ML20137V711
| ML20137V711 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 11/22/1985 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| 85-769, NUDOCS 8512100066 | |
| Download: ML20137V711 (6) | |
Text
DMb VINGINIA ELECTRIC AND POWHH COMI%NY Hicunown,VruarxrA enent w.I..sran ur vic v..nonwr November 22, 1985
' NarrLaam OrmeATIONs Dr. J. Nelson Grace Serial No.85-769 Regional Administrator NAPS /JHL Region II Docket Nos. 50-338 U. S. Nuclear Regulatory Commission 50-339 Suite 2900 License Nos. NPF-4 101 Marietta St., N.W.
Dear Dr. Grace:
We have reviewed your letter of October 25, 1985, in reference to the inspection conducted at North Anna Power Station from September 2 to October 6, 1985, and reported in Inspection Report Nos. 50-338/85-26 and 50-339/85-26. Our response to the Notice of Violation is addressed in the attachment.
We have determined that no proprietary information is contained in the report. Accordingly, we have no objection to this inspection report being made a matter of public disclosure.
Very truly yours, 5
e J W. L. Stewart rn I
c2 cA Attachment o
ca)
.3 17,10 h O D
G 1 l l
.rzol
7 Vsuonna Ex.scrn:C AND Powra COMPANY TO Dr. J. Nelson Grace cc:
Mr. Roger D. Walker,-Director Division of Project and Resident Programs Mr. Edward J. Butcher, Acting Chief Operating Reactors Branch No. 3 Division of Licensing Mr. M. W. Branch NRC Resident Inspector North Anna Power Station M'
N 99 b
o O
y
/
/
n RESPONSE TO NOTICE OF VIOLATION ITEM REPORTED DURING NRC INSPECTION CONDUCTED FROM SEPTEMBER 2, 1985 TO OCTOBER 6, 1985 INSPECTION REPORT NOS. 50-338/85-26 AND 50 339/85-26 NRC COMMENT:
Technical Specification (TS) 6.8.1 requires that written procedures be established, implemented and maintained covering the areas recommended in Appendix. A of Regulatory Guide 1.33, Revision 2, February 1978, which includes both the areas of equipment control (tagging and locking) and operation of the Auxiliary Feedwater System during both normal and abnormal conditions.
Contrary to the above, the requirements of the TS were not fully implemented in that:
Tagging requirements in Station Administrative Procedure (ADM) 14.0, Tagging of Systems and/or Components (March 31, 1985), were not followed during the repair on motor operated valve MOV 1586 (Work Order 5900029683).
This is a Severity Level IV violation (Supplement I) and applies only to Unit-1.
RESPONSE
1.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION:
This violation is correct as stated.
2.
REASONS FOR THE VIOLATION-MOV 1586 had a high temperature on its packing leak off line and was identified as the source of high unidentified RCS leakage. With the unit in mode 3, an emergency work order was written (WO 5900029683) to adjust the packing. The adjustment of packing does not require the valve to be
-tagged. The packing adjustment did not stop the leak and repacking of the valve commenced. Personnel did not recognize the need to install danger tags between the time the packing was adjusted and the initiation of repacking the valve. When it was recognized that danger tags should have been in r, lace, the repacking effort was already in progress. The control switch an MOV 1586 was then covered with a " danger" sticker to prevent remote operation.
3.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:
A danger sticker was,placed on the remote switch for MOV 1586 to warn agairst MOV operation while the MOV was repacked on its backseat.
The repack effort was completed and the packing assembly was reinstalled without incident.
Operations personnel who were involved in this incident have been given personal counselling to increase their awareness of the need to use danger tags.
4.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
An operations directive concerning implementation of ADM 14.0 will be issued to operations personnel.
5.
THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
The operations directive will be issued by January 31, 1986.
t
'i li
./ ;
s RESPONSE TO NOTICE OF VIOLATION q
-ITEM REPORTED DURING NRC INSPECTION i
j CONDUCTED FROM SEPTEMBER 2, 1985 TO OCTOBER 6, 1985 INSPECTION REPORT NOS. 50-338/85-26 AND 50-339/85-26 NRC COMMENT:
/-
i f
q-l Technical - Specification (TS). 6.8.1 requires that written procedures be established, implemented and maintain _ed covering the areas recommended in -
j Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, which includes both the areas of equipment control (tagging and locking) and operation of '. the Auxiliary Feedwater System during both normal and abnormal conditions.
i Contrary -to the above, the requirements-of the TS were not fully implemented in that:
Abnormal Operating Procedure'(AP) 1-AP-22.3, Placing 1-FW-P-3A and/or 3B In Service To Feed The Steam Generators Via The MOV Header (November 29, 1979)~, was inadequate in fthat, the procedure did not require monitoring pump inlet water temperature. + System design requirements of 120F were exceeded during pump operation on' September 15, 1985.
}
This is a Severity Level IV violation (Supplement I) and applies only to Unit 1.
F i
s f.
RESPONSE
w
- 1. ADMISSION'OR DENIAL OF THE ALLEGED VIOLATION:
This violation is correct as stated.
2.
REASONS FOR THE VIOLATION:
5 Initial procedure preparation and subsequent reviews of 1-AP-22.3 did not address a maximum UFSAR temperature limit of 120F in the emergency
^
condensate storage tank. The storage tank is pequired to be filled when the tank level reaches 94% indicated level. Tne flash evaporator makeup i
i water enters the tank very close to the zinlet of the feed pum;is such that 2
the pump draws a portion of its water from the tank makeup at 132F. Thus the condensate temperature to the pump is not the bulk temperature of the 4
~
storage tank when make up is in progress. Recent analysis has shown that had the tank temperature been 132F, there would have been sufficient NPSH for pump operation and sufficient tooling for the RCS. Cooling in the RCS is accomplished by boiling heat't;cnsfer. The elevated temperature would have reduced the heat transfer capability by only 1.0%.
In addition, the auxiliary feedwater system decay heat removal requirement on September 15, 1985 was only about 30% of the design basis requirement. Thus this s
i s
m
- 1 e
increase in temperature is insignificant when considering the mode of heat transfer. An engineering evaluation substantiates this.
3.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:
The water from the suction line to the auxiliary feedwater pumps was cooled down to less than 120F by adding water to it from a standby condensate tank and securing the continuous recirculation operation of the auxiliary feedwater pump.
Operating Procedure OP-31.2 and Abnormal Procedure AP-22 series associated with the auxiliary feedwater pumps and tank have been revised 9
to in'clude caution concerning tank temperatures.
4 4.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
Full compliance has been achieved.
5.
THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
7 1
Full compliance has been ' achieved.
?
'l N.
1
Y s.-
h
,'W j
5.)r tv L
7
- 7. m.
m-
..,_------_--,---s