ML20209H878
| ML20209H878 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 10/31/1985 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| 85-704, NUDOCS 8511110256 | |
| Download: ML20209H878 (4) | |
Text
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VINGINIA ELECTRIC AND PowEn COMPANY RICitMOND, VIRGINIA 20 2 6I t
W.L. STEWART Vaca PameanswT -
Nuctuan Oramations October 31, 1985 Dr. J. Nelson Grace Serial No.85-704 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:
We have reviewed your-letter of September 19, 1983, in reference to the inspection conducted at North Anna Power Station from August 5 to September 1,1985, and reported in Inspection Report Nos. 50-338/85-22 and 50-339/85-22. In a telephone call with Mr. Virgil Brownlee of your staff on October 20, 1985, we requested and were granted until November.1,1985 to respond to your letter. Our response to the Notice of Violation is addressed in the attachment.
We. have determined that.no proprietary information is contained in the,
report.
Accordingly, VEPC0_ has no objection to this inspection report being made a matter of public disclosure.
.Very truly yours, f
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W.
. Stewart
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8511110256 851031-ADOCK 0 % yB DR
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s VinointA Et.zetalC AND Powra COMPANY TO Dr. J.-Nelson Grace Mr.". Rogiir D.' iWalker,iDirector.,
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Division'of Project 'and Resident Programs i..
Mr. Edward J. Butcher. Acting Chief Operating Reactors Branch No. 3
_ Division of Licensing-Mr. M. W. Branch NRC Resident Inspector North Anna Power Station I
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s RESPONSE TO NOTICE OF VIOLATION -
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. ITEM REPORTED DURING NRC INSPECTION CONDUCTED FROM AUGUST 5, 1985 TO SEPTEMBER 1, 1985
-INSPECTION REPORT NOS. 50-338/85-22 AND 50-339/85-22 NRC COMMENT:
Unit 1 Technical Specification (TS) 3.3.3.6 action (a) requires that with the number of operable accident monitoring channels less than the total number of channels 7 shown in Table 3.3-10, either restore the inoperable channel lto operable status within 7 days or be in at least hot shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
Table 3.3-10 requires a total number of two channels of Reactor Vessel Coolant Level Monitoring (RVLIS) equipmen.
To verify. operability, ETS 4.3.3.6 requires the monthly performance of a channel check of the RVLIS system.
1-PT-44.7, Power Operate'd Relief Valve, Core Cooling Monitoring, and RVLIS Indication-Channel Check, dated July 3,1985, used to satisfy the
'cl annel. check requirement, specified an acceptance criterion of two percent span between channels.
Contrary: to. the. above, on August - 19, 1985, the dynamic range of the Unit 1 RVLIS system failed.co meet the acceptance criterion of two percent span between-channels. (i.e., actual values were four percent between channels) and the,. unit continued to operate at power past the seven day limit, which was exceeded on August 26, 1985.
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This is a Severity Level IV violation (Supplement I) and applies to Unit 1.
RESPONSE
1.
~ ADMISSION OR DENIAL OF THE ALLEGED VIOLATION:
.This violation is correct as stated.
2.
REASONS FOR THE VIOLATION:
The1 operator performing 1-PT-44.7 was misled as to the actions required ~by the procedure's acceptance criterion. Procedure 1-PT-44.7 used by the operator was approved by SNSOC, but was in handwritten form. Final typing of the procedure was in progress.
As noted in the inspection report, "The acceptance' criterion
. portion of the procedure stated, in part, that 'the maximum span
..between trains for.the reactor 1 vessel level indication system is less than 2% or a Work Request (WR) has been submitted to recalibrate the system and the appropriate Action Statement 4
1, has been entered.'- Prior to the procedure's approval, the
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Performance and Test Engineer had lined through the underlined section of the above quote. He.later attempted to reinstate the lined-through section by annotating it with "OK", as a proofreader's notation..." -This resulted in the operator submitting a Work Request and not entering the Technical Specifications action statement.
3.
CORRECTIVE STEPS WHICH HAvi BEEN TAKEN AND THE RESULTS ACHIEVED:
On August 27, 1985,; action required by T.S. 3.0.3 was initiated and the RVLIS vendor was contacted to obtain assistancs in evaluating the system's operability.
Based upon the vendor's recommendation and re-evaluation of the test data, the RVLIS was determined to be operable, thus satisfying the action required by TS 3.0.3.
A final typewritten version of procedure 1-PT-44.7 was issued on August 28, 1985.
4.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
Personnel responsible for-initiating and reviewing procedure revisions will.be rainstructed by memorandum from the Station Manager.s to the importance of denoting changes in a legible and ordecly fashion. This has been completed.
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The chairman of the Station Nuclear Safety and Operating Committee (SNSOC) will review and emphasize the details of this event.with the SNSOC members.
Station Administrative Procedure 3.4 will be revised to require that prior to issuance of new or revised procedures in handwritten form, the cognizant department supervisor shall assure that the procedure is written in a legible and orderly fashion with extraneous markings removed.
5.
THE DATE WHEN FULL COMPLIANCE WILL BE dCHIEVED:
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Full' compliance will be achieved by November 30, 1985.
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