ML20207G788

Responds to NRC Re Violations Noted in Insp Repts 50-338/88-06 & 50-339/88-06.Corrective Actions:Audit of Operator Aid Program Conducted Prior to Completion of NRC Insp & Noted Discrepancies Corrected

ML20207G788
Person / Time
Site:	North Anna
Issue date:	08/15/1988
From:	Cruden D VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
88-488, NUDOCS 8808240232
Download: ML20207G788 (5)

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VinoixrA ELecruic Axn Powen Coxmur IIIcnnoxo, VrHoINI A 20261 August 15, 1988 D. S. Cu t: Daw Vaca Passionsr-Neca. san U. S. Nuclear Regulatory Commission Serial No.88-488 Attention: Document Control Desk NAPS /JHL Washington, D. C. 20555 Docket Nos. 50-338 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. 50-338/88-06 AND 50-339/88-06 REPLY TO A NOTICE OF VIOLATION We have reviewed your letter of July 15, 1988 which referred to the inspection conducted at North Anna Power Station between March 28 - April 1, 1988 and April 11 - April 15, 1988 and reported in Inspection Report Nos. 50-338/88-06 and 50-339/88-06. The response to the Notice of Violation is provided in the attachment.

We have no objection to this report being made a matter of public record. If you have any further questions, please contact us.

Ve y truly yours,

\ b D. Sk Attachment cc: V. S. Nuclear Regulatory Commission 101 Marietta Street, N. W.

Suite 2900 Atlanta, Georgia 30323 Mr. J. L. Caldwell NRC Senior Resident Inspector North Anna Power Station

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8808240232 880915 ~

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E RESPONSE TO THE NOTICE OF VIOLATION REPORTED DURING THE NRC INSPECTION CONDUCTED FROM MARCH 28 - APRIL 1. '988 AND APRIL 11 - APRIL 15. 1988 INSPECTION REPORT NOS. 50-338/88-06 AND 50-339/88-06 NRC COMMENT During the Nuclear Regulatory Commission (NRC) inspection conducted on March 28 - April 1 and April 11 - 15, 1988, a violation of NRC requirements was identified. In accordance with the "General Statement of Policy ad Procedure for Enforcement Actions," 10 CFR Part 2, Appendix C (1988), the violation is listed below:

Technical Specification 6.8.1.a requires written procedures be established, implemented and maintained covering the activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Regulatory Guide 1.33, Quality Assurance Program Requirements, Appendix A, Revision 2, February 1978 requires administrative procedures for procedural adherence; procedures for the operation of safety related systems, including equipment control activities; and, procedures for implementing Technical Specification surveillances and taking appropriate respcnses to abnormal conditions.

Administrative procedure ADM-5.2, Procedure Adherence, Section 1.1, specifies that procedures shall be followed. Administrative procedure ADM-19.27, Control and Use of Operator Aids, paragraph 5.1, states that "audits of the Operator Aid Log Index will be conducted each calendar quarter and documented on 1-MISC-31." North Anna miscellaneous procedure 1-MISC-31, Quarterly Operator Aid Log Review, paragraph 3.1, states that "all Operator Aids in the areas of the station will be surveyed on a quarterly basis (staggered one-third of the areas every month)."

Operating procedure 1-0P-7.10A, Valve Checkoff -

Casing Cooling System, dated January 8, 1987, requires the Casing Cooling Tank recirculation pump 4A suction isolation valve 1-RS-105 to be open.

Administrative procedure ADM-14.0, Tagging of Systems and/or Components, dated February 4, 1988, requires that tagging shall be used in all cases where systems or components are being removed from service which require special operating configurations.

Techaical Specification Amendment Nos. 84 and 71, issued on August 25, 1986, changed Technical Specification 3.3.2.1 to require engineered safety feature actuation system instrumentation for containment i pressure - high in Mode 4, in addition to the previous requirement to l l

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maintain operability in Modes 1, 2, and 3. Technical Specification Table 4.3-2 requires a channel check every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for containment pressure - high. The action statement for containment pressure - high in Technical Specification Table 3.3-3 requires that an inoperable channel be placed in the tripped- condition within one hour for the operation to proceed. The licensee procedure LOG-4, Control Room Operator Log, is used to implement the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> surveillance requirements for containment pressure - high and abnormal procedure AP-3, Loss of Vital Instrumentation, is used to implement the action statement for inoperability of containment pressure -

high instrumentation.

Contrary to the above, the licensee failed to follow procedures in the following examples:

1. All operator aids were not surveyed for the first, second, and fourth quarters of 1987 or the first quarter of 1988,

2. a system operator closed valve 1-RS-105 without utilizing the provisions of ADM-14.0, and

3. the licensee failed to revise LOG-4 or AP-3 to include the Mode 4 applicability for containment pressure - high.

This is a Severity level IV violation (Supplement I).

RESPONSE

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

2. REASON FOR THE VIOLATION The cause of the violation for not performing the survey of operator aids was due to a failure to follow procedure. Administrative procedure ADM-19.27, Control and Use of Operator Aids, was not properly implemented to document the quarterly audit of operator aids. ADM-19.27 requires the use of 1-MISC-31 to document the audit of operator aids. 1-MISC-31 requires operator aids to be audited on a quarterly basis (staggered one-third of the areas every month). The violation was a result of tracking the quarterly audit frequency of operator aids instead of tracking the audit frequency on a monthly basis (staggered one-third of the areas every month).

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The cause of the Casing Cooling Tank recirculation pump 4A suction isolation valve 1-RS-105 being closed was a failure to follow the I requirements of 1-0P-7.10, Casing Cooling Subsystem of the Recirculation l Spray Subsystem and ADM-14.0, Tagging of Systems and/or Components. The l valve lineup discrepancy occurred during a troubleshooting effort during I the s.vapping of the operating recirculating pumps ar.d chiller units in accordance with 1-0P-7.10. During the troubleshooting. the operator became aware that the discharge check valve 1-RS-106 for the running pump (1-RS-P-4A) was stuck open. The procedure (1-0P-7.10) dia not require the normally open pump suction or discharge valve to have their positions al tered. However, the operator shut 1-RS-105 when the standby recirculation pump (1-RS-P-48) was started to prevent a undesired recirculation path backwards through the non-operating pump and the stuck s open check valve. This action precludes the potential for recirculation bypass flow. The altering of the position of 1-RS-105 should have been authorized in accordance with ADM-14.0 and ADM-5.3, Temporary and Prior to Use Procedure Deviations.

The failure to revise AP-3, Loss of Vital Instrumentation and LOG-4, Control Room Operatcr Log, was due to the failure to identify and/or implement changes to those procedures requiring revision as a result of License Amendments 84 and 71 for North Anna Units 1 and 2. AP-3 and LOG-4 were required to be revised to include Mode 4 applicability for containment pressure high instrumentation. 1 and 2-LOG-4 were identified as needing revision as a result of the amendments. It was an administrative oversight that the procedures were not revised. The channel check surveillonce for containment pressure high instrumentation was conservatively being performed twice a shift (every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />). AP-3 was not idenHfied as requiring revision, and it has been determined that the procedure was not used during any time frame when Mode 4 would have been applicable.

3. CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED An audit of the entire operator aid program was conducted prior to the completion of the NRC inspection. Discrepancies were noted and appropriately corrected.

The operator aid program is being scheduled by the Operations PT ind Work Schedule to ensure the quarterly audit (staggered one-third of the areas every month) is performed. This scheduling is being performed in accordance with ADM-19.1.

1-RS-105 was returned to its required position per 1-0P-7.10A. The personnel involved in the unauthorized closing of 1-RS-105 were counselled on the importance of following procedures. In addition, all Operations personnel were instructed on the importance of following procedures.

l AP-3 and 1 and 2-LOG-4 were revised to include Mode 4 applicability for containment pressure high instrumentation.

A procedures group has been established to enhance the procedure review and revision process. This group will review license amendments to ensure . appropriate procedures are identified and revised as a result of a license amendment.-

4. CORRECTIVE ACTIONS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS No further corrective actions are required.

5. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance has been achieved.

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