ML19225A899

Responds to NRC 790514 Ltr Re Violations Noted in IE Insp Repts 50-338/79-19 & 50-339/79-25.Corrective Actions: Completed Procedures Will Be Reviewed by Engineer Prior to Review by Supervisor

ML19225A899
Person / Time
Site:	North Anna
Issue date:	06/06/1979
From:	Stallings C VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML19225A898	List: ML19225A899
References
NUDOCS 7907230014
Download: ML19225A899 (3)

Text

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VIHOINIA Ex.ncrHIC AND Powen CourANY RICnM onD,V3 EDIN ZA 20261 l9JUN 3 AS: 15 June 6, 1979 Mr. Ja=cs P. O'Reilly, Director Serial No. 385 Office of Inspection and Enforcement P0/FHT:bav U. S. Nuclear Regulatory Commission Docket No.: 50-338 Region II s 50-339 Atlanta, Georgia 30303 License No.: NPF-4 CPPR-78

Dear Mr. O'Reilly:

We have received your letter of May 14, 1979, in reference to the 'nspec- .

tion conducted et North Anr? Power Station Units 1 and 2 on April 17, 1979, and reported in IE Inspection Report Nos. 50-338/79-19 and 50-339/79-25.

Our response to the specific infraction is attached.

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

Very truly yours,

.c f C. M. Stalli gs Vice President-Power Supply and Production Operations Attachment cc: Mr. Albert Schwencer b '907030o 6

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Attachment:

Page 1 of 2 Response to Non-Compliance Items Reported in IE Inspection Report No. 50-339/79-25 NRC Comment:

As required by 10 CFR 50, Appendix B, Criterion VI, a test prograc shall be establishcd to assure that all testing required is perforced in accordance with written test procedures which incorporate requirements and acceptance licits. These requirements are impicoented by the approved Topical Report Quality Assurance Program, Section 17.1.11, and the Nuclear Power Station Quality Assurance Manual (NPSOAM), Section 11, paragraph 5.1.4. The NPSOAM requires that the individual (s) performing the test record the inforcation required by the test procedure and initial each step as it is satisfactorily c omple ted .

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s Contrary to the above:

1. During *he performance of preoperational testing procedure 2-PO-39.2, Residual Heat Re= oval System Heat Removal Capacity, test results approved April 10, 1979, the flow to the tube side of the residual heat re= oval heat exchanger was not established at 4000 + 50 gpm as required by step 4.1 of the procedure.

The calculations indicate a flow rate less than the required flow. Ad ditionally ,

the step was initiale.d as having been satisf actorily completed.

2. During the performance of preoperational testing procedure 2-PO-39.1, Residual Heat Rc= oval System Testing at Cold Conditions, test results approved

, January 12, 1979, the discharge pressure gauges used to record the residual heat removal pu=p discharge pressure on the data sheet were not the same gauges as required by steps 4.1.4 and 4.1.8 of the procedure. Again the steps

. were initialed as having been satisf actorily completed.

This is an infraction.

Re s pons e The above infraction is not completely correct as stated. Specifically, item 2 states that improper gauges were utilized to record residual heat re-ceval pump discharge pressure. A review of the test and the residual heat re= oval system indicates that the correct gauges were utilized. Because of the placement of check valves in the discharge piping of the residual heat removal purp, it is not possible for the pressure gauge of the non-operating pu=p to indicate a discharge pressure from the operating pump. The error found on the data sheet was a result of the test engineer recording the

, vrong gauge mark number. This error was purely adcinistrative in nature.

Pursuant to specification 2.201 of the NRC's " Rules o' Practice" Part 2, Title 10 Code of Federal Regulations, the follovir, information is submitted:

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• Pr,,e 2 of 2

1. Corrective steps taken and results achieved:

With reference to item #1, the fact that a lower flow rate was present resulted in a cuch more corservative estimate of the heat transfer capabilities.

Since the acceptance criteria were met, this had no adverse effect on the test.

In addition, the lower flow rate is fully documented in the chronological log.

The necessity of utilizing a procedure deviation in this instance was discussed with the specific test engineer involved.

With reference to item 2, the gauge mark numbers were corrected utilizing the guidelines contained in NPSQAM section 5.7.

2. Corrective action taken to avoid further non-compliance:

These items were discussed and reviewed with the station test engineers to insure that the proper guidelines were followed while running a test. The importance of a proper document review was also discussed. In order to reduce the number of administrative errors, co=pleted procedures will be reviewed by an engineer prior to the review by the Engineering Supervisor specifically for finding errors in documentation.

3. Date when full co=pliance will be achieved:

Full compliance has been achieved.

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