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Provides Summary of 880328 Enforcement Conference Repts 50-338/88-02 & 50-339/88-02 Re Inservice Testing of Tech Specs Containment Isolation Valves.List of Attendees & Handout Encl
	ML20154B078
Person / Time
Site:	North Anna
Issue date:	05/06/1988
From:	Grace J; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Cruden D; VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
References
	NUDOCS 8805170058
	Download: ML20154B078 (17)
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May 6, 1988

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Docket Nos. 50-338, 50-339

License Nos.'NPF-4, NPF-7

Virginia Electric and Power Company

ATTN: Mr. D. S. Cruden, Vice President,

Nuclear Operations

P. O. Box 26666

Richmond, VA 23261

Gentlemen:

SUBJECT:

ENFORCEMENT CONFERENCE SUMMARY

NRC INSPEC1 ION REPORT NOS. 50-338/88-02 AND 50-339/88-02

This letter refers to the Enforcement Conference held at our request on March 28,

1988. This meeting concerned activities authorized for your North Anna facility.

The issues discussed at this conference related to the management controls

relating to inservice testing of Te ,nical Specification containment isolation

valves. A sumary, a list of attendees, and a copy of your handout are enclosed.

In accordance with Section 2.790 of the NRC's "Rules of Practice," Part 2,

Title 10, Code of Federal Regulations, a copy of this letter and its" enclosures

will be placed in the NRC Public Document Room.

Should you have any questions concerning this letter, please contact us.

Sincerely,

M!NAL mcNb n

A % G4Act

J. Nelson Grace

Regional ~ Administrator

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Enclosures:

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Enforcement Conference Summary

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List of Attendees

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Handout

cc w/encls:

G. Kane, Station Manager

N. E. Hardwick, Manager - Nuclear

Programs and Licensing

bec w/encls: (See page 2)

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DRS Technical Assistant

Document Control Desk

Commonwealth of Virginia

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ENCLOSURE 1

ENFORCEMENT CONFERENCE SUMMARY

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The Deputy Regional Administrator opened the meeting by stating that the

surpose of the meeting was to review issues related to North Anna and Surry.

Virginia Electric and Power Company (VEPCO) personnel and NRC personnel

introduced themselves.

The VEPC0 Senior Vice-President stated that the issue related to corrective

actions for inservice valve testing for Technical Specification containment

isolation values would be presented first.

The Assistant Plant Manager,

Operations and Maintenance, North Anna, started the presentation by stating

that VEPC0 did not dispute the inspection findings, that this situation was

considered serious, and that VEPC0 would perform adequate corrective action.

The subsequent discussions consisted of reviewing NRC Inspection Report

No. 50-338, 339/88-02, causes, actions initiated prior to the inspection,

corrective actions taken, corrective actions to be taken, safety significance,

quality assurance audits of the inservice inspection / testing programs, and

conclusions.

During the presents. tion, the Assistant Plant Manager, Operations and Maint! nance,

North Anna, stated that a root cause analysis of the valve failures had been

performed by a consultant; however, this analysis was not fully complete.

During the discussions, NRC and VEPC0 personnel presented sequence of events

summaries to clarify issues.

VEPC0 personnel discussed the valves' failure

analysis with the failures possibly being caused by a silicon residue found in

a valve internal.

VEPC0 personnel stated the valve vendor's position did not

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appear to agree with the VEPC0 position.

When asked if the water intrusion

into the instrument air lines to the solenoid valves was the probable cause of

multiple valve failures, VEPC0 personnel stated that this may have been a

contributor; however, when one solenoid valve that had experienced repeated

failures was disassembled, no evidence of water corrosion was identified on its

internals. Discussions were conducted relative to ASME Section XI requirements,

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corrective action adequacy, and stroke frequencies.

Discussions were also

conducted relative to the effect of the valves' exhaust port piping diameter size

on stroke times, since the valves with smaller exhaust port piping exhibited

longer stroke times.

Discussions were conducted relative to the effectiveness

of quality assurance (QA) audits and QA involvement in this area. The meeting

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was then concluded by the Deputy Regional Administrator.

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ENCLOSURE 2

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LIST OF ATTENDEES

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Virginia Electric and Power Company

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W. L. Stewart, Senior Vice President

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D. S. Cruden, Vice President, Nuclear Operations

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G. E. Kane, Assistant Station Manager, Operations and Maintenance

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M. L. Bowling, Assistant Station Manager (North Anna)

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E. S. Greycheck, Assistant Station Manager (Surry)

G. L. Pannell, Director, SEC

R. S. Hardwick, Jr., Corporate Manager, Quality Assurance

N. E. Hardwick, Manager, Licensing

J. P. Haciejewski, Manager, ISI/NDE

R. F. Driscoll, Manager, Quality Assurance

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H. V. Le, Plant Engineer

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Nuclear Regulatory Conin..sion

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M. L. Ernst, Deputy Regional Administrator

A. F. cibson, Director, Division of Reactor Safety (DRS)

C. W. Hehl, Deputy Director, Division of Reactor Projeccs (DRP)

B. A. Wilson, Chief, Branch 2, DRP.

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C. A. Julian, Chief, Operations Branch, DRS

C. P. Patel, Project Manager, Office of Nuclear Reactor kapinlation (NRR)

L. B. Engle, Projects Manager, NRR

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G. A. Belisle, Chief, Quality Assurance Programs Section, DRS

J. J. Blake, Chief, Materials and Processes Section, DRS

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T. J. Sullivan, Chief, Mechanical Engineering Branch, NRR

J. L. Caldwell, Senior Resident Inspector, North Anna

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L. E. Nicholson, Resident Inspector, Surry

R. D. Gibbs, Reactor Inspector

M. C. Shannon, Reactor Inspector

K. R. Jury, Reactor Inspector

E. H. Girard, Reactor Ir.ipector

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L. M. Slack, Enforcement and Investigation Coordination Assistant

B. Uryc, Senior Enforcement Coordinator

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ENCLOSURE 3

ENFORCEMENT CONFERENCE

ON

NORTH ANNA POWER STATION

INSERVICE TESTING PROGRAM

MARCH 28,1988

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REVIEW OF IR 88 02

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CAUSES

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CORRECTIVE ACTIONS

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SAFETY SIGNIFICANCE

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CONCLUSIONS

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VIRGINIA POWER REVIEW OFIR 88 02 l

ASCO VALVES IDENTIFIED IN IR88 02

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NO PERFORMANCE CONCERNS IDENTIFIED

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REMOVED FROM IST PROGRAM

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PERFORMANCE SAT BASED ON STROKE TIME < 2 SEC

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PERFORMANCE SAT BASED ON ENGINEERING EVAL

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PERFORMANCE SAT BASED ON CORRECTIVE ACTION

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VALVES NOT TESTED MONTHLY BASED ON COLD

SHUTDOWN CODE INTERPRETATION

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STROKING USED AS CORRECTIVE ACTION FOR

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PREVIOUS VALVE FAILURES

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ISI / IST PROGRAM

DIFFERENT INTERPRETATION OF ASME CODE FOR

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CORRECTIVE ACTIONS

lST PROGRAM IMPLEMENTATION WEAKNESSES

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ASCO VALVE PERFORMANCE

SERVICE WATER INTRUSION INTO INSTRUMENT LINES

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MODIFICATIONS TO SOV VENT PORT FOR EQ ENHANCEMENTS

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AFFECTED STROKE TIMES

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ACTIONS lNITIATED PRIOR TO INSPECTIO

REVIEW OF PAST STATION' DEVIATION REPORTS ON MOV

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PROBLEMS TO ENSURE ADEQUATE CORRECTIVE ACTION

EVALVATION OF ASCO SOV FAILURES

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DEVELOPMENT OF ADMINSTRATIVE VALVE STROKE

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LIMITS TO DETECT DEGRADING VALVE PERFORMANCE

BLOWDOWN AND DRAINING OF INSTRUMENT AIR SYSTEMS

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AFTER SERVICE WATER INTRUSION EVENT

UPGRADE OF STATION CORRECTIVE ACTION PROGRAM TO

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ENHANCE ROOT CAUSE DETERMINATION AND PROVIDE

EARLY IDENTIFICATION OF ADVERSE TRENDS

QA AUDITS OF ISI/IST PROGRAM AS REQUIRED BY

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10 CFR 50, APPENDIX B WERE ROUTINELY CONDUCTED OF

BOTH THE STATION AND CORPORATE ISI / IST GROUPS

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CORRECTIVE ACTIONS TAKEN l

ASCO SOVs

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REVIEWED UNIT 1 AND UNIT 2 VALVE HISTORIES

PERFORMED ADDITIONAL VALVE STROKING PRIOR TO

RESTART OF UNIT 1 AND ON UNIT 2 WHILE AT POWER

DEVELOPED AND APPROVED A JCO FOR UNIT 2 VALVES

WHICH COULD NOT BE SAFELY STROKED AT POWER

SHUT DOWN UNIT 2 ON FEBRUARY 12,1988 FOR VALVE

TESTING AND CORRECTIVE ACTION

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DISCRETIONARY ENFORCEMENT WAS GRANTED FOR ONE

UNIT 1 VALVE WHICH COULD NOT BE STROKED SAFELY

AT POWER

CORRECTIVE ACTION WAS TAKEN MARCH 18,1988

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. INCREASED SURVEILLANCE FREQUENCY OF ASCO SOVs

IN IST PROGRAM TO 31 DAYS

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CORRECTIVE ACTIONS TAKEN l

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ASCO SOVs (CONT'D)

REPLACED UNIT 2 SOV EXHAUST TUBING WITH PIPE

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ELBOWS

REPLACED EXHAUST PORT LINES ON 3 UNIT 1 VALVES WITH

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PIPE ELBOWS BASED ON EVALUATION OF STROKE TIMES.

INSPECTED FOUR MODEL 8321 (PISTON TYPE) AND SEVEN

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MODEL 206 380 (LEVER TYPE) ASCO SOVs AND REVIEWED

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WITH ASCO

PERFORMED LABORATORY ANALYSIS OF MODEL 206 380 SOV

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CORRECTIVE ACTIONS TAKEN l

lSI / IST PROGRAM

REVIEWED VALVE STROKE HISTORIES TO ENSURE VALVES

WERE IN ALERT,IF REQUIRED BY ASME CODE, AND TO

IDENTIFY ANY ADVERSE TREND

. REVIEWED VALVES AND PUMPS IN ALERT STATUS TO

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ENSURE AUGMENTED SURVEILLANCES ARE BEING PERFORMED

. STRENGTHENED NOTIFICATION AND FOLLOWUP FOR

PUMPS AND VALVES IN ALERT

. ISSUED OPERATIONS DIRECTIVE TO CLARIFY THE

PROCESS FOR DOCUMENTING PERIODIC TESTS

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. ISSUED MANAGEMENT AND OPERATIONS DIRECTIVES

TO CLARIFY POLICY ON VOIDING WORK ORDERS

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. ASSIGNED ENGINEER TO MAINTENANCE FOR ROOT CAUSE

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EVALUATION OF EQ FAILURES (INCLUDES IST PROGRAM VALVE

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. UPGRADED ADMINISTRATIVE PROCEDURE FOR PUMP AND

VALVE IST PROGRAM

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CORRECTIVE ACTIONS TO BE TAKEN l

ASCO SOVs

REPLACE REMAINING UNIT 1 EXHAUST PORT LINE ELBOWS

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(NEXT COLD SHUTDOWN)

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COMPLETE ROOT CAUSE EVALUATION OF ASCO SOV

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FAILURES INCLUDING INSTRUMENT AIR PURITY AND NEED

FOR PERIODIC VALVE REPLACEMENT (DECEMBER,1988)

ISI / IST PROGRAM

NEW ORGANIZATIONAL EMPHASIS ON NDE / ISI FUNCTIONS

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AT CORPORATE LEVEL (APRIL 1,1988)

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CONDUCT AN INDEPENDENT TECHNICAL REVIEW OF THE

STATION ISI / IST PROGRAM AND IMPLEMENTATION (APRIL 30,1988)

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. QUALITY ASSURANCE DEPARTMENT TO CONDUCT A

PERFORMANCE BASED SURVEILLANCE AUDIT OF THE IST

PROGRAM (APRIL 30,1988)

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CORRECTIVE ACTIONS TO BE TAKEN

ISI / IST PROGRAM (CONT'D)

COVER NEW PUMP AND VALVE IST PROGRAM IN

CONTINUING TRAINING (JULY 31,1988)

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ENHANCE ISI PERIODIC TEST PROCEDURES (OCTOBER 31,1988)

UPGRADE STATION CORRECTIVE ACTION PROGRAM TO ENHANCE

ROOT CAUSE DETERMINATION AND PROVIDE EARLY

IDENTIFICATION OF ADVERSE TRENDS (DECEMBER,1988)

. OP 1-A CHECKLIST FOR UNIT STARTUP FROM COLD SHUTDOWN

TO BE REVISED TO REQUIRE ISI SIGNOFF (APRIL 30,1988)

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_ SAF5TY . SIGNIFICANCE l

JUSTIFICATION FOR CONTINUED OPERATION PROVIDED BY ONE

OR MORE OF THE FOLLOWING:

VALVES OPERABLE BY TECHNICAL SPECIFICATIONS STROKE

TIME REQUIREMENTS

. INITIATING EVENT FOR PREVIOUS FAILURES IDENTIFIED

CORRECTIVE ACTIONS (BLOWDOWN OF AIR LINES, SOV

REPLACEMENT, VALVE EXERCISING) WERE EFFECTIVE

REDUNDANT VALVES WERE OPERABLE

. POTENTIAL CONSEQUENCES ARE GREATLY REDUCED

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BY EXPECTED OPERATOR AND SYSTEM ACTIONS

REVIEWED WITH NRC

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QUAL lTY ASSURANCE AUDITS

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OF ISI / IST PROGRAM

NAPS AUDIT N-85-18 - CORRECTIVE ACTION

- 2 FINDINGS

- POST MAINTENANCE TESTING OF COLD SHUTDOWN VALVES

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NAPS INSPECTION REPORT IR-N-85 772

- TESTING OF MAIN STEAM CODE SAFETY VALVES -> ;;;;d", Le~e

CORPORATE AUDIT N-86 79

INSERVICE INSPECTION

8 FINDINGS

- ISI MANUAL REVISION

NAPS AUDIT N 86-21 - INSERVICE INSPECTION

- 1 FINDING

5 AREAS NEEDING PROGRAMS, PROCEDURES, OR

PROGRAM SUMMARIES

NAPS ACTIVITY REPORT AR N 861647

- POST MAINTENANCE TESTING

NAPS AUDIT N 87 21

INSERVICE INSPECTION

- 1 FINDING

- UNIT 2 40 MONTH PLAN NOT IN STATION RECORDS

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QA AUDIT PROGRAM IS ADEQUATE

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IST PROGRAM IS ADEQUATE

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VALVE PROGRAM IS CURRENTLY IN COMPLIANCE WITH

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ASME SECTION XI AND TECH SPECS

INCREASED EMPHASIS ON EFFECTIVE IMPLEMENTATION

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IS BEING MADE

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CORRECTIVE ACTIONS HAVE BEEN IDENTIFIED AND ARE

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BEING IMPLEMENTED ON A PRIORITY BASIS

NONCOMPLIANCE WITH ASME CODE FOR AFFECTED ASCO

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SOV TRIP VALVES HAD MINIMAL SAFETY SIGNIFICANCE

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ML20154B078

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