ML20107M310
| ML20107M310 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 09/26/1984 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20107M287 | List: |
| References | |
| 529, NUDOCS 8411140105 | |
| Download: ML20107M310 (5) | |
Text
.,
o VIRGINIA EIECTRIC AND Powna CoxPANY
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. RIcnwoNn,VIMOINIA 20261
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nr September 26, 1984 Necs..a. OrseArsows Mr. James P. O'Reilly Serial No.
529 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 August 27, 1984, in reference to the inspection conducted at North Anna Power Station between July 6, 1984 and August 5, 1984 and reported in IE Inspection Report Nos. 50-338/84-27 and 50-339/84-27. Our responses to the infraction and deviation are 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 cantatined in the attached pages is true and accurate to the best of my knowladge and belief.
Ver truly yours, l'
\\ \\
h LJs m$Q W. L. Stewart Attachments cc:
Mr. Richard C. Lewis, Director Division of Project and Resident Programs Mr. James R. Miller, Chief Operating Reactors Branch No. 3 Division of Licensing Mr. M. W. Branch NRC Resident Inspector North Anna Power Station 8411140105 841018 PDR ADOCK 05000 G
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-Attachment 1 of RESPONSE TO NOTICE OF VIOLATION ITEM REPORTED DURING NRC INSPECTION CONDUCTED FROM JULY 6 TO AUGUST 5, 1984 INSPECTION REPORT 50-338/84-27 AND 50-339/84-27 NRC C0MMENT Technical Specification 3.3.3.10 (3.3.3.9 - Unit 2) requires that with less
-than' the minimum number of radioactive liquid. effluent monitoring instrumentation channels operable, for reasons other than an alarm / trip-setpoint less conservative than required, cction 26. _of Table 3.3-13 must be taken. This requires.12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> grab samples during discharge.
Contrary to the above, with RM SW 108 inoperable during the period July 2-9, 1984, and service water being discharged to Lake Anna, the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> grab samples required by action 26 of Table 3.3-13 were not obtained.
This is a Severity Level IV violation (Supplement 1).
RESPONSE
1.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION This violation is correct as stated.
2.
REASON FOR THE VIOLATION This violation was caused by a series of personnel errors resulting'from the following root causes:
The radiation monitoring systems are high maintenance items that are a.
frequently inoperable.
Some Control Room Operators have become desensitized to these failures and have not consistently recognized the status of required radiation monitors.
b.
The radiation monitoring systems are often inoperable for long l
periods of time awaiting repair parts from the manufacturer.
Obtaining spare and replacement parts has -not been given sufficient -
priority. This contributes further to the inoperability concerns.
c.
The radiation monitoring system includes both the channels required by Technical Specifications and the channels that are less important.
As such, the inoperability of a channel required by Technical Spectifications during special conditions, such as while discharging, is easier to overlook.
The specific errors that occurred include:
a.
Tne Instrument Maintenance Technician that declared the channel (RM-SW-108) inoperable submitted a work order to repair and placed a sticker indicating the submittal of a work order on the monitor.
However, the inoperability was not positively communicated. to the Shift Supervisor to ensure the action statement would be entered.
This normally occurs by the submittal of a Station Deviation Report.
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b.
- The Instrument Maintenance Technician entered:on the work order that
'the monitor would not: source check which indicated that there was an electronic failure.
However, this.did not completely. describe _the. _ _
cause'of the monitor inoperability.
c'. -
When the ' operator Tperformed the source check,' the monitor operated normally.- There was no further. investigation into the reasons for the work order. Consequently, the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> grab samples-which would normally;te required when the monitor is inoperable, were not obtained.
d.
In' addition, the surveillance (1-PT-37) of the monitor conducted
. once - per shift (every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />) includes. a source check of the monitor.
The record of these: surveillances indicates an inconsistency in the results of the test. On several occasions, the source c. heck was performed satisfactorily.
In other cases, the.
check we.s not performed and the notation was made' that the system was under retpair.
There was no record of the inoperability being investigated and no further effort to initiate the required Technical Specification action statement.
3.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED The corrective actions to resolve the root causes are discussed in paragraph 4.
The immediate corrective nctions were to halt discharge operations until the monitor was restored to operability and to reinstruct Operations personnel on the importance of being fully aware of the inoperability of radiation monitoring equipment at all times.
F 4.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS
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The following corrective steps will be taken:
i a.
The surveillance procedures for the radiation monitoring system will be revised to include a sign-off step by the Shift Supervisor acknowledging the inoperability of radiation monitoring channels and the appropriate action statement entry, if required.
This will be completed by October 31, 1984.
j b.
An evaluation of the frequent failures of radiation monitoring i
channels will be initiated.
This evaluation will focus on the systen enhancements that can be made to improve operability.
This evaluation will be completed by January 15, 1985.
j c.
The problem of obtaining spare and replacement parts will be given l
priority consideration.
The maintenance necessary to repair all inoperable radiation monitors will be actively pursued.
A target completion date for restoring inoperable radiation monitors to operable status is January 15, 1985. The monitors that are used for releases will be given first priority.
During the time period that the monitors ~ are inoperable, grab samples will be taken in accordance with the Technical Specifications for discharges.
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_m (3) 4 A monthly status report of the condition'of the radiation monitoring system will be provided to the Station Management (including the Station Manager) until the concerns have been addressed.
5.
pATE WHEN FULL CGMPLIANCE WILL BE ACHIEVED The dates associated with the corrective actions to prevent recurrence are included in paragraph 4.
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g Attcchm:nt-2 6-RESPONSE TO NOTICE Or DEVIATION.
ITEM REPORTED DURING NRC INSPECTION CONDUCTED FROM JULY 6 TO AUGUST 5. 1984 INSPECTION REPORT 50-338/84-27 AND 50-339/84-27 NRC COMMENT
]
Par'agraph 11.4'.2.9 of the North Anna' Power Station Units 1 and 2 updated Final Safety ~ Analysis Report discusses the service-water-discharge-to-reservoir monitor and states in part ~ "this channel continuously monitors the service water disharge to the service water reservoir".
I Contrary to the above, this channel (RM SW 109) has been inoperable since February 9, 1983, when the sample pump was isolated and tagged out.
This. deviation applies to both units.
RESPONSE
The corrective actions actions taken to prevent further deviations and completion dates for these actions that are identified in the response to the notice of violation in the Inspection Report (84-27) will include the inoperability of this radiation monitor.
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