ML19344F422

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Forwards Response to NRC Re Violations Noted in IE Insp Repts 50-338/80-29 & 50-339/80-28.Corrective Actions:Specific Instructions Given to Control Room Operators Re When to Place Channel in Tripped Condition
ML19344F422
Person / Time
Site: North Anna  Dominion icon.png
Issue date: 09/12/1980
From: Sylvia B
VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To: James O'Reilly
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
738, NUDOCS 8009150257
Download: ML19344F422 (4)


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.e VIRGINIA ELucrnic Axn Powen Co>imxy HIcItMOND,VINGINIA 2 02(31 September 12, 1980 Mr. James P. O'Reilly, Director Serial No. 738 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 H ve reviewed your letter of August 20, 1980 in reference to the inspection cou, cted at North Anna Power Station on June 2 through July 11, 1980, and reported in IE Inspection Report Nos. 50-338/80-29 and 50-339/80-28.

Our responses to the specific infractions are attached.

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

Accordingly, the Virginia Electric and Power Company has no obje'c-tion to these inspection reports being made a matter of public disclosure.

I Very truly yours, Gvr M B. R. Sylvia Manager - Nuclear Operations and Maintenance l

Attachment cc:

Mr. Robert A. Clark, Chief Operating Reactors Branch No. 3 Division of Licensing Mr. B. Joe Youngblood Lir. easing Branch.No. 1 Division of Licensing 80 0 91s u,25f 9

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Attachment-Page'1

. RESPONSE TO NOTICE OF VIOLATION ITEM REPORTED DURING NRC INSPECTION CONDUCTED FROM JUNE 2, THROUGH JULY 11, 1980 NRC. COMMENT A.

License No. NPF-4 Technical Specification 3.3.1.1

'able 3.3-1 for Steam Generator Water Level Low-Low and Low Steam Generator Water Level Note 7 requires that if the number of operable channels is one less than the total' number of channels, startup and power aperations may proceed until the next required Channel Functional Test provided the inoperable channel is placed in the tripped condition within one hour.

Contrary to the above, on June 12, 1980, while operating in Mode 1 the inoperable Steam Generator Level channel was not placed in the tripped condition within one hour.

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:

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1.

Corrective steps taken and results achieved:

When indication for LT-1474 began to deviate from the other two channels, Operations personnel questioned the operability of the channel.

The instru-ment shop was notified and the calibration of the channel was checked.

It was noted that the control room indication fluctuated over time and periodically returned to within the tolerances speci-fled on 1-LOG-4.

A containment entry was made and it was discovered that there was a steam leak on the upper transmitter isolation root valve.

Based on these actions to determine the operability of the channel, the channel was placed in trip when it was determined by the Operations Superintendent that the channel was, in fact, inoperable.

2.

Corrective action taken.to avoid further non-compliance:

Standing Order No. I was changed to give specific instructions to the control room operators concerning the criteria to use in determining when to place a channel in the tripped condition.

In the future, when the readings noted on-the control room logs do not meet the specified acceptance. tolerances, the actions specified in the appropriate Tech Spec will be taken immediately. Any related investigation to deter-

-mine-the, status of the subject channel will be performed subsequent to placing the channel.in trip.

3.

Date when full compliance will be achieved:

Full compliance was achieved by September 10, 1980.

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i Attachm:nt Page 2 RESPONSE TO NOTICE OF VIOLATION PtEM REPORTED DURING NRC INSPECTION CONDLCTED FROM JUNE 2 THROUGH JULY 11, 1980 NRC COMMEK1 B.

License No. NPF-7 Technical Specification 6.8 1.a requires that procc-dures be developed, implemented and maintained for the procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.

Section 3 of Appendix A discusses procedures for startup, opera-tions and shutdown of Safety Related Systems.

Contrary to the above, 2-0P-1A, "Prestartup Checkoff List" had not been revised to require the checking of instrument stop valves in order to insure Reactor Protection System instrumentation was in service prior to entering the modes where it would be required.

Specifically c., June 19, 1980, while in Mode 2,

flow transnitters FT-2476, FT-2477, FT-2487, FT-2496, and FT-2497 were found to be isolated.

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:

1.

Corrective steps taken and results achieved:

The Operating Proce-dures for Units 1 and 2 (OP-1A) "Prestartup Checkoff List" has been revised to require a signoff for operability status of safety related instrument transmitter stop valves.

This will ensure safety related instruments are in service prior to entering the mode where it is required.

2.

Corrective action taken to avoid further non-compliance:

Utilization of the Prestartup Checkoff should avoid further non-compliance.

3.

Date wh'n full compliance will be achieved:

Full compliance will be achieved on September 15, 1980.

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e Attachment Page 3 RESPONSE TO NOTICE OF VIOLATION ITEM REPORTED DURING NRC INSPECTION CONDUCTED FROM JUNE 2 THROUGH JULY 11, 1980 NRC COMMENT C.

License No. NPF-7 Technical Specification 3.3.1.1 Table 3.3-1 for Steam /

Feedwater Flow Mismatch Note 7 requires that if the number of operable channels is one less than the total number of channels, startup and power operations may proceed until the next required Channel Functional Test, provided the inoperable channel is placed in the tripped condition within one hour.

Additionally, Technical Specification 3.0.3 states that 's a Limiting Condition for Operation and/or associated action requirer.ents cannot be satisfied because of circumstances in excess of those addressed in the specification, the unit shall be placed in at least Hot Standby within one hour and Hot Shutdown within the next six hours.

Contrary to the requirements above, on June 19, 1980, while in operating Mode 2, the inoperable Feedwatet Flow Channels were not placed in the tripped condition within one Star nor was the unit placed in Hot Standby within one hour or Hot Shutdown within the next six hours.

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 Regtd.ations, the following information is submitted:

1.

Corrective steps taken and results achieved:

Vepco operating personnel received reinstruction via a standing order revision rela-ted to placing inoperable instrumentation in a tripped condition.

2.

Corrective action taken to avoid further non-compliance:

Reinstruc-tion should enhance more expeditious handling of inoperable instrument channels.

3.

Date when full compliance will be achieved:

Full compliance was achieved by September 10, 1980.

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