ML20091K179
| ML20091K179 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 01/16/1992 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 91-765, NUDOCS 9201230026 | |
| Download: ML20091K179 (7) | |
Text
.
Vilar,sutA Hi.1:rticle Ann l'ownst Cownwn IllCllMON H, ValtOINI A UllU O f January 16, 1992 U.S. Nuclear Regulatory Commission Serial No.
91 765 Attn: Document Control Desk NAPS /WCH Washington, D.C. 20555 Docket Nos.
60 338 50 339 Ucense Nos. NPF 4 NPF 7 Gentlemen:
ylRGINIA ELECTnic AND POWER QQMPANY NORTH _ ANNA _ POWER. STATION UNITS 1 AND_2 INSPECTION REPOHT tiQS. 53:,318191 17 AND_50 339/91-12 RESPONSE TO THELNQTICES Of VIOLATIQ_N We have reviewed your letter of Decernbec 18,1991, which loferred tu the inspection conducted at Nor1h Anna from July 29,1991, through August 30,1991, and reporteu in Inspection Report Nos. 50 338/91 17 and 50 339/91 17. These results were also discussed in a-meeting held in your Atlanta office on December 12, 1991. Our F
response to the Notices of Violation is attached, in your letier that transmitted the Noticos of Violation, you exprecsed concern regarding the violations because they demonstrated oxamples where procedures were inadequate, procedures were not followed, and corrective action for identified deficiencies was inadequate to preclude recurrence.
To address the issue of inadequate procedures, each case was reviewed and procedures were revised
.nccordingly. Where procedures were not adequate!y implemented, the evm.ts were discussed with the appropriate personnel arid attention to detall was stressed. A Technical Specification (7S) change associated with the under voltage / degraded
. voltage (UV/DV) setpoints was cubmitted to the NRC to preclude further confusion of i
station personnel. The TS change was approved by the NRC on November 29,1991.
To address the issue regarding procedures that were not followed (i.e., deviatior, reports (DR) riot being submitted when conditions exceeded TS allowed values),
management met with all members of the electrical department and stressed the expectations for submitting DRs. The Superintendent of Maintenance issued a Standing Order to all Maintenance Department personnel reinforcing the requirement to submit a DR when unexpected conditions are encountered. In addition, DR training was conducted as part of the Technical Staff Continuing Training (TSC1) Program.
Regarding inadequate corrective action, the example of the EDG load sequencing timer drift which was identitled on August 7,-1989, and again on Unit 1 in 1991 was evaluated and was determined not to be an operability concern. Since the time of the 1989 ovent, a new Virginia Power Administrative Procedure (VPAP 1601) has been implemented which would have required the cause of the deviation to be determined and appropriate corrective measures to be taken, for events of this nature.
[
2 01M o026 920116 gor < nocct05 cogs
Finally,in regard to your request in the EDSFl cover letter concernin0 review of tho DBD program in light of the EDSFl findings, wo are assessing the issue and will respond in detail when wo submit our response to the 23 findings.
if you have any further questions, please contact us.
Very truly yours, f
.st L
,k 3k
~ L Stewart 1
Senior Vice Prssideat Nuclear Attachment 1
i cc: U. S.14uclear Regulatory Commission 101 Mariotta Street, N.W.
Sulto 2900 Atlanta, Georgia 30323 Mr. M. S. Lessor NRC Senior Resident inspector North Anna Power Station m
i r
h t'
e:
NOV 50 338&335/9117 BESPONSE TO THE.E.QJICES OF Vl0LATION BEPORTED DURINQ.ltiU NRC INSEECTIOECONDUCTE(1 BETWEEN JULY 29 1991. AND AUGUSJ' 30. 1991.
INSPECTION REPORT NOS. 50 338/.91-17 AND 50 339/91-17 NRC COMMENT During an NRC inspection conducted between the period of July 29,1991, and August 30,1991, violations of NRC requirements were identified. In accordance with the
" General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C. (1991), the violations are listed below:
A, Technical Specification (TS) 6.8.1.c requires that procedures be established and implemented for surveillance and test activities of safety related equipment.
Surveillance procedures 1/2 PT 36.11 were established to demonstrate per TS 4.3.2.1.1 and 4,3.2.1.3 that the degraded voltage time dalay times and loss of voltage instrumentation response times were within the values provided in TS Tables 3.3 4 and 3.3 5 respectively.
Test Procedure EMP-P RT-206 and associated Protection Scheme Whitesheets were established to demonstrate per TS 4.3.2.1.1 that the loss of voltage time delay times were within the values provided in TS Table 3.3-4. Surveillance procedure 2-PT-84,4 was established to demonstrate per TS 4.8.2.5.1.3 that a representative sample of fuses meet the manufacturer's design criteria.
Contrary to the above, proceduros for surveillance and test activities were not adequately established or impirmented in that:
1.
1/2 PT-36.11 were not o.A outely establishad in that the TS Table 3.3 4 required degraded voltage time delay toleranca band of plus or minus three seconds was not specified. On October 29,_1990, this resulted in the 2J emergency bus time being left set outside the tolerance band.
2.
On August 14,1991,1/2-PT-36.11 were not adequately estab'ished in that the 74 percent loss of voltage relay circuitry had been included in the response time test in lieu of the 72 percent loss of voltage relay circuitry as required by TS.
3.
EMP P-RT 206 and Protection Scheme Whitesheets were not adequately established in that the procedures specified a loss of voltage time delay setpoint of 2,0 seconds which was outside the 2.2 plus or minus 0.03 secer.ds required by TS Table 3.3-4. This resulted in all four setpoints being found out of tolerance on August 13,1991.
4.
2-PT-84.4 was not implemented in that on September 4,1990, the procedure was signed as being completed satisfactorily even though five fuses were outside the stated acceotance criteria.
This is a Severity Level IV violation (Supplement 1).
B.
10 CFR 50 Appendix B Criterion V requires activities affecting quality be prescribed by documented proceduies and shsil be accomplished in accordance with these procedures. Administrative procedure VPAP-1501 attachment 3 item 1.d stated that deviation reports would be required for any conditions that xceed TS allowed values, including drift in trip setpoints.
. ~ -. _ _ _ _ _ _
,u y'
NOV 50-338&339/9117 m
Contrary to the above, deviation repoi1s were not issued as required by VPAPk 1501 when Unit 1 load sequencing timers were discovered outside their TS Table
- 4.81 required setpoint tolerances. Out of tolerance conditions were identified on January - 15, = 1991, January ~16,1991, and-February 4,- 1991, during the performance of PT 83.3, Emergency Diesel Load Sequencing Timer Verification Test, revision 3.
This is a Severity Level IV violation (Supplement l}
ificant condition adverse to C. -10 CFR 50 Appendix B Criterio,, XVI requires ' r quality, measures shall assure tht.. H.;ause on a condition lo determined and corrective actions are taken to preclude repetition. Station Deviation Report (DR):
891586 identified that Unit 2 TS required load sequencing timers were found with their setpoints outside allowable TS Table 4.8-1 tolerance.
Contrary to the above, measures were not taken to determine the cause of the condition and preclude repetition. This condition, EDG load sequencing timer drift, which was identified on Unit 2 in August 7,1989, was subsequently idantified on Unit 1 in 1991.-
This is a Severity Level IV violation (Supplement 1).
FIESPONSE TO VIOLATION A
- 1. ~ ADMISSION OR DENIAL OF THE ALLEGED VIOLATIONS The violation is correct as stated.
- 2. REASON FOR THE VIOLATIONS
- The violation associated with procedures for surveillance and test activities not being adequate:y established or implemented was caused by severalinstances of personnel error.
1.
Personnel error associated with inadequate procedures led to the 90 percent -
degraded voltag'e relay for the Unit 2 "J" bus being left with its time delay setting outside the TS requirement, it is-_ station policy to include TS I
surveillance requirements In the procedure's acceptance criteria; however, the time delay requirement was not included in this case. Station personnel
-did not recognize that the setpoint was outside the requirement because it
?
was not addressed in the procedure's acceptance criteria.
2&3. -Personnel error ascociated with an incorrect interpretation of TS resulted in-relay setpoints more conservative than the TS limits and failure to perform response time testing of the 72% under voltage (UV),r'sys. It is cuspected that the 72% UV relay setpoints were adjusted to 2.0 r econds based on the interpretation that the TS required time delay was inten3d to be the overall-l circuit response time between the initiating signal from the 72% UV relay and initiation of the EDG start. It has since been determined that this is an incorrect interpretation because the TS'setpoint requirement is for the relay time delay only.
o
NOV 50 338&339/9117 The test procedures used to verify the setpoints for the relay timers were an additional contributing factor to the event Since the test procedures used to calibrate the setpoint of the timers were not part of the Periodic Testing (PT)
)
Program, a TS cross reference to alert the user or reviewer that the acceptance critoria was associated with a TS requirement was not provided.
Therefore, the relay time response test was not inct porated into the PT Program as a TS surveillance and the setpoint verification test did not contain the appropriate acceptance criteria, in order to time the UV circuitry as required by TS 3.3.2.1, the 74% UV circuit was timed because this is the first and primary circuit that starts the EDG. The 72% UV circuitry is required to function to load the EDG, and this circuit is functionally tested in accordance with TS every other month during the degraded voltage / loss of voltage functional test. However, the voltage value specified in the TS equates to the 72% UV relays which were not response time tested.
4.
Personnel error due to inattention to detail led to five fuses for pressurizer
}
heater electrical containment penetrations not being replaced and retested prior to unit operation as required by TS. The individuals performing 'he test failed to recognize that the resistance data was outside the procedure's acceptance critoria. An additional point of consideration for the evont was that the acceptance criteria for the subject fuses is listed in a separate section of the procedure from the as found data sheets.
- 3. CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED Upon discovery of the degrad9d conditions, equipment was reset and retested in accordance with TS. Where procedural inadequacies were identified, procedure revisions were processed.
Licensee Event Report (LER) N2-91-005 was submitted to document relay time delay setpoints outside TS limits. LER N1/2 018 was submitted to document the failure to perform response time testing on the 72 percent under voltage relays and time delay setpoints found outside the TS limits.
LER N2-91008 was submitted for the failure to replace fuses with resistance measurements outside the acceptanca criteria.
All events were discussed with appropriate departments and personnel involved and strict compliance with TS was emphasized.
As an additional enhancement, a Technical Specification change which clarifies under voltage setpoints and time delay requirements was processed and submitted to the NRC. The TS change was approved by the Commission on November 29,1991.
- 4. CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS No further action is required.
- 5. THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED g
Full compliance has been achieved.
'4 NOV 50 338&339/9117 RESPONSE TO VIOLATION B
- 1. ADMISSION OR DENIAL OF THE ALLEGED VIOLATIONS 4
The violation is correct as stated.
- 2. REASON FOR THE VIOLATIONS The violation associated with failure to submit Deviation Reports when load sequencing timers were discovered outside their TS required setpoint tolerances was caused by personnel error. The personnel performing the ~ ss found" testing l
were not sensitive to submitting DRs when degraded conditions were identified.
- 3. CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED Upon discovery of the degraded conditions, the EDG load sequencing timer
-setpoints were reset in accordance with TS limits. The importance of following established _ administrative requirements, in particular, the requirements for submitting station deviation reports (VPAP-1501), has been discussed and re-emphasized with the appropriate station personnel as documented in our response to NOV 50 338,339/91-14. The Superintendent of Maintenance issued a Standing Order to all Maintenance Department personnel re-enforcing the requirement to submit a DR when unexpected conditions are encountered. In i
addition, DR training was conducted as part of the Technical Staff Continuing Training (TSCT) Program.
- 4. CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS No further action is required.
l-
- 5. THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance has been achieved.
l l
l I
-. ~,
. - - ~ -.
I NOV 8i04338339/9117 fHESPONSE-TO -VIOLATION C -
- 1. ADMISSION OR DENIAL OF THE ALLEGED VIOLATIONS The vlotation is correct as stated.
- 2. - REASON-FOR - THE VIOLAYlONS The violation associated with failure to take corrective measures to determine the cause=of load sequencing timers being outside adowable tolerance was caused by personnel error resulting from an inadequate administrative procedure. The--
DR was submitted because a. load sequencing timer verification test proceduto dio not provide for documentation of corrective actions if any were required. The response to the DR addressed the procedure problem and successfully adjusted the time response to within TS requiruments.
- 3. CORRECTIVE STEPS WHICH HAVE-BEEN-TAKEN AND THE RESULTS' ACHIEVED To address the issue of measures not being taken to determine the cause of the.
.1989 DR that was identified in your letter, an svaluation was performed which determined that there was not an operability concern.' Since the time cf the event,
!a.new Virginia Power Administrative Procedure (VPAP-1601 " Corrective Action")-
1has been _ implemented. This program provides a more rigorous review of plani-deviations to ensure causea are identified and appropriate _ corrective measures
- are taken.
.The-probable cause of the timers being outsido the TS tolerance limit is normal
. Instrument drift; however, this could not be verified when the unit was at power.
. Unit 1 is currently shutdown,' and an additional timer has been found outside the
.TS requirement. _ As required.by VPaP-1501 a DR was submitted, and VPAP-31601 will ensure the cause is identified and corrective measures are taken. -!n
-order to ensure no other timers are outside of their tolerance limit, the Emergency -
Diesel Load: Sequencing Timer _ Verification Test will be performed during the L
current Unit 1 outage.
4.. CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOL'ATIONS
[
No further action is required.
- 5. THE DATE WHEN-FULL. COMPLIANCE WILL BE ACHIEVED
_ Full compliance has been achieved.
... -