ML19323E840
| ML19323E840 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 02/25/1980 |
| From: | Stallings C VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML19323E818 | List: |
| References | |
| 104-012980, 104-12980, NUDOCS 8005270302 | |
| Download: ML19323E840 (6) | |
Text
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'. *. 00 February 25, [980 Mr. James P. O'Reilly, Director Serial No. 104/012980 Office of Inspection and Enforcement P0/RMT:sej U. S. Nuclear Regulatory Commission Docket No. 50-338 Region II License No. NPF-4 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303
Dear Mr. 0' Reilly:
We have reviewed your letter of January 29, 1980, in reference to the inspec-tion conducted at North Anna Power Station on December 17-21, 19 79, and re-ported in IE Inspection Report No. 50-338/79-49. Our responses to the speci-fic 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, k
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C. M. Stallings Vice President-Power Supply and Production Operations Attachment cc:
Mr. Albert Schwencer L-W 8005270301 g
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Attachment:
Page 1 Response To Notice of Violation Items Reported in IE Inspection Report 50-338/79-49 A.
NRC Comment As required by 10 CFR 50, Appendix B, Criterion V as implemented by the accepted quality assurance program, VEP-1-3A, Section 17.2.12.
"A pro-gram with applicable procedures has been established in the Nuclear Power Station Quality Assurance Manual (NPSQAM) that describes control of measuring and test instruments which includes handling of associated documents and gives the status of all items under the calibration system i
such as maintenance history, calibration test data, and individual log sheets assigned to each device." The NPSQAM, Section 12, Paragraph 4.3 states that the cognizant supervisor shall establish and maintain usage information of a device in the program.
Section 12.4.4 of the manual i
states that the suparvisor of the individual performing a calibration shall maintain a maintenance history record for each device in the program.
Contrary to the above, usage information had not been established and maintained for four torque wrenches (NQC 561, 526, 585, and 5F,6) which were in the measuring and test equipment calibration program.
A com-plete calibration history for each device was not maintained by the cognizant supervisor.
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This is a deficiency.
Response
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 four torque wrenches (NQC 561, 526, 585, and 586) were removed from the electrical department where they could be used without the approv-al of the cognizant supervisor.
The torque.. wrenches are presently locked up and maintained under administrative control.
Prior to use, the tool is calibrated and logged out for each job on the log sheet assigned to that particular tool.
- .. 2.
Corrective steps which will be taken to avoid further non-compliance:
We believe that no further corrective action is required.
s 3.
Date when full compliance will be achieved:
The torque wrenches are presently under administrative control and full compliance has been achieved as of the date of this report.
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Attachment:
Page 2 B.
NRC Comment As required by Technical Specifications Section 4.0.2.a. and 4.7.14.1.1.c, the Fire Suppression Water System shall be demonstrated operable at least once per 31 days with a maximum allowable extension not to exceed 25% of the surveillance interval by verifying thac each valve in the flow path is in its correct position.
Contrary to the above, periodic test procedure PT-100.3 (Fire Suppres-sion Water System - Valve Position Verification) was not performed between 8/12/79 and 10/13/79.
This is an infraction.
Response
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:
Although the periodic test procedure, 1-PT-100.3,could not be found, it was completed on 9-12-79 and the results were satisfactory as verified by the Operations Department.
A " Procedure Unaccounted For" form has been initiated to account for the lost procedure.
2.
Corrective steps which will be taken to avoid further noncompliance:
The " Procedure Unaccounted For" will be completed and filed in Station Records in lieu of the completed procedure.
Since this is an isolated occurrence, no further corrective action is required.
3.
Date when full compliance will be achieved:
Full compliance will be achieved by March 14, 1980.
C.
MRC Comment As required by 10 CFR, 50, Appendix B, Criterion V as implemented by the e accepted quality assurance program, VEP-1-3A, Section 17.2.11, the authority and responsibilities related to the test program are delineated in the Nuclear Power Station Quality Assurance Manual (MPSQAM).
NPSQAM Section 11, Paragraph 5.3.5 states that the cognizant supervisor and performance engineer are responsible for reviewing a periodic test (PT),
including critique sheet and procedure, for completeness and accuracy.
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Attachment:
Page 3 Contrary to the above, various calculational mistakes were contained in the data sheets of PT-11 (Core Reactivity Balance) which was performed on 2/22/79; PT-20.2 (Axial Plus Difference) which was completed on 3/1/79; PT-31.1 (Delta T/T Avg Protection Channel 1 Functional Test - 1412) which was performed on 6/14/79; PT-11 which was completed on 6/18/79, and PT-24 (Calorimetric) which was performed 9/21/79.
Although these documents had received two levels of review, the errors and mistakes had not been identi-fled.
This is an infraction.
Response
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:
In periodic test 1-PT-24, data was written over.
The correct method for changing data is to draw a line through the erroneous data, record the correct data, then initial and date the correction.
T.:is was not
'ane in the test performed on 9-21-79.
The trip setpoint recorded in 1-PT-31.1.1 should have been recorded as 7.429 rather than 4.429 which was the recorded value.
The reset point (which is lower than the trip setpoint) was 7.301.
2.
.arrective steps which will be taken to avoid further noncompliance:
A sign off line for the Reactor Engineer's review will be added to procedures 1-PT-11 and 1-PT-20.2.
The person who performed 1-PT-24 dated 9-21-79, his cognizant super-visors and the performance engineer involved will be reminded of the correct procedure for correcting data.
Since the error made in 1-PT-31.1.1 was a one time event, no correct-ive action is planned.
, 3.
Date when full compliance will be achieved:
Full compliance will be achieved by March 31, 1980.
D.
NRC Comment As required by Technical Specification 6.8.1.c., written procedures shall be established, implemented and maintained, covering the activities con-cerning surveillance and test of safety related equipment.
Step 4.7.a l
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Attachment:
Page 4 of PT 75.2B (Service Water Pump, 1-SW-P-18) states in part, "If devia-tions fall within the Alert Range, double the frequency of testing..."
Step 5.1 of the procedure states that a flow shall be indicated in step 4.1 as an acceptance criteria.
Contrary to the above, the test results fell within the alert ranga when conducted on May 24, 1979, but the test frequency was not doubled.
In addition, pump flow was not recorded in Step 4.1.
This is an infraction.
Response
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.
On May 24, 1979, pump flow was not recorded in step 4.1 of 1-PT-75.28.
This particular flow is recorded to verify that the check valve, 1-SW-10, is open.
Check valves are only required to be cycled every 3 months.
Since this is a monthly, test, the required surveillance interval was not exceeded.
Pump flow on 8-24-78 exceeded the allowable limit of 8160 gpm :/
t 40 gpm.
This flow was in the " ALERT" range which required the test frequency to be doubled which was not done.
The event occurred shortly after the pump testing program was initiated.
The deficiency of not doubling the test frequency when results are in the " ALERT" range was recognized and corrective steps were taken prior to this inspection.
2.
Corrective steps which will be taken to avoid further noncompliance:
Since this is a one time occurrence, no further corrective action is planned.
3.
Date when full compliance will be achieved:
A date of compliance is not applicable since no corrective actions are planned to be taken.
NRCLTR:55
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Revised Attachment : Page 5 3.
Date when full compliance will be achieved:
A date of compliance is not applicable since no corrective actions are planned to be taken.
4.
Additional Information:
As a point of clarification note that two different, dates of perfor-mance for 1-PT-75.2B are involved as given in the body of this Inspection Report.
Testing check valve 1-SW-10 does not require signiffsant effort and from an administrative standpoint it is more appropriate to test this valve monthly in conjunction with the service water pump testing, s
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