ML20073L680
| ML20073L680 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 05/10/1991 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 91-222, NUDOCS 9105140065 | |
| Download: ML20073L680 (7) | |
Text
I
\\
Viisuixir lb.1:rutw A s s> l'ows::
('i nt eA s y Hirnunoe.Vissuixar enes :
May 10, 1991 U.S. Nuclear Regulatory Commission Serial No.
91 222 Attn: Document Control Desk NAPS /JHLR2 Washington, D.C. 20555 Docket Nos. 50-338 50 339 License Nos. NPF 4 NPF 7 Gentlemen:
YJHGlHlA __ ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATIOB UNITS 1 AND 2 INSPECTION REPORT NOS. 50 338/9106 AND 50 339/9106 RESPONSES TO THE NOTICES OF VIOLATION We have reviewed your letter of April 12,1991 which referred to the inspection conducted at North Anna from February 17,1991 - March 16,1991 and reported in Inspection Repor1 Nos. 50 338/9106 cnd 50 339/9106.
In your cover letter, you expressed concerns regarding each of the three violations in terms of inadequate corrective actions, personnel errors and proceduralinadequacies. As part of the management review for those violations, it appears that a common thread in the violations is the implementation of existing programs, in each of the three events cited, genere'ly effective programs were already in place. Had those programs been adequately implemented, it is our judgment that the violations would not have occurred. Program implementation and effectiveness of corrective actions are an integral part of Quality Assurance and Corporate Nuclear Safety's assessments and will be specifically addressed in future assessments.
Virginia Electric and Power Company continues to emphasize the importance of attention to detail. The Self Check Program, the Nuclear Safety Policy, and the Nuclear Monthly Newsletter are but a few examples of ongoing efforts by management to emphasize the need for individuals to be accountable for their activities and the need to attend to the details in every activity affecting nuclear safety. Attention to detailis an integral part of our nuclear safety philosophy and will continue to receive the highest levels of management attention.
Our responses to the specific Notices of Violation are attached.
I l
Very truly yours, II kd 9 %d W. L. Stewart Senior Vice President Nuclear fg/})l n owon,,
'y m a o.x.oo w FDR
/
a Attachment cc: U. S. Nuclear Regulatoif Commission 101 Marietta Street, N.W.
Suite 2900 Atlanta, Georgia 30323 Mr. M. S. Lesser NRC Senior Resident inspector North Anna Power Station i
l 1
l._.,__....,.___________._...,.,.._,._...~..__._..._.....
i NOV 50 338&339/9106 11ESEQUSE_IQ_IHE_fJQJ1CE OF V10LAILOR R E P ORIED_QUR11LG _THE_11B C._lN SPECIl0lLCORDilCIE R DETWEEN FEBRUARY 17. 1991 AND MARCH 16. 1991 INSPECTION REFORT NOS. 50038/9106. AND 50 u91 & QA
~
URC COMMENI Dt ring an NRC inspection conducted between the period of February 17 through March 16, 1991, violations of NRC requirements were Identified.
In accordance with the
- General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, A,.pendix C, (1990), the violations are listed below:
A.
Technical Specification 3.11.2.5 requires the concentration of oxygen in the waste gas decay tanks be limited to less than or equal to 2 percent whenever the hydrogen concentration is between 4 and 96 percent. With the concentration of oxygen greater than 2 percent but less than 4 percent, reduce the oxygen concentration to the above limits within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. With the concentration of oxygen greater than 4 percent, immediately suspend all additions of waste gas to the system and reduce the concentration of oxygen to less than or equal to 2 percent without dolay.
10 CFR 50, Appendix B, Criterion XVI as implemented by Operational Quality Assurance Program Topical Report (VEP 15A) requires in part that measures be established to assure that conditions adverse to quality such as deviations and nonconformances are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.
Contrary to the above, corrective action, initiated in response to Ouality Assurance finding N 90 03 02 of February 23,1990 involving an explosive gas mixture in a waste gas decay tank, was ineffective and failed to preclude repetition. Althou0h 4
corrective action was completed on November 1,1990, a similar event occurred on March 5,1991, where a waste gas decay tank with oxygen concentration of 2.3 percent was not reduced to less than or equal to 2 percent within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.
This is a Severity Level IV violation (Supplement 1).
B.
Technical Specification 6.8.1 requires that writien procedures be implemented covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Included in Appendix A of Regulatory Guide 1.33 are procedures for performing maintenance and surveillances.
Contrary to the above, procedures were not followed or used as evidenced by the following examples:
1.
Maintenance Procedure 0 ECM 170101, dated January 10, 1991 Troublerhooting and Reoair of the Personnel Airlock Electrical System, is required to be used to provide instructions for troubleshooting, repairing and replacing components of the personnel airlock electrical system. Virginia Power Administrative Procedure (VPAP) 2002, Work Requests and Work Orders, dated July 1,1990, paragraph 6.4, requires b Troubleshooting Pre Job Review Sheet and Instruction form be completed for troubleshooting activities. VPAP 2002, paragraph 6.4, requires the determination of the "as
~
l NOV 50 3388339/91-00 found" condition of a failed component requiring corrective maintenance and i
i recordin0 on the work request, the work actually performed. 0 ECM 1701-01 and VPAP 2002 were not adequately implemented, in that on March 9, 1991 fol lowing the failure of an interlock on the personnel airlock provided by limit switch LS 7, troubleshooting activities were conducted on the personnel airlock outer door without the use of 0-ECM 170101. In addition, the Troubleshooting Pte Job Review Sheet and Instructions form was not completed to establish and approve job steps, a craftsman failed to determine the "as found" condition of LS 7 by inappropriately exercising it, and also the craftsman failed to record these actions on the associated work request.
2.
Periodic Test 1 PT 62.4, dated February 20,1990, Personnel Airlock Seal Lenkage Test, requires the "as found" condition of the test to be recorded in stop 4.11.1. Further, if the test results in a frequency of greater than 60 bubbles poi minute observed at the bubble flow detector, a calibrated rotometer shall be used to record flow. VPAP 2002, paragraph 6.1, requires a work request be written for performing maintenance on permanently installed equipment which is not considered minor maintenance or work required as a sesult of a station deviation report,1 PT 62.4 and VPAP 2002 were not adequately implemented in that on March 15, 1991, after the personnel airlock seal leakage test failed to meet the acceptance criteria due to a faulty LS 7 limit switch, the operators failed to record the results of the test following the use of the bubble flow detector and failed to use a calibrated rotometer to obtain the leakage. Also, following failure of the test, corrective maintenance was performed on the LS 7 limit switch without authorization and without a work request or procedures.
This is a Severity Level IV violation applicable to Unit 1 only (Supplement 1).
C. Technical Specification 6.8.1 requires that written procedures be established covering the app!icable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Included in Appendix A of Regulatory Guide 1.33 are procedures for performing surveillances.
Contrary to the above, surveillance procedures were inadequate in that, test and calibration procedures implementing Technical Specification 4.4.3.2.1.b did not fully test the automatic high pressure portion of the Unit 2 power operated relief valve 2-RC PC-2455C channel.
This is a Severity Level IV violation applicable to Unit 2 only (Supplement I).
l NOV 50 338&339/0100 RESPONSE TO VIOLATIOlLA
- 1. ADMISSION OR DENIAL OF THE ALLEGED VIOLATION The violation is correct as stated.
4 i
- 2. REASON FOR THE VIOLATION The violation was caused by inadequato implementation of corrective actions associated with a previously identified Quality Assurance audit finding.
- 3. CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED When the violation of Technical Specification 3.11.2.5 was identified, the release of l
the "A" Waste Gas Decay Tank (WGDT) was secured, nitrogen was added and the oxygen concentration was reduced to less than 2 percent.
A Technical Specification change which will provide appropriate guidance is currently pending NRC approval.
In the interim, an Operations Department Memorandum was written to clarify Technical Specification 3.11.2.5 requirements. This memorandum was provided to each Senior Roactor Operator (SRO). The SRO discussed the memorandum with their respective shift to ensure understanding and compliance with the Technical Specification.
The WGDT procedure (1 OP 23.2) has been revised to specifically identify actions reaulted to reduce oxygen concentration to less than 2 percent.
- 4. CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVolD FURTHER VIOLATIONS No further corrective actions are required.
- 5. THE DATE WHEN FULL COMPLlANCE WILL BE ACHIEVED Full compliance has been achieved.
t
',M*'r'ilew'er r e-
%ww-e r-
- -We-',ww-y.e,p-s-e, 9q.g-,-a,w, yep.y-.m
-.cw.,%ype,o g 9, mya--,.,e-..p p-p_wg,-,-ipg._
g rew,-9 9 g..
.y w-gg,,,~_
.,n.g 9,,
%gg.
,mp p
-_mmg_
mq_p
NOV 50 338&339/91-00 RESEQHSILIQ_YLQLA1101LD 1.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION The violation is correct as stated.
- 2. REASON FOR THE VIOLATION The violation was caused by personnel error in that the personnel involved in the maintenance evolution during non normal work hours took actions outside the scope of the work toquest system in troubleshooting the problem.
- 3. CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED The personnel involved were counseled by management regarding their unacceptable performance and coaching was conducted to assure acceptable performance in the future.
An Operations Department Memorandum was written to more ciearly specify the requirements for and scope of work requests prepared during non normal work hours.
Each operating shift discussed the requirements of the memorandum and the importance of following procedures.
- 4. CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS No further corrective actions are required.
- 5. THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance has been achieved.
l t
l
\\
NOV 50 338&339/9100 I
BESP_QNSLTO ViQtATION_C l
- 1. ADMISSION OR DENIAL OF THE ALLEGED VIOLATION l
Tho violation is correct as stated.
- 2. REASON FOR THE VIOLATION 4
The violation was caused by the incorrect interpretation of surveillance requirement 4.4.3.2.1.b and an administrative error, in an effori to provide additionalinformation to NRC regarding this previously unresolved item which was identified in Inspection Report 90 02 dated March 2,1990, we had performed a review in March 1991 to verify that testing was performed during tne Unit 21990 refueling outage and the Unit 11991 refueling outage. The review determined that a set of contacts on the control room benchboard switch for the automatic high pressure portion of the Unit 2 power operated rollef valve, 2 RC PCV 24550, were not tested due to an administrative
- error, i
- 3. CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED As an immediate corrective action, the appropriate action statement of Technical Specification 3.4.3.2 was entered and 2 RC PCV 2455C was declared inoperable and its associated block valve was shut.
The appropriate procedure was temporarily revised to allow a one time functional test of the contacts and associated wiring. This testing was satisfactorily performed.
- 4. CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS Appropriate procedures will be revised to ensule each contact and associated wiring j
j in the PORV control circuitry is adequately tested. Assurance that the appropriate revisions will be made prior to their next scheduled use is provided by assigning th9 actions through the commitment tracking system.
- 5. THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Contacts and associated wiring in the PORV control circuitry have been successfully tested, therefore full compliance has been achieved.
However, to maintain full compliance the required procedures will be revised prior-to their next scheduled performance.
l
-