ML20134P039

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Responds to NRC Re Violations Noted in Insp Repts 50-338/96-09 & 50-339/96-09.Full Compliance Was Achieved When O-AP-30 Was Revised
ML20134P039
Person / Time
Site: North Anna  Dominion icon.png
Issue date: 11/20/1996
From: Ohanlon J
VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
96-553, NUDOCS 9611270203
Download: ML20134P039 (4)


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O VINGINIA ELECTHIC AND POWEIt COMI'ANY HIcIIxoNI),VIHOINIA 20261 November 20, 1996 U. S. Nuclear Regulatory Commission Serial No.96-553 Attention: Document Control Desk NAPS /JHL R1 Washington, D. C. 20555 Docket Nos.

50-338 50-339 License Nos.

NPF-4 NPF-7 Gentlemen:

VIRGINlA ELECTRIC AND POWER COMPANY RORTH ANNA POWER STATION UNITS 1 AND 2 INSPECTION REPORT NOS. 50-338/96-09 AND 50-339/96-09 REPLY TO THE NOTICE OF VIOLATION We have reviewed your letter of October 21,1996, which referred to the inspection conducted at North Anna Power Station from August 11,1996 through September 21, 1996, and the associated Notice of Violation which was reported in Inspection Report Nos. 50-338/96-09 and 50-339/96-09. Our reply to the Notice of Violation is attached.

No new commitments are intended as a result of this letter. If you have any further questions, please contact us.

Very truly yours, i

James P. O'Hanlon Senior Vice President - Nuclear j

Attachment cc:

U. S. Nuclear Regulatory Commission Region ll 101 Marietta Street, N.W.

Suite 2900 Atlanta, Georgia 30323 n

I Mr. R. D. McWhorter gl NRC Senior Resident inspector North Anna Power Station 9611270203 961120 PDR ADOCK 05000338 G

PDR

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REPLY TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-338/96-09 AND 50-339/96-09 NRC COMMENI During an NRC inspection conducted on August 11,1996 through September 21,1996, a violation of NRC requirements was identified.

In accordance with the " General Statement of Policy and Procedures for NRC Enforcement Actions," NUREG 1600, the violation is listed below:

Technical Specification 6.8.1. requires that written procedures be established, implemented and maintained, including by reference to.

Appendix A of Regulatory Guide 1.33, Revision 2, procedures for irradiated fuel damage while refueling.

The licensee's Technical Specification Change Request dated October 17,1995, and the NRC's

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Technical Specification Amendment numbers 198 and 179, dated February 27, 1996, stated that upon notification of a fuel handling accident, the control room bottled air supply would be initiated by operators within two minutes.

Contrary to the above, from February 27,1996, until September 19,1996, the procedure for irradiated fuel damage while refueling, 0-AP-30, was inadequate in that it did not direct operators to initiate the control room bottled air supply within two minutes of notification of a fuel handling accident.

This is a Severity Level IV violation (Supplement 1).

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REPLY TO NOTICE OF VIOLATION 1.

REASON FOR THE VIOLATION The reason for the violation was personnel error.

Personnel performed an inadequate review of the proposed Technical Specification change request and Technical Specification Amendments that allowed both containment personnel l

airlock doors to remain open during fuel movement or core alterations.

l Due to this inadequate review of the proposed Technical Specification change request and subsequent approved Technical Specification Amendments 198 and i

179, abnorrnal procedure 0-AP-30, Fuel Failure During Handling, was not properly revised to include the requirement to initiate bottled air supply to the control room upon indication of a FHA in containment.

2.

CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED Abnormal Procedure 0-AP-30, Fuel Failure During Handling was immediately revised to provide instructions to isolate the control room and manually dump l

control room bottled air supply when any containment radiation alarm or notification of a FHA with a potential for radionuclide release is received. This was completed prior to commencing core on load for North Anna Unit 2.

Operations personnel were trained on the revised requirements of 0-AP-30.

Personnel involved in this event have been coached on the importance of 1

thoroughly reviewing proposed Technical Specification change requests, License Amendments and supporting Safety Evaluation Reports.

This is to ensure documents are appropriately revised.

A review of Technical Specification Amendments implemented during 1996 was performed to identify any similar deficiencies in implementation that would cause a Technical Specifications or analysis assumption non-compliance.

No additional discrepancies were identified.

An evaluation of the existing requirements of abnormal procedure 0-AP-30 was

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performed to determine if any other associated assumptions or requirements from this specific Technical Specification Amendment had not been correctly incorporated.

It was determined that the procedure would ensure that the necessary actions were taken following a FHA in containment to promptly j

terminate any release. These actions are intended to prevent doses for control room operators from exceeding GDC 19 limits.

Specifically, the procedure required 1) a designated individual to close the personnel airlock door to terminate the release,2) verification of the isolation of the containment purge i

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system (either manually or automatically), and 3) manual isolation of the control room ventilation fans and starting of the emergency ventilation fans.,

3.

CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOlD FURTHER VIOLATIONS As an enhancement, a root cause evaluation of this specific event is currently being conducted. The evaluation will also review the Technical Specification I

I implementation process. Recommendations from the root cause evaluation will be implemented, as necessary.

4.

THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance was achieved when 0-AP-30 was revised.

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