IR 05000338/1997006

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-338/97-06 & 50-339/97-06.Concluded That Representation of Examples 3 & 4,accurate as Stated in NOV

ML20202C872
Person / Time
Site:	North Anna
Issue date:	11/18/1997
From:	Jerrica Johnson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Ohanlon J VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
References
50-338-97-06, 50-338-97-6, 50-339-97-06, 50-339-97-6, NUDOCS 9712040087
Download: ML20202C872 (7)

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November 18, 1997

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! Virginia 1 Electric and Power Company-ATTN: Mr. J. P, O'Hanlon-Senior-Vice President - Nuclear

.Innsbrook Technical Center 5000 Dominion Boulevard-Glen Allen, VA 23060 SUBJECT: - NRC'I;i5FELTION REPORT NOS. 50-338/97-06 AND 50-339/97-06

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Dear Mr. O'Hanlon:

Thank you _for your response of October 1,1997, to ot< ( tice of Violation, issued on September 5,1997, concerning activities corm ted at your North Anna facility. In your response to the Notice of Violation (Notice), you c stated that you believed that the representation of Examples 3 and 4 did not accurately characterize the identified non-compliance.

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After careful consideration of the basis for your statement, we have F concluded, for the reasons presented in the enclosure to this letter that the i representation of Examples 3 and 4 was accurate as stated in the Notice. We recognize that under the specific circumstances, these individual examples are not significant. However, several additional examples of failure to effectively implement your requirements for procedural compliance were

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i_ identifled in the Notice and during a subsequent NRC inspection at North Anna.

Collectively we believe these examples indicated that various members of your p staff lack an adequate understanding of your procedural compliance

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requirements, specifically during plant testing evolutions.

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0n-November 13, 1997, _Mr. Robert Haag of my staff had a telephone conversation with Mr. David Heacock of your staff to further discuss the ::ited violation and additional actions you plan to take regarding procedural compliance.

Based on'this conversation it is our understanding that Maintenance Department

' Administrative Procedure M0AP-0019 " Maintenance Procedure Usage " will be

revised to further clarify _ management's expectations on verbatim procedural

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compliance and to provide additional guidance when taking credit for previously performed work. No additional response to this letter is required based on the actions stated-in the above noted telephone conversation.and the corrective actions-stated for the other examples in the Notice. These combined actions are sufficient for. examples 3 and 4.

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9712040087 971118 PDR- ADOCK 05000338-G PDR ,

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• We will examine the implementation of-your-actions to correct-the violation-during future inspections.

We appreciate your. cooperation in this matter.

Sincerely

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Orig signed by Loren n11sco for Jon Johnson. Director Division of Reactor Prcjects Docket Nos. 5b 338, 50-339 License Nos. NPF-4, NPF-7 Enclosure: Evaluations and Conclusions cc w/ encl:

J. H. McCarthy, Manager Nuc'iear Licensing and Operations Support Virginia Electric & Power Company 5000 Dominion Boulevard G',en Allen, VA 23060 David A. Christian. Manager

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Surry Power Station Virginia Electric & Power Company 5570 Hog Island Road Surry, VA 23883 W. R. Matthews, Manager North Anna Power Station P. O. Box 402 Mineral. VA 23117 Executive Vice President Old Dominion Electric Cooperative 4201 Dominion Boulevard Glen Allen. VA 23060 County Administrator-Louisa County P. O. Box 160 Louisa. VA 23093

cc_w/ encl

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=cc w/ encl: Continued Virginia State Corporation Comission Division of Energy Regulation P. O. Box 1197 Richmond. VA 23209 Hichael W. Maupin Hunton and Williams Riverfront Plaza. East Tower 951 E. Byrd Street Richmond, VA 23219 State Health Comissioner Office of the Commissioner Virginia Department of Health P. O. Box 2448 Richmond, VA 23218 Attorney General Supreme Court Building 900 East Main Street Richmond, VA 23219 Distribution w/ encl:

N. K11yanam. NRR R. Gibbs. RII P. Fillion. RII R. Aiello. RII W. Stansberry RII A. Boland. RII D. Jones. RII PUBLIC NRC Resident Inspector U.S. Nuclear Regulatory Commission Surr, Nuclear Power Station 58bo Hog Island Road Surry. VA 23883 NRC Resident Inspector U.S. Nuclear Regulatory Commission 1024 Haley Drive Mineral. VA 23117

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EVALUATIONS AND CONCLUSIONS

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On September 5. 1997, a Notice of Violation (Notice) was-issued for a violation identified during a routine NRC inspection. Virginia _ Electric and Power Company (the licensee) responded to the Notice on October 1.1997. The licensee stated that two examples of the identified non-compliance were not accurately characterized. The NRC's evaluations and conclusions regarding the licensee's response are es i'ollows:

Restatement of the Violation .

During an NRC inspection conducted on June 22 through August 9.1997, a violation cf NRC requirements was identified. In accordance with the " General Statement of Policy and Procedures for NRC Enforcement Actions." NUREG-1600.

the violation is listed below:

Technical Specification 6.8.1.a requires that written procedures shall be established, implemented and maintained covering the applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33.

Revision 2. February 1978.

Regulatory Guide 1.33. " Quality Assurance Program Requirements (Operations)," Appendix "A". Paragraphs 1.c and 8.b require procedures for equipment control and surveillance tests, respectively.

Operations Department Administrative Procedure. OPAP-0010. " Tag-Outs."

Revision 8. Step 6.10.2.a requires the use of the appropriate procedure (e.g.. Maintenance Operating Procedure) in conjunction with the tagging record, as instructions to align components and remove equipment tags.

Unit 1 Periodic Test (PT) Procedure 1-PT-36.18. " Train B Reactor Protection and Engineered Safety Feature Logic Channel Functional Test."

Revis;on 19. Step 6.2.3.C.2. requires closure of the reactor trip bypass breaker compartment door before an ooerator reopens the door and racks the bypass breaker into the connect position in the following step.

Unit 1 Periodic Test Procedure.1-PT-32.3.5. " Steam Generator B Steam Flow / Feed Flow Protection IV Channel Functional Test." Revision 28.

Steps 6.1.5 and 6.1.8 require verification of the correct test switch positions prior to actual testing. Step 6.1.6 requires that the test cabinet door be opened before testing. Step 6.3.6 requires that the test switch cabinet door, which was opened in Step 6.1.6. is to be locked closed when testing is complete.

Unit 1 Periodic Test Procedure. 1-PT-32.3.6. " Steam Generator C Steam Flow / Feed Flow Protection IV Channel Functional Test." Revision 27.

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Steps 5.1.5 and 6.1.8 require verification of the correct test switch positions prior to actual testing. Step 6.1.6 requires that the test cabinet door be opened b2 fore testing.

Contrary to the above, equipment control and surveillance test procedures were not im91emented as evidenced by:

1. On July. 9.1997, while returning the Service Water System to service following maintenarce. the unit shift supervisor failed to use 0-H0P-49.14 with Tagging Record (N) 0-97-SW-0015 to align components and remove equipment tags.

2. On July 10. 1997, during performance of 1-PT-36.1B. the assigned electrician failed to perform Step 6.2.3.C.2.

3. On August 2, 1997, during performance of 1-PT-32.3.5. the instrument and control technicians failed to perform Steps 6.1.5.

6.1.6. 6.1.8. and 6.3.6.

4. On August 2.1997. during performance of 1-PT-32.3.6. the instrument and control technicians failed to perform Steps 6.1.5.

6.1.6. and 6.1.8.

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This is a Severity Level IV violation (Supplement I)

Summary of Licensee's Response to Violation (Examoles 3 and 4)

In the licensee's response they stated that the Notice of Violation (Examples 3 and 4) did not accurately characterize the identified noncompliance for failure to perform Steps 6.1.5. 6.1.6. and 6.1.8. These steps are found in 1-PT-32.3.5. " Steam Generator B Steam Flow and Feed Flow Protection Channel IV (F-MS-1485 and F-FW-1486) Channel Functional Test." and 1-PT-32.3.6. " Steam Generator C Steam Flow and Feed Flow Protection Channel IV (F-MS-1495 and F-FW-1496) Channel Functional Test.' The licensee believes that Steps 6.1.5.

6.1.6. and 6.1.8 were followed because the same steps were performed previously during the performance of 1-PT-32.3.4 " Steam Generator A Steam Flow and Feed Flow Protection Channel IV (F-MS-1475 and F-FW-1476) Channel Functional Test." Periodic Test 1-PT-32.3.4 was the first test in a series of tests which-included 1-PT-32.3.5 and 1-PT-32.3.6. The licensee contends that having successfully performed these steps in 1-PT-32.3.4 allows them to take credit for satisfactorily performing these steps in 1-PT-32.3.5 and 1-PT-32.3.6. The licensee's basis for their position is found in MDAP-0019.

" Maintenance Procedure Usage." Step 6.1.3.c which states. "If a procedure step states an action to be performed.-and the action was performed previously l.

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'l (e.g. , " Remove Test Rig" and the test rig was removed). then the step shall be verified to be completed and the step initialed."-

NRC Evaluation of Licensee's Resoonse i The NRC staff reviewed the licensee's response and has concluded tn# Steps 6.1.5. 6.1.6. and 6.1.8 should have been performed as. described in 1-P1 <2.3.5 and 1-PT-32.3.6 and remain as two examples of failure to follow approved written procedures; There are two bases for the NRC staff disagreeing with the licensee's position that credit can be taken for Steps 6.1.5. 6.1.6.'and i 6.1.8 since they had been performed earlier while completing 1-PT-32.3.4.

The first basis involves MDAP-0019. Step 6.1.3.c which requires that procedure steps shall be verified to be completed and initialed when taking credit for action that was previously performed. Steps 6.1.5 and 6.1.8 involved verification of plant switch positions. Step 6.1.5 used the action verb

" verify" and Step 6.1.8 used the action verb " ensure." The licensee's definition of verify is provided in VPAP-0213. " Abbreviations. Acronyms, and Action Verbs." Revision 2. Verify is defined as. "To observe that an expected characteristic or condition exists." Procedure VPAP-0213 did not define ensure. The inspectors were informed that the definition of ensure was being added to VPAP-0213 and would De similar to the verify definition in that an

- observation would be required. During performance of the steps in question

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the inspectors noted that no action was taken to observe the switch positions in Steps 6.1.5 and 6.1.8. The licensee improperly took credit for the verify and ensure actions of the switch positions which had been previously performed while implementing 1-PT-32.3.4. ,

Step 6.1.6 was an action step to open the door wnere the testing took place -'

and verify that an annunciator was received. The inspectors noted that the technician did not perform these actions. Since the door in question was at the panel were the technician was performing the PT. the NRC recognizes that )

- the technician could verify that the door was open by the fact that he was working at the panel and the door was open to allow this testing to occur.

However the technician took no action associated with the annunciator. The licensee contends that performing this step again was not necessary because of

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the procedural flexibility provided by MDAP-0019. Step 6.1.3.c and the fact-that this step had been completed satisfactorily while earlier performing 1-PT-32.3.4. As stated above. Step 6.1.3.c requires that the step shall be verified to be completed and the step initialed when taking credit for action that was previously completed. There was no verification that the annunciator was received.

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The second basis for disagreeing with the licensee's position that credit could be taken for Steps 6.1.5. 6.1.6 and 6.1.8. which had been previously performed involves Step 6.1.1 of MDAP-0019. This step requires that periodic

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test procedures shall be performed in a step-by-step manner with each step completed prior to the performance of the next step. Based on this requirement the NRC concluded that the procedural flexibility' provioed by MDAP-0019. Step 6.1.3.c. i.e. relying on previously performed work, is not applicable to pts. Therefore, the steps in question should have been completed in each of the periodic test procedures in the specified sequence.

NRC Conclusion The NRC staff concludes that failure to perform Steps 6.1.5. 6.1.6. and 6.1.8 in procedures 1-PT 32.3.5 and 1-PT-32.3.6 remain as examples of failure to follow approved written procedures and did accurately characterize the non-compliance.

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1 Enclosure