ML20134N135
| ML20134N135 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 08/20/1985 |
| From: | Branch M, Elrod S, Leuhman J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20134N123 | List: |
| References | |
| 50-338-85-18, 50-339-85-18, NUDOCS 8509050015 | |
| Download: ML20134N135 (14) | |
See also: IR 05000338/1985018
Text
._
.
53 cat
.
UNITE *J STATES
./
%.
NUCLEAR REGULATORY COMMISSION
.7 "
I ,^
REGION li
h
N
101 MARIETTA STREET.N.W.
2
ATLANTA. GEORGI A 30323
\\...../
Report Nos.: 50-338/85-18 and 50-339/85-18
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: July 8 - August 4, 1985
h-
d.fl
Wo 41 19.(4 6
Inspectors:__
w
M. W. Brpcpenior Resident Ins (v'ctor
@teSigned
A>-46% L
.
L
2
tR N I
J . 'G . g
/,' Re ident Inspector [/
gite Sign'ed
Approved by:
,
4
Ag/.,r[ M,/9/I
S. v'A.E rroTi, 'Se'ction Chi e f
Date Signe'd
Division of Reactor Projects
SUMMARY
Scope: This routine inspection by the resident inspectors invol/ed 205 inspector-
hours on site in the areas of licensee event reports (LERs), previously identi-
fied items, licensee action on previous inspection findings, engineered safety
features (ESF) walkdown, operational safety verification, monthly maintenance,
monthly surveillance and inspection of spent fuel pool (SFP) reracking.
Results: One violation was identified: failure to properly perform surveillance
requirements, paragraph 9.
Additional . examples of previous violation 338,
339/85-16-02, failure to follow procedures, were identified; paragraphs 5, 6, 11,
13, and 17.
.
l
8509050015 850821
ADOCK 05000338
G
-
- - - -
-
-
-
- - -
-
-
. -
-
-
-
-
.
.
REPORT DETAILS
.
1.
Persons Contacted
Licensee Employees
- E. W. Harrell, Station Manager
A.
G.~ Hogg, Jr. , Quality Control (QC) Manager
- G. E. Kane, Assistant Station Manager
- E. R. Smith, Assistant Station Manager
R. O. Enfinger, Superintendent, Operations
- J. R. Harper, Superintendent, Maintenance
- 0. E. Hickman, Jr. .. Supervisor, Health Physics (HP)
- L.
L'. Edmonds, Superintendent, Nuclear Training
J. A. Stall, Superintendent, Technical 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. Termine11a, Quality Assurance (QA) Supervisor
R. C. Sturgill, Supervisor, Engineering
G. H. Flowers, Nuclear Specialist
- J. H. Leberstein, Licensing Coordinator
Other licensee employees contacted included . technicians, operators,
mechanics, security force members and office _ personnel.
- Attended exit interview
2.
Exit Interview
The _ inspection scope and findings were summarized on August 2,- 1985, with
those persons indicated in paragraph
1.-
The licensee acknowledged the
inspectors findings.
The' licensee did not identify.as proprietary any of
the material s ' provided to or reviewed by the- inspectors during this
inspection.
3.
Licensee Action on Previous Enforcement Matters
-(Closed) Violation . 338,339/84-41-03:
Failure to Include Containment Purge
. Test Valves in Independent Verification Checklist. , The inspectors reviewed
the licensee's response, serial number 85-034, dated February 12, 1985, and
determined that the specified corrective action appeared to be prudent and
proper.
Additionally,_ the inspectors _ reviewed- 1(2)-PT-61.3.1 -dated
March 14, 1985, . and verified the revision was completed as specified in the
' licensee's1 response.
q
,-
.
.
2
(Closed) Infraction 339/80-31-01:
Failure of Station Nuclear Safety and
Operating Committee (SNSOC) to Review a Temporary Modification Prior to
Implementation.
The inspectors reviewed the licensee's response dated
January 12, 1981, and based on the licensee response and current licensee
practice, contained . in Station Administrative Procedure ( ADM) 14.1 dated
May 9, 1985, find the corrective action acceptable.
(Closed) Infraction 338/80-26-01 and 339/80-31-05:
Failure of SNSOC to
Review Vendor Manuals When Referenced as Part of a Station Procedure. In a
letter dated February 19, 1981, Mr. R. C. Lewis of the NRC withdrew the
infraction stating that, although it was not a requirement to include vendor
manuals in the procedure approval process, .it was the NRC's position that
vendor manuals must be controlled. Control of vendor manuals continues to
be of concern to the NRC.
Generic Letter 83-28, which addressed the
anticipated transient without scram event at Salem, includes a section on
control of vendor manuals and VEPC0 has committed to improvements in this
area.
(Closed) Violation (339/80-39-05):
Failure to Implement Fire Protection
Modification Requirements of Operating License. This item is closed since
it was mistakenly closed-in Inspection Reports 50-338/81-18 and 50-339/81-15
as Item 339/80-39-03.
Iten 339/80-39-03 was legitimately closed in report
339/84-19.
4.
Unresolved Items
An unresolved item (UNR) is a matter about which more information is
required to determine whether it is acceptable or may involve a violation or
deviation.
One unresolved item was identified during this inspection and is discussed
in paragraph 14. Additional information concerning previous unresolved item
338, 339/85-16-03 is discussed in paragraph 13.
5.
Plant Status
Unit 1
Unit 1 operated at or near 100 percent power during the majority of the
inspection period; however, on August 3,1985, the unit was shut down. to
inspect and repair tube leakage in the-1A steam generator.
Earlier in the month on July 22, 1985, the plant developed a primary leak
,
that placed it.in the action statement for high unidentified leakage. The
i
leak was' subsequently found to be in a primary sample line which -was
-isolated, satisfying the action statement and preventing plant shutdown.
During this event the licensee discovered that a sample system trip valve
1-TV-SS-109B had been left open.
The mispositioning .of this valve allowed
~
the licensee to identify the leak, since, if the valve had been shut there
would have been no path from the primary to the sample line failure. This.
.I
.:.
7
.
.
3
,
is a further example of failure to follow procedure, see Inspection Report
l
Nos. 50-338, 339/85-16-02.
.
Unit 2
Unit 2 operated at or near 100 percent power during most of the inspection
period. However, on July 25, 1985, with the unit at full power, the unit
operator noted an increase in containment gaseous activity and requested a
containment . entry be made to determine - the source.
At 6:50 a.m.,
the
inspection team reported that the leak was coming from the A loop room and
at 7:00 a.m., 'a primary leak rate. calculation determined the unidentified
primary leak rate to be 5.25 gallons per minute (gpm). A power reduction
was initiate.d at 7:39 a.m.,
and at 4:48 p.m. the unit was placed in mode 3
after attempts to. repair the leak failed.
The leak was determined to be
coming from the packing' area of valve 2-RC-6 which is a two-inch manual
l-
isolation valve . in the bypass line around the A cold- leg stop valve.
l
Previous repairs were accomplished using furmanite injections, because the
!
valve was non-isolable from the reactor vessel, and replacement of the
packing would require going to cold shutdown and draining the loop. Valve
,
repairs were completed on July 28, 1985 by reinjection with- furmanite and
-
!
the unit was returned to power on July 29, 1985.
During evaluation of the above event, the inspectors determined that the
reporting requirements of 10 CFR 50.72(b)(1)(A) as clarified on page 33 of
'
NUREG-1022, Supplement No. I were not met.
Specifically, the licensee did
not make the one hour- notification to the NRC Operations Center upon the
<
initiation of a Technical Specification (TS) required plant shutdown. The
!
licensee had previously determined that the initiation of plant shutdown
meant.the point at which the determination is made to actually shut down the
,
reactor and not the point when power. reduction is initiated to allow
maintenance.
The determination to actually shut down-the plant did not
,
i
occur until 4:40 p.m.
on July 25, 1985; however, power reduction was
initiated at 7:39 a.m., with the notification being made at 1:00 p.m. of the
(
same day.
The inspectors discussed the current interpretation of what
~
constitutes initiation of plant shutdown.with the licensee; consequently,
the licensee agreed to apply this criteria to future events.
Additional _1y, during evaluation of reporting requirements for the above
r
event, the inspectors reviewed the station ; Emergency Plan (EP) and ques-
l
tioned the basis of the EP and Emergency Plan Implementing Procedures (EPIP)
I
that ties Notification of Unusual Events (NOVE) -to the moment of plant
j
shutdown and not to the initiating event that requires ~ the shutdown.
t
Specifically, NUREG-0654, revision 1,'gives examples-of initiating condi-
.
tions ,of an unusual event -(UE), one example being exceeding primary leak
>
rates specified in TS, another ~ being other plant conditions. requiring
shutdown per TS. However, the North Anna EP and. EPIP 1.01, revision 6,
makes the declaration of UE for several events upon entering mode 3 (i.e.,
plant is shutdown), and not the onset of the condition that requires the
shutdown. This item requires further review and'is identified as Inspector
Followup Item-.(IFI) 338,339/85-18-01.
.
<
w
_.
p
!
.
.
4
6.
Licensee Event Report (LER) Followup
The folicwing LERs were reviewed and closed. The inspector verified that:
reporting requirements had been met, causes had been identified, corrective
actions appeared appropriate, generic applicability had been considered, and
the LER. forms were complete. Additionally, for those reports identified by
an asterisk, a more detailed review was performed to verify that:
the
licensee had reviewed the event, corrective action had been taken, no
unreviewed safety questions were involved, and violations of regulations or
TS conditions had been identified.
- 338/81-42, Failure of One Volume Control Tank (VCT) Level Transmitter Could
Cause Loss of Suction to Charging Pumps
- 339/83-16, Containment Isolation Valves Indicating Both Open and Closed
- 338/84-03, Turbine Trip-Reactor Trip From Spurious Electrohydraulic Control
Reservoir Low Level Signal
- 338/80-08, Control Panel for Control Room Air Conditioning Chiller Units Not
Qualified to Seismic Category I Requirements
338/85-01, Motor Driven Fire Pump Out of Service for Greater Than Seven Days
- 338/83-42, Momentary Loss of Power to Inverter 1-I Causes Turbine / Reactor
Trip
- 338/83-58, Incorrect Alignment of High Head Safety Injection Pump Breakers
and Control Switches Due to Inadequate Procedural Guidance
^338/84-02, Inadvertent Single Train Emergency Core Cooling System (ECCS)
Actuation in Mode 5
(0 pen) LER 338/84-13, revisions 0 and 1, Liquid Waste Discharge Without
Demineralizer_ Treatment. This report documented the discharge of liquid
radwaste without treatment, with projected doses to the unrestricted areas
being in excess of the -limits specified in TS 3.11.1.3.
Two specific time
intervals were discussed in the report, July 11, 1984, to September 10,
1984, and September 10, 1984, to September 25, 1984.
During the first
period, the _ liquid waste mixed bed clarifier demineralizers were not in
service as required and, during the second period, a demineralizer was
placed-in service, however,.it did not contain any resin. On June 1,1985,
with projected _ doses to the unrestricted areas within TS limits and, with a
health physics recommendation to use the demineralizers, liquid radwaste was
again discharged without treatment. In this-case, an improper valve lineup
allowed much of the liquid clarifier ~ flow to bypass the operational
demineralizer.
As_a result of the first two problems, the licensee
committed to instructing operations personnel on the importance of verifying
clarifier demineralizer status and reviewing operating procedures _ for
adequacy. The' third incident, though not a violation of TS, reinforced the
.
..
_
,
F7
~
l
.
.
5
need to complete these actions. The inspectors informed the licensee at the
monthly exit meeting that the implementation of the corrective actions will
be carefully reviewed.
This is a further example of
failure to follow
procedure as identified in Inspection Reports 50-338, 339/85-16-02.
(Closed) LER 338/81-42, Failure of One VCT Level Transmitter Could Cause
Loss of Suction to the Charging Pumps.
The scheduled corrective action
indicated in the report has been taken and resulted in design change (DCP)
82-S21, VCT Level Circuitry Modifications, which has been completed.
(Closed) LER 339/83-16, Containment Isolation Valves Indicating Both Open
and Closed.
In addition to making the required repairs to the valves and
conducting inspections of other containment isolation valves, the licensee
has implemented a preventative maintenance inspection program to detect any
further problems of the kind discussed in the report.
The inspection
program will be performed every refueling outage.
(Closed) LER 338/84-03, Turbine Trip-Reactor Trip From Spurious EHC
Reservoir Low Level Signal.
The licensee conducted a flush of the EHC
system and replaced various components such as filters. The condition of
the system fluid as well as the condition of the removed filters supported
the licensee's conclusion that the unloader malfunction was a result of EHC
fluid particulate contamination. The licensee's inspection of the system
also resulted in some. suggestions for the long-term improvement of system
condition; however, none of these suggestions were felt to need immediate
implementation.
(Closed) LER 338/80-08, Control Panel for the Control Room Air Conditioning
Chiller. Units Was Not Qualified to Seismic Category I Requirements.
In a
letter dated January 31, 1980, Stone and Webster. Engineering Corporation
informed the licensee of the actions that needed to be taken to qualify
these control panels. These recommendations were the basis-for DCP 80-504,
Control Room Chiller-Seismic Modification, which has been completed by the
licensee.
(Closed) LER 338/93-42, Momenta ry loss of Pcwer .to Inverter 1-1 Causes
Turbine / Reactor Trip. The licensee committed to an revising the Abnormal
Procedure associated with loss of power to an inverter; however,-after more
evaluation, -it was felt that it would be more effective to revise the
Operating Procedure (0P). The inspectors have reviewed 1 and 2-0P-26.5 and
verified that a note has been added to alert the operator of -the conse-
quences of removing an inverter power supply from service.
(Closed) LER 338/83-58, Incorrect Alignment of High Head Safety Injection
Pump Breakers and Control Switches. Due to : Inadequate Procedural Guidance.
'The inspectors have verified that the licensee has revised the~ OP associated
with the alignment of breakers and control switches with these pumps (1 and
2-0P-8.1).
Additionally, the licensee.has revised the associated Mainte-
.)
nance Operating Procedures.
l
- -
'
r-
1
.
.
e
6
(Closed) LER 338/84-02, Inadvertent Single Train ECCS Actuation in Mode 5.
The licensee has developed a procedure for the removal of the Solid State
Protection System (SSPS) output fuses, IMP-P-SSPS-01, SSPS Fuse Removal and
Replacement, and has implemented the procedure by specifically referencing
the removal of the fuses in the appropriate OP. Replacement of the fuses is
verified.by performance of SSPS performance-tests.
7.
Followup of Previously Identified Items
(0 pen) IFI 338/81-05-05:
Installation of Larger Cable for Pressurizer
Heater Power Supply.
The licensee has formulated an engineering work
request (EWR) to- accomplish the work.
Presently, EWR 81-348B is scheduled
to be implemented during the upcoming Unit I refueling outage.
(Closed) IFI 338/80-30-01 and 339/80-29-05: Lamp Testing of Safety-Related
Displays. The inspectors reviewed this issue and are satisfied that lamp
testing presently . being performed by the licensee is consistent with
existing equipment or will be modified as part of the detailed control room
design review specified in Supplement I to NUREG 0737.
(Closed) IFI 338/80-30-02 and 339/80-29-06: Need for QA Review of Construc-
tion Work Accomplished During the Operational Phase. During routine design
i
'
change and plant maintenance reviews, the inspectors verified that adequate
GC inspection requirements for the verification of construction activities
.
were specified.
l
(Closed) IFI 339/80-31-02:
Completion sof Design Change 80-S49.
The
inspectors verified through review of QA records that the design change was
,
!
completed and forwarded to station records on February 26,-1982. Addition-
ally, the condition that the design change was to correct no longer existed
after the modification.
l
(Closed)' IFI 339/80-31-03:
Control of Setpoint' Changes. The inspectors
j
reviewed the current practice of requesting and implementing changes to the
i
North Anna Setpoint Document as specified in ADM 6.8 dated August 31, 1983,
'
and found it ' met current- industry and regulatory requirements.
(Closed) IFI 339/80-31-04:
Scheduling of 18 Month Surveillance Tests. The
inspectors, during the monthly surveillance review, verified that the
l '
requirements of TS were met. Additionally, during 1984, VEPC0 contracted an
independent consultant to accomplish a review of the surveillance program to
b
ensure the requirements of TS are being met.
(Closed) IFI 338/80-26-02 and 339/80-31-06:
Followup Licensee Action on
Unqualified Level Transmitter for Containment Sump - LER 338/80-71. Through
a review:of QA records, the inspectors verified that equipment specifiod as
being _ not qualified for' a harsh environment was ~ relocated by design change
DC'80-S64'to the rack rooms which are outside the accident envelope.
i
F
l
.
.
7
(Closed) IFI 50-338/80-21-20 and 50-339/80-22-20:
Determination of Sample
Hood Face Velocities. After evaluating this. item in the Regional Office and
utilizing the results of the latest region based inspection, this item was
determined to require no additional specific NRC followup.
8.
Monthly Maintenance
Several station maintenance activities affecting safety-related systems and
components were observed / reviewed to ascertain that the activities were
cor. ducted in accordance with approved procedures, regulatory guides and
industry codes or standards, and in conformance with TS.
Maintenance
activities . observed included:
transferring spent fuel pool filters to
casks, corrective ~ maintenance of system . radiation monitors, repair of the
packing in valve 2-RC-6, and mechanical cleaning of service water piping.
No violations or deviations were identified in this area.
9.
Monthly Surveillance
The . inspectors observed / reviewed TS required testing and verified that
testing was performed in accordance with - adequate procedures, that test
instrumentation was calibrated, that limiting conditions for operation (LCO)
were met and that any deficiencies identified were properly , reviewed and
resolved.
The inspectors observed the performance of 1-PT-36.1A, Reactor
Protection and Engineered Safeguards Function Logic Test (Train A), and had
two comments: First, the procedure has recently been revised and the rough
draft of the ' newly approved procedure is presently being used by the
technicians to perform the test. The inspectors' understood the need to use
the draft procedure while a final is being typed; however, the SNSOC needs
to be sensitive to the quality of the draft procedures they approve for
temporary use.
In this case, there were numerous lineouts and steps added
with arrows directing where new steps should be added to the procedure-
making the procedure very hard to follow. The second comment concerns the
required values for the undervoltage coil voltage meter reading.
In the
notes following steps 4.3 and 4.9, it is.specified as 40 plus or minus two
Vdc; while in step 4.5.2, it .is required to be- 42 plus or minus two Vdc.
The. voltage, 40 Vde, required by this procedure is a target voltage which is
not that critical. However, the licensee agreed to alter the procedure to
reflect the 40 plus or minus two Vdc.
On July 9, 1985,-licensee personnel performed 1 and 2-PT-85, DC Distribution
. System. These performance tests are required to be performed every seven
- days to meet the surveillance requirements of TS 4.8.1.1.3.a.
Due to a
scheduling error, these tests were not performed again until July 19, 1985.
The time elapsed exceeds that allowed under Units 1 and 2 TS 4.0.2 which
requires, 'in part, that each' surveillance requirement be _ performed within
the_ specified interval with the max! mum extension not to exceed 25-percent
of the interval. The failure to perform the surveillance requirements in
the allcwed time interval is identified as Violation 338,339/85-18-02.
m
3
0
.
8
10.
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 1, 1985.
Unit 1-
RWST (1-0P-7.7A dated May 3,1985) and NA0H Chemical Addition (1-0P-7.8A
dated June 11,1985)
Unit 2
RWST (2-0P-7.7A dated May 3,1985) and NA0H Chemical Addition (2-0P-7.8A
dated June 11,1985)
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 t,Wng met.
In addition, the
inspectors observed shift turnover to verify _that continuity of system
status was maintained.
The inspectors periodically questioned shift
personnel relative to their awareness of plant conditions.
Through log review and plant tours, the inspectors verified compliance with
selected TS and LCO.
During the course of the inspection, observations relative to Protected and
Vital Area security were made,_ including access controls, boundary integ-
rity, search, escort and badging.
On a regular basis, radiation work permits (RWP) were reviewed, and the
specific work activity was monitored to assure the activities were being
conducted per the RWP.
Selected radiation protection instruments were
periodically checked, and equipment operability and calibration frequency
were verified.
The inspectors kept informed, on a daily basis, of overall status of both
units and of any significant safety matter related to plant' operations.
Discus'sfons . were held with plant inanagement 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.
Observations'. included:
witnessing work activities in
progress; verifying the status of operating and standby safety systems and
equipment; confirming valve positions, instrument and recorder readings,
annunciator alarms, and housekeeping.
)
r
.
.
9
~ During a routine inspection of the plant, the inspectors found a piece of
measuring equipment marked NQC-PSE 2676. The calibration sticker indicated
the equipment had been due for calibration March 7,1985.
This resulted
from a failure to follow ADM 12.0 (August 23,1983) and is a further example
of failure to follow procedure as identified in Inspection Reports 50-338,
339/85-16-02.
No violations or deviations were identified in this area.
12. Nuclear Instrumentation System Flux Rate Trip Setpoints
A potential problem with compliance to the guidance of Westinghouse
Technical Bulletin NSID-85-13, dated may 28, 1985, was identified by the
licensee.
This bulletin informed Westinghouse plants with positive and
negative flux rate reactor trips that there appeared to be a problem with
the way licensees were setting these trips. The licensee has requested
further information from Westinghouse concerning this bulletin.- The
licensee's present position is that they are conforming with the TS dealing
with the flux rate trip setpoints. However, as a precautionary measure, the
present core loads were re-analyzed and _it was determined that adequate
safety margins exist despite the fact that the flux rate trip setpoints are
not set in accordance with this new vendor guidance.
This issue is being
evaluated on a generic basis by both NRC Region II and NRC Headquarters.
No violations or deviations were identified in this area.
13. Administrative Procedures
During this inspection period. selected Station Administrative Procedures
were reviewed.
Based on the review, the inspectors had the following
comments:
a.
ADM 2.19,
ISI' [ Inservice Inspection] Personnel Certification and
Training for Visual Examinations VT-2, VT-3, . and VT-4 (September 27,
1984), -in part requires that the station maintain the' qualification
records of the visual inspectors and those of the ISI supervisor. A
review of selected training records revealed that some inspection
qualification records were missing or incomplete.
The subject of
training records is discussed further in paragraph 14.
b.
ADM 19.27, Control and Use of Operator Aids (August 8,1983), requires
quarterly audits of the operator aid -log and prescribes the required
documentation of these audits. The audits are not being documented as
required, making it impossible to determine if the audits are being
done.
.
.
c.
ADM 20.32, 10 CFR 19 Posting Requirements. In addition to the required-
1
posting locations of this procedure, NRC Form 3s are posted in other
areas of the plant including the training ' building. and - records
building.
In.the case of the records building,'the posted form was
l
d
. .
- -
-
.
-
-
.
-
-
-
.
-
-
-
- -
.
.
.
-
-
rm
.
..
10
-found to be outdated, subsequently, licensee management committed to
removing or updating the form.
d.
ADM 19.17,
Incore Moveable Detector Background Characterization
(October 31, 1983), _ specifies a required use of the axial power
distribution monitoring system (APDMS).
By Technical Specifications
the APDMS .is utilized only when reactor power is above Pm (defined in
TS as ",surv'eillance power level" - it is used in a mathematical
formula) because of problems with the APDMS. Core reloads are designed
to ensure Pm > 100 percent power, thus, eliminating the need for the
monitoring system.
In order to maintain the number of ADM at a
minimum, the inspectors have recommended to the licensee that this
procedure be cancelled or placed in reserve until needed.
e.
ADM 6.28, Control of -Vendor Manuals, Vendor Files and Interface
(October 25, 1984), and the referenced Document Control Procedure
(DCM-41), cover the updating of vendor manuals and imply the require-
ment to update drawings as part of the manual. This item will be
looked at further as part of Unresolved Item 338,339/85-16-03.
Items a. and b. are further examples of the violation for failure to follow
procedure identified in Inspection Reports 50-338, 339/85-16-02.
14.
Training Records
The inspectors, in reviewing completed copies of 1-PT-79.1, Hydraulic
Snubber Accessible for Visual Inspection During Reactor Operations, and
1-PT-79.2, Snubber Not Accessible for Visual Inspection, checked the
training records of selected visual inspection personnel. The inspectors
found that some visual inspection qualification records were satisfactory
while others were incomplete or missing.
Based on these findings, the
inspectors reviewed the licensee's commitments in the area of collection and
storage of records.
The licensee is committed - to ANSI N45.2.9-1974 as
endorsed by Regulatory Guide 1.88 (Rev. 2,
10/76) and as clarified by
Virginia Electric and Power Company Topical Report, Quality Assurance
Program Operations Phase (VEP-1-4A) Amendment Four, October 1982.
ANSI
N45.2.9-1974Property "ANSI code" (as page type) with input value "ANSI</br></br>N45.2.9-1974" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. requires that the current individual plant staff member
qualifications, experience, training and retraining records be maintained as
lifetime records. The standard further requires, in Section 5.3, the method
of storage to have a specified filing system and a method of verifying
records received and removed. Section 5.7 of the standard specifies the
records should be audited periodically.
a.
A review of North Anna Power Station Training Administrative Guideline
6.2.14,
dated December 30, 1985, Records Management for Nuclear
Training Records, found that this procedure does not appear to be
prescriptive enough in setting guidelines for the maintenance of
individual training . records.
Review of additional training records
'found that training instructors in individual disciplines maintain
F
i
,
.
11
their own filing system. For example, in the area of General Employee
Training, it appears that all records are placed in the individual's
file.
In the chemistry area some records are kept in the individual's
file, while others are kept in the Chemistry Department retraining
records. Neither method is incorrect; however, in order to comply with
the standard and make training records auditable, one documented and
approved method should be used,
b.
The Training Department has a formal system for documenting the records
placed in an individual's training records.
Interviews conducted by
the inspectors revealed that though this receipt system exists, formal
and timely transmittal of training documentation from individual
station departments is not always occurring.
By Administrative
Procedures the Training Department is tasked with maintaining indivi-
dual training records, but the records will only be useful if indivi-
duals and their supervision forward all required documentation for
proper storage. A major problem area in this regard appears to be the
documentation of training received by licensee personnel at vendor and
other offsite training facilities.
The prevalent practice in these
types of training is that the individual receives his or her training
-
completion certificate,.a copy of which may or may not be forwarded to
tne Training Department.
Further, if a copy of such a record is
forwarded to the Training Department, the established formal trans-
mittal system used by the station for other quality records is frequ-
ently not used.
Finding no. two of the licensee's Quality Assurance
Audit 83-16 touched on this subject but did not examine it closely. In
that instance, it was found that various records were missing from
individual training records. The resolution was to obtain copies of
the missing records and bring the training records up to date. This
resolution solved the individual problems; however, it did not address
the larger question of formal overall records accountability which is
needed to ensure such instances are not repeated.
Overall accountability is currently being addressed by some individual
training instructors and, based on the inspector's comments, the
licensee's Training Department intends to make this a comprehensive
program.
c.
Both VEP-1-4A and the North Anna Power Station Updated Final Safety
Analysis Report, Appendix 3A, need to be revised to include the
training building records storage area as an approved storage area for
quality records. Presently, only the station records building inside
the Protected Area is addressed.
The .above items are of concern to the inspector and is identified as
Unresolved Item 338, 339/85-18-05 pending further information to be
provided by the licensee and investigation by the inspectors.
r
3
.
12
l
15. Station Emergency Plan
North Anna EP, Table 4.1A, no.12 and EPIP 1.01, Tab E, specify 2.4 E5
counts per minute (cpm) as the Notification of Unusual Event initiating
condition for the clarifier effluent and 6.8 E4 cpm as the same initiating
condition for the condenser air ejector monitor.
The present radiation
monitor alarm settings for the clarifier effluent monitor place the
initiating condition level between the high and high-high alarm setpoints.
In the case of the air ejector radiation monitor, the -initiating condition
value is below both the high and high-high alarm setpoints. The air ejector
alignment could create a situation where the plant reaches the threshold for
NOUE without even an alarming radiation monitor. It should be noted that at
the time the .present air ejector alarm setpoint values were input, the
recorded monitor value was 9.0 E4 cpm, which was above the EP initiating
condition for NOUE and below the alarm setpoints.
In. a related matter, the North Anna TS states that . radioactive liquid
effluent monitoring instrumentation channel alarm / trip setpoints shall be
determined and adjusted in accordance with the OFFSITE DOSE CALCULATION
MANUAL (0DCM). Using the methodology in the ODCM, the inspectors calculated
the maximum alarm / trip setpoint for the clarifier effluent radiation monitor
and compared that value with the setpoint presently in use.
The setpoint
presently being used is about two orders of magnitude higher than that
allowed by .the ODCM method.
Licensee HP personnel explained to the
inspectors that high background radiation levels in the area of the detector
were the reason the present setpoint did not agree with the calculated
value. The inspectors then explained to the licensee that the approved
methodology of the ODCM was what. Technical Specifications required and, if
it was found to be incorrect or unusable, it should be formally changed.
Correction of these problems associated with radiation monitor setpoints 'is
identified as Inspector Followup Item 338,339/85-18-03.
North Anna EP, Table 4.1A, no. 4, and EPIP 1.01, Tab A, state in part that
placing a unit in mode 3 or a lower mode as a result of meteorological
monitoring instrumentation less than minimum required to perform offsite
dose calculations per Unit 1 TS 3.3.3.4 is an initiation condition of NOVE.
Unit 1 TS 3.3.3.4 does not require plant shutdown on loss of meteorological
monitoring capability, nor does any other plant TS. Based on that fact, the
inspectors asked the licensee how the plant could ever get' into the
condition outlined above. Additionally, the inspectors pointed out to the
licensee that NUREG 0654, revision I guidance calls for the Notification of
Unusual Event based solely on loss- of all meteorological instrumentation
(page 1-5 no.11).
Revision of the procedures concerning NOUE of loss
meteorological monitoring instrumentation is identified as Inspector
Followup Item 338,339/85-18-04.
,.
No violations or deviations were identified in this area.
.
,.
l
"
. ..
r -
13
16.
Spent Fuel Storage Racks (50095)
During this inspection period the inspectors observed some of the work done
as part of DCP 82-19. The activities witnessed included:
preliminary SFP
diving operations, removal of existing racks from the SFP, decontamination
of the removed racks and transfer of those racks to shipping containers. In
addition, the inspectors observed licensee inspection of the vehicles used
to ship the racks (including radiation surveys), reviewed selected shipping
documentation and observed preliminary, cleaning of some of the new spent
fuel storage racks.
At present, 11 racks have been removed from the SFP (10 have been shipped
,
offsite). . One additional rack remains in the SFP in an area being worked
and cannot be removed at this time due to an obstruction along.the SFP wall.
Four new spent fuel storage racks have been transferred into the fuel
building with others being readied for transfer from the storage area to the
fuel building staging area.
No violations or deviations were identified in this area.
17. Compliance with Station Procedures
On July 19, 1985, NRC Region II issued a Notice of Violation for failure to
follow procedures against North Anna 1 and 2 (338,339/85-16-02).
This
~
report contains further examples of that violation.
The failure to close
the sample trip valve discussed in paragraph 5 is failure to follow
1-OP-12.1.
In paragraph 6, the discussion of a followup problem similar to
those discussed in LER 338/84-13 is.another example of failure to follow an
Operating Procedure.
The out-of-calibration: NQC device referenced in
paragraph 11 is an example of failure to follow ADM 12.0 (August 23, 1983).
Finally, paragraph 13 discusses failures to follow the requirements of both
3
.
ADM 2.19 and ADM 19.27.
The inspectors discussed with the licensee the
above failures to follow plant procedures and requested the licensee address
these items when specifying corrective action for the violations discussed
~
,
above.
1
i
i
<
.