ML20151C920
| ML20151C920 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 04/07/1988 |
| From: | Cruden D VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF ENFORCEMENT (OE) |
| References | |
| 88-136, NUDOCS 8804130264 | |
| Download: ML20151C920 (8) | |
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10CFR2.201 10CFR2.205 YIMOINIA }$LECTMIC AND POWEN COMPANY HICH MOND. VIItOINIA 2 0 2 61 April 7, 1988 Director, Office of Enforcement Serial No.86-136 U.S. Nuclear Regulatory Comission NA/MLB:bip Attn: Document Control Desk Docket Nos.
50 338 Washington, D.C.
20555 50-339 License Nos. NPF-4 NPF-7 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMP 6MY NORTH ANNA POWER STATION UNITS 1 AND_2 NRC INSPECTION REPORT NOS. 50-338/87-38 AND 50-339/87-38 REPLY TO A NOTICE OF VIOLATION faYN NT OF CIVIL PENALTY We have reviewed your letter of March 8,1988 which referred to the inspection conducted at North Anna between November 20, 1987 and December 18, 1987, and reported in Inspection Report Nos.
50-338/87-38 and 50-339/87-38.
The response to the violation assessed a Civil Penalty is addressed in Attachment 1, and a check in the amount of the assessed Civil Penalty ($100,000) is provided in Attachment 2.
A detailed discussion of the event and our conclusions regarding its safety significance are provided in Licensee Event Report (LER)87-015 01 dated February 3, 1988.
Your letter also addressed a concern with problems involving inadequate j
procedures and/or failure to follow procedures which were encountered during earlier plant startups and outages. We share your concern with these problems and have initiated an aggressive corrective action program to deal with the general concerns regarding procedures and procedure adherence.
This program was discussed in our letter of February 3, 1988 in response to NRC Inspection Report 87-36 and is being implemented on schedule.
As discussed with Mr. Cantrell of your staff on this date, our response to the violations not assessed a Civil Penalty will be provided by April 21, 1988.
This information is true and accurate to the best of my knowledge and belief.
We have no objection to this report being made a matter of public record.
If you have any further questions, please contact us.
Very trul
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Regional Administrator U. S. Nuclear Regulatory Comission i
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101 Marietta Street, N.W.
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Atlanta, GA 30323 l
Mr. J. L. Caldwell NRC Senior Resident Inspector North Anna Power Station i
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O COMMONWEALTH OF VIRGINIA CITY OF RICHMONO The foregoing document was acknowledged before me, in and for the City and Commonwealth aforesaid, today by D. S. Cruden who is Vice President - Nuclear, of Virginia Electric and Power Company.
He is duly authorized to execute and file the foregoing document in behalf of that Company, and the statements in the document are true to the best of his knowledge and belief.
Acknowledged before me this 7 b day of afd'
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ATTACIMENT 1 REPLY l0 A N0flCE OF VIOLATION
ATTACIMENT 1 t
RESPONSE TO THE NQTICE OF VIOLATIQtt REPORTED DURING 1HE NRC INSPECTION CONDUCTED BETWEEN NOVE7EER 20 THROUGH DECEMBER 18. 1987 15SPECT10N REPORT NOS. 50-338/87-38 AND 50-339/87-38 NRC C0fMENT I.
Violation Assessed A Civil Penalty Technical Specification 3.3.1.1. Table 3.3-1, requires that two Reactor Trip System steam flow channels per loop shall be operable when the Unit is in Modes 1 and 2.
When only one channel is operable, startup and power operation may proceed until performance of the next required channel functional test provided the inoperable channel is placed in the tripped condition within one hour.
Technical Specification 3.3.2.1 Table 3.3-3, requires that two Engineered Safety Feature Actuation System steam flow instrumentation channels per steam line shall be operable when the unit is in Modes 1, 2, and 3.
When only one channel per steam line is operable, operation may proceed until performance of the next required channel functional test, provided the inoperable channel is placed in the tripped condition within one hour.
Contrary to the above, on November 4, 1987, Unit 2 was operated in Modes 13 with an inoperable steam flow channel in both A and B steam flow lines. These steam flow channels, "A" steam generator Steam Flow Channel 111 (F12474) and "B" Steam Flow Channel IV (F1-2485), were identified as indicating zero steam flow with the other four channels indicating positive steam flow.
The difference in flow between the two channels indicating no flow and the other channels for the respective loops which were indicating flew was greater than the channel check acceptance criteria thereby, indicating the two chanr.els were inoperable.
The channels were not declared inoperable and the appropriate Technical Specification action of placing the inoper ble channels in trip within one hour was not taken.
This is a Severity Level III violation (Supplement I).
(Applies to Unit 2 only).
RESPONSE
1.
ADMISSION OR DENIAL OF THE VIOLATION The violation is correct as stated.
2.
REASONS FOR THE VIOLATION The cause of this violation was personnel error in that operations personnel did not adhere to the channel check criteria and declare the non indicating steam flow channels inoperable immediately upon detection.
The operators' actions were influenced by previous erratic steam flow behavior at low steam flow / low power cor.dttions which subsequently stabilized at higher steam flow / higher power conditions.
Operability requirements had included valve lineup checks and I&C verification of flow transmitter alignment and calibration.
Management tolerance of erratic steam flow indication behavior at the low steam flow / low power conditions was a significant contributor to this noncompliance.
3.
CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND THE RESULTS ACHIEVED An operations shift order was issued on December 21, 1987 to provide interim guidance for assessing the operability of steam flow channels during low steam flow / low reactor power conditions.
The shift order emphasized the compliance with channel check requirements and the use of alternate indications.
On January 29, 1988, final operability guidance was provided through an Operations Directive and was based on the completion of an engineering evaluation of steam flow indication problems.
In addition, OP-2.1 was revi'ed to require confirmation of steam flow channel operability prior to exceeding 5% power.
This event was also reviewed with licensed operations personnel by management.
An engineering evaluation was performed which examined the uncertainties associated with the main steam flow instrument channels and the safety analysis basis for the steam flow setpoints. As a result, a new channel check criterion (less restricted at low power levels than that in effect at the time of the event and discussed with you at the January 22, 1988 Enforcement Conference) was derived which provides a tolerance more consistent with the uncertainties of the steam flow channels at low steam flow / low power conditions.
The new criterion will more clearly indicate instrument failure.
Simulator exercise guides have been upgraded to include inoperable instrumentation that would not be normally indicating at very low power levels.
Increased emphasis is being provided on the use of alternative indication during simulator exercises.
A Human Performance Evaluation System (HPES) evaluation of this event wa>
performed to provide details concerning the untimely operator actions with respect to declaring the inoperability of the affected steam flow channels.
Recommendations from the HPES report were included in the review of this event that was provided to licensed operations personnel.
Corrective actions taken in response to the broader issue of procedural adherence and timely equipment operability determination included the issuance of a memorandum from the Station Manager to all station personnel regarding compliasce to Station procedures.
This was followed up by a briefing of station supervisors of recent events and by meetings
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CORRECTIVE STEPS WHICH WILL BE TAKEN TO AV01D FURTHER VIOLATIONS
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Station management's active participation in formulating corrective action and communicating their expectations regarding procedural compliance to stttion employees is essential to avoiding future violations.
Management will continue to aggressively emphasize and a
d demand high standards to include compliance with procedural and license l
requirements.
in order to minimize recurrence of instrument failures simil&r to that which caused the "B" steam flow channel IV to fail, investigations as to the cause of the failure are continuing.
These investigations will include an inspection of the transmitter and its sensing lines.
If the i
cause of the failure can be identified, corrective actions will be taken.
Additionally, the steam flow channel instrument calibration procedures will be reviewed and revised as needed to address vendor recommendations, valve lineup verification, and precautions for venting the transmitter sensing lines.
j 5.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED l
Revisions to steam flow channel instrument calibration procedures will be i
rade by April 30, 1988.
The Unit 2 channcl IV steam flow transmitter and sensing lines on the "B" steam generator will be inspected during the t
next refueling outage presently scheduled to begin November 4, 1988.
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ATTACINE41_2 REMITTANCE OF CIVIL PENALTY i
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