ML20246N211
| ML20246N211 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 07/14/1989 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 89-471, NUDOCS 8907190317 | |
| Download: ML20246N211 (5) | |
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VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 ~
July 14, 1989 U. S. Nuclear Regulatory Commission Serial No.
.89-471 Attention: Document Control Desk NAPS /JHL-Washington, D. C. 20555 Docket Nos. 50-338 -
50-339 License Nos. NPF-4 NPF-7 l
Gentlemen:
. VIRGINIA ELECTRIC AND POWER COMPANY 1 AND 2 INSPECTION REPORT N05. 50-338/89-11 AND 50-339/89-11 REPLY TO THE NOTICE OF VIOLATION AND NOTICE OF DEVIATION l
We have reviewed you r letter of June 20, 1989, which. referred to the inspection conducted at North Anna Power Station between. Apri!
'3, 1989 and j
April 7,.1989 and reported in Inspection Report Nos.
Sb-338/89-11 and 50-339/89-11. Our response to the Notice of Violation and Notice of Deviation j
are attached.
We have no objection to this correspondence being made a matter of public record.
If you _have any further questions, please contact us.
Very truly yours, I
W. L. Stewart 1
l Senior Vice President - Power Attachment cc; U. S. Nuclear Regulatory Commission 101 Marietta Street, N. W.
suite 2900 Atlanta, Georgia 30323 Mr. J. L. Caldwell NRC Senior Resident Inspector North Anna Power Station Q
8907190317 890714
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p RESPONSE TO THE NOTICE OF VIOLATION REPORTED DURING THE NRC INSPECTION CONDUCTED BETWEf.N APRIL 3, 1989 AND APRIL 7, 1989 INSPECTION REPORT NOS. 50-338/89-11 AND 50-339/89-11 NRC COPMENT During the Nuclear Regulatory Commission (NRC) inspection conducted on April 3
- 7,1989, a violation of NRC requirements was identified.
In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions,"
10 CFR Part 2, Appendix C -(1989), the violation is listed below:
10 CFR Part 50, Appendix B, Criterion XVI states that measures shall be established to assure that conditions adverse to quality such as deficiencies, deviations, defect've material and nonconformances are promptly identified and corrected.
Contrary to the above, the licensee failed to identify conditions adverse to quality as follows:
(a) The main control panel wiring and terminal block section had not been cleaned for an extended period of time resulting in a buildup 'of dust whic': could affect the integrity of the wiring.
(b) The Nuclear Instrumentation System Cabinets (two per Unit) which contain the excore neutron flux instruments in the-main control room contained one un-terminated multi-conductor control cable with bare (un-taped) conductors.
(c) A loose floor board in the control room constituted a deficiency
'because it could cause a person to fall into the wiring section of the open-back main control board.
(d) In nine panels in the main control room the bottom sealing boards were broken or missing.
This violation applies to Units 1 & 2, and is Severity Level IV, Supplement I.
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- a gx RESPONSE'TO THE NOTICE OF VIOLATION s
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ADMISSION OR DENIAL'0F THE ALLEGEt, VIOLATION
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The violation is: correct as stated..
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-REASON FOR THE VIOLATION The- _ violation was. caused by an inadequate procedure.
Station
' Administrative Procedure '(ADM) 20.48 Station Material Condition and Housekeeping. did' not specifically ident,1fy an individual responsible for the material. condition of the control room.
3.-
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED
' ADM 20.48 was revised'to identify the Superintendent Operations as the-individu61 responsible-for the material condition of. the control room.
Corrective actions to resolve the. discrepancies identified in the Notice of Violation were promptly initiated during. the inspection.
Corrective actions have since been completed to resolve the discrepancies.
Subsequent inspections of the control room area indicate that required
' corrective actions are being identified and addressed in a timely manner.
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.
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. RESPONSE TO THE NOTICE 0F'DEVIAT' ION' RE CTED
. BETWEEN APRIL 3, 1989 AND APRIL-.7,-1989
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INSPECTION REPORT N05.-50-338/89-11 AND 50-339/89-11 NRC C0pMENT-The following' deviation was identified during a Nuclear Regulatory ' Commission (NRC) inspection. conducted on' April 3-7,:1989.
.In Virginia: Electric ~and Power Company document, " Compliance.w.R Regulatory Gui_de l.97".. transmitted January 31, -1984, the licensee.
committed:~.to; comply with Regulatory. Guide-(RG) 1.97,: Instrumentation-for Light-Water-Cooled:. Nuclear Power-Plants to.. assess Plant and Env.Jons -Condition' during and following:.'and' Accident.
Specifically that commitment does not take exception ;for the neutron flux ' variable.
.RG 1.97. specifies ~ the.following design. criteria for Category.1 variables. Recording of instrumentation readout information. should be provided for at least.one redundant channel. Thetrending'information may be continuously updated. stroed in computer memory, and ~ displayed on demand.
Contrary to the above:
' Trend information for the neutron flux variable was not. available on' a
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dedicated recorder 'nor stored in computer memory for display on demand.
' Neutron flux is a Categcry'l variable.
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The Deviation. applies to the both Units.
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RESPONSE TO THE NOTICE OF DEVIATION 1.
REASONS FOR THE DEVIATION The deviation was due to not identifying the need to trend historical data, for Regulatory Guide (RG) 1.97 Variable B-1, Neutron Flux, in the design change package (DCP) that installed the excore neutron flux detectors.
2.
CORRFCTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED The Emergency Response Facility Computer System (ERFCS) has been modified to include historical recording for RG 1 97 Variable B-1, Neutron Flux.
A review was performed to determine if there were any other RG 1.97 Category 1 variables that were not being continuously recorded or stored in computer memory for display on demand. The review determined that RG 1.97 Category I variables are being historically recorded on the ERFCS.
Engineering Standard STD-GN-0028, Engineering Guidelines For ERF Computer System, was revised to include a checklist which requires the review of the ERF input for RG 1.97 variab'les that are being mr.dified.
3.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER DEVIATIONS i
No further corrective actions are required.
5.
THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED i
Full compliance has been achieved.
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