IR 05000338/1979025

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IE Insp Repts 50-338/79-25 & 50-339/79-34 on 790507-11. Noncompliance Noted:Failure to Meet Acceptance Criteria & Failure to Document,Review or Approve Change to Procedure
ML19207A811
Person / Time
Site: North Anna  Dominion icon.png
Issue date: 06/08/1979
From: Kellogg P, Wagner A, Webster E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML19207A800 List:
References
50-338-79-25, 50-339-79-34, NUDOCS 7908220418
Download: ML19207A811 (8)


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Report Nos. 50-338/79-25 and 50-339/79-34 Licensee:

Virginit Electric and Power Company Richmoi, Virginia 23261 Facility Name: North Anna, Units 1 and 2 Docket ros. 50-338 and 50-339 License Nos. hTF-4 and CPPR-78 Inspection at North Anna Site near Mineral, Virginia Inspectors:

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Approved by:

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Inspection on May 7-11, 1979 Areas Inspected Unit 1 This routine announced inspection involved 46 inspector-hours onsite in the area of IE Bulletin response verification.

Unit 2 This routine unannounced iaspection involved 16 inspector-hours onsite in the areas of preoperational test results; startup tests; and proposed Technical Specifications.

Results Unit 1 One apparent item of noncompliance was iientified in the area inspected (Deficiency:

Failure to document, review or approve a change to a procedure paragraph 6.b).

Unit 2 Of the three areas inspected, no apparent items of noncompliance or deviations were identified in two areas; one apparent item of noncompliance was found in one area (li traction: Failure to meet acceptance criteria paragraph 8.b).

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DETAILS 1.

Per:ons Contacted Licensee Employees W. R. Cartwright, Station Manager

  • J. D. Kellams, Superintendent - Operations
  • E. W. Harrell, Superintendent - Maintenance S. L. Harvey, Operating Supervisor
  • E. R. Smith, Superintendent - Technical Services
  • W. Madison, NRC Coordinator
  • W. F. Drehl, QC Engineer
  • J.

F. Mostirone, Shift Supervisor NRC Resident Inspector

  • M. S. Kidd
  • Attended exit interview.

2.

Exit Interview The inspection scope and findings were summarized on May 11, 1979 with those persons indicated in Paragraph I above. The licensee acknowledged the noncompliance items discussed in paragraph 6b and 8b, but stated that corrective action would be formulated upon receipt of this report.

3.

Licensee Action on Previous Inspection Findings Not inspected.

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4.

Unresolved Items Unresolved items are matters about which more information is required to determine whetbcr they are acceptable or may involve noncompliance or deviations.

New unresolved items identified during this inspection are discussed in paragraph 6b.

5.

Plant Status During this inspection, Unit I was operating at 100% power and Unit 2 was in preoperational testing.

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6.

IE Bulletin 79-06A and 79-06A Revision 1 Response Verification - Unit 1 a.

Valve Position Verification To verify the licensee's response of April 26, 1979, two inspectors verified actual valve, breaker, and switch positions proper according to plant operating procedures for all accessible Engineered Safety Features (ESF) systems listed below. The procedures used had been verified to be complete and correct by NRC inspectors as described in IE Report 333/79-21 paragraph 6.

System Operating Procedure No.

Drawing No.

Auxiliary Feedwater 1-0P-28A FM-74A-10 1-0P-31.2A Sodium Hydroxide Injection 1-0P-7.8A FM-78F-3 Refueling Water Storage Tank 1-0P-7.7A Quench Spray 1-0P-7.4A FM-91A-12 Outside Recirculation Spray 1-0P-7.5A FM-91A-12 Inside Recirculation Spray 1-0P-7.10A FM-91B-2 Containment Atmosphere Cleanup 1-0P-63A FM-106A-5 Low Head Safety Iniaction 1-0P-7.1A FM-96A-9 High Head Safety FM-96A-9 Injection 1-0P-7.2A FM-96B-6 Chemical and Volume FM-95A-7 Control System 1-0P-8A FM-95B-7 FM-95C-6 Service Water 1-0P-49.1A FM-78B-8 AC Electrical System 1-0P-26A Diesel Fuel Oil 1-0P-53.1A FB-35A-7 1-0P-53.2A Diesel Air Start 1-0P-46.4A FM-107A-2

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Control Room Air Conditioning 1-0P-21.6A FB-40D-3 Control Room Pressurization 1-0P-21.9A FB-34F-2 The inspector noted the following:

(1) Two stean drain valves:

1-MS-338 and 1-MS-422, on the steam driven auxiliary feedwater pump were not open, as required by 1-0P-31.2A. Licensee representatives explained that they are evaluating the proper pocitioning for these valves, but do not desire them open since this would result in steam release inside the pump cubicle when the pump is running. The inspector will review this area when the licensee has resolved the valve posi-tioning for these two valves (338/79-25-01).

(2) Fifteen valves were found to be locked in their proper position and under proper administrative controls which were not designated to be locked in their respettive valve check sheets.

Licensee management noted this and agreed to correct the three valve check sheets involved.

(3) Numerous valves were not labeled, most significantly in the casing cooling system. Licensee management agreed to look into this, though it was noted that valve descriptions in the valve check sheets were sufficient to identify most valves that are not labeled.

No items of noncompliance or deviations were identified.

b.

Surrevillance and Maintenance Test Review The inspectors reviewed the licensee's Maintenance Operating Procedure (M0P) and Periodie Tests (PT) to verify that ESF systems are restored to operable status following testing or maintenance. Further, the last completed PTr were reviewed to insure that acceptance criteria for ESF systems had been met.

The procedures reviewed are listed below and are marked with an asterick (*) where test results were also reviewed.

1-PT-13.3* Boration System 1-PT-14.1* Charging Pump 1A 1-PT-14.2* Charging Pump 1B 1-PT-14.3* Charging Pump 1C 1-PT-32.7.1* Instrument Calibration 1-PT-36.7.1 ESF Valve Response Time 1-PT-36.7.3 ESF Pump Response Time 1-PI-56.2* Accumulators 1-PT-56.3*' Accumulator Valves Vd1MO

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1-PT-57.1A* LHSI Pump 1A 1-PT-57.1B* LHSI Pump IB 1-PT-57.1C* ECCS Valves 1-PT-57.2* Valve Test 1-PT-57.3* ECCS Subsystem 1-PT-57.4 SI Functional Test "A" Train 1-PT-57.5 SI Functional Test "B" Train 1-PT-59.1* Boration Systems 1-PT-63.1A* Quench Spray "A" Train 1-PT-63.1B* Quench Spray "B" Train 1-PT-63.3 Quench Spray Air Test 1-PT-64.1A* Recirc Spray "A" Pumps 1-PT-64.1B* Recirc Spray "B" Pumps i-PT-64.2A* ORS Pump 2A 1-PT-64.2B* ORS Pump 2B 1-PT-64.3* Recirc Spray Air Test 1-PT-64.4A* Casing Cooling "A" Train 1-PT-64.4B* Casing Cooling "B" Train 1-PT-65.2 Chemical Addition System 1-PT-66.2 Containment Isolation Phase A Valve Test 1-PT-67A* Hydrogen Analyzer Calibration 1-PT-67B* Hydrogen Analyzer Calibration 1-PT-68.1.1* Recombiner Functional Test 1-PT-68.1.2* Recombiner Functional Test 1-PT-68.2.1 Recombiner Operability Test 1-PT-66.2.2 Recombiner Operability Test 1-PT-71.1* AFW Steam Driven Pump and Valves 1-PT-71.2* AW Pump 3A Test 1-PT-71 3* AFV Pump 3B Test 1-PT-71.4* AW Pump Logic Test 1-PT-75.1* Service Water Valves 1-PT-75.2A* Service Water Pump 1A 1-PT-75.2B* Service Water Pump IB

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1-PT-76.1A* Emergency Ventilation 1-PT-76.1B* Emergency Ventilation 1-PT-76.3* Bottled Air 1-PT-76.4 Bottled Air 1-PT-76.5* Emergency Ventilation 1-PT-76.6 Emergency Ventilation 1-PT-76.11 Emergency Ventilation 1-PT-76.12 Emergency Ventilation

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1-PT-76.13 Emergency Ventilation 1-PT-78.1* Residual Heat Removal System 1-PT-78.2* RHR Operability Test 1-PT-76.3a KHR Valve and Flow Test 1-PT-82A* IH Diesel Test 1-PT-82B* IJ Diesel Test 1-PT-84* AC Distribution 1-M0P-6.90 Emergency Diesel 1H 1-M0P-6.91 Emergency Diesel IJ 78.1.333

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1-M0P-7.01 LHSI Pump 1A 1-M0P-7.02 LHS1 Pump IB 1-M0P-7.04 IRS Pump 1A 1-M0P-7.05 IRS Pump IB 1-M0P-7.06 ORS Pump 2A 1-M0P-7.07 ORS Pump 2B 1-M0P-7.08 Quench Spray Pump 1A 1-M0P-7.09 Quench Spray Pump 1B 1-M0P-7.40 Valve MOV-RS-100R 1-M0P-7.41 Valves MOV-1867A and MOV-1867B 1-M0P-8.01 Charging Pump 1A 1-MOP-8.02 Charing Pump 1B 1-M0P-8.03 Charging Pump IC 1-MOP-8.04 Boric Acid Transfer Pump 2A 1-MOP-8.05 Boric Acid Transfer Pump 2B 1-M0P-26.70 MCC-iHI-25 1-M0P-26.71 MCC-IJI-2S apJ IJI-2N 1-M0P-26.73 MCC-IJI-1 1-MOP-26.74 MCC-IHI-4 1-M0P-31.01 AW Pump 3A 1-M0P-31.02 AW Pump 3B 1-MOP-31.03 AW Pump 2 1-MOP-49.04 Service Water Pump 4 1-MOP-90.2 Generic Procedure for Hea: Exchangers 1-M0P-90.6 Generic Procedure for Val.es The inspectors had the following comments (1) Procedures 1-PT-57.. A and 57.1B, both concerning LHSI pump run testing, do not spec lfy final pump switch lineup upon completion of the test. Step 4.8 in each of the procedures requires the pump be secured, with ao ensuing step to verify switch position.

Licensee management explained that since this switch is spring-returned to "AUT0", more detail had not been considered necessary, however, they agreed to revaluate the switch positioning in all ESP pump run test procedures (338/79-25-02).

(2) Periodic Test 1-PT-57.3 involved cycling various manual ECCS valves.

When completed on March 17, 1978, 7 valves were not cycled due to maintenance occuring on those systems. Although there is no Technical Specification requirement to cycle these valves, the licensee agreed to evaluate the valve cycling require-ments for the seven valves involved (338/79-25-03).

(3) Periodic Test 1-PT-76.5, which tests the ability of the charcoal absorber in the Control Room emergency ventilatiou system (1-HV-FL-8) to remove injected freon gas, was last conducted on March 29, 1979 following charcoal replacement.

Test results showed that 0.25% of the test gas leaked past the charcoal bed in 781QiO

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the test. The acceptance criteria, however, requires a maximum of 0.05% leakage based on Technical Specification (T.S.) 4.7.7.lb.1 Preliminary inquires to ONRR made by the inspector on May 10 and 11, revealed that the intent of T. S. 4.7.7.lf was to relax the leakage requirement of T. S. 4.7.7.lb.1 to 1% allowable leakage, and that the two specifications conflict.

Since the licensee took no corrective action based on the 0.25% leakage reading, this item is held unresolved pending action by the licensee and ONRR to resolve this comflict (338/79-25-04).

T. S. 6.8.3 details the requirements for making temporary changes to procedures which include documenting the change, the Station Nuclear Safety and Operating Committee (SNSOC) reviewing the change and the Station Manager approving the change within 14 days.

Since the acceptance criteria of step 5.3 of 1-PT-76.5 was altered when the procedure was conducted on March 29 and analyzed by a licensee engineer on April 24 to be a satisfactory change to the procedure, but said change was never documented, reviewed or approved by May 9, this appears to be in noncompliance with T. S. 6.8.3 (338/79-25-05).

7.

Precritical Test Procedure Review - Unit 2 The following Startup test was reviewed for conformance to Regulatory Guide 1.68, FSAR Section 5.5.5, FSAR table 14.1-2, VEPC0 Nuclear Power Station Quality /.ssurance Manual Section 5 and proposed technical specifications.

2-SU-14 Pressurizer Spray and Heater Capability Setting Continuous Spray Flow, approved 12-12-78.

The inspector commented on the failure to include all of the requirements of T. S. 3.4.9.2 for maintaining pressurizer heatup and cooldown within the required limits.

Also to include the requirements of T. S. 3.4.9.1 for maintaining RCS pressure within the limits of the pressure temperature These comments were incorporated into the procedure by procedure curve.

deviation form prior to the inspector departing the site.

8.

Preoperational Test Results Review - Unit 2 Completed preoperational test procedure results were reviewed for conformance with Nuclear Power Statiou Quality Assurance Manual sections 2, 5, 11, 14, and FSAR section 14.1.1.

No items of noncompliance or deviations were noted during the review a.

of the following procedures:

2-PO-11.4, Camponent Cooling System Test at Hot Plant Conditions, completion approved 3/6/79.

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e-7-2-PO-19, Hydrogen Removal System Test, completion approved 4/10/79.

2-PO-37.1, Quench Spray System Pump Performance Test, completion approved 3/6/79.

2-PO-31.2, Quench Spray System Spray Nozzles Testing, completion approved 1/8/79.

2-PO-38.1, Recirculatior. Spray System Pump Performance Testing, comple-tion approved 4/10/79.

2-P0-38.2, Recirculation Spray System Spray Nozzles Testing, completion approved 4/10/79.

b.

The following coments were noted during the review of test procedures results:

2-P0-11.1, Component Cooling System Test at Ambient Plant Conditions, completion approved 1/12/79.

It was noted by the inspector that the data recorded for component cooling pumps 2-CC-P-1A and 2-CC-P-1B did not meet the acceptance criteria listed in paragraph 5.1.

It was noted by the test engineers in the critique section that the acceptance criteria was met satisfac-torily.

This test had been audited by on-site Quality Control and this discrepancy was not noted. This is an apparent item of noncompliance in the area of failure to adequately review acceptance criteria (339/

79-34-01).

The inspector also noted in the data that the Residual Hert Removal heat exchangers did not meet design component cooling flow requirements listed in paragraph 5.2.

Heat exchanger 2-RH-E-1A had 6350 gpm with a 20 pound differential pressure and 2-RH-E-1B had 6150 gpm with a 20 pound differential pressure. The flow required by the procedure was 8900 gpm 10% at a 20 pound differential pressure. This discrepancy was noted by on-site Quality Lontrol during their audit of the procedure.

9.

Proposed Technical Specification Review - Unit 2 Subsequent to the inspection, the inspectors completed a review of the Proof and Review Copy of the Unit 2 Technical Specifications.

Coments from tne review have been forwarded to NRC Headquarters via separate corre-spondence concerning technical errors and typographical errors noted.

Specific differences betwe en Unit I and Unit 2 Technical Specifications were not addressed unless ',he Unit 2 proposed limits were less conservative than the present Unit 1 limia.

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