ML20128K594
| ML20128K594 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 06/18/1985 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| 85-381, NUDOCS 8507110072 | |
| Download: ML20128K594 (5) | |
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June 18, 1985 VIRGINIA POWER Dr. J. Nelson Grace Serial No.85-381 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-4 Atlanta, Georgia 30323 NPF-7
Dear Dr. Grace:
We have reviewed your letter of May 13, 1985, in reference to the inspection conducted at North Anna Power Station from April 8 to April 12, 1985, and reported in IE Inspection Report 50-338/85-11 and 50-339/85-11.
Our responses to the Notices of Violation are addressed in the attachment.
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 con-tained in the attached pages is true and erurate to the best of my know-Jedge and belief.
Very truly yours, O
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W. L. Stewart Attachment cc:
Mr. Roger D. Walker, Director Division of Project and Resident Programs Mr. Edward J. Butcher, Acting Chief Operating Reactors Branch No. 3 Division of Licensing Mr. M. W. Branch NRC Resident Inspector North Anna Power Station kO J
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RESPONSE TO NOTICE OF VIOLATION ITEM REPORTED DURING NRC INSPECTION CONDUCTED FROM APRIL 8 TO APRIL 12, 1985 REPORT NOS. 50-338/85-11 AND 50-339/85-11 NRC COMMENT:
10 CFR 50.54(a)(1) requires Virginia Electric and Power Company (VEPCO) to implement their Quality Assurance Program described in its Safety Analy-sis Report.
Section 17.2.6 of the VEPCO Quality Assurance Program requires that procedures, instructions, and drawings be reviewed to assure they are adequate and contain quality require.ments. Administra-tive Procedures 16.8, 5.3 and 5.4 further amplify review requirements.
Contrary to the above, the reviews of Electrical Maintenance Procedures EMP-P-EP-8 and 8A were inadequate in that several errors and inaccuracies
'(typographical errors, figure numbers not compatible with text, and fig-ures difficult to read) were identified.
This is a Severity Level V Violation (Supplement 1). Repeat of similar type violation 338/84-37-03.
RESPONSE
- 1. ADMISSION OR DENIAL OF THE ALLEGED VIOLATION:
This violation is not correct as stated since it is our interpretation that this is not a repeat of a similar type of violation.
- 2. REASON FOR THE VIOLATION:
The procedure review and approval process requires that the new or revised procedures be submitted in draft form for supervisory reviews and approval by the Station Nuclear Safety and Operating Committee (SNSOC).
When approved, the precedure goes through a typing and proofreading process until issued in its final form. The editorial reviews conducted during the typing and proofreading process were not adequate. In addition, copy quality was not verified as adequate pri-or to issuing the copy of the procedures for use. However, the technical review of the procedures by station supervision and the SNSOC were adequate.
Therefore, the problems that have been identified are minor and admin-istrative in nature and have not affected the performance of the pro-cedures.
- 3. CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED:
Administrative Procedure 5.4," Processing New and Revised Procedures, Deletion of Procedures," was revised to better control the procedure development and review process. This revision was completed but not yet implemented (see Virginia Power letter dated March 21, 1985, Seri-l J
al No.
690A) when EMP-P-EP-8 and 8A were approved. Also the impor-tance of procedures was emphasized to station supervision by memorandums from station management dated February 28, 1985 and March 20, 1985. The first memorandum provided managements expectation for high quality procedures and detailed guidelines for development of procedures. The second memorandum summarized the changes to ADM 5.4.
These revisions to ADM 5.4 were reviewed and assessed with the inspec-tors at the time of the inspection and were found to be adequate.
Additional revisions to improve ADM 5.4 have been initiated and are currently scheduled to be implemented in July,1985.
- 4. CORRECTIVE SKIPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
We have reviewed the previous violation (50-338/84-37-03) and com-pared it to the events reported herein.
The violation in inspection report 84-37 (50-338/84-37-03) was not similar to the violation in this inspection report. The* previous vio-lation addressed errors in PT 94.5 and PT 94.7 that indicated inade-quate technical review. Corrective actions for the root cause of this problem had been developed but were not yet completely implemented by the time EMP-P-EP-8 and 8A were developed and approved. Nevertheless, the technical review was thorough and adequate and the several admin-istrative errors noted are not considered significant to the successful implementation of the procedures.
In order to preclude further administrative review problems, the fol-lowing corrective actions will be taken:
1.
An evaluation will be conducted to determine the need for additional procedure writers training which will address reviewing procedures for administrative accuracy. Training will be initiated as necessary based on the results of the evaluation. The evaluation will be completed by July 31, 1985.
2.
EMP-P-EP-8 and 8A will be revised by September 1, 1985.
- 5. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Corrective actions have been outlined in paragraph 4.
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- RESPONSE TO NOTICE OF VIOLATION ITEM REPORTED DURING NRC INSPECTION CONDUCTED FROM APRIL 8 TO APRIL 12, 1985 REPORT NOS. 50-338/85-11 AND 50-339/85-11 NRC COMMENT:
10 CFR 50.54(a)(1) requires Virginia Electric and Power Company (VEPCO) to implement their Quality Assurance Program described in its Safety Analy-sis Report.
Section 17.2.5 of the VEPCO Quality Assurance Program requires that activities affecting quality be performed in accordance with instructions, procedures, or drawings.
Contrary to the above, completion steps on Mechanical Maintenance Proce-dure MMP-C-GV-1.2 were not initialed as required by Administrative Proce-dure 16.8, Use of Procedures During Maintenance.
This violation is applicable to Unit 1 only.
This is a Severity Level V 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 due to personnel error resulting from improper attention to procedural compliance during performance of work utiliz-ing Mechanical Maintenance Procedure MMP-C-GV-1.2.
It should be not-ed that the intent of ADM 16.8 for supervisory acceptance was met.
Each step in the procedure was initialed except for step 6.2 under Limits and Precautions and step 9.1 under acceptance. However, the signature blank under step 9.1 was fully executed and served to docu-ment that the acceptance criteria was met. Also, it should be noted that the completion of step 3.1 was not required to be performed by the person initialing the signoff step. The intent of the requirement was only that the Work Order be issued prior to proceeding.
- 3. CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED:
As a result, the station has and will continue to provide more super-vision and training on the importance of following station procedures to maintenance support groups, i
't
- 4. CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
l No further corrective actions are planned.
- 5. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Corrective actions outlined in paragraph 3 above.
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