ML20154L052
| ML20154L052 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 02/28/1986 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| 86-071, 86-71, NUDOCS 8603110382 | |
| Download: ML20154L052 (4) | |
Text
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. VIRGINIA ELECTRIC AND l'OWUH COMPANY Ricuxoxn,VrunixrA ununI w.t.. stun ar wo((d'o"['.[7...
February 28, 1986
~
Dr. J. Nelson Grace Serial No. 86-0712 Regional Administrator NAPS /JHL/aca E
Region II Docket No. 50-338; U. S. Nuclear Regulatory Commission License No. NPF-k2 Suite 2900 101 Marietta St., N.W.
7L Atlanta, Georgia 30323
Dear Dr. Grace:
C3u VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNIT 1 RESPONSE TO NOTICE OF VIOLATION I
NRC INSPECTION REPORT NOS. 50-338/85-36 AND 50-339/85-36 We have reviewed your letter of January 30, 1986, in reference to the inspection conducted at North Anna Power Station from December 2,1985 to January 5,1986, and reported in Inspection Report Nos. 50-338/85-36 and 50-339/85-36. Our response to the Notice of Violation is addressed in the attachment.
We have no objection to this inspection report being made a matter of public disclosure.
If you have any further que:tions, please contact me.
Very truly yours, W. L. Stewart Attachment 8603110382 860220 PDR ADOCK 05000338 G
/ l 2EDI
a.
VanoixrA ELECTRIC AND Powna COMPANY TO cc:
Mr. Roger D. Walker, Director Division of Reactor Projects NRC Region II Mr. Lester S. Rubenstein, Director PWR Project Directorate # 2 Division of PWR Licensing - A Mr. M. W. Branch NRC Senior Resident Inspector North Anna Power Station Mr. Leon B. Engle NRC North Anna Project Manager PWR Project Directorate #2 Division of PWR Licensing-A
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RESPONSE TO NOTICE OF VIOLATION ITEM REPORTED DURING NRC INSPECTION CONDUCTED FROM DECEMBER 2, 1985 TO JANUARY 5, 1986 INSPECTION REPORT NOS. 50-338/85-36 and 50-339/85-36 NRC COMMENT:
10 CFR 50, Appendix B, Criterion V, as implemented by the VEPC0 QA Topical Report (VEP-1-4A), requires that activities affecting quality shall 'be prescribed by documented instructions, procedures or drawings of a type appropriate to circumstances and shall be accomplished in accordance with these instructions, procedures or drawings.
Design Change 83-32. procedure used through Field Change No. 36 was employed for the installation of environmentally qualified solenoid operated valves.
The solenoid operated. valve vendor installation instructions provided by the Automatic Switch Company (ASCO) for series 206-380 valves states that the valve must be mounted with the solenoid vertical and upright.
Contrary to the above, Design Change 83-32 procedure was not appropriate for use through Field Change No, 36, dated October 12, 1985, in that it contained conflicting requirements, resulting in improper installation of an ASCO solenoid operated valve, S0V-BD-100H. The solenoid was mounted at; an approximate 45 degree angle to the vertical instead of in the required vertical position.
l This is a Severity Level IV violation (Supplement I) and applies only to Unit 1.
RESPONSE
1.
ADMISSION OR DENIAL OF THE ALLEDGED VIOLATION:
The violation is correct as stated.
2.
REASONS FOR THE VIOLATION:
Step 4.1.05.8 of DCP 83-32 states " Install new SOV in accordance with ASCO Instruction Manual and in the same orientation as the old SOV was installed". The ASCO Instruction Manual, under the heading Positioning, states " valves must be mounted with the solenoid vertical and upright".
These statements are conflicting. The existing SOV was mounted on an angle and the new SOV was mounted on the already existing support which was on an angle. The new SOV was installed in the same position as the old SOV but not " vertical and upright".
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3.
CORRECTIVE STEPS WIIIClf IIAVE BEEN TAKEN AND TliE RESULTS ACIIIEVED:
A review was performed on the S0V in question and it was, in fact, installed incorrectly in DCP 83-32.
A review was then conducted on the other S0Vs that were installed using DCP 83-32 and several other S0Vs were also oriented incorrectly. To correct the discrepancy, Field Change No.
38 was written to make new supports and mount the affected SOVs in the vertical position.
The proper installation of the affected SOVs was completed on December 19, 1985.
4.
CORRECTIVE STEPS WilICli WILL BE TAKEN TO AVOID FURTIIER VIOLATIONS:
The Site Engineering Office (SEO) will review the active DCP's to ensure that steps requiring the installation of equipment / devices are clear, concise, and in accordance with applicable manufacturers requirements.
The SE0 will ensure that the installation of equipment can be performed as required when specifying installation in accordance with the manufacturer's instructions. The SEO will re-emphasize the importance of this to applicable personnel as described in E&C Standard STD-GN-0001,
" Instructions for DCP Preparation."
Since Quality Control (QC) personnel did not identify the inconsistency in the DCP at a QC hold point, QC personnel will be directed to be more observant of instructions provided in manufacturer's instruction manuals.
When there is conflict between the DCP and the manufacturer's instructions the discrepancy will be brought to the attention of engineering for resolution.
5.
DATE WilEN FULL COMPLIANCE WILL BE ACIIIEVED:
The items described in Section 4 of this response will be completed by April 1, 1986.
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