ML20132B866
| ML20132B866 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 09/18/1985 |
| From: | Branch M, Elrod S, Luehman J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20132B830 | List: |
| References | |
| 50-338-85-22, 50-339-85-22, NUDOCS 8509260326 | |
| Download: ML20132B866 (6) | |
See also: IR 05000338/1985022
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NUCLEAR REGULATORY COMMISSION
UNITED STATES
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101 MARIETTA STREET.N.W.
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Report Nos.:
50-338/85-22 and 50-339/85-22
Licensee: Virginia Electric and Power Company
Richmond, VA 23261
Docket Nos.:
50-338 and 50-339
License Nos.:
Facility Name: North Anna 1 and 2
Inspection Conducted:
ug st 5 - September 1, 1985
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Inspectors:
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M. W.
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enior Resident Inspector
. Dste Signed
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J. G. Lue an Resident Inspector
Oats Signed
Approved by:
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S. Elrod, Section Chief
'Dats Signed
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Division of Reactor Projects
SUMARY
Scope:
This routine inspection by the resident inspectors involved 130
inspector-hours on-site in the areas of Licensee Event Reports, Engineered Safety-
Features walkdown, operational safety verification, monthly maintenance, monthly
surveillance and inspection of spent fuel pool reracking.
Results: One violation was identified in that the licensee failed to comply with
the action statement requirements for Limiting Condition for Operations (LCO)
3.3.3.6.a (paragraph 13).
8509260326 850919
ADOCK 05000338
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REPORT DETAILS
1.
Licensee Employees Contacted
E. W. Harrell, Station Manager
,
A. L. Hogg, Jr. , Quality Control (QC) Manager
G. E. Kane, Assistant Station Manager
M. L. Bowling, Assistant Station Manager
R. O. Enfinger, Superintendent, Operations
J. R. Harper, Superintendent, Maintenance
A. H. Stafford, Superintendent, Health Physics
J. A. Stall, Superintendent, Technical Services
G. J. Paxton, Supervisor, Administrative Services
J. R. Hayes, Operations Coordinator
J. P. Smith, Engineering Supervisor
D. E. Thomas, Mechanical Maintenance Supervisor
E. C. Tuttle, Electrical Supervisor
R. A. Bergquist, Instrument Supervisor
F. T. Terminella, Quality Assurance (QA) Supervisor
R. C. Sturgill, Engineering Supervisor
G. H. Flowers, Nuclear Specialist
J. H. Leberstein, Licensing Coordinator
Other licensee employees contacted included technicians, operators,
mechanics, security force members and office personnel.
2.
Exit Interview
The inspection scope and findings were summarized during the reporting
period with selected individuals identified in paragraph 1.
The licensee
acknowledged the' inspectors' findings.
The licensee identified as
proprietary the Westinghouse technical manual for the Reactor Vessel Level
Indication System (RVLIS) that was reviewed by the inspectors during this
inspection.
However, no proprietary information is contained in this
report.
3.
Licensee Action on Previous Enforcement Matters
Not inspected.
4.
Unresolved Items
Unresolved items were not identified during this inspection.
5.
Plant Status
On August 3, 1985, Unit 1 was removed from service and cooled down to repair
leaks in the 1A Steam Generator.
Approximately 800 tubes were eddy current
tested; 13 were. found to be defective and were mechanically plugged.
The
unit-was returned to service on August 17, 1985, and after power level holds
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for secondary chemistry clean-up, operated at or near 100 percent power for
the remainder of the inspection period.
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Unit 2 ope' ated at or near 190 percent power for the entire inspection
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period.
6.
Licensee Event Report (LER) Follow-Up
The following LERs were reviewed and closed.
The inspector verified that
reporting requirements had been met, that causes had been identified, that
corrective actions appeared appropriate, that generic applicability had been
considered, and that the LER forms were complete.
Additionally, the inspec-
tors confirmed that no unreviewed safety questions were involved and that
violations of regulations or Technical Specification (TS) conditions had
been identified.
-(Closed) LER 339/85-08, Plant Shutdown Required by the TS due to High
Reactor Coolant System (RCS) Leakage
(Closed) LER 338/85-08, Security Breach - Potential for Unauthorized Entry
into the Protected Area.
This event resulted in an inspection by an NRC
Region II physical security inspector.
The results of that inspection are
contained in Inspection Reports 338, 339/85-20.
7.
Follow-Up of Previously Identified Items
Not inspected.
8.
Monthly Maintenance
Station maintenance activities affecting safety-related systems and
components were observed / reviewed to assure that they were conducted in
accordance with approved procedures, regulatory guides, industry codes or
standards, and the facility's TS.
In conjunction with the problem
documented in paragraph 13, the troubleshooting of RVLIS. was closely
followed by the inspectors.
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No violations or deviations were identified in this area.
9.
Monthly Surveillance
The inspectors observed / reviewed TS required testing and verified that it
was performed in accordance with adequate procedures, that test instrumenta-
tion was calibrated, that LCOs were met and that any deficiencies-identified
were properly reviewed and resolved.
In addition to closely following the
problems associated with 1-PT-44.7 documented in paragraph 13, the
inspectors observed the performance of 1-PT-30.2.2, Nuclear Instrumentation
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System (NIS) Power Range Channel II (N42) Functional Test.
The inspectors
questioned the personnel performing the procedure and ascertained that they
clearly understood its requirements.
No violations or deviations were identified in this area.
10.
Engineered Safety Features (ESF) System Walkdown
The following selected ESF systems were verified operable by performing a
walkdown of the accessible and essential portions of the systems on
August 29, 1985:
Unit 1
Auxiliary Feedwater (1-0P-31.2A) dated April 18, 1985
Unit 2
Auxiliary Feedwater (2-0P-31.2A) dated April 25, 1985
No violations or deviations were identified in this area.
11.
Routine Inspection
By observations during the inspection period, the inspectors verified that
the control room manning requirements were being met.
The inspectors
observed shift turnover to verify that continuity of system status was
maintained.
In addition, the inspectors periodically questioned on-shift
personnel relative to their awareness of plant conditions.
Through log review and plant tours, the inspectors verified compliance with
selected TSs and LCOs.
During the course of the inspection, the inspectors verified the maintenance
of Protected and Vital Area security.
Observations include 6 access control,
boundary integrity, and personnel search, escort, and badging.
On a regular basis, radiation work permits (RWPs) were r2 viewed, and
specific work activities were monitored to assure compliance with the RWPs.
Selected radiation protection instruments were periodically checked, and
equipment operability and calibration frequency were verified.
The inspectors kept informed, on a daily basis, of the overall status of
both units and of any significant safety matters related to plant opera-
tions.
Discussions were held with plant management and various members of
the operations staff on a regular basis.
Selected portions of operating
logs and data sheets were reviewed daily.
The inspectors conducted various plant tours and made frequent visits to the
control room.
The inspectors observed work activities in progress and
verified the status of operating and standby safety systems and equipment.
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Valve positions, instrument and recorder readings, and annunciator alarms
were confirmed by the inspectors.
The status of plant housekeeping was also
observed.
During the brief outage for steam generator fube plugging and repair on
Unit 1, the inspectors ' toured the containment to observe housekeeping /
cleanliness and general radiological control practices.
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No violations or deviations were identified in this area.
12.
Spent Fuel Storage Racks (50095)
The inspectors continued to monitor the replacement of the storage racks in
the spent fuel pool.
The inspectors observed selected portions of the new
rack installation, including leveling procedures and associated diving
operations.
The licensee has completed removal of all the old racks and
installation, including drag testing, of 10 of the 16 new racks.
The cell
in location Q-31 failed testing and has been capped by the licensee to
prevent any possibility of installing a spent fuel element in that location.
The inspectors.also monitored the licensee's preparation and inspection of
the vehicles ' intended for use in shipping the old fuel storage racks.
No violations or deviations were identified in this area.
13.
Compliance with Technical Specifications
During a Unit 1 control room tour on August 27, 1985, the inspectors noted
that channel A of the RVLIS was tagged with a work request sticker
(No. 227414) annotated with words to the effect that " channels do not agree
within two percent". When questioned by.the inspectors, the licensee stated
that on August 19, 1985, the channel had exceeded the two percent maximum
deviation between channels allowed by 1-PT-44.7, Power Operated Relief
Valve, Core Cooling Monitor and RVLIS Indication Channel Check. This PT is
used to satisfy the monthly channel check and operability demonstration
requirement of TS 4.3.3.6 and Table 4.3-7.
Base'd upon the inspectors'
review of the TS, the failure of the channel to meet the specified two
percent deviation criterion should have resulted in the plant's entering
action (a) of TS 3.3.3.6 (number of operable accident monitoring channels
less than the total number of channels shown in Table 3.3-13).
A review of
control room logs indicated that .the system's operability had not been
evaluated and the TS required action had not been followed.
Following
consultation with NRC Region II, the licensee was informed that the unit
was in TS 3.0.3, which specifies the steps to be taken when a LCO is not
met.
The licensee entered the action required by TS 3.0.3 and immediately
contacted the RVLIS vendor to obtain assistance in evaluating the system's
operability with regard to the two percent deviation criterion specified in
the RVLIS technical manual.
The vendor evaluated the' licensee's test data
taken on August 19, 1985, and concurred with the licensee that two percent
between channels was a very tight band and indicated that 10 percent would
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be a more realistic deviation limit.
The vendor representative stated that
the two percent criterion was not intended to be a threshold for determining
operability but rather a threshold for initiation of corrective action to
bring the two channels into closer agreement.
Based upon the vendor's
recommendation, the licensee reevaluated the August 19, 1985, data against
the new acceptance criterion and determined RVLIS to be operable, thereby
satisfying the action of TS 3.0.3.
The licensee has also initiated a change
to procedure 1(2)-PT-44.4.
Action (a) of TS 3.3.3.6 requires that an inoperable channel of RVLIS be
restored to operable status within seven days or that the plant be placed in
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hot shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
However, Unit 1 continued to operate
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at power past the seven days without restoring the RVLIS channel to an
operable status.
This failure to comply with the action of the TS. appears
to have been caused, in part, by an improper surveillance procedure
(1-PT-44.7) which was approved in a handwritten form by the Station Nuclear
Safety and Operating Committee (SNSOC) on July 3,1985.
The acceptance
criterion portion of the procedure stated, in part, that "the maximum span
between trains for the reactor vessel level indication system is less than
2% or a work request (WR) has been submitted to recalibrate the system
and the appropriate Action Statement has been entered."
Prior to
the
procedure's approval, the Performance and Test Engineer had lined through
the underlined section of the above quote.
He later attempted to reinstate
the lined-through section by annotating the it with
"0K",
as a
proofreader's notation to ensure that the typist would include the informa-
tion when typing the final . approved procedure.
When the inspectors
questioned the operator who performed the surveillance, he indicated that he
was not familiar with the "0K" notation.
He had assumed that the procedure
writer had determined that failure to meet the two percent criteria did not
make the equipment inoperable and all that was necessary was to submit a WR
for grooming of the system.
The operator also indicated that-he had assumed
the "0K" to be the initials of the person who had lined through the state-
ment.
t
The use of hard-to-follow handwritten procedures was discussed in
paragraph 9 of the inspectors' last report (338, 339/85-18).
It appears
that a quicker turn-around time on final typed procedures or more
restrictions on the use of hand-written procedures- will be necessary to
prevent further. problems in this area. . The inspectors also questioned the
actions of the Control Room Operator and the Senior Reactor Operator, who,
although led by an improper procedure, did not question the operability of
RVLIS when the WR pr'ocedure prompted a decision as to whether the equipment
is necessary to satisfy a TS condition.
The inspectors expressed an
additional concern to the licensee as to the extent of training the
operators had received on the recently implemented post-accident monitoring
TS.
The failure to comply with the action of TS 3.3.3.6 is identified as a
violation 338/85-22-01.
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