining relays Develop required testing procedures 1
Provide the test plan and schedule-to the NRC for review Test those Unit 2 relays that are finally determined to be testable on or before August 11, 1989 Test those Unit 1 relays that are final!y determined to be testable '
within 90 days of entering Mode 4 following the current refueling outage 1
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Following NRC revisw and approval of the test plan and schedule, any I
required UFSAR and Technical Specification changes will be submitted.
J Technical Specification 3/4. 3.2.1 requires that the on-line testing be conducted no later than June 11,1989 (including the additional time permitted under Specification 4.0.2).
We ' have determined that an additional sixty day period is required in order to implement the' actions described above.
Therefore, Virginia ' Electric ' and Power Company requests one-time discretionary enforcement from the requirements of Technical Specification 3/4.3.2.1 for -sixty days.
The basis for the additional sixty day period is provided below.
North Anna Unit 2 returned to power operation from its 1989 refueling outage on May 9,1989. During the outage, the ESF systems were functionally tested, including the actuation of the safeguards equipment via the slave relays.
The current interval for conducting-
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i such testing in the Standard Technical Specifications is quarterly.
Currently, Technical Specification 3/4.3.2.1 requires Reactor Protection System testing every 62 days on a staggered test basis.
J However, on-line slave relay tests were not factored into our test j
program and supporting procedures because of our previous j
interpretation of the Technical Specifications.
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Application of the test interval described in the Standard Technical I
Specifications on a one-time basis corresponds to the end of the
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first operating quarter for North Anna 2, i.e.,
August 11,1989. Thus, the period requested would not be outside the previously analyzed and accepted test interval for ESF systems as described in the Standard Technical Specifications.
In addition, a Westinghouse study, WCAP-10271-P-A, Supplement 2, Revision 1, " Evaluation of Surveillance Frequencies and Out of Service Times for the Engineered Safety Features Actuation I
System," supports quarterly testing of slave relays, in addition, it addresses the potential for extending the surveillance interval to 18 months with little negative effect on core melt frequency or safety system unavailability.
The study includes an NRC Safety Evaluation Report which endorses the quarterly test frequency for slave relay testing.
Finally, based on operating experience, the actual North Anna failure rate of relays has been acceptably low, and currently performed on-line testing will continue to be performed on a 62 day staggered test frequency.
It should also be recognized that the power supply demand for the Virginia Electric and Power Company grid has been unusually heavy due to the extremely hot / humid weather in the southeast portion of the U.S.
This, coupled with the number of large generating units currently unavailable, has already resulted in voltage reductions and is expected to continue to challenge our ability to meet demand.
Because of this, we believe it is prudent not to unnecessarily challenge the operating unit until the additional actions described l
above can be completed and there is reasonable assurance that the additional testing will not adversely affect unit operation.
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l This request for discretionary enforcement has been reviewed by the
- j Station,- Nuclear Safety and Operating Committee.
If you have any.
questions or require additional information, please' contact us-immediately.
Very truly yours, I
L,-
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W. L. Stewart cc:
U. S. Nuclear Regulatory Commission 101 Marietta Street, NW Suite 2900 Atlanta, Georgia, 30323 Mr. J. L. Caldwell NRC Senior Resident inspector North Anna Power Station l
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