ML20237L149

Notice of Violation from Insp on 870621-0710.Violation Noted:Licensee Attempted to Perform Evolution W/Intent of Drawing Vacuum in Pressurizer W/O Procedure

ML20237L149
Person / Time
Site:	North Anna
Issue date:	08/18/1987
From:	Reyes L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20237L133	List: IR 05000338/1987021 ML20237L131 ML20237L149
References
50-338-87-21, NUDOCS 8708270437
Download: ML20237L149 (2)

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ENCLOSURE 1 NOTICE OF VIOLATION l

Virginia Electric and Power Company Docket No. 50-338  ;

North Anna Unit 1 License No. NPF-4 During the Nuclear Regulatory Commission (NRC) inspection conducted on June 21

- July 10, 1987, violations of NRC requirements were identified. The violations involved a failure to have adequate procedures, failure to use procedures, and failure to perform e 10 CFR 50.59 safety evaluation.

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. T6chnical Specification 6.8.1.a. requires written procedures to be established, implemented and maintained covering the areas associated with filling, draining, venting, startup, shutdown and changing modes of the Reactor Coolant System (RC5) and maintenance relating to repairs of the Reactor Coolant Pumps (RCP).

(1) Contrary to the above, on June 17, 1987, the licensee established plant corditions per 1-0P-3.4, Unit Shutdown from Cold Shutdown (Mode

5) <200 degrees F. to Coldwas This procedure Shutdown (Modein5) inadequate t liat it allowed the<140 degrees F. and K eff 5.0.35.

operators to establish conditions which led to the inadvertent voiding of the reactor vessel and steam generator tubes without the knowledge of the operators.

(2) Contrary to the above, on June 20, 1987, with the unit in an abnormal condition, an evolution to lower pressurizer level was performed without a procedure. This evolution was performed in an attempt to reduce leakage from the RCS through the "A" RCP. The result of the evolution was not only a reduction in pressurizer level, but also without the operator's knowledge of a reduction in the reactor vessel and steam generator tube level.

(3) Contrary to the above, on June 21, 1987, the licensee attempted to perform an evolution with the intent of drawing a vacuum in the pressurizer without a procedure. This evolution was started but not completed since the licensee discovered that a vacuum had already been inadvertently established in the pressurizer. The purpose of the evolution was to reduce RCS leakage by the "A" RCP.

8708270437 870818 8 DR ADOCK 050 h

Virginia Elect'ric and Power Company 2 Docket No. 50-338 North Anna Unit 1 License No. NPF-4 i i

(4) Contrary to the above, maintenance procedure MMP-C-RC-28, Reactor Coolant Pump Coupling Disassembly / Reassembly, used during the repairs .

to the "A" RCP in June 1987 was inadequate for the following reasons: '

a. There is no action statement in the procedure' directing the I operators to maintain the RCS at 15 PSIG to minimize the amount of leakage from a disassembled RCP. The operators are required to not exceed 15 PSIG by step 5.4.a. while lowering the shaft to q minimize RCS leakage, however, no guidance is given to the {'

operator on maintaining 15 PSIG while the pump is disconnected.

A caution preceding step 7.1 that the maximum expected leak rate from a backseated RCP is 1 GPM with the'RCS at 15 PSIG, however, this is a caution and implies no action on the operators part to maintain those conditions.

b. There is no guidance provided for the use of seal injection when the procedure is used without the RCS being drained. Because this condition cen occur and the effect of seal injection on a l disassembled.RCP directly effects the amount of leakage from the RCP, guidance is required.

c. The steps for the alignment of the RCP and motor are not included in the procedures. Tt > procedure is used to l disassemble and reassemble the A ' coupling and prior to  ;

reassembling, alignment of the coupling is needed, those I instructions are required. '

d. There is no statement concerning the minimizing of RCS leakage when the pump internals are raised from their backseated position. If the procedure states that the operators shall not exceed 15 PSIG when lowering the pump internals, the same direction is required when the pump is being raised as an increase in the expected leakage rate is just as likely.

l This is a Severity Level IV violation (Supplement 1) and applies only to Unit 1.

B. 10 CFR 50.59 states in part that the licensee may conduct tests or experiments not described in the Final Safety Analysis Report (FSAR) without prior Commission approval if the licensee determines the test or  !

experiment does not involve a change to the Technical Specification or an unreviewed safety question. The licensee must maintain records of these tests or experiments including a copy of the written safety evaluation which provides the basis for the determination that the test or experiment does not involve an unreviewed safety question.

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Virginia.NiectricandPowerCompany 3 Docket No. 50-338.

North Anna Unit 1 License No. NPF-4 Contrary to the above, on June 21, 1987, the licensee conducted an evolution with the intent of-drawing a vacuum in the pressurizer, in an attempt. to reduce RCS leakage, without performing a safety evaluation.

This evolution which is not described in the FSAR and-is clearly not a-routine' evolution' was an attempt to change a plant parameter with a nonroutine plant manipulation, and consequently is considered a test or experiment.

This is a ' Severity Level. IV violation (Supplement 1)- and applies only to

-Unit 1.

Pursuant to the provisions of 10 CFR 2.201, VEPC0 is hereby required to submit to this Office. within 30 days of the date of the letter' transmitting this -

Notice, a written statement or explanation in reply, including (for each violation): (1) admission or denial of the. violation, (2) the reason for the

- violation if admitted, (3)'the corrective steps which have been taken and the results achieved, (4) the corrective steps which wil be taken to avoid further a violations, and (5) the date when full compliance'will be achieved. Wherel good l cause is shown, consideration will be given to extending the response time.

FOR THE NUCLEAR REGULATORY COMMISSION ORIGINAL SIGNED Sy '

VIRGIL L BROWIR.gg , %

Luis A. Reyes, Director Division of Reactor Projects Dated at Atlanta, Georgia on this 18 day of August 1987 4

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