ML20101H782
| ML20101H782 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 11/08/1984 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20101H724 | List: |
| References | |
| 609, NUDOCS 8412280342 | |
| Download: ML20101H782 (5) | |
Text
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3 USNRC RE010N d Vruoixr/b' dEdic*1NMkna Courwxy t
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November 8, 1984 I
Mr. James P. O'Reilly Serial No.
609 Regional Administrator N0/JHL:lms Region II Docket Nos. 50-338 U. S. Nuclear Regulatory Commission 50-339 101 Marietta Street, Suite 2900 License Nos. NPF-4 Atlanta, Georgia 30323 NPF-7
Dear Mr. O'Reilly:
We have reviewed your letter of October 9,
1984, in reference to the inspection conducted at North Anna Power Station between August 6, 1984 and i
September 5, 1984 and reported in IE Inspection Report Nos. 50-338/84-30 nnd 50-339/84-30. Our response to the infraction is attached.
We have determined chat 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.
V y trul yours, W. L. Stewart Attachment cc: Mr. Dichard C. Lewis, Director Division of Project and Resident Programs Mr. James R. Miller, Chief Operating Reactora Branch No. 3 Division of Licensing Mr. M. W. Branch NRC Resident Inspector North Anna Power Station
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Attcchment 1 RESPONSE TO NOTICE OF VIOLATION ITEM REPORTED DURING NRC INSPECTION
-CONDUCTED FROM AUGUST 6 TO SEPTEMBER 5, 1984 INSPECTION REPORT 50-338/84-30 AND 50-339/84-30 NRC COMMENT 10 CFR, Part 50.59 allows n' holder of a license to operate a utilization facility to make changes in the facility as described in the safety analysis report without prior Commission approval provided that the change does not involve a change in technical specification or an unreviewed safety question.
Additionally, 10 CFR, Part 50.59 requires that a written safety evaluation be performed and provide the basis for determining that the change does not involve an unreviewed safety question.
g Section 3.8.2.7.6 of the North Anna Updated Final Safety Analysis Report describes the protective coating process for coatings applied within the containment liner boundary.
Paragraph 3.8.2.7.6.6 allows additional painting within the containment liner boundary provided the new coating meets the technical performance requirements for simulated DBA testing as described in ANSI N101.2-72.
Contrary to the above requirements, on January 13, 1983, for Unit 1 and May 8, 1983, for Unit 2 an unanalyzed modification was authorized and subsequently performed which involved painting approximately 8000 square feet of containment ring ventilation duct per unit with non-DBA qualified coating.
This is a Severity Level IV violation (Supplement 1).
o
RESPONSE
1.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION This violation is correct as stated.
2.
REASON FOR THE VIOLATION The root cause of this violation was the failure to recognize the safety implications of this modification (repair) activity and, as a result, failure to implement the required administrative and technical controls.
3.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED The corrective steps described in paragraph 10 of this IE Inspection Report and in the Vepco Licensee Event Report (LER 84-006) dated August 30, 1984 included:
a.
An immediate investigation was initiated on Unit I to determine the type and qualification of the paint applied to the ventilation ring duct.
This investigation was expanded to include Unit 2.
As a result of the investigation, Unit 2 was removed from service.
Unit I was already in a refueling outage.
9 j
t 13.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED (cont.)
b.
_ Paint samples were removed from both unita ventilation system ring
. ducts ' and were subjected to post-LOCA condition ~ testing.
In both cases, the paint samples failed to meet the acceptance criteria.
i c.
The investigation was expanded -to include all painted surfaces-within the Unit 1 and 2 containments, particularly galvanized steel surfaces.
There. were no other discrepancies of this type noted.
(Some discrepancies from the station painting specifications were found but were assessed - to be acceptable by Engineering - see paragraph,4a[3]).
d.
The corrective actions for the painted galvanized steel surfaces included the designing and installation of a fine wire mesh stainless steel screen over the entire affected area.
Engineering analysis and testing demonstrated that this corrective action would prevent the clogging of the containment sumps following a LOCA.
4.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS A corrective action plan has been developed to avoid further violations and is summarized below:
a.
From LER 84-006 dated August 30, 1984 paragraph 5 " Actions Taken to Prevent Recurrence"...
1)
Review the Painting Specification NAS-1016 and_ update as required.
Expected completion December 1985. -As an interim
- measure, Engineering has developed and implemented an Engineering Work Request delineating acceptable surface preparations and coatings to be used for frequently painted surfaces.
2)
Augment the Station Administrative, Quality Assurance and Construction Procedures to further ensure that no plant modification work can be performed under the maintenance program.
These actions have been completed.
This corrective action has substantially reduced the possibility of an event similar to the ones that led 'o this violation.
3)
Complete the painting documentation review.
This review has been completed and the identified discrepancies from NAS-1016 were resolved by Engineering.
1 4)
Retain a consultant to independently evaluate the adequacy of the existing controls over the painting and maintenance program process.
This consultant review has been completed and the resulting recommendr.tions are being implemented.
b.
Based on the consultant review (a.4 above), as well as internal l
management evaluation, the following additional actions have been l
undertaken:
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4.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS (cont.)
1)
Augment - the records files to correct the painting records-without altering the original form.
Estimated completion i
December 1, 1984.
2)
An evaluation of the QC Inspector training program for coatings has been completed.
It has been decided that the National
~ Association of Corrosion
. Engineers (NACE) inspectors certification program will-be the basic element in the. QC inspector training program for coatings.
Four experienced coating inspectors have been enrolled in the NACE certification'
~
program to be ' completed in
- January, 1985.
The NACE recertification-program will also be used to maintain - the
-proficiency,of coating inspectors.
i'g 3)
Revise _the Training Administrative Procedure to include i
specific training on the specification and procedures.
Estimated completion of the scope - of the training program is l
' January 15, 1985.
4)
Revise the Design Control Program to require specific i
references to painting requirements as an interim measure l
pending completion of the update to the Painting Specification l
NAS-1016. Estimated completion December 31,'1984.
l 5)
Review the training programs for station employees to determine j
if specific training on the Administrative. Procedure controls is required.
Estimated completion February 15, 1985.
i 6)
Review the adequacy of controls for all consumables.
Estimated completion February 28, 1985.
+
l 7)
Emphasize the use of Station Administrative Procedures to Engineering - and Contruction personnel.
Estimated completion November 30, 1984.
8)
Evaluate present Shift Supervisor's administrative workload, specifically-work order review, and amend or revise as required.
Estimated completion March 1, 1985.
l 9)
Evaluate the process of Work Order classification and recommend improvements.
Estimated completion December 15, 1984.
5.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED L
l The dates for resolution of the problems identified are included in paragraph 4 of this response.
6.
EVALUATION OF " WORK CONTROL" PROGRAM The " Work Control" program has been revised and automated since the situations involving painting of containment duckwork occurred.
As part of the review of the painting situation, the " Work Control" program was reassessed. The initial results of this review indicated that the safety classification and approval process for Work Requests to station
4 6.
EVALUATION OF " WORK CONTROL" PROGRAM (cont.)
mainteaance are effective.
However, as identified in Paragraph '4b(9) above, additional evaluation is currently. ongoing to ensure that the process is adequately controlled. The initial review also indicated that the Work Requests made to the Construction Department were not being adequately classified or reviewed from a safety standpoint.
To correct this situation, the station Administrative Procedures controlling Work Requests - to the Construction Department have been augmented to require Engineering and Quality Assurance ~ review and to provide specific references to be used for painting Work Requests.
Finally, the " blanket" Work Requests for painting given to the Construction Department have been terminated and the station Administrative Procedures have been revised to-preclude the use of " blanket" Work - Requests for painting.
With the changes made and implemented to date, the Work Request program is believed to be adequate and should be effective in controlling Work
_f Requests under the responsibility of either the station Maintenance Department or the Construction Department, and for ensuring that the design change work is performed under the Work Request program.
The l
Design Change program, under which design changes are performed, is believed to be both adequate and effective for controlling painting based I
on the results of Paragraph 4a(3) above.
With the implementation of Paragraph 4a(1) and (2), and 4b(4), the Design Control program will be further enchanced.
With the completed corrective actions to date the " Work Control" program at North Anna is believed to be effective ~ for classifying safety Work Requests and in ensuring that design changes are performed under the Design Control portion of the Work Control program.
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i JDH/1ms/LTR2/609
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