ML20071K918
| ML20071K918 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 04/08/1983 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20071K879 | List: |
| References | |
| 168, NUDOCS 8305270426 | |
| Download: ML20071K918 (4) | |
Text
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' ' VIRdiINIi -EtecritIC AND POWER COMPANY Hicnxoxn,V HOINIA 20261 33 APR 18 P I : 35 y., t, 3,,,,,,
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Apri1 8,
1983 I
i Mr. James P. O'Reilly Serial No. 168 Regional Administrator N0/JHL:aca Region II Docket Nos. 50-338 U. S. Nucicar Regulatory Commission 50-339 101 Marietta Street, Suite 2900 License Nos. NPF-4 Atlanta, Georgia 30303 NPF-7
Dear Mr. O'Reilly:
We have reviewed your letter of March 11, 1983 in reference to the inspection conducted at North Anna Power Station between November 6, 1982 and December 6, 1982 and reported in IE Inspection Report Nos. 50-338/82-39 and 50-339/82-39.
Our responses to the specific infractions are attached.
We have determined that no proprietary information 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 truly yours,
/
//t W. L. Stewart Attachment cc:
Mr. Robert A. Clark, Chief Operating Reactors Branch No. 3 Division of Licensing l
F305270426 830509 PDR ADOCK 05000338 0
9 Attcchment Pagn 1 Serial No. 168 RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-338/82-39 AND 50-339/82-39 A.
NRC COMMENT:
Technical Specifications 3.3.2.1 and 3.0.3 require two channels for automatic actuation of Engineered Safety Features (ESF) be operable with the plant in Mode 1, 2, 3, or 4 or the plant be placed in hot shutdown within seven hours and cold shutdown in the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
Contrary to the above, on December 5-6, 1982, following a trip and safety injection, neither train of the automatic ESF actuation systems were operable for 22.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> with the plant remaining in Mode 3.
This is a Severity Level IV Violation (Supplement I), and applies to Unit 1 only.
RESPONSE
(1) ADMISSION OR DENIAL OF THE ALLEGED VIOLATION:
The Notice of Violation is correct as stated.
(2) REASONS FOR VIOLATION:
Blocking of the automatic safety injection (SI) signals by actuation of the manual SI reset pushbuttons on the main control board is a design feature described on pages 7.3-3, 7.3-17 and 7.3-18 of the UFSAR.
The automatic safety injection block feature of the protection system is a necessary design feature.
Without the automatic safety injection block, operators would be unable to control safety equipment and secure from a safety injection event.
Blocking automatic safety injection signals by pushing the SI reset pushbuttons on the main control board is the first deliberate operator action taken following an SI event to return ESF equipment to the non-safety-feature mode or realign ESF equipment.
The automatic SI block is reset when the reactor trip breakers are reclosed.
The Technical Specifications do not specifically address the block of both trnins of automatic SI which occurs during a safety inj ection event.
Because the Action Statement associated with Technical Specification 3.3.2.1, the LCO requiring two trains of automatic SI to be operable during Mode 1,
2, 3 and 4 operation, only addresses the inoperability of a single train of automatic SI, the actions specified in Technical Specification 3.0.3 must be taken following a safety injection event.
Technical Specification 3.0.3 states that when an LCO and its associated Action Statement cannot be met, the Unit must be placed in HOT STANDBY within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, HOT SHUTDOWN within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and COLD SHUTDOWN within the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
Attechnent Pegs 2 Serial No. 168 On December 5, 1982 during an inadvertent safety injection event, the automatic safety injection block was " set".
The operatora, apprehensive that another inadvertent automatic SI signal could be generatad from an ongoing. instrumentation problem (two inoperable steam flow channels had been placed in trip and all that'was needed for an SI signal was a low
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RCS Tavg input), decided not to immediately reset the automatic SI block.
The Safety Inj ection Emergency Procedure, 1-EP-5, incorrectly implied l
that the Technical Specifications required the automatic SI block to be reset within 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> af ter safety injection initiation.
The procedural error was not discovered until 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> af ter the SI event. The automatic SI block was immediately reset.after the error was discovered.
Investigation revealed that the procedure had been correct prior to August 5,
1980.
On August 5,
1980 a change to Technical Specification 3.0.3 was made.
It appears that 1-EP-5 was not updated to reflect the new requirements of Technical Specification 3.0.3.
Throughout the event.the operators had been misled by 1-EP-5 and believed that they were in full compliance with the Technical Specifications.
Throughout the event the operators knew that the RCS was borated to Cold Shutdown (uncontrolled cooldown reactivity protection) and were ready to 4
manually initiate SI if required.
(3) CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:
All applicable emergency procedures were revised: to reflect current Technical Specification 3.0.3 requirements.
(4) CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FUR'HER VIOLATIONS:
The corrective steps already taken should prevent further violations.
(5) THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Full compliance has been achieved.
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Serial No. 168
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RESIONSE TO-NOTICE OF VIOLATION i
9' INSPECTION" REPORT NOS. 50-338/82-39 AND 50-339182-39 3
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Technical Specifications \\ 4.3.1.1.1 requires that each reactor trip system instrumentation channel shall be demonstrated operable \\ by the mo'nibly performance of the Chant.el Functional Test.
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1 Contrary to the above, as of December 6,
1982, the
- sus',e%11ance channel functional tests for power range nuclear instrt3efits we'rA not performed for the last 42 days.
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This is a Severity Level IV Violation (Supplement I) and applies to Unit 2
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RESPONSE:_
(1) ADMIS51 b OR DENIAL OF THE ALLEGED VIOLATION:
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The Notice of Violation is' correct as stated.
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4 This infraction was the result of an administrative error. The procedureTm 5 ms i was scheduled by Engineering to be performed within the norma 131 day #
period.
The monthly surveillance tests were assigned by the.
Instrumentation Supervisor.
At " a later
- time, the schedule. wasl inadvertently. marked to. indicate that the tests were completed when theyz A
had, not actually been performed.
The Engineering Review Group cleo failed to identify the missed surveillance. AQCreviewdiscovered(that i
the tests were missing.
(3) CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:
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l When the completed copies of the surveillance tests could not3be found, y,
an investigation to find the tests was begun.
The Instrument. Departmenth ' ',
immediately ctarted the required functional tests in the event that t{ e
~ procedures had snot been performed.
The NRC Resident Inspector was notified of the situation.
The investigation discovered that tfie'teste' "e
had not been performed. While the investigation was being cdadEcted, thet surveillance tests were completed satisfactorily.
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t (4) CORRECTIVE STEPS WHICH WILL BE TAKEN70 AVOID FURTHER VIOLiTIONS;",
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)t The Administrative Control Program for Periodic ~ Tesi:inQis being evaluated to determine if any changes re, required.
,7, N $ i-(5) THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
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Full compliance will be achieved by June 1, 1983.
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