IR 05000338/1986025

Insp Repts 50-338/86-25 & 50-339/86-25 on 861013-1117. Violation Noted:Failure to Establish Adequate QC Measures to Ensure Proper Incorporation of Tech Spec Amends

ML20215C476
Person / Time
Site:	North Anna
Issue date:	12/02/1986
From:	Caldwell J, Cantrell F, King L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20215C461	List: IR 05000338/1986025 ML20215C458 ML20215C464
References
50-338-86-25, 50-339-86-25, IEB-85-002, IEB-85-012, IEB-85-12, IEB-85-2, NUDOCS 8612150165
Download: ML20215C476 (10)

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. UNITE 3 STATES

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NUCLEAR REGULATORY COMMISSION

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g j 101 MARIETTA STREET, N.W.-

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Report Nos.:- 50-338/86-25 and 50-339/86-25

- Licensee: Virginia' Electric and Power Company-

' Richmond, VA .-23261 ( Docket Nos.:- 50-338-and 50-339 ' License Nos.: NPF-4 and NPF-7 Facility Name: North Anna 1 and 2-Inspection Conducted October 13 - November 17, 1986 ,

(Inspectors: (M /2 8 J. L. Cal l}, SRI- Datb Signed L. P. King, RI fd- /2h 5 Date Signed

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Approved by: M F. S. Cantrell, Sb d Chief

/2 2 6 Date Signed Division of Reacto rojects SUMMARY Scope: This routine inspection by the resident inspectors. involved the' following areas: plant status, licensee action on previous enforcement matters, monthly maintenance observation,' monthly surveillance observation, ESF walkdown, review '

of inspector followup items, operational safety. verification and.IE Bulletin Results:'One violation was identified - the failure * of the licensee to establish adequate quality control measures to ensure p'oper r incorporation of Technical Specification amendments. See paragraph 9 for detail .

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REPORT DETAILS ,

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' dicenseeEmployeesContacted-

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, !*E.W.fH'arrell,StationManager- . . . x

• R. C.lDriscoll,tQuality Controli(QC) Manager G.sEe Kane, Assistant: Station Manageri

• E.xR. Smith,LAssistant Station' Manager

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= R. 0.:Enfinger, Superintendent, Operations:

_M. R.1 Kansler,-Superintendent, Maintenance

~A. .H.'Staffordh Superintendent, Health Physics "

, - *J. A." Stall, Superintendent, Technical ~ Services

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J.6L.l Downs, Superintendent,-Administrative Services J.:R 7 Hayes, Operations-Coordinator-20.LA.~ Heacock, Engineering Superviso D.;E.: Thomas, Mechanical Maintenance Superviso G._D. Gordon : Electrical Supervisor

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• R.- A. Bergquist,eInstrurent Supervisor-F. T.1Terminella,_QA Supervisor--

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R. S. Thomas, Superinter. dent Engineering

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D. B. Roth, Nuclear Specialist

• J. H.~Leberstein, EAgineer

• G.'.G.-Harkness,-' Licensing Coordinator

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<0ther licensee employees contacted include technicians -operators, Emechanics,; security force members, and office' personne . . * Attended ~ exit : interview s

- Exit-Interview'

The-inspect. ion scope and findings were summarized on November 18, 1986, with those' persons indicated in' paragraph 1 above. The licensee acknowledged the

. inspectors findings. The licensee did not identify as proprietary any of'the material provided to or reviewed by the inspectors during this inspectio '(Open) Violation 338,339/86-25-01: Failure to establish adequate quality control measures to ensure that TS amendments are correctly incorporated into_TSs. See paragraph 9 for detail !3. l Plant Status Unit 1 Unit 1 began the inspection period at approximately 100% power and operated without any major problems until October 31, 1986. On '>ctober 31, Unit 1 power was reduced to less than 10% to allow the generator to be taken off line and the main turbine to be tripped. This reduction was required to allow the repair of an Electro-Hydraulic Control (EHC) System oil lea ^

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i This, leak had increased to the point where it was difficult to maintain EHC oil -inventory and consequently EHC oil pressure. The leak was also getting progressively worse. The licensee chose to reduce ' power to fix the leak

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rather than run the risk of an automatic turbine and subsequent reactor trip due to low EHC System oil pressure. The leak was repaired and Unit 1-

~ started' increasing power on November 1, 1986, and operated.at'approximatel % power for the remainder of the inspection perio Unit 2 Unit 2 began -the -inspection period at 100% power with a packing leak developing on the loop A . bypass valve. This leak had -increased the

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identified leak rate from approximately 0.8 gpm to approximately 6.5 gpm over a period of several days. On October 16, 1986, the identified leak rate- had increased to 8.89 gpm indicating the leak was getting worse; therefore, the. licensee choose to shut the unit down. The leak was' repaired

.and Unit 2 was started back up on October- 18, 1986, and stayed in a 30%

power secondary chemistry hold until October 22, 1986, when power was increased to 100%. The unit operated at 100% power for the remainder of the inspection perio . Licensee Action on Previous Enforcement Matters (92702)

(Closed) Violation 338,339/86-13-02: Design Change Packages on Batterie Administrative Procedure 3.1 has been revised to ensure that the Technical Specification surveillances have been satisfied during the design change proces . Review of Inspector Follow-up Items (92701)

(Closed) IFI 338,339/86-10-01: Batteries - Exide Cells Adjustmen It was determined after further testing and discussions with the vendor that a one-time adjustment was not necessar PT-86A was completed satisfactorily and the batteries specific gravities ir.dicate that no adjustments are necessar (Closed) IFI 338,339/86-10-02: Licensee Plans for Coping with Strikes. The North Anna Strike Plan was reviewed against the emergency response personnel staffing requirements listed in Section 5 of the NAPS Emergency Plan. The provisions set forth in the Strike Contingency Plan adequately meet the manning requirements specified in the Emergency Pla . MonthlyMaintenance(62703)

Station maintenance activities affecting safety related systems and components were observed / reviewed, to ascertain that the activities were conducted in accordance with approved procedures, regulatory guides and industry codes or standards, and in conformance with Technical Specification _ -

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<The ' inspectors observed the installation of packingion 2-FW-FCU-2488, Flow

- Control Valve ?B" Main Feed . (Work Request 121895).; Packing control form - ,

1MMP-C-GV-1.5:was-also reviewed. The Belleville washers ~for the live loading -

of-the:glandsiwere being replaced with thinner washer ,

.On-October 28,'1986, the-inspectors reviewed'1-TOP-49.1-" Alternate Service

. Water Lineyups for Pipe' Replacement". ~ The "B" ' return, header 1s being

hydro 1 red and 1-SW-250 valve is being replaced. The. controlling proc.adure -

is-1-M0P-49.08 " Removing #1-Supply-and #3 Return from Service". No problems

.were noted. The ' licensee assigned a reactor operator full time to

. coordinate the outages with operation .

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The' following ' radiation monitors have outstanding work requests:

RMS-159 - Containment Air Particle Monito Work Request dated 111/12/8 GW-101 - Process Vent. Work Request dated 11/17/3 SW-107 .

Component Cooling Heat Exchanger Service Water. Work Request Ldated 3/29/8 RMS-161 - Containment High Range Gamma. Work Request dated 4/10/8 '

RMS-162 - Manipulator Crane. Work Request 4/12/8 Kaman Monitors RI-VG-179-1 and RI-VG-179-2 - Vent Stack A is out of commissio RI VG-180-1 and RI-VG-180-2 - Vent Stack B is out of commissio RI-VG-178-1 and RI-VG-178-2 - Process Vent is out of commissio No violations or deviations were identifie . Monthly Surveillance (61726)

The inspectors observed / reviewed Technical Specification required testing and verified that testing was performed.in accordance with adequate procedures, that test instrumentation was calibrated, that limiting l conditions for operation (LCO) were met and that any deficiencies '

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identified were properly reviewed and resolve l The inspectors reviewed the following post accident sampling system l

calibrations:

1-PT-46.2.1 dated 7/23/86 t

1-PT-46.2.1 dated 1/2/86

1-PT-46.2.2 dated 1/6/86

< 1-PT-46.22 dated 7/24/86

i On November 12, 1986, the inspectors reviewed leak rate data for Unit 2 (2-PT-52.2). No problems were noted. The leak rates were .116 gpm unidentified leakage and .605 gpm identified leakage.

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m LThe. inspectorsE alsoireviewed 2-PT-82J_ " Emergency Diesel Generator Slow

5 -iStart Test". iThe diesel-wasioperated ;successfully at 0117 'on 11/13/86.~ .

i Noiproblems/ occurred.--

, No violations or deviations were identified.:

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18.: _ESFSystem'Walkdownt(71710)~~

i .1The following selected ESF; systems;were. verified operable'by performing 'a :

a -.walkdown of the accessible { and essential portions ;of the systemsion-

'% Novembern17,;1986.

$- The inspectors walked idown oth'e control e room bottled - air , pressurization .

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. system for : Unit -2. V.alve Checkoff. -1-OF-21.9A _ was J used. The' following

comments :are noted:

%' , The _ norma 11 position for 2-CA-6, #1-Header.0utlet Isolation Valve, is

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.-open . but it_ was found : closed. . The normal position for- 2-CA-11,' #2~

• . Header =0utlet Isolation Valve.ois closed but it was found open. The-valve: checkoff should ' indicate that 'either . position is acceptable,as -

U long as at least one valve is open.

! :The valve ' lineup position for 2-CA-13, TV-HV-2306A Inlet Isolation f Valve, .is: open but the actual-position istlocked open. If the valve is E ' required or desired to be locked open then the valve. lineup procedure should. reflect'that positio No violations or deviations were identified.

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, Operational = Safety Verification (71707)

!' By observations during the inspection period, the inspectors verified that the control room manning requirements were being met. In addition, the

inspectors observed shift turnover to verify that continuity of system status was maintained. The inspectors periodically questioned shift personnel relative to their awareness of plant condition Through log review and plant tours, the inspectors verified compliance with selected Technical Specification and Limiting Conditions for Operation In the course of the monthly activities, the resident inspectors included i a review of the licensee's physical security program. The performance of various shifts of the security force was observed in the conduct of daily

,, activities to include: protected and vital areas access controls, searching of personnel, packages and vehicles, badge issuance and retrieval, escorting of visitors, patrols and compensatory posts. In addition, the resident C inspectors observed protected area lighting, protected and vital areas

barrier integrity and verified an interface between the security organi-

. zation and operations or maintenance.

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On la Lregular basis, radiation work permits (RWP):were reviewed 'and. the

. specific work activity was monitored to assure the- activities were-being conducted per the RWPs. Selected radiation protection instruments were periodically checked and equipment operability and calibration frequency was

verifie ;The inspectors kept informed, on a daily basis, of-overall status of both units and of any significant safety matter related 'to plant operation ~ Discussions wereiheld with plant: management and various members of the operations staff'on a regular basis. Selected portions of operating logs and; data. sheets were reviewed dail The inspectors conducted.various plant tours and made frequent visits to the Control Room. Observations included: witnessing work activities in progress;.

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verifying the status of operating and ' standby safety systems and equipment; confirming valve positions, instrument and recorder readings, annuciator alarms, and housekeepin 'The following comments were noted:

=On October 29, 1986, while reviewing the control room operator's night orders, the inspector discovered the licensee had' replaced an Environ-mentally Qualified-(EQ) level instrument on the Volume Control Tank (VCT)

with a non-EQ 1evel instrument. The inspector reviewed the licensee's justification for the use of a non-qualified level instrument and determined that' the justification was based in part on a misunderstanding of 10 CFR

~ 50.49, paragraph The licensee understood the paragraph to allow the use of non-qualified replacement equipment if they have sound reasons. Their sound reason consisted of the'fcilowing:

.(1) The installed level instrument was questionable with regard to whether or not it would indicate properly or perfonn its control function

. . under normal or adverse condition (2) The VCT level instrumentation is not addressed in Technical Specifications therefore no action is required to be taken if the level instrument is declared inoperabl (3) The level instrument has no protection function and its control function, which is to cause an automatic swap of the charging pump suction from the VCT to the Refueling Water Storage Tank (RWST) on low VCT water level, is over-ridden during an accident by the Engineered Safety Feature (ESF) automatic swap of the charging pump suction. Therefore, the failure of the non-EQ 1evel instrument would not affect the operation of ESF equipment during an accident.

! (4) The operators were provided instructions not to use this le"el instrument to verify VCT level during adverse environmental condition _ _ --_ _

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• instrument during. normalloperating conditions was'far' greater -than;

!duringLadverse condition ~

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JTherefore, Lbased on the interpretation ~of paragraph 1 ~of ;10 CFR 50.49 'an'd '

- ,- : theiabove reasons, the ilicensee felt ' that 'it-was prudent to have an

- operational' non-EQ ' level: instrument installedL ratheri than an inoperable

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level' instrumen "

E iThe inspector discussed this situation ~with ~ ~both the headquarters .and ,

, . regional . staffs- and : determined that . the correct interpretation 'of paragraph 1 ofJ10 CFR .50.49 only allowed' licensees to use replacement .

equipment which met DOR guidelines or NUREG-0588-instead of' upgrading:to-the

10'CFR 50.49 requirements if they had sound reasons, but did not all.ow the-use of non-qualified replacement equipment. zThis' interpretation is based on Regulatory Guide 1.89. . Based on this interpretation ' of 10.CFR 50.49,

,' . paragraph 1, the licensee modified the;non-qualified level- instrumentation to cause the-low VCT level signal from that i_nstrument to be'present.at all times.- The VCT has two leve11 instruments, and it takes two out of two low

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levelssignals to cause the automatic swap of the charging pump suctio '

The licensee began an investigation to determine the reason for these level

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. instruments'being on the EQ list. This investigation . revealed that these-

~1evel instruments were required to be EQ by Regulatory Guide (RG) 1.97 and ~

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per this _RG only one instrument is required to be EQ. Since the other VCT~

level instrument was EQ, the licensee removed the-modification from the '

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-non-qualified. level instrument and changed their EQ list. This EQ list '

change still indicates that both instruments are to be EQ, but allows one to

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be replaced with non-qualified equipment while a qualified replacement is being obtained. The licensee will endeavor to maintain both level instruments qualifie In another matter, the licensee's present method for incorporation of [

a approved 'TS arendments is to first make distribution of the amendment te F designated TS holders via pink copies of the TS amendment. These pink copies allow implementation of the TS amendment while waiting for the

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_ official distribution of the TS amendment (white copies) from the corporate i office.

t On October 20, 1986, the licensee distributed a memorandum to station i personnel holding official controlled copies of Technical Specifications F ~ (TS). This memorandum stated that pages attached provided corrections to

[ a previous pink copy TS distribution for the core uprat Again en ( October 21, 1986, the licensee distributed another memorandum making F additional corrections to the same TS Amendment (#84 for Unit 1 and #71 for

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Unit 2). After a review of these memorandums, the inspector requested more information from the licensee regarding the reason for the TS corrections.

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The licensee informed the inspector that the initial distribution of the TS

. amendment for the core uprate contained information different from that

approved by the NRC. These differences consisted of the reference to

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fm Mcorrectlaction statements for/ source range ' neutron flux and. 0vertempera-

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M4 ;ture~ Delta T4 instrumentation on_ Table ~ 3.3-1 of the .TS{ and cthe omission' of -

itwo action: statements'related.toqTable13.3-1.ofzthe.TS.:

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• Atithelinspector's request [ the ilicensee' initiated a : plant deviation' reportc c ~ documenting theJproblem, :the cause of the' problem, andf theccorrective' .

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! actions'which the licenseeLwill take =toipreventf recurrence. LThe ' licensee ; .

• . Lalso provided.the inspector with the following 4 sequence of. events which~1edL

Sto the Limproper

implementation of the core.uprate TS Amendmen J a'. . Theilicensee amendment.:84 for Unit 1 and 71 for Unit 2, was. approved:

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by the NRC.on-August 25,:1986.-

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. The licensee-made distribution of pink copies of this amendment _to the

, station TS holders for incorporation into their TS on; August 27,1986, sThese-pink copies were'made.from a copy of the:TS amendment provided to--

the 1 station licensing.-department from; the corporate licensing A department for that purpose'. , The' NRCiapproved license amendment was received by the corporate licensing department on August 28, 198 ~

d.- On October- 14,.1986, a reactor operator trainee discovered the apparent TS discrepancies and reported them to the station licensing departmen m J Theicorrected pink copies of the amendments were not issued until October 20,~1986, and had to be corrected again on October 21, 198 '

, The licensee. determined that the cause of the incorrect incorporation of TS r' , . amendment 84 for- Unit- 1 and 71 for Unit 2 was the use of 'a copy of the

, . amendment provided by the corporate licensing department which turned out to

, be different~from that approved by the NRC. Neither station nor corporate ..!

! -licensing._ personnel compared the. approved amendment with the pink ' copies l

which were- distributed for incorporation into the T The licensee's

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corrective action to prevent recurrence is to allow only the use of the NRC approved TS amendment to make the pink copies for incorporation into the T In November, the inspector received an official distribution memorandum dated October 30, 1986, stating that the official distribution (white copies) of Amendment 71 for Unit 2 contained typographical error This memorandum provided sheets which contained the corrected informatio The i typographical errors consisted of non-technical information such as L incorrect dates, but still indicates an apparent quality control problem l: with the incorporation of TS amendments by the corporate and station l licensing staff ,

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L On October 18, 1986, following the monthly inspection exit meeting, the inspector was informed that the licensee had identified an additional error in the official distribution (white copy) of amendment 71 for Unit 2. This error occurred during the retype of the amendment in the Corporate Offic The NRC approved amendment 71 for Unit 2 contained the following statement; I

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VEPCO is; authorized to operate the facility at steady state reactor power levels notEin excess of 2893 megawatts' (thermal)." The TS amendment distributed Fy the licensee for incorporation .into their -TS stated- the following: "VEPC0 is authorized to operate the facility.at steady state reactor. core' power levels in excess 2893 megawatts (thermal)." The omission of the word not in the 1Eensee's retyped version clearly changes- the meaning of the statement. However the station procedures and knowledge level of the' reactor operators would have prevented exceeding 100% power based on the use of'the incorect statement in T CFR 50 Appendix B Criteria VI states the following: " Measures shall be established to control the issuance of documents, such as . instruction procedures, and drawings, including changes thereto, which prescribe all activities affecting' qualit These measures shall assure that documents, including changes, are reviewed for adequacy and approved for release by authorized personnel and are distributed to and used at the location where the . prescribed activity is performed. Changes to documents shall be reviewed _ and approved by the same organizations that performed the original review and approval unless the applicant designates another responsible organization."

Contrary to the above, on August 27, 1986, the licensee issued TS Amendments 84 for Unit 1 and 71 for Unit 2 which were incorporated into the

.TS containing incorrect information, and on October 22, 1986, the licensee issued the official distribution of TS amendment 71 for Unit 2 which contained typographical errors and omissions. The failure of the licensee to establish adequate quality control and assurance measures to ensure that NRC approved TS amendments are correctly incorporated into their TS is identified as a Violation, 338,339/86-25-0 Another issue that was reviewed involved Service Information Letter (SIL)

445 issued by General Electric (GE) describing a problem with the intermediate range neutron monitoring system at the Monticello Nuclear Plant. This problem involved a failure of the + and - 24 vde power supply fuses and the lack of positive indication that the - 24 vde fuse was operabl The inspector discussed this SIL with the licensee and determined that the policy for fuse replacement at the North Anna Power Station (NAPS) is as tollows. If the replacement of a fuse does not require equipment disassembly, the fuse may be replaced without the use of an Instrument Maintenance Procedure. However, the technician replacing the fuse must verify that the replacement fuse is operable by ensuring that the condition which indicated the fuse had failed has cleared. If the replacement of a fuse requires equipment disassembly, then an Instrument Maintenance Procedure is required and for all Technical Specification (TS) related instrumentation at least a TS channel functional test is required upon equipment reassembly to verify operability. In the case of the 25 vdc neutron monitoring instrumentation at NAPS, the replacement of the 25 ydc fuses requires disassembly of the drawer. Therefore, the minimum retest requirements for declaring the IR drawer operable is a TS channel functional tes c -

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9-During a review of' the control, room logs, the inspector discovered that on October 28, 1986, the Unit 1 B charging pump-had been secured due to an oil-leak'...The Unit 1 A charging pump was operating and the C charging pump was zinoperable.due to having the motor removed. The unit was operating at 100%

power.and the TS requirement for_this condition-required two charging pumps to.be operable. The inspector questioned the licensee as to whether the oil leak caused the B charging pump to be inoperable and'was told that-it was considered operable. However,-the inspector was not able to determined if a complete evaluation had been performed to determine the _ leak size and how -

long the charging pump would' operate without operator action -if. a safety injection occurred.and the A charging pump failed as the single failur The licensee informed theEinspector that the leak was considered minor and they were confident that the charging pump was capable of performing its intended functio The charging pump oil leak was repaired and the charging pump was operated on October 31, 1986, to verify the leak repair and pump operability. The licensee also provided the inspector a memorandum dated November 7,1986, presenting an engineering evaluation of the oil leak and how it affected the operability of the charging pump. The memorandum concluded that, after taking a conservative estimate .of the oil leak the charging pump would operate several days without operator action. The memorandum also stated that the lube oil level was under surveillance every four hours by operator logs which was sufficient to detect the necessity for oil makeup. The inspector discussed with the licensee the need to conduct this type of thought process and evaluation on all equipment problems associated with TS related and especially ESF equipment to ensure their availblity in the case of an acciden With the exception of the Violation involving TS changes, no violations or deviations were identified in this are . IE Bulletins (92703)

(Closed) 338,339/IE Bulletin 85-02: Undervoltage Trip Attachments of Westinghouse DB-50 Type Reactor Trip Breakers. The design change package for Unit I was installed on December 21, 1985, and the design change package for Unit 2 was completed on May 7, 198 (Closed) 338,339/IE Bulletin 80-12: Decay Heat Removal System Operabilit In inspection report 84-14, the resident inspectors reviewed IEB 80-12 and reconnended changes to the procedures to include an update of the ,

prerequisites for RHR pump Procedures M0P 14.01, 14.02 and AP-11 were .

reviewed by a regional inspector in report 86-21 and it was determined that the recommendations were incorporated in M0P 14.01 and 14.02, but not AP-1 The item was left open pending incorporation of the recommendations in AP-11. The resident inspector reviewed the necessity to incorporate the requirements with the licensee and former senior resident and concluded that it was not necessary to include the prerequisites in AP-11. This item is considered closed.

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