ML20062L919
| ML20062L919 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 11/17/1981 |
| From: | Leasburg R VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20062L917 | List: |
| References | |
| 624A, NUDOCS 8112160449 | |
| Download: ML20062L919 (6) | |
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USNRC REGlon ~
VIRGINIA ELECTRIC AND Powna COMPAND, g;g RicnxoNn, VIRGINIA 20261 3i NOV 2t P 2 3 i R.H.EnANSUNG NOVEMBER 17,.1981
- Vacs Pasespant Nectuan Oramarnown Mr. James P. O'Reilly, Director Serial No. 624A Office of Inspection and Enforcement
'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 October 16, 1981 in reference to the inspection conducted at North Anna Power Station between August 1, 1981 and September 5, 1981 and reported in IE Inspection Report Nos. 50-338/ 81-22 _' and 50-339/81-19.
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 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 yours, R. H. Leasburg Attachment City of Richmond
/7 (A Commonwealth of Virginia day of '7/ eta.,19 8/
Acknowledged before me this O. M *h Notary Public My_ Commission expires: 4 - 2 /.,192 f SEAL
.cc: Steven A. Varga, Chief Operating Reactors Branch No. 1 Division of Licensing 811216 0 t ly-]
Attechment Pzg2 1 RESPONSE TO NOTICE OF VIOLATION ITEMS REPORTED DURING NRC INSPECTION CONDUCTED FROM AUGUST 1 TO SEPTEMBER 5, 1981 IEIR 338/81-22-01 AND 339/81-19-01 NRC COMMENT A.
Technical Specification 3.5.4.2 requires that two independent channels of heat traced portions of the associated flow paths from the boron injection tank be operable. With only one channel operable, operation may continue for up to 30 days provided the tank and flow path temperatures are verified to be greater than or equal to 145 F at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
Contrary to the above, verification of operability for the two independent q5 channels were deficient in that during the period August 21, 1981 through September 2,1981, no objective evidence was available that indicated corrective action was taken to determine operability of the heat traced circuits on the flow path from the boron injection tank. During this period numerous low temperature alarms were received.
This is a Severity Level IV Violation (Supplement I.D.3).
RESPONSE
1.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION The Notice of Violation is correct as stated.
2.
REASONS FOR THE VIOLATION The heat tracing panels were monitored by Operations on a 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> period. When a channel indicated a low alarm, the operator noted the circuit number on the log sheet and was supposed to test the alarmed channel per 1-AR-33.
The annunciator response requires the operator to test the channel in question for the proper current demand.
If no amperage was indicated, the channel would be removed from service and the redundant channel glaced in service. The temperature would be assumed to be 145 F if the alarmed channel indgcatedthecorrectamperage. The alarm setpoint of approximate 1g 166 F provides a large band before the low temperature limit of 145 F is reached; therefore, a low temperature alarm does not necessarily mean that the temperature has dropped below the Tech. Spec. minimum.
3.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED Alarm setpoints for heat tracing channels required by Technical Specifications have been verified.
The Electrical Department is logging the heat tracing temperatures at least every eight hours for any channel required by Technical Specifi-cations that has a low temperature clarm.
If any monitoring thermocouple is 145 F, the Shif t Supervisor is notified and a maintenance request is s bmitted. The associated heat tracing channel is then removed from service and the redundant channel is energized.
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-Attechment PJg2 2 The corrective steps initiated are meeting or exceeding all surveillance requirements.
- 4.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS The corrective steps that have already been implemented will avoid further violations.
5.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance was achieved on September 4, 1981.
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Attschm;nt P;gn 3 NRC COMMENT B.
Technical Specifications 4.1.2.1.a, 4.1.2.2.a, and 4.5.4.2.b requires that spegified borated' flow path temperatures be verified to be greater than 145 F on a frequency of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, 7 days, or whenever it is a required water source.
Contrary to the above, the specified surveillances were not being conducted on Unit 1 or 2 until identified by the inspector on August 27, 1981.
This is a Severity Level IV Violation (Supplement I.D.3).
RESPONSE
1.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION The Notice of Violation is correct as stated.
2.
REASONS FOR THE VIOLATION The heat tracing panels for the specified borated water flow paths were being checked every four hours via the auxiliary building log 6D.
The low temperature alarms come in about 20 F above the minimum limit of 145 F.
The annunciator was used to verify that the heat trac-ing channel was above 145 F; however, the alarm setpoints are not calibrated on a periodic basis.
The surveillance of the borated water flow paths was being conducted in accordance with the Technical Specifications. The incongruity is in regard to the reliability of the low temperature alarm setpoints.
3.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED Alarm setpoints for heat tracing channels required by Technical Specifi-cations have been verified.
The Electrical Department is presently logging the heat tracing at least every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> for any channel required by the Technical Specifications that has a low temperature alarm.
In the event that a low alarm is received, the electrician will measure the e.tual temperature using the installed thermocouples.
This surveillance is adequately monitoring the required hect tracing circuits to verify that the flow path temperatures are greater than or equal to 145 F.
4.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS A procedure is being developed to periodically calibrate the heat trac-ing circuits high and low temperature alarms. This will enhance the re-liability of the surveillance technique that utilizes the low temperature alarm as a threshold temperature indicator.
5.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance will be achieved on or about December 15, 1981.
Attrchment
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P:gn 4 NRC COMMENT C.
Technical Specification 6.8.1.c requires that written procedures shall be established, implemented and maintained cove.ing surveillance and test activities of safety-related equipment.
Operating procedure 1-OP-27, Heat Tracing System, requires that only one heat tracing power supply circuit be energized at any given time.
Contrary to the above, measures to ensure written procedures were established, implemented, accomplished and maintained were deficient for those operations:
1.
Procedures were not established or implemented that covered surveillances per Technical Specifications 4.1.2.1.a, 4.1.2.2.a, and 4.5.4.2.b.
Applicable to Units 1 and 2.
2.
Procedures were not implemented that prevented four heat tracing distribution panels from having both the normal and redundant circuits energized at the same time.
Applicable to Unit 1.
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 surveillances requi. red by the Technical Specifications were covered by the auxiliary building log 6D.
This log and the associated annunciator response procedure were determined to be inadequate to meet the surveil-lance requirements due to improper implementation.
These procedures did not adequately assure that the boration flowpath temperatures were above 145 F.
3.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED Alarm setpoints for heat tracing channels required by Technical Specifica-tions have been verified.
A procedure was written and implemented to log the heat tracing circuit alarm status and record the actual temperature of any circuit indicating a low alarm. This procedure achieves the desired result of adequately covering the required surveillance.
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Attcchment Pcgs 5 s
i 4.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS l
A procedure to periodically calibrate the high and low temperature alarms on the heat tracing circuits will be implemented.
The temperature alarms will be able to provide reliable indication to verifg that the borated flowpath temperature is greater than or equal to 145 F.
Operating procedure 1-0P-27 requires that only one power supply circuit be energized at a time. Operations personnel will be reinstructed on the requirements of this procedure.
5.
DATE WHEN FULL COMPLIAl'CE WILL BE ACHIEVED Full compliance will be achieved on or about December 15, 1981.
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