ML20056D427

Responds to NRC Re Violations Noted in Insp Repts 50-338/93-18 & 50-339/93-18 on 930509-0619.C/As:instrument Technicians Have Been Counseled on Importance of Completing All Actions Required by Procedures

ML20056D427
Person / Time
Site:	North Anna
Issue date:	08/09/1993
From:	Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
93-461, NUDOCS 9308160172
Download: ML20056D427 (5)

Text

i l

VinorNIA EI.ECTHIC AND POWER COMi%NY R2cunoNn, VIRGINIA 202 61 August 9,1993 U.S. Nuclear Regulatory Commission Serial No.93-461 Attention: Document Cc ntrol Desk JHL/MAE R2 Washington, D.C. 20556 Docket Nos. 50-338 50-339 License Nos. NPF-4 NPF-7 Gentlemen:

VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNITS 1 & 2 ,

INSPECTION REPORT NOS. 50-338/93-18 AND 50-339/93-18 REPLY TO A NOTICE OF VIOLATION We have reviewed your letter of July 13,1993, which referred to the inspection conducted at North Anna Power Station from May 9,1993 to June 19,1993,and reported in inspection Report Nos. 50-338/93-18 and 50-339/93-18. Our reply to the Notice of Violation is attached.

Because of recent trends and management sensitivity on the issue of adherence to procedures, we have been taking additional actions to preclude further errors. Actions include: 1) more frequent monitoring of trends in human performance with increased management review and followup,2) holding information/ coaching meetings with I&C technicians to discuss items such as self checking, verifications and applicable deviation reports or near misses,3) re-evaluation of the level of verificatiors that is actually needed in I&C procedures, and 4) upgrade of l&C procedures. Additional oversight activities by Corporate Nuclear Safety and Quality Assurance, as wall as, the j use of HPES and the Integrated Event Trending Program will be utilized to assess  !

specific events and also monitor ongoing activities for specific trends so that early l

management attention may be directed to problem areas.

If you have any further questions, please contact us.

1 Very truly yours, i

/ /

[ '%wd~ l W. L. Stewart  !

Senior Vice President - Nuclear Attachment '

i 160000  ! 40 i

9308160172 930809 gg / I  ;

PDR ADDCK 05000338 N P 1

_O PDR b  !

~

cc: U.S. Nuclear Regulatory Commission Region ll l 101 Marietta Street, N.W.

Suite 2900 i Atlanta, Georgia 30323 l NRC Senior Resident inspector .

North Anna Power Station t

F b

i k

REPLY TO A NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-338/93-18 AND 50-339/93-18 NRC COMMENT During an NRC inspection conducted on May 9, through June 19,1993, a violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violation is listed below:

Technical Specification 3.6.4.1 requires two independent containment hydrogen analyzers (shared with the other unit) shall be OPERABLE. Action statement a requires with one hydrogen analyzer inoperable, restore the inoperable analyzer to OPERABLE status within 30 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

Contrary to the above, hydrogen analyzer 1-HC-H2A-101 was determined to be inoperable from February 9,1993, to May 9,1993 without implementing the requirements of the action statement.

This is a Severity Level IV violation (Supplement I).

REPLY TO A NOTICE OF VIOLATION

1. REASON FOR THE VIOLATION The violation was caused by personnel error which resulted from a procedure step that required the implementation of multiple actions. On February 9,1993, I&C personnel calibrated hydrogen analyzer 1-HC-H2A-101 using Instrument Calibration Procedure ICP-HC-1-H2A-101. The sensing line (tubing) to -

pressure switch PS-3 was not reconnected following the removal of the calibration test equipment. The condition was subsequent:y discovered on May 9,1993 by an operator. This failure of human performarce is attributed to lack of attention to detail and self checking.

Inadequacies with the calibration procedure was a concributing factor. The calibration procedure did not require that the re-connection of the tubing to pressure switch PS-3 be independently verified by another individual prior to returning the equipment to service. Also, there was no statement in the calibration procedure requiring that the functional components of the overall system be calibrated in a specific sequence. Section 4.4, Analyzer Calibration, was performed before section 4.3, Calibration of Pressure Switches PS2 and PS3. Had the analyzer calibration been performed last, the disconnected tubing would have been detected because a low flow alarm would have been received during the calibration.

2. CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED The Technical Specification Action Statement for an inoperable hydrogen analyzer was entered. The Instrument Department calibrated pressure switch PS-3 and reconnected thu sensing line to the pressure switch. The Technical Specification Action Statement was subsequently cleared.

Instrument technicians have been counseled on the importance of completing all actions required by procedures.

The Unit 1 containment hydrogen analyzer calibration procedure, ICP-HC H2A-101, has been changed to 1) eliminate multiple action steps for disconnecting test equipment and restoring pressure switch tubing to normal,2) include simultaneous verification during calibration activities to ensure discor.nected tubing is reconnected,3) include an independent verification step to the return to service section of the procedure to ensure tubing is reconnected prior to returning the_ equipment to operable status, and 4) add a precaution to ensure the analyzer calibration (section 4.4) serves as a retest for prior performed sections of the procedure if the entire procedure is being performed.

The corresponding Unit 2 calibration procedure was also changed.

3. CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS No further corrective actions are required.

c.. . .

4. THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance has been achieved.

u i

(

I P

k i

5 i

i l'