ML19282A437

Responds to NRC 790105 Ltr Re Violations Noted in IE Insp Rept 50-338/78-42.Corrective Actions:Applicable Operating Procedures Are Being Revised to Include Condition Verifying Automatic Stop Oil Pressure Is Below Setpoint

ML19282A437
Person / Time
Site:	North Anna
Issue date:	01/26/1979
From:	Stallings C VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	Oreilly P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML19282A435	List: ML19282A437
References
NUDOCS 7903010028
Download: ML19282A437 (3)

Text

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VxnotwzA ELucraic Ann Powen COMPANY R scu w on n,Vi noi n tA seco January 26, 1979 Mr. James P. O'Reilly, Director Serial No. 022/010579 Office of Inspection and Enforcement P0/DLB:sej U. S. Nuclear Regulatory Conmission Docket Ros. 50-338 Region II 101 Marietta Street, Suite 3100 License Nos. NPF-4 Atlanta, Georgia 30303

Dear Mr. O'Reilly:

We have reviewed your letter of January 5,1979 in reference to the inspection condue:ed ac North Anna Power Station on December 11-15, 1978 and reported in IE Inspection Report No. 50-338/78-42. Our responses to the specific violations are attached.

We have determined that no proprietary information is contained in the report. Accordingly, the Virginia Electric and Power Company interposes no objection to the inspection report being made a matter of public disclosure.

Very truly yours, C. M. Stallings Vice President-Fower Supply and Production Operations Attachment ec: Mr. Albert Schwencer ,

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RESPONSE TO NON-COMPLIANCE ITEMS REPORTED IN IE INSPECTION REPORT NO. 50-338/78-42 ERC EOMMENT A. Technical Specification 4.3.1.1.1. Table 4'3.1. Item 18. A requires that a functionaT t'est of the turbine generator auto stop oil reactor trip be performed prior to reactor startup if not performed in the previous seven days.

Contrary to the above, the turbine generator auto stop oil functional test was not performed prior to reactor startup on October 25, 1978, and had not been performed within the previous seven days.

EESPONSE

.The above infraction is correct as stated.

Specifically 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 steps taken and results achieved:

The applicable operating procedures are being revised to include an initial condition verifying that the Auto Stop Oil pressure is below its setpoint by both annunciator status lights and computer readout prior to a reactor startup. This will verify the operability of this reactor trip in accordance with T.S. 4.3.1.1.1.

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

1-plementaticc of the above mentioned revision will achieve full compliance.

3. Date when full compliance will be achieved:

Full compliance will be achieved by February 15, 1979 when the above mentioned procedures are revised.

s NRC COMMENT

3. Technical Specification 6.8.3.c requires that temporary changes to procedures be documented, reviewed by the Station Nuclear Safety and Operating Committee and approved by the Station Manager within 14 days of implementation.

Contrary to the above, twenty-three temporary procedure changes had not been reviewed by the Station Nuclear Safety and Operating Committee and approved by the Station Manager within 14 days during the period between July 3 - November 27, 1978. Corrective actions preventing recurrence of these items have not been effective since the licensee had identified each of these items as they occurred.

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RESPONSE

. The above infraction is correct as stated..

Specifically, pursuant to section 2.201 of the NRC's " Rules of Practice" r Part 2. Title 10, Code of Federal Regulations, the following information is submitted:

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1. Corrective steps taken and results achieved: -

Following the verbal notification that this was considered an item of non-compliance on December 20, 1978, supervisors involved in the processing of deviations were notified of this non-compliance and the importance of insuring all deviations were processed within the 14 day interval. Since this time, no late deviations have been  : .-

received.

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

la order to insure the timely processing of deviations, a review of the present system by plant management was undertaken. During this review it was found that a number of the late deviations were a .

result of personnel changes in the positions responsible for process-ing these deviations and that the program was not being properly r followed in other cases. As a result, it was determined that the e L present program for handling deviations with the same minor modifica-tions would be sufficient when properly implemented. The major

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change was to have the actual deviation remain with the cognizant supervisor while a copy was sent to the field to allow performance of the procedure for those operations which take longer than one day .

to complete. This process was already being followed by a few supervisota and will now be expanded to include the other departments.

3. Date when full compliance will be achieved:

Full compliance in this area has been achieved as of the date of this response. ,

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