IR 05000338/1987039

Ack Receipt of Ltrs Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-338/87-39 & 50-339/87-39. Portion of Deviation Noted in of Dispute Will Be Withdrawn & Reexamined During Future Insp.Evaluation Encl

ML20155A171
Person / Time
Site:	North Anna
Issue date:	09/21/1988
From:	Gibson A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Cartwright W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
References
NUDOCS 8810050235
Download: ML20155A171 (5)

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September 21, 1988

/ Virginia Electric and Power Company ATTN: Mr. W. R. Cartwright Vice President Nuclear Operations P. O. Box 26666 Richmond, VA 23261 Gentlemen:

SUBJECT: NRC INSPECTION REPORT NOS. 50-338/87-39 AND 50-339/87-39 l

Thank you for your responses of February 26, March IS, and August 22, 1988, to l our Notices of Violation and Deviation issued on January 27, 1988, concerning 1 activities conducted at your North Anna facility. We have evaluated your responses and found that they meet the requirements of 10 CFR 2.20 In your response, you admitted the violation but denied a portion of the deviation. After careful consideration of the bases for your denial of one part of the deviation, the current NRC position regarding the documentation requirements for Emergency Operating Procedures, and comitments made in your letter of August 22, 1988, we have decided to withdraw the portion of the deviation in dispute. We will examine the implementation of your actions to i correct the violation and deviation during future inspection The responses directed by this letter and its enclosure are not subject to the clearance procedare! of the Office of Management and Budget as required by the paperwork reduction act of 1980 Pub L. No. 96-51 We appreciate your cooperation in this matte Sincerel Original signed by Al Gibson Albert F. Gibson, Director Division of Reactor Safety Enclosure: Evaluation and Conclusion cc w/ encl:

vG. Kane, Station Manager vN. E. Hardwick, Manager - Nuclear Programs and Licensing l

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I vliRC Resident Inspector ORS Technical Assistant Document Control Desk State of Virginia k

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ENCLOSURE

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EVALUATIONS AND CONCLUSIONS  ;

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1 On January 27, 1988, a Notice of Violation and a Notice of Deviation were issued for findings identified during an NRC inspection. VEPC0 responded to these Notices on February 26, 1988. The licensee admitted the Violation as [

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stated, but denied an item contained within the Notice of Deviation. The NRC's evaluation and conclusion for the area of the Deviation which was Jenied by VEPC0 is as follows:

Restatement of Deviation

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On July 1,1983, the licensee submitted a Procedure Generation Package (PGP)

I for Emergency Operating Procedures (EOPs) to the NRC. In that submittal, the -

j licensee committed to implement the Westinghouse Owners Group (WOG) Emergency

Response Guidelines (ERGS), Rev. 1, as approved by the NRC. In addition, the

licensees PGP required that justification of any significant deviation from an i ERG step and justification of all E0P setpoints be documented. The licensee us> a Step Deviation Document (SDD) for this documentation. The licentae's

PGP also required that controls and displays referenced in E0Ps be identified to assist the operator in accurate and quick identificatio The licensee's SDD for procedure ES-0.28, Natural Circulation Cooldown Without

Shroud Cooling Fans, Rev.1, failed to document justification of a significant i departure from the ER Step 20 of procedure ES-0.2B directed the operators a

to perform an isothermal depressurization following an 8-hour soak perio '

This represented a significant departure from the WOG ERGS wherein the l operators are directed to continue cooling down, following the soak period, .

, while maintaining 200*F subcoolin The RCS depressurization method used in l l step 20 of ES-0.2B resulted in significantly less upper head subcooling than I a in the ERG procedure from which it was derived. This step deviation was not j identified or justified in the licensee's SD !

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Also, the licensee's SDD failed to identify the use of different setpoint ;

j The minimum temperature / pressure cooldown curve shown in Attachment 1 i Pressure / Temperature Limits for Cooldown, to ES-0.2B was less conservative l

than the cooldown curve defined by Technical Specifications, Figure 3. <

Other setpoints contained in ES-0.2B were different from those used in the ERG !

(including cooldown rate; subcooling margin; and holdpoint pressur l 1 temperature, end time). These setpoint differences were not mentioned in the 1 licensee's 50 j

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Finally, the licensee's E0Ps for natural circulation cooldown ES-0.2A, Natural f Circulation Cooldown With Shroud Cooling fans, Rev. 1; ES-0.2B, Natural ;

Circulation Cooldown Without Shroud Cooling Fans, Rev.1; and ES-0.2, Natural ,

I Circulation Cooldown With Steam Void in Vessel (with RVLIS), Rev. 1 failed to !

I identify controls and displays to be used in maintaining cooldown pressure and I temperature limits in that Attachment 1. Pressure / Temperature Limits for

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Cooldown, did not indicate which temperature instruments are to be used.

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.. l Enclosure 2 Summary of Licensee's Response i

The licensee denied that there was a deviation for failure to document a significant deviation from the WOG ERG by performing an isothermal depressurization. The basis for this statement was derived from a comparison

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made between the generic methodology and the process used in the North Anna

! procedur The WOG ERG Background document defines operating limits for a generic plant design which are designed to maintain subcooling in the reactor vessel upper head during a plant cooldown on natural circulatio ,

The response also explained the methodology used to determine the plant  ;

specific setpoint values for North Anna. The licensea concluded that: i The North Anna natural circulation cooldown procedure (ES-0.28)

confo*ms to the corresponding generic guideline with no significant l

deviation in strategy, execution. or intent.

1 The plant specific natural circulation limitations maintain .

approximately the same subcooling margin in the reactor vessel upper head region as the generic guidelines through all phases of the cooldow This includes allowance for process instrumentation  !

accuracy as directed by the generic guideline i NRC Evaluation of Licensee Response  !

t The NRC discussed the E0P Setpoint Document with the licensee and Volian, the  !

consulting firm that performed the evaluation The licensee agrees with the ,

section of the deviation that cites the lack of documentation within the SDD  ;

for the isothermal depressurization and intends to cross-reference the l

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setpoint document as justificatio During subsequent telecons the licensee and the NRC agreed that procedure ES-0.2B does not place the plant in an i unanalyzed or unsafe ccnditio However, the licensees response indicated that their policy is to not document l deviations that the licensee considers to be consistent with the strategy and '

l intent of the WOG ERG The NRC is concerned that this policy is in conflict with conrnitments made in the PGP submittal which states that justification of i any significant deviation from an ERG step and justification of all E0P  ;

setpoints be documented, i Regarding the adequacy of the licensees E0P setpoint document; the inspectors reviewed this document dated 4/15/87, and found it to contain the following basis: "7) Af ter the wait period, the cooldown and depressurization is i

continued be placed while maintaining).at in operator (sic " leastWnst 200'F subcooling disturbed until theabout the inspectors RHR this system was can that it was cited in the E0P setpoint document that was supposed to justify an l isothermal depressurization that would be in direct conflict with the above I noted basis. This alone cast doubt as to the thoroughness of the effort to I

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analyze what the NRC considers to be a safety significant deviation from the WOG ER l i

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Enclosure 3

i The licensee intends to rely upon a revised setpoint document that more clearly relates the step deviation to the WOG ERG. This E0P setpoint

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document, dated 2/23/88, will be cross referenced in the 500 for this ste i The NRC performed a review of this setpoint document and had the following comment:

"The primary concern during a loss of forced flow through the reactor core !

is upper head voiding, which is of particular interest in a plant design

such as North Anna where there is little mixing of the fluid in the upper head during this transient. The most important parameter to be monitored

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is the subcooling margin in the upper head. The licensees E0p setpoint documents, both 4/15/87 and 2/23/88, do not list this parameter in their i cooldown tables. Instead, it must be calculated by the reviewer for each

time increment in the cooldown to verify that adequate upper head

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subcooling is maintaine It is not a requirement to list this i pirameter, however, it is expected that since upper head subcooling is of 1 primary concern, it would be the focus of the data table '

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Sibsequent communication between the licensee and the NRC resolved all of the perceived technical concerns regarding the E0P setpoint document of 2/23/8 A final request was made by the NRC of the licensee in the telecon of 7/23/88 (

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to fennally submit in a correspondence the licensees t.urrent policy for  ;

documenting E0P deviations from the WOG ER The licensee made the following :

commitment in their letter of 8/22/8 '

"The North Anna policy is to document and justify any procedure deviations from the WG ERGS, including the following:

1 Any additions or deletions of Notes, Steps, or Cautions j 2 Any changes to setpoints

3 Any step sequence changes l

4 Any changes due to tactical or design differences.

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Cross references between the SDD which documents any step additions, deletiond, and change in sequence, and the Setpoint Document which j documents the basis for the procedure setpoints will be provided whenever ,

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a setpoint specified in the WO3 ERGS is changed. This policy does not j apply to those setpoints which are normally plant specific and are only ;

documented in the Setpoint Document." j j The NRC requested clarification of the final sentence (underlined) and l 1 received from the licensee the statement that any of the netpoints that are '

j assigned specific values in the WOG ERG will be subject to the policy. Those '

setpoints thet are footnoted within the WOG ERG to reference setpoint studies !

or plant specific values will have specific calculations or references l 1 contained in setpoint documents that will verify the value, however these will ;

not be cross referenced in the 500. The NRC cautioned the licensee that a f l

clear audit path between the E0Ps and all supporting documentation, .< bile not ;

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a regulatory requirement, is a preventative measure that can preclude the i difficulties that may arise when plant modifications or other associated l i

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Enclosure 4

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changes affect equipment, setpoints, and/or mitigative action Furthermore, Standard Review Plan 13.5.2. Appendix A. Section 3.3.2, Deviations and Additions, subsection 1.e. states an example of a deviation as the following:

"Plant-specific setpoints or action levels that are calculated or determined in the manner other than specified in the generic technical

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guidelines."

The NRC expects the licensee to follow this guidance as clarification to the above noted underlined sentence contained in the commit:.*ent taken from the correspondence from the licensee dated August 22, 198 ,

NRC Conclusions l

The NRC would like to remind the licensee of what has been identified in the past as weak supporting documentation for changes made to the WOG ERG' Specifically, a NRC audit report of the E0P PGP implementation audit for the North Anna power station, Units no. I and no. 2, issued August 1986, had ,

similar finding Specifically, section 3.1.2.1, Deletion / Revision of ERG steps, states: "Many ERG steps were not included in the North Anna E0Ps or were revised to the extent that their content was in questio Sufficient justification for these deletions / revisions was rarely documented."

t-Ease; on subsequent evaluations of the licensees procedures for natural circulation cooldown and their associated documentation, the NRC is l withdrawing the contested example of the deviation. The reasoning for this 1 decision is based primarily on the fact that the procedure did not place the plant in an unsafe or unanalyzed conditio i

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