ML20127J625

Responds to NRC Re Violations Noted in Insp Repts 50-338/84-44 & 50-339/84-44.Corrective Actions:Charging Pump B Restored to Standby Condition by Clearing Lockout & Personnel Reinstructed in Responsibilities

ML20127J625
Person / Time
Site:	North Anna
Issue date:	03/12/1985
From:	Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	Grace N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20127J603	List: IR 05000338/1984044 ML20127J600 ML20127J625 ML20127J640 ML20127J653
References
85-119, NUDOCS 8505210530
Download: ML20127J625 (5)

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, \*kel'resklent Itut OficeEkm2tS666 bWhwCperations 0;wjarmsRirerl%ua s Rkinnorut tirginkt23261 a h 2 k9 weomuroeven Dr. J. Nelson Grace Serial No.85-119 Regional Administrator N0/sbe Region II Docket Nos. 50-338 U. S. Nuclear Regulatory Commission 50-339 101 Marietta Street, Suite 2900 License Nos. NPF-4

-Atlanta, Georgia 30323 NPF-7

Dear Dr. Grace:

We have reviewed your letter of February 11, 1985, in reference to the inspection conducted at North Anna Power Station conducted from December 6 to January 5, 1985 and reported in IE Inspection Report 50-338/84-44 and 50-339/84-44. Our responses to the violations are addressed in the attachment. -

We have determined that no proprietary information is contained in the report. Accordingly, Virginia Power has no objection to this inspection report 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,

(

W. L. Stewart

Attachment cc

Mr. Roger D. Walker, Acting Director Division of Reactor Projects Mr. James R. Miller, Chief Operating Reactors Branch No. 3 Division of Licensing Mr. M. W. Branch NRC Resident Inspector North Anna Power Station 8505210530 850408 PDR ADOCK 05000338 G PDR L 1

l RESPONSE TO NOTICE OF VIOLATION ITEM REPORTED DURING NRC INSPECTION CONDUCTED FROM DECEMBER 6 TO JANUARY 5, 1985 REPORT 50-338/84-44 AND 50-339/84-44 NRC COMMENT:

1. Technical Specification'6.8.1 requires that written procedures be established, implemented and maintained to control safety-related activities. Annunciator Response Procedure 1-AR-3 specifies the necessary actions to respond to panel IC main control board annunciator A-8 (Charging Pump 1B 15J6 lockout).

North Anna Power Station Administrative Procedure (ADM 19.3),

" Shift Conduct" outlines the minimum turnover to be performed by the shift supervisor and control room operator.

Contrary to the above, during the December 4-5 timeframe, the annunciator response procedure and shift turnover procedure were not followed when the alarm was received, resulting in the continued lockout of IB charging pump; thus reducing to one the number of operable charging pumps for the unit.

This is a Severity Level IV violation and applies to North Anna Unit 1.

RESPONSE

1. ADMISSION OR DENIAL OF THE ALLEGED VIOLATION This violation is correct as stated.

2. REASON FOR THE VIOLATION c

This violation was due to personnel error, in that, the conditions

- affecting the availability of the charging pumps were not closely monitored. Testing subsequent to the maintenance on C charging pump caused the lockout of the B charging pump. The lockout condition should have been cleared by placing the control switch in " pull' to lock" and then returning the switch to the " auto after stop" position. Testing of the C charging pump with its normal power supply breaker would have prevented the B pump lockout. This lockout condition is alarmed by an annunciator and it remained in this condition for at least three operating shift turnovers contrary to the established turnover procedure.

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.3. CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED The B ' charging pump was restored to " standby" condition by clearing the lockout. In the event of an ESF actuation that would have required the auto-start of the pump, the Operator would have determined the failure to start by the procedure verification

. checklist and would have responded by the above actions.

The operating shift personnel and others involved in this event were reinstructed in their responsibilities to respond to all unusual conditions in.the plant and to maintain a-clear understanding of plant conditions at all times.

In addition, this event was discussed with the operating shift personnel with special emphasis on the response to annunciator alarms.

4. CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS No further corrective actions are required for this event. A similar ,

event,'in regard to the responsiveness of the Operators to lighted

. annunciators, was reported in Inspection Report 50-338/84-38 and 50-339/84-38. In this event, the casing cooling tank level annunciator was thought to be invalid. In response to this

! occurrence,. an action. plan to reduce the number of lighted annunciators was implemented and is still in progress. This action was taken to eliminate nuisance alarms and to increase the

, sensitivity of the Operators to remaining annunciators.

5. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED

. No further corrective actions are required.

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NRC COMMENT:

2. North Anna Power Station, Unit 2 Facility Operating License NPF-7, dated August 21, 1980, condition 2.c. (5) requires, " Prior to operating the facility at a power leveh above 25 percent, VEPC0 shall develop a surveillance program for fiberglass spray pond piping and supports that is in compliance with the regulatory position in Revision 2 of Regulatory Guide 1.72, or an alternative position acceptable to the Commission."

The regulatory position in Revision 2 of Regulatory Guide 1.72 specifies a yearly inspection frequency for fiberglass piping without an' exterior weather resistant coating.

Contrary to the above, the North Anna spray pond piping, which does not have a special weather-resistant coating, was being inspected on a frequency less than annual.

This is a Severity Level IV violation and applies to North Anna Unit 2

RESPONSE

,1. ADMISSION OR DENIAL OF THE ALLEGED VIOLATION This violation is not correct as stated. The program for the surveillance of the fiberglass piping was appropriate since the originally installed piping was provided with a weather ,

resistant coating. As such, the conditions of the license for this program were met. However, during the investigation of this event, it was determined a small percentage of the original piping was replaced with non-weather resistant coated piping.

Since this was not known at the time of the replacements, the periodic surveillance frequency was not adjusted as appropriate.

2. REASON FOR THE VIOLATION The cause of the change in the treatment of the replacement piping is still under-investigation but is believed to be due to a change in the vendors manufacturing process.

3. CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED The surveillance frequency will be adjusted to annually until the results of the investigation are complete.

4. CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID TO FURTHER VIOLATIONS:

No further corrective actions are required until the results of the further investigation are evaluated.

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5. DATE WHEN FULL. COMPLIANCE WILL BE ACHIEVED  !

The periodic test requiring surveillance of the piping will be revised by_ May 15, 1985 which is prior to the next scheduled inspection.

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