ML20029B265
| ML20029B265 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 03/01/1991 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 91-074, NUDOCS 9103060331 | |
| Download: ML20029B265 (5) | |
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VnuiiNIA Bi.ncinic AND POWE H COMI'ANY Itie m m un,V n mix A 20201 f4 arch 1,1991 U.S. Nuclear Regulatory Comm'ssion Serial No.
91 074 Attn: Document Control Desk NAPS /JHL Washington, D.C. 20555 Docket Nos. 50 338 50 339 License Nos. NPF 4 NPF 7 Gentlemen:
y.lBEINIA ELECTRIC AND POWER COMPANX NORTH ANNA POWER STATION UNITS 1 AND 2 INSPECTION P.EPORT NOS. 50 338/90-29 AND 50 339/90 29 fHiSPONSE TO THE NOTICE OF VIOLATIQH L We have reviewed your letter af February 1,1991 which r6ferred to the inspection conducted at-North Anna from November 18,1990 through December 18, 1990 and reported in Inspection Report Nos. 50 338/90-29 and 50 339/90 29. Our response to the Notice of Violation is attached, in your letter transmitting the Notice of Violation, you identified two issues. The first is that up-front safety evaluations should be performed-for operating configurations inconsistent with the UFSAR. The second is that procedures and administrative controls thoroughly consider
- the design basis of the plant. To address the first issue, Safety Engineering Administrative Procedure SEAP-0002 was revised to provide the Shift Technical Advisor additional guidance for reviewing operatmg configurations and performing a 10 CFR 50.59 evaluation if required in addition, licensed operators on each shift have received awareness training to 3reclude operating outside the assumptions of the UFSAR unless a 10 CFR 50.59 evaluation s reviewed and approved. Also, the process for revising procedures includes a review of the
- UFSAR to ensure the system being changea does not invalidate the design basis.
To address the second issue, the Design Basis Integration Review program has incorporated a process to review station documents and opercting configurations against the design basis.
As system design basis. documents are approved and issued, System Engineering will
- review station documents and system operating configurations against the design basis, if you have any further questions, please contact us.
Very truly yours,
. POLL
' (et. W. L. Stewart
. Senior Vice President - Nuclear
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Attachment
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Docket Nos. SD 338&339 setial No. 91074 pc: U. S. Nuclear Regulatory Commission 101 Marietta Street, N.W.
Suito 2900 Atlanta, Georgia 30323 Mr. M. S. Lesser NRC Senior Resident inspector North Anna Power Station t
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j The4 foregoing document was acknowledged before ~me, in and for --the
-l County and Commonwealth aforesaidrtoday by J.- P. O'Hanlon~ who is Vice President 1-Nuclear Services, for _W. L. Stewart who-is Senior Vice' 3
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- President -1 Nuclear, of ; Virginia. Electric and Power Company.
He is duly -
authorizedito. executeJand. file the foregoing _ document in behalf of that LCompany, and_ the: statements in' the document are true to the best of his J
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' Acknowledged before _me this N day of r M//,19 9/.
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RESPOliSElp THE NOTICE OF VIOLATION flEPORTED _ DURING THE NRC INSPECTION CONDUCTEQ BETWEEN NOVEMBER 18. 1990 AND DECEMBER 18.199.Q INSEEQJION REPORT NOS 50 338/90 29 AND 50 339/90 29 STATEldENT OF VIOLATION During an NRC inspection conducted between -the-period of November 18 through December 18,1990, violations of NRC requirements were identified. In accordance with the
" General Statement of Policy and Procedure for NRC Enforcement Actions, 10 CFR Part 2, Appendix C, (1990), the violation is listed below:
A. Technical Specification 6.8.1 requires that written procedures be established, implemented and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Included in Appendix A of Regulatory Guide 1.33 are procedures for operation of the service water system.
Contrary to the above, operating procedures for the service water system were inadequate in that neither Procedure 1-OP-49.1, Revision 18, Service Water System Operation, nor other service water operating procedures specified that required alignments to reduce flow to tne component cooling water heat exchangers be made in order to assure design basis flows to the recirculation spray heat exchangers, during all periods of time when a service water pump is inoperable. This procedural inadequacy contributed to a degraded recirculation spray system condition occurring during the 1990 Unit 2 refueling outage, 1
This is a Severity Level IV violatlan (Supplement 1).
BESPONSE TO VIOLATION
- 1. ADMISSION OR DENIAL OF THE ALLEGED VIOLATION The violation is correct as stated.
- 2. REASON FOR-THE VIOLATION The violation was caused by not appropriately applying the requirements _ of Technical Specification 3.0.5 to the shared Service Water (SW) System when Unit 2 was shutdown
- and Unit 1 remained operating in Mode 1 --4.
Standing Order 165 and subsequent revisions were developed to address the adequacy of SW flow during a Design Basis
. Accident (DBA). However, the Standing Order failed to address emergency electrical power source requirements. Specifically, when the Unit 2 emergency diesel generator was out of service for extended maintenance, as allowed by Technical Specifications, the corresponding SW pump d;d not have its respective emergency power source available.
Therefore, during a DBA the SW pump could not be assumed to be available due to the loss -of emergency electrical power.
During this plant operating configuration, conservative controls were not fully established to ensure design SW flow to the Unit 1 Recirculation Spray Heat Exchangers during a DBA.
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Docket Nos. 50 338&339 seria1No 91074
- 3. CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND RESULTS ACHIEVED Upon discovery of the degraded condition, Technical Specificatb compliance was verified, _the Station Nuclear Safety and Operating Committee reviewed the degraded condition for reportability, prompt notification per 10 CFR 50,72(b)(2)(iii)(D) was made to the NRC and the NRC Resident inspector, and a 10 CFR 50.59 evaluation was performod to evaluate and document operation with two component cooling water heat exchangers.
in addition, Operations Standing Order 177 was implemented to ensure the service water system can supply adequate flow to necessary equipment in the event of a DBA and to ensure at least three service water pumps are maintained operable. LER N1/90 012 00 was submitted to document the degraded service water system condition.
- Also, applicable station procedures were revised to. establish acceptable operating configurations of the SW system when service water pumps become inoperable, an independent compliance review was perforred to ensure the revised procedures aodresst inoperable service water pumps w..re effectively irWemented, and the MERITS _1echnical Specifications were reviewed to ensure acceptable service water pump operating configurations were identified.
The service water system design basis document has been completed.
4, CORRECTIVF STEPS TO BE -TAKEN TO AVOID FUTURE VIOLATIONS Technical Specification-changes and revisions to the UFSAR are being evaluated to clarify service water system and power source requirements in Modes 1 through 6.
- 5. THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Technical Specification changes will be submitted to the NRC for approval as required.
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