ML19344A788
| ML19344A788 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 08/20/1980 |
| From: | Sylvia B VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8008220209 | |
| Download: ML19344A788 (8) | |
Text
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Go VIROINIA EI.ucTunc Axn Powsu Co>imxy Ricarwoxn,Vamoru rA coast August 20, 1980 Mr. James P. O'Reilly, Director Serial No. 657 Office of Inspection and Enforcement N0/RMT:ms U. S. Nuclear Regulatory Commission Docket Nos. 50-338 Region II 50-339 101 Marietta Street, Suite 3100 License Nos. NPF-4 Atlanta, Georgia 30303 NPF-7
Dear Mr. O'Reilly:
We have reviewed your letter of July 21, 1980, in reference to the inspection conducted at North Anna Power Station on April 14 - May 30, 1980, and reported in IE Inspection Report Nos. 50-338/80-19 and 50-339/80-20. Our responses to the spr.cific infractions are attached.
We acknowledge that the submittal of this response is beyond the twenty day period specified in your letter.
Due to delays encountered while performing final revisions to ensure the responses were as complete as possible, the submittal was detained.
We have determined that no proprietary information is contained in the reports.
Accordingly, the Virginia Electric and Power Company has no objection to these inspection reports being made a matter of public disclosure.
Very truly yours,
/
- c..,~p
. R.
ylvia Manager - Nuclear Operations and Maintenance Attachment cc:
Mr. Robert A. Clark, Chief Operating Reactor Branch No. 3 seesseo 2<i9 p
k RESPONSE TO NOTICE OF VIOLATION I1EM REPORTED IN IE INSPECTION REPORT NO. 80-20 NRC C0m1ENT As required by Criterion V of Appendix B of 10 CFR 50, as implemented by paragraph 17.2.5 of Vepco's " Topical. Report - Quality Assurance Program
-Operations Phase", (VEP 3A) requires that activities affecting quality be performed in accordance with procedures.
Contrary to the cbove, rework of the Unit 2 control room air conditioning chillers and their control panels per Engineering and Design Coordination Report P-2717-2 was accomplished without the use of a Rework Control Form. Use of the rework control form is required by Construction Quality Control Procedure 26.1 " Rework Control Program".
This is an infraction.
RESPONSE
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:
j 1.
Corrective steps taken and results achieved:
A review was made of the Vepco Construction Quality Assurance Manual, Vepco Nuclear Power Station Quality Assurance Manual, and the Vepco Construction Quality Control Procedure 26.1, entitled " Rework Control Program".
The primary purpose of Vepco QC procedure 26.1 is to provide a vehicle for getting QC involved in maj or rework activities on system / components which have been previously accepted by QC, as described in QC Procedure 26.1.
In the subject case, QC Procedure 26.1 was not followed by the personnel involved.
North Anna 2 is in transition from the construction phase, where QC Procedure 26.1 applies, to operating status, where the Vepco Nuclear Power Station Quality Assurance Manual for operating plants applies.
In the future all work activities which would have previcusly been performed under QC Procedure 26.1 will be carried out under the direction of Section 3 of the Vepco Nuclear Power Station Quality Assurance Manual.
It has been determined that Section 3 of the Vepco Nuclear Power Station Quality Assurance Manual is adequate for Design Control as required by 10 CFR 50, Appendix B.
2.
Corrective action taken to avoid further non-compliance:
To ensure established procedures are followed correctly, the Vepco design control engineer will be instructed to ensure applicable procedures for rework are available to craftsmen, and also that they are fami-liar with the requirements of the Vepco Operational Quality Assurance Program.
(3) Date when full compliance will be achieved:
Full compliance will be achieved by August 31, 1980.
s I.
..a RESPONSE TO NOTICE OF DEVIATION ITEM REPORTED ON IE INSPECTION REPORT NO. 50-338/80-20-03 NRC COMMENT Vepco's " Topical Report - Quality Assurance Program - Opaations Phase" (VEP-3A), Section 17.2.27, as implemented by Paragraph 2.5.3.2 of the
" Nuclear Power Station Quality Assurance Manual", requires that temporary personnel be indoctrinated in Vepco's Quality Assurance procedures as related to their specific tasks to be performed.
RESPONSE
The above Deviation is correct as stated.
1.
Corrective steps taken and results achieved:
As a corrective mea-sure, the specific test engineer involved was indoctrinated in the Quality Assurance Procedures specific to his tasks and this training was documented on May 16, 1980.
2.
Corrective action taken to avoid noncompliance:
To ensure that sub-sequent staffing of the start-up program meets the Quality Assurance Manual indoctrination requiraents, a list of acceptably trained shift engineers was distributed and lead engineers responsible for this staffing from both Vepco and B&W were instructed to organize e
shift coverage which meets requirements in the N. A.P.S. QA Manual.
3.
Date when full compliance will be achieved:
Full compliance was achieved on May 16, 1980.
h RESPONSE TO NOTICE bEV1ATION ITEM REPORTED DURING NRC INSPECTION _
CONDUCTED FROM APRIL 14 - MAY 30, 1980 NRC COMMENT Vepco letter serial number 1160, dated December 28, 1979, a supplement to Unit 1 LER 79-149, stated that emergency procedures would be revised as necessary to assure continued ventilation flow from the safeguards buil' ings and the auxiliary building central area in the event of duct wot failure during a seismic event.
Contrary to the above, linits 1 and 2 abnormal operation procedure 1-AP-36, " Seismic Event", was revised March 5, 1980, but instructions were not provided for assuring continued ventilation of the safeguards buildings in the event of failure of exhaust duct work.
RESPONSE
The above deviation is correct as stated.
Specifically, pursuant to Section 2.201 of the NBC's " Rules of Practice", Part 2, Title 10, Code of Federal Regulations, the following information is submitted:
1.
Corrective steps taken and results achieved:
Vepco Abnormal Proce-dure 1-AP-36 entitled " Seismic Event" was revised on May 27, 1980 and instructions are now provided for assuring continued ventilation
'~
si the safeguards building in the event of a failure of exhaust duct work.
?
orrective action taken to avoid further non-compliance:
Personnel will be instructed to ensure that commitments are handled more promptly in the future.
3.
Date when full compliance will be achieved:
Full compliance will be achieved on August 31, 1980.
d RESPONSE TO NOTICE DEVIATION ITEM REPORTED IN IE INSPECTION REPORT 50-338/80-19-05 NRC COMMENT Vepco letter serial' no. 1179 dated December 28, 1979, concerning commit-ments to correct identified equipment problems, stated that any use of service water mode of containment cooling would have to be under strict administrative control and these controls for Unit I would be in place prior to start-up from the first refueling outage.
Contrary to the above, no administrative controls were implemented until after May 16, 1980.
Start-up from the first refueling was in Jaunary 1980.
RESPONSE
The above deviation 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:
Procedure changes had not been implemented due to an oversight resulting from an extremely heavy work load during this period of time. The personnel involved have been made aware of the importance of meeting all commitments.
2.
Corrective action taken to avoid further noncompliance:
We believe that the above listed corrective action will be sufficient.
3.
Date when full compliance will be achieved:
Full compliance was achieved on May 16, 1980.
f.
RESPONSE TO NOTICE DEVIATION ITEM REPORTED DURING NRC INSPECTION CONDUCTED FROM APRIL 14 - MAY 30, 1980 NRC COMFENT Vepco letter serial No. 123 of February 14, 1980, original report per 10 CFR 50.55(e) on the non-seismically qualified control room air condi-tioning chiller control panels, stated that required Unit 2 modification would be completed prior to initial fuel loading.
Contrary to the above, electrical modifications per Engineering and Design Coordination Report P-2717-2 were not completed until April 28, 1980.
Initial fuel loading began April 12, 1980.
RESPONSE
This is a deviation from a written commitment.
Three chiller units (A, B, and C) required modification.
Chiller Unit was out of service for repairs waiting for replacement parts.
The seismic modifications were made on Unit C,
but it could not be placed in service because the replacement parts required for repair were unavailable.
Units A or B could not be taken out of service until Unit C was placed in service.
When the replacement parts became available, Unit C was repaired, tested, and placed in service.
Then, one at a time, the other two units were taken out of service, modified, tested and returned to service.
1.
Corrective steps taken and results achieved:
None necessary; when the replacement parts arrived the unit was placed in operation as soon as possible and E&DCR P-2717-2 was completed.
2.
Corrective action taken to avoid further noncompliance: None neces-sary.
3.
Date when full compliance will be achieved:
As stated above, full compliance was achieved April 28, 1980 for Unit 2.
_ ~
d Attachment Page 1 RESPONSE TO NOTICE OF VIOLATION ITEM REPORTED IN IE INSPECTION REPORT NOS.
338/80-19 AND 339/80-20 APPENDIX A NRC COMMENT A.
- As required by Unit 1 Technical Specification 6.8.lc, written procedures shall be established, implemented and maintained for conduct of surveil-lance and test activities of safety related equipment Contrary to the above, Unit 1 Periodic Test Procedure 1-PT-36.10, "P-4 Permissive Verification", written to verify proper operation of reactor trip breaker auxiliary contacts feeding P-4 every 31 days, was not per-formed between the dates of January'14, 1980 and May 8, 1980.
This is an infraction.
RESPONSE
Specifically, pursuant to Section 2.201 of the NRC's " Rules of Practice",
Part 2, Title 10, Code of Federal Regulations, the following information j
is submitted.
1.
Corrective Steps Taken and Results Achieved:
A new P.T. had been written in January to test the operation of the auxiliary contacts in the reactor trip breakers.
A review of our Test Control Program was made and it was determined that'the Periodic Testing Program described in Nuclear Power Station Quality Assurance Manual, Section 11, paragraph 5.3, is adequate.
Since the Test Control Program is adequate, the Performance Engineer will notify the cognizant supervisor when a new Periodic Test is created.
2.
Corrective Action Taken to Avoid Further Noncompliance:
The Administrative. Procedure that controls Periodic Tests (Adm.
13.1) will be changed to insure that the Performance Engineer noti-fies the cognizant supervisor of a new Periodic Test via a memorandum.
3.
Date When Full Compliance Will Be Achieved:
Full compliance will be achieved by September 1, 1980.