ML20249A014
| ML20249A014 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 06/11/1998 |
| From: | Ohanlon J VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-338-98-02, 50-338-98-2, 50-339-98-02, 50-339-98-2, 98-323, NUDOCS 9806150314 | |
| Download: ML20249A014 (4) | |
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Vincisia Isticcinic ann l'owica Cmti'ANY Riciistosis, MRGINI A 232(,1 June 11, 1998 U. S. Nuclear Regulatory Commission Serial No.98-323 l
Atterition: Document Control Desk NAPS /MPW R1 l
Washingtcn, 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 NO3. 50-338/98-02 AND 50-339/98-02 REPLY TO A NOTICE OF VIOLATION l
We have reviewed your letter of May 18, 1998, which referred to the inspection l
conducted at North Anna Power Station from March 8,1998 through April 18,1998, and the associated Notice of Violation, which was reported in inspection Report Nos.
50-338/98-02 and 50-339/98-02. Our reply to the Notice of Violation is attached.
l No new commitments are intended as a result of this letter. If you have any further questions, please contact us.
1 Very truly yours, W
James P. O'Hanlon Senior Vice President - Nuclear l
Attachment
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I cc:
U. S. Nuclear Regulatory Commission 1
Region il l
Atlanta Federal Center 61 Forsyth St., SW, Suite 23T85 Atlanta, Georgia 30303 Mr. M. J. Morgan NRC Senior Resident inspector North Anna Power Station
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,.8,v-9906150314 990611 PDR ADOCK 05000338 G
REPLY TO A NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-338/98-02 AND 50-339/98-02
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l NRC COMMENT l
"During an NRC inspection conducted on March 8 through April 18,1998, a violation of NRC requirements was identified, in accordance with the " General Statement of Policy j
and Procedures for NRC Enforcement Actions," NUREG 1600, the violation is listed i
below:
I Technical Specification 6.8.1.c states that written procedures shall be established, implemented and maintained for surveillance and test activities of
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safety related equipment.
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Virginia Power Administrative Procedures, VPAP-1102, " Periodic Testing,"
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Revision 1, step 6.4.1.c.5 states that all steps are to be completed unless the periodic test specifically directs otherwise.
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Operations Department Administrative Procedures, OPAP-002, " Operations Department Procedures," Revision 5, Step 6.* 2.e.2 states that procedure steps l
shall be initialed by the qualified operator performing the step when possible.
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However, if it is not possible for the qualified operator performing the step to
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initial, a senior reactor operator may initial the step if they possess sufficient l
know! edge and confidence that the task required by the step has been completed.
l Periodic Test Procedure 2-PT-83.1, " Simulated Loss of Offsite Power (LOOP) and ESF Actuation-H Bus," Revision 20, Step 6.3.6.a required placement of the Unit 21 A inside recirculation spray pump breaker in the TEST position.
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' Contrary to the above, on April 6,1998, a senior reactor operator improperly j;
initialed step 6.3.6.a of 2-PT-83.1 as having been performed without sufficient knowledge that the step had been completed. The senior reactor operator used uncontrolled information from a control board magnetic sign which indicated the breaker was in the TEST position. The breakar, however, was in the CONNECT i
position. When the pump circuitry was tested, the pump unexpectedly started.
This is a Severity Level IV violation (Supplement I)."
REPLY TO NOTICE OF VIOLATION 1.
REASON FOR THE VIOLATION The reason for the violation was inadequate communications, inattention to detail; and inadequate status controls.
During the performance of Periodic Test 2-PT-83.1, Simulated Loss of Offsite Power with ESF Actuation-H Bus, operations personnel inadvertently started the Unit 2 "A" inside recirculation spray pump (2-RS-P-1A). The events that led to-the inadvertent start of 2-RS-P-1A are discussed below.
Night shift operations personnel were assigned to rack the breakers for 2-RS-P-18 and 2-RS-P-2B to " TEST" for "J" bus blackout testing. The operator in the field racking the pump breakers notified the operator at the controls (OATC) that the "J" bus recirculation spray pumps were in " TEST." The OATC mistakenly placed magnetic "IN TEST" labels on all four recirculation spray pump (2-RS-P-1A and B and 2-RS-P-2A and B) control switches. The operator at the controls assumed the field operator's message was that all four pump breakers were racked to the " TEST" position.
The day shift senior reactor operator (SRO) preparing for the performance of "H" bus blackout testing noted the magnetic "lN TEST" labels on the control switches for 2-RS-P-1A and 2-RS-P-2A. The SRO relied on the magnetic labels for status control and signed off on the applicable steps of 2-PT-83.1 that the breakers-
. were in " TEST." The SRO did not receive a status of breaker conditions from the night shift and did not verify that the breakers were actually racked to the " TEST" position. As a result, when the breaker for 2-RS-P-1A was closed during the testing sequence, the pump started.
2.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED
- As an immediate_ corrective action, the pump's breaker was re-opened and 2-PT-83.1 was stopped until all required recirculation spray pump breakers were
' placed or verified to be in the test position.
The unit was in Mode 5 in preparation for refueling. As such, the recirculation pumps were not required to be operable.
A deviation report was initiated to document the inadvertent start of 2-RS-P-1 A.
l Operations procedures OP-26.9 and OP-26.10 for 4160 and 480 voit breaker operation were revised to add a signoff step for placing and removing the "In l
Test" labels when a breaker is racked to or from the test position. This adds a j
more positive control to the label.
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Th3 individu:Is involvsd in ths ovant wara coach:d on tha importance of accurate communications, procedure compliance, and attention to detail.
An entry was made into Operations Department Required Reading to alert all operations personnel on the importance of accurate communications, procedure compliance, and attention to detail.
Additionally, the Operations Standard for equipment status and visual cues was revised to add criteria for magnetic labels. The primary purpose and use of magnetic labels is to provide the operators with a reminder of information pertaining to component situations. The magnets do not provide procedural guidance and do not replace component configuration verification.
3.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOlD FURTHER VIOLATIONS No further corrective actions are required.
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THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance has been achieved.
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