ML20235Y769
| ML20235Y769 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 03/03/1989 |
| From: | Cartwright W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 89-081, 89-81, NUDOCS 8903140559 | |
| Download: ML20235Y769 (7) | |
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' VINGINIA ELECTRIC AND Powsu COMPANY Hicrruonn, VIRGINIA 20261 W.H.Camrwamnv
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March 3, 1989 U. S. Nuclear Regulatory Commission-Serial No.
89.-081 Attention: Document Control Desk NAPS /DEQ/JHL Washington, D. C. 20555 Docket Nos.
50-333 50-339
' License Nos. NPF-4~
NPF-7 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNITS 1 AND 2 INSPECTION REPORT NOS. 50-338/%-33 AND 50-339/88-33 REPLY TO THE NOTICES OF VIOLATION
.We have reviewed your letter. of February 1, 1989 which referred to the inspection conducted at North Anna on November 5,.1988 through December 30, 1988 and reported in Inspection Report Nos. 50-338/88-33 and 50-339/88-33.
Our responses to tha Notices of Violation are attached.
In addition, we are continuing our review of station controlled drawings and the process for updating these drawings.
Any additional corrective actions will be implemented based on the results of this review.
We have no objection to this correspondence being made a' matter of public record.
If you have any further questions, please contact.us.
V ry trup ygur
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T W. R. Cart right Attachment cc:
U. S. Nuclear Regulatory Commission 101 Marietta Street, N. W.
Suite 2900 Atlanta, Georgia 30323
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Mr. J. L. Caldwell NRC Senior Resident Inspector North Anna Power Station
[6 8903140559 890303 l
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DR ADOCK 0500 j8
RESPONSE TO THE NOTICES OF VIOLATION REPORTED DURING THE NRC INSPECTION CONDUCTED BETWEEN NOVEMBER 5, 1988 AND DECEMBER 30, 1988 INSPECTION REPORT NOS. 50-338/88-33 AND 50-339/88-33 NRC COMENT During the Nuclear Regulatory Commission.(NRC) inspection conducted on November 5, 1988 - December 30, 1988, violations of NRC requirements were L
identified.
In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1988), the violations are listed below:
A.
Technical Specification 6.8.1 requires written procedures be established, implemented and maintained covering procedure adherence and temporary change method as-documented in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Administrative Procedure (AP) 3.12, Redline of Control Room. Drawings, requires that ' drawings be red. lined within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of a system becoming operational.
Contrary to the above, the inspectors identified that the licensee had not red lined the control ' room drawings to include the on-line chemistry sampling' system which~ had been in operation for two years.
This is a Severity Level IV violation (Supplement 1) and applies to Unit 1 only.
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RESPONSE TO' VIOLATION A 1..
ADNISSION OR DENIAL OF THE ALLEGED VIOLATION The violation is' correct as stated.
2.
REASON.FOR THE VIOLATION
~The violation was.caus'ed by inadequate controls-for transferring existing redline information on control room drawings to replacement drawings.
Component ' Cooling valves 1-CC-1002 through 1-CC-1018 could not be located' on the newly issued Computer Assisted Drawings'(CADS)..These. valves 'had been installed by Design Change Package (DCP) 85-01, "On-Line' Chemistry Monitoring," and.have been in. operation.for' two years.
A Partial-
. Technical. Review had_been performed on DCP 85-01 in 1985 and 1986,land the appropriate control room drawings updated with redline information.
At some later time, Records Management personnel replaced the existing redline ' drawings ~ with a revision that did.not contain the redline-information. The existing redline drawing-and the. replacement drawing were not compared at that time..
The major ' contributing cause -for the violation was that several..
departments had responsibility for drawing updates, but,no one department had overal.1 responsibility for ensuring accurate drawings.
. 3.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED Control room drawings have been rev.iewed and redline information verified.
Open DCPs have been reviewed to ascertain the' status of redline control room drawings.
'As' a result of this review, two fi. eld changes to a DCP were identified that were supposed to have generated redlined. control room drawings.
Review of these drawings could.not verif; that the redlining had been performed. These control' room drawings have.been re-redlined.
Also, drawing updates were initiated for several DCPs in the open file which had only been partially implemented, i
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In addition to the above, several programmatic enhancements have been made to the Drawing Control Program.
First, the Engineering Department has been given overall responsibility for the Drawing Control Program.
Secondly, the practice of redlining has been eliminated for drawings affected by Design Change Packages except for emergency changes required during non-routine work hours.
Redlining for drawings affected by Engineering Work Requests (EWRs) will be eliminated to the extent possible. Any redlined drawings will be updated within 15 days.
- Finally, drawing updates, as defined in Administrative Procedure 6.10, are now required to be initiated when any portion of a modification is made operable rather than waiting for the entire modification to be completed.
4.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS No further corrective actions are required.
5.
THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance has been achieved.
NRC COP 94ENT B.
10 CFR 50 Appendix B, Section VI, Document Control, states that measures shall be established to control the issuance of documents, such as instructions, procedures and drawings, including changes thereto which prescribe all activities affecting quality.
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l Contrary to the above, on December 5, 1988, the process vent system was
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filled with water resulting in contamination of the auxiliary building.
This was caused by the failure to document changes on the drawings and I
procedure 1-M0P-90.7, Generic Procedure For Resin Addition to Ion Exchangers.
I This is a Severity Level IV violation (Supplement 1) and applies to Unit 2 only.
a RESPONSE TO VIOLATION B-
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ADMISSION 09 DENIAL OF THE ALLEGED VIOLATION The violation is correct as stated.
- 2. - REASON'FOR THE VIOLATION The violation was caused by an inadequate procedure, improper job turnover, and the fact that controlled drawings, operating procedures and/or Maintenance Operating Procedures (M0Ps) could be revised independently of each other.
3.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED 1
A Human Performance Evaluation of this event was performed.
Personnel involved in this event were reinstructed on the proper mechanism to deviate a procedure and for documenting work that had been performed but not completed on their operating shift.
1-M0P-90.7 was revised to prevent the intrusion of water into the Process Vent System.
In addition, 1-M0P-90.7 will be restructured into several specific operating procedures.
Generic Maintenance Operating Procedures, except 1-M0P-90.7, have been deleted to eliminate procedure write-in steps.
4.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS 1-M0P-90.7 will be restructured into several specific operating procedures.
This event will be discussed with operations personnel to emphasize the importance of operator actions, increased communications, proper job turnover, verbatim procedure compliance and.the proper mechanism for deviating a procedure.
Finally, operations personnel will be instructed that when a procedure and drawing are not censistent, the work process must be stopped so the discrepancy can be resolved.
Appropriate Station Administrative Procedures will be revised to ensure valve line-up operating procedures, maintenance operating procedures, and controlled drawings are reviewed when procedure changes are generated.
If a drawing. revision. is deemed necessary, due to a procedure revision, a drawing update request will be initiated in accordance with ADM-3.14, Drawing Update Requests.
5..
THE DATE WHEN FULL COMPLIANCE NILL BE ACHIEVED 1-M0P-90.7 will.be restructured into several specific operating procedures by. August 31, 1989.
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.The training discussed in section 4 will be completed by April 20,'1989.
L-Appropriate Station Administrative Procedures will be revised by April'15,
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-1989 to require that valve line-up operating procedures, maintenance operating procedures, and controlled drawings-be reviewed when procedure changes are being generated.
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