ML20055A117
| ML20055A117 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 06/11/1982 |
| From: | Leasburg R VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20055A103 | List: |
| References | |
| 310, NUDOCS 8207150492 | |
| Download: ML20055A117 (7) | |
Text
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VINGINIA,iErmcrgIC AND Pown.a CoxPAny R ucunown, Vimorn:A 20261 82 JUN 21
^3 F 2 n.n.LEANBURG June 11, 1982 Vaca Pmessons?
Noctuan Orsmarions Mr. James P. O'Reilly, Serial No. 310 Regional Administrator N0/PJIT: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 Sir:
We have reviewed your letter of May 14, 1982 in reference to the inspection conducted at North Anna Power Station between March 6 - April 5, 1982 and reported in IE Inspection Report Nos. 50-338/82-08 and 50-339/82-08. Our response to the specific infractions are attached.
We have determined that no proprietary information is contained in the report.
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 trul you s,
)
R.
1.
easburg Attachment cc: Mr. Robert A. Clark, Chief Operating Reactors Branch No. 3 Division of Licensing 8207150492 820707 PDR ADOCK 05000338 G
PDR b
i Attachment Page 1 4
A. NRC COMMENT Technical Specification 3.5.1 requires that each reactor coolant system accumulator shall be operable with the isolation valves open when pressurizer pressure is greater than 1000 psig and Tave greater than 350F.
Contrary to the above, on March 7,
1982, all three safety inj ection accumulator isolation valves were closed simultaneously for about 2 minutes for testing purposes with the reactor coolant system above 1000 psig and 350F.
The valves wou?d have opened automatically on receipt of a safety injection signal.
This is a Severity Level IV Violation (Supplement I.)
RESPONSE
- 1. ADMISSION OR DENIAL OF THE ALLEGED VIOLATION The Notice of Violation is correct as stated.
- 2. REASONS FOR THE VIOLATION The cause of this event was personnel error and improper review of procedures. While at a system pressure of 2000 psig it was felt that a surveillance procedure could be completed which also required operation of the accumulator isolation valves. The surveillance procedure was deviated to allow the isolation valves to be energized and closed at a system pressure of 2000 psig rather than at a pressure of less than 1000 psig with a simulated pressure signal of 2000 psig. However, the initial condition in the surveillance test which required pressurizer pressure to be greater than 800 psig and less than 1000 psig was not deviated and was not followed.
- 3. CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED The accumulator isolation valves reopened as pressurizer pressure was brought greater than 2000 psig and power was subsequently removed from the valve. A deviation report was written and those involved were informed of their error. Subsequent to this event a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> report and 14 day Licensee Event Report (LER N2-81-008) were submitted to the NRC.
- 4. CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS The Company has embarked on a program that emphasizes adherence to procedures and that jobs be accomplished in a quality manner. The Vice President, Nuclear Operations has personnally held meetings with starting employees to stress the importance of following procedures and to ensure that all employees understand the expectations of management.
- 5. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance has been achieved.
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Attachment Page 2 B. NRC COMMENT Technical Specification 6.5.1.6 specifies that the Station Nuclear Safety and Operating Committee (SNSOC) shall be responsible for review of all procedures required by specification 6.8.1 and changes thereto.
Contrary to the above, the SNS00 erroneously approved a temporary change to Procedure 2-PT-56.3, on March 7, 1982, which permitted closing of all three of the accumulator isolation valves in a violation of Technical Specification 3.5.1.a.
This is a Severity Level IV Violation (Supplement I.)
RESPONSE
- 1. ADMISSION OR DENIAL OF THE ALLEGED VIOLATION The Notice of Violation is correct as stated.
'. REASONS FOR THE VIOLATION This violation was the result of an improper review of a temporary change (procedure deviation) to 2-PT-56.3 by members of the Station Nuclear Safety and Operating Committee. The review of the procedure deviation was completed hastily and without the required thoroughness.
- 3. CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED The need to complete more thorough reviews was discussed among Safety Committee members. In addition, recent meetings with Company executives and Station personnel attending have emphasized the requirement to follow procedures more carefully.
- 4. CORRECTIVE ACTIONS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATION No further actions are required.
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- 5. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED
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Full compliance has been achieved.
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Attachment Page 3 C. NRC COMMENT Technical Specification 6.12.1 requires that a radiation monitoring device which continuously indicates the radiation dose rate in the area is required upon entry into a high radiation area. T.S.6.8.1 requires that procedures be implemented and maintained. Health Physics Procedure, Section 6,
Exposure Control, states that an "RWP, pocket dosimeter, and dose rate meter are required for entry into a high radiation area".
Contrary to the above, (1) On January 10, 1982, an operator entered a high radiation area to check an instrument, (PI-1-152) and did not have in his possession a radiation dose rate meter.
(2) On February 19, 1982, two engineers were observed taking data readings adjacent to the charging pumps, which is a high radiation area. They did not have a radiation measuring device, nor were they qualified in the use of a dose rate meter.
This is a Severity Level IV Violation (Supplement IV.).
RESPONSE
- 1. ADMISSION OR DENIAL OF THE ALLEGED VIOLATION The Notice of Violation is correct as stated.
- 2. REASONS FOR THE VIOLATION The operator was under the impression that he could enter the high radiation area without notifying Health Physics personnel or obtaining a radiation dose rate meter if the situation was an emergency. He ascertained that time was of the essence to protect plant equipment important to safety. He was aware that the high radiation area existed and he did not obtain the Shift Supervisor's permission prior to entering the area.
The two engineers that were observed within a high radiation area taking data readings were aware of the Health Physics requirements to enter a high radiation area.
- 3. CORRECTIVE STEPS TAKEN RESULTS ACHIEVED Upon discovery of the operator within a high radiation area, a Health Physics Supervisor informed him of the violation and escorted him out of the area. He was later counselled as to the correct procedures which must be followed when entering a high radiation area.
When the engineers were discovered in a high radiation area in violation with Health Physics regulations, they were provided with Health Physics coverage until they obtained the required data in the area. They were then counselled by the Health Physicist for disregarding the high radiation barrier and disciplined accordingly.
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Attachment Page 4
- 4. CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS The correct procedures for entering high radiation areas are emphasized in the General Employee Training Class which is mandatory before new employees may obtain security clearances to enter the exclusion area without an escort. This information is also re-emphasized in detail to every employee yearly in the annual Employee Retraining Program. An examination must be completed for each training class and a passing grade must be attained before an employee is issued a clearance or is allowed to maintain a current clearance.
On March 4, 1982, the Station Manager issued a memorandum to all Supervisors to ensure that all personnel are aware of their responsibilities in the area of Health Physics. It mentioned that violations of Health Physics barriers and regulations are in direct conflict with our policy of ALARA and will not be tolerated.
- 5. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance has been achieved.
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Attachment Page 5 D. NRC COMMENT Technical Specification 6.8.1 requires that written procedures be established, implemented and maintained. Maintenance Procedure MMP-C-GP-1 section 5.3 requires approval of the Mechanical Maintenance Supervisor and Quality control prior to pump disassembly. Maintenance Procedure MMP-ADM-1.0, section III, states that approved maintenance procedures will be used on safety-related systems.
Contrary to the above:
(1) On March 10, 1982, two valves associated with the Casing Cooling System which were specified to be closed were erroneously left open. This event resulted in pumping of approximately 20,000 gallons of water onto the containment floor.
(2) On February 5,1982, a safety-related service water pump was disassembled without the specific approval of the Mechanical Maintenance Supervisor and Quality Control as required by MMP-C-GP-1.
J (3) On March 16, 1982, maintenance activities were performed on safety-related valves 2-FW-192, 2-FW-127 and 2-FW-129 without required procedures.
This is a Severity Level IV Violation (Supplement V.).
RESPONSE
- 1. ADMISSION OR DENIAL OF THE ALLEGED VIOLATION (1) The notice of violation is correct as stated.
(2) The notice of violation is correct as stated.
(3) The notice of violation is denied.
- 2. REASONS FOR THE VIOLATION (1) The periodic surveillance for the Containment Depressurization and Cooling System (2-PT-66.3) was being performed on March 10, 1982. One portion of this test is to verify that the Casing Cooling pumps start and discharge valves open on a containment depressurization actuation
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(CDA) signal. This portion of the test requires the manual isolation valve to be closed on the discharge of each Casing Cooling system to the suction of each outside recirculation spray pump suction. These valves are closed while cycling the series motor operated valves to prevent the Casing Cooling tank from draining by gravity into the recirculation spray sump and onto the containment floor. The manual isolation valves are located in the safeguards valve pit. The operator that was responsible for closing the valves did not personally verify that the normally open valves had been closed. The operator asked Maintenance personnel that were in the valve pit as to the valve positions in question. The Maintenance personnel that checked the valve position were qualified to determine the valve positions and consequently reported the valves as being closed when they were actually open. The Casing Cooling discharge motor operated valves were opened during the test and the water was pumped into the containment.
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Attachment Page 6 (2) On February 5,1982 the Unit 2 Service Water Pump 1A was removed from the Service Water Pump House and transferred to the No. I track bay for maintenance.
The work to remove the pump was commenced on day shift with no procedure.
The night crew arrived on site and initiated a general pump procedure for repairing the pump. The general pump procedure requires the prior approval of the Mechanical Maintenance Supervisor and Quality Control to perform specific steps for pump disassembly. The signatures of the Mechanical Maintenance Supervisor and Quality Control were not obtained prior to disassembling the pump. The approval was obtained on February 6th. The j
failure to obtain the appropriate approval was identified by North Anna Quality Control Inspection Report IR-N-82-161 on February 6, 1982.
(3) On March 16, 1982, inspection of the valve internals was performed on safety-related valves 2-FW-127, 2-FW-129, 2-FW-172, 2-FW-192 without the procedures being at the work location. This is contrary to the VEPCO Nuclear Power Station Quality Assurance Manual Section 16, Part 6.5.4.j but not contrary to T.S. 6.8.1.
- 3. CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED (1) The responsible operator was made aware of the correct procedure for verifying a valve line-up and appropriate disciplinary action was taken.
(2) The Mechanical Foreman was notified by a Quality Control inspection report as to the proper sequence of signatures required to perform maintenance on safety-related equipment and disciplinary action was taken. The appropriate signatures were obtained within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of the work being started to disassemble the pump.
(3) The Maintenance personnel responsible were instructed to maintain a copy of the procedure in use at the work location.
In all cases, these actions resulted in full compliance with Station Procedures.
- 4. CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATION The Company has embarked on a program that emphasizes adherence to procedures and that jobs be accomplished in a quality manner. The Vice-President, Nuclear Operations has personally held meetings with Station employees to stress the importance of following procedures and to ensure that all employees understand the expectations of management.
- 5. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance has been achieved.
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