ML20066E679
| ML20066E679 | |
| Person / Time | |
|---|---|
| Site: | North Anna |
| Issue date: | 10/28/1982 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20066E673 | List: |
| References | |
| 579, NUDOCS 8211150384 | |
| Download: ML20066E679 (2) | |
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October 28, 1982 i
i Mr. James P. O'Reilly Serial No. 579 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 Atla.v:a, Georgia 30303 NPF-7
Dear Mr. O'Reilly:
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We have reviewed your letter of October 4,1982 in reference to the inspection conducted at North Anna Power Station between August 6 and September 5, 1982 i
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and reported in IE Inspection Report Nos. 50-338/82-29 and 50-339/82-29.
Our response to the specific infraction is attached.
We have determined that no proprietary information is contained in the reports.
Accordingly, the Virginia Electric and Power Company has no i
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.
4, Very truly yours, a
, b.
W. L. Stewart l
Attachment cc:
Mr. Robert A. Clark, Chief Operating Reactors Branch No. 3 Division of Licensing 4
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Attcchment Ssrici Na. 579 RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-338/82-29 AND 50-339/82-29 NRC COMMENT:
Technical Specification 4.7.8.1.e requires as a surveillance on the safeguards area, ventilation system (SAVA), that after every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of charcoal absorber operation a laboratory analysis of a representative carbon sample be obtained.
Contrary to the above, as of August 27, 1982, a representative carbon sample had not been taken af ter 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of operation on the charcoal absorbers.
Both trains of the system had been in operation for over 2800 hours0.0324 days <br />0.778 hours <br />0.00463 weeks <br />0.00107 months <br /> since the last test.
This is a Severity Level IV Violation (Supplement I.).
RESPONSE
(1) ADMISSION OR PENIAL OF THE ALLEGED VIOLATION:
The Notice of Violation is correct as stated.
(2) REASONS FOR VIOLATION:
The surveillance on the SAVS absorbers was missed due to a lack of administrative control. Laboratory analysis of the SAVS filter carbon is required by T.
S.
3.7.8.1 every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of filter operation and at least once every 18 months.
The 18 month surveillance of the charcoal filter was being performed when it was discovered that the filters had accumulated 2922 hours0.0338 days <br />0.812 hours <br />0.00483 weeks <br />0.00111 months <br /> and 2848 hours0.033 days <br />0.791 hours <br />0.00471 weeks <br />0.00108 months <br /> for I-HV-FL-3A and 3B respectively since the last test.
Timers on each filter record the integrated number of operating hours.
An inadequate administrative mechanism existed for initiating the surveillance every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of filter operation.
(3) CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:
A periodic test has been written and implemented to insure the charcoal filters are tested as often as necessary to comply with Technical Specification requirements. This test will calculate the number of hours available for the use of each filter until a lab analysis is necessary.
i (4) CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
No further actions are required.
(5) THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Full compliance has been achieved.
.