ML20064C486

Responds to NRC Re Violations Noted in IE Insp Repts 50-338/82-25 & 50-339/82-25.Corrective Actions: Operations Personnel Will Be Surveyed to Identify Any Other Sys Operations Where Addl Controls Would Be Advisable

ML20064C486
Person / Time
Site:	North Anna
Issue date:	09/03/1982
From:	Leasburg R 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
486, NUDOCS 8301040410
Download: ML20064C486 (4)

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vic. p......., September 3, 1982 Noca.. A. Op..Arno.o Mr. James P. O'Reilly Serial No. 486 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 Mr. O'Reilly:

We have reviewed your letter of August 6, 1982 in reference to the inspection i conducted at North Anna Power Station between May 24 and June 5, 1982 and reported in IE Inspection Report Nos. 50-338/82-25 and 50-339/82-25. Our responses to the specific infractions are attached.

We have determined that no proprietary infc mation 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 tru y yours, j R. H. Leasburg i

l Attachment a cc: Mr. Robert A. Clark, Chief Operating Reactors Branch No. 3 Division of Licensing t

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8301040410 821227 PDR ADOCK 05000338 G PDR i

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.Attcchment

. Pcge.1 Serial No. 486 i

RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-338/82-25 AND 50-339/82-25

. 1 A. NRC COMMENT: .

Technical Specification 6.8.1 requires that written procedures shall be [' H i established, implemented, and maintained for isafety-related systems. sx 3l ;

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Contrary to the above, as of May 24, 1982 written procedure.s or. valve line-up _i sheets were not provided for the overpressure protectior. system. This was a 4 contributing factor to the event of May 22, 1982, in which both trains of the overpressure protection system were inoperable when required by Technical e Specifications to be operable. } q' t ,

This is a Severity level IV Violation (Suppleneit I.).

4 RESPONSE: .

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(1) ADMISSION OR DENIAL OF THE ALLEGED VIOLATION:

The Notice of Violation is correct as stated. '

(2) REASONS FOR VIOLATION:

This infraction was the reruit of an administrative error. The repressurization of the PORV nitrogen system . involved the opening and closing of a single valve. Due to the sidplief ty of this operation, a 1 specific procedure for the repressurization was-not considered necessary.

l In retrospect, due to the confusing ley ' cut of the system and the l

proximity of other valves which could, disable the systere if closed, a procedure with an accurate sketch should have been developed.

(3) CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:

A procedure with a valve line up sheet as an attachment has been provided. This procedure (1-0P-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.

(4) CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:

The corrective steps taken should prevent recurrence of this particular event. In order to preclude similar events from occurring in other systems and to better manage the control of procedural guidance of

operating evolutions, Operations Personnel will be surveyed to identify

[ any other system operations where new or additional controls would be l advisable. When this response is received, the existing procedures will be reviewed or new procedures develcped that will providc the necessary control. This will be a continuing effort.

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l Att chment

. - P:g3 2 Serial No. 486 l (5) THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

The procedure and valve line up sheet has been developed and was issued for use on June 7,1982. The request for input from Operations Personnel will be completed by September 15, 1982. The numbered tags will be l placed on the Unit 1 valves during the current Unit 1 outage and on the j Unit 2 valves during the next Unit 2 Mode 5 outage. )

l B. NRC COMMENT:  ;

10 CFR 50, Appendix B, Criterion VI and the accepted VEPCO QA program section 17.2.6 requires that measures be entablished to control the issuance of documents and changes thereto which prescribe activities affecting safety.

These measures shall ensure that documents, including changes, are reviewed for adequacy.

Contrary to the above, when overpressure protection system piping drawing 11715-FM-105A-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 22, 1982.

This is a Severity level V Violation (Supplement I.).

RESPONSE

(1) ADMISSION OR DENIAL OF THE ALLEGED VIOLATION:

The Notice of Violation is correct as stated.

(2) , REASONS FOR VIOLATION:

This infraction was the result of an administrative error. The drawing that describes this system was taken from the design change drawings whicF did include the valves in question. Therefore, the omission of these valves was a transcription error made by contracted drawing revisiod services. This omission was not noticed due to the unusual

' location of the valve and difficulty in tracing the piping configuration.

s In addition, the placement of 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) CORR 2CTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:

An immediate drawing annotation was made to the Control Room drawings as per the Engineering Administrative Procedure DC 2. In addition, an Engineer'ng Work Request was submitted for the revision of the drawings.

The drawing 1171 ? -105A has been revised (revision 11 dated June 25, t

1982) and issuec p a controlled drawing revision. In addition, the

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revised drawing shows the newly assigned valve numbers.

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Att chment

. Prgo 3 Serial No. 486 (4) CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:

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 errors on station drawings that are discovered during the performance of their job will be reemphasized to all Operations Personnel.

(5) THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

The system drawing in question has been revised. The request for input from Operations Personnel will be completed by September 15, 1982. This will be a continuing effort.

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