ML19347E225
| ML19347E225 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 04/03/1981 |
| From: | Sylvia B VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML19347E223 | List: |
| References | |
| 180, NUDOCS 8104240284 | |
| Download: ML19347E225 (5) | |
Text
(-
~
^
n.
VIaOINIA EI.ECTRIC AND Powan COMP h
Rxcuxown,VraroxxzA 20261
.!m u AN:30 April 3, 1981 Mr. James P. O'Reilly, Director Serial No. 180 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 March 10, 1981 in reference to the inspection conducted at North Anna Power Station between December 1, 1980 and January 10, 1981 and reported in IE Inspection Report Nos. 50-338/80-41 and 50-339/80-38.
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 objec-tion to these inspection reports being made a matter of public disclosure.
The information contained in the attached pages is true and accurate to the best of my knowledge and belief.
Very truly yours, ff ~
B. R.
ylvia Manager - Nuclear Operations and Maintenance l
Attachment I
City of Richmond Commonwealth of Virginia Acknowledged before me this 3 day of b, 198]
&~ C. }hcn l
Notary Public i
l My Commission expires:
_a _.1 6
, 19p-SEAL I
l cc:
Mr. Robert A. Clark, Chief Operating Reactors Branch No. 3 Division of Licensing 4810.4 2.4 0 3 Y
~
2
Attcchme2t Peg 2 1 RESPONSE TO NOTICE VIOLATION ITEM REPORTED DURING NRC INSPECTION CONDUCTED FROM DECEMBER 1, 1980 THROUGH
~
JANUARY 10, 1981 i
A.
NRC COMMENT Technical Specification 3.3.1.1 Action Statement No. 7 requires that an inoperable channel be placed in a tripped condition within one (1) hour.
Contrary te the above, on November 14, 1980, Channel I of steam generator A level was placed in a tripped condition 9\\ hours after the level indication reading was logged as being greater than the allowed tolerance from che average of the three level channels and was therefore inoperable.
This is a Severity Level IV_ Violation (Supplement I.D.3.) and applicable to Unit 1.
A similar item was brought to your attention in our letter dated August 20, 1980.
RESPONSE
1.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION The Notice of Violation is correct as stated.
l 2.
REASONS FOR THE VIOLATION This violation was the result of a personnel error on the part of the control operator trainee taking the CR0 Logs (1-LOG-4).
He failed to note that the affected level channel was out of tolerance.
The control room operator and the Shift Supervisor in their review of LOG-4 -also -failed -to motice that the affected channel was ~- ~
logged as being greater than the allowed tolerance from the average of the three channels.
3.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED Withir one hour after the channel was determined to be inoperable, protection Channel I for steam generator A was placed in the tripped condition.
4.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS Those individuals involved in the above mentioned occurrence were formally counseled.
Further action will include the distribution of a memorandum to all Operations personnel. This memorandum will reemphasize the require-ment to note and explain all out of tolerance readings on logs taken and to conduct log reviews in a more careful manner both prior to and during the shift, as required by administrative procedures.
l I.
- - - - - - - - - ~. - - - - - - - - - - - - - - - - - - - -
2.
Attachment Pega 2 5.
DATE WifEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance for the further action stated above will be achieved on or about March 31, 1981.
1 I
i i
l l
l w-,
,w._.,-.----,--v.,, - -, - -, -. -,. -,,,..,,,, - - _.,. _,.,
,,_,_..n
--n.
,_, _,,_ _., -,,,,,n
,,,4,
,,._,,,_,,,_n.
r Att:chment g
Pega 3
.9 RESPONSE TO NOTICE OF VIOLATION ITEM REPORTED DURING NRC INSPECTION CONDUCTED FROM DECEMBER 1, 1980 THROUGH JANUARY 10, 1981 B.
NRC COMMENT Technical Specification 6.8.1.a requires that procedures 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, operations and shutdown of safety related systems.
Contrary to the above, during the startup conducted from November 24, through November 30, 1980, the verification of service operability of engineered safeguards and reactor protection instrument transmitters was not performed as required by 1-OP-1A, Prestartup Check Off List.
This item reflects incomplete corrective action to a previous violation.
This is a Severity Level V Violation (Supplement I.E.) and applicable to Unit 2.
A similar item was brought to your attention in our letter dated August 20, 1980.
RESPONSE
1.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION The Notice of Violation is correct as stated.
_ 2.__ REASONS FOR THE VIOLATION.
Previously, the Operating Procedure for Unit No. I and No. 2 (OP-1A)
"Prestartup Check Off List" had been revised to require a signoff for operability status of safety related instrument transmitter stop valves.
However, because the "Prestartup Check Off List" is used primarily after a major outage (i.e.
refueling), there was no mechanism to ensure that the instrument department was to complete IMP-P-MISC-11 (Maintenance Procedure for Verification of Level Line Ups for Engineered Safeguards and Reactor Protection Systems) for outages of shorter duration.
This inadequacy led to the violation.
3.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED When notified of this infraction, Station management committed to complete IMP-P-MISC-11 prior to startup from the December mainte-nance outage.
The procedure was successfully completed on December 10, 1980.
,,y
,-----v---,m----,,
w-y
..-,*.y.
9,_y.,p.,.,py.,wpp_,g.
.-%,y-y,gw-*=,,,aee,.yy,,,,.w,-wy,we.g,*,--e-*w,----we*--g-m
.--w
p*-
Attachment Pcg2 4 o
4.
CORRECTIVE STEPS WHICH WIII BE TAKEN TO AVOID FURTER VIOLATIONS To prevent recurrence, Units 1 and 2 (OP-1A) "Prestartup Check Off List" will be signed off to the extent necessary, prior to entering Mode 4.
In addition, the planning and scheduling department has been instructed to inform the instrument department to conduct I
IMP-P-MISC-11 prior to entering Mode 4 following each outage, regardless of its duration.
5.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVEE Full compliance has been achieved.
en e
_.+,,..-w.,.---.,.y-_--,,._
.wg
- y,,y,,,
,.,w,9-w.yg--wm, v
-_py.99--
..,,-,,,,,gg-,,,9y
,,y--
y.,w,w---
,y,-
w.
-..y-w--y%-.-ewwg=
e.
--w q
q--m e-- -
,---w-.
I w[g ar UNITED STATES o
8
'h NUCLEAR REGULATORY COMMISSION 3
E REGION 11 101 MARIETTA sT., N.W *AJITE 3100
%.....[
ATI.ANTA. G EORGIA 30303 MAR 101981 Virginia Electric and Power Company ATTN:
J. H. Ferguson Executive Vice President-Power P. O. Box 26666 Richmond, VA 23261 Gentlemen:
Subject:
Report Nos. 50-338/80-41 and 50-339/80-38 This refers to the routine safety inspection conducted by E. H. Webster of this office on December 1, 1980 through January 10, 1981, of e :tivities authorized by NRC License Nos. NPF-4 and NPF-7 for the North Anna fac-lity. Our preliminary findings were discussed with W. R. Cartwright at the conclusion of the inspection.
Areas examined during the inspection and our findings are discussed in the enclosed inspection report.
Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations by the inspectors.
During the inspection, it was found that certain activities under your license appear to violate NRC requirements. These items stad references to pertinent requirements are listed in the Notice of Violation enclosed herewith as Appendix A.
Elements to be included in your response are delineated in Appendix A.
We have examined actions you have taken with regard to previously identified enforcement matters. These are discussed in the enclosed inspection report.
In accordance with Section 2.790 of the NRC " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC Public Document Room. If this report contains any information that you believe to be proprietary, it is necessary that you make a written application within 20 days to this office to withhold such infor-mation from public disclosure. Any such application must include the basis for claiming that the information is proprietary and the proprietary information should be contained in a separate part of the document.
If we'do not hear from you in this regard within the specified period, the report will be placed in the Public Document Room.
Should you have any questions concerning this letter, se will be glad to discuss them with you.
Sincerely, J.o % W 81o3y/o 787 t
e Enclosu're: 'See Page 2
4-a e
4
..4
, ALAR 10198;
~
Virginia Electric ~ and Power Company -
Enclosure:
'1.
- Appendix.Ai Notice of Violation-T2.
Inspection Report Nos. 50-338/80-41-~
and 50-339/80-38 cc w/ encl:-
W. R. Cartwright, Station Manager P. G. Perry,'Sen'ior Resident Engineer J.
w e
e g
E Y 'a j
1 k
4 i '
a g
1 i~
1
' s r
i
~
i
?
, s t
r 1-
-w
~
t.
5 i
t 6
Y e
s de l'
P E,0 r G
g
$.p##m g,
{
"y q
(
i
4 APPENDIX A NOTICE OF VIOLATION Virginia Electric and Power Company Occket Nos. 50-338 &_50-339 North Anna 1 and 2 License Nos. NPF-4 & NPF-7 s
As a result of the inspection conducted on December 1, 1980 through January 10, 1981,. and _ in. accordance with the Interim Enforcement Policy, 45. FR 66754 (October 7,1980), the following violations were identified.
A.
Technical Specification 3.3.1.1 Action Statement #7 requires that the inop-erable channel be placed in a tripped condition within one (1) hour.
Contrary to the above, on November 14, 1980, Channel 1 of Steam Generator A Level was placed in a tripped condition 91s hours after the level indicator reading was logged as being greater than the allowed tolerance from the average of the three level channels and was therefore inoperable.
This is a Severity Level IV Violation (Supplement I.D.3.) and applicable to Unit 1.
A similar item was brought to your attention in our letter dated August 20, 1980.
B.
~ Technical Specific ~ation '6.8'.1.'a requires' that procedures 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 l
discusses procedures for Startup, Operations and Shutdown of Safety Related Systems.
C'ontrary to the above, during the startup conducted from November 24 through November 30,. 1980 the veriff_ cation of service operability of Engineered Safeguards and Reactor Protection' instrument transmitters was not performed l
as required by 1-0P-1A, Pre Startup Checkoff List.
This item reflects l
incomplete corrective action to a previous violation.
This is a Severity Level V Violation (Supplement I.E.) and applicable to l
Unit 2.
A similar item was brought to your attention in our letter dated August 20, 1980.
Pursuant to the provisions of 10 CFR 2.201, Virginia Electric and Power Company is hereby required to submit to this off. ice within twenty-five days of the date of this Notice, a written statement or explanation in reply, including: (1) ad-mission or denial.of the alleged violation's; (2) the reasons for the violations if admitted; (3) the corrective steps which have been taken and the results achieved; (4) corrective steps which will be taken to avoid further violations; and (5) the date when full compliance will be achieved. Under the authority of i
Section 182 of the Atomic Energy Act of 1954, as amended, this response shall be submitted under oath or affirmation.
Date:
~ ~
-?
~
' M dR i 0'19e r ht"~ 9/0 D-4 5 ' D
f FEcuq 4
UNITED STATES
$ch O
! T*
NUCLEAR REGULATORY COMMISSION REGION 11 e, 'hN
[
101 MARIETTA ST., N.W SulTE 3100 ATLANTA, GEORGIA 30303
' %.r j Report Nos. 50-338/80-41 and 50-339/80-38 Licensee: Virginia Electric and Power Company P.O. Box 26666 Richmond, VA 23261 Faciiity Name: North Anna Units 1 and 2 Docket Nos. 50-338 and 50-339 License Nos. NPF-4 and NPF-7 Inspection at North Anna Site near Mineral, Virginia and Corporate Office, Richmond. Virginia
'2
^"
~ ~ ~ '
-' ' ~
Inspectors:
E H. Webster, Senior Resident Inspector Date Signed
/
{'
. t 4 /_ t. h
~ ~,
h g
A. P. Ta e 1
ent Inspector Date Signed Approved by:
p
/
66
/
P. J// Kel oV
. r Chief, RONS Branch Date Signed
SUMMARY
Inspection on December 1-January 10, 1981 Unit 1 Areas Inspect'ed This routine inspection by the resident inspectors involved 99 inspector-hours onsite in the areas of plant transients, 10CFR21 reports, Task Action Plan requirements, followup of previous concerns, licensee event reports, and refueling operations.
Unit 1 Findings Of the six areas inspected, no violations or deviations were identified in five areas. One violation was identified in one area (Failure to trip an inoperable instrument within the timeframe required by the Technical Specification Action Statement paragraph 7.)
g g -! q.lp, g -.-s-g g w,U L'l ~_
_ g.n 7,
3 ji fW "~
f:LL, - M s; L
AUspectors involved 113 inspector-hours DUPLICATE DOCUMENT g!, 10CFR21 reports, Task Action Plan y
g y) and licensee event reports.
p, Entire document previously entered into system under:
SlO 3240 803
-a aNo p
C N o. of pages:
//
N :em9 vi g i{
gggrf _, g s