ML20207P250
| ML20207P250 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 01/07/1987 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF ADMINISTRATION (ADM) |
| References | |
| 86-813, NUDOCS 8701150303 | |
| Download: ML20207P250 (5) | |
Text
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VINGINIA ELECTHIC AND Pownu COMPANY CFR2.201 nicuxono.vinoixm unvoi w.L.sen.sv udE.5. "".'.""..
January 7, 1987 U. S. Nuclear Regulatory Commission Serial No.86-813 Attn: Document Control Desk N0/RMK:dmk 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 RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT NOS. 50-338/86-25 AND 50-339/86-25 We have reviewed your letter of December 4,
- 1986, in reference to the inspection conducted at the North Anna Power Station from October 13, 1986 to November 17, 1986, and reported inInspectionReportNos.50-3p/86-25and 50-339/86-25. Our response to the Notice of Violation is addressed in the attachment.
We have no objection to this inspection report being made a inatter of public disclosure.
If you have any furth9r questions, please contact me.
Very truly yours.
W. L. Stewart Attachments Q115030387o107 ADOCK 05000330 O
PDR 760f I(
cc:
U. S. Nuclear Regulatory Conunission Suite 2900 Marietta Street, N. W.
Atlanta, GA 30323 Mr. J. L. Caldwell l
NRC Senior Resident Inspector North Anna Power Station
RESPONSE TO NOTICE OF VIOLATION ITEM REPORTED DURINC THE NRC INSPECTION CONDUCTED FROM OCTOBER 13 TO NOVEMBER 17, 1986 INSPECTION REPORT NOS. 50- 3 /86-25 AND 50-339/86-25 NRC COMMENT l
A.
10 CFR Appendix B Criteria VI states the following:
" Measures shall be established to control the issuance of documents, euch as instructions, procedures, and drawings, including changes thereto, which prescribe all activities affecting quality. These measures shall assure that documents, including changes, are reviewed for adequacy and approved for release by authorized personnel and are distributed to and used at the location where the prescribed activity is performed. Changes to documents shall be reviewed and approved by the same organizations that performed the original review and approval unless the applicant designates another responsible organization."
Contrary to the above, adequate measures were not established to assure the adequacy of the issuance of Technical Specification (TS) amendments as shown in the following examples.
(1) On August 27, 1986, amendments 84 for Unit I and 71 for Unit 2 were incorporated into the station TS but these amendments, as incorporated by the licensee, contained info rmation different from that approved by the NRC on August 25, 1986.
(2) On October 22, 1986, the licensee final issuance of amendment 71 for Unit 2 contained minor typographical errors and an omission which changed the technical meaning of information which had been approved by the NRC on August 25, 1986.
This is a Severity Level V violation (Supplemental I).
RESPONSE
1.
ADMISSION OR DENIAL OF THE ALLE0ED VIOLATION This violation in correct as stated.
2.
REASON FOR THE VIOLATION Because this violation involven deviations resulting from both the practice of issuing " pink sheet" copien of approved licenne amendments and the method by which the officini " white sheet" copies of amendments are prepared for distribution, the reasons for thin violation are categorized na the following.
A.
Insuance of Temporary " Pink Sheet" Copies of Amendments #84 (Unit
- 1) and #71 (Unit 2).
The practice of issuing " pink sheet" copten of new amendments to Technical Specifications (TS) manual holdern was instituted as a means of ensuring that compliance with new licenno requirements was achieved in a timely manner.
In this cano, the " pink sheet" l
l
copies were made frcm the Company's proposed core uprate TS changes in an effort to disseminate the new license conditions as quickly as possible. The proposed core uprate TS change used to prepare the " pink sheet" copies of the amendments did not include other unrelated changes since these other changes were approved by the NRC after the submittal of the proposed core uprate TS change.
Consequently, the " pink sheet" amendments issued to station personnel contained a number of errors.
B.
Issuance of Official " White Sheet" Copies of Amendments #84 and
- 71.
In order to ensure the legibility of new license amendments issued to TS manual holders, the practice of retyping new amendments received from the NRC was established. The following errors were made during the retyping of Amendment #71.
" Tabulation of Changes" sheet incorrectly identified that License page 4 was to be replaced, rather than License page 3.
- The word "not" was omitted from License condition 2.C.(1).
- The date on page 3/4 2-15 was mistakenly changed.
Even though an accuracy check was performed, in accordance with normal practice, the errors were undetected.
Consequently, the official copies of Amendment #71, containing the errors identified above, were distributed to TS manual holders.
3.
CORRECTIVE STEPS WHICll HAVE BEEN TAKEN AND Tile RESULTS ACHIEVED A.
Issuance of Temporary " Pink Sheet" Copies of Amendments #84 and
- 71.
Corrected " pink sheet" copies of Amendments #84 and #71 were issued to TS manual holders by October 21, 1986. These temporary sheets were copied directly from the NRC issued pages to ensure accuracy.
B.
Issuance of Official " White Sheet" Copies of Amendments #84 and
- 71.
Amendments #84 and #71 were reissued to all TS manuni holders in their entirety by December 8, 1986.
These reissued amendments were copied directly from the NRC lasued pages.
A review of the safety impact of the errors in both the " white" and
" pink nhoot" amendments was conducted. No unsafe conditions resulted from the issuance of these amendments.
e 4.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS A.
Issuance of Temporary " Pink Sheet" Copies of License Amendments.
All future temporary " pink sheet" copies of new amendments will be copied directly from the NRC issued pages exclusively. Accuracy checks of new amendments will, however, continue to be performed.
B.
Issuance of Official " White Sheet" Copies of License Amendments.
The practice of retyping license amendments received from the NRC has been discontinued.
All future amendments will be copied directly from the NRC issued pages. Accuracy checks will continue to be performed. The potential for introducing errors during transcription of new amendments has been eliminated.
In addition to the corrective steps described above, all previously issued " white sheet" license amendments which were retyped have been reviewed for accuracy and correctness.
Although a number of typographical errors have been identified, none of these errors adversely impact the safety of either Unit 1 or Unit 2.
TS manual holders have already been issued corrected pages.
5.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED With regard to the deviations identified in this violation, full compliance was achieved by December 8,
1986.
The remaining typographical errors were corrected and distributed to TS manual holders.
I i
t
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