ML20246K086
| ML20246K086 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 07/10/1989 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 89-449, NUDOCS 8907180044 | |
| Download: ML20246K086 (7) | |
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'f VIRGINIA ELECTRIC AND PO WER COMPANY RICHMOND, VIRGINIA 23261 1.
iW. Ib STEWART SENIOR VICE PatsmENT -
-July 10, 1989 Powek l-U.S. Nuclear Regulatory Commission Serial No 89-449 Attn: Document Control Desk -
NAPS /DEO Washington, D.C. 20555 Docket No.
50-338 50-339 Licensa No.
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- Gentlemen:
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VIRGINIA ELt:CTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNITS 1 AND 2 INSPECTION REPORT NOS. 50 338/89-18 AND 50 339/89-18
- REPLY TO THE NOTICE OF VIOLATION We have reviewed your letter of June 9,1989 which referred to the inspection conducted at North Anna on May 15,1989 through May 19,1989 and reported in inspection Report Nos. 50-338/89-18 and 50-339/8918. Our responses to the Notices of Violation are attached.
We have no objection to this correspondence being made matter of public record.
If you have any further questions, please contact us.
Very truly yours, n
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W. L. STEWART Attachments:
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8907180044 890710
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PDR ADOCK 05000338
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. U. S. Nuclear Regulatory Commission 101 Marietta Street, N.W.
Suite 2900 Atlanta, Goargia 30323 Mr. J. L. Caldwell NRC Senior Resident inspector North Anna Power Station
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RESPONSE TO THE NOTICES OF VIOLATION REPORTED DURING THE NRC INSPECTION CONDUCTED BETWEEN MAY 15. 1989 AND MAY 19. 1989 INSPECTION REPORT NOS 50-338/89-18 AND 50 339/89 18 During the Nuclear Regulatory Commission (NRC) inspection conducted on May 15 -19,1989, violations of NRC requirements were 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.
10 CFR 50, Appendix B Criterion V as implemented by the Virginia Electric and Power Company OA, Topical Report (VEP-1-4A) requires in-part that, activities affecting quality shall be prescribed by documented instructions or procedures and shall be accomplished in accordance with these instructions or procedures.
Virginia Electric Power Company's Radiographic Examination Procedure No. NDE-RT 101,.Rev.
O, Paragraph 2.1.3 states that a system shall be used to produce permanent identification on the radiograph traceable to the Contract Component, weld or weld seam or part numbers. Addendum A, paragraph A.2 states that welds that are shown by radiography to have incomplete fusion are unacceptable.
Contrary to the above, on May 16,1989, seven film packages for welds in the Feedwater System had incorrect line identification permanently radiographer on the films. In addition, approximately 1 1/2 inches of incomplete fusion in the weld at break point 851 had not been rejected by the licensee in accordance with the approved procedure.
This is a Severity Level IV violation (Supplement 1-D).
B.
10 CFR 50, Appendix B, Criterion V as implemented by the Virginia Electric and Power Company OA Topical Report (VEP-1-4A) requires in-part that, ac0Vities affecting quality shall be prescribed by documented instructions or procedures and shall b3 accomplished in accordance with these instructions or procedures. Relative to fire protectior', these requirements are implemented, by the North Anna Fire Protection Manual" Fire Protectian Program" Sectiori 3.5.7 which states, in part, that a firewatch shall be required during any work involving ignition sources when the work is performed in a safety-related area.
Contrary to the above, on May 17,1989, activities were not accomplished in accordance with the above, in that an employee assigned a firewatch duty was observed, by NRC, to be sleeping on duty in the Unit 1 containment building, while welding was in process. This individual was working to Work Order 88-11, under Radiation Work Permit 1885.
This is a Severity Level IV violation (Supplement 1-D).
NOV IR 50-338&339/89-18 A1 of 5 j
l VIOLATION A '
NRC COMMENT A. 10 CFR 50, Appendix B, Criterion V as implemented by the Virginia Electric and Power Corrpany OA Topical Report (VEP-1-4A) requires in-part that, activities affecting quality shall be prescribed by documented instructions or procedures and shall be accomplished in accordance with these instructions or procedures.
Virginia Electric Power Company's Radiographic Examination Procedure No. NDE-RT-101, Rev. O, Paragraph 2.1.3 states that a system shall be used to produce permanent identification on the radiograph traceable to the Contract Component, weld or weld seam or part numbers. Addendum A, paragraph A.2 states that welds that are shown by radiography to have incomplete fusion are unacceptable.
Contrary to the above, on May 16,1989, seven film packages for welds in the Feedwater System had incorrect line identification permanently radiographer on the films. In addition, approximately 1 1/2 inches of incomplete fusion in the weld at break point 851 had not been rejected by the licensee in accordance with the approved procedure.
This is a Severity Level IV Violation (Supplement I-D).
RESPONSE TO VIOLAT;ON A
- 1. ADMISSION OR DENIAL OF THE ALLEGED VIOLATION The violation is correct as stated.
- 2. REASON FOR THE VIOLATION The violation was caused by Virginia Power and contract personnel error. The radiographer put the wrong line identification on seven Feedwater System radiographs. Subsequent inspections by Virginia Power and contract radiograph interpreters failed to detect this error. The Virginia Power and contract radiograph interpreters also f ailed to detect the area of incomplete fusion in the weld at break point 851,
- 3. CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED The line identification was corrected on the seven Feedwater System radiographs. Also, the remaining Feedwater System break point locations were reviewed by the Virginia Power Corporate NDE Level 111 and no additional problems were identified.
The area of incomplete fusion in the weld at break point 851 was rejected and submitted for repair.
1 NOV IR 50-338&339/89-18 A2 of 5
k RESPONSE Tb VIOLATION A
-(continued)
- 4.- CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS Contract radiograph interpreters will be qualified in accordance with a Virginia Power documented qualification program which will include practical examinations.
NDE RT-101 will be revised to include a radiograph interpretation checklist. The checklist will be'used.
by Virginia Power radiograph interpreters to ensure that adequate time is taken for consideration of important technique parameters and to ensure the radiograph Interpreters properly review the radiographs
- 5. THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The qualification program will be implemented by August 1,1989.
The radiograph interpretation checklist will be incorporated into NDE-RT 101 by August 1,1989.
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NOV IR 50 338&339/89-18 A3 of 5
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VIOLATION B' NRC COMMENT I
B. 10 CFR 50, Appendix B, Criterion V as implemented by the Virginia Electric and Power Company OA Topical Report (VEP.14A) requires in-part that, activities affecting quality shall be prescribed by documented instructions or procedures and shall be accomplished in accordance with these instructions or procedures. Relative to fire protection, these requirements are implemented, by the North Anna Fire Protection Manual" Fire Protection Program" Section 3.5.7 which states, in part, that a firewatch shall be required during any work involving ignition sources when the work is performed in a safety-related area.
Contrary to the above, on May 17,1989, activities were not accomplished in accordance with the above, in that an employee assigned a firewatch duty was observed, by NRC, to be sleeping on duty in the Unit 1 containment building, while welding was in process. This individual was working to Work Order 88-11, under Radiation Work Permit 1885.
This is a Severity Level IV violation (Supplement 1-D).
RESPONSE TO VIOLATION B
- 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 and inadequate procedure. The employee had been instructed on the duties of a firewatch but, failed to properly perform those duties. The procedure f ailed to require the firewatch to continuously walk and observe all affected areas.
- 3. CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED The employee was immediately removed from the site and terminated. The foreman of the employee was questioned to determine if he was aware of any of his employees sleeping. The foreman was not aware of any of his personnel sleeping and was aware that sleeping is not allowed onsite by any employee in any capacity.
The Nuclear Site Services work procedure #WP 001, " Welding and Flame Permits", was revised to:
- 1) require the foreman to instruct the firewatch prior to starting a job,2) req 9 ire continuous walking and observing of all affected areas, and 3) add cautions to remain alert and observant.
This incident has been reviewed with the Nuclear Site Services contract employees. The importance of firewatches and attentiveness of supervision was stressed.
l NOV 19 50-338&339/89-18 A4 of 5 1
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RESPONSE TO VIOLATION B (continued)
- 4. CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID'~ FURTHER VIOLATIONS No additional corrective actions are necessary to avoid further violations.
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- 5. THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full cornpliance has been achieved.
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