ML20041C363
| ML20041C363 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 02/24/1982 |
| From: | Leasburg R VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| 059, 59, NUDOCS 8203010218 | |
| Download: ML20041C363 (3) | |
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VIHOINIA HLl!CTHIC AND POWI!It COMI'ANY llICII M ON1h VIItGINIA 20 2 61 It. II. LF, A NDI!MO February 24, 1982 vu v.....r Nect.Am Ors arnown Mr. James P. O'Reilly Serial No. 059 Regional Administrator N0/RMT:acm U. S. Nuclear Regulatory Commission Docket Nos. 50-338 Regica 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 January 29, 1982 in reference to the inspection conducted at North Anna Power Station between December 6, 1981 and January 5, 1982 and reported in IE Inspection Report Nos. 50-338/81-31 and 50-339/81-28. 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 objection 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, 3
R. H. Leasburg Attachment cc:
Mr. R. A. Clark, Chief Operating Reactors Branch No. 3 7
Division of Licensing f(
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i Attachment Page 1 i
RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-338/81-31 AND 50-339/81-28 i
NRC COMMENT Technical Specification 3.0.4 requires that entry into an operational mode shall not be made unless the conditions of the limiting condition for operation are met without the reliance on provisions contained 11. the action requirements.
Contrary to the above, on December 9, 1981, the reactor was taken critical from hot standby (mode 3) to startup (mode 2) with the limiting condition for operation of Technical Specification 3.3.1.1 not met.
The action requirement j
of Tabic 3.3-1, Item 21, permitting one channel of the Reactor Trip Breakers to be bypassed, was in effect.
This is a Severity Level IV Violation (Supplement I.D).
RESPONSE
1.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION The Notice of Violation is correct as stated.
2.
REASONS FOR THE VIOLATION This event occurred on December 9, 1981, after a Unit 2 reactor trip caused by an apparent contact failure on Bypass Breaker "B" during the performance of the Reactor Protection and ESF Logic Test, 2-PT-36.1.
Upon satisfactory determination of the cause of the trip, the trip breakers, RTA and BYB, were closed and tha control rods were withdrawn, boron dilution was initiated, and the plant was taken from Mode 3 to Mode 2.
In the interim, the decision was made to continue the performance of the Reactor Protection and ESF Logic Test which required that the trip functions for one SSP train be defeated for a maximum of two hours.
While this condition was being met, the requirements of T.S. 3.0.4, entry into an Operation Mode while meeting the Limiting Condition for Operation were not met.
Technical Specification 3.0.4 was not intentionally i
violated, but the violation of Technical Specification 3.0.4 was a personnel error.
3.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED Upon discovery of this event, the test was stopped, Bypass breaker "B" was opened and racked "out" and the " Inhibit" switch was returned to
" Normal".
At that time operations personnel responsible for making the decision for the Mode change realized that their actions were contrary to Technical Specification 3.0.4.
This event was reported to the NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and a written followup report LER/RO-N2-81-88 was submitted within 14 days as required by Technical Specification 6.9.1.8.
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Attachment Page 2 1
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The startup procedures for both units have been changed to include a step to review all periodic tests and maintenance evolutions in progress and verify that none in progress will preclude a mode change as per Technical Specification 3.0.4.
4.
CORRECTIVE STEPS WilICil WILL BE TAKEN TO AVOID FURTilER VIOLATIONS A precaution will be added to 2-PT-36.1 and 1-PT-36.1, Reactor Protection l
and ESF Logic Test, stating that a Mode change cannot transpire while this test is in progress.
5.
DATE WilEN FULL COMPLIANCE WILL BE ACllIEVED Complete compliance will be achieved by March 31, 1982.
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