ML19207A802

Responds to NRC 790608 Ltr Re Violations Noted in IE Insp Repts 50-338/79-25 & 50-339/79-34.Corrective Actions:Test Engineers Instructed to Insure Proper Use of Procedure Deviations & Documentation of Problems

ML19207A802
Person / Time
Site:	North Anna
Issue date:	07/03/1979
From:	Stallings C VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML19207A800	List: ML19207A802
References
NUDOCS 7908220406
Download: ML19207A802 (3)

Text

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'].Uilk I, lhhh Mr. James P. O'Reilly, Director Serial No. : 542 Office of Inspection and Enforcement P0/FHT:baw U. S. Nuclear Regulatory Commission Docket No.: 50-338 Region II 50-339 101 Marietta Street, Suite 3100 License No.: NPF-4 Atlanta, Georgia 30303 CPPR-7R

Dear Mr. O'Reilly:

We have reviewed your le:ter of June 8, 1979, in reference to the inspec-tion conducted at North Anna Power Station Units No. I and 2 on May 7-11, 1979, and reported in IE Inspection Report Nos. 50-338/79-25 and 50-338/

79-34. Our responses to the specific infractions are attached.

We have determined that no proprietary infcrmation is contained in ;he report. Accordingly, the Virginia Electric and Power Company has no ob-jection to this inspection report being made a matter of public disclosure.

Very truly yours,

'./ )/ N7 40 )

C. M. Stallings Vice President-Power Supply and Production Operations At tachnient cc: Mr. Albert Schwencer Yf0

'/61329 7908220e/66 U: h: a. : . .

Attachment page 1 of 2 RESPONSE TO NOTICE OF VIOLATION ITDI REPORTED IN IE INSPECTION REPORT NOS.

50-338/ 79-25 and 50-338/ 79-34 A. NRC Comment As required by 10 CFR 50 Appendix B Criterion XI which states in part:

" Test results shall be documented and evaluated to assure that test requirements have been cet." This requirement is further defined in VEP-1-3A, Topical Report Quality Assurance Program Operations Phase, Section 17.2.11, and the Nuclear Power Station Quality Assurance Manual, Section 11, paragraphs 5.1.1.d. , which requires "The Supervisor -

Engineering Services, the Joint Test Group, and the Station Nuclear Safety and Operating Committee shall be responsible for reviewing the test results and determining if the results meet the established acceptance criteria..."

Contrary to the above, 2-PO-11.1 Component Cooling System Test At Ambient Plant Conditions, results approved January 12, 1979, indicated that the data obtained for pumps 2-CC-P-1A and 2-CC-P-1B met the acceptance criteria of paragraph 5.1. The acceptance criteria required pump flow of 8000 gpm at a 200 f t. pump head. The data indicated an unsatisfactory head of 198.7 ft. for 8000 gpm flow for each pump.

This is an infraction.

A. Res ponse The above infraction is correct as stated. Specifically, pursuant to Section 2.201 of the NRC's " Rules of Practice" Part 2, Title 20, Code of Federal Regulation, the following information is submitted :

1. Corrective steps taken and results achieved:

The acceptance criteria of 2-PO-11.1, Component Cooling System Test at Ambient Plant Conditions, states in paragraph 5.1 that for component cooling pump 2-CC-P-1A and 2-CC-P-1B the required head is 200 feet at a flow of 8000 gpm. The acceptance criteria as stated in 2.PO.ll.1, depicts the proper head for this flow to be 190 feet. It is also

, stated in the Specification for the Component Cooling Water Pump Equipment (NAS-124) that the design condition is 8000 gpm at 190 TDH. This information was not included in the critique of the test re sul t s.

In accordance with NPSQAM Section 17, paragraph 5.1.6, supplemental information correcting toe acceptance criteria of 2-PO-11.1 vill be included with the test.

2. Corrective action taken to avoid further non-compliance:

On 5-30-79, test engineers were instructed to insure the proper use of Procedure Deviations and the proper documentation of a problem or discrepancy.

3. Date when full compliance will be achieved: D1330 Full compliance with respect to instruction and training has been achieved. The records for 2-PO-ll.1 will be corrected before August 1, 1979.

a  ;

Attachment page 2 of 2 RESPONSE TO NOTICE OF VIOLATION ITEM REPORTED IN IE INSPECTION REPORT NOS. 50-338/ 79-25 and 50-338/ 79-34 B. NRC Corrent As required by Technical Specification 6.8.3.c, temporary changes to surveillance procedures of safety related equipment shall be documented, reviewed by the Station Nuclear Safety and Operationg Cummittee (SNSOC) and approved by the Station Manager within 14 days of implementation.

Contrary to the above, a temporary change to acceptance criteria step 5.3 of periodic test 1-PT-76.5 on Control Room Emergency Ventilation filter testing, conducted on March 29, 1979, was not documented, re-viewed by the SNSOC, or approved by the Station Manager as of May 9,1979.

B. Re s ponse In regards to comment B above, af ter evaluation it is our opinion that we are not in violation of Technical Speci fication 6. 8. 5, temporary changes to procedures, in that the steps of the procedure were followed as stated in the procedure.

The results of 1-PI-76.5 were reviewed in accordance with the NPSQAM Section 11, paragraph 5.3, Periodic Test Program.

The results of 1-PT-76.5 were not consistent with the stated acceptance criteria, therefore, as required by paragraph 5.3.5 of Section II of the NPSQAM, the Performance Engineer notified the Engineering Supervisor of the inconsistency of 1-PT-76. 5. An engineering study was initiated to evaluate the results of 1-PT-76.5. On April 24, 1979, Engineering Study 79-11 was completed and reviewed by the Engineering Supervisor. This

- study considers the results of 1-PT-76. 5 to be satisfactory. Engineer ing Study 79-11 has since been approved by the SNSOC.

Since this inconsistency in the acceptance criteria constituted a condition adverse to quality, a Deviation Report should have been completed in accordance with Section 26 of NFSQAH. This Deviation Report and the engineering evaluation of the periodic test would have then been re-viewed by the Station Nuclear Safety and Operationg Committee.

To prevent this problem from recurring, cognizant supervisors will be instructed to inform their personnel that when an acceptance criterion for a safety related Periodic Test is not met, a Deviation Report nast be submitted.

W1331

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