ML20004C179

Responds to NRC Re Violations Noted in IE Insp Repts 50-338/81-05 & 50-339/81-03.Corrective Actions: Instituted Administrative Procedure Requiring Review of Flux Traces Once Per Shift & Will Review Setpoint Changes

ML20004C179
Person / Time
Site:	North Anna
Issue date:	05/05/1981
From:	Sylvia B VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20004C175	List: IR 05000338/1981005 ML20004C174 ML20004C179 ML20004C180 ML20004C183
References
255, NUDOCS 8106010688
Download: ML20004C179 (6)

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VIRGINIA Ez.ECTRIC AND OWE P, h0XPANT O

Rtcunown Vxmornu,20261 May 5,31 MAY 8AiG : 30 1981 Mr. James P. O'Reilly, Director Serial No. 255 Office of Inspection and Enforcement N0/RMT:ss U. S. Nuclear Regulatory Commission Docket Nos. 50-338 Region II 50-339 101 Marietta Street, Suite 3100 License Nos. NPF-4 Atlanta, Georgin 30303 NPF-7

Dear Mr. O'Reilly:

We have reviewed your letter of April 10, 1981 in reference to the inspection conducted at North Anna Power Station between February 1 - March 5,1981, and reported in IE Inspection Report Nos. 50-338/81-05 and 50-339/81-03.

Our responses to the specific infractions are attached.

We have determined that no proprietary information is contained in the reports.

Accordingly, the Virginia Electric and Power Company has no objec-tion to these inspection reports being made a matter of public disclosure.

The information contained in the attached pages is true and accurate to the best of my knowledge and belief.

Very truly yours, RY/ '

B. R. 'Sylvi 4 Manager - NucJear Operations and M,.ntenance Attachment City of Richmond Commonwealth of Virginia q

Acknowledged before me this 6 day of M W 19 2 '

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My Commission exp;res:

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Mr. Robert A. Clark, Chief Operating Reactors Branch No. 3 l

Division of Licensing i

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P Attachment Page 1 i

RESPONSE TO NOTICE OF VIOLATION ITEM REPORTED DURING NRC INSPECTION CONDUCTED FROM FEBRUARY 1 THROUGH MARCH 5, 1981 NRC COMMENT a

A.

10 CFR 50, Appendix B, Criterion XVI and Virginia Electric and Power Quality Assurance Program Company's (Vepco) approved Tcpical Report Operations Phase, Section 17.2.16, requires measures to assure that the cause of a significant condition adverse to quality is determined and corrective action taken to preclude eucurrence.

A significant condition adverse to quality was identified and reported to the Nuclear Regulatory Commission (NRC) on January 11, 1979 concerning the failure of the Axial Power Distribution Monitoring System (APDMS) to subtract the background detector current signal from the measured flux signal.

Vepco letters to the NRC dated February 16 and 27, 1979 stated that an administrative procedure requiring the reactor operator to review flux traces in order to characterize detector background levels was in use on Unit 1 and would be established on Unit 2.

Contrary to the above, measures established to ensure corrective action for identified deficiencies were ineffective in that:

1.

A Unit 2 flux map, N2-126, obtained October 31, 1980, indicated abnormally high background detector levels and was not identified by the plant staff to preclude detector input to the APDMS.

2.

Station procellure did not specify detector background level limits or require any review of.the data until identified by the inspector during December 1980.

This is a Severity Level V Violation (Supplement I.E.) and applicable to l

Units 1 and 2.

Similar items were identified to you in our correspondence transmitting Inspection Report Nos.

50-338/80-41, 50-339/80-38 and 50-338/80-38.

RESPONSE

1.

ADMISSION OR DENIAL OF THE ALI.EGED VIOLATION The Notice of Violation is correct as stated.

2.

REASON FOR THE VIOLATION This violation was the result of administrative errors.

The origin-al constitment, made on February 16 and 27,1979, were not entered in a formal Commitment Tracking Program.

As a result, the assignment and subsequent tracking of this commitment at the station level were not accomplished. When the same item was identified as an open ites, it was placed in the tracking system on February 24, 1981; e

however, the computer printout did not specify a completion require-ment date.

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s' Attachment Page 2 2.

REASON FOR THE VIOLATION (Continued)

Although a records search failed to demonstrate compliance with the commitment to generate a procedure which described the requirements to monitor detector background levels, the intent of the commitment has been met.

There exists evidence to show that Operations and Engineering personnel were reviewing flux traces for detector back-ground and that there existed an awareness of the issue since it

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l 3.

CORRECTIVE STEPS AND RESULTS ACHIEVED l

On April 24, 1981 an administrative procedure requiring a review of l - - - ' -- -

flux traces at least once per shift was approved by the Station Nuclear Safety and Operating Committee.

This procedure will be used to ensure that detector background levels are below acceptable values during periods when the APDMS is in service.

This action j

constitutes compliance with original commitments.

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4.

CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS In the last 6 months substantial improvements in the Commitment Tracking Program have been made.

Future changes are planned which l

should substantially improve commitment tracking and timely l

compliance with commitments.

5.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED l

Full compliance has been achieved with regard to the detector back-ground issue.

Proposed changes to the Commitment Tracking Program will be implemented by January 1, 1982.

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i Attachment Page 3 RESPONSE TO NOTICE OF VIOLATION ITEM REPORTED DURING NRC INSPECTION CONDUCTED FROM FEBRUARY 1 THROUGH MARCH 5, 1981 NRC COMMENT B.

10 CFR 50, Appendix B, Criterion V and Vepco approved Topical Report Operations Phase, Section 17.2.5, requires Quality Assurance Program that activities affecting quality shall be prescribed by documented procedures appropriate to the circumstances and shall be accoarplished in accordance with these procedures.

Nuclear Power Station Quality Assur-ance Manual Section 6 and Engineering Administrative Procedures 1 and 2 specify processing of the Setpoint Change Request Form to insure proper review, subsequent change of engineering documents, and document reten-tion in the records vault.

Contrary to the above, review of 33 Setpoint Change Request Forms for the period February 1978 to February 1980 determined that none were filed in the records vault, three were net reviewed for document revision and nine were not reflected on the appropriate engineering documents.

This is a Severity Level V Violation (Supplement I.E.) and applicable to Units 1 and 2.

RESPONSE

1.

ADMISSION OR DENIAL OF THE ALLEGED VIOLATION The Notice of Violation is correct as stated,.

2.

REASON FOR THE VIOLATION This violation is the result of improper procedural control.

The existing requirements of the Nuclear Power Station Quality Assurance Manual (N.P.S.Q.A.M.) apply only to setpoints identified in the Westinghouse Precautions, Limitations and Setpoint Document.

The majority of the station setpoints do not appear in this listing.

In addition, an Engineering Administrative Procedure had been deve-loped to control the setpoint change review process without incorporating all of the requirements of the N.P.S.Q.A.M.

3.

CORRECTIVE STEPS TAIGN AND RESULTS ACHIEVED When notified of this infraction, a review of all contpleted setpoint changes was initiated.

This review will include the safety relate-edness of the change, the need for an Engineering Safety Analysis, a Controlled Document Review and Revision based on the safety related changes, and the establishment of a permanent (lifetime) record file in the records vault.

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i Attcchment Page 4 4.

CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS When the corrective actions described above are completed, a program for the control of setpoint changes will be developed to comply with the intent of 10 CFR 50 Appendix B Criterion V and the Vepco Topical Report Section 17.2.5.

A request to change Section 6 of the N.P.S.

Q.A.M.

will be submitted.

In addition, a Station Administrative Procedure will be written to address the processing of station set-point changes.

This procedure will be approved by the Station Nuclear Safety and Operating Committee and will be used to satisfy the requirements (10 CFR 10, Appendix B, Criterion V) that "activi-ties affecting quality shall be prescribed by documented instruc-tions, procedures,

." until the change to N.P.S.Q. A.M. becomes effective.

5.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Request to change Section 6 of N.P.S.Q. A.M.

will be submitted by July 1, 1981.

The administrative procedure detailing the require-ments for processing setpoint changes will be approved by SNSOC by July 1, 1981.

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RESPONSE TO NOTICE OF VIOLATION ITEM REPORTED DURING NRC INSPECTION CONDUCTED FROM FEBRUARY 1 THROUGH MARCH 5, 1981 NRC COMMENT C.

10 CFR 50.59 requires that records of changes to the facility described in the safety analysis report include a written safety evaluation which provides the basis for the determination that the change does not involve an unreviewed safety question.

Contrary to the above, of thirteen setpoint changes requiring safety evaluations reviewed for the period February 1978 to February 1980, eleven were not accompanied by a safety evaluation.

Additionally, the Nuclear Power Station Quality Assurance Manual, Section 6,

which prescribes the methods and requirements for making changes to setpoints of safety related instrumentation and controllers, did not specify that a safety evaluation be completed.

This is a Severity Level V Violation (Supplement I.E.) and applicable to Units 1 and 2.

RESPONSE

1.

ADMISSION OR DENIAL OF THE ALLEGED VIOLATION The Notice of Violation is correct as stated.

2.

REASON FOR THE VIOLATION This violation was the result of improper procedural control.

3.

CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED As described in the Vepco response to violation 81-05-08 and 81-03-07, the completed setpoint changes are being reviewed and, if required, a safety evaluation will be completed.

4.

CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS Setpoint changes that have not yet been completed will be processed in accordance with the revised program.

This program will require safety evaluations for safety related setpoint changes.

5.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED All future setpoint changes that are classified as being safety related will have a safety evaluation performed as required by 10 CFR 50.59.

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