ML20141L021

Responds to NRC Re Violations Noted in Insp Repts 50-338/97-02 & 50-339/97-02.Corrective Actions:Adjusted Reactor Coolant Pump 1 Seal Leakoff Chart Recorders & Implemented General Operating Procedure 0-GOP-7

ML20141L021
Person / Time
Site:	North Anna
Issue date:	05/23/1997
From:	Ohanlon J VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-338-97-02, 50-338-97-2, 50-339-97-02, 50-339-97-2, 97-300, NUDOCS 9706020249
Download: ML20141L021 (5)

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', YlltGINI A Eircruic ANI Powen Co.sieANv RicissioNin, VIHGINI A 23261 May 23, 1997 U. S. Nuclear Regulatory Commission Serial No.97-300 Attention: Document Control Desk NAPS /MPW/ETS R3 Washington, D. C. 20555 Docket Nos. 50-338 50-339 License Nos. NPF-4 NPF-7 Gentlemen:

VIRGINlA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNITS 1 AND 2 INSPECTION REPORT NOS. 50-338/97-02 AND 50-339/97-02 REPLY TO THE NOTICE OF VIOLATION We have reviewed your letter of May 5,1997, which referred to the inspection conducted at North Anna Power Station from February 23,1997 through April 5,1997, and the associated Notice of Violation which was reported in Inspection Report Nos.

50-338/97-02 and 50-339/97-02. Our reply to the Notice of Violation is attached.

Each chart recorder in question has an indicator and/or redundant instruments which provide parameter indication for operational control. The charts are used for historical record and furthermore, are not required by Technical Specifications. Based on the limited regulatory and safety significance of the issue, it is requested that the Notice of j

Violation be reconsidered for categorization as a Non-Cited Violation. We believe that this issue meets the requirements in the NRC Enforcement Manual for categorization as a Non-Cited Violation.

No new commitments are intended as a result of this letter. If you have any further questions, please contact us.

Very truly yours, Om James P. O'Hanlon i Senior Vice President - Nuclear wg { g Attachment e000G4

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9706020249 970523 **

PDR ADOCK 05000338 G PDR

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cc: U. S. Nuclear Regulatory Commission l Region ll Atlanta Federal Center 61 Forsyth St., SW, Suite 23T85 Atlanta, Georgia 30303 Mr. M. Morgan NRC Senior Resident Inspector North Anna Power Station i

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4 REPLY TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-338/97-02 AND 50-339/97-03

[ NRC COMMENT i

During an NRC inspection conducted on February 23,1997 through April 6,1997, a violation of NRC requirements was identified. in accordance with the " General 1

Statement of Policy and Procedures for NRC Enforcement Actions," NUREG 1600, the 4

violation is listed below:

i l Technical Specification 6.8.1 requires written procedures to be  !

i established, implemented and maintained covering the activities i i

recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Regulatory Guide 1.33, item 1.a references procedures l for operator log-keeping.

4 Procedures 1 and 2-GOP-1.0, Unit 1 and 2 CRO Turnover Checklist, Revision 12 and 11, respectively state, " Verify proper operation of the i i control board recorders by verifying that the recorder is rotating, inking properly, and that the chart paper is the proper scale. IF NOT. THEN take

. corrective action."

0-OPAP 0004, Logs and Operating Records, Revision 5, Paragraph 6.7, states in part, that " Recorder charts shall be checked to ensure they are operational."

Contrary to the above, on March 28,1997, operators had not correctly verified that the Units 1 and 2 Reactor Coolant Pumps' Number 1 Seal Leakoffs and the Unit 2 NR 46 Nuclear Power Range chart recorders were operational. For several days, operators had initialed the chart recorders without identifying that the recorders were not inking properly.

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

REPLY TO NOTICE OF VIOLATION

1. REASON FOR THE VIOLATION The reason for the violation was a failure to place adequate emphasis on proper chart recorder inking. The chart recorders are primarily used for a historical record and are not used nor required for operational control. The control room operators were relying on redundant indication for these parameters. It should be noted that although the pens were not inking, each recorder has an indicator that was functioning properly.

There are two chart recorders, per unit, associated with the reactor coolant pumps number 1 seal leakoff (i.e. narrow and wide range). The narrow range recorders, were not inking properly since the pens were off scale. This is an expected condition for the narrow range indicators when the plant is at norma: I operating pressure. With the pens off scale, their siphon capability was lost as a result of riding over the chart paper drive holes. Primary indication is obtained from the wide range indicators during normal operating conditions. The wide range indicators were operating / inking properly during this time.

Each chart recorder for overpower range indication has 2 different color pens inking on the same chart paper. When the unit is at 100 percent power, as was the case, the pens ink virtually on tcp of each other. At first glance the chart recorder would appear to be functioning properly with one pen not inking. Again, the control room operators reiy on the ca!!brated instruments on the bench board and vertical boards to provide parameter indication for operational control. As such, the safety significance associated with the chart recorders not inking properly is extremely low.

2. CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED Upon identification of the deficiency, a station deviation report was initiated.

The reactor coolant pump number 1 seal leakoff chart recorders identified in the Notice of Violation have been adjusted to limit the upscale travel of the pens.

The narrow range recorder pen was re-primed and proper operation resumed.

General Operating Procedure 0-GOP-7, Daily Check of Control Room Chart Recorders was implemented to perform a daily verification that all control room control room chart recorders in service are working properly.

Operators were coached on the operability of control room chart recorders and procedure compliance.

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