ML20092C175
| ML20092C175 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 02/04/1992 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 92-029, 92-29, NUDOCS 9202110320 | |
| Download: ML20092C175 (6) | |
Text
,
Yum!NIA UM:C*fMIC AND POWER COuMY Iticimoxn.mosuir eucc,i February 4,1992
~ U.S. Nuclear Regulatory Commission Serial No.92-029 Attn: Document Control Desk NAPS /JHL:R8 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 UNITS 1 ANDJ INSPECTION REPORT NOS. 50 338i91-26 AND 50-339/91-26 RESPONSE TO THE NOTICES OF VIOLATION We have reviewed your letter of January 6,1992, which referred to the inspection conducted at North Anna from November 3,1991 to December 7,1991, and reported in inspection Report Nos. 50 338/91-26 and 50-339/91-26. Our response to the Notices of Violation is attached.
in your letter that transmitted the Notices of Violation, you expressed concern about Violation A, which involved two valves that are required to be locked in position that were found unlocked, because it appears to be indicative of continuing problems with operator inattentiveness to detail. We are in agreement that this issue requires additionai management attention.
Although recent operator personnel error trends are favorable, we believe that there continues to be room for improvement. Because of our sensitivity to this issue, we-have elected to use our Quality Assurance (QA) Department in an assistance role, it is our. intent to use this organization to witness the performance of safety related independent verification activities. We expect that this will not only add an additional layer of defense to our Iridependent verification program, but will also raise the
-awareness of the operations personnel.
You also. expressed _ concern with Violation-B, which involved an apparent misapplication of a test procedure used to conduct testing on an operable safety related system and the failure to perform an activity screening checklist, which bypassed the program for ensuring that tests do not involve an unreviewed safety question.
92o211o320 'i202o4 6
PDR ADOCK 050DOO?A
/ v i
g l
0 PDR I
..~.
Serial No.92-029 Dock 01 Nos.-50 338&339 Page 2 of 2 The newly revised Design Change Package (DCP) process requires that an activity screening be performed and attached to the DCP.which will prevent any further
-misunderstanding about the review process for ' modifications and ensure that an evaluation is made for unreviewed safety questions. Also, the use of test procedures has been revised to require a 10 CFR 50.59 Activity Screening if the test procedure is not pad of an approved modification package, if you have any further questions, please contact us.
Very truly yours,
}
W. L. Stewart Senior Vice President - Nuclear Attachment cc: U. S. Nuclear Regulatory Commission
.101 Marietta Street, N.W.
Suite '2900 Atlanta, Georgia 30323 Mr. M. S. Lesser NRC Senior Resident inspector North Anna Power Station
t
':4' e
RESPONSE-TO THE NOTICES OF VIOL ATION REPORTED DURING THE.Nfl0 INSPECTION - CONDUCTER BETWEEN NOVEMBER 3.1991. AND DECEMBER 7.1991 jl{SPECTION REPORT NOS. -50 338/91-26 AND 50-339/91 26 NRC COMMENT During.the Nuclear Regulatory-Commission (NRC) inspection conducted on November 3,1991 - December 7,1991, 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 Spec!fication 6.8.1.a requires written procedures to be established, implemented and maintained covering activities referenced in Appendix A-of Regulatory Guide 1.33,- Revision 2, February 1978, to include operating l
procedures.
Operating Procedures 1-OP 63A, Valve Checkoff-Containment Atmosphere Cleanup, and 1-OP 23.3, Process Vent System, respectively require i
- that valves 1 HC 40 and 1-GW-135 be locked.
I-
' Contrary to the above, on November 19,1991, valve 1-H-C 40 (1-HC-40) was found to be unlocked, and on December 4,1991, valve 1-GW 135 was found to be unlocked.
-This is a' Severity Level IV Violation applicable to Unit 1 only (Supplement 1).
B.
Technical Specification 6.8.1.a requires written procedures to be established, implemented 'and maintained covering activities referenced in Appendix A of Regulatory Guide -1.33, Revision 2, February 1978,.to include administrative procedures. _' Administrative Procedure ADM 3.7, Engineering Work Requests, i
requires' Station Engineering to-prepare an : Activity Screening Checklist for j
Engineering Work Requests to determine if a safety evaluation is required. VPAP-0102, Station Nuclear Safety and Operating Committee-(SNSOC), requires the SNSOC; to review surveillance and testing procedures for safety-related equipment and that written approval or disapproval be certified in writing by the SNSOC Chairman or Vice Chairman.
L
- Contrary to the above, on November 24,1991, test activities were performed on the
- Unit 12 Safeguards Area Ventilation System in accordance with Engineering Work 4
Request 90-381 without any Activity Screening Checklist having been co,mpleted, as required by ADM 3.7, and with the use of a specific test procedure which was not reviewed and approved by the Station Nuclear Safety and Operating Comrnittee as L
required by VPAP-0102.
l This is a Severity Level IV Violation applicable to Unit 2 only (Supplement I).
L 1
4 g
Sorial No. 92 029 N')V IP, 50-338&339/91-20 Attachment Page 2 of 4
+
RESPONSE TO VIOLATION' A 1'. - ADMISSION OR DENIAL-OF THE ALLEGED VIOLATION The violation is correct as stated.
- 2. REASON FOR' THE VIOLATION The reason for the improper attachment and/or locking of the valves was due to -
lack of attention to detail by Operations Department personnel. In the case of valve 1 HC 40, on tne Containment Atmosphere Cleanup System, the chain to lock the valve in position was incorrectly attached.- In the case of valve 1 GW 135, on the Process Vent System, the valve was correctly chained and the lock was applied through the chain. However, the hasp on the lock was not properly engaged.
- 3. CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE
- RESU LTS ACHIEVED 1-GW-135 and 1-HC 40 were verified to be in their proper position, i-The lock on valve 1-GW-135 was securely locked and the chain on valve 1 HC 40 was adjusted and the valve properly locked.
i A walkdown of locked valves in the vicinity of the two valves that were found unlocked was performed. No discrepancies were identified.
A coaching session was held with operations personnel to stress the importance of attention to detail and self checking when locking valves in--position, and L
appropriate disciplinary action has been taken with the Individuals involved.
Additionally, we have elected to use our Quality Assurance (OA) Department in an l
assistance role. It is our intent to use this organization to witness the performance L
of safety related independent verification activities. We expect that this will not L
only add an additional layer of defense to our independent verification program, but will also raise the awareness of the' operations personnel. This effort will be continued until station management is satisfied that the operation performance meets that required high standards.
- 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
.7m P
aus
,t--
?
r
if Serial No. 93 029 NOV IR S0 338&339/9126 Attachment Pago 3 of 4 RESPONSE TO VIOLATION B-
- 1. ADMISSION OR DENIAL OF THE ALLEGED VIOLATION The violation is correct as stated.
- 2.1 REASON-FOR THE VIOLATION The-violation-was caused by inappropriately using Engineering Work Request (EWR) 90 381 and Test Engineering procedure 0-NAT M-001.(Mechanical Functional Loop
- Checkout) to perform test activities on the Safeguards Area
. Ventilation System '(SAVS). Specifically, personnel did not adequately review EWR'90 381,.which was being used as a guideline to air flow balance the operable SAVS,.without first performing an Activity Screening Checklist to
- determine if a safety evaluation was required. EWR 90-381 did not direct that work be performed, but was used to provide guidance to balance the ventilation system in accordance with approved station procedures and drawings. Also,0 NAT-M-001 was used with write in steps to perform an air flow balancing of the operable SAVS without obtaining prior SNSOC approval.
- 3. -CORRECTIVE STEPS WHICH HAVE BEEN 7AKEN AND THE RESULTS ACHIEVED Upon discovery of the inadequate document review, testing was stopped.-
Technical Specification _ compliance was venfled using Perindic Test procedures 2-PT-77.2A and B, and a station deviation report was written. An EWR addendum
.(EWR 90 381 A) was later issued with 'a SNSOC approved work procedure and -
activity screening.
The SAVS was air flow balanced to its original design flows, c
The newly revised Design Change Package (DCP) process requires that an activity screening be performed and attached to the DCP which will prevent any further misunderstanding about the review process for. modifications and ensure that an evaluation is made for unreviewed safety questions.
The use of test procedures has been revised to require a 10 CFR 50.59 Activity Screening if the test procedure is not part of an approved modification package.-
- 4. CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS The new requirement-to perform a 10 CFR 50.59 Activity Screening for test procedures that are not part of an approved modification package is expected to resolve this issue. However, additional followup by engineering management will verify this.
Sorial No. 92 029 NOV IR 50-338&339/9126 Attachment Pago 4 of 4
- 5. THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compilance has boon achieved.
4