ML19257D047

Forwards Supplemental Response to 791129 Ltr & Special Insp Rept Re 790925 Cooldown Incident.Accessible Portions of Air Sweep Lines Visually Inspectd & No Discrepancies Found

ML19257D047
Person / Time
Site:	North Anna
Issue date:	01/14/1980
From:	Stallings C VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	Stello V NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
References
NUDOCS 8001310274
Download: ML19257D047 (5)

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Vruo tNrA E r.ncIRLC AND POW E H C OXPANY llicIIMONI),Vinoux rA 2:3261 January 14, 1980 Mr. Victor Stello, Director Serial No. 928A/110279 Office of Inspection and Fnforcement PO/INr:baw U. S. Nuclear Regulatory Ocumission Docket No. 50-338 Mishington, D. C. 20555 License No. NPF-4

Dear Mr. Stello:

In reference to the Special Inspection Report concerning the Septerber 25, 1979 cooldown incident at North Anna Power Station Unit No. 1 and our letter Serial no. 928/110279 dated Noverber 29, 1979, we are fonvarding the attached supple-mental response.

In addition to the attached response, infonnation about the SepteTber 25 cool-down event is contained in the following previous correspondence.

1. North Anna Unit 1 IER-79-128, dated October 9,1979 (Vepco letter Serial No. 829, dated October 9, 1979).

2. Vepec letter Serial No. 796, dated Novater 25, 1979, providing additional infonmtion on the cooldown event.

3. Vbstinghouse event suTmary forwarded by Vepco letter Serial No. 939, dated Novoser 15, 1979.

Very truly yours, C. M. Stallings Vice President-Power Supply and Prcduction Operations Attac' Tent cc: " . James P. O'Prilly, Director Of fice of Inspection and lhforcenent

" . Albert Schvencer 1841 227 h 8001310 2W g

Attachnent: Page 1 (Revised)

RESPONSE 10 hUTICE OF VIDIATION ITDE FnUirED IN IE SPECIAL INSPT'CTION PHORT A. -NPC Ccnment As required by 10 CFR 50.59 (b) and paragraph 14.5.2 of the Fuelear Power Station Quality Assurance P.bnual, records shall be maintained of changes to tne facility as described in the safety analysis report.

These records shall include written safety evaluations which provide the basis for detennining that the changes do not involve unreviewed safety questions.

Contrary to the above, a one-inch liquid waste line, IM-81-152 (FSAR Figure 11.2.2-1) was found disconnected on Septcnber 25, 1979 at the flanged connection for restricting orifice PO-IM-104 with an elbow installed in place of the orifice. 'Ihe elbow was open to the auxiliary building atmosphere and was a flow path for the release of radiaaeti re gases in the event of Septonber 25, 1979. This change was made to a systcm corponent as described in the safety analysis report without the required evaluation.

This is an infraction. A similar iten was brought to your attention in our letter dated May 25, 1979.

RESPONSE

This infraction is similar to that brought to our attention in your letter dated P'ay 25, 1979; howver, the cause of the infraction of May 25, 1979 was di f ferent . The infreetion of Pay 25, 1979 apparently occurred because, at that time, the NPSr#? was based on the asstuption that a safety analysis was not required for chr.ges to non-safety related systems. We were lvised by Region 11 personnel the this was not an appropriate interpretation of 10 CFR 50.59. 7he NPSOAV has since been modified to require a written safety analysis for all changes to a systen as described in the Final Safety Analysis Report (r5AR). Be disconnecting of the restricting orifice described in this infraction was done by persons unknown. A review of the construction records indicate that the orifice was installed on Decarber 2,1976. Subse-quent to this, the liqrid waste systen underwent pre-operational testing.

No reco-d 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.

The Vepco Nuclea- Power Station Quality Assurance Minual (NPSQMI) provides suitable and appropriate requiranents that address the return of systens to their nonnal status. Section 5 concerns procedures and procedures content with the requiranent that " procedures shart reference or include detailed steps to renove a systan fran service and to return the systan to operating status". Section 14 concerns jtnpers and their use with the requiranent that trethods, subsecuent to installation, be described "to assure operability of the systen has been unaffected (except for the jtnpered function)" and that methods be described "to ensure the systan will be functional when restored to No mal Operable Stnus". Additionally, other mechanians such as Design 1841 228

Attachment:

Page 2 (Revised)

Control Final Design Implementation and Testing, Maintenance Oparating Proce-dures, and Maintenance Procedures, are utilized to assure the return of safety-related systems to a normal status.

An audit of operations is conducted on a calendar year basis by station QC auditors. This audit is preplanned and covers the following areas: duties and responsibilities, program, program implementation, documentation and records and followup action on previously identified deficiencies.

The Vepco (Corporate) Qua!1ty Assurance Manual provides the necessary controls for preliminary operation (administrative procedures). These controls estab-lish the turnover procedures necessary to begin initial operation of systems and final turnover to the Operations staff. These controls require a review for system completeness and a field Quality Control review of system documenta-tion prior to conditional release. A master deficiency list is maintained to

" track" known deficiencies. These controls provide a structured, controlled turnover of systems to the Operations Staff.

In addition to general shif t turnover procedures already in use, specific shif t turnover p rocedures have been developed as required by NUREG-0578. The procedures require that selected oncoming and of f going personnel review their respective logs and communicate the status of their areas of responsibility.

Pursuant to Section 2.201 of the NRC's " Rules of Practice" Part 2, Title 10, Code of Federal Regulations, the following information is submitted :

1. Corrective steos taken and results achieved: Modification of piping systems described in this inf raction would require implementation in accordance with the NPSQAM section 14. This section of the manual has been updated since the infraction notice of May 25, 19 79. Since it is apparent that the line was disconnected prior to the NPSQAM revision, no further corrective action with respect to the NPSQAM is required.

Since the process vent air sweep system performs a passive function and the disconnected orifice was located in a high radiation area, the disconnected line was not readily apparent. During the week of Octo-ber Sch, the accessible portions of the air sweep lines from both the High Level Liquid Waste Tanks (HLLWT) and the Low Level Liquid Waste Tanks (LLLWT) were visually inspected. Piping not inspected was located in radioactive piping chases. No discrepancies such as those stated in the infraction were found.

2. Corrective steps which will be taken to avoid further non-compliance:

We believe that no further corrective action is required.

3. Date when full compliance will be achieved :

Full compliance has been achieved as of the date of this report.

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B. NRC CmMr As required by 10 CFR 50, Appendix A, Criterion 13, instrtmentation shall be provided to monitor variables and systems over their anticipated ranges for nonnal operation, for anticipated operational occurrences, and for accident conditions as appropriate to assure adequate safety, includ-ing those variables and systans that can affect the fission process, the integri ty of the reactor core, the reactor coolant pressure boundary, and the contaiment and its associated systans. Appropriate controls shall be provided to nnintain these variables and systcms within prescribed operating ranges. Also, as required by 10 CFR 50.59 (b) and paragraph 14.5.2 of the Nuclear Power Station Quality Assurance Manual, records shall be maintained of changes to the facility as described in the safety analysis report. These records shall include written safety evaluations which provide the bases for detennining that the changes do not involve unreviewed safety questions.

Contrary to the above, the control switch for the Voltme Control Tank (VCr) level control valve, IG-1115A was observed to be mechanically held to the VCr position by means of penei1 and paper elip, on Septanber 28 and October 1,1979, negating the autcmatic level control functions of the valve as described in the Unit 1 FSAR pages 0.3.4-7, 0.3.4-8, and 0.3.4-24. This change in syston operation was also perfonned without the required evaluation.

Use of a paper clip and pencil fails to satisfy the definition of appro-priate controls to maintain variables and systems within prescribed op-erating ranges.

This is an infraction.

RESPONSE

IG-1115A is a three way valve which allows letdown to flow to the VCT, to the Poron Recovery Systen (ERS) or to split letdown flow so that a portion pes to the FRS and a portion to the VCT. Problems within the centrol valve prevented the valve fra, diverting all letdown flow to the VCr. The valve is located in a high radiation area and repair was pro-hibited un*.il the area was accessible. Since the blocking of the switch for IC-1115A was under the control of a control roon operator, it vms not censidered a change to the facility as described in the FSAR. It should be noted that had the water level in the VCr continued to rise, the hi d level 11 arm would alert the operator and the operator could manually divert letdown to the Doron Recovery Systen. It should also be noted that this condition has never led to the release of any radioactivity.

General Design Criterion 13 requires that instrtmentation be provided to monitor variables and systems over their anticipated ranges for nonnal operation, for anticipated operational occurrences and for accident con-ditions as appropriate to assure adequate safety, including those variables 1841 230'

Attachnent: Page 4 (Revised) and systans that can affect the fission process, the integrity of the re-actor core, the reactor coolant pressure boundary, and the contairment and its associated systans. Also, appropriate controls shall be provided to maintain these variables and systens within prescribed operating ranges.

Instrinnentation and control systans are provided in the North Anna Power Station to monitor and miintain plant variables including those variables which affect the fission process, integrity of the reactor core, the reactor coolant pressure boundary, and the containment over their pre-scribed ranges for nonnal operation, for anticipated operational occur-ences and under accident conditions. Refer to the North Anna FSAR, Section 3, Article 3.1.9 for further aTplification of this discussion.

Specifically, the Volume Control Tank (VCT) is provided with indication and alarms for level, pressure and temerature. Additionally, auxi1iary systans are provided to maintain these variables within prescribed operat-ing ranges. "Iherefore, QDC 13 is met for the VCf.

Wiring and piping changes to the plant have always been considered changes to the facility and, as such, have required the appropriate controls of the NPSQN1. 'Ihe blocking of protective functions is controlled by Technical Specifications. 'Ihis type of activity would never have been allowed to block a protective function. However, the bypassing of a control function by an operator in the control roan, with appropriate indication of the bypassed function was not considered a change to the facility as described in the FSAR.

Pursuant to Section 2.201 of the NRC's " Rules of Practice", Part 2, Title 20, Code of Federal Paulations, the following is subnitted:

1. Corrective steps taken of and results achieved: Effective October 1, 1979, when the pencil and paper clip was permanently ramved fran the controls of ILV-1115A, the scope of changes to the facilit7 as described in the FSAR was changed to include such activities as described in this infraction. Therefore, any chaves or odifications to the plant would require iriplemen-tatier in accordance with the NPSONI which is ca:patible with 10C:'3.5 0. 5 9 .

2. Corrective steps which wil1 be taken to avoid further noncoTpliance:

T ainirg of the Operations staff supervisors and the IWiintenance staf f supewisors will be conducted to reinstniet station super-viso"y personnel of the requirements of 10 CFR 50.59 and NPSQMJ.

This training will reiterate the requiranents of 10 CHI 50.59 and the NPSCWf. It is intended that this training will provide the reason why safety evaluations are required and will discuss the methods by which these evaluations are accanplished. 'Ihis training will delineate that artificial devices (similar to that described in this Notice) belong in the category of "junpers". 'Ihis training is intended to accoTplish a " lessons learned" ef fort.

3. Tbte when full caTpliance will be achieved: Training of Operations staf f supervisors will be ccTpleted by Decather 31, 1979. Training of maintenance staff supervisors will be completed by January 31, 1979.

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