ML20064G824

Responds to Violation Noted in Insp Repts 50-338/93-30 & 50-339/93-30.Corrective Actions:Justification for Continued Operation Developed Along W/Corresponding Safety Evaluation Supporting Current Condition of Components

ML20064G824
Person / Time
Site:	North Anna
Issue date:	03/11/1994
From:	Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
94-124, NUDOCS 9403170013
Download: ML20064G824 (4)

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VilfulNIA ell;CTHIC AND POWl?It COMi%NY H icit M ON D, Vil(UINI A 2026l March 11, 1994 U.S. Nuclear Regulatory Commission Serial No.94-124 Attention: Document Control Desk NAPS /JHUMAE R2 Washington, D.C. 20555 Docket No. 50-339 License No. NPF-7 Gentlemen:

VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNIT 2 INSPECTION REPORT NOS. 50-338/93-30 AND 50-339/93-30 REPLY TO A NOTICE OF VIOLATION We have reviewed your letter of February 17,1994, which referred to the inspection conducted at North Anna Power Station from December 19,1993 to January 21,1994, and the associated Notice of Violation which was reported in inspection Report Nos.

50-338/93-30 and 50-339/93-30. Our reply to the Notice of Violation is attached.

If you have any further questions, please contact us.

Very truly yours, o RE/L ky W. L. Stewart Senior Vice President - Nuclear Attachment cc: U.S. Nuclear Regulatory Commission Region 11 101 Marietta Street, N.W.

Suite 2900 Atlanta, Georgia 30323 Mr. R. D. McWhorter NRC Senior Resident inspector North Anna Power Station

.160C.?/

I 9403170013 940311 PDR ADOCK 0500o338 yd [vh Q PDR }.

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HEPLY TO A NOTICE OF VIOLATION l INSPECTION REPORT NOS, 50-338/93-30 AND 50-339/93-30 NRC COMMENT During an NRC inspection conducted on December 19, 1993 - January 21,1994,a violation of NRC requirements was identified. In accordance with the " General i Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violation is listed below:

10 CFR 50.55a(g) and TS 3.4.10.1 require that American Society of Mechanical Engineers (ASME) Code Class 1,2 and 3 components be subject to inservice inspection requirements delineated in Section XI of

' the ASME Boiler and Pressure Vessel Code.Section XI of the ASME Code paragraph IWA-5250,1986 Edition, requires that leakage detected at bolted connections during pressure tests be evaluated by removing the bolting and performing a VT-3 visual examination.

Contrary to the above, on January 6,1994, it was determined that leakage detected at seven bolted connections during pressure tests on September 29, October 3, and October 6,1993, was not evaluated by performing VT-3 visual examinations with the bolting removed.

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

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REPLY TO A NOTICE OF VIOLATION

1. REASON FOR THE VIOLATION The violation was caused by personnel failing to follow procedure. Periodic Tests (PT) 2-PT-48, Visual inspection of ASME XI Class 1 Pressure Boundary Components, and 2-PT-48.1, Visual Inspection of ASME XI Class 2 and 3 Pressure Boundary Components, were performed during the 1993 Unit 2 refueling outage to visually inspect ASME Class 1,2 and 3 pressure boundary components. Components-with indications of leakage were identified during the inspections and corrective maintenance was initiated. During the corrective '

maintenance process the required bolting replacements were not performed as specified by 2-PT-48,2-PT-48.1 and applicable work orders. This event was discovered during the preparation of the Unit 2 Refueling Outage NIS-1 Inservice inspection Report.

A lack of full understanding of the ASME Code requirements by maintenance personnel was also a contributing factor. In addition, a mechanism did not exist where the individuals responsible for identifying the failures ensured corrective actions were performed as required by the ASME Code.

2. CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED Upon discovery of the missed surveillance on January 6,1994, a station deviation report was submitted, and it was determined that the requirements of ASME Section XI had not been met. The NRC was promptly notified of the event.

A Justification for Continued Operation (JCO) was developed along with a corresponding safety evaluation supporting the current condition of the components.

An ASME Section XI Relief Request was submitted to the NRC on January 7, 1994 requesting relief from performing VT-3 examinations on the seven bolted connections that previously exhibited leakage until the next suitable outage to perform the examinations. Verbal approval of the relief request was granted by the NRC on January 7,1994.

Several contingency actions have been initiated to aid licensed operators in identifying increased leakage so it can be quickly dispositioned. The Periodic Test (PT) surveillance frequency for the Reactor Coolant System (RCS) leakrate determination has been increased and is being performed on a daily basis.

The daily PT performance will continue until the bolting is inspected or replaced during the next suitable outage. If the RCS unidentified leakrate exceeds 0.4-gallons per minute, then an investigation will be initiated to determine the source of leakage. A camera has been installed in the Volume Control Tank (VCT) cubicle to monitor potential leakage from the VCT manway. The VCT manway will be monitored once per 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shift. Operations management issued guidance to operations personnel on compensatory actions to be taken for the deviated bolting conditions.

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Mechanical planners have been instructed to contact Maintenance Engineering q for guidance when planning work orders for leaks on borated water systems to ensure the appropriate actions are taken to return the system to an operable status.

The Startup Assessment Plan has been revised to include an Engineering review of work orders on ASME XI bolt repair / replacement to ensure the proper  ;

inspections are completed prior to returning the unit to service following a  ;

refueling outage.

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3. CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS l Periodic Test (PT) Procedures PT-48 and PT-48.1 will be enhanced, by June 29,1994, to include which examination failure codes require VT-3 disposition.

Appropriate Maintenance Engineering personnel will be trained on the 4 enhancements to PT-48 and PT-48.1 by September 1,1994 (the start of the next outage where these examinations will have to be done). J A mechanism will be established, by October 14,1994, to ensure PT-48 and PT-48.1 are reviewed against associated work order packages prior to Mode 4  ;

entry to confirm the repair / replacement and/or VT-3 examinations have been l performed for identified failures. l Either replacement of bolting or performance of VT-3 examinations from which relief was requested will be performed during the next suitable outage which is expected to be the 1995 Unit 2 refueling outage.

4. THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance was achieved when NRC granted relief on January 7,1994 from the applicable ASME Section XI requirements.  ;

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