ML20137G576
| ML20137G576 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 01/10/1986 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | Taylor J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| 85-877, NUDOCS 8601210090 | |
| Download: ML20137G576 (5) | |
Text
k VIRGINIA ELucrHIC AND POWER COM1%NY R 1C11M O N D, VI HG INI A 232G1 W. L. STEWANT Vaca Puessomar Noctuan OPENATIONm January 10, 1986 Mr. James M. Taylor, Director Serial No.85-877 Office of Inspection and Enforcement N0/JMA:vlh U. S. Nuclear Regulatory Commission Docket Nos. 50-338 Washington, D.C.
20555 50-339 License Nos. NPF-4 NPF-7
Dear Mr. Taylor:
VIRGINIA ELECTRIC AND POWER COMPANY RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT NOS. 50-338/85-30 AND 50-339/85-30
@ OFFICE OF INVESTIGATIONS REPORT NO. 2-84-015 We have reviewed your letter of December 13, 1985, in reference to the Enforcement Conference held in the NRC Region II Office on October 22, 1985.
Our response to the Notice of Violation is addressed in the attachment. A check in the amount of twenty thousand dollars ($20,000.00) is also enclosed as requested.
We have determined that no proprietary information is contained in the report. Accordingly, we have no objection to this inspection report being n.ade a matter of public disclosure. The information contained in the attached pages is true and accurate to the best of my knowledge and belief.
Very truly yours,
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,L, MA W. L. Stewart Attachments:
1.
Response to Notice of Violation 2.
Civil Penalty Payment dh3B DOC Pon 5
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V Vsmo wtA Etncrmic awn Powsm Couraxy 7 Mr. Jam s M. Tayle i
cc: Dr. J. Nelson Grace l
Regional Administrator NRC Region II i
Mr. Roger D.' Walker, Director Division of Reactor Projects NRC Region II Mr. Lester S. Rubenstein, Director PWR Project Directorate #2 Division of PWR Licensing-A Mr. Morris W. Branch NRC Resident Inspector North Anna Power Station f
Mr. Leon B. Engle NRC North Anna Project Manager PWR Project Directorate #2 Division of PWR Licensing-A l
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RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-338/85-30 AND 50-339/85-30 AND OFFICE OF INVESTIGATIONS REPORT NO. 2-84-015 NRC COMMENT l
10 CFR Part 50, Appendix B, Criterion V requires that activities affecting quality be prescribed by and accomplished in accordance with documented instructions, procedures, and drawings of a type appropriate to the
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circumstances.
Criterion X requires that a program for inspection of activities affecting quality be established and executed to verify conformance with these documented instructions, procedures, and drawings i
for accomplishing the activity.
Criterion XVII further requires that sufficient records be maintained to furnish evidence of these activities affecting quality.
The Virginia Electric and Power Company Topical Report, Quality Assurance Program, Operations Phase (VEP-1-4A), Amendment 4, implements 10 CFR Part 50, Appendix B.
Pursuant to VEP-1-4A, specifications and instructions were prescribed for painting the containment ventilation ring ductwork, an activity affecting quality.
Site Painting Specification 13075.89, NAS 1016, Part II (Application of Protective Coating Materials Within Containments),
defined the r
requirements for materials and workmanship for field application of protective coatings within the reactor containment liner boundary.
Additionally, Quality Control Instruction 11.1 established a program for controlling protective coating materials, surface preparation, and the application of protective coatings to assure that they conformed to the governing specification and required that conformance with the program be documented in the Protective Coating Surface Preparation Record.
l Contrary to the above, the Protective Coatings Surface Preparation Records (PCSPRs) that documented containment ventilation ring ductwork i
painting and inspections performed in Units 1 and 2 from December 1982 through May 1983 failed to reflect the actual quality of work performed.
The PCSPRs, because of falsification, indicated an acceptable quality of work when in fact the Site Painting Specification and Quality Control Instruction had not been met.
This is a Severity Level III violation (Supplement VII).
(Civil Penalty - $20,000) l l
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RESPONSE
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ADMISSION OR DENIAL OF THE ALLEGED VIOLATION i
j This violation is correct as stated.
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REASON FOR THE VIOLATION 4
j The procedures for controlling the quality of the painting activities
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being performed on the containment ring ductwork did not contain i
j sufficiently detailed instructions.
Instructions were provided that should have enabled the craft supervisor and the QC inspectors to i
j recognize that work process controls were required. However, because the work was misclassified as a Maintenance Request work activity and an error l
4 in judgement was made by the craft supervisor and the QC inspectors i
concerning their required actions, the documentation was completed in a j
manner that did not accurately reflect the actual work performed.
j 3.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED j
The technical deficiencies -in the application of unqualified protective coatitas were addressed in NRC Inspection Report Nos. 50-338/84-30 and i
50-339/84-30 (and the enclosed Notice of Violation) which was issued on
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October 9,1984. Our response to the inspection report (Letter Serial No.
609), as well as the North Anna Licensee Event Report No. LER 84-006 which was issued on November 8,
1984 (Serial No. N-84-014), documents our 4
corrective actions that address the technical deficiencies.
i The actions taken to address the falsification of records by Quality Control personnel have included the upgrading of the QC certification process for Coatings Inspectors and the development of more detailed Quality Assurance Department procedures to provide specific guidance for QC personnel performing their duties. Also, additional training has been provided for craft personnel, supervisors, engineers, and QC inspectors 4
which emphasized their required actions and responsibilities.
I Prior to becoming aware of the applications of the unqualified coatings, the responsible craf t supervisor's employment was terminated. The two QC inspectors involved with the falsification of the inspection records
.l employment are also no longer company employees because of personnel j
actions taken by management.
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l Additionally, a program to validate the work perforced by the two QC inspectors since the coatings incident has been initiated. The validation involves the review of a sample of their inspection forms for completeness i
and consistency, and a selected review of installed items within the station.
The review of the inspection forms has been completed. No problems were found. The selected review of installed items has been started and will be completed by April 30, 1986.
4.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS A review of station work processes is being performed to determine if similar situations exist where construction or modification may be performed without proper engineering review.
(This reconfirms the commitment that we made during the Enforcement Conference held on October 22, 1985). Appropriate actions will be taken to correct any deficiencies j
identified.
Additionally, the Nuclear Operations Department is currently in the process of implementing policy statements and standards that will further clarify responsibilities and interfaces between various corporate and station organizations.
Existing station and corporate administrative procedures will be revised as needed to reflect these new policy statments and standards.
5.
DATE WHEN FULL COMPLIANCE WILL BE ACHEIVED The review of station work processes is scheduled to be completed by March 1, 1986.
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