ML19345G752

Responds to NRC 810227 Ltr Re Violations Noted in IE Insp Repts 50-338/80-42 & 50-339/80-39.Corrective Actions:Damper Repaired,Sprinkler Sys Changed to Utilize Open Heads & Fire Extinguishers Provided in Auxiliary Svc Water Pump House

ML19345G752
Person / Time
Site:	North Anna
Issue date:	03/24/1981
From:	Sylvia B VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML19345G747	List: ML19345G752
References
163, NUDOCS 8104220219
Download: ML19345G752 (5)

Text

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. . . . r <g ~ ,. [J a March 24, 1981 Mr. James P. O'Reilly, Director Serial No. 163 Office of Inspection and Enforcement N0/RMT:ms U. S. Nuclear Regulatory Commission Docket Nos. 50-338 Region II 50-339 101 Marietta Street, Suite 3100 License Nos. NPF-4 Atlanta, Georgia 30303 NPF-7

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Dear Mr. O'Reilly:

We have reviewed your letter of February 27, 1981, in reference to the inspection conducted at North Anna Power Station on December 9-12, 1980 and reported in IE Inspection Report Nos. 50-338/80-42 and 50-339/80-39.

! Our responses to the specific infractions are attached.

We have determined that no proprietary information is contained in the l reports. Accordingly, the Virginia Electric and Power Company has no objec-tion to these inspection reports being made a matter of public disclosure.

Pursuant to Section 182 of the Atomic Energy Act of 1954, this material is being submitted under oath.

l Very truly yours, t

B. R. Sylvia Manager - Nuclear Operations and Maintenance Attachment cc: Mr. Robert A. Clark, Chief Operating Reactors Branch No. 3 Division of Licensing 81042gogR, m., - - - w -we wn m -- , -

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t C0!9f0NWEALTH OF VIRGINIA )

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CITY OF RICHMOND )

The foregoing document was - acknowledged before me, in and for the City and Commonwealth aforesaid, today by B. R. Sylvia, who is Manager-Nuclear Operations and Maintenance, of the Virginia Electric and Power Company. He is duly authorized to execute and file the foregoing document in behalf of that Company, and the statements in the document are true to the best of his knowledge and belief.

Acknowledged before me this 2iTH day of $0tch _ _, 19 1 My Commission expires: Smtuatv FI , 19 8 9 .

V U n JLAr" O Notary Public 1 t.LW 0%M M W. f 04 UL a Lbb',

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.' . Attachment Fega 1 cf 3 RESPONSE TO NOTICE OF VIOLATION ITEM REPORTED DURING NRC INSPECTIO_N CONDUCTED FROM DECEMBER 9-12, 1980 NRC COMMENT Technical Specification Section 4.7.15.b requires that penetration fire barriers shall be verified to be functional by a visual inspection prior to declaring a penetration fire barrier functional following repairs or mainte-nance.

Contrary to the above, the fire damper modification between the Units 1 and 2 cable tunnels was not inspected after the modification to assure that this penetration fire barrier was functional.

This is a Severity Level V Violation (Supplencatal I.E.).

RESPONSE

1. Admission or Denial of the Alleged Violat. ion The Notice of Violation is correct as stated.

2. Reasons For The Violation This infraction was th e result of an administrative error. Vepco Design Change No.78-68I inadvertantly omitted the requirement to inspect the damper after it was installed. Field Quality Control waived visual inspection of the damper since it was classified as QA Category III.

Stone & Webster Advisory Operations performed a visual inspection of the damper after it was installed, but no documentation was made at the time for later verification.

3. Corrective Steps Taken and Results Achieved On March 16, 1981 this damper was visually inspected by the Fire Marshal's designee, and found in need of repair. A fire watch was immediately posted in the area, and an Emergency Maintenance Request and a Deviation Report were submitted. Maintenance was performed on the damper, and it was visually inspected and verified operational.

l 4. Corrective Steps Which Will Be Taken to Avoid Further Violations l

Henceforth, all Design Change modifications to fire protection related systems will be 100% inspected by Q.A. prior to being placed in service.

5. Date When Full Compliance Will Be Achieved Full compliance has been achieved.

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Attcchinent Page 2 of 3 RESPONSE TO NOTICE OF VIOLATION ITEM REPORTED DURING NRC INSPECTION CONDUCTED FROM DECEMBER 9-12, 1980 i

NRC COMMENT l License Condition paragraph 2.c (11) requires that no later than November 1,

! 1980, Vepco shall implement the fire protection modifications as described in the Commission Safety Evaluation Report, " Fire Protection Program for North Anna Power Station Units 1 and 2" (FPSER), dated February 1979, except imple-l mentation of the safe shutdown system shall be implemented no later than April 1, 1981.

Contrary to the above, the sprinkler system for the high ceiling portion of the cable tunnel utilized closed heads in lieu of open heads as required by Table I of FPSER, and in addition, portable fire extinguishers were not provided at Auxiliary Service Water Pump House as required by Table 1 of FPSER.

This is a Severity Level V Violation (Supplement I.E.).

RESPONSE

1. Admission or Denial of the Alleged Violation The Notice of Violation is correct as stated.

2. Reasons for the Violation This infraction was the result of an administrative error. The only difference between closed heads and open heads on the sprinkler system is that the closed head uses a fusible link which opens at a specified temp-erature. The Fire Marshall had not removed the fusible links because he thought that the fire insurance company representative had to witness a

, hydrostatic test of the oprinkler system. On December 11, 1980, when l informed of the violation, the Fire Marshall contacted the insurance company and determined that it was not necessary to have a representative l" witness the hydrostatic test of the system. The fusible links were then removed to provide open heads on the sprinkler system to comply with the FPSER.

The Fire Marshall misunderstood the requirement that a fire extinguisher be placed in the Auxiliary Service Water Pump House. He thought it_was to be placed in the Fire Pump House.

3. Corrective Steps Taken and Results Achieved On Eccember 11, 1980, when informed of the infractions, the fusible links were removed from the sprinkler system which changed the closed heads to open heads as required by Table 1 of FPSER. On the same date, portable fire extinguishers were provided in the Auxiliary Service Water Pump Hotse.

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' Attcchment Peg 2 3 of 3

4. CorreediveStepsWhichWillBeTakentoAvoidFurtherViolations No additional corrective steps are required.

5. Date When Full Compliance Will Be Achieved i

Full compliance has been achieved.

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