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 ',

9009140044 900907 f

PDR ADDCK 050003*30 / I' s G Pitu ' \- ,

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

[ 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-procedures are referenced in Regulatory Guide 1.33.

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L - 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). ;l i

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,; " RESPONSE TO THE NOTICE OF VIOLATION ,

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1. ADMISSION OR DENIAL OF THE ALLEGED VIOLATION .;

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The violation is correct as stated.  !

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

. to follow procedures. j w -

3 Personnel also failed to follow procedures by using an uncontrolled vendor l 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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'3. CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE D PtESULTS ACHIEVED i

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

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 ~

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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, ' 'y!4. CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER }-

VIOLATIONS

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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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! 5. THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED j I

Full compliance has been achieved. l i

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