ML20129B548

Safety Evaluation Accepting Licensee 831104 & 850208 Responses to Generic Ltr 83-28,Items 4.1 & 4.5.1 & Requesting Addl Info Re Items 3.1.1,3.1.2,3.2.1 & 3.2.2 Concerning Testing & Maint Procedures

ML20129B548
Person / Time
Site:	North Anna
Issue date:	06/24/1985
From:	NRC
To:
Shared Package
ML20129B512	List: ML20129B509 ML20129B548
References
GL-83-28, NUDOCS 8507150537
Download: ML20129B548 (7)

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$ WASHINGTON, D. C. 20555 SAFETY EVALUATION VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION, Units NO. 1 AND NO. 2 DOCKET N05. 50-338 AND 50-339 GENERIC LETTER 83-28, ITEMS 3.1.1, 3.1.2, 3.2.1, 3.2.2, 4.1 AND 4.5.1

1. Introduction In February 1983, the Salem Nuclear Power Station experienced two failures of the reactor-trip system upon the receipt of trip signals. These failures were attributed to Westinghouse - Type DB-50 reactor trip system (RTS) circuit breakers. The failures at Salem on February 22 and 25, 1983, were believed to have been caused by a binding action within the undervoltage trip attachment (UVTA) located inside the breaker cubicle. Due to problems of the circuit breakers at Salem and at other plants, NRC issued Generic Letter 83-28, Required Actions Based on Generic Implementation of Salem

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Anticipated Transient Without Scram (ATWS) Events, dated July 8,1983. This letter required the licensees to respond on imediate-tenn actions to ensure reliability of the RTS. Actions to be performed ihcluded development of programs to provide for post-trip review, classification of equipment, vendor interface, post-maintenance testing, and RTS reliability improve-ments. The Generic Letter stated that for Actions 3.1.1., 3.1.2, 3.2.1, 3.2.2, 4.1, 4.4 and 4.5.1, NRC Regional Offices would perfonn a post-implementation review and issue Safety Evaluation Reports (SER). This report is the Regional SER for North Anna Units 1 and 2 and includes the results of R11's review of the licensee's submittals to Generic Letter 83-28. A Regional inspection was conducted at the North Anna facility during April 8-12, 1985, to review the licensee's current program, planned program improvements, and implementation of present procedures associated with post-trip review, equipment classification, vendor inter- ,

face, post-maintenance testing, and RTS reliability. The details of the j inspection findings are discussed in Inspection Report No. 338, 339/85-11. 4 II. Review Guidelines The licensee's responses dated November 4,1983, and February 8,1985, were evaluated for compliance to the staff's positions delineated in Generic 1 Letter 83-28 for Action Items 3.1.1, 3.1.2, 3.2.1, 3.2.2, 4.1 and 4.5.1. ,

Item 4.4 is applicable to Babcock and Wilcox (B&W) plants and therefore is i not applicable to North Anna 1 and 2. The requirements of the above action l items as described in the Generic Letter are paraphrased below:

8507150537 850624 PDR ADOCK 05000338 P PDR

3.1. POST-MAINTENANCE TESTING (REACTOR TRIP SYSTEM COMPONENTS)

Position

1. Licensees and applicants shall submit the results of their review of test and maintenance procedures and Technical Specifications to assure that post-maintenance operability testing of safety-related components in the RTS is required to be conducted and that the testing demonstrates that the equipment is capable of performing its safety functions before being returned to service.

2. Licensees and applicants shall submit the results of their check of vendor and engineering recommendations to ensure that any appro-priate test guidance is included in the test and maintenance procedures or the Technical Specifications, where required.

3.2 POST-MAINTENANCETESTING(ALLOTHERSAFETY-RELATEDCOMPONENTS)

Position The following actions are applicable to post-maintenance testing:

1. Licensees and applicants shall submit a report documenting the extending of test and maintenance procedures and Technical Speci-fications review to assure that post-maintenance operability testing of all safety-related equipment is required to be conduct-ed and that the testing demonstrates that the equipment is capable of perforining its safety functions before being returned to service.

2. Licensees and applicants shall submit the results of their check of vendor and engineering recomendations to ensure that any appropriate test guidance is included in the test and maintenance procedures or the Technical Specifications where required.

4.1 REACTORTRIPSYSTEMRELIABILITY(VENDOR-RELATEDMODIFICATIONS)

Position All vendor-recomended reactor trip breaker modifications shall be reviewed to verify that either: (1) each modification has, in fact, been implemented; or (2) a written evaluation of the technical reasons for not implementing a modification exists.

I For example, the modifications recommended by Westinghouse in NCD-Elec-18 for the DB-50 breakers and a March 31, 1983, letter for the DS-416 breakers shall be implemented or a justification for not imple-menting shall be made available. Modifications not previously made shall be incorporated or a written evaluation shall be proVided.  :

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4.5 REACTOR TRIP SYSTEM RELIABILITY (SYSTEM FUNCTIONAL TESTING)

Position On-line functional testing of the reactor trip system, including independent testing of the diverse trip features, shall be performed on all' plants.

1. The diverse trip features to be tested include the breaker undervolt-age and shunt-trip features on Westinghouse, Babcock and Wilcox (B&W) and Combustion Engineering (CE) plants; the circuitry used for power interruption with the silicon-controlled rectifiers on B&W plants and the scram circuitry) pilot valve and on General backup-scram Electric (GE) plants.valves (including all initiating III. Evaluation and Conclusion By letters dated November 4,1983, and February 8,1985, Virginia Electric and Power Company (VEPCO), the licensee of North Anna Power Station, Units -

I and 2, provided information regarding their compliance to Sections 3.1, 3.2,

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4.1 and 4.5 of Generic Letter 83-28. We have evaluated the licensee's responses against the NRC positions described in Section II above for completeness and adequacy. We concluded that the licensee's responses to Action Items 3.1.1, 3.1.2, 3.2.1 and 3.2.2 are incomplete and additional information is required to determine acceptability. The responses to Action Items 4.1 and 4.5.1 are acceptable and meet the intent of Generic Letter 83-28. Delineated below is a brief sumary of the licensee's response and the results of the Regional Evaluations:

a. Item 3.1.1, Review of Test and Maintenance Procedures and Technical Specifications (RTSC).

The licensee's response to this item is considered incomplete and additional information is needed to determine acceptability. The licensee needs to confim in their response that test and maintenance procedures and Technical Specifications have been reviewed for all safety-related components in the RTS. This review is to assure that post-maintenance testing is specified in the working level procedures and that the testing will verify component capability to perfom safety functions prior to being returned to service. The licensee's response dated February 8,1985, only states that the Administrative Procedures, OA procedures, and Technical Specifications require demonstration of equipment operability before returning to equipment service. The response does not confirm that individual maintenance and test procedures have been reviewed to ensure they contain post-maintenance testing requirements specified by Administrative Procedures, QA procedures, and Technical Specifications. We request that the licensee provide a statement con-firming that test and maintenance procedures and Technical Specifications associated with the Reactor Trip System were reviewed to assure that

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post-maintenance testing is required. In addition, the statement should indicate whether such testing adequately verifies component capability to perfom its intended safety functions.

b. Item 3.1.2, Check of Vendor and Engineering Recomendations for Testing and Maintenance The licensee's response to this item is considered incomplete and additional infomation is needed to determine acceptability. The licensee states in their response that Station Controlling Administrative procedures require current vendor infomation be referenced or included in test and maintenance procedures. The licensee also states that vendor recomendations for testing and maintenance of the Reactor Trip Breakers have been reviewed and in-corporated into plant procedures. However, the licensee does not state whether a review was made of test and maintenance procedures for other safety-related components in the RTS to verify that appropriate vendor and engineering infomation was included in the procedures. It is con-cluded from the response and from discussion with plant personnel (In-spection Report 338,3339/85-11) that only new and revised vendor informa-tion will be reviewed and evaluated for incorporation into plant procedures.

The Generic Letter is quite specific in this area in that it states in part that, " licensees shall submit the results of their check of vendor and

. engineering recommendations to ensure that any appropriate test guidance is included in the test and maintenance procedures or the Technical  %

Specifications." However, the respo1se does not address the adequacy

. - of current (in use) procedures which are developed from older vendor '

and engineering recomendations. We request that the licensee provide additional information on:

(1) How VEPCO's administrative procedures ensure that all previous vendor and engineering recomendations were appropriately incorporated into test and maintenance procedures or Technical Specifications.

(2) The results of VEPCO's check to detemine if vendor and engineering recomendations have been included in current test and maintenance procedures.

c. Iten 3.2.1, Review of Test and Maintenance Procedures and Technical Specifications (All Other Safety-Related Comporents)

The licensee's response to this item is considered incomplete and additional information is needed to determine acceptability. We request that the licensee provide a statement confirming that test and maintenance procedures and Technical Specifications were reviewed for all other safety-related components to assure that post-maintenance testing is required and that the testing verifies component capability to perform safety functions prior to being returned to service.

d. Item 3.2.2, Check of Vendor and Engineering Recomendations for Testing and Maintenance (All Other Safety-Related Components) ,

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.- .' 5 The licensee's response to this item is considered incomplete and additional information is needed to determine acceptabili.ty. For further discussion see paragraph b. We request that the licensee provide additional information on how VEPC0's administrative procedures ensure that all previous vendor and engineering recomendations were appropri-ately incorporated into test and maintenance procedures or Technical Specifications. ,

e. Item 4.1 Reactor Trip System Reliability (Vendor-Related Modifications)

The licensee's response to this action item is acceptable and meets the

- intent of Generic Letter 83-28. The licensee states in their submittal that all vendor recomended reactor trip breaker modifications have been implemented at North Anna Units 1 and 2. The licensee further states in their response that there are only two modifications recom-mended by the vendor for the DB-50 type reactor trip breakers used at North Anna. The modifications performed on the breakers are identified as follows: A NCD-Elect-18 dated December 17, 1971, requiring replacement of the undervoltage trip assemoly.

WES-3023 dated April 19, 1983, requiring removal of the over- "

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current trip bracket on the trip bar.

f. Item 4.5.1 Reactor Trip System Reliability (System Functional Testing)

The licensee's response to this item is acceptable and meets the intent of Generic Letter 83-28. The licensee confirmed in their response that on-line functional testing of the undervoltage and shunt-trip features shall be performed as part of the routine monthly logic testing. The procedures utilized for the testing will be based on the Westinghouse Owners Group test procedure submitted to NRC in a letter dated June 14, 1983. The Shunt Modification has been completed on Unit 2 and is scheduled to be completed on Unit I during the next outage of sufficient duration in 1985 (See Inspection Report 338, 339/85-11).

Unit 2 Periodic Test Procedure No. 2-PT-36.1, Reactor Protection and Engineered Safety Feature (ESF) Logic Test, has been revised to incorporate on-line functional testing of the auto shunt trip feature. This action was confi,rmed by the Region and is discussed in Inspection Report 338, 339/85-11. In conclusion, we recommend that the licensee should complete the shunt modification on North Anna Unit I during the next outage and implement the revised periodic test procedures. Finally the licensee should submit a statement confirming that this action has been completed for North Anna Unit 1.

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g. Conclusion Based on our review, we conclude that the licensee's submittals to items 3.1.1, 3.1.2, 3.2.1 and 3.2.2 are incomplete and additional information is needed to determine acceptability. However, items 4.1 and 4.5.1 were determined to be acceptable and meet the intent of GL 83-28.

l Acceptable responses to the above noted deficiencies are required before we can complete our review of the licensee's Post-Maintenance Testing (Reactor Trip System Components) and Post-Maintenance Testing (All Other Safety-Related Components) for the North Anna Power Station. Region II will review these responses when received and will report our findings in a supplement to this Safety Evaluation (SE).

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Mr. W. L. Stewart Virginia Electric & Power Company North Anna Power Station Richard M. Foster, Esq. Atomic Safety and Licensing Appeal Musick, Williamson, Schwartz, Board Panel Leavenworth & Cope, P.C. U.S. Nuclear Regulatory Comission P. O. Box 4579 Washington, DC 20555 Boulder, Colorado 80306 Regional Administrator Michael W. Maupin, Esq. USNRC, Region II Hunton, Williams, Gay and Gibson Office of Executive Director P. O. Box 1535 for Operations Richmond, Virginia 23212 101 Marietta Street N.W., Suite 2900 Atlanta, Georgia 30323 Mr. W. T. Lough Virginia Corporation Commission Mr. E. W. Harrell Division of Energy Regulation P. O. Box 402 P. O. Box 1197 Mineral, Virginia 23117 Richmond, Virginia 23209 Old Dominion Electric Cooperative Ellyn R. Weiss, Esq. c/o Executive Vice President Harmon, Weiss and Jordan Innsbrook Corporate Center 2001 S Street NW 4222 Cox Road, Suite 102 Washington, DC 20009 Glen Allen, Virginia 23060 Mr. J. H. Ferguson Mr. Richard C. Klepper Exer.utive Vice President - Power Board of Supervisors Virginia Electric and Power Co. Louisa County Courthouse Post Office Box 26666 P. O. Box 27 Richmond, Virginia 23261 Louisa, Virginia 23093 Mr. Anthony Gambardella Office of the Attorney General Supreme Court Building 101 North 8th Street Richmond, Virginia 23219 Resident Inspector / North Anna c/o U.S. NRC Senior Resident Inspector Route 2, Box 78 Mineral, Virginia 23117 Mrs. Margaret Dietrich Route 2, Box 568 Gordonsville, Virginia 22042 .

Mr. Paul W. Purdom Environmental Studies Institute Drexel University 32nd and Chestnut Streets >

Philadelphia, Pennsylvania 19104 L_.