ML19257A839

Forwards Response to NRC 791102 Ltr Re Items of Noncompliance Noted in IE Insp Rept 50-338/79-39.Manual Did Not Require Safety Analysis for Changes to nonsafety-related Sys,But Has Since Been Revised

ML19257A839
Person / Time
Site:	North Anna
Issue date:	11/29/1979
From:	Stallings C VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML19257A838	List: ML19257A839
References
928-110279, NUDOCS 8001090194
Download: ML19257A839 (4)

Text

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November 29, 1979 Mr. James P. O'Re11Ly, Director Se rial No . 928/110279 of fice of Inspection and Enforcement P0/RMT:scj U. S. Nuclear Regulatory Commission Docket No. 50-338 Region II 101 Marietta Street, Suite 3100 License No. NPF-4 Atlanta, Georgia 30303

Dear Mr. O'Reilly:

We have reviewed your letter of November 2, 19 79, in reference to the inspection conducted at North Anna Power Station, Unit No. 1 on September 25 - October 5, 1979, and reported in the IE Special Inspection Report. Our responses to the specific infractions are attached.

We have determined that no proprietary information is contained in the report.

Accordingly, the Virginia Electric and Power Company has no objection to this inspection report being made a matter of public disclosure.

Very truly yours, g A g 9 3' WW" * " " ' #

C. M. Stallings Vice President-Power Supply and Production Operations Attachment cc: Mr. Albert Schwencer 1707 228 8001090/9f I

Attachment:

Page 1 RESPONSE TO NOTICI: OF VIOLATION ITE3fS REPORTED IN IE SPECIAL INSPECTION !!EPONT s

A. NRC COMMENT As requi red by 10 CFR 50. 59(b) and paragraph 14.5.2 of the Nuclear Power Sta t ton Quali ty Assurance Manual, records shalI be naintained of change:,

to the facility as described in the safety analysis report. These reco rd s shall include written safety evaluations which provide the basis for deternining that the changes do not involve unreviewed safe ty questions .

Contrary to the above, a one-inch 1 iqu id was te line, IR--81-15 2 (FS AR Figure 11. 2.2-1) wa s found disconnected on Sep tenhe r 2 5, 19 79, a t the flanged connection for restricting orifice R0-LU-104 with an elbow in-stalled in place of the orifice. The elbow was open to the auxiliary building atmosphere and was a flow path f or the release of radioactive ga s": , in the event of September 25, 19 79 . This change was r'ade to a systen component as described in the safety analysis report without the required evaluation.

This is an infraction. A siatlar iten was brought to your attention in our letter date May 25, 19 79 .

RESPONSE

This infr:ction is sini.lar to that brought to our attention in your letter da ted "a y 2 5, 19 79 ; however, the cause of the inf raction of !!ay 25, 19 79 wu difforent. ?c infraction of May 25, 19 79 apparently occurred because, at .at tire, the PSQM' was based on the assu:,pt ion that a safety analysis was not recuired for changes to non-safety rela ted sys tems. We were advised by Eer,Io, I! pencrnel that this was not an appropriate interpretation of 10C F:S O. 59. The ';?SqA'! has since been modified to require a wri tten safety analysis for all changes to a system as described in the Final Safe ty Analysis Report (FSAR). The disconnecting of the restrict ing orifice described in this infraction was dene by persons unknown. A review of the construction records indicate that the orifice was installed on Decenber 2, 1976. Subsequent to this, the liquid waste systen underwent pre-operational testing. No record of any change to the restricting orifice could be found, although it is considered highly probable that the orifice was disconnected during this phase of plant pre-operational testing.

Pu rs ua n t to Section 2. 201 of the NRC's " Rules of Prac t ice" r',rt 2, Title 10, Code of Federal Pegulations, the following inform tion is witted:

1. Co r re c t iv e Steps Taken and results achieved : Med ification of piping systens described in this infraction would require imple-contatica in accordance with the NPSQAM section 14. This section of the mnual has been updated since the infractLon notice of May 25, 19 70 Since it is apparent that the line was disconnected prie to the NPSQA't revision, no further corrective action with respect to the NPSQA't is required .

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Attachment par,o 2 Since the process vent air sweep systen performs a passive function and the disconnected orifice was located in a high rad iat loa area ,

thesdisconnected IJne van not read il y appa re nt . Imring the week of Oc t obe r 8 t h , the acee ulble portions of the air sweep 1ines fron both the High Level LLquid Jante Tanke (lli L'iT) and the I.ow Level Liquid Waste Tanks (LLLWT) were visually inspectod. Piping not inspected was located in radioactive piping chases.. No discrepancies such as those stated in the infraction were found.

2. grrective steps which will be taken to avoid further non-compliancel We believe that no further correct ive act ion is requi red .

3. Date when full compilance will be achieved: Full compliance has been achieved as of the date of this report.

B. .P_.C COMMENT As required by 10 CFR 50, Appendix A, Criterion 13, instrumentation shall be provided to raonitor variables and systens over their anticipated ra :ges for normal operation, for ant icipa ted ope ra tional occurrencea, a nd f.

accident conditions as appropria te to assu re ade<pta te safe ty, including t Mse variables and systens that can affect the fizulon procean, the in-refrity of the reactor core, the reactor coolant prensure '>ounda ry, and th- contai ent an?. its arsociatcJ sytees. Appropriate controls shalI be pr e r ided to maintain these variables and cyatens wi th in prescribed ope ra t-leg ra n ; m . O no, as requi red by 10 CVR 50. 59 (b) and paragraph 14.5.2 of t5 .ucl< < r Pm r Sta tion Qia'. i t; A mirar: e Manual, records shall be ca .n liH c: cH nges to the facility as described in the safe ty analysis repert. Thn e records shall incluJo written safety evaluations which pr 19 the F.v s for determining that the changes do not involve unre-viewed Iafet) ,uestions.

Contr. v to th- above, the cent rol switch for the Volume Control Tank (VCT) level control valve, LCV-lll5A was observed to be mechanically held to the VCT penition by means of pencil and paper clip, on Septemb- 28 and October 1, 19 79, nep t ing the autcmatle level control functions of the valve as described in the l'ni t 1 FSAR pagea 9. 3. 4-7, 9 . 3. 4-3, a nd 9. 3. 4-24. This cb mge in system operation was also performed without the required evalua-tlan.

Use of a papet clip and penell f ails to satisfy the definition of appro-priate controls to maintain variables and systems within prescribed operat-i ng ranges.

This is an infraction.

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Attachment:

pa y,e 3 R ES PO':S F.

s I.CV-Ill5A is a three way valve which allows letdorn to flow to the VCT, to the Boron Recovery Systen (URS) or to split letdown flow so that a portion r, w s to the URS arul a portion to the VCT. Pr ob l er's wi t h i n t h e cont rol valve prevent ed the valve f ron d iverting all le tdown flow to the VCT. The valve is l oca t e.! in a high radiation area and repair var. prohibite' un t il the area uns accesstble. Since the blocking of the swi tch for LCV-1115A was under the control of a control room operator, it was not considered a change to the facility as described in the FSAR. It should be noted tha t had the water level in the VCT continued to rise, the high level alarm would alert the operator and the operator could manually divert le tdown to the Eoron Recovery Systen. It should also be noted that this condition has never led to the release of any radLoactivity.

Wiring and piping changes to the plant have always l'een considered changes to the facility and, as such, have required the appropri. ate controls of the NPSQA'4.

The blocking of protective functions is controlled by Technical Specifications.

This tvoe of act tvity would never have been allowed to block a protective function. Powever, the bypassing of a control function by an operator in the control roon, w! th appropriate indic;. tion of the bypassed function was not.

considered a chang to the facility as described in the FSAR.

Pu c :a r.: to Fectien 2.201 of the NRC's " Rules of Pract ice", Pa r t 2, Title 10, Code of Federal 6 mlations, the following is subni t ted :

1. Correct. stens taken of ari re<ilts achieved' Ef f ect ive October

.. . ', whe- the pencil and paper cl ip was pe raanently rer.oved from t'.~ centrols of LCV-Ill5A, the scope of changes to the f ac 111ty as des ribe: in the FSAR war changed to include such activities as desc:.aed in this infraction. Therefore, any chany,ea or modifica-tions to the plant would require implementation in accordance with the NPSPA". which is compatible with 10CFR50.59.

2. Correctite steps which will be taken to avoid further nonconpliance:

Training ef the Operations staf f supervisors and the ::a ln tenance staff supervisors util be conductec' te reinstruct station supervisory personnel of the requirerents of 10CFR50.59 and the NPSOA.'i.

3. Date when full compliance will be achieved : Training of Operations staft supervisors will be completed by Pecember 31, 1979. Training of naintenance staff supervisors will be compl e ted by Janau ry 31, 19 79 .

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