ML20211J250
| ML20211J250 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 10/01/1997 |
| From: | Ohanlon J VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-338-97-06, 50-338-97-6, 50-339-97-06, 50-339-97-6, 97-531, NUDOCS 9710080046 | |
| Download: ML20211J250 (8) | |
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VmOINIA Ei.ecruic Asn Powen CosirAsv Riniu psn, h m stA 2.ne,i e
October 1, 1997 I
U. S. Nuclear Regulatory Commission Serial No.97-531 Attention: Document Control Desk NAPS /JHL R1 Washington, D. C. 20555 Docket Nos.
50-338/339 License Nos.
NPF-4/7 i
Gentlemen:
ylBGINIA ELECTRIC AND POWER COMPANY NOATH ANNA POWER STATION UNITS 1 AND 2 INSPECTION REPORT NOS. 50-338/97-06 AND 50-339/9Z-Q1 REPLY TO A NOTICE OF VIOLATION We have reviewed your letter of September 5,1997, which referred to the inspection conducted at North Anna Power Station from June 22,1997 through August 9,1997, and the associated Notices of Violation which were reported in inspection Report Nos.
50-338/97-06 and 50-339/97-06. Our reply to the Notice of Violation is attached.
On September 23,1997, the NRC Resident inspectors conducted an exit raeeting for the inspection period of August 10,1997 through September 20,1997. The inspection results will be documented in NRC Inspection Report Nos. 50-338/97-07 and 50-339/97-07. The Inspection Report will document a Notice of Vio ation for station personnel failing to properly follow proedures during ventilation radiation monitor maintenance. This event occurrad prior to the NRC issuance of NRC Inspection Report Nos. 50-338/97-06 and 50-339/97-06 dated September 5,1997. The corrective actions documented in the attachment to this letter are inclusive of the corrective actions for the Notice of Violation that will be issued in NRC Inspection Report Nos. 50-338/97-07 and 50-339/97-07. Therefore, it is requested that no written response be required for the Notice of Violation that will be included in NRC Inspection Report Nos. 50-338/97-07 and 50-339/97-07.
No new commitments are intended as a result of this letter. If you have any further questions, please contact us.
s Very truly yours f
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P. O'Hanlon i
S r Vice President - Nuclear Attachment 9 10000046 971001 PDR ADOCK 05000338 O
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cc:
U. S. Nuclear Regulatory Commission Region 11 Atlanta Federal Center 61 Forsyth 9t. SW, Suite 23T85 Atlanta, Georgia 30303 Mr. M. J. Morgan NRC Senior Resident inspector North Anna Power Station h
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REPLY TO A NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-338/97-06 AND 50-339/97-06 i
NRC COMMENT During an NRC inspection conducted on June 22 through August 9,1997, a violation of NRC requirements was identified. In accordance with the " Genera 1 Statement of Policy _
j and Procedures for NRC Enforcement Actions," NUREG 1600, the violation is listed below:
Technical Specification 6.8.1.a requires that written procedures shall be established, implemented and maintained covering the applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, Revision 2, Febraary 1978.
Regulatory Guide 1.33, Quality Assurance program Requirements (Operations),"
Appendix "A", Paragraphs 1,c and 8 b require procedures for equipment control and surveillance tests, respectively.
Operations Department Administrative Procedure, OPAP-0010, " Tag-Outs,"
Revision 8, Otep 6.10.2.a requires the use of the appropriate procedure (e.g.,
Maintenance Operating Procedure) in conjunction with the tagging record, as instructions to align components and remove equipm9nt tagt Unit 1 Periodic Test Procedure,1-PT-36.1B, " Train B Reactor Protection and Engineered Safety Feature Logic Channel Functional Test," Revision 19, Step 6.2.3.C.2, requires closure of the reactor trip bypass breaker compartment door before an operator reopens the door and racks the bypass breaker into the connect position in the following step.
Unit 1 Periodic Test Procedure,1-PT-32.3.5, " Steam Generator B Steam Flow / Feed Flow Protection IV Channel Functional Test," Revision 28, Steps 6.1.5 and 6.1.8 require verificatioi, of the correct test switch positions prior to actual testing. Step 6.1.6 requires that the test cabinet door be opened before testing. Step 6.3.6 requires that the test switch cabinet door, which was opened in Step 6.1.6, is to be locked closed when testing is complete.
Unit 1 Periodic Test Procedure,1-PT-32.3.6, " Steam Generator C Steam Flow / Feed Flow Protection IV Channel Functional Test," Revision 27, Steps 6.1.5 and 6.1.8 require verification of the correct test switch positions prior to actual testing. Step 6.1.6 requires that the test cabinet door be opened before testing.
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Contrary to the above, equipment control and surveillance test procedures were not implemented as evidenced by:
- 1. On July 9,1997, while retuming the Service Water System to service following maintenance, the unit shift supervisor failed to use 0-MOP-49.14 with Tagging Record (N) 0-97-SW-0015 to align components and remove equipment tags.
- 2. On July 10,1997, during performance of 1-PT-36.1B, the n signed electrician failed to perform Step 6.2.3.C.2.
- 3. On August 2,1997, during performance of 1-PT-32.3.5, the instrument and control technicians failed to perform Steps 6.1.5,6.1.6,6.1.8, and 6.3.6.
- 4. On August 2,1997, during performance of 1 PT-32,3.6, the instrument and control technicians failed to perform Steps 6.1.5,6.1.6 and 6.1.8.
This is a Severity Level IV violation (Supplement 1).
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l BEPLY TO NOTICE OF VIOLATION 1.
REASON FOR THE VIOLATION The reason for the violation was personnel error.
A description of the circumstances which lead to each example of the violation is provided below.
During the completion of Maintenance Operating Procedure (MOP) 0-MOP-49.14, Removing Charging Pump and Air Compressor Header No. 2 (B) Supply and Return From Service and Retuming to Service, operators noted that two service water header isolation valves,1-SW-284 and 2-SW-202, were to be left in the closed position. Tagging record (N) 0-97-dW 0015, which was also being cleared, required the valves, to be retumed to their normal open position.
Operations personnel stopped the performance of the procedure and notified the Shift Supervisor in accordance with Operations Administrative Procea (OPAP) 0002. The Operations Shift Supervisor subsequently determined that 0-MOP-49.14 could be safely performed as written with the two service water header isolation valves left in the closed position and then tagging record (N) 0-97-SW-0015 would be used to retum the valves to their normal open position.
The as-left valve positions were noted on the procedure cover page and a procedure deficiency form was submitted. 0-MOP-49.14 was revised later the same day. The Shift Supervisor made the decision to proceed in this manner to allow the timely restoration of the safety related service water system to operable status.
The process described above was not consistent with the requirements of OPAP-0010, Tag-Outs. Specifically, OPAP-0010, Step 6.10.2.a. In part, requires the use of the tagging record, tag stubs and appropriate procedure (MOP, OP, TOP or TMOP), if applicable, as instructions to align components and remove tags, Therefore, 0-MOP-49.14 should have been revised to retum the two service water valves to the open position while clearing the tagging record.
During the performance of Periodic Test (PT) Procedure 1-PT-36.1B, Train B Reactor Protection and ESF Logic Channel Functional Test, Step 6.2.3.c.2 directed the Electrician to close the bypass breaker cubicle door following the completion of the bypass breaker inspection. The next step in the procedure had an Operator rack Bypass Breaker B to connect in accordance with Operations Procedure 0-OP 26.15, Local Operation of the Reactor Trip or Bypass Breakers or Rod Drive MG Set Output Breakers.
The Electrician decided not to close the bypass breaker cubicle door since it was going to be immediately reopened in the next procedure step. The Electrician should have followed the procedure as it was written or changed the procedure to reflect the proper step sequence.
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The Inspection Report identified that Steps 6.1.5,6.1.6,6.1.8 and 6.3.6 were not j
followed during the performance of Periodic Test Promdare (PT) 1-PT-32.3.5, i
Steam Generator B Steam Flow and Feed Flow Protection Channel IV (F-MS-1485 and F FW-1486) Channel Functional Test and that Steps 6.1.5, 6.1.6 and 6.1.8 were not followed during the performance of 1-PT-32.3.6, Steam Generator C Steam Flow and Feed Flow Protection Channel IV (F MS-1495 and F-FW-1496) Channel Functional Test. Following our assessment, we believe that this representation does not accurately characterize the identified non-compliance.
We conclude that only Step 6.3.6 was not followed during the performance of 1-PT-32.3.5 ~ 1 PT-32.3.5, Step 6.3.6 directed the Instrument Technician to close and lock Channel IV Protection Cabinet 4,1-El CB-54, and verify Annunciator 1P G-8, PCC CAB IV VIOLATED DCOR OPEN, goes off. However, since the Instrument Technician was going to immediately proceed with the performance of 1-PT-32.3.6 which is in the same protection cabinet, he decided to not close the protection cabinet door because it was going to be immediately opened again.
We believe Steps 6.1.5,6.1.6 and 6.1.8 were followed during the performance of 1-PT-32.3.5 and 1 PT-32.3.6.
Specifically, these steps had already been performed during the performance of 1-PT-32.3.4, Steam Generator A Steam Flow and Feed Flow Protection Channel IV (F-MS-1475 and F-FW-1476)
Channel Functional Test. 1 PT-32.3.4 was the first procedure in the series of procedures that were being performed by the Instrument Technicians. Having successfully periormed 1-PT-32.3.4, the instrument Technicians relied on the requirements of Maintenance Department Administrative Procedure (MDAP) 0019, Maintenance Procedure Usage, to justify that Steps 6.1.5,6.1.6 and 6.1.8 had already been completed. MDAP-0019, Step 6.1.3.c states, "If a procedure step states an action to be performed, and the action was performed previously (e.g., " Remove Test Rig" and the test rig was removed), then the step shall be verified to be completed and the step initialed."
Steps 6.1.5 and 6.1.6 of 1-PT-32.3.4,1-PT-32.3.5 and 1-PT-32.3.6 are written exactly the same in each procedure. Therefore, if the step is performed once, it ic., performed for the series of procedures. Step 6.1.8 requires the Instrument Technicians to verify that selected master test switches are in the normal position.
Each procedure specifies the verification of different master test switches. The instrument Technicians while performing 1-PT-32.3.4 verified that all the master test switches were in the normal position. Therefore, Step 6.1.8 was performed for the three procedures. As a result, the requirements of MDAP-0019 were complied with because the Instrument Technicians were in the same protection cabinet during testing and it was known that the verifications for Steps 6.1.5,6.1.6 and 6.1.8 had already been successfully performed.
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CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS i
ACHIEVED Station deviation reports were initiated to document the deficiencies and to ensure appropriato corrective actions were implemented. Equipment operability was not affected.
The individuals involved in these events were coached on verbatim procedure compliance.
The supervisor of each maintenance craft involved with the Notice of Violation examples (i.e., Electrical arid instrument Maintenance) conducted meetings with their department personnel to discuss the events and emphasize management's expectations on verbatim procedure compliance.
0-MOP-49.14 was revised to reflect the proper operating position of 1-SW-284 and 2-SW-202.
Units 1 and 2 Periodic Test Procedures 36.1 A and 1B were revised to make the Electrician's door closure step conditional. This revision will allow the door to
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remain open if the breaker will immediately be racked to connect by operations f
personnel.
Operations, Radiological Protection, Engineering and Site Services Department management have discussed the imporiance of verbatim procedure compliance
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with personnel in their department.
1 Maintenance management has held all-hands meetings with Maintenance -
Department personnel to:
- review the examples that lead to the Notice of Violation and to discuss their importance,
- further communicate management expectations on verbatim procedure compliance and their bases, i.
- provide a forum for questions and two-way communication, j
A Training Information Bulletin has been issued to station personnel expressing management's expectation for verbatim procedure compliance.
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CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS Operations and Maintenance Administrative Procedures will be reviewed to determine whether clari:ication on procedure / tag-out usage is needed.
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THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED l
Full compliance has been achieved.
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