ML20247F058
| ML20247F058 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 05/18/1989 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 89-312, NUDOCS 8905260408 | |
| Download: ML20247F058 (6) | |
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VIRGINIA ELECTRIC AND POWER COMPANY RicIIMOND, VIRGINIA 23261 fiay 18,1989 U.S. Nuclear Regulatory Commission Serial No.89-312 Attention: Document Control Desk NAPS /DEO/R2.
Washington, D.C. 20555 Docket Nos. 50-338 50-339 License Nos. NPF-4 NPF-7 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNITS 1 AND 2 INSPECTION REPORT NOS. 50-338/89-03 AND 50-339/89-03 REPLY TO THE NOTICES OF VIOLATION We have reviewed your letter of April 18,1989 which referred to the inspection conducted at North Anna Power Station on February 3,1989 through March 20,1989 and reported in Inspection Report Nos. 50-338/89-03 and 50-339/89-03.
Our -
response to the Notices of Violation are attached.
We have no objection to this correspondence being made a matter of public record. If
- you have any questions, please contact us.
Very truly yours,
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W. L. Stewa Senior Vice' President - Power Attachment cc:
U.S. Nuclear Regulatory Commission Region 11 101 Marietta Street, N.W.
Suite 2900 Atlanta, Georgia 30323 Mr. J. L. Caldwell NRC Senior Resident inspector North Anna Power Station 1
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8905260408 890518 PDR ADOCK 05000338 i
O PDC
RESPONSE TO THE NOTICES OF VIOLATION REPORTED DURING THE NRC INSPECTION CONDUCTED BETWEEN FEBRUARY 3.1989 AND MARCH 20. 1989 INSPECTION REPORT NOS. 50-338/89-03 AND 50-339/89-03 NRC COMMENT During the Nuclear Regulatory Commission (NRC) inspection conducted on February 3, - March 20,1989, two 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 (1989), the violations are listed below:
A.
10 CFR 50, Appendix B, Criterion XVI, Corrective Action, requires that measures be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and non::onformances are promptly identified and corrected.
In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.
Contrary to the above, adequate corrective actions were not taken to preclude repetition of the erratic response by the condenser air ejector radiation monitor (1-RM-SV-121) in that, moisture in the monitor lines was identified as the cause of the monitor being declared inoperable on July 13,1987, prior to the last steam generator tube incident. Subsequently, no actions were taken to correct the problem which, again, apparently caused the monitor to respond erratically during the steam generator tube leak on February 25,1989.
This is a Severity Level IV violation (Supplement I) and applied to Unit 1 only.
RESPONSE TO VIOLATION A 1.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION The violation is correct as stated.
2.
REASON FOR THE VIOLATION i
1 The violation was caused by inadequate controls to ensure a Root Cause Evaluation (RCE) was performed subsequent to initially identifying moisture intrusion problems with air ejector radiation monitor 1-SV-RM-121.
At 0809 hours0.00936 days <br />0.225 hours <br />0.00134 weeks <br />3.078245e-4 months <br /> on July 13,19871-SV-RM-121 was removed from service due to 1
abnormally low radiation level readings in the control room. At this time the action statement of Technical Specification 3.3.3.11 was entered and a work request was submitted. Moisture was subsequently drained from the detector and the radiation monitor was returned to service at 0815 hours0.00943 days <br />0.226 hours <br />0.00135 weeks <br />3.101075e-4 months <br /> on July 14, 1987.
At 2238 hours0.0259 days <br />0.622 hours <br />0.0037 weeks <br />8.51559e-4 months <br /> on July 14, 1987 the radiation monitor was again indicating low radiation levels.
As a result,1-SV-RM-121 was declared inoperable and the action statement of Technical Specification 3.3.3.11 was re-entered.
On July 15,1987, North Anna Unit 1 experienced a Steam Generator Tube Rupture (SGTR) with 1-SV-RM-121 stillinoperable. Subsequent to the SGTR event on July 15,1987, maintenance performed on 1-SV-RM-121 identified a failed power supply as the cause for the low radiation level readings. The power supply was then replaced and the radiation monitor was satisfactorily calibrated and returned to service.
No additional work requests have been submitted concerning water intrusion problems with 1-SV-RM-121 from the time the power supply was replaced in July 1987 until moisture was again identified as a problem with the detector during Health Physics local sampling following the steam generator tube leak event on February 25,1989.
3.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED Engineering was assigned to perform a RCE on the air ejector radiation monitor due to the erratic readings which occurred during the February 25,1989 steam generator tube leak event. Based on preliminary results, it appears that the root cause of the erratic readings was the system piping arrangement.
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The current system piping arrangement on Unit 1 allows the after condenser drain loop sea! to be broken when the air ejector is automatically diverted to containment upon detection of high radiation levels. Breaking this loop seal allows water from the loop seal to flow from the after condenser through the radiation monitor.
4.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS Check valves will be added to the air ejector radiation monitor piping on Unit 1 to prevent water from the loop seals from flowing through the radiation monitor when the air ejector is automatically diverted to containment upon detection of high radiation levels.
5.
THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The check valves will be added to the air ejector radiation monitor piping prior to the end of the 1989 Unit 1 refueling outage. Check valves on Unit 2 currently exist and no modifications were required.
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g NRC COMMENT L
B.
Technical Specification 6.8.1.a. requires written procedures be established, L
implemented and maintained for operr. tion of the service water system as documented in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Operating Procedure 1-OP-49.1 A, Valve Checkoff-Service Water, and service water system drawing 11715-FM-078B require that service water valve 2-SW-242 be in the closed position.
Contrary to the above, on February 6,1989, service water valve 2-SW-242 was found in the open position.
This is a Severity Level V violation (Supplement 1) and applied to Unit 2 only.
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I RESPONSE TO VIOLATION B 1.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION The violation is correct as stated. However, on February 6,1989 operations personnel, when notified of a missing pipe cap, found service water valve 2-SW-242 open with the pipe cap removed. This is contrary to Operating Procedure 1-OP-49.1 A and drawing 11715-FM-078B which require that valve 2-SW-242 be in the closed position. At that time, operations personnel closed the valve and installed the pipe cap, initiated an investigation to determine how the valve was left open and uncapped, notified the on-site NRC inspectors, and suomitted a station deviation report to document the event.
2.
REASON FOR THE VIOLATION An investigation was initiated to determine how service water valve 2-SW-242 was left open.
Periodic test procedure 2-PT-62.2.1, "RSHX SW INLEAKAGE," is performed weekly or at an increased frequency, based on the surveillance results, to verify that the Recirculation Spray Heat Exchangers are being maintained in dry layup. During the performance of 2 PT-62.2.12, the supply header vent valve, 2-SW-242, to the Recirculation Spray Heat Exchangers is opened to facilitate drainage, through the drain valve, of any service water leakage and then independently verified closed. Prior to this event,2-PT-62.2.1 was satisfactorily performed on February 4,1989, with valve 2-SW-242 independently verified closed.
Results of an investigation to determine how and when the valve was left open and uncapped was inconclusive.
3.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED Upon discovery, valve 2-SW-242 was closed and the pipe cap installed.
4.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS Based on our investigation, we have concluded that the event was an isolated
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case. Therefore, no additional actions are necessary to avoid further violations.
5.
THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance has been achieved.
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