ML19327A838
| ML19327A838 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 10/10/1989 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 89-704, NUDOCS 8910180235 | |
| Download: ML19327A838 (3) | |
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. VIPMNIA ELECTRIC AND POWER COMPANY ,
RICHMoxo, VIRGINIA 23261 October 10, 1989
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U.S. Nuclear Regulatory Commission Serial No 89-704 i Attn: Document Control Desk NAPS /DEO 1 Washingtun, D.C. 20555 Docket No. 50 338 l 50 339 ;
License No. NPF 4 I NPF-7 Gentlemen: :
VIRGINIA ELECTRIC AND POWER COMPANY i NORTH ANNA POWER STATION UNITS 1 A'ND 2 I
INSPECTION REPORT NOS. 50438/89-26 AND 50-339/89 28 REPLY TO THE NOTICE OF VIOLATION We have reviewed your letter of September 21, 1989 which referred to the int.pection ,
conducted at North Anna on July 16,1989 through August 22,1989 and reported in Inspection Report Nos. 50 338/89 26 and 50 339/89 26. Our response to the Notice of Viol & tion is attached. I s
We have no objection to this correspondence being made matter of public record. If you !
have any further questions, please contact us. ;
Very truly yours,
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W. L. Stewa
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- Senior Vice President - Power ,
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Attachment
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E cc: U. S. Nuclear Regulatory Commission
~1 01 Manetta Street, N.W.
Suite 2000 Atlanta, Georgia 30323 Mr. J. L. Caldwell l NRC Senior Resident inspector North Anna Power Station
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RESPONSE TO THE NOTICES OF VIOLATION REPORTFD DURING THE NRC INSPECTION CONDUCTED ,
311 FEEN JULY 16. 1989 AND AUGUST 22. 1989 .
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INSPECTION REPORT NOS 50-338/89-26 AND 50 33')/89 26 NRC COMMENT During the Nuclear Regulatory Commission (NRC) inspection conducted on July 15 through August 22, a violation of NRC requirements was identified. In accordance with :
the " General Statement ot Policy and Procedures for NHC Enforcement Actions," 10 CFR Part 2, Appendix C (1989), the violation is listed below: -
Technical Specification 6.8.1.c requires written procedures be established, implemented, and maintained covering surveillance and test activities of safety related equipment.
Contrary to the above, surveillance procedures 2-PT 36.5.3A and 3B, "SSPS Output Slave Relay Trains A & B," performed on August 6 and 8,1989, was inadequate in that:
- 1. Proceduro 2 PT 36.5.3A did not correctiy detall the interlock conditions for energizatio of the K630 relay.
- 2. Procedure 2 PT-36.5.3A did not indicate that the casing cooling supply to the recirculation spray valve,2 RS MOV-201B, would close on energization of K645, -
K645XA, resulting in the valve closure, making the B train of the cuiside ,
recirculation spray system inoperable.
- 3. Procedures 2 PT-36.5.3A and 3B did not reset the Phase A signal generated by the K614 relay, resulting in the air ejector discharge to containment valves, SV-TV-20101 and 203 not properly opening on a Hi-Hi radiation signal generated during subsequent surveillance testing.
This is a Severity Level IV violation (Supplement I),
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s:rialNo 89 704 NAPS UNITS 1 AND 2
- , REPLY TO THE NOV IR NOs. s0-338&3390940 l
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" htESPONSE TO VIOLATION ;
- 1. ADMISSION OR DENIAL OF THE ALLEGED VIOLATION The violation is correct as stated with the exception of example 2. The closure of 2 RS MOV 201B did not render the B tra ' of the outside recirculation spray system Inoperable. Within the text of this inspec lon report example 2 (given as example b) is also incorrect in that the closure of 2 RS MOV-201B did not render a casing couting subsystem inoperable, and there' ore, did not meet the entry conditions for Technical Specification 3.0.3. However, Technical Specification 3.0.3 was initially entered because the Shift Supervisor was unaware of the fact that 2-RS MOV- 2 201B receives an " assure" open signal upon initiation of a containment I depressurization signal and thought that having the normally open casing cooling i supply valve, 2-RS MOV 201B, closed rendered the casing cooling subsystem inoperable. (See LEh N2 89 008 01 for addi'ional information).
- 2. REASON FOR THE VIOLATION
The root cause of the violation was procedure inadequacy. The August 6,1989 l events were caused by failure of the procedure to properly identify plant responses '
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to testing of slave relays. The August 8,1989 event was caused by failure of the procedure to state that the Phase A signal had to be reset. The step to reset the .
Phase A signal had inadvertently been omitted from the procedure during a previous revision. A contributing factor was that this was the first testing of selected !
ESF slave relays during on line operation. Validation of the procedure during off-line testing was performed to the extent possible. Due to the complexity of this testing, engineering and independent reviews alone were not adequate to detect the above deficiencies. ,
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- 3. CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED i
The blocking schemes for both the A and B train slave relays have been reviewed and no additional problems were identified for ESF slave relays tested during on-line operation. The Unit 1 and Unit 2 periodic tests 1(2) PT 36.5.3A and 2 PT-36.5.3B have been revised to correct the problems identified during the initial on-line testing on August 6,1989 and August 8,1989. .
- 4. CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOL ATIONS Additional actions are not required to avoid further violations. The corrective actions stated in Section 3 w;ll prevent recurrence of futurs violations.
- 5. THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance has been achieved.
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