ML20246J107

Rev 0 to Response to NRC Ltr of 890626,Serial 89-485,App C, Finding IC-7

ML20246J107
Person / Time
Site:	North Anna
Issue date:	07/18/1989
From:	Mcbride W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:
Shared Package
ML20246J098	List: ML20246J091 ML20246J099 ML20246J107 ML20246J119 ML20246J126 ML20246J139 ML20246J148 ML20246J158
References
89-485, EE-0020, EE-0020-R00, EE-20, EE-20-R, NUDOCS 8909050038
Download: ML20246J107 (7)

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. TECHNICAL REPORT NO. EE-0020 - REVIS DN 0 RESPONSE TO THE NRC LETTER OF JUNE 26, 1989 SERIAL #89-485, APPENDIX C, FINDING IC-7 ELECTRICAL ENGINEERING

-POWER ENGINEERING' SERVICES VIRGINIA POWER

. JULY 14, 1989 Prepared By: -

Date: f//8[89 Independent Review By:_ o Date: '7- / N-89

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l QA CATEGORY - SAFETY RELATED I-KEY WORDS: NRC Letter f89-485 l

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k' 1.0 . INTRODUCTION 'l R

j 2.0 METHOD 0LOGYi

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3 1 RESULTS  !. 2 :

4.0 CONCLUSION

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- 5.0 ' REFERENCES- 3 Attachment l'.NRC Letter 89-485 Finding-IC . .

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1.0 INTRODUCTION

Lg The~ purpose -of this Technicul Report is to respond to the Nuclear, i

L, Regulatory Commission .(NRC) letter of June 26, 1989, Serial' #89-485, Appendix C, Finding IC-7 (Attachment 1).

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l 2.0 METHODOLOGY During- the 1987 ' review by the NRC for equipment qualification'(EQ) compliance at North Anna Power Station, a violation of 10CFR50.49(j)

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was found. 10CFR50.49(j) requires a record of electrical equipment-performance requirements (QDR) under conditions existing during and following' design basis accidents be maintained in an'auditable form.

VEPCO-comitted to. revise the engineering standard that describes the' requirements' for QDR packages by August 31, 1988, and define.

performance requirements and incorporate them into the_QDR packages by December 30, 1989. The specific performance requirement in question during the SSOMI audit related to cable leakage currents and the effect on instrument loops operating in a harsh environment. A review of the standard was performed and a status of performance requirements was made.

A review of previous correspondence from VEPC0 to the NRC on SSOMI topics was performed. It appears that the June 26, 1989 NRC letter was written prior to receiving all of the related VEPC0 correspondence.

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'3.0oRESULTS A review' of STD-GN-0025, " Equipment Qualification' . Standard".(see'-

' Appendix C Section'2.3), revealed 'that performance characteristics-(requirements) had been incorporated into the revision of August 31, 1988.

1 Guidance; on when to perform instrument loop. calculations and what is..

included in a calculation was established in Technical -Report Number' s

EE-0019..

In the VEPC0 letter to the NRC dated May 15,'1989,'(Serial.#89-206C),

calculations were presented which demonstrated that cable leakage currents were included in harsh environment circuits.

4.0 CONCLUSION

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Engineering standards have been developed that provide a methodology for calculating, documenting, and reviewing changes to setpoints.

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- Setpoint calculations, which included cable leakage current, were 1:

i; _ performed on loops that function in a harsh environment and found to be acceptable.

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O .s 5;0 REFERENCES i.1 i5.l VEPC0 g STD-EEN-0304-11 5,2' VEPC0 STD-GN-0030 5.3 l Attachment 1 - NRC letter to VEPCO dated June 26,'1989,

. Serial #89-485, > Appendix C, Finding. IC-7 15.4 VEPC0 letter to the NRC dated.May 15, 1989, i

. Serial #89-206C' 515':VEPC0fletter to the NRC dated May 19 1988,

, Serias ' #88-230, Violation D' 5.61 VEPC0-STD-GN-0025-f74.WTM.0020-

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51311ar requirements for 30 day reports are identified. in 10 CTR 50.73(a)(2)(ii)(B)or-(v)(B).'

References:

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-(1) VEPCO Deviation Report 87-1452,. December 22, 1987 VEPCO Design Change 84-43-3 ' Service Water Reservoir Improvements, (2) Final Sys?am Tie-in and Startup/ North Anna Units 1&2" i

'(3)-VEPCODeviationReport 87-1405, December 8, 1987 FINDING IC-6: Inadequate Operator Training and Simulator Modeling.

(Unresolved Item 89-200-05).

Discussio;n 87-1405 associated with

.As a result of the team's review of. Deviation Report'DC 84-43-3, a qu Report 87-1405. identified the failure of a service water. bypass motor-operated VEPC0 investi-valve to close an initiation of a signal from the control room.

' fatiure to chse was that the operator did not realize that the throttleable and that thr. circuitry for the valve does not have a seal-in '

satact, the operator has to continually hold the contact (without a seal-tc handswitch in the open oratosed position to move the valve.to the fully open crclosedposition).

During the inspection, the team determined that reactor operators had receive training on.the new service water reservoir spray and bypass system but that A training did not specifically cover the operation of.the particular valves

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In addition, when the simulator was changed several months -later in 'uestion.

to reflect the service water system changes, the bypass valves were incorrec Theedtemrometas open .

modeled'with seal-in versus throttleable circuitry.

pendtem VEpCG correctias,the s4msteter hypoor vet wheel > switches heemses&4s veesus throttleeMe stres$ err.

Regulatory Basis:

10 CFR Part 55.11 requires reactor operators be trr,ined in the operation plant systems.

References:

.(1) VEPC0 Deviation Report 87-1405, December 8, 1987 FINDING IC-7:

Inadequate Loop Accuracy Calculation for Charging Flow Instrumen (Unresolved Ites 80-200-06)

Discussion:

During the inspection, the team reviewed portions of Design Change 8 pertaining detector.

to the installation of a new charging flow differ C-6 I

new detecttr and its effect en the ovarall instrument loop accuracy. During the review the team found that Calculation EE-0048 perforined for determining the instrument loop accuracy, did not consider the effects of current leakage due the degradation of the cable insulation system in a postulated harsh environment. In a postulated harsh environment, cable insulation resistance decrease which increases leakage currents and cause a corresponding decrease in instrument accuracy. TMs, was a repeat of violation 87-32-03 cited in NRC Inspection Report 50-338/87-32 and 50-339/87-32. During that inspection VEPCO was cited for failing to address the effects of characteristics such as leakage currents on total loop instrument accuracy calculations. In a response to this violation, submitted to the NRC on May 19, 1988, VEPC0 committed to revising Engineering Standard STD-N-0025 by August 31, 1989, as necessary to preclude further violations. This standard had been changed; however, the changes made appeared to be inadequate for ensuring that loop accuracy csiculations would be correctly perforined when changs were made to environmentally qualified systems.

Calculation EE-0048 was performed after the standard was changed.

As a result of this finding, VEPC0 performed a new calculation which included the effects of the cable leakage currents. This calculation showed that the cable added an additional 0.3 percent to the previously assumed error of 5 percent. TMs iten remn6ms open pending VEpCG'st revlam et othee prov$eur changes to the fetility uMob may have affectae insteumontestes loope WettEqP

in a hereb environment; Also, VEp e te regnestee te tsomo e r r M ; :: --

dura fee - ' i pos&thill'tp.e6 adshe$asteumano r errore tr future modifient6eas.

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Regulatory 8 asis:

10 CFR 50.49(d)(1) requires that the qualification file for electrical equipment important to safety specify the performance requirements under conditions exist-ing during and following design basis accidents. 10 CFR 50.49(j)(2) requires that the qualification file for electrical equipment important to safety demonstrate that the equipment meets its specified perforinance requirements.

References:

(1) VEPCO Design Change 87-29-2, "CRDR Instrtssentation Range Changes, Marth Anna Unit 2." November 3, 1988 (2) YEPC0 Calculation EE-0048, " Instrument on Channel Accurscy for Charging and Letdown Flow," Revision 0, February 10, 1989 (3) NRC Inspection Report 50-338/87-32 and 50-339/87-32 November 25, 1987 (4) VEPC0 Letter to MtC. Serial No.88-230, May 19,1988 (5) VEPC0 Response IAC-002, 'IR Loss in Cable " February 16, 1989 (6) VEPCO Standard STD-GN-0025. " Equipment Qualification Standard", Revision 6 Change 2. October 13, 1988.

FINDING IC-8: Inadequate Pest Modification Test Program.

(Unresolved Item 89-200-07):

C-7

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