ML20247P067
| ML20247P067 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 07/28/1989 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | Lieberman J NRC OFFICE OF ENFORCEMENT (OE) |
| References | |
| 89-512, EA-89-103, NUDOCS 8908030317 | |
| Download: ML20247P067 (7) | |
Text
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VIRG!NIA ELECTRIC AND POWER COMPANY RICilMOND, VIRGINIA 23261
'.V. l. ST E W A R T SrNton Vict PREstpENT I""
July 28, 1989 Mr. James Lieberman, Director Serial No 89-512 Office of Enforcement NAPS /JHL/TAH:jmj U. S. Nuclear Regulatory Commission Docket No.
50-338 Attn: Document Control Desk 50-339 Washingtori, D. C. 20555 License No.
NPF-4 NPF-7 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNITS 1 AND 2 INSPECTION REPORT NOS. 50 338&339/89 08 AND 50-338&339/89-14 REPLY TO THE NOTICE OF VIOLATION (EA 89-103)
We have reviewed your letter of July 5,1989, which referred to the inspect;ons conducted at North Anna Power Station, March 21, 1989 through April 17,1989, April 25,1989 thrcugh May 3,1989 and April 18,1989 through May 31,1989 and reported in inspection Report Nos. 50-338&339/89-08 and 50-338&339/89-14. Our responses to the Notice of Violation are attached. A detailed discussion of these issues was discussed in the Enforcement Conference held on May 24,1989 t.nd was documented in yourletter dated June 23,1989.
We have no cbjection to this correspondence being made a matter of public record.
If you have further questions, please contact us.
Very truly yours,
(
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,w.
l W. L. STEWART Attachtnents:
i 8908030317 890728 ADOCK 0500 8
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cc:
U. S. Nuclear Regulatory Comnission 101 Marietta Street, N.W.
Suite 2900 Atlanta, GA 30323 Mr. J. L. Caldwell NRC Senior Resident inspector North Anna Power Station l
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L RESPONSE TO THE NOTICE OF VIOLATION REPORTED DURING THE NRC INSPECTIONS CONDUCTED MARCH 21 THROUGH APRIL 17. 1989 APRIL 25 THROUGH MAY 5.1989 AND APRIL 18 THROUGH MAY 31. 1989 ENFORCEMENT ACTION EA 89-103 EA 89103 VIOLATION A NRC COMMENT During the Nuclear Regulatory Commission (NRC) inspections conducted on March 21 - April 17, April 25 -
May 5, and April 18 - May 31,1989, violations of NRC requirements were identified. In accordance with the l
" General Statement of Policy and Procedure for NRC Enforcement Actions,"10 CFR Part 2, Apperidix C, 53 Fed. Reg. 40019 (October 13,1988), the violations are listed below:
I A.
Technical SpecMication (T.S.) 3.6.2.2 requires, in part, that the containment recirculation spray system shall be operable with four separate and independent containment recirculation spray subsystems, each composed of a spray pump, associated heat exchanger and flow path. With one containment recirculation spray subsystem inoperable, T.S. 3.6.2.2 requires the inoperable I
subsystem to be restored to OPERABLE status within 7 days or the unit shall be in at least HOT i
STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and if not restored to OPERABLE status within the next 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> l
the unit shall be placed in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
j Contrary to the above, the following conditions singularly or in combination rendered the containment recirculation spray system inoperable and the affected unit was not placed in HOT STANDBY or COLD SHUTDOWN as required:
1.
For an indeterminate period prior to April 1989, two of the four Unit 1 recirculation spray heat exchangers (RSHX) and one of the four Unit 2 RSHX would not have received the design basis service water flow of 4500 gpm as specified in Table 6.2.2 of the Updated Final Safety Analysis Report (UFSAR) due to incorrectly set throttle valves.
2.
Maintaining all the RSHX for both units in wet lay-up from June 1987 to June 1988 resulted in higher heat transfer foul!ng factors than assumed in the UFSAR.
3.
For an indeterminate period prior to October 1988, the RSHX, under design basis accident conditions, could have received less than design basis service water flow in certain combinations of service water pumps and component cooling water heat exchangers.
This is a Severity Level 111 violation (Supplement I).
A - 1 of 5
EA 89-103
,s.
RESPONSE TO VIOLATION 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 the failure to recognize and apply design basis limitations to operating, surveillance and maintenance procedures.
3.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED Upon identification that the recirculation spray heat exchangers (RSHXs) were being operated outside the design basis of the UFSAR immediate action were take to ensure compliance with the Technical Specifications. This included administratively restricting operations to ensure the design basis wero met, review of the system conditions by the Station Nuclear Safety and Operating Committee, and notifying the NRC Resident inspector.
Corrective actions associated with RSHX tube fouling, reduced service water system flow rate through the Component Cooling Heat Exchangers (CCHXs) and reduced service water system flow rate through the RSHXs includes:
Performing an assessment of the RSHXs in a wet lay-up condition.
Cleaning and flushing the RSHXs with biocides.
Placing the RSHXs in dry lay-up.
Inspecting one RSHX to verify there is no fouling.
Installing drain valves to remove any leak-by from the service water header isolation valves.
Initiating a dry lay-up surveillance program for the RSHXs.
Implementing an Operations Standing Order to limit flow through the Component Cooling Heat Exchangers (CCHXs) and to insure at least 3 service water pumps are maintained operable.
Cleaning of the CCHXs to improve heat transfer capabilities.
i A - 2 0f 5
l EA 89-103 Performing a flow balance on the CCHXs using ultrasonic flow meters.
Performing testing to obtain the service water pumps' head curves over the entire operating range.
Adjusting the electrical and mechanical limits on the service water system inlet motor operated valves (MOVs) to achieve the required flow through the RSHXs.
Administratively controlling the position, of the service water bypass f40Vs.
Revising maintenance procedures to assure limits are properly set and checked after maintenance on the service water system inlet MOVs to the RSHXs.
Revising the appropriate documents to reflect the as left limit switch setting To address the root cause of the violatien, a program has been initiated to develop design basis documentation which includes a testing and surveillance assessment for each system.
4.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS Periodic head curve testing will be performed on each service water pump once every 18 months during a scheduled refueling outage if significant head curve degradation is detected (compared to the last test), either pump repair will be performed or the service water flow to the RSHXs will be rebalanced prior to designating the affected pump as an OPERABLE pump. In addition, testing per ASME Section XI is performed quarterly and will ensure no significant pump degradation occurs between the 18 month (refueling outage) testing.
5.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Procedures will be revised, by August 31,1989, to perform periodic head curve testing of each service water pump once every 18 months during a scheduled refueling outage.
A - 3 of 5
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EA 89-103 I
RESPONSE TO THE NOTICE OF VIOLATlQN l
REPORTED DURING THE NRC INSPECTIONS CONDUCTED MARCH 21 THROUGH APRIL 17. 1989 APRIL 25 THROUGH MAY 5.1989 AND APRIL 18 THROUGH MAY 31. 1989 ENFORCEMENT ACTION EA 89 103 EA 89-103 VIOLATION B NRC COMMENT l
During the Nuclear Regulatory Commission (NRC) inspections conducted on March 21 - April 17, April 25 -
l May 5, and April 18 - May 31,1989, violations of NRC requirements were identified in accordance with the
" General Statement of Polcy and Procedure for NRC Enforcement Actions,"10 CFR Part 2, Appendix C, 53 Fed. Reg. 40019 (October 13,1988), the violations are listed below:
B.
Technical Specification 6.8.1.a requires written procedures be established, implemented, and maintained covering procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Regulatory Guide 1.33, Revision 2, February 1978 recommends written procedures for startup, operation, and shutdown of the reactor coolant system.
Contrary to the above, a Unit 1 reactor coolant system operating procedure for purging the reactor vessel head,1-OP-11.3, was inadequate in that it did not preclude inadvertent lowering of reactor vessel level while purging operations were in progress. On April 26 and 27,1989, the routine diversion of reactor coolant system inventory from the primary drain transfer tank, during a vessel purge, caused inadvertent reductions in reactor vessel inventory.
This is a Severity Level IV violation (Supplement 1).
RESPONSE TO VIOLATION B 1.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION The violation is correct as stated.
2.
REASON FOR THE VIOLATION Tne cause of the violation was due to an inadequate procedure for controlling reactor head purging operations.
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EA 89-103 i
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CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED
-Unit 1 and 2 procedures,1(2)-OP-11.3, Puraina the Reactor Vessel Head. were revised to provide 7
L additional precautions and limitations associated with head purging and reduced inventory operations.
Training was provided to licensed operators on the reduced RCS inventory events to stress the potential consequences of a loss RCS inventory. In addition, the licensed operators were trained on the revisions to the head purging procedures.
4.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS The reactor head purge hose will be evaluated to determine if it can be made less susceptible to forming loop seals.
The permanent RCS reduced inventory levelindication system was partially installed on each unit during the 1989 refueling outages. Finalinstallation and testing of the permanent RCS reduced inventory levelindication system will be completed prior to the next entry into a reduced inventory condition on each unit.
5.
DATE WitEN FULL COMPLIANCE WILL BE ACHIEVED The evaluation of the reactor head purge hose to make it less susceptible to forming loop seals will be completed by the next refueling outage (for each unit).
The perrnanent RCS reduced inventory level indication system will be installed prior to the next entry irto a reduced inventory conditior for each unit.
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