ML20205A999
| ML20205A999 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 07/31/1986 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| 86-458, NUDOCS 8608110497 | |
| Download: ML20205A999 (4) | |
Text
DMf5 VIROINIA ELECTHIC AND Pownu CoxiwNY Ricnxoxn,VIHOINIA 20061 July 331, g986 0 6 0
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,,iae Vars Pasususwr NectsAs Oramations Dr. J. Nelson Grace Serial No.86-458 Regional Administrator NAPS /JHL/vlh Region II Docket Nos.
50-338 U. S. Nuclear Regulatory Commission 50-339 Suite 2900 License Nos. NPF-4 101 Marietta St., N.W.
Dear Dr. Grace:
VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNITS NO. 1 AND 2 RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT NOS. 50-338/86-13 AND 50-339/86-13 We have reviewed your letter of July 1,
1986, in reference to the inspection conducted at North Anna Power Station from May 5,1986 to June 1,
1986, and reported in Inspection Report Nos.
50-338/86-13 and 50-339/86-13.
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 questions, please contact me.
l Very truly yours, l
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l W.
. Stewart Attachment l
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cc:
Mr. Lester S. Rubenstein, Director PWR Project Directorate #2 Division of PWR Licensing-A Mr. J. L. Caldwell NRC Senior Resident Inspector North Anna Power Station l
Mr. Leon B. Engle NRC North Anna Project Manager PWR Project Directorate #2 Division of PWR Licensing-A t
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e RESPONSE TO NOTICE OF VIOLATION ITEM REPORTED DURING NRC INSPECTION CONDUCTED FROM MAY 5, 1986 TO JUNE 1, 1986 INSPECTION REPORT NOS. 50-338/86-13 AND 50-339/86-13 NRC COMMENT:
Technical Specification 6.8.1.a requires that procedures be implemented and maintained covering safety-related activities addressed in Appendix "A" of Regulatory Guide 1.33, Revision 2, February 1978, which includes procedures for repair or replacement of major equipment during the life of the plant. Administrative Procedure 3.1, provides control of equipment design changes and associated testing via the Design Change Procedure.
Contrary to the above, as of June 6, 1986 the corrected specific gravity of the replaced station batteries was not determined and documented as required by the acceptance tests and their data sheets, associated with design change procedures 85-29 and 85-30 for Units 1 and 2, respectively.
The station batteries were replaced during November 1985, and March 1986 time frame for both units.
This is a Severity Level IV violation (Supplement I).
RESPONSE
1.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION:
The violation is correct as stated.
2.
REASONS FOR THE VIOLATION:
The cause of the violation is an inadequate procedure.
Design Change Packages (DCP) 85-29 and 85-30 required performance data to be taken at the factory before shipment, after battery installation, after the initial charge, and after the service test.
The testing that was incorporated into the DCPs satisfied the Technical Specification
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surveillance requirements with the exception of level correction.
The i
requirement to correct the specific gravities for level was not
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specifically delineated in the DCPs; however, the instructions required l
1evels to be taken and a column for corrected specific gravities was included on the data sheets.
l The only portion of the required surveillance that was not performed during testing was the correction of the specific gravities for full i
electrolyte level.
During installation and initial testing the battery I
vendor was contacted to clarify the definition of " full" battery level as stipulated in the Technical Specifications.
The vendor stated that the batteries are " full" and no correction is required if the level is between the high and low marks on the cell.
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. o After the batteries were installed, the battery vendor later stated that the specific gravities could be corrected for level.
3.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:
The testing that was done initially on the replacement batteries satisfied the required surveillances except for level correction of the specific gravities. During the first surveillance interval (92 days) the required surveillances were satisfactorily performed on the batteries.
4.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
Administrative Procedure (ADM) 3.1 will be revised to ensure that applicable Technical Specification surveillance requirements are satisfied during the design change process.
5.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
ADM-3.1 will be revised by August 29, 1986.
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