ML20133B935

Responds to NRC Re Violations Noted in Insp Repts 50-338/96-10 & 50-339/96-10.Corrective Actions:Operations Procedure 0-OP-20.6 Revised

ML20133B935
Person / Time
Site:	North Anna
Issue date:	01/02/1997
From:	Ohanlon J VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9701060279
Download: ML20133B935 (9)

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e YIHOINIA ELECTHIC AND POWER COMPANY Ricnwoxo,VIHOINIA 20261 l January 2, 1997 l

U. S. Nuclear Regulatory Commission Serial No.96-622 Attention: Document Control Desk NAPS /JHL R5 Washington, D. C. 20555 Docket Nos. 50-338 50-339 License Nos. NPF-4 NPF-7 Gentlemen: l VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNITS 1 AND 2 INSPECTION REPORT NOS. 50-338/96-10 AND 50-339/96-10  !

BEPLY TO THE NOTICE OF VIOLATION We have reviewed your letter of December 2,1996, which referred to the inspection conducted at North Anna Power Station from September 22,1996 through November i 2,1996, and the associated Notice of Violation which was reported in Inspection Report l Nos. 50-338/96-10 and 50-339/96-10. Our reply to the Notice of Violation is attached.

In the letter transmitting the Notice of Violation, you expressed concern over the  ;

increasing number of equipment and personnel problems in maintenarce-related 1 activities. We have also noted this declining trend and are taking the following steps:

1) a check technician has been established in each functional area in maintenance to  !

provide expert overview to other craft personnel,2) meetings are being conducted with maintenance craft personnel to reiterate management's expectations on work practices and procedure usage, and 3) a rework assessment is being performed to identify the causes for several equipment-related failures. These measures are intended to i strengthen and monitor performance in the maintenance area.

If you have any further questions, please contact us.

4 Very truly yours, f ^--

1 James P. O'Hanlon - 'I, Senior Vice President - Nuclear Q k- qV l Attachment 9701060279 970102 PDR ADOCK 05000338 G PDR

cc: U. S. Nuclear Regulatory Commission i Region ll 101 Marietta Street, N.W. .

Suite 2906 J-Atlanta, Georgia 30323

. Mr. R. D. McWhorter  !

NRC Senior Resident inspector  !

North Anna Power Station t N v D

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REPLY TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-336196-10 AND 50-339/96-10 NRC COMMENT j During an NRC inspection conducted on September 22,1996 through November 2, 1996, violationc of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG 1600, the violations are listed below:

A. 10 CFR 61.56 (a)(3) requires that solid waste containing liquid for land disposal shall contain as little free standing and noncorrosive liquid as is reasonably achievable, but in no case shall the liquid exceed one percent

! of the volume.

Contrary to the above, Radioactive Waste Shipment No. 0596-5939 (96-0004), classified as, " Radioactive Material, LSA, n.o.s., 7," described as,

" solid oxides deposited on spent resin," and packaged in a poly High integrity Container was shipped to the Low-Level Radioactive Waste Disposal facility at Bamwell, South Carolina, on May 14,1996, containing liquid in excess of one percent of the total waste volume. The excess liquid was identified by a Chem-Nuclear Systems, Inc. operator on May 17,1996. (01014)

This is a Severity Level IV violation (Supplement IV).

4 B. 10 CFR 50.65(a)(1) requires, in part, that licensees shall monitor the performance or condition of Structures, Systems, or Components (SSCs) against licensee-established goals, in a manner sufficient to provide reasonable assurance that such SSCs within the scope of the rule are capable of fulfilling their intended functions. When the performance or

, condition of an SSC does not meet the established goals, appropriate corrective action shall be taken.10 CFR 50.65(a)(2) requires, in part, that monitoring as specified in paragraph (a)(1) is not required where it has been demonstrahd that the performance or condition of an SSC is being effectively controlled through the performance of appropriate preventive maintenance, such that the SSC remains capable of performing its intended function. Virginia Power Administrative Procedure VPAP-0815, Maintenance Rule Program, Revision 2, Section 6.1.4.a, implements these 10 CFR 50.65 requirements and states, in part, monitoring performance will be performed by evaluating SSCs against established

, criteria and performing a Category 1 or 2 Root Cause Evaluation (RCE) if functional failures are identified.

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Contrary to the above requirements, as of October 8,1996, an RCE had not been completed for several pump 1-CH-P-1A seal failures which occurred between February 11 and July 18,1996. Additionally, a failure of the instrument air system on August 1,1996, was determined to be a maintenance rule functional failure but no RCE was completed. Finally, corrective actions for an unmonitored release from the boron recovery system on September 10, 1996, failed to identify that plant level monitoring criteria had been exceeded. As a result, no RCE was performed following the release.

This is a Severity Level IV Violation (Supplement 1).

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I REPLY TO VIOLATION A

1. REASON FOR THE VIOLATION The most probable reason for the violation was the incomplete dewatering of the  ;

high integrity container (HIC) due to a malfunction of the dewatering leg.

The HIC, Serial Number L-487022-6, was dewatered on April 9,1996, in accordance with station operating procedures which are consistent with Chem-Nuclear's dewatering procedure FO-OP-023, Bead Resin / Activated Carbon Dewatering Procedure for CNSI 14-215 or Smaller Liners. At that time the total volume of free standing liquid was determined and documented to be less than one percent of the container volume. Thirty-five days elapsed from the time final dewatering was performed and the time the container was shipped. Three possible causes were evaluated: 1) the addition of media to the container after ,

final dewatering,2) delay time prior to shipping, and 3) malfunction of the HIC dewatering leg. Media additions were made to the container during the time period between the final dewatering and shipping. However, liquid was drained from the media prior to placing it in the HIC. Therefore, the most probable cause of the violation is a malfunction of the dewatering leg.

2. CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED Operations Procedure 0-OP-20.6, Dewatering Chem-Nuclear 14-215 or Smaller Liners Containing Bead Resin or Activated Carbon was revised to 1) test the j dewatering leg prior to use to ensure its integrity, 2) ensure the final dewatering i of the liner will occur within seven days of shipping, and if shipping has not I occurred within seven days of dewatering the container will be dewatered again,

3) limit the allowable liquid generated during the final dewatering pass from less than five gallons to less than two gallons, and 4) require installation of the l shipment liner lid once final dewatering is completed. j 1

A review of previous resin shipments since 1986 determined that there have I been no other instances identified where free standing liquid exceeded one i percent of the container volume.

The NRC Division of Low-Level Waste Management and Decommissioning and l the South Carolina Division of Radioactive Waste Management were notified by Virginia Electric and Power Company letter dated June 7,1996 of this event and associated corrective actions in accordance with Generic Letter 91-02, Reporting Mishaps involving LLW Forms Prepared For Disposal.  !

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3. CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS No further corrective actions are required.

4. THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance has been achieved.

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B_EPLY TO VIOLATION B

1. REASON FOR THE VIOLATION The reason for the violation was personnel failing to implement the requirements of Virginia Power Administrative Procedure VPAP-0815, Maintenance Rule Program. Specifically. personnel were not attentive in identifying maintenance rule functional failures, performing maintenance preventable functional failure determinations, and ensuring root cause evaluations were completed. A contributing cause was an overall program weakness in Maintenance Rule Program implementation, including insufficient training for personnel performing deviation report screenings.

The inspection report indicated that the time fr le for completing root cause ,

evaluations (RCE) for the identified discrepanc.as was not timely. The time frame for completing Category 1 root cause evaluations is addressed in the l Virginia Power Root Cause Program Manual. However, personnel did not I appropriately implement the Program's requirements. In addition, the time frame for completing Category 2 RCEs is not addressed in the Virginia Power Root Cause Program Manual.

2. CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS I ACHIEVED 1 A Category 2 RCE was completed for the failure of the instrument air system that occurred on August 1,1996.

i Additional personnel have been temporarily assigned to strengthen the implementation of the Maintenance Rule Program.

A Maintenance Rule Coordinator position has been filled. The Maintenance Rule i Coordinator is responsible for the day-to-day implementation of the Maintenance Rule at North Anna.

Personnel responsible for screening station deviation reports have received additional training to ensure maintenance rule functional failures and the need for root cause evaluations are appropriately identified.

Maintenance Rule Working Group meetings are being temporarily conducted on an increased frequency to expedite the review of maintenance rule functional failures and improve timeliness of maintenance rule evaluations. Following confirmed improvements in Maintenance Rule Program implementation, the frequency for Maintenance Rule Working Group meetings may be relaxed.

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Appropriate personnel have been coached on the current requirements of the Virginia Power Root Cause Program Manual for performing and documenting the timely completion of root cause evaluations.

VPAP-0815 was revised to address the completion of Category 1 root cause evaluations, i

3. CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER l VIOLATIONS l l

Root cause evaluations are being completed for the charging pump seal failures l and the unmonitored release from the boron recovery system. The results of the root cause evaluations will be reviewed by management and corrective actions will be implemented as appropriate. The root cause evaluations will be provided to the NRC Resident inspectors upon completion. 1 1

Key station personnel will obtain enhanced Maintenance Rule training to facilitate proper program implementation and reinforce program requirements. .

This will be completed by January 31,1997.

An independent assessment by a consultant with extensive experience in  ;

Maintenance Rule Program development and implementation was recently l performed to determine the effectiveness of the Maintenance Rule Program.

Upon issuance of the final assessment report, the results will be reviewed by management and corrective actions will be implemented to strengthen the Maintenance Rule Program. In addition, we will evaluate including a time frame for completing Category 2 RCEs in the Virginia Power Root Cause Program Manual. The NRC Resident inspectors will be advised of the assessment results and associated corrective action plans.

4. THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Root cause evaluations on the charging pump seal failures and the unmonitored release from the boron recovery system will be completed by February 14,1997.

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SijMMARY OF COMMITMENTS The following is a summary of commitments in response to the Notices of Violation in NRC Inspection Report Nos. 50-338/96-10 and 50-339/96-10.

Root cause evaluations are being completed for the charging pump seal failures and the unmonitored release from the boron recovery system. The results of the root cause evaluations will be reviewed by management and corrective actions will be implemented as appropriate. The root cause evaluations will be provided to the NRC Resident inspectors upon completion, j Roo* cause evaluations on the charging pump seal failures and the unmonitored release from the boron recovery system will be completed by February 14,1997.

Key station personnel will obtain enhanced Maintenance Rule training to facilitate proper program implementation and reinforce program requirements.

This will be completed by January 31,1997.

An independent assessment by a consultant with extensive experience in Maintenance Rule Program development and implementation was recently performed to determine the effectiveness of the Maintenance Rule Program. ,

Upon issuance of the final assessment report, the results will be reviewed by l management and corrective actions will be implemented to strengthen the j Maintenance Rule Program. In addition, we will evaluate including a time frame i for completing Category 2 RCEs in the Virginia Powar Root Cause Program 1 Manual. The NRC Resident inspectors will be advised of the assessment results and associated corrective action plans.

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