ML20209G426
| ML20209G426 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 08/28/1986 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| 86-505, NUDOCS 8609120467 | |
| Download: ML20209G426 (7) | |
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[) M10 VINGINIA ELECTRIC AND POWEH COMi%NY Ricinwoxn,VinoixiA u:1unt August 28, 1986 gg. sg 3 Pl.su W.L.STEWANT Vaca l'annsommt NarrLaam OPRBATIONN Dr. J. Nelson Grace Serial No.86-505 Regional Administrator NAPS /JHL/bgp Region II Docket Nos. 50-338 U. S. Nuclear Regulatory Ccmnission 50-339 Suite 2900 License Nos. NPF-4 101 Marietta St., N.W.
Dear Dr. Grace:
VIRGINIA ELECTRIC AND POWER CCNPANY NORIE ANNA POWER STATIM UNITS NO.1 AND 2 RESPONSE 'IO NCTICE OF VIOIATION NRC INSPECTION REIORT NOS. 50-338/86-17 AND 50-339/86-17 We have reviewed your letter of July 29, 1986, in reference to the inspection conducted at North Anna Power Station frcun June 2,1986 to July 6, 1986, and reported in Inspection Report Nos. 50-338/86-17 and 50-339/86-17.
Our responses to the Notices of Violation are addressed in the attachment.
Due to an oversight, we inadvertently overlookal your request to address the additional inspector findings on design change procedures, detailed in paragraph 13 of Inspection Report Nos. 50-338, 339/86-13 dated July 1,
1986.
As discussed between Mr. G. L. Pannell and Mr. A. J. Ignatonis on August 11, 1986, it was agreed that the additional information, provided below, would be included in the response to this inspection report.
a.
The Attachment 6.1 of Administrative Procedure 3.1 titled " Design i
Change Notification for Final Design Testing" was missing frtzn l
design change package 85-30.
l l.1 was not included in design change 85-30. To prevent l
recurrence, administrative procedure (ADM) 3.1 is being revised to ensure that appropriate material is included in DCPs.
b.
'Ihere is no requirenent for quality control to review and sign for the ccrupleted acceptance test.
[
'.2, " Station Design Change Acceptance Form", was signed off by the Site Engineering Supervisor, the Cognizant QC Supervisor and approved by the Station Nuclear Safety and Operating l
Ccmnittee (SNSOC) as acceptable and ccznplete with respect to the deficiencies in DCP 85-30.
8609120467 860828 PDR ADOCK 05000338 2l G
PDR f
Quality Control reviews acceptance testing in a surveillance mode during the design change process. OA does review the design change package when the Design Change Acceptance Form is cmpleted.
This is to review the entire package for empleteness and any additicnal deficiencies.
We plant procedures, identified in the design change procedures as c.
requiring modifications to bring then into cmpliance with the design change, were not modified.
1/2-PT-85, 86, 87, and 88 have been revised and approved by SNSOC.
To prevent this deficiency frm recurring, AIN-5. 28,
" Procedure Revisions Due to Design Changes", will be revised to interface with AIM-3.1 to ensure timely revision of documents that are affected by design changes.
d.
The specific gravities for the batteries were not corrected for level or tenperature as required by the test data
- sheets, TS 4.8.2.3.2.a.2 and IEEE-450, 1980.
We response to this item is addressed in our response to the notice of violation in Inspection Report Nos. 86-13.
We have no objection to this inspection report being made a matter of public disclosure.
If you have any further questions, please contact me.
Very truly yours, W. L. Stewart Attachment
cc:
Mr. Lester S. Rubenstein, Director PWR Project Directorate #2 Division of PWR Licensirg-A Mr. J. L. Calchell NRC Senior Resident Inspector North Anna Power Station Mr. Iron B. Engle NRC North Anna Project Manager PWR Project Directorate #2 Division of PWR Licensing-A i
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RESPONSE TO IUI' ICE OF VIOIATION ITEM REPORTED DURING THE NBC INSPECIION OONDUCTED FROM JUNE 2 TO JULY 6,1986 INSPECTION REPORT NOS. 50-338/86-17 AND 50-339/86-17 NRC OCIHENT A.
10 CFR 50 Appendix B, Criterion XI, Test Control, states in part that a test program shall be established to assure that all testing required to denonstrate that structures, systens and ccznponents will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents. Also, the test results shall be documented and evaluated to assure that test requirenents have been satisfied.
Contrary to the above, as of July 6, 1986, the licensee did not have a formal program requiring acceptance tests for design change procedures to be reviewed for Tecimical Specification requirenents or a formal method to provide additional testing to meet Technical Specification requirenents prior to the modified equipnent being declared operational.
This is a Severity Ievel IV violation (Supplement I) for Units 1 and 2.
RESPONSE
1.
AEMISSION OR DENIAL OF THE AILEGED VIOIATION This violation is correct as stated.
2.
REASON FOR THE VIOIATION This violation was caused by a deficiency in the Design Change process. There was no formal mechanism to ensure that equipnent, that was replaced or modified, satisfactorily meets applicable Tbchnical Specification surveillance requirements prior to being put back in service.
Previously, a mechanism to ensure that equignent covered by the Technical Specifications was operable prior to being put back into service was the IfD action statment log.
3.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND 'IEE RESULTS ACHIEVED ADM-3.1 is in the process of being revised to ensure that the Surveillance and Test Group receives and reviews a draft copy of any Design Change Package (DCP) that affects Technical Specification surveillance requirenents. 'Ihis review will ensure that the applicable surveillance requirements will be satisfied during the performance of final design testing in design change packages.
In addition, the Surveillance and Test Group will review the final design testing to ensure Technical Specification surveillance requirenents are met.
4.
CORRECTIVE STEPS WHICH WIIL BE TAKEN 'IO AVOID FURTHER VIOIATIONS ADM-3.1 will be revised by August 29, 1986 as described in section 3 above.
5.
DATE WHEN FULL CCNFLIANCE WIIL BE ACHIEVED AEM-3.1 bill be revised by August 29, 1986.
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RESPONSE 'IO NCTTICE OF VIOIATION ITD4 REPORTED DURING THE NRC INSPECTION CONDUCTED FRCN JUNE 2 'IO JULY 6,1986 INSPECTION REPORP NOS. 50-338/86-17 AND 50-339/86-17 NRC OCPNENT B.
Technical Specification 6.8.1.a requires the licensee to implenent approved procedures covering the areas recm mended in Appendix "A" of Regulatory Guide 1.33, Revision 2,
February 1978, which includes administrative procedures for equipnent control.
Administrative Procedure 14.1, Jumpers (Terporary Modifications),
requires a written safety evaluation for jumpers installed in systens that are safety-related or installed in systens, camponents or equip wnt which are described in the Updated Final Safety Analysis Report (UFSAR).
'Ihis procedure canplies with the 10 CFR 50.59 requirenent which requires the licensee to maintain records of changes in the facility, including a written safety evaluation which provides the basis for the determination that the change does not involve an unreviewed safety question.
Contrary to the above, Administrative Procedure 14.1 requirements were not fully implenented in that no written safety evaluation was performed for an electrical jumper installed on January 2, 1986.
Jurrper N-1-1165 was installed for the purpose of renoving fran service the 1H Dnergency Diesel Generator Control Roan Annunciator.
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'Ihis is a Severity Level IV violation (Supplanent I) for Unit 1 only.
RESPONSE
1.
ADMISSION OR DENIAL OF 'IEE AILEGED VIOIATION l
This violation is correct as stated.
l 2.
REASON FOR 'IEE VIOIATION 1
This violation was caused by the failure of personnel to realize that the jumpered function was a function described in the UFSAR and, as l
such, required a written safety evaluation to address the review required by 10 CFR 50.59.
3.
CORRECTIVE STEPS WHIG HAVE BEEN TAKEN AND RESULTS ACHIEVED A written safety evaluation has been performed on the junpered function. It has been determined that the change does not involve an unreviewed safety question.
The Station Administrative Procedure that governs the review and approval of jumpers (tmporary modifications) was revised on July 31, 1986 to strengthen the overall control of this function.
This procedure now requires a written safety evaluation for all jumpers to ensure that the change does not involve an unreviewed safety function.
4.
CORRECTIVE STEPS WHICH WILL BE TAKEN 'IO AVOID FURTHER VIOIATIONS No further corrective actions are required.
5.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full canpliance has been achieved.
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