ML20137T209

Insp Repts 50-338/85-27 & 50-339/85-27 on 851007-1103. Violation Noted:Failure to Maintain Necessary Quality Records to Verify Qualification of Personnel Performing Actions Specified in Design Change Procedures

ML20137T209
Person / Time
Site:	North Anna
Issue date:	11/14/1985
From:	Branch M, Elrod S, Luehman J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20137T187	List: ML20137T181 ML20137T191 ML20137T209
References
50-338-85-27, 50-339-85-27, NUDOCS 8512060410
Download: ML20137T209 (8)

See also: IR 05000338/1985027

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o UNITED STATES

NUCLEAR REGULATORY COMMISSION

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y REGION il

j j 101 MARIETTA STREET,N.W.

• '- 2 ATLANTA. GEORGI A 30323

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Report Nos.: 50-338/85-27 and 50-339/85-27

Licensee: Virginia Electric & Power Company

Richmond, VA 23261

Docket Nos.: 50-338 and 50-339 License Nos.: NPF-4 and NPF-7

Facility Name: North Anna 1 and 2

Inspection Conducted: Octobir 7 - November 3,1985

, Inspectors: . W. A dov7[J9kf

M. W. Branch (SRI ) Date Signed

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~5 L + W NJJlt15X

J. G. Luehman (RI) Date Signed

Approved by: .

h M0JMiW(

S. Elrod, Section Chief Date Sicjned

Division of Reactor Projects

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SU E RY

Scope: This routine inspection by the resident inspectors involved 175

inspector-hours on-site in the areas of engineered safety features (ESF) walk-

down, operational safety verification, monthly maintenance, monthly surveillance,

preparations for refueling, design changes and modifications, and Inspection and

l Enforcement Information Notice follow-up.

Results: One violation was identified - failura to maintain necessary quality

records to verify qualification of personnel performing the actions specified in

design change procedures (paragraph 7).

8512060410 851115

PDR ADOCK 05000338

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REPORT DETAILS

1. Licensee Employees Contacted

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E. W. Harrell, Station Manager l

D. B. Roth, Quality Control (QC) Manager

G. E. Kane, Assistant Station Manager

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E. R. Smith, Assistant Statien Manager

R. O. Enfinger, Superintendent, Operations

J. R. Harper, Superintendent, Maintenance

A. H. Stafford, Superintendent, Health Physics

J. A. Stall, Superintendent, Technical Services

J. R. Hayes, Operations Coordinator

D. A. Heacock, Engineering Supervisor

D. E. Thomas, Mechanical Maintenance Supervisor

E. C. Tuttle, Electrical Supervisor

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R. A. Bergquist, Instrument Supervisor

4 F. T. -Terminella, Quality Assurance (QA) Supervisor

R. S. Thomas, Engineering Supervisor

G. H. Flowers, Nuclear Specialist

J. H. Leberstein, Licensing Coordinator

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i Other licensee employees contacted include technicians, operators,

mechanics, security force members, and office personnel.

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2. Exit Interview

The inspection scope and findings were summarized on November 5,1985, with

selected individuals identified in paragraph 1. The licensee acknowledged

the inspectors' findings. The licensee did not identify as proprietary any

of the material provided to or reviewed by: the inspectors during this

inspection.

3. Licensee Action on Previous Inspection Findings

This was not inspected during this reporting period.

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4. Unresolved Items

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Unresolved items were not identified during this inspection.

5. Plant Status-

, Unit 1

The unit . operated at or. near 100% power during most' of the inspection

period. On the evening of November 3,1985, _ the unit was shut down to

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commence.the cycle five six refueling outage.

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One reactor trip occurred on Unit 1 during the inspection period. The

a following paragraphs describe the operational transient which resulted in a

manual trip of the reactor by the control room operator on October 24, 1985.

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At 3:30 a.m. , the 480 volt AC circuit breaker for battery room exhaust -

fan 1-HV-F-57C failed and caused melting of the vertical bus bars in

motor control center (MCC) IJ1-1. This resulted in an electrical trip

of the MCC supply breaker,14J-4, and subsequent loss of power to

equipment supplied from the MCC. The equipment that was de-energized

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included the battery chargers for two of the four instrument buses and

the solenoid valves (TV-CC-106A, B, and C) which supply component

cooling water (CC) to all three reactor coolant pumps' (RCP) motor oil,

stator, and shroud coolers.

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At 3:45 a.m., a power decrease was initiated because of increasing RCP

motor bearing temperatures.

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At 3:50 a.m. , manual reactor and turbine trips were initiated in

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preparation for securing the RCPs.

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At 3:52 a.m. , all three RCPs were secured and natural circulation was

established. The incident was classified as an unusual event (UE) per

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the site emergency plan and the necessary notifications were initiated.

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At 6:45 a.m. , the 1A RCP was restarted af ter installing a temporary

jumper which allowed opening TV-CC-106A, thereby re-establishing CC

flow to the RCP motor.

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At 7:54 a.m. , repairs to MCC 1J1-1 were completed and at 8:56 a.m. 'all

loads except 1-HV-F-57C were re energized and returned to normal.

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At 9:02 a.m. , the UE was terminated and subsequent notifications were

made.

The plant's response to the natural circulation event was as expected; the

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conditions described in section 9.2.2.5.4 of the Updated Final Safety

Analysis Report (UFSAR), which describes a loss of CC to the RCPs, were

validated.

Unit 2

The unit was shut down from 100% power on October 11, 1985 because of a

failure of the 2H emergency diesel generator (EDG). Following repairs to

the EDG the unit was returned to power on October 15, 1985, and operated at

or near 100% power for the remainder of the inspection period. Details of

'the EDG failure are addressed in paragraph 12.of this report.

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6. Licensee Event Report (LER) Follow-up

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This was not inspected during this reporting period.

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7. Follow-up of Previously Identified Items

(Closed) Unresolved Item 338,339/84-38-02; Validity of Quality Records

Associated With Design Change Procedures. The conditions discussed in

paragraph 10 of Inspection Report 338,339/84-38 have been evaluated by the

NRC and appear to violate the requirements of 10 CFR Part 50 Appendix B,

Criterion XVII, which requires that sufficient records be maintained to

provide information regarding the qualification of personnel performing the

actions specified in the procedures.

The inspector's original concern, as discussed in Inspection Report

338,339/84-38, is provided below:

Section 5.2.2.1 of Administrative Procedure (ADM) 3.1 discusses the

control of design change procedures. being performed by the Engineering

and Construction (E&C) group. Specifically, the ADM states that, "upon

completion of each shift, the white working controlled copies are to be

returned to the design change log room and those steps completed shall

be signed in the master colored controlled copy by the supervisor

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immediately responsible and knowledgeable of activities completed."

The current practice at North Anna is to only keep the master colored

controlled copy of the procedure. The working copies are thrown away,

thereby destroying the ability to verify personnel qualifications. The

following regulatory concerns associated with this practice were

discussed with station QA personnel: r

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Technical Specification (TS) 6.10.2.a requires records and drawing

changes reflecting facility design modifications made to systems

and equipment described in the Final Safety Analysis Report be

retained for the duration of the facility operating lic,e,nse.

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Amendment 4 of the Virginia Electric and Power Company (VEPCO) '

Topical Report, VEP-1, " Quality Assurance Program, Operations

Phase", commits VEPC0 to collect, store, and maintain QA records

in accordance with NRC Regulatory Guide 1.88, Revision 2,1976,

which endorses American National Standards Institute (ANSI)

N45.2.9-1974.

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Section-3.2 of ANSI N45.2.9-1974, provides instructions on what

constitutes a valid QA record.

The inspector reviewed several design change procedures and verified that

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the record copy of the procedures do not identify the individuals who

actually performed the actions; therefore, no traceability of qualifications

exists. The design change procedures (DCPs) reviewed, along with the

inspector's findings, are listed below:

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DCP-82-148, Class IE Transmitter Replacement, required in section

4.2.1.13 as well ~ as in numerous other sections, that Conax seal

assemblies be installed using Rosemont and Conax installation

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instructions. The working copy and record copy of this procedure were

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signed by different individuals.

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DCP-83-24, Appendix "R" Emergency Diesel Generator Isolation, required

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in section 4.11.2 as well as numerous other related sections, that

i specific safety-related cables be disconnected. The working copy and

record copy of this procedure were signed by different individuals.

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DCP-84-15, Outside Recirculation Spray Pump Valve Replacement, North

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Anna Unit 1, required in section 4.3.5 that certain precise measure-

ments be made. The working copy and record copy of this procedure were

signed by different individuals. Another section of this DCP (4.5.16)

required a verification that the temperature of the weld returned to

within 5-10 degrees Fahrenheit of room temperature using a contact

thermometer. Once again, the working copy and record copy of the

procedure were signed by different individuals.

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The failure to provide traceable records regarding the qualification of

individuals actually performing these actions is identified as violation

338,339/85-27-01, and applies to both units.

8. Monthly Maintenance

Station maintenance activities affecting safety-related systems and

components were observed / reviewed to ascertain that the activities were

conducted in accordance with approved procedures, regulatory guides and

industry codes or standards, and in conformance with TS. Specific items

observed include the repairs to the 2H EDG discussed in paragraph 12, and

repairs to the Unit 1, IJ1-1 MCC discussed in paragraph 5.

No violations or deviations were identified.

9. Monthly Surveillance

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The inspectors observed / reviewed TS-required testing and verified that

testing was performed in accordance with adequate procedures, that test

instrumentation was calibrated, that limiting conditions for operation (LCO)

were met and that any deficiencies identified were properly reviewed and

resolved.

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No violations or deviations were identified.

10. ESF System Walkdown

, The following selected ESF systems were verified operable by performing a

walkdown of the accessible and essential portions of the systems on

October 25, 1985.

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Unit 1 and Unit 2 EDG remote and local breaker alignment.

No violations or deviations were identified.

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11. Routine Inspection

The inspectors' observations during the inspection period verified that

control room manning requirements were being met. In addition, the

inspectors observed shift turnover to verify that continuity of system

status was maintained. The inspectors periodically questioned shi fi,

personnel relative to their awareness of plant conditions.

Through log review and plant tours, the inspectors verified compliance with

selected TSs and LCOs.

During the course of the inspection, observations relative to Protected and ,

Vital Area security were made, including access controls, boundary inte-

grity, search, escort and badging.

On a regular basis, radiation work permits (RWP) were reviewed and specific

work activities were monitored to assure they were being conducted per the

RWPs. Selected radiation protection instruments were periodically checked,

and equipment operability and calibration frequency were verified.

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The inspectors kept informed, on a daily basis, of the overall status of ,

both units and of any significant safety matters related to plant opera-  ;

tions. Discussions were held with plant management and various members of

the operations staff on a regular basis. Selected portions of operating logs

and data sheets were reviewed daily.

The inspectors conducted various plant tours and made frequent visits to the

Control Room. Observations included' the following: witnessing work

activities in progress; verifying the status of operating and standby safety

systems and equipment; confirming valve positions, instrument and recorder

readings, ann'unciator alarms, and housekeeping.

No violations or deviations were-identified.

12. Diesel Generator Failures <

Both units at North Anna have experienced numerous internal failures of

their EDG engines. The failures can be categorized as either piston / ring

failure or cylinder liner scoring / cracking failures. The licensee' has

attributed past failures _ to severe TS testing requirements (ie. fast, cold

starts and/or fast loading). The term " fast, cold start" refers to the TS

requirement to start the'EDG from ambient conditions and reach rated voltage .

and frequency within 10 seconds.

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The diesel engines are manufactured by the Fairbanks Morse Engine Division

of Colt Industries (model 38TD8-1/8), and. use a 12-cylinder, opposed piston,

turbocharged design. These EDGs are rated for continuous duty at 2750

kilowatts (KW), for 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> at-3000 KW, and for 30 minutes at 3300 KW.

The diesel manufacturer and the licensee speculated that the most probable

cause of piston / liner failures could be attributed to stress-related damage

to the wrist pin-to-connecting rod and wrist pin-to piston insert bushings,

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causing piston distortion with ultimate contact between the piston and the

cylinder liner. This contact causes excessive heating and continued piston

growth until high temperature stress-related piston or liner cracking

occurs. This results in pressurization of the crar.kcase and engine shutdown

by the engine protection system. A wrist pin-to-connecting rod bushing on

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damaged equipment removed from the 2H diesel was measured and found to have

elongated by approximately 0.2".

On October 18, 1985, the licensee' met with members of the NRC staff which

included personnel from NRR, IE, and Region II. The purpose of the meeting

! was to discuss the details and probable cause of recent engine failures, and

the proposed corrective actions to improve reliability. The licensee

discussed past engine failures and presented their estimate of the most

probable cause; the upcoming complete engine overhaul was also discussed.

i The licensee committed to complete the engine overhauls prior to returning

the units to power following the November 1985 and April 1986 refueling

cutages -for Units 1 and 2, respectively. Additionally, the licensee

. presented information to justify continued operation of the units until

completion of these overhauls; this included past failure analyses and

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details of previous component replacements.

The diesel generator reliability improvement program was required as part of

License Amendment No. 48 of the Unit 2 TS and will be closely followed by

the inspectors during the upcoming refueling outages; this is identified as

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Inspector Follow-up Item (IFI 338, 339/85-27-02).

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No violations or deviations were identified.

, 13. Inspection and Enforcement Information Notice (IEIN) Follow-up

IEIN 85-82, Diesel Generator Differential Protection Relay Not Seismically

Qualified, identifies a concern that General Electric (GE) model 12CFD

rel_ays, often used for EDG protection against electrical shorts and grounds,

are not seismically qualified. The . inspectors verified that EDG output

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breaker protection at North Anna is 'not being provided by the type relays

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identified in the IEIN. The protection for both North Anna 1 and 2 is

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provided by GE model 12HFA and 12CFVB relays which are not addressed in the

IEIN.

14. Preparations for Refueling

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During the week cf October 28, 1985, the inspector reviewed the upcoming

refueling outage schedule and discussed major objectives of the outage with

the refueling coordinator. The inspector also reviewed several refueling

procedures and verified that the licensee had reviewed vendor change

recommendations and appropriately modified station implementing procedures.

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No violations or deviations were identified.

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15. Design Changes and Modifications (37700)

The design change and modification program was reviewed by the inspectors.

Specifically, the inspectors selected several design change packages and

verified the following:

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that design changes were reviewed and approved in accordance with TS

and QA program requirements;

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that design changes were controlled by established plant procedures;

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that design changes were reviewed and approved in accordance with the

requirements of 10 CFR 50.59;

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and that operating procedures and drawings were updated in a timely

manner to reflect the modification.

Those design changes reviewed are discussed in paragraph 7 of this report.

No violations or deviations, other than that listed in paragraph 7, were

identified.

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