ML20151P503

Responds to NRC Re Violations Noted in Insp Repts 50-338/87-38 & 50-339/87-38.Corrective Actions:Station Mgt Briefed on Requirements of 10CFR50.73 Re Scope & Content of LERs & Mgt Interviews Will Be Conducted as Required

ML20151P503
Person / Time
Site:	North Anna
Issue date:	04/21/1988
From:	Cruden D VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM), NRC OFFICE OF ENFORCEMENT (OE)
References
88-136A, NUDOCS 8804260180
Download: ML20151P503 (9)

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• ' l 10CFR2.201 VIRGINIA ELECTRIC AND POWER COMPANY RIcnxonn, VIRGINIA 20261 April 21, 1988 Director, Office of Enforcement Serial No. 88-136A U.S. Nuclear Regulatory Commission NA/MLB:blp 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 COMPANY 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 We have reviewed your letter of March 8,1988 which referred to the inspection conducted at North Anna between November 20, 1987 and Decerk:r 18, 1987, and reported in Inspection Report Nos. 50-338/87-38 and 50-339/87-38. The response to the violations not assessed a Civil Penalty is addressed in the Attachment.

Mr. Cantrell of your staff agreed on April 7,1988 to extend the response time for these violations to 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 truly yours, S

D. S. Cruden \

Vice President - Nuclear Attachments cc: Regional Administrator V. S. Nuclear Regulatory Commission Region II 101 Marietta Street, N.W. '

Suite 2900 /0.

Atlanta, GA 30323 8

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Mr. J. L. Caldwell \

NRC Senior Resident Inspector North Anna Power Station 8804260100 880421 PDR ADOCK 05000338

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l COMMONWEAi.TH OF VIRGINIA )

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CITY OF RICHMOND )

The foregoing document was acknowledged before me, in and for the City and Commonwealth aforesaid, today- by W. L. Stewart, who is Senior Vice President -

Power, for 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 [/ day of 97 , 19 8 B .

, 19 90 My Commission expires: i. IMAaa u,4 ff .

N'di . $&ff Notary'Public

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ATTACHMENT RESPONSE TO THE NOTICE OF VIOLATION REPORTED DURING THE NRC INSPECTION CONDUCTED BETWEEN NOVEMBER. 1987 20 THROUGH DECEMBER 18. 1987 INSPECTION REPORT NOS. 50-338/87-38 AND 50-339/87-38 NRC COFMEhI Violati ms_not Assessed a Civil Pena ~lty A. 10 CFR Part 50, Appendix B, Criterion V, as implemented by the licensee's Quality Assurance Topical Report VEP l-5A, and ADM-5.0, Instructions, Procedures and Drawings, requires in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, and drawings.

Engineering Work Request (EWR)87-206 stated that following completion of Raychem splice installation, performance testing of the modi fied component be accomplished per approved station test procedure.

Contrary- to the above, following performance of the Raychem splice installation specified in EWR 87-206, the licensee failed to perform a post-maintenance test to verify the operability of the steam flow instrument, FI-2474.

This is a Severity Level IV violation (Supplement I). (Unit 2 only)

RESPONSE

1. ADMISSION OR DENIAL 0F THE VIOLATION The violation is correct as stated.

2. REASONS FOR THE VIOLATION The Raychem splice installation for FT-2474 was completed on September 14, 1987. When the tagging record was prepared for approximately 40 instruments to accomplish testing of the circuits affected by the Raychem splice work as required by EWR 87-206, a mistake was made in that the location for power supply card FT-2474 was interchanged with the location for power supply card LT-2474. Because of the tagging error, the circuit for LT-2474 was actually energized instead of that for FT-2474. As a result, the post-maintenance test for FT-2474 was performed on September 21, 1987 by reading the voltage output of the power supply card for LT-2474.

On September 29, 1987, the power supply card was inserted to energize the circuit for LT-2474. Because of the tagging error, the circuit for FT-2474 was energized instead. The post-maintenance test of LT-2474 is believed to have been completed by satisfactorily verifying level indication in the Control Room. Therefore, the original tagging error resulted in two post-maintenance tests being performed on the circuit for l LT-2474 and no post-maintenance test being performed on the circuit for FT-2474. The root cause of failing to perform a post maintenance operability test of steam flow instrument FT-2474 was the lack in the controlling Engineering Work Request (EWR) of specific test guidance and the requirement to apply appropriate testing controls.

l On October 25, 1987, the procedure for verifying transmitter FT-2474 operability prior to startup was performed while Unit 2 was in operating Mode 5. Since there was no steam flow available in this mode, the transmitter was verified to be operable for the startup based on a verification of valve lineup. Accordingly, the inoperability of FT-2474 remained undetected until November 4, 1987.

3. CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND THE RESULTS ACHIEVED Steam Generator (S/G) "A" steam flow channel III was placed in the tripped condition in accordance with Technical Specification requirements once it was confirmed that the channel was not responding after power was escalated. Troubleshooting was conducted on the accessible portions of the circuit for FT-2474. Measurement of the output voltage at the power supply card indicated that the transmitter leads appeared to have been reversed as part of the Raychem splice rework. S/G "A" steam flow channel III was returned to service by reversing the wiring leads at the process rack.

4. CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS When plant conditions are such that the field wiring inside containment is accessible, the S/G "A" steam flow channel III wiring will be inspected in order to confirm the suspected cause of the reversed transmitter leads.

The procedural controls which govern post modification testing for both I EWRs and Design Change Packages (DCPs) will be strengthened.

Specifically, administrative controls will be revised to require that:

(1) the preparing engineer for EWRs explicitly determine and document the need for testing requirements, (2) testing requirements are clearly defined in all DCPs and EWRs which result in a modification to plant equipment, (3) existing station procedures be identified to conduct testing where possible; otherwise, a new test procedure will be developed, ha-... . . . .

(4) testing requirements and procedures be approved by SNSOC prior to being performed, (5) . changes to testing requirements and, procedures be approved by SNSOC prior to being performed, and (6) for safety related equipment, testing requirements be addressed in the safety analysis.

Following identification of the affected procedures, the necessary revisions to implement these practices will be made.

5. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Inspection of the field wiring for S/G "A" steam flow channel III will be performed during the next Unit 2 outage of sufficient duration.

The appropriate station administrative procedures and subordinate test procedures will be revised by June 30, 1988.

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B. Technical Specification 6.6.1.a requires that the Commission shall be notified and a report submitted pursuant to the requirements of 10 CFR 50.73.

10 CFR 50.73 requires that the licensee report any operation or condition prohibited by the plant's Technical Specifications, and include in the report the cause of each component or system failure or personnel error, the dates and approximate time of occurrences, the method of discovery of each component or system failure, and operator actions that affected the course of the event.

Contrary to the above, Licensee Event Report No. (LER)87-015, issued by the licensee on December 4,1987, to describe the violation of Technical Specifications associated with inoperable steam flow instruments FI-2474 and FI-2485 was inadequate for the following reasons:

(1) LER 87-015 failed to identify that the "B" steam generator Steam Flow Channel IV (FI-2485) had been inoperable since the unit entered Mode 3 and consequently the LER did not identify any cause for the failure or any corrective actions.

(2) LER 87-015 failed to identify the lack of a proper post maintenance test and testing documentation for "A" steam generator Steam Flow Channel III (FI-2474) following maintenance performed during the refueling outage. The lack of a post maintenance test was not identified as a cause for the steam flow channel being inoperable and in violation of Technical Specifications.

(3) LER 87-015 failed to identify that the operators violated the Technical Specification 4.3.1.1.1 and 4.3.2.1.1 channel check criteria and the licensee's operation standard concerning channel checks in that the operators logged that both Steam Flow Channels FI-2474 and FI-2485 were outside the licensee's established channel chd criteria but did not declare the instruments inoperable and take the actions required by Technical Specification.

(4) By failing to document specific times of discovery LER 87-015 did not make it clear that the operators had identified problems with Steam Flow Chanr.els FI-2474 and FI-2485 as early as 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> prior to declaring them inoperable. The LER also did not state that the unit operated at approximately 25 percent reactor power for aporoximately four hours with both Steam Flow Channels FI-2474 and F;-2485 indicating zero steam flow (e.g., failed low) before declaring the channels inoperable and taking the required Technical Specification actions.

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4 (5) LER 87-015 did not state that the' condition with inadequate steam flow indication at low steam flow and the action taken by the operators which was in violation of Technical Specification channel check surveillance criteria was known and condoned by licensee management, nor was this listed as a cause and discussed under corrective action.

This is a Severity Level IV violation (Supplement I). (Unit 2 only) i I

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RESPONSE

1. ADMISSION OR DENIAL OF THE VIOLATION The violation is correct as stated.

2. REASON FOR THE VIOLATION Station management incorrectly decided to limit the scope of the LER to the "A" steam generator steam flow channel III and the period of time following the official declaration of its inoperability. In addition, the lack of a proper post maintenance test of the channel was not identified because problems associated with testing had not been completely recognized at this time, although inadequate post maintenance testing was suspected as a probable contributor to the event.

3. CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND THE RESULTS ACHIEVED An updated Licensee Event Report, LER 87-015-01, was submitted on February 3, 1988 after completion of a detailed evaluation. The five specific concerns identified in the violation were addressed in the revisions to the LER.

In order to ensure that investigations of reportable events are thorough, and that complete and accurate information is provided in the LER, Station Administrative Procedure, ADM-16.2, Reportable Occurrences /LER, has been revised to include the following additional requirements:

(1) a qualified Shift Technical Advisor will be assigned to review each reportable event and oversee the preparation of the LER, (2) management interviews will be conducted, as required, (3) the need for additional investigation and a supplemental LER will be evaluated and identified in the initial report, if applicable, and (4) all significant comments and their resolution will be presented to SNSOC.

Station management has been briefed on the requirements of 10CFR50.73 regarding scope and content of LERs.

4. CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS SNS0C will be verifying compliance to the new requirements in ADM-16.2 to ensure that reportable events are fully evaluated and accurately reported.

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5. PflE_l!EEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance has been achieved.

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