ML20113D945
| ML20113D945 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 02/12/1985 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20113D940 | List: |
| References | |
| 85-034, 85-34, NUDOCS 8504150717 | |
| Download: ML20113D945 (3) | |
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c 85 FEB27 AID: 18 February 12, 1985 Mr. J. Nelson Grace Serial No: 85-034 Regional Administrator N0/JHL:pa 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 January 14, 1985, in reference to the inspection conducted at North Anna. Power Station between October 22 and October 26, 1984 and reported in IE Inspection Report Nos. 50-338/84-41 and 50-339/84-41. Our response to the notice of violation is attached.
i We'have determined that no proprietary information is contained in the report.
Accordingly, Virginia Power has no objection to this inspection report being made a matter of public disclosure.
The information obtained in the attached pages is true and accurate to the best of my knowledge and belief.
Very truly yours.
W. L. Stewart Attachment cc:
Mr. Roger D. Walker, Acting Director Division of Reactor Projects Mr. James R. Miller, Chief Operating Reactors Branch No. 3 Division of Licensing Mr.-M. W. Branch NRC Resident Inspector North' Anna Power Station 8504150717 850307 PDR ADOCK 05000338 G
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RESPONSE TO NOTICE OF VIOLATION ITEM REPORTED DURING NRC INSPECTION CONDUCTED FROM OCTOBER 22 TO OCTOBER 26, 1984
' INSPECTION REPORT 50-338/84-41 AND 50-339/84-41 NRC COMMENT:
Virginia Electric and Power Company's letter to Harold R.
Denton, Director, Offic'e of Nuclear Reactor Regulation, dated December 15, 1980, entitled
" Response to NUREG-0737 Post-TMI Requirements", states in part, that at North Anna, administrative controls will be in effect for Item I.C.6 of NUREG-0737 until procedures are reviewed and revised.
This will be completed by June 1, 1981.
Nuclear Regulatory Commission Order Confirming Licensee Commitments on Post-TMI Related Issues 7590-01, in the Matter of Virginia Electric and Power Company (North Anna Power Station. Unit Nos. I and 2) requires that the licensee implement procedures to verify correct performance of operating activities (Item I.C.6 of NUREG-0737).
10 CFR 50 Appendix B, Criterion V requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.
Contrary to the above, Operating Procedure 2-OP-lE " Containment Integrity Checklist" ' was inadequate in that test connection valves associated with and upstream of containment purge isolation valves were not required to be independently verified closed.
This is a Severity Level IV violation (Supplement I).
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 an administrative oversight.
The Operating Procedure Checklist required the testing of the Containment Purge Valves by a general test method rather than by detailing a step-by-step procedure.
The general test method did not require the independent verification of the test connection valve position as normally required.
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CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED:
When notified of this discrepancy, the test connection valves were independently verified to be closed.
The Containment Integrity Startup Checklist (1-OP-1E and 1-0P-2E) procedures were revised to delete the step specifying the general method for testing the Containment Purge Valves.
In place of this step is a requirement to perform 1-PT-61.3.1 or 2-PT-61.3.1.
At this time, the referenced periodic tests are being revised to more clearly specify the required testing and to require double verification'of valve position. These revisions will be completed prior to the next required test.
4.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
This event is considered to be an isolated event.
Therefore, no further corrective actions are required.
5.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
The indicated corrective actions will be completed before the next required test but no later than April 1, 1985.
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