ML20064C417

Forwards Supplemental Response to NRC Re Violations Noted in IE Insp Repts 50-338/82-25 & 50-339/82-25.Corrective Actions:Procedures W/Valve line-up Sheet & Sys Sketch Initiated & Drawings Annotated

ML20064C417
Person / Time
Site:	North Anna
Issue date:	12/14/1982
From:	Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20064C381	List: ML20064C417 ML20064C457 ML20064C486
References
486B, NUDOCS 8301040396
Download: ML20064C417 (4)

Text

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VIRGINIA ELECTRIC AND POwen COMPANY RicnwoNu, VIRGINIA 23261

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W.L.STRWART Ysca Pos.aps.T December 14, 1982

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Mr. James P. O'Reilly Serial No. 486B Regional Administrator N0/RMT:acm Region II Docket Nos. 50-338 U. S. Nuclear Regulatory Commission 50-339 101 Marietta Street, Suite 3100 License Nos. NPF-4 Atlanta, Georgia 30303 NPF-7

Dear Sir:

Enclosed please find a supplemental response to our responses to your Reports of Inspection Results numbers 50-338/82-25 and 50-339/82-25.

The enclosed response includes our schedules for completion of the proposed corrective actions.

Very truly yours, s

W. L. Stewart Enclosure l

cc:

Mr. Robert A. Clark, Chief Operating Reactors Branch No. 3 Division of Licensing 83010403% B21227 PDR ADOCK 05000338 i

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I ENCLOSURE SERIAL NO.486B NRC COMMENT:

TECHNICAL SPECIFICATION 6.8.1 REQUIRES THAT WRITTEN PROCEDURES SHALL BE ESTABLISHED, IMPLEMENTED, AND MAINTAINED FOR SAFETY-RELATED SYSTEMS.

CONTRARY TO THE ABOVE, AS OF MAY 24, 1982 WRITTEN PROCEDURES OR VALVE LINE-UP SHEETS WERE NOT PROVIDED FOR THE OVERPRESSURE PROTECTION SYSTEM.

THIS WAS A CONTRIBUTING FACTOR TO THE EVENT OF MAY 22, 1982, IN WHICH BOTH TRAINS OF THE OVERPRESSURE PROTECTION SYSTEM WERE INOPERABLE WHEN REQUIRED BY TECHNICAL SPECIFICATIONS TO BE OPERABLE.

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 THIS INFRACTION WAS THE RESULT OF AN ADMINISTRATIVE ERROR. THE REPRES-SURIZATION OF THE PORV NITROGEN SYSTEM INVOLVED THE OPENING AND CLOSING OF A SINGLE VALVE. DUE TO THE SIMPLICITY OF THIS OPERATION, A SPECIFIC PROCEDURE FOR THE REPRESSURIZATION WAS NOT CONSIDERED NECESSARY. IN RETROSPECT, DUE TO THE CONFUSING LAYOUT OF THE SYSTEM AND THE PROXIMITY OF OTHER VALVES WHICH COULD DISABLE THE SYSTEM IF CLOSED, A PROCEDURE WITH AN ACCURATE SKETCH SHOULD HAVE BEEN DEVELOPED.

3.

CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED A PROCEDURE WITH A VALVE LINE UP SHEET AND A SYSTEM SKETCH AS AN ATTACHMENT HAS BEEN PROVIDED. THIS PROCEDURE (I-OP-24.2) COVERS THE NORMAL REPRESSURIZATION EVOLUTION AND THE INITIAL SYSTEM CONFIGURATION.

THIS IS A COMMON PROCEDURE FOR BOTH UNITS. IN ADDITION, THE VALVES IN QUESTION HAVE HAD NUMBERS ASSIGNED.

IN ORDER TO UPGRADE THE NITROGEN SYSTEM TO THE PORV'S AND TO IMPROVE OVERALL SYSTEM OPERABILITY, THE FOLLOWING ACTIONS HAVE BEEN TAKEN:

1.

SOFT SEATS HAVE BEEN PURCHASED FOR INSTALLATION IN THE NITROGEN SYSTEM RELIEF VALVES TO PREVENT SEAT LEAKAGE.

j 2.

A SETPOINT CHANGE THAT INCREASES THE LOW NITROGEN PRESSURE ALARM l

SETPOINT FOR THE CONTROL ROOM ANNUNCIATOR HAS BEEN COMPLETED. THIS i

WILL ALLOW TIME FOR OPERATOR RESPONSE PRIOR TO ENTERING THE T.S.

3.4.9.3 ACTION STATEMENT.

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ENCLOSURE SERIAL NO.486B

4. CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATION THE CORRECTIVE STEPS TAKEN SHOULD PREVENT RECURRENCE OF THIS PARTICULAR EVENT. IN ORDER TO PRECLUDE SIMILAR EVENTS FROM OCCURRING IN OTHER SYS-TEMS AND TO BETTER MANAGE THE CONTROL OF PROCEDURAL GUIDANCE OF OPERA-TION EVOLUTIONS, OPERATIONS PERSONNEL HAVE BEEN SURVEYED TO IDENTIFY ANY OTHER SYSTEM OPERATIONS WHERE NEW OR ADDITIONAL CONTROLS WOULD BE ADVISABLE.

5. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED A.

THE PROCEDURE WITH A SYSTEM SKETCH HAS BEEN DEVELOPED AND ISSUED FOR USE ON JUNE 7, 1982.

B.

THE REQUEST FOR INPUT FROM OPERATIONS PERSONNEL HAS BEEN MADE.

C.

VALVE IDENTIFICATION TAGS HAVE BEEN PLACED ON THE UNIT 1 SYSTEM VALVES. THE TAGS WILL BE PLACED ON UNIT 2 DURING THE NEXT MODE 5 OUTAGE OF SUFFICIENT DURATION.

D.

SOFT SEAT PACKAGES FOR THE RELIEF VALVES HAVE BEEN INSTALLED IN THE UNIT 1 VALVES. THE SEATS WILL BE INSTALLED IN THE UNIT 2 VALVES DURING THE NEXT MODE 5 OUTAGE OF SUFFICIENT DURATION.

E.

A LIQUID NITROGEN SYSTEM HAS BEEN PURCHASED AND INSTALLED.

NRC COMMENT:

10 CFR 50. APPENDIX B, CRITERION VI AND THE ACCEPTED VEPCO QA PROGRAM SECTION 17.2.6 REQUIRES THAT MEASURES BE ESTABLISHED TO CONTROL THE ISSUANCE OF DOCUMENTS AND CHANGES THERETO WHICH PRESCRIBE ACTIVITIES AFFECTING SAFETY. THESE MEASURES SHALL ENSURE THAT DOCUMENTS, INCLUD-ING CHANGES, ARE REVIEWED FOR ADEQUACY.

CONTRARY TO THE ABOVE, WHEN OVERPRESSURE PROTECTION SYSTEM PIPING DRAWING 11715-FM-205A-10 WAS PREVIOUSLY REVISED, THE NITROGEN RESERVOIR ISOLATION VALVES WERE ERRONEOUSLY OMITTED FROM THE DRAWING.

THIS RESULTED IN AN INACCURATE CONTROL DRAWING BEING IN USE IN THE CONTROL ROOM ON MAY 2, 1982.

THIS IS A SEVERITY LEVEL V VIOLATION (SUPPLEMENT I.).

RESPONSE

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l. ADMISSION OR DENIAL OF THE ALLEGED VIOLATION THE NOTICE OF VIOLATION IS CORRECT AS STATED.

2.

REASONS FOR THE VIOLATION THIS INFRACTION WAS THE RESULT OF AN ADMINISTRATIVE ERROR. THE DRAWING i

THAT DESCRIBES THIS SYSTEM WAS TAKEN FROM THE DESIGN CHANGE DRAWINGS

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WHICH DID INCLUDE THE VALVES IN QUESTION. THEREFORE, THE OMISSION WAS l

NOT NOTICED DUE TO THE UNUSUAL LOCATION OF THE VALVE AND DIFFICULTY l

IN TRACING THE PIPING CONFIGURATION. IN ADDITION, THE PLACEMENT OF l

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ENCLOSURE SERIAL NO.486B IDENTIFICATION TAGS ON THESE VALVES WAS NOT REQUIRED BY THE DESIGN DOCUMENTS. THIS MADE THE CORRECTION OF THE DRAWING TO THE ACTUAL PIPING ARRANGEMENT DIFFICULT.

3.

CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED AN IMMEDIATE DRAWING ANNOTATION WAS MADE TO THE CONTROL ROOM DRAWINGS AS PER THE ENGINEERING ADMINISTRATIVE PROCEDURE DC 2.

IN ADDITION, AN ENGINEERING WORK REQUEST WAS SUBMITTED FOR THE REVISION OF THE DRAWINGS.

THE DRAWING 11715-FM-105A HAS BEEN REVISED (REVISION 11 DATED JUNE 25, 1982) AND ISSUED AS A CONTROLLED DRAWING REVISION. IN ADDITION, THE REVISED DRAWING SHOWS THE NEWLY ASSIGNED VALVE NUMBERS.

4.

CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATION A RECENT RENOVATION OF THE DRAWING CONTROL PROGRAM HAS INCREASED THE ADMINISTRATIVE CONTROL OF DRAWINGS AND DRAWING REVISIONS. THESE ACTIONS SHOULD PRECLUDE FURTHER VIOLATIONS OF THIS TYPE. IN ORDER TO INCREASE THE CONFIDENCE IN THE ACCURACY OF EXISTING DRAWINGS, PARTICULARLY FLOW DIAGRAMS AND VALVE OPERATING DRAWINGS, THE IMPORTANCE OF IDENTIFYING AND REPORTING ERRORS ON STATION DRAWINGS THAT ARE DISCOVERED DURING THE PER-FORMANCE OF THEIR JOB HAS BEEN REEMPHASIZED TO ALL OPERATIONS PERSONNEL.

5. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED THE SYSTEM DRAWING IN QUESTION HAS BEEN REVISED. THE IMPORTANCE OF TDENTIFYING AND REPORTING DRAWING ERRORS HAS BEEN REEMPHASIZED TO OPERATIONS PERSONNEL. THIS WILL BE A CONTINUING EFFORT.

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