ML20041F871
| ML20041F871 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 02/17/1982 |
| From: | Leasburg R VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20041F857 | List: |
| References | |
| 034, 34, NUDOCS 8203170494 | |
| Download: ML20041F871 (4) | |
Text
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February 17, 1982 Nuca..A. Ormaatson.
Mr. James P. O'Reilly Serial No. 034 Regional Administrator N0/RMT:acm 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 January 20, 1982 in reference to the inspection conducted at North Anna Power Station between November 6,
and December 5,
1982, reported in IE Inspection Report Nos. 50-338/81-29 and 50-339/81-26. 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 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 rs, I
l R. H. Le.sb rg Attachment l-cc:
Mr. Robert A. Clark, Chief l
Operating Reactors Branch 3 i
Division of Licensing 1
i l
l 8203170494 820308 PDR ADOCK 05000338 G
i Attachm:nt Paga 1 RESPONSE TO NOTICE OF VIOI.ATION INSPECTION REPORT NOS.50-338/81-29 AND 51 339/81-26 A. NRC COMMENT Technical Specification (TS) 4.7.10.b requires snubbers which appear inoperable as a result of visual inspection may be dete rmined operable providing that the affected snubber is to be functionally tested and determined operable per T.S. 4.7.10.b.
Contrary to the above, verification of operability for Unit 2 snubber 2-SHP-USS-219A was not met in that the snubber was not functionally tested prior to returning it to service on or about September 13, 1981.
This is a Severity Level IV Viriation (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 The referenced snubbe,r is an eight inch Tomkins Johnson cylinder supplied by the Grinnel Corporation. The snubber was declared inoperable due to the loss of visible oil level in the reservoir.
The oil line was removed at the snubber cylinder and no oil was present in the line. This condition indicates that air may have been admitted to the pilot valve.
The snubber was removed, placed on a test stand and refilled with oil.
During the refilling process, the snubber was purged and vacuum evacuated.
The reach rod nuts on the cylinder were retorqued in an effort to stop the leak that caused the initial loss of oil from the reservoir.
The snubber was returned to service without being functionally tested because a replacement snubber was not available and the snubber was too large to be tested using the equipment available on site.
3.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED l
The snubber was removed 28 days af ter being returned to service and sent to l
ITT Grinnel for functional testing.
The snubber satisfactorily passed.the l
functional test in the "as installed" condition. The snubber was subsequently rebuilt as part of the normal periodic maintenance program.
The cause of the oil leak was determined to be a scored bushing on the snubber cylinder.
The bushing was replaced and the snubber was functionally tested satisfactorily.
Similar snubbers have been placed on an accelerated visual inspection schedule to prevent the oil level from dropping below an acceptable limit.
This will prevent possibic air intrusion into the pilot valves for these snubbers.
Attachment Page 2 LER 81-0/1/03L-0 was submitted on October 8,
1981 to address snubber 2-SHP-HSS-219A being inoperable. The failure to functionally test the snubber was discovered by the VEPC0 QC Department and identified on QC Inspection Report IR-N-81-2227 dated October 22, 1981.
An updated LER was submitted on December 30, 1981 to include the failure to functionally test the snubber in question.
4.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATION All the snubbers of the same design on Unit No.
1 (three total) will be replaced during the next outage of sufficient duration to facilitate the modification.
The snubbers removed from Unit No. I will be available for spares on Unit No. 2.
5.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance has been achieved.
B. NRC COMMENT Technical Specification 6.8.1 and 6.8.2 requires written procedures to be established, approved and implemented.
Contrary to the above, on September 11-14, 1981, maintenance was conducted on Unit 2 snubber 2-SHP-HSS-219A without following approved procedures.
This is a Severity Level V Violation (Supplement I.E.)
RESPONSE
1.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION The notice of violation is correct as stated.
2.
REASONS FOR THE VIOLATION The snubber in question was declared inoperable and removed from service due to a loss of oil from the reservoir. The line from the, reservoir was removed at the snubber and determined to contain no oil.
The lack of oil in the supply line indicated that air may have entered the cylinder's pilot valve.
The cylinder was purged and vacuum evacuated to facilitate refilling it with oil.
The tie rod nuts were retorqued in an attempt to stop oil from leaking out the cylinder seals.
Procedures in existence were written to replace an inoperable snubber with a snubber that has been repaired and tested previously.
This event required immediate repair which was only partially covered by the procedure used. All work that was performed was carried out using accepted industry practices.
t
Attachment Page 3 3.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED The requirement that all maintenance be performed in accordance with an approved written procedure was re-emphasized to the snubber maintenance personnel.
The snesber in question was functionally tested satisfactorily 28 days af ter being returned to service.
At this time, a scheduled maintenance outage allowed removal of the snubber.
4.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATION In the event of a similar type of snubber failure, station management will become involved in the determination of the appropriate course of action.
Maintenance of a failed snubber will only be performed in accordance with an approved procedure.
5.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance has been achieved.
.