ML20096E655
| ML20096E655 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 05/14/1992 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 92-281, NUDOCS 9205190289 | |
| Download: ML20096E655 (6) | |
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.4 VING1NI A 13LI:CTHIC ANil POWMH COMPANY I
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Rf CllMOND VallOINIA UllM61 May 14, 1992 U. S. Nuclear Regulatory Commission Serial No.
92 281
- Attention: Document Control Desk NAPS /MPW/TAH:R3
_ Washington, D. C. 20555 Docket Nos. 50 338 50 339 License Nos. NPF 4 NPF 7
_ Gentlemen:
l YlflGINIAELEGIBlC_AND_P_QWER COMPANY TS 1 AND 2 INSPECTION REPORT NOS. 50 338/92-04 AND 50-339/92-04 RESPONSE TO THE NOTICE OF VIOLATION
' We. have reviewed ~ your letter of April.16,1992, which referred to inspections
'3 conducted at North Anna Power Station from February 16,1992, through March 21, 1992, and which were. reported In inspection Report Nos. 50 338/92 04 and 339/92-04. The letter transmitted a notice of two violations resulting from these Inspections. Our response to the Notice of Violation is attached.
In your_ letter, you expressed concern with the v:olations because they involved our failure to.Jperform testing on reactor ? coolant pump bus undervoltage and-
--- underfrequency. relays _as required by the North Anna Technical Specifications. In addition, you also expressed concern that thess-latest failures are indicative of recurring problems _with. relay testing and weak Jnterface between our Nuclear-Operations and Control Operations departments. - We. agree with your concern regarding these violations.
Although the Control Operations procedures' had been reviewed and approved-in J
accordance_with Technical Specification 6.8, these procedures were not considered a'
.part of the station procedure upgrade program. The Control Operation procedures, i
?therefore, may not have.been written to the some quailty standards that we currently require in the station pr_ocedure generation process. To rectify this situation, we have
.. elected to incorporate these ' procedures into our station procedure upgrade program.
'The upgrade process will strengthen the interfaces between Nuclear Operations and
' Control. Operations.by requiring clear _ identification of equipment being worked on L
and/or protection-features being defeated. The procedures will also identify test-D
. responsibility boundaries and determine any redundancies.
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Docket Nos. 50 338&339 Serial No.
92P81 Pago 2 of 2 In addition, we have initiated a management task team review of missed surveillance events and related issues. The purpose of this review program is to determine the root causes of missed surveillances and to provide corrective actions that will prevent recurrence.
Also, we are developing a comprehensive plan end schedule for thoroughly reviewing the surveillance requirements of the North Anna Technical Specifications. This effort
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willinclude an evaluation of the surveillance procedures to ensure that the technical specification surveillance requirements are fully satisfied.
If you have any further questions, please contact us.
Very truly yours,
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W. L Stewart Senior Vice President - Nuclear Attachment cc: U. S. Nuclear Regulatory Commission 101 Marietta Street, N.W.
Suite 2000 Atlanta, Georgia 30323 Mr. M. S. Lessor NRC Senior Resident inspector North Anna Power Station l
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Docket Nos. 50 3388339 Sedal No.
92 281
Attachment:
Page 1 of 4 BESEONSE TO THE NOTICE OF VIOLATION INSEECTION REPAILT NOS. 50 338/92-04 AND 50-33932-Q4 MBC COMMEHI During the Nuclear Regulatory Commission (NRC) laspection conducted February 16 -
March 21,1992, 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 (1992), the violations are listed below:
A. Technical Specification 4.3.1.1.1 requires that each reactor trip system instrumentation channel be demonstrated OPERABLE by the performance of the CHANNEL CHECK, CHANNEL CAllBRATION and CHANNEL FUNCTIONAL TEST operations for the MODES and at the frequencies shown in Table 4.31.
Table 4.3-1, Items 16 and 17, require that CHANNEL FUNCTIONAL TESTS be performed monthly on Reactor Coolant Pump Bus Undervoltage and Underfrequency Channels while in Mode 1.
Contrary to the above, monthly CHANNEL FUNCTIONAL TESTS were not performed on:
- 1. Reactor Coolant Pump Bus Undervoltage channels.
- 2. Reactor Coolant Pump Bus Underfrequency channels.
This is a Severity Level IV Violation applicable to Unit 2 only (Supplement li 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, which include sarveillance procedures.
Contrary to the above,1 (2) PT-33.2 A (B) (C), Reactor Coolant Pump Undervoltage A (B) (C) Bus Periodic Test Procedures were inadequate to perform a CHANNEL CAllBRATION on the Reactor Coolant Pump Bus undervoltage channels in that they failed to encompass the entire channel including the alarm and trip functions and failed to include the CHANNEL FUNCTIONAL TEST.
This is a Severity Level IV Violation (Supplement I).
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Dock:t Nos. 50 338&339 SedalNc.
92 281
Attachment:
Page 2 of 4 BESPONSE TO VIOLATION "A" 1.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION Violation "A"is correct as stated.
2.
REASON FOR THE VIOLATION The vlotation was caused by inadequate testing procedures which did not satisfy technical specification surveillance requirements. The reactor coolant pump bus undervoltage and unJerfrequency surveillances were not being performed under Table 4.31 Item 16 and 17 requirements but under an automatic trip logic test, Table 4.31 Item 20, which includes a portion of the undervoltage/underfrequency circuitry. The automatic trip logic test is performed to meet the surveillance requirement for reactor coolant pump breal<er position trip, which is performed on a staggered test basis of once every two months. Thus, the monthly r julrement for reactor coalant pump bus undervoltage and uncerfrequency functional testing was not being satisfied.
3.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED The reactor coolant pump bus undervoltage/underfrequency protection circuitry surveillance procedures have been modified and successfully completed in accordance with technical specification requirements. The channel protection procedures are now scheduled to be performed monthly as required.
An in-depth review of the Nurth Anna Technical Specifications complex electrical and instrumentation surveillances is being performed for both units to verify that the existing procedures fully meet the surveillance requirements. This roview includes a detailed check of the component wiring and relay diagrams to verify that the testing procedures encompass the entire circuit.-
During this review two additional surve!ilance problems have been identified. The monthly channel functional test of the Safety injection input to the Reactor Trip System Instrumentation was being performed on a staggered test basis, with each train being tested every 62 days (altemate channels overy 31 days), instead of the monthly frequency required by technical specificati.ons (LER N192 007-00). We have since rescheduled the test procedure and both channeh are now being tested on a raonthly_ basis. Also, the review identified that a poruon of the circuitry on the containment purge and exhaust radiation monitor iso!ation system was not being adequately tested. The test procedures were revised and successfully performed to verify that the circuits were operable (LER 1-92-009 00).
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Dockst Nos. 50 338&339 Sedal No.
92 281
Attachment:
Page 3 of 4 4.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS We are developing a comprehensive plan and schedule for thoroughly reviewing the surveillance requirements of the North Anna Technical Specifications. The surveillance test / technical specification cross reference document will be updated so that each technical specification surveillance requirement is cross referenced to the appropriate procedure. Finally, the surveillance procedures will be evaluated to ensure that the technical specification surveillance requirements are fully satisfied.
A license amendment request will be submitted to change the surveillance of the Safety injection input to reactor trip from a monthly to a 62 day (alternate channels every 31 days) frequency.
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THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance has been achieved, i
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3 Dock:t Nos. 50 338&339 Serbi No.
92 281 4
Attachment:
Page 4 of 4 n
RESPONSE TO VIOLATION "B"
'1.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION Violation "B" is correct as stated.
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2.
REASON FOR THE VIOLATION r
The violation was caused by inadequate testing procedures which did not completo!y verify the operability of the Unit 1 reactor coolant pump "A" bus undsivoltage protection circuit. The overlapping test procedures did not require documentation that the undervoltage alarm circuitry was operable as required by a channel calibration.
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' 3.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS
. ACHIEVED Tomporary changes were written for the Unit 1 and Unit 2 channel calibration 1
procedures, and Unit 1 was satisfactorily tested. Since Unit 2 was in a refueling
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outage at the time, the testing for that unit was performed satisfactoilly prior to restart.
- 4.- l CORRECTIVE STEPS WHICH Wil.L BE TAKEN TO AVOID FURTHER
' VIOLATIONS -
The 18 month reactor coolant pump bus'undervoltage/underfrequency protection channel calibration procedures for both units will be modified ta incorporate the temporary changes to verify the entire circuits are tested as reqiAred by a channel calibration 5.
THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance was achieved.with the issuance of the temporary chang'es to the testing procedures, and the satisfactory-testing of the undervoltago protection
- circuits.
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