ML20237H938
| ML20237H938 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 08/12/1987 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| 87-418A, NUDOCS 8708170422 | |
| Download: ML20237H938 (7) | |
Text
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e j
VINGINIA ELECTHIC AND l'OWEH COMI*ANY i
R1cunono,V1uonn1x unuc,n August 12, 1987 W,L.SrawAur vsom Panasomar NoctaAm orzuAttone r
U. S.; Nuclear Regulatory Commission Serial No.
87-418A
. Attn: Document Control Desk NAPS /JHL Washington, D. C. 20555 Docket Nos. 50-338 i
50-339 License Nos. NPF-4 NPF-7 Gentlemen:
i VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNIT NOS. 1 AND 2 NRC INSPECTION REPORT NOS. 50-338/87-15 AND 50-339/87-15 j
J We have reviewed your letter of June 29, 1987 which referred to the inspection conducted at North Anna between May 13, 1987 and June 16, 1987 and reported in Inspection Report Nos.
50-338/87-15 and 50-339/87-15. Per a conversation
- between our respective staffs on July 29, 1987, agreement was reached that our responses to.the Notices of Violation would be delayed until no later than August 12, 1987..This delay resulted from the diversion of management's attention. to the July 15, 1987 Steam Generator Tube Rupture Event and subsequent recovery activities at. North Anna Unit 1.
The responses to the Notices of Violation are addressed in the attachments.
We have no objection to this inspection report being made a matter of public l
record.
If you have any further questions, please contact us.
J Very truly yours, r
s
(
W. L. Stewar Attachments I
B708170422 870812 PDR ADOCK 05000338 G
pm l
cc:
U. S. Nuclear Regulatory Commission Regicn II 101 Marietta Street, N. W.
Suite 2900 Atlanta, Georgia 30323 Mr. J. L. Caldwell NRC Senior Resident Inspector North Anna Power Station l
f ATTACHMENT RESPONSE TO THE NOTICE OF VIOLATION REPORTED DURING THE NRC INSPECTION CONDUCTED BETWEEN MAY 13, 1987 AND JUNE 16, 1987 INSPECTION REPORT NOS. 50-338/87-15 AND 50-339/87-15
- NRC COMMENT:
During the Nuclear Regulatory Commission (NRC) inspection conducted on May 13 June-16, 1987, violations of NRC requirements were identified. The violations involved a failure to comply with Technical Specifications (TS) 3.6.1.1 and failure to follow refueling procedures.
In accordance with with the " General Statement of Policy and Procedure for NRC Enforcement Actions,"
10 CFR Part 2, Appendix C (1987), the violations are listed below:
A.
Technical Specification 3.6.1.1 requires primary containment integrity to be maintained in modes 1, 2, 3 and 4.
Containment integrity is maintained by verifying that all penetrations not capable of being closed by operable containment automatic isolation valves and required to be closed during accident conditions are closed by valves, blind flanges, or deactivated automatic valves secured in their positions, except as provided in Table 3.6-1 of Specification 3.6.3.1.
Contrary to the above on numerous occasions during the past two years the performance of TS 4.4.6.2.a, surveillance requirement for the hydrogen recombiner, was conducted with the associated unit in modes 1, 2, 3 or 4.
The performance of this surveillance requires. manually operated containment isolation valves listed in TS table 3.6-1 to be open for greater than one hour violating the containment integrity TS 3.6.1.1.
The last performance of this surveillance was March 6, 1987 for Unit I which was operating at 100% and May 21, 1987 for Unit 2 which was operating at 100%.
This is a Severity Level IV violation (Supplement 1) and applied to both units.
RESPONSE
1.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION:
)
I The violation is correct as stated except that the surveillance requirements in question for the hydrogen recombiner are addressed.in Technical Specification 4.6.4.2.a.
rather than Technical Specification 4.4.6.2.a.
1
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2.
REASON FOR THE VIOLATION:
In ' Inspection ' Report Nos. 50-338/85-12 and 50-339/85-12, dated May 22, i
1985,'the North Anna'..NRC Resident Inspector identified a discrepancy between the NRC's review for conformance to Generic Letter 82-16 (NUREG j
0737, Item II.E.4.1, specifica11y) and North Anna Technical Specification
.]
.4.6.4.2.a.
The NRC review acknowledged that the opening of the recombiner j
isolation valves would "take place only under specific administrative' l
control as.specified. in post-accident procedures." The requirements of
]
L Technical Specification 4.6.4.2.a however, have always. required testing q
of - the hydrogen.recombiner in Modes 1 and 2.
Since the test requires i
aligning the hydrogen recombiner to the containment by opening the manual isolation valves which are remotely operated from the control room, i
containment integrity required by Technical Specification 3.6.1.1 in Modes 3
1 - 4 is violated while meeting the surveillance requirement. Table 3.6 '
of Specification 3.6.3.1 does allow for administrative control of remote manual valves during periods-when containment integrity is required by designating such valves with an asterisk next to the valve mark number.
When the Technical Specifications were revised to. implement the NUREG.
0737, Item II.E.4.1 requirements for dedicated hydrogen' penetrations, an oversight was made in not designating'the hydrogen recombiner isolation valves as administrative 1y controlled valves in Technical Specifications Table 3.6-1.
At.the time the Resident Inspector. initially identified the discrepancy for the hydrogen recombiner surveillance during early 1985, the concern was focused on the capability of the hydrogen recombiner and associated piping to withstand the maximum pressure it could see if an accident occurred during surveillance testing in Modes 1, 2, 3 or 4.
To address this-issue, an engineering evaluation was performed to demonstrate the capability of the hydrogen recombiner and associated piping to withstand maximum containment pressure should a Design Basis Accident (DBA) occur during surveillance testing.
No safety concerns associated with performing the surveillance testing at power were identified in the evaluation. The evaluation has been made available to the NRC Resident Inspector for review, and the issue was believed to be resolved.
The need to revise the Technical Specifications was not fully realized until a review by the NRC Resident Inspector was completed in late 1986 of
' unresolved item 338, 339/85-12-01. Based on the review and discussions between station management and the NRC Resident Inspector, it was decided that a Technical Specification change was administrative 1y required in
. order to resolve the conflicting Technical Specification requirements.-
However, no safety problem existed with opening the hydrogen recombiner isolation valves during Mode 1, 2, 3, or 4 operation. Further, the valves are automatically operated from the main control room and under the direct control of the licensed control room operator.
I i
Y
3.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:
1 A Technical Specifications change request for Table 3.6-1 of Specification 3.6.3.1 was prepared, reviewed by the Station and Corporate safety review groups and submitted to the NRC on - May : 27, 1987.
This request is currently under review by the NRC.
The change, when approved, will designate the. hydrogen recombiner isolation valves in Technical Specifications Table 3.6-1 as valves which can be administratively controlled during' surveillance testing (i.e., an asterisk will be added for these valves).
PT-68.1.1, PT-68.1. 2, PT-68. 2.1, and PT-68.2. 2 have been revised to add a precaution to instruct the control room operator to secure the hydrogen recombiner and then close che recombiner remote isolation valves if a containment' isolation signal is generated while the' functional test is in progress.
4.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
Pending NRC approval of the submitted Technical Specification changes, hydrogen recombiner testing required by Technical Specification 4.6.4.2.a will be performed with the hydrogen recombiner aligned to the containment of a unit which is in Mode 5 or 6 unless specific approval by the NRC for testing in Modes 1 - 4 is granted.
5.
THE DATE WHEN FULL COMPLIANCE FJLL BE ACHIEVED:
Full compliance will be achieved upon implementation of revised Technical Specifications which are pending NRC review as discussed above.
7 ATTACHMENT RESPONSE TO THE NOTICE OF VIOLATION REPORTED DURING THE NRC INSPECTION CONDUCTED BETWEEN MAY 13, 1987 AND JUNE 16, 1987
. INSPECTION REPORT NOS. 50-338/87-15 AND 50-339/87-15 NRC COMMENT:-
- During the Nuclear Regulatory Commission (NRC) inspection conducted on May 13.
- June 16, 1987, violations of NRC requirements.were identified.
The
-violations involved a failure. to comply with Technical Specifications (TS) 3.6.1.1 and failure.to follow refueling procedures.
In accordance with with the- '" General' Statement of' Policy and Procedure for NRC Enforcement Actions,"
- 10.CFR Part 2 Appendix C (1987), the violations are listed below:
B.
-Technical Specification 6.8.1.b requires-written procedures to be established, implemented and maintained covering refueling operations.
Contrary. to the above on May 16, 1987 the refueling building bridge operator violated'the licensee's refueling procedures and policies by operating the bridge in the lateral direction with an attached spent fuel' assembly.still inserted in the fuel storage rack and operating the bridge, crane with only one operator when the licensee policies require two..-This failura to follow procedure resulted in the potential for damage to a-spent fuel assembly. The assembly was removed from the rack, inspected and determined not to be damaged.
This is a Severity Level IV violation (Supplement 1) and applies only to Unit 1.
RESPONSE
1.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION:
The violation is correct ~as stated.
2.
REASON FOR THE VIOLATION:
The violation was caused by personnel error. Specifically, there was inattention to detail on the part of the refueling operators.
The operator moved the fuel assembly without ensuring that it was fully withdrawn from the fuel racks.
This is contrary to fuel handling procedures.
The inattention to detail was caused by an inadequate shift turnover. Also, the operators did not adequately discuss the status of' the fuel assembly during shift turnover.
l 1
- Finally, the~ refueling operators did not adhere to the Senior Reactor
.0perator's instruction regarding the station policy 'that two operators must be involved in the fuel handling process, and the Operating Procedure 1-0P-4.10 did not contain an explicit statement of that requirement.
3.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:
At the tfme fuel assembly G-56 was mishandled, refuelfng operations. were suspended.
Fuel assembly G-56 was examined with binoculars and by video tape. Engineering evaluation of the examination determined that there was no fuel or structural damage to fuel. assembly G-56.
Personnel involved in refueling operations were counselled in the importance of following procedures. Refueling operations were resumed and successfully completed without further incidents.
4.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
i A precautionary step will be added to 1-0P-4.10 to ensure two operators are present when fuel is being moved. One operator is to operate the crane controls and observe the load device.
The other operator will stabilize the fuel and observe the fuel assembly motion to detect any possible interferences.
In addition, whenever contractor services are utilized for refueling (a contractor was used for the' Unit 1 1987 refueling), a detailed orientation on procedure requirements will be given.
5.
THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Procedure 1-OP-4.10 will be revised by August 17, 1987.
_