ML20098A493
| ML20098A493 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 07/13/1984 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20098A481 | List: |
| References | |
| 369, NUDOCS 8409250044 | |
| Download: ML20098A493 (3) | |
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VIRGINIA ELECTRIC AND POWER COMPANY RIcnwown,V1BOINIA 20261
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July 13, 1984 Mr. James P. O'Reilly Serial No. 369 Regional Administrator N0/JHL:acm Region II Docket Nos. 50-338 U. S. Nuclear Regulatory Commission 50-339 101 Marietta Street, Suite 2900 License Nos. NPF '
Dear Mr. O'Reilly:
We have received your letter of June 11, 1984, in reference to the inspection conducted at North Anna Power Stat-ion between April 6, 1984 and May 5, 1984 and reported in IE Inspection Report Nos. 50-338/84-09 and 50-339/84-09.
I'e r a telephone conversation between Mr. R. J. Hardwick and Mr. H. C. Dance, on July 11, 19P4, an extension until July 13, 1984 was granted to respond to this inspection report. Our response to the specific infraction is attached.
We have determined that no proprietary information is contained in the report.
Accordingly, the Virginia Electric and Power Company has no objection to this inspection report 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, f
/'
b ll b
W. L. Stewar Attachment ec:
Mr. Richard C. Lewis, Director Division of Project and Resident Programs Mr. James R. Miller, Chief Operating Reactors Branch No. 3 Division of Licensing 3
Mr. M. W. Branch NRC Resident Inspector North Anna Power Station 1
8409250044 840816 PDR ADOCK 05000330 G
Attcchment P2g2 1 Serial No. 369 f
RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-338/84-09 AND 50-339/84-09 NRC COMMENT:
Technical Specification 6.8.1.c requires, in part, that written procedures be established covering surveillance _ and test activities of safety-related equipment. ANSI N18.7-1976, to which the licensee is committed, requires that procedures-incorporate or reference requirements and acceptance limits.
Contrary to the above, 1 and 2-PT-36.7.5 " Engineered Safeguard Features Pump Response Times" and numerous other time response testing periodic tests do not contein adequate acceptance criteria in that the acceptance criteria of these procedures do not specify acceptance limits.
This is a Severity Level IV violation (Supplement I).
i
RESPONSE
(1) ADMISSION OR DENIAL OF THE ALLEGED VIOLATION:
This violation is correct as stated.
The Response Time Surveillance Requirement of Technical Specifications 3.3.1.1 and 3.3.2.1 accomplished by 1 and 2-PT-36.7.5 did not contain specific acceptance limits.
The acceptance limits of the entire response time loop were given in a separate surveillance document 1 and 2-PT-36.8.
(2) REASONS FOR VIOLATION:
This violation occurred because the original procedure development utilized a partial loop testing technique.
Separate surveillance documents were used for these partial response time measurements, and a i
compiling document was utilized to obtain all partial response times and then verify that the total loop response time met Technical Specification i
requirements. The requirement of ANSI N18.7-1976 for acceptance criteria in each discreet surveillance document was not believed to be applicable for partial loop testing.
Each procedure did contain an acceptance criteria section in the format, but the acceptance criteria were limited just to obtaining test data.
(3) CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:
An evaluation of the program was conducted on partial locp testing. The results of this evaluation indicated the need for the corrective actions j
delineated in Section 4 below.
Attcchment Pega 2 Serial No. 369 (4) CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
The discrepancies and problems with response time tests, as identified in Notice of Violation 84-09-02, are in the process of being resolved. The following actions are either being implemented or planned to correct the problems.
1.
All response time tests, except the RTD response time procedure, are scheduled to be performed during the 1984 refueling outages for Unit 1 and 2.
Because of plant conditions required by our test method, the RTD response time procedure will be completed when the unit is stable at 100% power.
This action will insure that the most recent data is available to calculate the total train response time.
2.
As a conservative measure the total train response time procedure (PT-36.8) will be completed prior to startup utilizing response time data provided by the RTD manufacturer. This action will identify any unacceptable equipment response times prior to startup.
The actual EFD test data will be utilizied to calculate the total train response time when it becomes available.
3.
Following the refueling outage all equipment response time procedures will be reviewed and revised to insure adequate acceptance criteria exists.
The acceptance criteria will be based on past data, and developed such that the sum of individual equipment response times is less than the maximum acceptable total train response time. Also, if the equipment response time exceeds the acceptable limits, the total train response time procedure shall be performed to reflect the new time and to insure compliance with the Technical Specification limit.
4.
The development of a master callout procedure, or other mechanism to insure all response time tests are scheduled during a refueling outage and as close to startup as possible, will be evaluated and implemented as necessary.
5.
The compiling document (PT-36.8) and partial loop procedures are being revised to ensure that the entire loop (i.e. all partial loop tests) is completed within the same 18 month inspection timeframe and that adequate corrective actions are initiated if a partial loop test does not meet its acceptance criteria.
(5) THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
The above actions will resolve the problems associated with the response time tests, and will be completed prior to the next performance of the total train response time procedure.
Based on the present refueling schedule the Unit 1 and 2 procedures will be revised no later than i
12-13-85 and 02-28-86 respectively, f
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