ML20246J322

Discusses Insps on 861117-890202 & Forwards Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $25,000

ML20246J322
Person / Time
Site:	North Anna
Issue date:	04/21/1989
From:	Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Cartwright W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
Shared Package
ML20246J327	List: ML20246J322 ML20246J330
References
EA-88-311, NUDOCS 8905170049
Download: ML20246J322 (5)

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Docket Nos. 50-338 and 50-339 License Nos. NPF-4 and NPF-7 EA 88-311' Virginia Electric and Power Company

C ATTN: Mr. W. R. 'Cartwright Vice President, Nuclear Operations 5000 Dominion Boulevard Glen Allen, Virginia 23060

' Gentlemen:

SUBJECT:

NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY (NRC INSPECTION REPORT NOS. 50-338,339/86-28; 50-338,339/87-01; 50-338,339/87-19, 50-338,339/88-02; 50-338,339/88-31, AND 50-338,

'339/88-36)

This refers to the Nuclear Regulatory Commission (NRC) inspections conducted on November 17, 1986 - January 11, 1987; January 12 - February 20, 1987; June 17 -

August' 18, 1987; January 25-29 and February 8-12, 1988; September 17 -

' November'4, 1988; and December 31,1988 -' February 2,1989, at the North Anna .

Power.' Sta ti on . The inspections included a review of the degradation of several safety systems which revealed inadequacies in your corrective action process.

.These events are further discussed below. The; reports documenting these inspec-tions were sent to you by letters dated January 29, 1987; March 12, 1987;

. September 10, 1987; May 26, 1988; December 26, 1988; and March 27, 1989. As a result of these inspections, significant failures to comply with NRC regulatory requirements were identified, and accordingly, NRC concerns relative to the -

inspection findings were discussed in Enforcement Conferences held on January 18 and February 7, 1989. A summary of these conferences was sent to you by letters

-dated February 16 and March 1,1989.

The enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Notice) identifies a violation of 10 CFR Part 50, Appendix B, Criteria XVI as evidenced by two examples of failure to identify and promptly correct significant conditions adverse to quality. Due to the nature of the examples described below, it is apparent that your staff's awareness and followup on potential operability issues involving equipment deficiencies lacked the management attention necessary to ensure such issues were promptly addressed and appropriately resolved.

The first example cited in the violation involved your failure to adequately evaluate and subsequently correct problems that rendered several of your control room habitability systems inoperable. Specifically, there were two Technical Specifications violations that were identified which were not adequately evaluated or promptly corrected.

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Virginia Electric & Power Company APR 211989 First, the control room emergency ventilation system flow rate did not meet Technical Specification requirements for operability from June 1986 until identified by the survey team in December 1986. This problem would have been identified by your staff had plant personnel performed post maintenance testing following maintenance on the emergency ventilation system in June 1986. Second, the control room bottled air system surveillance test, required by Technical Specifications to ensure operability of the bottled air portion of the habita-bility system, was identified by the team to be inadequate in that the accep-tance criteria allowed the readings from the Differential Pressure (D/P) test gauges to be averaged. This resulted in the completion of the test during the years prior to December 1986 with results meeting the acceptance criteria but allowing the D/P between the control room and several of the adjacent compart-ments to be outside the Technical Specification limit. The inoperability of either of these two systems required the plant to be in a cold shutdown action statement per Technical Specification 3.7.7.1.

The Technical Specification violations are a significant concern; however, enforcement action is not being taken for those, in part, because you volunteered to participate in the NRC's Control Room Habitability Survey. Your failure to properly evaluate and correct the problems once they were identified is the more fundamental safety concern. Although you immediately resolved the emergency ventilation system flow rate problem, complete resolution of the control room bottled air system problem was not prompt. With respect to the problem of averaging the control room envelope D/P instrumentation readings instead of using discrete readings, your Technical Specification interpretation was unrealistic and not based on sound technical judgment. Corrective action was also not as rapid as the problem warranted. After taking compensatory measures to assure adequate air supply and pressure, you performed the D/P test successfully in August 1987 (after two failures in June and July 1987) using the correct inter-pretation. But in October 1988, a test failure due to your use of a combination of turbine building exhaust and supply blowers revealed that your corrective action in this matter was not comprehensive enough to assure satisfactory test results under all conditions.

The second example cited in the violation involved a failure to promptly correct a degradation of your instrument air system resulting from water and oil contamination. On April 24, 1987, the plant had an event which resulted in a service water intrusion into the instrument air system. The corrective action involved blowing down the instrument air system at the low points and testing safety-related equipment affected by the water intrusion to ensure operability. This corrective action was completed in April 1987; however, in September 1988, and again in January 1989, you discovered water in an auxiliary feedwater system control valve which, when sampled, indicated that a portion of the water had resulted from the service water event. In addition, in March 1988 you identified, based on samples of the instrument air system, that the air was contaminated with oil, to a level greater than that permitted by either the ANSI /ISA standards or the vendor recommendations. In June 1988, you initiated a Safety System Functional Inspection (SSFI) of the instrument air system as a result of these and other instrument air problems. This review revealed that you had allowed the system to degrade over the years to the point where the original oil free compressors for the instrument and service air systems were no longer considered operable. Consequently,

Virginia Electric & Power Company APR 211989 instrument air and service air were being maintained by compressors (Sullair  ;

and construction air) that are oil lubricated and do not meet many of the I requirements in the Updated Final Safety Analysis Report. )

Your review of NRC Information Notices and INP0 Significant Operating Event Reports on air system problems should have resulted in mora aggressive action in identifying and correcting the contamination sources for your instrument air system. Although the SSFI was a positive action on your part and instrumental 1 in identifying the compressor replacement deficiencies, we believe that your lack of appropriate sensitivity to the problems with your instrument air system resulted in your failure to promptly identify and take appropriate corrective l4 actions. Even with the invaluable information provided to you from the SSFI, you continued to operate the instrument air system with the dryer out of service until September 1988, and the oil filter out of service until December 1988. Not until water was discovered in the auxiliary feedwater control valve ,

in January 1989 did you appear to take adequate actions to aggressively resolve the degradation of your instrument air system.

The NRC staff considers the deficiencies in your corrective action process to have potentially significant safety implications and that any problem identi-fied by your staff that involves the potential degradation of safety equipment should be given the utmost attention by your management. We understano that you have taken action to assess your corrective action program and are developing a more thorough root cause evaluation program.

In order to emphasize the need to take lasting, effective action to assure prompt identification and resolution of equipment deficiencies, I have been authorized, 1

after consultation with the Director, Office of Enforcement, and the Deputy Executive Director for Nuclear Materials Safety, Safeguards, and Operations Support, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty in the amount of Twenty-Five Thousand Dollars ($25,000) for the violation described in the enclosed Notice. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," in 10 CFR Part 2, Appendix C, 53 Fed. Reg. 40019 (October 13, 1988) (Enforcement Policy),

the violation described in the enclosed Notice has been categorized as a Severity Level III. The base value of a civil penalty for a Severity Level III violation is $50,000. The escalation and mitigation factors in the Enforcement Policy were considered, and the base civil penalty amount has been decreased by 50 percent in recognition of your prompt and extensive corrective actions once you were aware that these deficiencies had not previously been properly addressed.

You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. In your response, you should document the specific actions taken and any additional actions you plan to prevent recurrence. After reviewing your response to this Notice, including your proposed corrective actions and the results of future inspections, the NRC will determine whether further NPC enforcement action is necessary to ensure compliance with NRC regulatory requirements.

In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, l

Title 10, Code of Federal Regulations, a copy of this ketter and its enclosure will be placed in the NRC Public Document Room.

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j Virginia Electric & Power Company APR 211989 l

The responses directed by this letter and the enclosed Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, Pub. L. No.96-511.

I Should you have any questions concerning this letter, please contact us.

Sincerely, 1

Original signed by MLErnst Stewart D. Ebneter Regional Administrator

Enclosure:

Notice of Violation and Proposed Imposition of Civil Penalty

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cc w/ encl:

G. E. Kane, Station Manager R. F. Saunders, Manager - Nuclear Programs and Licensing Commonwealth of Virginia

Virginia Electric & Power Company APR 2 i 1989 DISTRIBUTION:

PDR LPDR SECY CA HThompson, DEDS JMTaylor, DEDR JLieberman, OE SDEbneter, RII LChandler, OGC TMurley, NRR SVarga, NRR Enforcement Coordinators RI, RII, RIII, RIV, RV Resident Irspector FIngram, GPA/PA BHayes, 01 FHerr, 01A EJordan, AE0D JLuehman, OE 0E:Chron OE:EA DCS Commonwealth of Virginia DRS Technical Assistant RII RII [/ R (1,A eyes JPStohr GRJe ins MLErnst i 4 3489 4/,2t/89 4/gc/89 4/ /89 l I 1 l

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