ML20212H603

Responds to NRC Re Violations Noted in Insp Repts 50-338/86-28 & 50-339/86-28.Severity Level for Violation a Should Be Revised to Severity Level V.Corrective Actions: Technician Counseled Re Importance of Following Procedures

ML20212H603
Person / Time
Site:	North Anna
Issue date:	03/02/1987
From:	Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
87-042, 87-42, NUDOCS 8703060165
Download: ML20212H603 (8)

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VIRGINIA EI.ECTRIC AND POWEH COMPANY RIcuxoxn,VIHOINIA 20261

.W.L.STnwAar Vaca Passinarr NccLEAm ormautions March 2, 1987

-U. S. Nuclear Regulatory Commission Serial No.87-042 Attn: Document Control Desk NAPS /JHL:jmj 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 RESPONSES TO THE NOTICE OF VIOLATIONS NRC INSPECTION REPORT NOS. 50-338/86-28 AND 50-339/86-28 We have reviewed your letter of January 29, 1987 in reference to the inspection conducted at the North Anna Power Station between November 17, 1986 and January 11, 1987, and reported in Inspection Report Nos. 50-338/86-28 and 50-339/86-28. Our responses to violations A and B in the Notice of Violations are addressed in the attachments. As discussed with representatives of the NRC Region II on February 25, 1987, our response to violation C will be submitted by March 31, 1987. This delay was requested in order to ensure that the necessary corrective actions are identified and implemented.

With respect to the severity level assigned to violation A - failure to comply with an approved procedure - we have reviewed 10CFR2, Appendix C and the applicable sections of 10CFR20. We have concluded that this violation is more appropriately classified as Severity Level V since it was administrative in nature and has minor safety or environmental significance. The exposure limits specified in 10CFR20 could not have been exceeded and the proper control of radioactive material was not a matter of issue since the contaminated clothing was detected and confiscated before the individual left the Radiological Control Area (RCA). The violation was incurred due to the fact that a contamination report required by health physics procedures was not completed.

While we view this incident seriously, we consider that such an occurrence has minor safety or environmental significance since no contamination was spread outside the RCA. Accordingly, we request that the severity level for violation A be revised from a Severity Level IV to a Severity Level V.

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We ;' have ; no objection to' this inspection report being made a matter of public

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'If you have any further questions, please contact me.

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Very truly yours,

'W. L. Stewart' Attachments

- cc:1U..S.-Nuclear Regulatory Commission

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-Suite 2900 101 Marietta Street, N. W.

Atlanta.. Georgia 30323-

'Mr. J. L. Caldwell ~

NRC Senior' Resident Inspector

-North Anna Power Station 4

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RESPONSE TO THE NOTICE OF VIOLATION ITEM REPORTED DURING THE NRC INSPECTION CONDUCTED FROM NOVEMBER 17, 1986 TO JANUARY 11, 1987 INSPECTION REPORT NOS. 50-338/86-28 AND 50-339/86-28 NRC CODGEENT A. Technical Specification 6.11, Radiation Protection Program, requires that procedures shall be prepared consistent with the requirements of 10 CFR 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposures.

Section 4.2.2 of Health Physics Procedure 3.1.7 requires that Rubidium-88 contamination be recorded on the clothing contamination section of form H. P. 3.1.7.1.

Contrary to the above, Health Physics Procedure 3.1.7 was not adhered to since a-report was not filled out for a technician contaminated with Rubidium-88 on Decer'rcr 12, 1986, at approximately 3:00 p.m. (EST).

This is a Severity Level IV violation (Supplement 1) and applied to both units.

RESPONSE

1. ADMISSION OR DENIAL OF THE ALLEGED VIOLATION This violation is correct as stated with clarification that the event took place on December 16, 1986.

2. REASON FOR THE VIOLATION The violation was caused by personnel error. The Health Physics technician responsible for documenting the event failed to initiate a contamination report for the worker's contaminated trousers. This is considered an isolated event.

3. CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED On the date of the contamination, the worker's trousers were confiscated prior to the worker leaving the Radiological Control Area. The trousers were analyzed and the source of the contamination was determined to be Rubidium-88. The worker's trousers were subsequently released following appropriate decontamination.

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.The technician that failed to initiate the contamination report was counselled on the importance of following Health Physics Procedures.

4. CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS A discussion of this violation will be included in the next cycle of the Health Physics Technician Continuing Training Program.

5. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance will be achieved by May 31, 1987, i

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RESPONSE TO THE NOTICE OF VIOLATION ITEM REPORTED DURING THE NRC INSPECTION CONDUCTED FROM NOVEMBER 17, 1986 TO JANUARY 11, 1987 INSPECTION REPORT NOS. 50-338/86-28 AND 50-339/86-28 NRC COMfENT B. Technical Specification 6.8.1.a requires written procedures be established, implemented and maintained covering the startup operation and shutdown of the Chemical and Volume Control System.

Contrary to the above, on November 26, 1986, 2-0P-8.1 " Chemical and Volume Control System" was inadequate in that this procedure allowed placing of 2-CH-P-1A charging pump into service with service water isolated which resulted in the overheating of the bearings of the A charging pump speed increaser and subsequent inoperability of the A charging pump.

This is a Severity Level V violation (Supplement 1) and applied to Unit 2.

RESPONSE

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

2. REASON FOR THE VIOLATION Service water is supplied to each charging pump to provide cooling for each of two pump seals (fore and af t) and for the speed increaser (gear box) oil. The service water configuration for these coolers is as follows. Two supply lines, each from separate trains of service water, are headered together upstream of the three coolers. (Each of the supply lines contains an isolation valve.) This header is then divided into three parallel l

branches, one to each of the pump seal coolers and one to the speed increaser oil cooler. The speed increaser oil cooler branch is the only l line of the three that contains a valve. (Note: This valve is located just downstream of the oil cooler.) The three branches are headered together downstream of coolers, and this header is then split into two service water return lines, each containing an isolation valve, connected to two separate trains of service water return. An instrument which measures differential pressure is connected to pressure taps located i upstream and downstream of the three parallel cooler circuits, on the service water supply and return headers. The valve involved in this violation, 2-SW-264, is the one in the branch line for the speed increaser oil cooler for Unit 2 charging pump 2-CH-P-1A. Applicable procedures identify the valves in the service water supply and return lines as the

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means of- isolating service water to the three coolers. These valves are located outside the charging pump cubicle, whereas valve 2-SW-264 is inside the pump cubicle and therefore within the normal isolation boundary.

A Human' Performance Evaluation was conducted to determine the.cause.of this event. Although we . vere unable 'to determine under. what specific circumstances the. position of valve 2-SW-264 was changed from open to closed,~the root cause of this event was determined ( to be -inadequate procedures,- le, procedures covering valve lineups and the meaning of the

' differential pressure instrument-indications.

The interruption of service water flow through the speed increaser oil cooler was not detected before the oil reached its maximum temperature for the following reasons.

Speed increaser oil takes a relatively long time to heat because of the volume of oil in the sump.

Local temperature and differential pressure readings are taken once per shift for running charging pumps.

Procedure 2-0P-8.1 did not provide detailed guidance to ensure that service water was. flowing through the speed increaser oil cooler.

Valve 2-SW-264 was not addressed in the procedure for returning the

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charging pump to service.

The valve lineup for removing the charging pump from service addressed the service water supply and return isolation valves only, and did not include manipulation of 2-SW-264. As stated above, valve 2-SW-264 is not normally operated to effect isolation of service water.

3. CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED Padlocks have been installed on the speed increaser oil cooler valves in

.both Unit 1 and Unit 2.

Procedures 1/2-M0P-8.01, 8.02, and 8.03 were revised to include directions to cpen and lock, or verify that the speed increaser oil cooler valves for each charging pump are opened and locked prior to returning the charging pumps to service after speed increaser maintenance.

Procedures 1/2-0P-8.1 were revised to include verification that service water flow is available to the speed increaser oil cooler. The revised procedures direct the user to investigate low or high differential pressure readings and to verify by various means that service water is flowing through the speed increaser oil cooler. The procedure provides an approximate differential pressure value as a reference point.

Procedure 1-0P-49.1A was revised to administrative 1y lock open the speed increaser oil cooler valve for each charging pump speed increaser.

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4. CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS This event uncovered 'certain- inconsistencies in the interpretation of indications from the differential pressure instrument for the seal / speed increaser oil coolers. Accordingly, in addition to the actions described above .the following revisions will be completed.

'The annunciator responses for low charging pump speed increaser oil cooler flow for both Unit I and 2 charging pumps will be corrected.

Instrument loop drawings will be revised to reficct .the correct response 'of the differential _ pressure instrument to changes in service water flow to the charging pump seal / speed increaser oil coolers.

5. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance will be achieved by May 15, 1987.