ML20070D976

Responds to NRC Re Violations Noted in Insp Rept 50-338/94-10 & 50-339/94-10.Corrective Action:Containment Hydrogen Analyzer Calibration Procedure Has Been Modified

ML20070D976
Person / Time
Site:	North Anna
Issue date:	07/05/1994
From:	Ohanlon J VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
94-374, NUDOCS 9407130244
Download: ML20070D976 (3)

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1 VIltOINIA ELECTlfl0 AND Powen COMI'ANY lllCII M OND, VI HOINI A 2112 61 1

July C, 1994 l

l U.S. Nuclear Regulatory Commission Serial No.94-374 Attention: Document Control Desk NAPS /MPW/MAE R5 '

Washington, D.C. 20555 Docket Nos. 50-338 50-339 License Nos. NPF-4 NPF-7 Gentlemen:

VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNITG 1 and 2 INSPECTION REPORT NOS. 50-338/94-10 AND- 50-339/94-10 REPLY TO A NOTICE OF VIOLATION We.have reviewed your letter of June 9,1994, which referred to the inspection conducted at North Anna Power Station from April 17,1994 to May 21,1994, and the associated Notice of Violation which was reported in Inspection Report Nos. 50-338/94-10 and 50-339/94-10. Our reply to the Notice of Violation is attached, if you have any further questions, please contact us.

Very truly yours, J. P. O'Hanlon t

Senior Vice President - Nuclear Attachment cc: U.S. Nuclear Regulatory Commission Region ll 101 Marietta Street, N.W.

Suite 2900 Atlanta, Georgia 30323 Mr. R. D. McWhorter NRC Senior Resident inspector North Anna Power Station 94o713o244 94o7o5 8

{DR ADOCK 05o00339 j PDR .

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_ REPLY TO A NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-338/94-10 AND 50-339/94-10 NRC COMMENT l During an NRC inspection conducted from April 17,1994 - May 21,1994, a violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violation is listed below:

Unit 1 and UM: ?. Technical Specification Limiting Condition for l

Operation 3.6.4.1 mquires that two independent hydrogen analyzers (shared with the otnar unit) shall be OPERABLE. Action statement "a" requires with one hydrogen analyzer inoperable,19 store the inoperable analyzer to OPERABLE status within 30 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

Contrary to the above, hydrogen analyzer 1-HC-H2 A-101 was inoperable from February 4,1994, to April 26, 1994, without imp ementing the requirements of the action statement.

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 mechanical failure of the hydrogen analyzer sample fitting resulting in an inoperable analyzer. Continued removal and recoupling of the sample fitting, during each quarterly calibration, resulted in a connection that did not seal properly when reinstalled using normal methods and established procedure. The leakage was sufficient to render the analyzer inoperable since under design basis conditions following a return to sub-atmospheric conditions, the actual hydrogen sample would have been significantly diluted. Therefore, the analyzer was inoperable for greater than the time limits specified in the Technical Specification.

2. CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED Subsequent to identification of the leak, testing was performed to quantify the fitting leakage and to assess the consequences had a design basis accident occurrcd. After quantifying the leakage and adding it to the current leakrate values for both units, the resultant total leakrate would still be within the requirements of the Technical Specifications.

The containment hydrogen analyzer sample fitting was further tightened and the leak stopped. The leak test of the Unit 1 containment atmosphere clean-up system was completed and the seven day Technical Specification action cleared. A station work order has been issued to replace the fitting during the next calibration of the Unit 1 containment hydrogen analyzer. The Unit 2 containment hydrogen analyzer leak check was completed satisfactorily on April 26,1994.

3. CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS The containment hydrogen analyzer calibration procedure has been modified so that the sample line fittings will not have to be routinely disconnected to provide a flow path for the sample pump during quarterly calibrations. Existing vent taps in the containment atmospheric clean up system will be used for this purpose. This procedure also performs a leak test on any fittings or components manipulated during testing.

4. THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance was achieved when the fitting leakage was stopped and the Technical Specification seven day Limiting Condition for Operation exited.

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