ML20154B078
| 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) | |
See also: IR 05000338/1988002
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May 6, 1988
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Docket Nos. 50-338, 50-339
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:
1.
Enforcement Conference Summary
2.
List of Attendees
3.
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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Virginia Electric and Power Company
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flay 6,1988
bec w/encis:
NRC Resident Inspector
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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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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COMPLETE ROOT CAUSE EVALUATION OF ASCO SOV
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FAILURES INCLUDING INSTRUMENT AIR PURITY AND NEED
FOR PERIODIC VALVE REPLACEMENT (DECEMBER,1988)
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
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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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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