ML20134F598

Provides Listed Info & Documents Delineating Staff Actions on Items Initiated by Late C Morris.Differing Professional View That Originated from C Morris Concern Re Catawba Breaker Miscoordination Also Encl

ML20134F598
Person / Time
Site:	Catawba, Three Mile Island
Issue date:	11/04/1996
From:	Varga S NRC (Affiliation Not Assigned)
To:	Morris C AFFILIATION NOT ASSIGNED
References
CON-#197-18045 2.206, DD-96-12, NUDOCS 9611070045
Download: ML20134F598 (1)

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NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20666-0001 M a S

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Mrs. Carol V. Morris 6516 Roy Shafer Road @

• Middletown, Maryland 21769 11 @

Dear Mrs. Morris:

As discussed between you and Mr. James F. McDermott of the NRC Office of Personnel, I am providing the following information and enclosed documents delineating the staff's actions on the six items initiated by your late 4

husband, Mr. Charles Morris.

Two letters from Mr. William T. Russell to you close out two of the six items raised by Mr. Morris: (1) July 25, 1996, regarding Three Mile Island Ur,it 1 4

safety concerns; and (2) September 17, 1996, regarding residual voltage transfer capabilities. In his letter dated April 10, 1996 addressing the Three Mile Island Unit I safety concerns, Mr. Morris asserts misfeasance on the part of the staff in the apparent suppression of a safety evaluation that he prepared during his employment as an NRC reviewer. On September 23, 1996, the staff referred this assertion to the NRC Inspector General for his consideration.

l A third item was initiated by Mr. Morris' letter dated June 18, 1996, where he  !

asserted that the staff did not properly disposition the potential safety l issues that he had raised in his petitions filed pursuant to 10 CFR 2.206. He also asserted that the staff mishandled issues while he was employed with the NRC. On August 23, 1996, the staff referred these assertions to the NRC Inspector General for his consideration.

I am also enclosing two Director's Decisions addressing the two petitions filed by Mr. Morris under 10 CFR 2.206. These Director's Decisions complete the staff actions for another two of the six items:

1. September 26, 1996, regarding undervoltage relay setpoint error at nuclear plants.

2. October 10, 1996, regarding Catawba breaker miscoordination.

Completed staff action for the sixth item, a Differing Professional View that originated from Mr. Morris' concern about the Catawba breaker miscoordination, is also enclosed.

Sincerely, f

veN a, Dir tor ivision of Reactor rojects - I/II Office of Nuclear Reactor Regulation

Enclosures:

As stated (5)

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NUCLEAR REGULATORY COMMISSION j z WASHINGTON, D.C. 20066 4001 l k...../ September 26, 1996 l

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l Mrs. C. Morris 6516 Roy Shafer Road

, Middletown, Maryland 21769  ;

Dear Mrs. Morris:

This letter is in response to the Petition filed by your husband on March 5,

1996. His Petition was considered pursuant to Section 2.206 of Title 10 of the Code of Federal Reaulations (10 CFR 2.206). In his Petition, Mr. Morris requested that the operating licenses of all nuclear power plants be suspended l

within 90 days and remain suspended until such time as the licensees of those j plants have (1) discovered the reason for what he asserted are repeated errors I in the undervoltage relay (UVR) setpoints (SPs) and electrical distribution  !

system (EDS) designs and (2) provided convincing evidence that these j deficiencies have finally been corrected. Since he had requested action {

within 90 days, his request was treated as a request for immediate relief. He i also requested that the aforementioned evidence be reviewed by a competent l third party, in addition to the U.S. Nuclear Regulatory ComMssion (NRC) l' i staff, and that if the NRC staff concludes that plants may safely operate with UVRs that cannot be properly set for long periods, the NRC should reach these l conclusions by way of a public meeting.

4 In a letter dated April 17, 1996, he was informed that his request for the

suspension of all nuclear power plant licenses within 90 days for the purposes

of remedying repeated errors i- UVR SPs and EDS designs ci those plants was denied because licensees have, to a large degree, already addressed the issues that he had raised. Also, he was informed that his request was being evaluated pursuant to 10 CFR 2.206 of the NRC's regulations and that a decision, as provided for in 10 CFR 2.206, would be made on his request within j a reasonable time. -

For the reasons given in the enclosed Director's Decision, his Petition has .

been denied. A copy of the decision will be filed with the Secretary of the l Commission for the Commission's review in accordance with 10 CFR 2.206(c). As l 1

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.l Mrs. C. Morris  ;

provided by this regulation, the decision will constitute the final action of I i the Commission 25 days after the date of issuance of the decision unless the 1 Commission, on its own motion, institutes a review of the decision within that i

time. A copy of the notice of decision that is being filed with the Office of  ;

j the Federal Register for publication is also enclosed. '

Sincerely, i

i

)4)h-s k William T. Russell, Director Office of Nuclear Reactor Regulation

Enclosures:

1. Director's Decision DD 12

2. Federal Reaister Notice i cc w/encls: See next page l 1

i

I

! =,

i cc:

Mr. Charles H. Cruse Calvert Cliffs l Vice President, Nuclear Energy

Baltimore Gas and Electric Company-Calvert Cliffs Nuclear Power Plant j 1650 Calvert Cliffs Parkway

. Lusby, MD 20657-4702-5 Mr. William J. Cahill, Jr. FitzPatrick and Indian Point 3

! Chief Nuclear Officer

Power Authority of the State l of New York 123 Main Street j White Plains, NY 10601 i Mr. Stephen E. Quinn Indian Point 2 l

! Vice President, Nuclear Power l Consolidated Edison Company of New York Broadway and Bleakley Avenue Buchanan, NY 10511 Dr. Robert C. Mecredy R. E. Ginna Vice President, Nuclear Operations Rochester Gas and Electric Corporation 89 East Avenue -

Rochester, NY 14649 Mr. E. Thomas Boulette, Ph.D Pilgrim Senior Vice President - Nuclear Boston Edison Company Pilgrim Nuclear Power Station RFD #1 Rocky Hill Road Plymouth, MA 02360 Mr. B. Ralph Sylvia Nine Mile 1/2 Executive Vice President, Nuclear Niagara Mohawk Power Corporation Nine Mile Point Nuclear Station P.O. Box 63 Lycoming, NY 13093 Mr. Leon R. E11ason Hope Creek Chief Nuclear Officer & President-Nuclear Business Unit Public Service Electric and Gas Company Post Office Box 236 Hancocks Bridge, NJ 08038

i'

. .: 1 i

i j Mr. George A. Hunger, Jr. Limerick 1/2 j Director-Licensing, MC 62A-1 1 flC0 Energy Company

. Nuclear Group Headquarters i Correspondence Control Desk i P.O. Box No.195 i Wayne, PA 19087-0195 l

l Mr. George A. Hunger, Jr. Peach Botton 2/3 i Director-Licensing, MC 62A-1 l PEC0 Energy Company

> Nuclear Group Headquarters l Correspondence Control Desk

P. O. Box No. 195 Wayne, PA 19087-0195 l

i Mr. Leon R. Eliason Salem 1/2

! Chief Nuclear Officer & President-

! Nuclear Business Unit I' i Public Service Electric and Gae,

! Company 4 Post Office Box 236 i Hancocks Bridge, NJ 08038 l

Mr. Robert G. Byram Susquehanna 1/2 Senior Vice President-Nuclear

! Pennsylvania Power and Light Company i 2 North Ninth Street Allentown, PA 18101 l  :

l Mr. J. E. Cross Beaver Valley 1/2

Senior Vice President and I Chief Nuclear Officer i i Nuclear Power Division j f

Duquesne Light Company i j Post Office Box 4  !

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Shippingport, PA 15077 i Mr. Ted C. Feigenbaum Haddam Neck and l 4 Executive Vice President and Millstone 1/2/3

Chief Nuclear officer a

Northeast Utilities Service Company c/o Mr. Terry L. Harpster l

Director - Nuclear Licensing Services P.O. Box 128 Waterford, CT 06385

e l _3 Mr. Charles D. Frizzle, President Maine Yankee Maine Yankee Atomic Power Company i

329 Bath Road Brunswick, ME 04011 i

i

, Mr. Michael B. Roche Oyster Creek

Vice President and Director 1

GPU Nuclear Corporation

Dyster Creek Nuclear Generating Station 1

P.O. Box 388 Forked River, NJ 08731 '

1 Mr. Ted C. Feigenbaum Seabrook 1 Executive Vica President and Chief Nuclear Officer I Northeast Utilities Service Company I c/o Mr. Terry L. Harpster '

Director - Nuclear Licensing Services i P.O. Box 128

] Waterford, CT 06385 i i

Mr. James Knubel, Vice President Three Mile Island 1 and Director - TMI-1 l GPU Nuclear Corporation

P.O. Box 480 i

Middletown, PA 17057 Mr. Donald A. Reid Vermont Yankee Vice President, Operations j Vermont Yankee Nuclear Power Corporation i Ferry Road '

j Brattleboro, VT 05301 l

l Mr. Percy M. Beard, Jr. Crystal River 3 Senior Vice President, Nuclear Operations (SA2A)

Florida Power Corporation ATTN: Manager, Nuclear l Licensing Crystal River Energy Complex 15760 W Power Line Street Crystal River, FL 34428-6708

1

. l i

s li l Mr. J. P. O'Hanlon North Anna 1 i

Sr. Vice President - Nuclear '

l Virginia Electric & Power Co.

Innsbrook Technical Center

! 5000 Dominion Blvd. l Glen Allen, Virginia 23060 Mr. J. P. O'Hanlon Surry 1/2 j Sr. Vice President - Nuclear

Virginia Electric & Power Co.

1 Innsbrook Technical Center i 5000 Dominion Blvd.

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Glen Allen, Virginia 23060 i Mr. Themes F. Plunkett St. Lucie 1/2 i l President - Nuclear Division I

{ Florida Power and Light Co.

P.O. Box 14000

Juno Beach, Florida 33408-0420 4

Mr. Thamas F. Plunkett Turkey Point 3/4 i President - Nuclear Division i

Florida Power and Light Co.

P.O. Box 14000

Juno Beach, Florida 33408-0420 i

l Shearoe Harris

{ Mr. W. R. Robinson, Vice President Shearon Harris

! Shearon Harris Nuclear Power Plant

! Carolina Power & Light Company l Post Office Box 165, Hall

! Code: Zone 1 i New Hill, Morth Carolina 27562-0165

Mr. W. R. Campbell Brunswick 1/2 i Vice President i Brunswick Steam Electric Plant Carolina Power & Light Company

. Post Office Box 10429 l Southport, North Carolina 28461 Mr. C. S. Hinnant, Vice President H. B. Robinson 2 Carolina Power & Light Company H. B. Robinson Steam Electric Plant, Unit No. 2 3581 West Entranco Road Hartsville, South Carolir.a 29551-0790

i i .

e-Mr. W. R. McCollum Catawba 1/2 i

Site Vice President

' Catawba Nuclear Station Ouke Power Company

4800 Concord Road York, South Carolina 29745

Mr. T. C. McNeekin McGuire 1/2 l Vice President, McGuire Site i Duke Power Company j 12700 Hagers Ferry Road Huntersville, North Carolina 28078 d

} Mr. J. k'. Hampton Oconee 1/2/3

} Vice President, Oconee Site Duke Power Company 4

P. O. Box 1439 Seneca, South Carolina 29679 l Mr. J. T. Beckham, Jr. Hatch 1/2 Vice President - Plant Hatch l Georgia Power Company l P. O. Box 1295 j Birmingham, Alabama 35201 i Mr. C. K. McCoy Vogtle 1/2 Vice President - Nuclear

! Vogtle Project

Georgia Power Company

P. D. Box 1295

! Birmingham, Alabama 35201 i

i Mr. D. N. Morey Farley 1/2

Vice President .

i Southern Nuclear Operating Company, Inc.

i Post Office Box 1295 Birmingham, Aldama 35201 l

I Mr. Oliver D. Kingsley, Jr. Browns Ferry / Sequoyah /

President, TVA Nuclear and Watts Bar / Bellefonte

. Chief Nuclear Officer

Tennessee Valley Authority

6A Looknut Place i 1101 Market Street i Chattanooga, Tennessee 37402-2801 a

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3

j Mr. Gary J. Taylor, Vice President Sumner Nuclear Operations South Carolina Electric & Gas Company Virgil C. Summer Nuclear Station Post Office Box 88 Jenkinsv111e, South Carolina 29065 i

Mr. E. E. Fitzpatrick, Vice President i

Indiana Michigan Power Company D. C. Cook c/o hearican Electric Power Service Corporation '

i t

1 Riverside Plaza I Columbus, OH 43215 i Mr. Douglas R. Gipson Fermi 2

Senior Vice President

Nuclear Generation

. Detroit Edison Company 6400 North Dixie Highway Newport, MI 48166 Mr. Roger 0. Anderson, Director Monticello / Prairie Island Licensing and Management Issues Northern States Power Company 414 Nicollet Mall Minneapolis, MN 55401 Mr. Patrick M. Donnelly, Plant Manager Big Rock Big Rock Point Plant Consumers Power Company 10269 U.S. 31 NorP Charlevoix, MI 49; A Mr. Richard W. Smedley Palisades Manager, Licensing Palisades Plant 27780 Blue Star b eorial Highway Covert, MI 49043 Mr. D. L. Farrar, Manager Braidwood / Byron / LaSalle Nuclear Regulatory Services Quad Cities 1/2 / Zion /

Commonwealth Edison Company Dresden Executive Towers West III, Suite 500 1400 Opus Place Downers Grove, Illinois 60515

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l Mr. Michael W. Lyon Clinton

. Director - Licensing -

Clinton Ptnser Station P. 0. Box 678 Mall Code V920 j Clinton, it 61727

? Mr. John P. Stetz Davis-Besse Vice President - Nuclear, Davis-Besse Centerior Service Company c/o Tolede Edison Company Davis-Besse Nuclear Power Station 5501 North State Route 2 Cak Harbor, OH 43449 Mr. Lee Liu Duane Arnold Chairian of the Board and Chief Executive Officer IES Utilities Inc.

Post Office Box 351 Cedar Rapids, IA 52406 Mr. M. L. Marchi Kewaunee Manager - Nuclear Business Group Wisconsin Public Service Corporation Post Office Box 19002 Green Bay, WI 54307-9002 Mr. Donald C. Shelton Perry 1/2 Acting Vice President Nuclear - Perry Centerior Service Company P. O. Box 97, A200 Perry, OH 44081 Mr. Robert E. Link, Vice President Point Beach 1/2 Iheclear Power Department Wisconsin Electric Power Company 231 West Richigan Street, Room P379 Rilwaukee, WI 53201 Mr. Jerry W. Yelverton ANO 1/2 Vice President, Operations ANO Entergy Operations, Inc.

1448 S. R. 333 Russellville, AR 72801

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Mr. C. Lance Terry Comanche Peak 1/2 Group Vice President, Nuclear TU Electric Energy Plaza 1601 Bryan Street,12th Floor Dallas, TX 75201-3411

, Mr. Guy R. Horn Cooper i Vice President - Nuclear Nebraska Public Power District i P. O. Box 499 j Columbus, NE 68602-0499 Mr. C. Randy Hutchinson Grand Gulf

Vice President, Operations GGNS i Entergy Operations, Inc.

1 P. O. Box 756 l

Port Gibson, MS 39150 l

Mr. Michael B. Sellman Waterford 3 Vice President Operations Entergy Operations, Inc.

P. O. Box B Killona, LA 70066 Mr. William T. Cottle South Texas 1/2 Executive Vice President General Manager, Nuclear Houston Lighting & Power Company South Texas Project Generating Station P. O. Box 289 Wadsworth, TX 77483 Mr. John R. McGaFa, Jr. River Bend Vice President Operations Entergy Operations, Inc.

River Bend Station P. O. Box 220 St. Francisville, LA 70775 Mr. Donald F. Schnell Callaway Senior Vice President - Nuclear Union Electric Company Post Office Box 149 St. Louis, Missouri 63166

4

, l' Mr. Harold B. Ray San Onofre 2/3 Executive Vice President Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 j San Clemente, California 92674-0128 e

! Mr. J. V. Parrish (Mail Drop 1023) WNP-2 j Chief Executive Officer i 3000 George Washington Way j Washington Public Power Supply System

, P.O. Box 968 Richland, Washington 99352-0968

' Mr. William L. Stewart Palo Verde 1/2/3

Executive Vice President, Nuclear l Arizona Public Service Company l Post Office Box 53999 i (Station No. 7601)

Phoenix, Arizona 85072-3999 i

! Mr. Neil S. Carns Wolf Creek

! President t;d Chief Executive Officer i Wolf Creek Nuclear Operating Corporation

P.O. Box 411

! Burlington, Kansas 66839 l Mr. Gregory M. Rueger Diablo Canyon 1/2 l Pacific Gas and Electric Company 2

NPG - Mail Code A10D i P.O. Box 770000

San Francisco, California 94177

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i Mr. Terry L. Patterson Ft. Calhoun Division Manager - Nuclear Operations Omaha Public Power District

, Fort Calhoun Station FC-2-4 Adm.

l Hwy. 75 - North of Fort Calhoun Fort Calhoun, Nebraska 68023-0399 l Mr. Charles D. Frizzle, President Maine Yankee l Maine Yankee Atomic Power Company i 329 Bath Road l Brunswick, Maine 04Gil t 9

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. 7590-01  ;

DOCKETED  !

USNRC UNITED STATES NUCLEAR REGULATORY COMMISSION ALL NUCLEAR POWER PLANTS ISSUANCE OF DIRECTOR'S DECISION UNDER 10 CFR 2.206 OfflCE OF McRETARY  !

00CKEIM a cimVICE l BRANU Notice is hereby given that the Director, Office of Nuclear Reactor i Regulation, has taken action with regard to a Petition dated March 5,1996, by Mr. C. Morris. The Petition pertains to all operating nuclear power plants.

In the Petitica, the Mtitioner requested that the operating licuises of all nuclear power plants be suspended within 90 days and remain suspended until such time as the licensees of those plants discovered the reason for what the Petitioner asserts are repeated errors in the undervoltage relay (UVR) setpoints (SPs) and electrical distribution system (EDS) designs and provided convincing evidence that these deficiencies had finally been corrected. Since the Petitioner had requested action within 90 days, the request was treated as a request for immediate relief. The Petitioner also requested that the aforementioned evidence be reviewed by a competent third party, in addition to the staff of the U.S. Nuclear Regulatory Commission (NRC), and that if the NRC concludes that plants may safely operate with UVRs that cannot be properly set for 1.ong periods, the NRC should reach these conclusions by way of a public meeting.

The Director of the Office of Nuclear Reactor Regulation has denied the Petition. The reasons for this denial are explained in the " Director's Decision Under 10 CFR 2.206" (DD ), the complete text of which follows this notice and is available for public inspection at the Commission's Public Document Room, the Gelman Building, 2120 L Street, NW., Washington, DC.

lolO

l i A copy of the decision will be filed with the Secretary of the

! Commission for the Commission's review in accordance with 10 CFR 2.206(c) of

the Commission's regulations. As provided by this regulation, the decision

, will constitute the final action of the Commission 25 days after issuance unless the Commission, on its own motion, institutes review of the decision in that time.

Dated at Rockville, Maryland, this26th day of September, 1996.

FOR THE NUCLEAR REGULATORY COMMISSION

.AUD R William T. Russell, Director Office of Nuclear Reactor Regulation

_. . ~ . . ._- _ _ _ . __ _ .._ _ _. __

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DD 12 UNITED STATES OF AMERICA 00CKETED NUCLEAR REGULATORY COMMISSION USNRC j l

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OFFJCE Nilliam OF NUCLEAR T. Russell, REACTOR Director REGULATION '96 N0,/ -7 P4 :12 {

In the Matter of ) All Dockets 0FFICE y c TETAg1 l DOM }j 3 EL:

ALL NUCLEAR POWER PLANTS All Licenses

) i i

, DIRECTOR'S DECISION UNDER 10 CFR 2.206

I. INTRODUCTION s

On March 5,1996, Mr. Charles Morris (Petitioner) filed a Petition with the Executive Director for Operations pursuant to Section 2.206 of Title 10 of the Code of Federal Reaulations (10 CFR 2.206). The Petitioner requested that the operating licenses of all nuclear power plants be suspended within 90 days

and renain suspended until such time as those plants have (1) discovered the 1

reason for what the Petitioner asserts are repeated errors in the undervoltage relay (UVR) setpoints (SPs) and electrical distribution system (EDS) designs and (2) provided convincing evidence that these deficiencies have finally been corrected. Since the Petitioner had requested action within 90 days, the request was treated as a request for immediate relief. The Petitioner also requested that the aforementioned evidence be reviewed by a competent third party, in addition to the Nuclear Regulatory Commission (NRC) staff, and that if the NRC concludes that plants may safely operate with UVRs that cannot be properly set for long periods of time, the NRC should reach these conclusions by way of a public meeting.

On April 17, 1996, the Petitioner was informed that the request for the suspension of all nuclear power plant licenses within 90 days for the purposes of remedying repeated errors in UVR SPs and EDS designs was denied because licensees have, to a largr degree, already addressed the issues which the

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Petitioner had raised. Also the Petitioner was. informed that the request was being evaluated pursuant to 10 CFR 2.206 of the NRC's regulations and that a.

a decision, as provided by 10 CFR 2.'206, would be made on the request within a reasonable time.

On the basis of my review of the issues raised by the Petitioner as i

discussed below, I have concluded that no substantial health and safety issues

have been raised that would require the initiation of the action requested by l the Petitioner.

II. DISCUSSION l

. In his Petition, the Petitioner stated his concern that the " enduring and widespread nature of the electrical distribution system (EDS) and

undervoltage relay (UVR) setpoint (SP) errors (e.g., incorrect UVR and thermal l- overload setpoints) was recognized by neither the licensees nor the NRC

) staff," and was not included in NRC Information Notice (IN) 93-99, i '

"Undervoltage Relay and Thermal Overload Setpoint Problems."

! IN 93-99 did, in fact, inform all holders of operating licenses or q construction permits of the widespread nature of the setpoint errors by listing approximately 40 licensees with incorrectly set UVRs or thermal overload (TOL) protective devices. The identification of these problems was

not inadvertent, but was the result of concerted NRC st2ff attention to these I issues. As was indicated to the Petitioner in a April 17, 1996, letter acknowledgir ,, receipt of his March 5, 1996, 10 CFR 2.206 Petition, the Petitioner himself recognized that Electrical Distribution System Functional Inspections (EDSFIs) were highlighting these issues and that licensees were

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conducting self-initiated design basis reviews (possibly in anticipation of

pending EDSFis) to identify problems and were undertaking corrective actions.

In his March 5,1996, Petition, the Petitioner listed seven specific reasons that he believed caused repeated EDS and UVR deficiencies. The following is a description of each concern accompanied by the NRC staff's

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response:

1. The Petitioner stated that NRC Branch Technical Position PSB-1, j " Adequacy of Station Electric Distribution System Voltages," contained i i l in NUREG-0800, " Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants," which requires a degraded voltage j relay with a long delay and a loss of power relay with a short delay, is inadequate because it does not recognize the complexity of the matter, j Except for the arbitrary time delays associated with the UVRs, no ,

l recognition has been made of voltage dynamics and time dependence.

! Signal bandwidths, responses of tap changing transformers, and UVR time ,

I i

delays have been overlooked and should be considered.

! RESPONSE:

1 NRC Branch Technical Position PSB-1 does not recommend that licensees arbitrarily select time delays for UVRs. On the contrary,

! PSB-1 states that "the selection of undervoltage and time delay setpoints shall be determined from an analysis of the voltage f requirements of the Class 1E loads at all onsite system distributions

levels." Further, it states that " Tap settings selected should be based on an analysis of the voltage at the terminals of the Class IE loads.

The analyses performed to determine minimum operating voltages should typically consider maximum unit steady state and transient loads..."

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1.dditionally, "the first time delay should be of a duration that established the existence of a sustained degraded voltage condition (i.e., something longer than a motor starting transient)" and "the  !

second time delay should be of a limited duration such that the

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permanently connected Class 1E loads will not be damaged."

Therefore, the staff concludes that NRC Branch Technical Position

! PSB-1 is adequate as it addresses those topics which the Petitioner '

believes are neglected by the Branch Technical Position.  ;

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2. The Petitioner asserted that UVR tolerances are statistical in nature and not, as the staff and design engineers often regard them, limits to 1 i

) the errors in the relay setpoints. This is a significant problem which I may not be solved if previous approaches are utilized and decision y analysis is not applied to study the consequences of attempting to l prevent the occasional loss of the most vulnerable safety load at the expense of transferring a complete division to another power source with

attendant problems.

ESpQ!iSI:

Regulatory Guide 1.105, " Instrument Setpoints for Safety-Related Systems," states that ISA-S67.04-1982, "Setpoints for Nuclear Safety-1 Related Instrumentation Used in Nuclear Power Plants," establishes NRC staff guidance for ensuring that instrument setpoints in safety-related I

systems are initially within and remain within the technical specification limits. Section 4.3.1 of ISA-S67.04 states that I instrument accuracies (uncertainties, errors or tolerances) may be combined in one of five ways: algebraically, square root of the um of

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j the squares, statistically, probabilistically, or combinations of the 8

first four. Justification is to be provided for the method used.

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Regulatory Guide 1.105 expands upon this point:

Paragraph 4.3 of the standard specifies the methods for combining

, uncertainties in determining a trip setpoint and its allowable

values. Typically, the NRC staff has accepted 95% as a probability

. limit for errors. That is, of the observed distribution of values  !

for a particular error component in the empirical data base, 95% of  !

i, the data points will be bounded by the value selected. If the data I base follows a normal distribution, this corresponds to an error distribution approximately equal to a "two sigma" value.

Although the use of "two sigma" values (values equal to twice the

! standard deviations of the errors) does not completely ensure that the  ;

! measured parameter will not exceed the safety analysis limit without 3

accompanying protective action, the probability of all the individual l

l errors occurring simultaneously at their extreme, non-conservative, random values is very low. Therefore, the regulatory guide and the industry standard together support a credible, statistical approach for establishing setpoints that considers such things as sample size of l

error values, random versus non-random errors, and independence of errors.

i The preparatory training for EDSFI team members also did not overlook the statistical nature of the VVR tolerances. In Section 4.8.2 of the EDSFI training textbook, a discussion of instrumentation setpoint problems was provided with a sample application of ISA-S67.04 to degraded voltage relays. This methodology was also discussed in the

{ course itself. Using this knowledge EDFSIs were conducted and findings

were written covering improper degraded voltage relay setpoints. As a 4

result, licensees then followed this action with event notification and

, other activities as described in Information Notice 93-99.

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n l Additionally, in response to a request from Region III pertaining to l i

an unanalyzed degraded voltage concern at Perry Nuclear Power Plant, j the Electrical Engineering Branch (EELB) of NRR in an April 13, 1992, memo provided inspectors in NRC Regional Offices with guidance for I establishing an adequate setpoint for the degraded voltage relays by way of reference to Section 4.8.2 of the EDSFI training course manual and ,

I Regulatory Guide 1.105. Furthermore, the staff informed all holders of '

operating licenses about a statistical approach for establishment of UVR setpoints when IN 91-29, " Deficiencies Identified during Electrical Distribution Functional Inspections," made reference to ISA-S67.04-1982 for useful guidance in determination of setpoints.

The staff therefore has regarded the UVR setpoint determinations as statistical in nature.

3. The Petitioner stated that although General Design Criterion (GDC) 17,

" Electric power systems," requires all EDS to be testable, only parts are tested because plants cannot conveniently be placed in a condition where actual loads can be placed on the EDS and measured.

RESPONSE

The staff has always been aware that in certain situations it is not practical nor safe to test each and every component in the exact way it is used. General Design Criterion 18, " Inspection and testing of electrical power systems," states that " systems shall be designed with a capability to test periodically...the operability of the systems as a whole and, under conditions as close to design as practical...."

Regulatory Guide 1.118, " Periodic Testing of Electric Power and Protection Systems," Revision 2, endorses IEEE Std 338-1977, " Criteria

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for the Periodic Testing of Nuclear Power Generating Station Safety Systems," which states that "the test program of each system shall be designed to provide for minimum interference with related operational channels, systems, or equipment." It further states that "wherever possible, tests shall be accomplished under actual or simulated operating conditions, including sequence of operations, for example,

diesel load sequencing," but also where it is not practicable to 'nitiate the protective action, the system shall be designed such '. hat... Designs...shall be justified on the basis that there is no practical system design that would permit operation of the actuated equipment without adversely affecting the safety or operability of the plant, and that the probability of failure of actuated equipment not tested during plant i operation is acceptably low, and that the actuated equipment can be

routinely tested when the plant is shut down.

It is the staff's goal to have all components of the EDS periodically tested in a manner that is both reasonable and practical.

Various practical test methods such as the use of miniflow paths, overlap testing, simulated loads, etc. have been found acceptable by the staff.

NRC Temporary Instruction 2515/107 (which provided guidance for performing EDSFIs) required the EDSFI teams to " verify that the surveillance and test procedures are adequate to demonstrate the functionality of the equipment or system being tested or the design assumptions being verified."

Therefore, as shown above, testing of the EDS is evaluated in terms of satisfying NRC requirements (GDC-17 &nd GDC-18) utilizing the guidance provided by Regulatory Guide 1.118 for a reasonable and practical approach (in lieu of testing each system as a whole), and tests are properly implemented in the manner described above.

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4. The Petitioner pointed out' that load nameplate ratings are used in voltage analyses even when common knowledge shows that most loads are l operated at a fraction of their ratings. Furthermore, worst-case

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ambient; temperatures are used to select motor protection time delays even though few loads, if:any,'see those conditions except during a

loss-of-coolant accident when the motor protection is bypassed.

Additionally, UVR output delays are treated as known quantities, when the protection of loads by time delays and inverse time overcurrent t

l relays is a crude mitigating approach. As a related matter, the Petitioner objects to the inconsistent use of significant figures to represent EDS and UVR SP parameters.

RESPONSE

The aforementioned temporary instruction (TI) for the EOSFIs stated that the inspectors should verify that values for mechanical loads used for electrical calculations are based on actual system operat:+ ; points during both normal and accident conditions. The staff expects licensees to perform accurate, conservative, and bounding calculations involving worst-case estimates for parameters such as ambient temperatures and loads. The licensees' analyses are reviewed by the staff utilizing engineering judgment and applicable industry guidance to ensure that reasonable, yet adequately safe solutions are provided.

It is true that, occasionally, designs proposed by licensees do involve basic approaches (such as inverse time delay relays) and that some calculations performed by licensees involve the use of ultra-precise numerical values. What the staff does require is that the l

l l

i

0 designs utilized by licensees meet applicable NRC regulations and that 4

adequate protection of public health and safety is ensured.

The staff, therefore, concludes that component characteristics are treated and utilized properly in calculations that support EDS and UVR designs.

5. The Petitioner believed that when licensees have discovered that UVR SPs are set too low, the typical response has been to raise the setpoints.

This, in turn, reduces the safety adv:ntage of providing UVRs for the EDS due to more frequent and unnecessary UVR actuations accompanied by i possible undesirable power systems transfers.

RESPONSE

In a letter dated August 8, 1979, addressed to all power reactor licensees regarding the adequacy of station electric distribution systems voltages, the staff stated that:

Protection of safety loads from undervoltage conditions must be designed to provide the required protection without causing voltages in excess of maximum voltage ratings of safety loads and without causing spurious separations of safety buses from offsite power.

Moreover, Voltage-time settings for undervoltage relays shall be selected so as to avoid spurious separation of safety buses from offsite power during plant startup, normal operation and shutdown due to startup and/or operation of electric loads.

NRC Branch Technical Position PSB-1 states that:

...imporper (sic) voltage protection logic can itself cause adverse effects on the Class 1E systems and equipment such as... spurious separation of Class IE systems from offsite power due to normal motor starting transients.

Additionally, in IN 95-37, " Inadequate Offsite Power System Voltages during Design-Basis Events," the staff informed power reactor licensees that although raising UVR setpoints ensures that adequate voltages exist

- .- . . . . .= _- -.- . - - . . . . _ _ .

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at equipment input terminals, the higher setpoints also increase the

! ' potential for separation from the offsite power system during design-

, basis events over the range of normally anticipated offsite grid

voltages.

In a more specific example, a February 23, 1995, staff safety evaluation of the degraded voltage design for the Edwin I. Hatch Nuclear l-Plant, determined that a combination of automatic ana manual actions was an acceptable alternative approach to meet the branch technical position l in lieu of raising the degraded voltage setpoints which could lead to

unwanted plant trips. That safety evaluation and the above staff

guidance provide evidence that the staff has considered avoidance of spurious bus trips as one objective to be considered when selecting an adequate setpoint for UVRs.

. The staff, therefore, has repeatedly and in detail both considered the detrimental effects of raising the UVR setpoints and communicated its concerns to licensees.

6. The Petitioner stated that in IN 95-05, "Undervoltage Protection Relay Settings Out of Tolerance Due to Test Equipment Harmonics," the staff discovered that peak reading voltmeters calibrated for root-mean-square (RMS) are affected by the proportions of harmonics in the AC bus voltages and in the calibrators used to set the UVRs. Additionally, the harmonics affect the UVR responses by changing their setpoints when the harmonic content of the bus voltage changes.

RESPONSE

IN 95-05 discusses three occurrences, reported by licensees, where harmonics in the output voltage of the power supplies used during testing and calibration of UVRs resulted in the relay setpoints being

J 1

out of tolerance. The setpoint errors were also affected by the use of 1 I

digital voltmeters which do not respond to the harmonic content of the

test input voltage as do the UVRs. The purpose of the IN was to inform all operating power plant licensees that harmonics in the voltage inputs (test source voltage or normal bus voltage) to the UVRs impact the actual operating points of those relays, as the Petitioner believes, l

] and to instruct the licensees to take appropriate action (i.e., install l filters, adjust setpoints, select proper test equipment, etc.) to ensure I that UVR setpoints are adequate. j The staff, therefore, has addressed this concern and brought it to 1

the attention of licensees who are taking appropriate action as discussed above.

l 7. The Petitioner concluded that impedances and inrush currents to motors and other loads are not known to the precision with which the staff and the licensees' engineers have been trying to set UVRs. Both groups must

recognize that their task may be impossible and that their attempts to

do so have increased the risk of a nuclear accident.

RESPONSE

Branch Tec.hnical Position PSB-1 states that voltage analyses (including effects of impedances and inrosh currents) should be performed with analytical techniques and assumptions verified by actual measurement. It also states that, in general, test results should not be more than 3% Icwer than the analytical results. This level of precision has been determined to be acceptable based on engineering judgment.

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Furthermore, as stated in the response to the Petitioner's fourth

{ concern, even though licensees propose solutions involving different equipment and unique, precise calculations (which should be supported by-actual test data as mentioned above), staff reviews are conducted l utilizing both guidance from Branch Technical Position PSB-1 and engineering judgment to ensure that all applicable regulations are met and that adequate protection of public health and safety is ensured.

This approach provides reasonable assurance that the level of risk of a nuclear accident is not increased and remains acceptable.

Choosing a setpoint above an analytical limit based on minimum voltage requirements and below nominal voltage ranges while accounting for instrumentation errors and analytical inaccuracies is often a challenge which leads licensees to use more precise equipment and more precise calculations. It is concerns such as these that have led the staff to consider alternative approaches to its position on degraded voltage protection on a plant-specific basis as noted above in the staff's response to the Petitioner's fifth concern.

Therefore, although the staff has concluded that the task is not impossible, it has recognized alternative approaches that address degraded voltage concerns without increasing the risk of an accident.

To continue the discussion, identification of problems with UVRs and EDSs was not inadvertent. The NRC staff had undertaken more global measures j i

to ensure that concerns such as those raised by the Petitioner were addressed i i

satisfactorily. Because previous NRC inspection teams had observed that the l required functional capabilities of certain safety-related systems (including l

EDSs) were compromised due to a lack of proper engineering support and the i

3

4 introduction of various design deficiencies, EDFSIs were scheduled to be conducted for all operating plants beginning with pilot inspections in 1989.

NRC Temporary Instruction (TI) 2515/107 was issued on October 19,1990, to be made part of the NRC Inspection Manual. That TI stated that calculations to i

establish protective relay setpoints had not been initially performed or were not updated to reflect setpoint changes and plant modifications. These failures constituted some of the deficiencies that had been encountered by previous inspection teams. The TI stated, with regard to those concerns l voiced by the Petitioner, that the forthcoming inspections should verify

That ratings and setpoints have been correctly chosen and controlled for protective and control relays and circuit breakers to assure proper coordination, protection, required automatic action, and annunciation.

The adequacy of the load study, voltage profiles, voltage drop calculations, motor starting study, load shedding, engineered safety features (ESF) bus load sequencing and overload trip settings for ESF loads including consideration of steady-state and accident transient loads and consideration of acceleration of the loads during degraded voltage conditions that may occur during various modes of plant operation and accident mitigation scenarios.

- The adequacy of short circuit calculations, design of protective relay logic and relay setting calculations, grounding calculations and schemes, and protective device coordination studies.

- That setpoints for overcurrent protective relays are correctly chosen (1) to assure proper breaker coordination between different voltage levels; (2) to prevent exceeding the vendor-specified thermal limits on motors, containment electrical penetrations and cable insulation

.4' 14 -

! systems; (3) to allow starting of electrical equipment under degraded voltage conditions; and (4) to provide adequate pre-trip alarms, when applicable.

l -

The adequacy of setpoints and time delays for other protective relays )

for attributes such as undervoltage, underfrequency, reverse power, ground faults, differential current, thermal overload and phase I synchronization to assure functionality of the EDS.

That mechanical loads, such as pump horsepower, correspond to actual 1

i system operating points during normal and accident conditions and have been correctly translated to electrical loads and incorporated in the i

electrical load list as appropriate. l That surveillance and test procedures are adequate to demonstrate the

! functionality of the equipment or system being tested or the design j

! i

assumptions being verified. I

NRC inspectors (including NRC contractors) assigned to the EDSFI teams attended a week-long course (held in September and December 1990) to enhance their knowledge of EDSs, the TI and related requirements. Using the guidance l provided by the TI and the EDSFI training course, the EDSFI teams then R

conducted inspections of the EDSs through early 1994 at most operating nuclear power plants. As a result, numerous deficiencies were identified and

, documented in plant-specific EDSFI inspection reports, and corrective actions

, were taken. Those corrective actions were subsequently evaluated, found l acceptable by the staff and documented in follow-up inspection reports. Many i of these deficiencies and corrective actions were listed in IN 93-99 and '

include incorrect UVR relay and thermal overload setpoints caused by design errors, as well as other points raised by the Petitioner.

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In summary, as stated in my April 17, 1996, letter, I believe the NRC staff recognized the existence of repeated errors and widespread EDS design deficiencies, including those associated with UVR SPs, took appropriate actions (conducted EDSFIs, identified deficiencies, required corrective actions) based on those observations, and made all licensees aware of typical design deficiencies encountered during EDSFIs and licensees' self-initiated efforts by issuing ins such as IN 91-29, "Deficies ies Identified During Electrical Distribution System Functional Inspections," its supplements, and IN 93-99. Additionally, the staff has continued to inform power reactor licensees of other design deficiencies when they are encountered (e.g., IN 95-37 which discusses UVR setpoints in relationship to inadequate offsite power system voltages during design-basis events) and will continue to do so in the future when necessary. Such action by the staff is appropriate to address repeated errors in UVR setpoints and EDS designs and to provide reasonable assurance of adequate protection of public health and safety.

III. CONCLUSION The institution of proceedings pursuant to 10 CFR 2.206 is appropriate only if substantial health and safety issues have been raised. See Consolidated Edison Co. of New York (Indian Point Units 1, 2, and 3) CLI-75-8, 2 NRC 173, 175 (1975) and Washinaton Public Power Sucolv System (WPPSS Nuclear Project No. 2) D0-84-7, 19 NRC 899, 924 (1984). This is the standard that has been applied to the concerns raised by the Petitioner to determine whether the action requested by the Petitioner, or enforcemer.t actian, is warranted.

On the basis of the preceding assessment, i have concluded that no substantial health and safety issues have been raised by the Petitioner that 1

_ _ _ _ . _ _ _ . _ _ _ _ _ . . _ _ _ _ _ __ _.- - . _ - - - - - .~-

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4 would warrant the action requested by the Petitioner. I further conclude that the Petitioner's concerns have been adequately addressed by the staff and that i there is no need for a third party review. Additionally, with regard to plants with UVRs that cannot be properly set, the staff has shown in plant-

specific evaluations, such as described above, that other alternative designs

are acceptable.

The Petitioner's request for action pursuant to 10 CFR 2.206 is denied.

As provided for in 10 CFR 2.206(c), a copy of the decision will be filed with the Secretary of the Commission for the Commission's review. The decision

! will constitute the final action of the Commission 25 days after issuance

unless the Commission, on its own motion, institutes review of the decision in that time.

FOR THE NUCLEAR REGULATORY COMMISSION O0 William T. Russell, Director Office of Nuclear Reactor Regulation Dated at Rockville, Maryland, this 26 day of September,1996.

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Rockville, MD 20852 g/ g

Dear Mr. Taylor:

li l CO The following is a petition under 10 CFR 2.206.

On 21 December 1993, IN 93-99 (Attachment 4 to this petition) was belatedly issued by the NRC. Approximately forty licensees were listed in Attachment 1 to IN 93-99, as having had undervoltage relay set point corrections. However, the IN, as issued, was a bowdlerized notice in that a major concern of the principal reviewer (PR), the author of this 2.206 petition, had been deleted. That concern was that the enduring and widespread nature of the electrical distribution system (EDS) and undervoltage relay (UVR) set point (SP) errors was recognized by neither the licensees nor the NRC staff.

The concern was carried, as an exception, in a box, on the concurrence page (Attachment 5 to this petition) to the draft IN, dated 15 November 1993, which went as far as, Brihn Grimes D/ DORS:NRR. No notice was taken by him or any one else in the NRC, of the concern, then or thereafter. In fact, contrary to the ostensible philosophy of the NRC to treat the public as a partner in the regulatory process, both C. Berlinger, C/EELB/DE:NRR and W. Russell, ADT/NRR, separately, but not independently, told the PR that he could not write, even in an internal note (Attachments 1 and 2 to this petition) to his section chief E. Weiss, that it was "an awe-inspiring circumstance" that after repeated attempts, many, if not most, licensees could not get their UVR SPs and EDS designs right. The reason the PR could not write this, and suggest that an investigation of the problem was long overdue, was said by both these manag3rs to be because the public might become inflamed by such a statement. Russell was not receptive to the PR's  ;

suggestion that the public had every reason to be so and that the l management of the NRC should be, also.  !

The fear of FOIA requests was responsible for the sensitivity of l managers to the PR's remark about the extent of the UVR SP and EDS problems. It is improper, however, for the agency to behave in this way and to, once again, subordinate public safety to the maintenance of an image of safe nuclear power. I 1

ACTION REQUESTED  !

The NRC should suspend, within 90 days, the operating licenses of all nuclear power plants, and not just those listed in the IN 93-99 table: Representative List of Undervoltage Relay Set Point EDO -- GT96105

8

. M. Taylor Revision Notifications and Technical Specification Change proposals for 1988-1993. The licenses should remain suspended until such time as the licensees shall have discovered the reason for the repeated errors in their UVR Sps and in their EDS designs, and given convincing evidence that they have finally corracted the deficiencies.

The convincing evidence should be submitted to the review of a competent third party and not only to the NRC staff, who have shown, by their repeated concurrences in the erroneous calculations of many licensees, that the competence of the staff 14 not sufficient to the task.

If the NRC decides, as it surely will, that the licensees can continue to operate safely with UVRs that cannot be properly set for long, the NRC should do so in a public meeting.

Some of the reasons for these repeated EDS and UVR deficiencies follow:

1. The BTp pSB-1 requirement for licensees to provide a degraded grid voltage relay with a long delay and a loss of power relay with a short delay, while admirable in intention, like the ,

intention to be good, is by itself, inadequate in that it does l c.c t recognize the complexity of the matter. Thus, except for the arbitrary time constants associated with the UVRs, no recognition cf the dynamics of the voltages to which the relays are to respond can be found. In fact, time dependence has, for the most

, par:, been resolutely ignored, as in an IN which discusses the corrections on safety bus voltages by tap changing transformers.

In this :: , the need to consider the bandwidths of the signals and the responding filters; i.e., the tap changing transformers and UVRs with t'ime delays, has been overlooked. In other words, the rates at which AC bus voltages change and the rates at which tap changing transformers can change their output voltages in response should have been considered. i l

t has been known, at least since World War II, (vide: Radiation Laboratory Series, Volume 25, 1947) that automatic systems cannot be properly designed without consideration of the statistical I properties of their input signals, in this case the AC voltages  !

on the safety buses the'UVRs are installed to protect. l l

. The tolerances on the UVRs are statistical in nature and as such are not, as the reviewing staff and the design engineers l seem often to regard them, limits to the errors in the UVR Sps. i The tolerances are the standard deviations on normal distributions and as such only mean that .67 of the UVRs are '

within the specified tolerance. It also means that .95 of them fall within twice the specified tolerances and that .99 of them

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! fall within three times the specified tolerances.

encugh? No one has noticed, in print, that there is Is that good a problem i here, much less tried to solve it.

' Ferhaps the UVR Sp/EDS problems are, in fact, not resolvable in the ways that have been attempted. Then new techniques must be i

introduced'and not the current piecemeal approaches to patch what cannet be fixed.

1 i

The ACES has commented on the sometimes original use of statistics by the staff, ar did the author of this petition, on

.s ' January 1995, in respon:< to the NRC request for public

!. comment on the proposed application of pSA to regulatory 1

concerns. The ACRS comments have been largely ignored; the l comments by this reviewer were " lost" by the NRC.

1 l 30 sne on the staff has attempted to apply decision analysis to j the E;S and UVR Sp, which would include the consequences of i

trying to prevent the occasional loss of the most vulnerable l

j i

safety load at the expense of transferring the entire safety '

.ivision to another pow, supply with attendant opportunities for j upsets and even greater tosses.

I j The NRC has innocently tried to do the impossible before, as when, in 10 CFR 50.49 (e) (5), it required that safety equipment 3 be tested in the end-of-life condition. When it turned out that {

4 i

for many materials there was neither theoretical nor practical r.nowledge to make it possible to do so, and after millions of i

del;ars had been expended in research to find a way, the NRC 1 l  ::.odestly averted its gaze and accepted licensees' submittals, j based on myths, as responsive.

3 l .. Although all EDS are required by GDC 17 to be testable, testable has had a weak interpretation put on it by the staff, in that only parts of the EDS and its logic are tested because

.1censees say that plants cannot be conveniently put in a state waere the actual emergency loads could be put on the EDS and

t ea s ur ed .

i. Load nameplate ratings are used to analyze the voltages on the E;S, when, as every design engineer knows, most of the loads are

.perated at a frection of their ratings. Furthermore, the worst case ambient temp;ratures are used in selecting time delays for raotor protection, even though few, if any, of the loads are  !

actually run under these conditions, except during that never to be LOCA, when safety load protections are bypassed, anyway. In addition, the output delays allowed to UVRs which protect loads

- gainst overheating on degraded grid voltages are treated as precisely known quantities when, in fact, the protection of loads i Ly time delays and inverse time overcurrent relays is a crude, if econcmic, mitigating measure.

6 l

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. M. Taylor l l

A related matter could be ignored did it not indicate a more serious concern with this entire means of guarding against l t

persistent low voltages and that is the variable and inconsistent use of significant figures purporting to represent EDS and UVR parameters. Nothing much has changed since Carl Friedrich Gauss!

The analysis of CDS and UVR Sp problems may not need much precision, but the theory of the design of experiments should

. ave seen applied before the need to apply excessive precision reached such ubiquitous acceptance. Study, as belated as it would now be, is needed before licensees and the agency staff expend thousands more review hours at 140 dollars an hour,

b. Although in April 1993, C. Berlinger, C/EELE:DE:NRR, deleted, from a draft IN 93-99, (Attachtaent 3 to this petition) this PR's aut;cn to licensees that raising the UVR Sps might have ecnsequences, a remark to the same effect, in an SER dated 25

!anuary 1995, for Hatch entitled, Degraded Voltage Relay Set

. Folnts, suggests that with a new branch chief in EELE, the suasect may have become respectable, so that I introduce it

ain, in this petitlen, with less hesitation than I might

fc.e r w ; 3 e feel.

The incariable response of the NRC and its licensees to UVR Sps tc; .ow to protect safety loads on their associated buses has

.; c te raise the Sps. The UVR Sps were set as low as possible

..i the initial EDS design so that there would be as few UVR

.aaced ?S b.ansfers as possible, as, for example, during large ma:Or starts.

.._ eiR Sps are raised, the safety advantage of providing UVRs on

ne ECS is reduced because more frequent, unnecessary actuations

_: c. e L"/Ks has to be the consequence. If smaller dips in the cus voltage can start UVR timers, then they will start more often

. a c. ;f they are filtered out by lower UVR Sps, since it is in

he nature of reliable FS that there should be more frequent

mall perturbations than large ones. It is likewise true that lower frequency porturbations to the safety bus voltage will

aase the UVR timers to start more often than before the UVR Sps were raised. If one recalls that frequency is the reciprocal of c+r;cd this will be immediately apparent. Some of these timed sta.tv vill lead to the associated logic initiating unnecessary pS .ansfers.

.. In ::. 35-05, rather late in the day, staff discovered that peah reading voltmeters calibrated for RMS are affected by the essecrti ns of harmonics in the AC voltages on the bus and in the calibrators used to set the UVRs. Harmonics also affect the

e;rcnse of the UVRs, in effect changing their Sps, when the narmonic content of the bus voltages changes.

J. M. Taylor 7. Impedances and inrush currents to motors and other loads are not known to the precision with which the staff and licensee engineers have been trying to set UVRs. Both must recognize that they may have been trying, in many cases, to do the impossible, and that, in so trying, they have increased the risk of a nuclear accident.

Tcsblems with the text of IN 95-05 suggest that some of the staff

.r.ay still not be clear as to the function of UVRs, so that one may expect the long history of UVR concerns to continue, if licensees continue to operate nuclear power plants with design deficiencies; they should not be allowed to.

ADDENDUM If you do not say a thing in an irritating way, you may just as well not say it at all, since nobody will trouble themselves about anything that does not trouble them.

G.B. Shaw 8

f C. Morris 6516 Roy Shafer Road Middletown, MD 21769 Attachments:

.. .iemcrandum to E. Weiss, S/C, EELB 19 April 1993

_. Memorandum to E. Weiss, S/C, EELB 03 November 1993

2. URC :M 93-XXXX: Undervoltage Relay Setpoint [ sic]

April XX 1993 (draft)

4. URC IN 93-99: Undervoltage Relay and Thermal Overload Setpoint problems, December 21, 1993

. :n 93-XX, November XX, 1993, page 3 of 3 cc. Shirley Ann Jackson, Chairman, USNRC

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j MEMORANDUM TO : E. Weiss, S/C. EELB 19 April 1993 4

j l FROM : C. Morris. EELB s i

3 SUBJECT : , Attached Proposed Draft Information Notice h-hJ On two occasions before your tenure, menos of mine to my *eection l l or branch chief were revised. I put this warning early in you l

won't waste your time revising the following matter. When I write i

for the branch I try, of course, to write in the manner that you have told me you want; when I write to you in order to clarify come issue within the section. I hope you will pardon me if I write to please myself.

j 4

} The attached draft IN is for your emendation.

n A few hiatdEical comments may be in order as this document has a lor.g history. On 25 September 1992 my S/C the S/C who preceded ycur appointment, instructed me to write an IN on the overall issue of degraded grid voltage conditions which B. Grimes had, on October 8. 1992, written to Region II, EELB would do. The draft F )

of my response to these instructions was act well received by C.

Berlinger, B/C, who said among many things, which it is '

IbEi unnecessary to introduce here, that an IN should consist of two to four pages and contain nothing but what was found at the plants and what was done in consequence. I will not dwell on the overstatement made then, but pass on to C.Berlinger's subsequent reception of the IN draft of March 2, 1993. He returned the draft \

IN unsigned with a note saying," Haven't there been a (N-M considerable number of plants that have recently determined that their grid undervoltage protection / trip settings were too low and have resolved issue by raising WTrip settings-----? See Trehan." N.Trehan provided me with a list of 11 plants. While looking for dates and other related matters, I found that in fact there had been many more, over 30 to date and that those WR mistakes not discovered by EDSFIs were found by licensees through self initiated design basis reviews (DBR). These DBR may be owed to licensee attempts to avoid discoveries by NRC inspections and thereby to anticipate them. I told you of this and some of my conclusions about so many WR mistakes, at so many plants, over

• auch a long time. I pass over your indignation at that time and its shadow on my mid-year Performance Appraisal to connect these , ~

latter events to the draft IN you are about to review. ]k It is impossible to obey the branch chief's strictures regarding the contents and the length of an IN when so many plants are included. In an attempt to do so, I have tried to concentrate on the licensee *s need to resolve the seemies2r perpetual recurrence of WR setpoint errors and of undersized thermal overloads, and have simply listed the names and dates of many licensees who have discovered such errors with and without the assistance of the NRC. If you have other ideas as to how to include in an IN the dotails, however sketchily, of so many events I am sure you will

a Y

IN Review lot me know. We might then speak to the Branch Chief about a TAC to investigate, further, the awe inspiring circumstance of scores of nuclear power plants being unable, after repeated attempts. to act their EDS designs right. .

AW C. Morris. EELB e

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MEMORANDUM FOR: Gail Marcus, Chief Generic Communications Branch j Division of Operating Reactor Support s

Office of Nuclear Reactor Regulation

FROM

Carl Berlinger, Chief i

Electrical Engineering Branch j

Division of Engineering Office of Nuclear Reactor Regulation i

SUBJECT:

INFORMATION NOTICE 93- XXXX , UNDERVOLTAGE RELAY

}

SETPOINTS AND THERMAL OVERLOAD RATINGS l

I j

By memorandum dated August 31, 1992 A. Gibson, Director. Division of Reactor Safety. Region II proposed that the NRC issue a draft Information Notice (IN) entitled. Non-conservative Overload Relay ()

Settings. The attached proposed IN incorporates the substance of '

{ the Grand Gulf and other licensee concerns by citation and by .

i this means addresses the much larger general concera. - 9

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We recommend that this information notice be issued.

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Carl H. Berlinger, Chief &

j Electrical Engineering Branch Division of Engineering

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Enclosure:

! As stated .

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Contact:

C. Morris, EELB/DE i X2778 '

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) OFFICE RELB/DE SC/EELB/DE BC/EELB/DE MDk j[ j l NAME C. Morris E. Weiss C.Berlinser I [New k ry k

1 DATE 04/ /93 04/ /93 04/ /93 [ !04/[/93 /

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a MEMORANDUM TO: E. WEISS, S/C, EELB i

'03 NOV. 1993' j FROM: C. MORRIS EELB j

IN RES:pgES,J CONCURRENCE IN IN 93-XX: hDE@fplT[GQytAQPgIg ~

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Yesterday you returned to me the latest version of the subject' j

information notice initialed by G. Marcus B/C, OGCB and B. ..f, Grimes, D/D, DORS, et alii, together with a note saying, " Please' review this and let me know if it is 0.K. by you. Eric."  ;

j j It is not, and not because I find any errors in the remaining ..,' .

text, but because my principle concern with the undervoltage ' -' I l

l relay set point problem, which I told you of, orally in March j

1993, and in my memorandum to you of 19 April 1993, has been all l

' bu. eliminated. Only the most experienced reader, the most i j

curious and the most persistent, will be able to suspect its j

presence when he reads the version you returned to me for my O.K.

The public will not.

l i Anticipating these spins and elisions, I am, after all, as you i

have often told me, an experienced reviewer, I had already

! diluted and tempered the substance of my concern, which I will again restate now, and only now, so as to avoid the i anticlimactic.

I My principle concern, when I reviewed the many examples of undervoltage relays set too low, was that they had continued for i,

so long, and in so many plants, and despite repeated reviews by the licensee and his contractors, and by the NRC staff, continued i to recur.

! l i

I pass over your reaction, then, to my observations, to come to  !

i i my present concern. Calculating undervoltage setpoints should be 1 l within the competence of undergraduate electrical engineers. It -

! appears not to be. Either,then,the licensee engineers are incompetent, and some NRC staff, or there are factors present of

{ which I am unaware. Either way, as investigation is warranted. I- i i

' proposed Juwt such a task ig my April 19th memorandum to you. -

1

! I do not expect you or the branch chief to agree with me. After s i all, W. Russell, A/D ADT, found my remark about the persistence i

of so many improperly set undervoltage relays, namely that it was; an awe-inspiring circumstance, inflammatory and inappropriate. He' did not change his opinion when I insisted that it certainly was i

i awe-inspiring and that something should be done. You are I

therefore politically correct and can rest easy.

i i

4 i

e i

To conclude, I could accept the present innocuous version of the subject IN, provided I could place on the concurrence page a sentence to the effect that while there is nothing to object to in what remains, there is much to object to in what does not. If this is too high a price for my concurrence, please remove my name from the concurrence page. I should of course be more than .

happy to remain as the technical contact. s , .

~'

. Morris '

EELB * -

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g lh Mof~W W 9i o fet av UNITED STATES i 4 ih NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION 9 01 p-WASHINGTON, D.C. 20555 j

4 NRC INFORMATION NOTICE 93-XXXX: UNDERVOLTAGE RELAY SETPOINT CHANGES g[0

{ ADDRESSEES i All holders of operating licenses, or construction permits. -end j uendees for nuclear power plants.

} PURPOSE j The U.S. Nuclear Regulatory Commission (NRC) is issuing this j Information Notice-(IN) to alert addressees to continuing i diadoveries of undervoltage relays (UVR) with setpoints too low.

! Other licensees have found thermal overloads (TOIs), that are see-asin H . UVR and TOL protect safety loads during degraded grid vo 3 ( episodes.

(g g i <. t is expected that recipients will review the information herein

, for applicability to their facilities, and consider actions to l% ovoid similar problems. However, suggestions contained in this

!J IN are not NRC requirements; therefore, no specific action or .

j lg written response is required. M

!}

a DESCRIPTION ef CIRCUMSTANCEE L

Q Utilities have, in the last few years, initiat d extensive ..cIga!

! [offertstoimprovetheadequacyandcompletenasofthe t of j ' design bases, design analyses, and final desi n output cuments i that define the design of their facilities. he princ al reason i for these initiatives has been the consisten findings4 e6 NRC if cafety system functional inspections (SSFIs) and safety system k outage modification inspections (SSOMIs) tha : :some licensees hav j I.

made i- rr ;rict-- plant modifications whichg have affected the functionality of safety systems. Thr:0 :di.ic;ti:n: ver: r-t

w 4 . uu ,w. ju.n... no4-- - r4 -

7.d;;;;;;d4.. nf the au a s.J.

! d;eigm - r i r.e r.d the e f fe - * + h = t +" " 4 # 4 - d ir- "-- 4

{M i rr'r;;9The NRC inspection findings prompt _ed manyffcensees W AW4

! (e--to rev_iew and reconstitute their design bases. fat ac m. as a J 7# TW d ie.ne ri tif y #

I DS). As a result of earlier deficiencies, th E has

? develo] ped the electrical distribution system nopection i

=

] (EDSFIh , to evaluate the EDS. Since 1989, the has performed f j over 50 EDSFIs, andhasfounddesignweaknessesinseveralareasj J

including UVR setpoints for DGV. Between May 1990 and January '

1993, ozer 30 licensees have written to the NRC about changing

UVR set points . They have found that the UVR setpoints were set

co low % at safety loads Jtare not en protected the grids h experienced DGVs.

Q

- - . - _ - _ _ - . - . . . . - . - - . -- .....- - . ._~. - -- . -

! .* - D' f .

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.1 i

IN 93-XX i

N April XX, 1993 Page 2 of 5 e

An additional

-..e L. 3 licensees discovered a related deficienc '

whi.h 2'1  % g A% (OLQ l DGV and UVR set points have been extensively reviewed before, t

basinning with Tach plant's initial EDS design. In August 1976, i

the NRC wrote generic letters to all IMR licensees concerning the

naed for licensee av uat on of potential generic implications of AAW.4N

Millstone events, a ained degraded grid voltage episodes.g j f:11eri : ireur rf the i- term. 14cen-- e, - en; eth:r :;t....e.

a =="ir rd +keir t"!? r rt -ada+ . -- did +%- MFC. On June 2, 1977

{ the staff, as part of multiplant action (MPA) MPA-23, stated the #

i ctaff's position that all licensees must have a second level of

! under voltage protaction with a time delay. On August 8, 1979j the l NRC by generic letter, as part of MPA-48, requested all licenseet to determine the capability of the offsite power system to r operate all required loads within their voltage ratings under all conditions within their design basis. UVR setpoints were

.accessarily reviewed on each of these occasions. In 1981, the NRC i

icsued Branch Technical Position, Power System Branch-1, which

! roquired, among other things, the addition of a second UVR with

{ cn associated time delay. ~~'. 1..yi. .;nt th; ;Le..e;;, rc.r i "~' '"1"-

f=+ W t: c;.. .......J L. i m.m. . . , nd *k- F"C.

i

'Batween woA ano 1990 N wo INy which discussed UVR 4set' points amongetr other concerns, were i,ssued by the NRC:

• l 1

1. IN 84-02,80perating a Nue ar Power Plant at Voltage Levels LowerthanAnalyzed1Jan 10, 1984.f.

2. IN 91-29, Supplemenk if iciencies Identified During

, Electrical System Functional Inspections Sept. 14, i Inaddition,becausesomeoftheDGVproblems)decurredasa1992.j recult of inadequate control over the design process, the NRC i

! icouedSystems-Inadequate Power Generic Letter 88-15 Control c,n Over Sept. 12,Processes."

Design 1988, entitled,' Electric h 9 *1 p

/$- W ys%s #4e #4C 4*J Amadr.c/a., (M4 Ang

< C; nci ::1 fechnical Specification chang concer VR , . C gwR, ,,

! cetpointse he.. been - hitt;d f^ --'J e -- 10 th 6C hi;h has 4 . - '-- - '

-nd =nereved * % d r. i- 'oon. rrrult ef t'-

! ine;::tir. finding; 254 1-du-*n reepvu=== w L. . 2 rrris of

! tre;:::d revie

• a e tr L"*; = L rwinw. L..;n -tich i; ;;ntinaio. =t

! -p..se ' st i A , partial list of these is attached f,hansur. 7 E' ##

3

' DISCUSSION M d/y 46q

. e i

[hbicm::m1"mTeri:mW::::s1C"'

~onqgpasety eu tm e e n have beeJvhposed t,cr vusta 4 -me I Ma\

i Many of the licensees anal sinn +keir WD _

{ stpoints n; % ini iber. ;fts I ni;;. M r" -

" *

• T' # --'s

/w**.

f Nkc( M.

u m w. ~u

,ni s ~g -

t p; g &a.rAc. st h A*' E f e d w k As' Y ( e,Al b d

!. y  % .! n' -J.

f~ katL '

_ ,(, f n e k / h a d y n /cSac M) a{ M /4 &A.

! IN 93-XX April XX, 1993 Page 3 of 5

{ chould consi r the ine med risk o nnecessa ottendan allenge o safety e pment. L trips with the /

cone neees uda *

r the rea a that th roblems w inad

! v ages and t e associated /R setpoi t conc ate ED

. . . n ,. ~ . . f . . . _. m ....rm ... ,,--....

no have currsd j

. F w iM G/IeS K k NLe IOyrNei' R ~ I*IF X M E k w /$ &

~

i j Flthough it w e, A d be des ble to fi 11y resolve t se DGV dn l UVR set po a concer licensee e reminded l

j at nothin n i

{this cpec IN ould be r arded as e action RC requirem  ; therefo , no written r ponse is re ed. But I neees i

ch d be awa that if t y have not re owed their tpoints _ adequacies R \

ay exist.( If you have any questions 6 bout the Tnformation in this notice, please contact the 1

technical contact listed below or the appropriate NRR project manager.

1 Brian K. Grimes Director Division of Operational Events Assessment

{ Office of Nuclear Reactor Regulation T

l 1

Tochnical

Contact:

C. Morris, NRR (301)-504-2778 1

i Attachmen4: ?.; et ted

i.

Ms./ 45f lOtM sefpAd nwas <*pB-np l A. List / &ce</f -[ssd #4 &$mak 4.Vunr i

l A wf g q"*N A 44-/fs w#<

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d A A rd4 Q ~~~5{p ele.

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• IN 93-XX April XX, 1993 l Page 4 of 5 1

. ATTACHMENT 1 j Partial List Technical of I E Set Point Soeelfication N nmeRevimien prenomala Notification and for 1988-1993 Event Notification Licensee l Number Event Notification '

i Date i 11374 Pilgrim 1

! 14043 Pilgrim 1 January 30, 1988

• 00000 Pilgrim 1 November 18, 1988 i .

June 30, 1988

! 14780 Cooper 1 j 18540 Crystal River 3 February 17, 1989

17121 September 8, 1989 Robinson 2 November 18, 1989 1

18322 Oconee 1,2 and 3 28486 April 24, 1990 '

McGuire 1 and 2 May 14, 1990 l 18892 St. Lucie 2

19023 July 14, 1990 Haddam Neck 1 August 2, 199G j -20021 Calvert Cliff 1 and 2 December 8, 1990

20435 Ft. Calhoun 1 20503 February 12, 1991 Kewaunee 1 February 20, 1991

! 20542 Salem 2 i 21891 February 27, 1991 Dresden 2 and 3 August 23, 1991

{ 22281 Dresden 2 22498 November 20, 1991 Zion 1 and 2 December 19, 1991 22534 Haddam Neck 1 December 27, 1991

{ 22580 Indian Point 3 January 9, 1992

22658 Dresden 3 January 22, 1992 22847 (TOL) 2 Washington Nuclear 2 February 19, 1992

{ 22918 Washington Nuclear 2 March 1, 1992 i

23148 Vermont Yankee April 1, 1992 t

23191 Quad Cities 1 and 2 April 7, 1992 23338 LaSalle 1 and 2 April 27, 1992 i 23385 LaSalle 2 April 29, 1992 j 23385 Crystal River 3 May 1, 1992

23439 (TOL) Grand Gulf May 11, 1992 23452 1

Comanche Peak 2 May 13, 1992

$ 23578 Crystal River 3 June 4, 1992

} 23784 Zion 1 and 2 July 2, 1992 i 23932 Byron 1 and 2 July 24, 1992 i 00000 Callaway July 23, 1992 i 24229 Crystal River 3 September 14, 1992 1

24384 Dresden 2 and 3 October 6, 1992

=

j, .

IN 93-XX April XX, 1993 Page 5 of 5 a

Attachment 1 ( continued )

00000 0000C Prairie Island 1 & 2 November 6, 1992 l 24757 St. Lucio 1 November 30, 1992 00000 Maine Yankee December 15, ?.992 24845 Diablo Canyon 1 and 2 December 22, 1992 Point Beach 1 and 2 22658 January 7, 1993

- Dresden 3 January 22, 1993 25248 (TOL) Pilgrim March 29, 1993

! 25362 South Texas 1 April 6, 1993

, EEN numbered 00000 concern licensees whose UVR set point notifications to the NRC are carried by other files; e.g.

LERS, licensee letter etc., and whose EN numbers, known. if any, are not i

1 1

1 i

TI

y yg$) kt~ $

].

DISCUSSION ff i

$ a g tv A k u i For many years the NRC has reviewec and approved Technical S>ecification i

changes concerning UVR setpoints.

! partiallistoftheseisattached.I;ThecontinuingneedtoraisetheUVRThese have cont setpoints is of concern for two reasons. First, the NRC staff has given the issue substantial attention and yet the problem has persists. Second, the i problem is perhaps indicative of inadequate control of the design process.

1 This information notice requires no specific action or written response. If i

1 you have questions about the information in this notice, please contact the technical contact listed below or the appropriate NRR project manager.

NOTES: 5th l [The statements using the word "should" are inappropriate for an information@

1. [

notice because the notice should not contain requirements.

! OM i

Thestatementregarding"onoccasionssafetyloadshavebeenexposedto3kN* T.N j sustained voltages below their ratings" is unsupported conjecture. y

• Wg.

j The main point of the conclusion is pervasiventss of the UVR setpoint problem and not how to find an acceptable UVR setpoint.

N

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i

lN-b Uvk .>s gTT'AmhC, i at pu e

• UNITED STATES 15#7 Mj NUCLEAR REGULATORY COMISSION 0FFICE OF NUCLEAR REACTOR REGULATION y g4

, WASHINGTON, D.C. 20555 i

December 21, 1993

. ~

NRC INFORMATION NOTICE 93-99: UNDERVOLTAGE RELAY AND THERMAL OVERLOAD l

SETPOINT PROBLEMS Addressees ,

i All holders of operating licenses or construction permits for nuclear power plants.

i Purcose The U.S. Nuclear Regulatory Commission (NRC) is issuing this information notice to alert addressees to continuing discoveries of undervoltage relay and thermal overload setpoints that are set too low. It is expected that recipients will review the information for applicability to their facilities and consider actions, as appropriate, to avoid similar problems. However, suggestions contained in this information notice are not NRC requirements; therefore, no specific action or written response is required.

Backaround ,

In August 1976, the NRC wrote generic letters to all LWR licensees regarding the need'for licensees to evaluate any generic implications of several events at the Millstone site involving episodes of sustained degraded grid voltage.

On June 2,1977, as part of multiplant action MPA-23, the staff stated its position that all licensees must have a second level of undervoltage protection with a time delay. (During degraded grid voltage episodes, undervoltage relays and thermal overload protective relays protect the safety equipment.) In a generic letter dated August 8,1979, the NRC requested all licensees to determine the capability of the offsite power system to operate all required loads within their voltage ratings under all conditions within their design basis. The licensees reviewed their undervoltage relay setpoints on each of these occasions. In 1981, the NRC issued Branch Technical .

Pesition, Power System Branch-1, " Adequacy of Station Electric Distribution System Voltages," which discussed, among other things, the addition of a second undervoltage relay with an associated time delay. Between 1981 and 1992, the NRC issued two information notices, in which it discussed undervoltage relay setpoints and other concerns:

1. IN 84-02, " Operating a Nuclear Power Plant at Voltage Levels Lower than Analyzed," issued January 10, 1984.

2. IN 91-29, " Deficiencies Identified During Electrical Distribution System Functional Inspections," issued April 15, 1991.

9312150073

IN 93-99 I

a December 21, 1993 Page 2 of 3

! 3. IN 91-29, Supplement 1, " Deficiencies identified Durin Electrica? Distribution System Functional Inspections,g issued September 14, 1992.

In addition, recognizing that certain degraded grid voltage problems resulted from inadequate control over the design process, on September 12, 1988, the NRC issued Generic Letter 88-15, entitled, " Electric Power Systems -

i Inadequate Control Over Design Processes."

j Descrintion of Circumstances i

Since 1989, the NRC has performed electrical distribution system functional inspections at nuclear power plants. The NRC has found design weaknesses in i several electrical distribution system areas including undervoltage relay i

setpoints for degraded grid voltage. These are addressed in IN 91-29 and in IN 91-29, Supplement 1. From May 1990 to January 1993, over 30 licensees wrote to the NRC about inadequate setpoints. Licensees found that the i undervoltage relay setpoints were set so low that safety equipment would not

have been protected if degraded grid voltage had occurred. Three licensees

! discovered deficiencies in which the thermal overload protective relay i setpoints were set too low.

1 l Discussion J

4 In the last few years, licensees began extensive efforts to improve the i

adequacy and completeness of the set of design bases, design analyses, and i final design output documents that define the design of their facilities. The licensees began these initiatives primarily because, during inspections such as safety system functional inspections and safety system outage modification inspections, the NRC consistently found that some licensees have made plant modifications which have affected the functionality of safety systems ,

e w

making the appropriate setpoint change. The NRC inspection findings prompted many licensees to review and reconstituts their. design bases.

twhM

~ ~

L- veW c These reviews and the generic communication documents discussed above prompted licensees to submit technical specification changes for undervoltage relay satpoints tha,t were discovered to be incorrect after the problem was created for one of several reasons shown (see Attachment 1). Attachment I was developed from 50.72 reports as a representative summary of the types and number of problems encountered. Subsequent LERs may provide additional  !

information. Of the reports where the cause could be determined based on the event report, design error was the predominant cause of the problem. i Licensees have generally found setpoint problems when the setpoints were examined as a result of a special inspection or design basis reconstitution.

)

l

751 IN 93-99 December 21, 1993

• Page 3 of 3 This information notice requires no specific action or taritten response. If you have any questions about the information in this notice, please contact the technical contact listed below or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager.

T  !

l 1

Brian K. Grimes, Director l Division of Operating Reactor Support l

, Office of Nuclear Reactor Regulation

Technical contact: C. Morris, NRR j (301) 504-2778 l 3  !

l Attachments:

1

1. Representative List of Undervol'ge i Relay Setpoint Revisions 1988-!M3 l

2. List of Recently Issued NRC Information Notices i i  !

. l l

l

• e l

l l

1 I

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c 1

4 Attachment 1 IN 93-99 i.

' December 21, 1993 Page 1 of 2 i

Reoresentative List of Undtrvoltaae Relav Set Point Revision Notifications and Technical Soecification Chanae Prooosals for 1988-1993 Event Notification Licensee Number Event Notification Date Ghn 11374 Pilgrim 1 January 30, 1988 1 7- 14043 Pilgrim 1 November 18, 1988 5

/ 00000 Pilgrim 1 June 30, 1988 1

' <f 14780 Cooper 1 February 17, 1989 c 5 16540 Crystal River 3 September 8, 1989 1

& 17121 Robinson 2 November 16, 1989 1

18322 Oconee 1, 2 and 3 April 24, 1990 5

! ( 18466 McGuire 1 and 2 May 14, 1990 1 S

18892 St. Lucie 2 July 14, 1990 2

'. 19023 Haddam Neck 1 August 2, 1990 5

20021 Calvert Cliff I and 2 December 6, 1990 1

-'20435 Ft. Calhoun February 12, 1991 1

20503 Kewaunee 1 February 20, 1991 5

. 20542 '

Salem 2 February 27, 1991 2 1 21691 Dresden 2 and 3 August 23, 1991 5

. 22281 ,* Dresden 2 November 20, 1991 1

~ 22498 Zion 1 and 2 December 19, 1991 4

5 I i 1 22580 Indian Point 3 January 9, 1992 5

.- 22658 Dresden 3 January 22, 1992 5 22847 (TOL) Washington Nuclear 2 February 19, 1992 5 y 22918 Washington Nuclear 2 March 1, 1992

'- 1

23148 Vermont Yankee April 1, 1992 4

23191 Quad Cities I and 2 April 7, 1992 5

):'23338 LaSalle 1 and 2 April 27, 1992 1

23365 . LaSalle 2 April 29,1992 1

2 23385 Crystal River 3 May 1, 1992 5

' 23439 (TOL) Grand Gulf May 11, 1992 3

[ 23452 Comanche Peak 2 May 13, 1992 1 3 23576 Crystal River 3 June 4, 1992 1 9 23784 Zion 1 and 2 July 2, 1992 5

23932 Byron 1 and 2 July 24,1992 1

~ 00000 Callaway July 23, 1992 1

' 24229 Crystal River 3 September 14, 1992 1

- ,'24384 Dresden 2 and 3 October 6, 1992 5 cTOL = Thermal Overload

l.

Attachment 1

!'* IN 93-99 j December 21, 1993

Page 2 of 2

, Event Notification Licensee Event Notification Date Clagg Number i M 00000 Prairie Island I & 2 November 6, 1992

6 00000 St. Lucie 1 1

November 30, 1992 1 7 24757 Maine Yankee December 15, 1992 i

600000 5

, Diablo Canyon 1 and 2 December 22, 1992 1 1

i ',f24845 Point Beach I and 2 ' January 7,1993 1

- 25248 (TDL) Pilgrim March 29, 1993 5 t 9f 25362 South Texas April 6, 1993 5

{ i.i t gh Po lj @ l i

Events Notification Number-00000 Licensees whose undervoltage relay setpoint notifications to the NRC were reported by LERs, licensee letter, etc., and i 4

event notification numbers if any, were not known.

j Class Definitions:

1 j 1. Undervoltage Relay setpoints were found to be incorrect because of

design errors. ,

) 2.

Undervoltage Relay setpoints, as found, were not the same as required by 4

the'*technical specification.

{ 3. Safety load circuit breaker thermal overloads or other trip setpoints j

were too low because of design errors.

! 4. Safety load circuit breaker thermal overload, or other trip setpoints, as found, were not the same as required by the technical specification.

! 5. Membership in one of the preceding four classes could not be definitely established because of incomplete information in the event notification.

l 4

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}

j .* Attachment 2 h IN 93-99 December 21, 1993 ia- '

Page 1 of 1 i

LIST OF RECENTLY ISSUED

! NRC INFORMATION NOTICES

! Information Date of j Notice No. Subject Issuance Issued to i

93-98 Motor Brakes on Valve 12/20/93 All holders of OLs and cps j Actuator Motors for nuclear power reactors.

i

93-97 Failures of Yokes 12/17/93 All holders of OLs or cps Installed on Walworth for nuclear power reactors.

I 1

Gate and Globe Valves

! 93-96 Improper Reset Causes 12/14/93 All holders of OLs or cps l Emergency Diesel for nuclear power reactors.

Generator Failures

! 93-95 Storm-Related Loss of 12/13/93 All holders of OLs or cps j Offsite Power Events for nuclear power reactors due to Salt Buildup located close to a large on Switchyard Insulators body of salt water.

93-94 Unauthorjzed Forced 12/09/93 All holders of OLs or cps i Entry into the Pro- for nuclear power reactors.

! tected Area at Three

!

• Mile Island Unit 1 on i February 7, 1993 i 93-93 Inadequate Control of 12/08/93 All holders of OLs or cps j Reactor Coolant System for nuclear power reactors.

j Conditions During Shutdown l

93-92 Plant Improvements to 12/07/93 All holders of OLs or cps Mitigate Common Depend- for nuclear power reactors.

anc.ies in Component Cooling Water Systems 91-21 Inadequate Quality 12/07/93 All holders of Ols or cps Supp. 1 Assurance Program of for nuclear power reactors Vendor Supply <ng and all recipients of Safety-Related Equipment NUREG-0040, " License Con-tractor and Vendor Inspec-tion Status Report" (White Book).

OL = Operating License CP = Construction Permit

)

!. IN 93-XX November XX, 1993

! Page 3 of 3 I This information notice requires no specific action or written response. If l

you have any questions about the informa" on in this notice, please contact the technical contact listed below or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager.

l l

i

' Brian K. Grimes, Director Division of Operating Reactor Support Office of Nuclear Reactor Regulation I

4 j Technical contact: C. Norris, NRR i (301) 504-2778 i

4 i Attachments:

l 1. Representative List of Undervoltage l Relay Setpoint Revisions 1988-1993 3

2. List of Recently Issued NRC Information Notices i

i i

i l ExcentiGHL The stress laid by the initial reviewer on the degree of concern that

} ifcensees and the staff should feel for such a widespread and persistent problen, viz.10w UVR set points, has been all but eliminated from the present IM.

f C.M0RRIS

15 N0V. 93 l \

i

i. l 4

1 j Document Name: G:\ SHARED \R3UNRELS.IN

' i

• SEE PREVIOUS CONCURRENCES # Concurred in electronically by JMain. -

}] D/ DORS:NRR *C/0GCB: DORS:NRR *0GCB: DORS:NRR )

1 BKGrimes GHNarcus NCampbell l

}), 11/ /93 08/10/93 07/30/93  ;

g F

• EELB:DE:NRR *SC/EELB:DE:NRR *C/EELB:DE:NRR *D/DE:NRR CMorris EWeiss CHBerlinger JTWiggins

• RPB:ADM Tech Ed l

jZ 04/28/93 U5/19/93 05/19/03 07/23/93 07/13/93 ,

lh 4

24A i

i .

' 1 l

UNITED STATES 5 .

[ War 'o g NUCLEAR REGULATORY COMMISSION l

[ o WASHINGTON, D.C. 20556-4001 E

March 14, 1996 OFFICE OF THE GENERAL COUNSEL MEMORANDUM TO: William T. Russell, Director  !

bffice of Nuclear Reactor Regulation  !

j ^()';

4 FROM: ack R. Goldberg

{-)DeputyAssistantGeneralCounsel l j

g for Enforcement

SUBJECT:

SECTION 2.206 PETITION OF C. MORRIS REGARDING ELECTRICAL  !

DISTRIBUTION SYSTEM AND UNDERV01.TAGE RELAY SET POINT ERRORS j Attached is a copy of a Petition filed pursuant to 10 C.F.R. I 2.206 by Mr. C.

Morris, requesting that the operating licenses of all nuclear power plants be s

suspended within 90 days, and remain suspended until such time as those plants have (1) discovered the reason for what Petitioner asserts are repeated errors in the plants' undervoltage relay (UVR) set points (SP) and electrical distribution system (EDS) designs, and (2) provided convincing evidence that 4 these deficiencies have finally been corrected. Because Petitioner has

' requested action be taken within 90 days, his request should be treated as one for immediate relief. Petitioner also requests that the aforementioned  :

evidence be reviewed by a competent third party in addition to the NRC staff, and that, if the NRC concludes that plants may safely operate with UVRs that cannot be properly set for long periods of time, the NRC should reach conclusions by way of holding a public meeting.

The Petition provides, as bases for the aforementioned requests, both additional information within the Petition itself as well as attached documentation. With regard to documentation, the Petition has an attached memorandum from Petitioner to "E. Weiss, S/C, EELB," dated April 19, 1993, wherein Petitioner discusses a draft proposed Information Notice (IN), in which among other things Petitioner (then an NRC employee) describes the need of a licensee to resolve the seemingly perpetual recurrence of UVR setpoint i errors and undersized thermal overloads. Petitioner has stated that he was told twice, both with regard to this memorandum and another from himself to E.

Weiss, dated November 3,1993, (also included with this Petition), that he was not permitted to write of his concern that after repeated attempts, many if not most licensees could not achieve correct UVR SPs and EDS designs.

Petitioner also states that he was told by two managers that his concerns in this regard could not be included in the memoranda because they could lead to  ;

fear and distress on the part of the general public, and because of the fear i of FOIA requests. Petitioner noted his concern at another point on the concurrence page of another draft IN, dated November 1993, which he also included with his Petition.

Contact:

Michael Rafky 415-1974

e i h

i l.'

I i

William T. Russell Petitioner also attached as documentation IN 93-99, which lists approximately l

4 forty licensees in an attachment as having had undervoltage relay set point 1

' connections. However, Petitioner's concern that the enduring and widespread .

nature of EDS and UVR SP errors was unrecognized by both licensees and the NRC l l staff was deleted from the final version of that Notice. i In terms of additional information contained within the Petition itself, the i i first reason Petitioner gives for repeated UVR and EDS deficiencies is that the BTP PSB-1 requirement for licensees to provide a degraded grid voltage l i relay with a long delay and a loss of power relay with a short relay is by l itself inadequate. This is because, Petitioner states, the issue is more 1

complex, as notwithstanding the arbitrary time constraints associated with the '

UVRs, there is no recognition of the dynamics of the voltages to which the j relays are to respond.  :

l l Petitioner's second stated reason in support of his Petition is that the

! tolerances on the UVRs (which are the standard deviations on normal

distributions) are statistical in nature and therefore are not, as he believes i

the staff mistakenly views them, limits on the errors in the UVR SPs.

j Petitioner believes this represents a significant problem which may not be  ;

! resolvable using previous'.y attempted approaches.

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Next, Petitioner asserts that although all EDSs are required by GDC 17 to be )

testable, only portions of the EDSs and their logic are tested because, according to licensees, plants cannot be conveniently put into a state that i

would allow actual emergency loads to be placed on the EDS and measured.

Petitioner also believes that while lead nameplate ratings are used to analyze I i EDS voltages, it is common knowledge that most loads are operated at only a j fraction of their ratings. Furthermore, worst-case ambient temperatures are used in selecting time delays for motor protection, even though few if any l loads are actually run under such conditions, notwithstanding the possibility  !

of a LOCA when safety load protections are bypassed regardless. '

Petitioner's fifth point of support is that raising the UVR SPs might have the  !

. result of reducing the safety advantage of providing UVRs on the EDS, as more  !

frequent and unnecessary actuations of the UVRs will occur. That in turn  :

. would lead to the associated logic initiating unnecessary PS transfers.  ;

' l l The sixth reason Petitioner gives in support of his Petition is that in l l

j IN 95-05, the NRC staff found that peak reading voltmeters calibrated for RMS are affected by the proportions of harmonics in the AC voltages on the bus and in the calibrators used to set the UVRs. In addition, Petitioner states that i l i harmonics also affect the response of the UVRs, in effect changing their SPs,

when the harmonic content of the bus voltages changes, i

Petitioner's final reason provided is that impedances and inrush currents to  ;

I motors and other loads are not known to the level of precision with which the '

NRC staff and licensee engineers have been attempting to set UVRs. Petitioner i believes that both groups must recognize that their task may be impossible and that their attempts to complete it have increased the risk of a nuclear J accident.

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. William T. Russell Problems with the text of IN 95-05, Peti?.ioner believes, suggest that some NRC staff may be unclear as to the function t f UVRs, and that it may be expected that the long history of UVR concerns will continue if licensees continue to o>erate nuclear power plants with design deficiencies. In Petitioner's view, tiose licensees should not be allowed to do so.

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I have attached drafts of a letter of ackiowledgement to the Petitioner and a Notice of Receipt of the Petition for publication in the federal Register.

) Since Petitioner's request for suspension of all nuclear power plant operating licenses is being treated as a request for immediate relief, a portion of the acknowledgement letter will require input from your staff regarding whether the immediate relief requested is warranted.

Please inform Michael Rafky of my staff of the technical contact who will be  ;

involved in preparing a response to the Petition. Also, please ensure that I am provided copies of all correspondence related to the Petition and that I am asked to concur on all staff correspondence.

Attachments: 1. Copy of Petition

2. Draft of Letter to Petitioners

3. Draft Federal Register Notice l

cc w/atts: M. Malsch, OGC l S. Burns, OGC  !

W. Olmstead, DGC '

L. Chandler, OGC T. Martin, RI S. Ebneter, RII l H. Miller, RIII i

L. Callan, RIV l i

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i (10 C.F.R. 1 2.206)

Mr. C. Morris 6516 Roy Shafer Road Middletown, Maryland 21769

)

Dear Mr. Morris:

This is to acknowledge receipt of your letter dated March 5,1996, requesting action with regard to all nuclear power plant licensees. Your request is  !

being treated as a petition under 10 C.F.R. I 2.206 of the Commission's l

regulations.

1 i Your Petition requests that the operating licenses of all nuclear power plants i be suspended within 90 days, and remain suspended until such time as those j plants have discovered the reason for what you assert are repeated errors in p the plants' undervoltage relay (UVR) set points (SP) and electrical )

distribution system (EDS) designs, and provided convincing evidence that these )

! deficiencies have finally been corrected. Because you have requested action j within 90 days, your request is being treated as one for immediate relief.

i Your Petition also requests that the aforementioned evidence be reviewed by a i competent third party in addition to the NRC staff, and that if the NRC ,

i concludes that plants may safely operate with UVRs that cannot be properly set '

l- for long periods of time, the NRC should reach conclusions by way of holding a

! public meeting.

j You'have provided, as bases for your requests, both additional information j within your Petition itself as well as attached documentation. With regard to documentation, you have included a memorandum from you to "E. Weiss, S/C, EELB," dated April 19, 1993, wherein you discuss a draft proposed Information Notice (IN), in which among other things you discuss the need of a licensee to resolve the seemingly perpetual recurrence of UVR setpoint errors and undersized thermal overloads. You state that you were told twice, both with regard to this memorandum and another from yourself to E. Weiss, dated i November 3, 1993, (also-included with this Petition), that you were not l permitted to write of your concern that after repeated attempts, many if not i most' licensees could not achieve correct UVR SPs and EDS designs. You state l that you were told by two managers that your concerns in this regard could not i be-included in your memoranda because they could lead to fear and distress on the part of the general public, and because of the fear of FOIA requests. You noted your concern at another point on the concurrence page of another draft IN, dated November 1993, which you also included with your Petition. ,

You also attached as documentation IN 93-99, which lists approximately forty licensees in an attachment as having'had undervoltage relay set point r

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connections. However, your.. concern _that the_endur.ing and widespread nature of- --

~ 'EDS~and UVR SP errors was unrecognized by both licensees and the NRC staff was deleted from the final version of that Notice.

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Mr. C. Morris In terms of additional information contained within your Petition itself, the first reason you give for repeated UVR and EDS deficiencies is that the BTP PSB-1 requirement for licensees to provide a degraded grid voltage relay with a long delay and a loss of power relay with a short relay is by itself inadequate. This is because, you state, the issue is more complex, as notwithstanding the arbitrary time constraints associated with the UVRs, there is no recognition of the dynamics of the voltages to which the relays are to respond. i Your second stated reason in support of your Petition is that the tolerances on the UVRs (which are the standard deviations on normal distributions) are statistical in nature and therefore are not, as you believe the staff mistakenly views them, limits on the errors in the UVR SPs. You believe this i represents a significant problem which may not be resolvable using previously I attempted approaches.

l

! Next, you assert that although all EDSs are required by GDC 17 to be testable, '

! only portions of the EDSs and their logic are tested because, according to i licensees, plants cannot be conveniently put into a state that would allow I actual emergency loads to be placed on the EDS and measured. '

]

! You also believe that while load nameplate ratings are used to analyze EDS voltages, it is common knowledge that most loads are operated at only a fraction of their ratings. Furthermore, worst-case ambient temperatures are

used in selecting time delays for motor protection, even though few if any

{ loads are actually run under such conditions, notwithstanding the possibility of a LOCA when safety load protections are bypassed regardless.

s

! Your fifth point of support is that raising the UVR SPs might have the result

! of reducing the safety advantage of providing UVRs on the EDS, as more

frequent and unnecessary actuations of the UVRs will occur. That in turn I would lead to the associated logic. initiating unnecessary PS transfers.

J The sixth reason you give in support of your Petition is that in IN 95-05, the NRC staff found that peak reading voltmeters calibrated for RMS are affected i

by the proportions of harmonics in the AC voltages on the bus and in the a

calibrators used to set the UVRs. In addition, you state that harmonics also j affect the response of the UVRs, in effect changing their SPs, when the

! harmonic content of the bus voltages changes.

i Your final reason provided is that impedances and inrush currents to motors i

and other loads are not known to the level of precision with which the NRC

staff and licensee engineers have been attempting to set UVRs. You believe l that both groups must recognize that their task may be impossible and that l l their attempts to complete it have increased the risk of a nuclear accident. I a

4 Problems with the text of IN 95-05, you believe, suggest that some NRC staff l may be unclear as to the function of UVRs, and that it may be expected that  ;

the long. history of UVR concerns will continue if licensees continue to l l operate nuclear power plants with design deficiencies. In your view, those l licensees should not be allowed to do so.

Mr. C. Morris Your request for the suspension of all nuclear power plant licenses within 90 days for the purposes of remedying repeated errors in those plants' UVR SPs and EDS designs is because . [NRC to provide reasons for grant or denial of this request for immediate relief)

Your Petition has been referred to me pursuant to 10 C.F.R. I 2.206 of the Commission's regulations. As provided by section 2.206, action will be taken on your requests within a reasonable time. I have enclosed for your information a copy of the Notice that is being filed with the Office of the

) Federal Register for publication.

Sincerely, i

i 1

William T. Russell, Director

, Office of Nuclear Reactor Regulation l

h

Enclosure:

As stated 4

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l U.S. NUCl. EAR REGULATORY COMISSION Docket No.

RECEIPT OF PETITION FOR DIRECTOR'S DECISION ,

UNDER 10 C.F.R. I 2.206 l

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Notice is hereby given that by a letter dated Narch 5, 1996, Mr. C.  !

l Norris requested the U.S. Nuclear Regulatory Cossiission (NRC) to take action )

1 with regard to all nuclear power plants. i 1

The Petition requests that, within 90 days, the operating licenses of

!- all nuclear power plants be suspended until such time as those licensees have l l discovered the reasons for the repeated errors in their electrical i 1 j distribution system designs and in their undervoltage relay (UVR) set points, l and provided convincing evidence that these deficiencies have been corrected.

Since the Petitioner asserts that the situation is urgent, the request is

being treated as one for inunediate relief. The Petition also requests that i

the aforementioned evidence be submitted for review by a competent third i

. party, and that if the NRC finds that licensees may safely operate with UVRs that do not remain properly set, it do so in the context of a public meeting.

The Petition is being treated pursuant to 10 C.F.R. I 2.206 of tho Commission's regulations. The Petition has been referred to the Director of

Nuclear Reactor Regulation (NRR). As provided by Section 2."00, appropriate j action will be tairen on this Petition within a reasonable time. By letter dated , the Director [ granted or denied) Petitioner's request for

, _ . . . . _ _ - - - . ~ .

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immediate relief in the form of suspension of all nuclear power plant operating licenses. A copy of the Petition is available for inspection at the Commission's Public Document Room at 2120 L Street, NW, Washington, O.C.

. 20555.

3

) FOR THE NUCLEAR REGULATORY COMMISSION William T. Russell, Director j Office of Nuclear Reactor Regulation

! Dated at Rockville, Maryland 1

this day of 1996.

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