ML20003G588
| ML20003G588 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 03/10/1981 |
| From: | Sylvia B VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20003G585 | List: |
| References | |
| 127, NUDOCS 8104300213 | |
| Download: ML20003G588 (9) | |
Text
{{#Wiki_filter:. ./ e VxmorwxA Er.ncruzc Axn Powna Cddd^w1P F'!!.~. N Fr, J. a $; T A .d'. ,,....p,rcunsown,VrmorwzA saaes ,:,; ;,R cU ~ ! U Q' I ~ All * ! , \\ \\., i ar'ch' IO,d M 1981 Mr. James P. O'Reilly, Director Serial No.127 l Office of Inspection and Enforcement N0/RNT:ss 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 February 13, 1981 in reference to the inspection conducted at North Anna Power Station on November 1-30, 1980 and reported in IE Inspection Report Nos. 50-338/80-38 and 50-339/80-36. Our responses to the specific infractions are attached. We have determined that no proprice.ary information is contained in the reports. Accordingly, the Virginia P.;ectric and Power Company has no objec-tion to these inspection reports being made a matter of public disclosure. Pursuant to Section 182 of the Atomic Energy Act of 1954, this material is being submitted under oath. Very truly yours,
- 2 La B. R. Sylvia Manager - Nuclear Operations and Maintenance Attachment cc:
Mr. Robert /. Clark, Chief Operating Reactors Branch No. 3 Division of Licensing O t y 8104300 M
COMMONWEALTH OF VIRGINIA )) s. s. CITY OF RICHMOND ) Before me, a Notary Public, in and for the City and Commonwealth aforesaid, today personally appeared B. R. Sylvia, who being duly sworn, made oath and said (1) that he is Manager-Nuclear Operations and Maintenance, of the Virginia Electric and Power' Company, (2) that he is duly authorized to execute and file the foregoing response in behalf of that Company, and (3) that the statements in the response are true to the best of his knowledge and belief. Given under my hand and notarial seal this lO day of M 1 l986 l My Commission expires M l9, 19 8d-v y O U44& A V Notary (?ublic l k-i i (SEAL) l l l i 1
Attcchment P:g2 1 RESPONSE TO NOTICE VIOLATION ITEM REPORTED DURING NRC INSPECTION CONDUCTED FROM NOVEMBER 1-30, 1980 A. NRC C0t9fENT Technical Specification 6.8.la requires that written procedures shall be established, implemented and maintained covering activities described in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Contrary to the above, procedures covering nine engineered safeguards systems' valve lineups were not maintained current to reflect the as built condition of these systems. These valve lineup errors were the result of system modifications which had not been incorporated into procedural changes. No valves were identified in an incorrect position. This is a Severity Level IV Violation (Supplement I.D.3) Unit 2 only.
RESPONSE
1. ADMISSION OR DENIAL OF THE ALLEGED VIOLATION The Notice of Violation is correct as stated. 2. REASONS FOR THE VIOLATION The violation resulted from a lack of administrative control in that Operations Department was not always included in the post-implemen-tation technical review process for Design Changes prior to starting up the affected unit. 3. CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED The incorrect valve lineup procedures have been changed to reflect as built conditions of the affected systems. 4. CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS A signoff for the Superintendent of Operations will be added to the " Design Change Technical Review" form. This form is initiated by the Design Control Engineer once a Design Change is physically complete and is used to document the technical review of the Design Change package by Maintenance Construction, the Project Engineer, Operations Superintendent, the Performance Engineer, and the Design Control Engineer. The Superintendent of Operations, by his signa-ture on this form, will be documenting that either all required control room procedures and lineup checklists have been changed to reflect the modifications made by the Design Change or that instruc-tions have been incorporated in the Standing Order Book addressing temporary operating changes and/or restrictions needed until the procedures and lineups have been changed. m _-,,y.
,-7.
,,..,p y .-.3,e ,.w.w,.., ,,-.-y.g- ,,,,m.---
- ~
Attcchment P 32 2 4. (Continued) Therefore, there will now exist a mechanism to, first of all, alert Operations that procedural changes may be required and, secondly, provide the Chairman of the SNSOC confirmation that Operati'ons is prepared to operate the plant in accordance with the modifications made by the Design Change. 5. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance will be achieved by March 15, 1981. O l O e 1 6 4 m a ,..e--p, ,., _ _..yy., ,,,----,,,,,._.--p., -p.,-,p., g,p,9,,,y g,.-- .y.,. __m__,_
Attcchment P 32 3 RESPONSE TO NOTICE OF VIOLATION ITEM REPORTED DURING NRC INSPECTION CONDUCTED FROM NOVEMBER 1-30, 1980 B. NRC COMMENT Technical Specification 4.3.3.6 requires that each post accident monitor-ing instrument channel shall be demonstrated operable by performance of the channel calibration operation at least every 18 months as per Table 4.3-7. Contrary to the above, all three reactor coolant outlet temperatures, hot leg (wide range), and reactor coolant inlet temperatures, cold leg (wide range), primary sensors (RTD's) were not calibrated at least every 18 months. This is a Severity Level V Violation (Supplement I.E.) Unit 1 only.
RESPONSE
1. ADMISSION OR DENIAL OF THE ALLEGED VIOLATION The specifics presented in the above are correct as stated. However, since Vepco identified this omission and took immediate action to address the problem, we do not believe that a Notice of Violation is justified. We therefore propose that the Fotice of Violation be withdrawn. 2. REASONS FOR THE VIOLATION l Administrative error resulted in the failure to properly schedule ar.d perform the calibration procedure. 3. CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED At the same time it was discovered that the narrow range RTD's were beyond their surveillance interval, it was also realized that the l l wide re 'ge RTD's were beyond their surveillance interval. PT-121, the procedure for checking RTD Cross Calibration, verifies both narrow range and wide range RTD's. The special test, 1-ST-32, which j was written to verify the satisfactory performance of the RTD's, did not address the wide range RTD's for several reasons: (1) the wide range RTD's are installed in thermal wells as opposed to being installed in a common manifold as is the case of the narrow range RTD's; as a result, there was no way to compare the RTD's to each other, given that the core was at power and isothermal conditions did not exist; (2) the wide range RTD's do not provide inputs to control or protection logic; they provide inputs to stop valve interlocks, subcooling monitors, and control room recor' der; (3) the l temperature indication provided by the wide range RTD's was consis-l tent with the remaining RCS temperature indications (i.e., incore l T/C's and narrow range RTD's). I -v'- w 'v7--*---- __p+-r i--g-gapy w-7 e-e-+--9" --*-y-9 -e--w-+- y-- - ' e -- w -e- -,--yr-e-e-- -,--e--------we
w--
- = -
- -w-
y Attachme t P ge 4 3. (Continued) Based on the results of 1-ST-32 and the reasons for not addressing the wide range RTD's in the special test, there existed sufficient justification for continuing. operation until the refueling outage. 4. CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS PT-121 is scheduled to be performed during the next heat-up prior to criticality. In addition, the test frequency classification has been changed from "Special" to " required every 18 months" as required by Tech. Specs. Tables 4.3-1, 4.3-2, and 4.3-7. 5. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance has been achieved. I t = O 6 l t I f I ,s' .1 e 4
(, Attcchment P:ga 5 RESPONSE TO NOTICE OF VIOLATION ITEM kEPORTED DURING NRC INSPECTION CONDUCTED FROM NOVEMBER 1-30, 1980 C. NRC COMMENT 10 CFR 50.59b requires written safety evaluations for each special test not described in the FSAR which provides the basis for the determination that the test does not involve an unreviewed safety question. Contrary to the above, 1-ST-32, "RTD Cross Calibration at Power" was performed without a written safety evaluation. The Station Nuclear Safety and Operating Committee had reviewed the special test prior to its performance and had considered the existence of an unreviewed safety question. This in a Severity Level V Violation. (Supplement I.E.) Unit 1 only.
RESPONSE
The above infraction is not correct as stated. A written safety evalua-tion signed by the Chairman, Station Nuclear Safety and Operating Committee and dated September 24, 1980 is filed with 1-ST-32, "RTD Cross Calibration at Power". The safety evaluation which could not be located at the time of the inspection was later located in Station Records. Accordingly, we propose that this Notice of Violation be withdrawn. l O e 9 m e ew y p-.i_-----*9... g w g- .,-y. ,,,,,g- - - + -, - - - -. -. - - -,, -. -,_.
[ _.- I* Attechnent Pegn 6 RESPONSE TO NOTICE OF VIOLATION ITEM REPORTED DURING NRC INSPECTION CONDUCTED FROM NOVEMBER 1-30, 1980 D. NRC COMMENT Technical Specification 6.8.3 requires that tempor.Ary changes to proce-dures required by Technical Specification 6.8.1 may be made provided: (a) the intent of the procedure is not changed, (b) the change is approved by two members of the plant supervisory staff at least one of whom holds a Senior Reactor Operators License on the Unit affected and (c) the change is documented, reviewed by the SNSOC and approved by the Station Manager within 14 days of implementation. Contrary to the above, procedure deviations to 2-OP-7.6A " Valve Checkoff Inside Recire. Spray System" implemented in February 1980, and 2-OP-31.2 " Valve Checkoff - Auxiliary Feedwater" implemented in February 1980, were not approved by two members of the plant supervisory staff nor reviewed by SNSOC and approved by the Station Manager within 14 days of implemen-tation. This is a Severity Level V Violation (Supplement I.E.) Unit 2 only.
RESPONSE
1. ADMISSION OR DENIAL OF THE ALLEGED VIOLATION The Notice of Violation is correct as stated. 2. REASON FOR THE VIOLATION The subject incident occurred when deviations from a valve lineup were documented as procedure deviations and were not reviewed by the SNSOC within 14 days. It is normal practice to begin valve lineup well in advance of the time that the lineup is required. Previously, as individual portions of the lineup had been completed, any discrepancies were immediately documented by procedure deviations. Since a valve lineup may take two weeks or more t'o complete, it was difficult to adatpistratively control all deviations for a lengthy lineup. This was the case in the subject incident. 3. CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED The administrative problen described above has been corrected as follows. As individual checkoff sheets are completed, discrepancies pror.edure deviation will not be immediate1y will be noted but a issued. When the entire lineup is complete, all discrepancies will be compiled and reviewed. The valve lineup will then be ' considered complete. At that time all discrepancies will be documented by procedure deviations. This will greatly simplify the administrative process and will help to ensure that deviations will be reviewed within the required time. T-'Tf F--T-g'w-T-v- -ry-"-e9tw-9--g-r3-mW- +w7+-e-t-vgevw+-y-er*ym-e--+--ww-t'- res-7u-4--m v--1e--s--r-w---t-weevT-p. w w wwwe me e e err weemev-*-*er-egrv-==per - irt+r++- Y --=wwe+r-*mNwet-=t---
(z7 )., ::,, Attcchment P 32 7 4. CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS No additional corrective action is planned. 5. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance has been achieved. 9 O e-O 1 W '1-WW-9--T*f't'mTvv"FP*v T' T*7'""-**FMvs= W-vT-W1 wwW-'d -rP-*----===r--'v er'v=*-7-wMFr-*M e te4* -w*Tu--** -Te7--F* = =m='m =9'-----9 p'**W-"4r-Fm-N*P-WT*'WW-1N W-1w-WW-u-}}