ML20039A212
| ML20039A212 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 11/25/1981 |
| From: | Leasburg R VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20039A208 | List: |
| References | |
| 635, NUDOCS 8112160367 | |
| Download: ML20039A212 (3) | |
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VINGINIA ELECTRIC ann Powan COMPANyg RICHMOND, Y1MUINIA 20 261 Bl Dfr 3 A8.S' November 25, 1981 N.H.LuAmmuno Vsom Pasassant Noctuam Orsmarions Mr. James P. O'Reilly, Directer Serial No. 635 Office of Inspection and Enforcement N0/RMT:acm U. S. Nuclear Regulatory Conunission 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 October 30, 1981 in reference to the inspection conducted at North Anna Power Station between September 6, 1981 and October ~5, 1981 and reported in-IE Inspection Report Nos. 50-338/81-25 and 50-339/81-22.. Our response to the specific infraction is attached.
We have determined that no proprietary information is contained in the reports.
Accordingly, the Virginia Electric and Power Company has no obj ection 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, 4
p-R. H. Leasburg Attachment City of Richmond Acknowledged before me this 4 I::(Lday of D ev., 19 P /
Commonwealth of Virginia b d. W h Notary Public My Commission expires: 16, 19 W SEAL cc:
Mr. Robert A. Clark, Chief I
Operating Reactors Branch No. 3 Division of Licensing 811216 0 3 C'74e
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wnn Attcchment l
Paga 1 RESPONSE TO NOTICE OF VIOLATION ITEM RE?ORTED DURING NRC INSPECTION CONDUCIED FROM SEPTEMBER 6 - OCTOBER 5, 1981 IEIR 338/81-25-1 AND 339/81-22-1 NRC COMMENT Technical Specification 6.8.1 requires that written procedures shall be established and implemented.
Abnormal procedure 1-AP-5.2 requires a daily stack sample and a recalculation of release rates prior to returning stack exhaust to normal whenever the vent stack monitor is in alarm condition.
s Contrary to the above, on September 30 and October 1, 1981, 1-AP-5.2 was not followed in that daily grab samples of the vent stack were not obtained and recalculated release rates for the affected system were not completed prior to restoring the discharge path to the environment.
This is a Severity Level V Violction (Supplement I.E.).
RESPONSE
1.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION The first comment is not correct as stated.
Abnormal procedure 1-AP-5.2 does not require a daily stack sample whenever the vent stack monitor is in the alarm condition. A daily grab sample is only required when the radiation monitor is inoperable. However, the abnormal procedure does state that upon receiving a visual and audible alarm, the Health Physics Department is to be notified to sample the affected system (Step 4.4);
that the vent samples and/or Health Physics surveys be utilized to deter-mine which area has high activity (Step 5.13.1), and that HP surveys be utilized to determine the exact source of the activity (Step b.13.3).
Contrary to the A.P., an initial sample of the affected area (Auxiliary Building General Vent Stack A) was not taken. The taking of subsequent grab samples of the affected area, although advisable, is not required with the radiation monitor in alarm only.
With regard to the second comment, that a recalculation of release rates for the effected system was not completed prior to restoring the discharge path to the environment, it is admitted that there is no documentction to verify that the release rates were recalculated, or that the radiation monitor in alarm was cleared, prior to restoring the discharge path of Vent Stack A from diverting through the charcoal filter banks to flowing directly to the stack.
2.
REASONS FOR THE VIOLATION The reasons for the violation occurring are due to several problems, which iv f t de the failure to properly maintain procedures; the failure to accut. ely document all activities concerning the situation from a
beginning to end; and most importantly, the failure of the groups involved to communicate with each other throughout the event.
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CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED When notified of the infraction, grab samples of the affected area (Auxiliary Building General - Vent Stack A) were taken, and an in-vestigation was conducted to insure that no significant increase in the release rate occurred during the period referred to in the. Notice of Violation. Both the grab samples of the A Vent Stack and the sub-saquent investigation previously mentioned indicated that all releases
- re well within limits.
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CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS The Operations personnel received a memorandum to address Radiation Monitor Abnormal Procedures and actions required when radiation monitor alarms are received, including giving Health Physics personnel precise instructions concerning grab samples to be taken.
5.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance has been achieved.
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