ML20137E398
| ML20137E398 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 11/20/1985 |
| From: | Brownlee V NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| References | |
| NUDOCS 8511270250 | |
| Download: ML20137E398 (3) | |
Text
,
o NOV 2 01985 Virginia Electric and Power Company JTTN:
Mr. W. L. Stewart, Vice President, Nuclear Operations P. O. Box 26666 Richmond, VA 23261 Gentlemen:
SUBJECT:
REPORT N05. 50-338/85-16 AND 50-339/85-16 This refers to your September 19, 1985 response to our Notice of Violation issued on July 19, 1985, concerning licensed activities conducted at your North Anna facility, and our November 1, 1985 acknowledgement of your response.
Our evalua-tion, which was in progress on November 1, has since been completed and is enclosed with this letter.
After careful consideration of the basis for your denial of example 5 of the Violation, we have concluded, for the reasons given in the enclosure, that the Violation as stated in the Notice is valid.
In accordance with the requirements of 10 CFR 2.201(a), please provide us, within 30 days of the date of this letter, with written statements of the actions you have taken or plan to take to correct and prevent recurrence of this Violation and the date when full compliance will be achieved.
The responses directed by this letter are not subject to the clearance procedures of the Office of Management and Budget issued under the Paperwork Reduction Act of 1980, PL 96-511.
We appreciate your cooperation in this matter.
Sincerely, C RI M". S YZD CY
'iO L L B,iOWNLEE Virgil L. Brownlee, Chief Reactor Projects Branch 2 Division of Reactor Projects
Enclosure:
Staff Evaluation of Licensee
Response
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s ENCLOSURE STAFF EVALUATION OF LICENSEE RESPONSE NRC Inspection Report Nos. 50-338, 339/85-16 documented that, during the installation of emergency lighting per Design Change Package (DCP) 84-26, some of the lamp heads were installed outside the elevation band allowed by the DCP, i.e., the DCP was not fully implemented.
The licensee's response statt.d that the Violation example was not correct as stated in the NRC report.
The response stated that the DCP did state that all lamp heads were to be mounted at an elevation of eight feet plus or minus one foot.
The response also stated that the note in the DCP, section 4.0, Instructions, was intended to be used as a construction guide only, that the construction drawing (#739122/8426-FE-688) has general notes for the placement of lamp heads, and that the exact location was to be determined in the field to permit adequate access / egress paths and illumina-tion of specified equipment.
The staff has reviewed Inspection Report 338, 339/85-16, the licensee's response, the pertinent sections (4.0) of the Final Design Controlling Procedure for DCP 84-26, and drawing #739122/8426-FE-688-Rev 40 (Field Change #62 to DCP 84-26).
A review of general notes E2 and E3 on the construction drawing confirmed that the exact battery / fixture location and mounting height was to be determined in the field and that the lamp heads generally were to be mounted with their center lines eight feet zero inches above the finished floor (AFF).
The Final Design Controlling Procedure, which is a specifically approved controlling document, placed a specific tolerance of plus or minus one foot on the " generally shall be mounted up 8'-0" above finished floor" stated in general note E3 on the contruction drawing.
It is clear that the specific tolerance in the procedure was a requirement because it is phrased " Lamp heads shall be installed...".
Additionally, if the procedure note were a " suggestion", then the note preceeding it, which requires that installation shall be performed in accordance with NAS-1010 " Specification for Installation of Electrical Equipment", would also be a " suggestion".
The staff concludes that the procedure note is a requirement.
The individuals performing the emergency lig ' ting installation, when confronted with a situation in which they could not ac'iere to the procedural lamp head elevation restrictions, should have initiated action to obtain relief from the procedural specification.
Apparently, neither an engineering evalaution nor a procedural field change was accomplished to justify deviation from the original eight foot, plus or minus one foot, AFF elevation specification in the Final Design Controlling Procedure.
The staff must conclude, therefore, that DCP-84-26 was not fully implemented and that example 5 of the Violation did occur as stated in the Notice.
Subsequent review of draft Inspection Report 338,339/85-24, concerning an
" Appendix R" inspection, and discussions with those inspectors show that in general, the result of the lighting modification is adequate.
The staff concluded from this that the severity level five selected for the Violation under review was appropriate.
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