ML20064A520

Responds to NRC Re Violations Noted in Insp Repts 50-338/90-15 & 50-339/90-15.Corrective Actions:Procedures Revised to Include Tolerance Bands for Temp Control Switch Setpoints & Involved Personnel Counseled

ML20064A520
Person / Time
Site:	North Anna
Issue date:	09/07/1990
From:	Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
90-539, NUDOCS 9009140044
Download: ML20064A520 (4)

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' Y1MGINIA ELECTNIC AND POWER COMPANY R ICH M O N D,Yl MOINI A 2152 61 September 7,1990 United States Nuclear Regulatory Commission Serial No.:

90-539 Attention: Document Control Desk NAPS /JHL R0 Washington, D.C. 20555 Docket Nos.:

50-338 50-339 License Nos.:

NPF 4 NPF 7 Gentlemen:

g VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNITS 1 AND 2 NRC INSPECTION REPORT NOS. 50-338/90-15. AND 50-339/90-15 RESPONSE TO THE NOTICE OF VIOLATION We have reviewed your letter dated August 10,1990, which refers to the inspection-conducted at North Anna from May 16,1990 through July 14,1990 and reported in' Inspection Report Nos. 50 338/90-15 and 50 339/9015. Our response to the Notice of Violation is attached, if you have any further questions, please contact us.

Very truly you,

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W. L. Stejv rt Senior Vice President - Nuclear o

Attachment cci U. S. Nuclear Regulatory Commission Region ll 101 Marietta Street, N. W.

Suite 2900 Atlanta, Georgia 30323

. Mr. M. S. Lesser NRC Senior Resident inspector North Anna Power Station 0 ? i C ',

f 9009140044 900907 PDR ADDCK 050003*30

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RESPONSE TO THE' NOTICE OF VIOLATION L,i REPORTED DURING THE NRC INSPECTION CONDUCTED l

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BETWEEN MAY 28. 1990 AND JULY 14. 1990 INSPECTION REPORT NOS. 50 338/90-15 AND 50-339/90-15 l

NRC COMMENT j

.During the Nuclear Regulatory Commission (NRC) inspection conducted May 26 - July.

14,1990, a violation of NRC requirements was identified. In'accordance with the 1

" General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR-i Part 2, Appendix C (1990), the violation is listed below:

Technical Specification 6.8.1 requires that written procedures be: established.:

Implemented and maintained covering the activities referenced in Appendix "A".of Regulatory Guide 1.33, Revision 2, February 1978. Calibration and Maintenance-l~

procedures are referenced in Regulatory Guide 1.33.

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- Contra"<Lto the above,. procedures were not followed. or were inadequate as f

evidenced by the following:

1.

ICP-P MI-3 (sic), Miscellaneous Safety Related Instruments, specifies in Section 1.0 that its. purpose is to. provide instructions to calibrate any instrument j

provided the instrument is not Environmentally Oualified.(EO).' On June 26, 1990, the procedure was not followed in that it was used to calibrate the Unit 2 1

hydrogen _ analyzer, which is EO.

It was subsequently. identified that the l

procedure has also been used to calibrate the Unit 1: hydrogen analyzer the i

previous week.

2.

ICP-P-1 MI 3 was Inadequate in that acceptance criteria for calibrating the temperature control switch and the low temperature alarm failed to specify.

tolerance bands or specified incorrect tolerance bands for required setpoints, 3.

Maintenance Depaitment : Administrative Procedure 0002, Conduct 1of

. Maintenance, Section 6.3.4 requires that maintenance activities affecting safety-:

related equipment shall be performed using only controlled vendor manuals.

On June 26,1990, the procedure was not followed in that calibration activities

.were performed on the safety related Unit 2 hydrogen analyzer, using i

uncontrolled reference material for determining instrument setpoints.

This is a Severity Level IV Violation (Supplement 1).

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" RESPONSE TO THE NOTICE OF VIOLATION i

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ADMISSION OR DENIAL OF THE ALLEGED VIOLATION o

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The violation is correct as stated.

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REASON FOR THE VIOLATION The violation was caused by the failure of personnel, both supervisory and craft,-

. to follow procedures.

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Personnel also failed to follow procedures by using an uncontrolled vendor technical manual to perform maintenance on the Unit 2 hydrogen analyzer. - A l

copy of Surry's controlled vendor manual, " Operation Manual For l'-111 j

Containment Hydrogen Monitor", the same model as used at North Anna, was obtained. However, the administrative processing to incorporate the manual into the North Anna Controlled Vendor Manual Program was not completed prior to use in_the field.

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CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE D

PtESULTS ACHIEVED i

Evaluations were performed by both I & C and Engineering and it was -

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determined that the calibrations on the hydrogen analyzers were acceptable.

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A copy ' of the hydrogen analyzer vendor. tech'nical manual has been

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incorporated into the controlled vendor manual program.

Instrument Calibration Procedure ICP P 1-MI-3 was revised to include in the initial conditions that it be verified.that the instrument being calibrated is not environmentally qualified and that it is not covered by another calibration 1

procedure.

ICP-P-1-MI 3 will not be used for calibrating the hydrogen

- analyzers.

Personnel involved were counselled on the importance.of compliance with' I

1 procedures.

Instrument Department Supervisors have been made more sensitive to the need for procedure compliance.

t The more appropriate EO procedures (ICP-HC 1 H2A-101 and ICP-HC-2-H2A-201 " Containment. Hydrogen System Reactor Containment Hydrogen Analyzer") were revised to include tolerance bands for the temperature control C

switch setpoints.

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Periodic OA Performance Based Assessments of maintenance (including iu Instrumentation) activities have not identified any additional examples of using L

. Incorrect procedures on EQ or safety related equipment.

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CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS

.J No specific additional actions required. However, three ongoing programs.

4 Procedure Upgrade, Vendor Manual Upgrade and Internal Self Assessment will j

further strengthen the meJntenance process.

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THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED j

I Full compliance has been achieved.

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