ML20247J939
| ML20247J939 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 05/22/1989 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | Lieberman J NRC OFFICE OF ENFORCEMENT (OE) |
| References | |
| 89-321, NUDOCS 8906010166 | |
| Download: ML20247J939 (9) | |
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Mr.' James Lieberman,' Director Serial No.89-321 Office of Enforcement -
NAPS /DEO/R2 U.S. Nuclear Regulatory Commission Docket Nos. _50-338 l
- Washington, D.C. 20555 50-339-License Nos. NPF-4 NPF-7 VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNITS 1 AND 2 j
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-REPLY TO A NOTICE OF VIOLATION AND PAWMENT OF IMPOSED civil PENALTY Gentlemen:
-We:have reviewed your letter of April 21,1989, which referred to the inspections-conducted at North Anna Power Station 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 and reported in 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, respectively. The response to the violation is addressed in Attachment
- 1. Corrective actions to resolve the control room habitability issues and to assure the
. reliability.and quality of the currently Installed Instrument Air system have been completed.i Additional enhancements'for the instrument Air system have been
' identified and scheduled. A detailed discussion of these issues and our program-Initiatives and enhancements to ' address the timeliness of corrective actions were discussed in Enforcement Conferences held on January 18, and February 7,1989.
t A c6eck in the amount of the assessed Civil Penalty. ($26,000) is -provided in. We have no objection to this correspondence being made a matter of public record. If you have any questions, please contact us.
Very truly y
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W. L. Stewart i
Senior Vice President - Power
= Attachments M
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U.S. Nuclear Regulatory '?ommission Attention: Document Cv.nrol Desk Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Region ll 101 Marietta Street, N.W.
Suite 2900 Atlanta, Georgia 30323 Mr. J. L. Caldwell NRC Senior Resident inspector North Anna Power Station
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e ATTACHMENT 1 RESPONSE TO THE NOTICE OF VIOLATION i
RESPONSE TO THE NOTICE OF VIOLAT;ON AND PROPOSED IMPOSITION OF CIVIL PENALTY REPORTED IN NRC REGION 11 LETTER DATED APRIL 21. 1989 REFERENCED 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 AND REPORTED IN INSPECTION REPORT NOS. 50-338.339/86 28: 50 338.339/87-01:
i 50 338.339/87-19: 50 338.339/88 02: 50 338.339/88 31: and 50 338.339/88 36 NRC COMMENT As a result of 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, 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,53 Fed. Reg. 40019 (October 13, 1988), the Nuclear Regulatory Commission proposes to impose a Civil Penalty pursuant to Section 234 of the Atomic Energy Act of 1954, as amended (Act),42 U.S.C. 2282, and 10 CFR 2.205. The violation and associated civil penaity are set forth below:
10 CFR Part 50, Appendix B, Criterion XVI, requires, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances 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 is taken to preclude repetition.
Contrary to the above, the licensee failed to implement that portion of its Quality Assurance Program dealing with Criterion XVI of Appendix B, in that conditions adverse to quality were not promptly identified and corrected as evidenced by the following examples:
1.
In June 1986, the licensee failed to identify and correct a control room emergency ventilation system flow rate that did not meet the requirements of Technical Specification 3.7.7.1.
Additionally, prior to December 1986, the licensee failed to identify and between December 1986 and January 1989, the licensee failed to correct deficiencies in the control room bottled air system which resulted in differential pressures between the control room and several adjacent compartments being outside the limits of Technical Specification 3.7.7.1.
2.
Between April 1987 and January 1989, the licensee failed to take adequate corrective actions to correct the degraded air quality in the instrument air system.
Specifically, following an April 1987 water intrusion event, the licensee failed to adequately address the presence of
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. water in the system and failed to identify the potential for and later correct r
.the presence of an excessive level of oil,'
.This is a Severity Level ill violation (Supplement l).
Civil Penalty - $25,000 O
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RESPONSE
1.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION j
The violation is correct as stated.
2.
REASON FOR THE VIOLATION
- The root cause of the Instrument Air system and control room habitability system degradation was due to lack of timely corrective actions.
3.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED Corrective steps taken include both actions to address the specific events identified in the inspection report as well as those actions to address programmatic weaknesses of timeliness in the corrective action program.
The corrective action for the control room emergency ventilation system flow rates exceeding the Technical Specification limit included 1) declaring the -
I control room ventilation system inoperable,2) adjusting the inlet dampers to bring the flow rates within the Technical Specification limits,3) submitting LER N1-86-019, and 4) developing a preventative maintenance procedure to require operability testing of the intake filters and provide for post maintenance testing.
Items 1 and 2 above were completed immediately upon identification of the problem.
i For the issue concerning the inadequate acceptance criteria for the control room bottled air system surveillance test, which allowed the readings from the -
differential pressure test gauges to be averaged, the corrective actions included changing the interpretation of the Technical Specifbation and revising the surveillance test to reflect the new Technical Specification interpretation. The control room bottled air system capacity was also upgraded.
A comprehensive program plan has been developed and is currently being implemented to address the instrument air issues identified in 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, NRC Information Notice 87-28, Generic Letter 88-14, INPO SOER 88-0, and the North Anna Safety System Functional Inspection. The objectives of the program are to:
a.
Ensure the reliability and quality of the currently installed instrument air L
system by:
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Performing a systematic inspection of instrument air components and replacing components es necessary based on inspection results.
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Adding additional air dryers and filters.
u Refurbishing the safety related air compressors in the Auxiliary 1
Building.
Samp!ing the instrument air system for oil and/or particulate.
Verifying the design basis of the instrument air system.
Performing design basis testing of safe shutdown air operated equipment.
Verifying the Emergency Operating Procedures are adequate for a loss of instrument air event.
Enhancing operator training for loss of instrument air events.
Adjusting the low pressure instrument air annunciator setpoint to a -
value above the setpoint of the PCV which provides service air (supplied by construction air) as a backup to instrument air. This allows more timely operator action ~ to be taken to restore instrument air if service air becomes the backup.
The corrective actions stated cbove have been completed on Unit 2 and will be completed on Unit 1 prior to the'end of the 1989 refueling outage.
~ b.
Provide increased reliability, comply with the commitments made in
- response to Generic Letter 88-14, and eliminate the use of contaminated construction air as a backup for either service air or instrument air by enhancing the instrument air system.
To address the root cause, additional actions have been taken. These actions include:
a.
Revising the station deviation reporting program to require the need for a root cause evaluation to be determined and to provide failure trend analysis information to determine the effectiveness of previous corrective actions.
b.
Developing program controls for root cause evaluations.
c.
Enhancing the information provided to management to provide timely indication of adverse trends or conditions of safety-related and nonsafety-related equipment.
e 4.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS No additional corrective actions are required to address the control room habitability issues stated in this Notice of Violation. (See also our letter of March 1,1989, Serial No.89-022)
The ongoing implementation of the instrument air program plan will be updated to include additional actions required as a result of reviewing NRC Information Notice 89-26, " Instrument Air Supply to Safety-Related Equipment." Long term upgrades to the instrument air system (see paragraph 3b) have been scheduled.
i Self assessment of the timeliness of corrective actions' will be performed periodically.
5.
THE DATE WHEN FULL COMPLIANCE WILL BE-ACHIEVED Full compliance for resolution of the control room habitability issues has been achieved.
The long term upgrades to the instrument air system are scheduled to be completed by the end of 1989 based on current engineering, procurement, and installation schedules.
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ATTACHMENT 2 VOUCHER CHECK - PAYMENT OF CIVIL PENALTY r
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