ML20246J099

Rev 0 to Response to NRC Ltr of 890626,Serial 89-485,App C, Finding IC-2

ML20246J099
Person / Time
Site:	North Anna
Issue date:	07/18/1989
From:	Mcbride W, Michael Reynolds VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:
Shared Package
ML20246J098	List: ML20246J091 ML20246J099 ML20246J107 ML20246J119 ML20246J126 ML20246J139 ML20246J148 ML20246J158
References
89-485, EE-0019, EE-0019-R00, EE-19, EE-19-R, NUDOCS 8909050037
Download: ML20246J099 (4)

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s-7i TECHNICAL REPORT NO. EE-0019 - REVISION 0 d

RESPONSE TO THE NRC LETTER OF JUNE-26, 1989 SERIAL #89-485, APPENDIX C, FI NIN IC-2 ELECTRICAL EMINEERIM.

POWER EMINEERIM SERVICES VIRGINIA POWER JLE.Y 14, 1989  ;

Prepared By: b./ M b Date: ~f /

/89 Independent Review By: M[ [ Date: 7- /8-8S 8

Approved By: [M i Date: k/f/49 I

Q4 CATEGORY - SAFETY RELATED

'yj KEY WORDS: NRC Letter #89-485 89090 BOO 37 890825 DR ADOCK 0500 $ g L___________________________.______ _ >

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TABLE OF_ CONTENTS i-f ..

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1.0 INTRODUCTION

1 2.0. METHODOLOGY -1 3.0 RESULTS. 1 4.0 . CONCLUSIONS 2

'5.0. REFERENCES 2

, Attachment 1 NRC Letter #89-485 Finding IC-2

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1.0 The purpose of this Technical Report is to respond to the Nuclear Regulatory Commission (NRC) letter of June 26, 1989, Serial #89-485, Appendix C, Finding IC-2 (Attachment 1).

2.0 METHODOLOGY A detailed analysis of- Westinghouse methods (NSSS supplier) for performing instrument uncertainties was conducted. Additionally, Instrument Society of America (ISA) standards and recommended

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practices were utilized in developing methodology and control r documents for setpoints.

3.0 RESULTS The investigation of the Westinghouse methodology and ISA documents resulted in the development and issue of two standards. STD-EEN-0304,

" Calculating Instrumentation Uncertainties By the Square Root of the Sum of the Squares", was developed to provide a consistent, conservative method to address the error associated with setpoints.

STD-GN-0030, " Revising Nuclear Plant Setpoints", was developed to identify the requirements for calculating, documenting, and reviewing changes to setpoints.

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4.0 CONCLUSION

S The standards identified in 3.0 above have been developed to provide methodology for development and control of setpoints. STD-EEN-0304 was issued for use on April 14, 1989, and STD-GN-0030 was issued on April 29, 1989.

5.0 REFERENCES

5.1 STD-EEN-0304 I A

5.2 STD-GN-0030 t 5.3 Attachment 1 - NRC letter dated June 26, 1989, Serial #89-485, Appendix C Finding IC-2.

74-WTM-0016

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Juna 26, 1989 ooooo ,. ", t. .

[h 3 _Mg, Docket Nos. 50-338 ane 50-339 Jhe'd.) JiiN 2 9 m Mr. W. R. Cartwright - ^

j Nuclear Operations Vice President-Nuclear .

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Glen Allen, Virginia 23060

Dear Mr. Cartwright:

NORTH AiglA POWER STATION, UNIT 2 - SAFETY SYSTEM OUTAGE

SUBJECT:

50-339/89-200 M(BIFICATION INSPECTION (CESIGN) -

This lesser conveys the results' and conclusions of th Station' unit 2 conducted by the NRC's Office of Nuclear Reactor Regulation.

The inspection The inspection team consisted of Mtc personnel and consultants.

was conducted primarily at your engineering offices in Richmond, Virginia .

during the periods February 13-17 and February 27 - March 3,198g and was augmented with a 1-day site visit.

The purpose of the design portion of the 550MI was to examine, on a sa basis the detailed design and engineering that were required to supportIn ad modifications impionssted during theA outage.of separate report the.550MI, will be this offic test activittas for Unit 1 during its outage.

published detailing that phase of the SS0MI.

Section 1.3 The report is organized.to present the findings in three formats.

provides d16cipline.

an overview of the team's activities and suem The items of concern in terms of weaknesses ane strengths, respectively.

identified by the team during the inspection have been classified as fine and are referenced throughout the report ans presented in detail in b separete correspondnece dated March 17,1989 you were advise findings characterized as " safety-significant Your response of March matters 31 1989* which resultedneeded addressed is as eagediticus manner.in the week of a Regies 11April 3,19N.1989 confituatory inspe Also your letters of April 13,1989 and Aprij 28 information findings.

with regard to your actions and consItsen provided in the enclosed Executive Summary.

Of particular concern to the team were findings related to impro motor operated valve actuators and improper isolatten The motor-operated valvebetween instrument that was powered from a Class 1E bus.

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Mr. W. R. Cartwright June 26, 1989 actuator issue has resultee in the resetting of torque suitches es well as the need for new tongue switch spring packs for certain valves in the service water system. The improper isolation has resulted in the replacement of the associated fuses with ones qualified as Class 1E. Additionally, VEPC0 needs to assess the pervasiveness of taproper isolation of nonclass 1E components powered from Class IE buses at the North Anna facility.

NRR is planning to reinspect the findings addressed herein. Once your response to this inspection report is received a schaeale will be established. Some of the identified items may be potentici enforcement findings. Any enforcseant actions will be identified by Region 11 in separate correspondence.

A safeguards finding is being transmitted to you under separate cover.

In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosure will be placed in the NRC Public Document Room.

You are requested to respond to this office within 60 days regarding the unresolved items in Appendix C and weaknesses in Section 2 ictentified in the encloses inspection report. Should you have any questions concerning this inspection, please contact the NRR Project Manager, Leon Engle or Ron Parkhill of the NRC staff. Messe s. Engle and Parkhill can be reached at (301) 4g2-1484 and (301) 4g2-0g53, respectively.

Sincerely, _

1 Division of Reactor is - I/II Office cf leclear Rea Regulation

Enclosures:

1. Executive Susunary

2. Inspection Report 50-33g/89-200 cc w/ enclosures:

See next page i

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April 28. Ig8g response indicated that they had confirmed the adequacy As aof all safety-rel(ted MOVs that had been replaced or modified for U2ft 2.

result of this generic review. VEPC0 indicated that additional torque switch.

setting changes were required. This item remains open pending completion of a sistlar reviour42,Jh1L.1.MVs that were replaced or modified.

Regulatory Basis:

Criterion III of 10,CFR 50 Appendix B requires that measures shall be established to assure that applicable regulatory requirements and design bases are correctly transferred into specifications, drawings and procedures.

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References:

(1) VEPC0 Design Change 84-43-3. " Service Water Reservoir Improvements. Final l System Tie-In and Startup/ North Anna Units 1&2.*

(2) VEPC0 Specification No. MS-2018. " Specification for Motor Operated Butterfly Valves for Service Water Reservoir Spray and Bypass System Isolation Valves /horth Anna Power Station Units 1 & 2." Revision 1.

FI NING IC-H; Setpoint Calculation omissions and L.ack of an Approved Prepas (Unresolved Item 8g-200-02).

for Perforw ng Setpoint Calculations. .

Discussion:

The team reviewed DC 87-2g issued for control room ongs desi pthereview ranges (CRDR) of a instrumentation range changes. This DC was issued to c few Class IE transmitters, replace the charging flow The transmitters team noted and the add a square-root extractor in charging flow loop.

following:

a. The loop accuracy calculation performed for the charging flow loop did not include measurenant and test equipment (MTE) accuracy.

including

b. The accurscy calculation had many unverified assumptions allowances for uncertainties in process variables following a design basis-event, calibration period 1steous pressure and charging pressure. Also, the team noted that there was no existing program for tracking and resolving these assumptisme before making the modificaties operable.

c. The effect of instrumentation range changes on the associated setpoints was not evaluated.

Subsequent to inspection teen's finding, VEpCO engineers performed s calculations for transmitters which had undergone range changes for DC and these calculations were acceptable.

The team requested to review the plant's setpoint calculations, but only emergency operation procedure (E0p) indicating instruments unc tions were provided. These calculations used assumed values of drift of vendor-published actual values as related to the surveillance freq each loop. Also, these calculations used assumed values for calibration accuracy.

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.The team believed that VEPC0 should hava a corporate procedurv fcr perfcraing The team

" engineering evaluations of setpoints resulting from design changes l procedure dev01oped.

had bene previously identified by VEPC0 and was currentl l safety-related systems would be reviewed as part of the design bases reconsti-tution (DBR) progres scheduled to tu comeleted within the next 3 to 5 years.

To ensure that safety-related setpoints had not been adversely affected since the plant was licensed and since the DBR program was not scheduled for the immediate future, the inspection team requested VEpC0 to review 10 safety-related MC loops.

VEPC0's response of March 31, 198g, couaitted to develop a controlled procedure for performing setpoint calculations and to review all modifications Alse for in thethis outage to ensure setpoint calculations were properly performed.

April 28. Iges response. VEPC0 confirmed that the 10 setpoin safaty.

The inspection team revisW64 tsc :2inistrnive procedures. EEN-0211 for sotpoint documentation and ADR-6.6 for administrative control o changes.

una:thortred changes to so w ints and an efficient way for documentation of s:tpoint changes.

Tbde.

reenins. egen penmay 98ptre MMsNNie'oh p 'fbr geefase6es setpoint salesdattempt Reevlatorv Basis:

Criterion III of Appendix 8 to 10 CFR 50 states, in part. " Design changes, including field changes, shall be subject to design control procedures commensurate with those applied to the original design...".

ANSI N4g.2.11. section 8 Design chang control states, in part. ' Documented procedures shall be provided for destgn changes to approved design docu including field changes, which assure that the impact of the change is care-fully considered...".

References:

(1) DC 87-2g ,

23. 1987 (2)

VEPCO, Setpoint Document Standard EEN-0211. Revision 1. November (3)

VEPCO, Admiststrative Procedure for Satpoint Changes AIM-6.8.

NonClass IE Loads Connected to Class 1E Suses Without Proper FIN 0!NG IC-3:

Isolation. (Waseselved,Itas,88-200-@).

Discussion:

DC 86-34-3 renovated the common service water system for North including installation of eight pressure transmitter loops, four temperatu C-3

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