ML20071K852

Responds to NRC Re Violations Noted in IE Insp Repts 50-338/83-01 & 50-339/83-01.Corrective Actions: Equipment Failure Trend Analysis Program Will Be Described, Implemented & Controlled by Administrative Procedure

ML20071K852
Person / Time
Site:	North Anna
Issue date:	03/17/1983
From:	Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20071K807	List: ML20071K852 ML20071K888
References
071, 71, NUDOCS 8305270407
Download: ML20071K852 (4)

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-t pC/t' VINGINIA ELECTHIC AND POWEN'(l**(5dMPANY 7; l J

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• Vics Passionzr NuctaAm oes:marrowns Mr. James P. O'Reilly Serial No. 071 Regional Administrator N0/RMT:acm Region II Docket Nos. 50-338 U. S. Nuclear Regulatory Commisaion 50-339 101 tbrietta Street, Suite 3100 License Nos. NPF-4 Atlanta, Georgia 30303 NPF-7

Dear Mr. O'Reilly:

We have reviewed your letter of February 4, 1983 in reference -to the inspection conducted at North Anna Power Station between January 3, 1983 and January 7, 1983 and reported in IE Inspection Report Nos. 50-338/83-01 and 50-339/83-01. 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 objection 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, f

Y. V-W. L. Stewart Attachment cc: Mr. Robert A. Clark, Chief Operating Reactors Branch No. 3 Division of Licensing 8305270407 830407 PDR ADOCK 05000330 PM Q

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Attachm;nt Pega 1 Serial No. 071 RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-338/83-01 AND 50-339/83-01 A. NRC COMMENT:

10 CFR 50, Appendix B, Criterion XVI, and the accepted QA Program (VEP-1-3A)

Section 17.2.16, require establishing measures to assure that ' conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances shall be evaluated. The accepted QA Program Table 17.2.0 endorses ANSI N18.7-1972. Section 5.1.6.1 of this standard states that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective materials and equipment shall be evaluated. Experience with failed equipment and similar components shall be reviewed to determine whether a replacement component of the same type can be expected to perform its function reliably.

Contrary to the above, a defined program has not been established to require evaluating equipment failures and conducting reviews to determine whether replacement components of the same type can be expected to function reliably.

This is a Severity Level IV Violation (Supplement I).

RESPONSE

(1) ADMISSION OR DENIAL OF THE ALLEGED VIOLATION:

The Notice of Violation is correct as stated.

(2) REASONS FOR VIOLATION:

A trending program was originally scheduled for implementation in late 1982. The scope of the original proj ect changed as it was being developed from a Nuclear Operations Department project to a Power Operations proj ect (Nuclear / Fossil / Hydro). The proj ect , known as the Work Planning and Tracking System (WPTS), will involve many applications.

The initial application will provide, as a minimum, inquiry into the computer's data base showing maintenance history for a specified system, component, or item. The maintenance histories will be used by station personnel to evaluate equipment failures and perform equipment trend analyses. The initial application is currently scheduled to be installed no later than the end of the first quarter of 1984.

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Attachm:nt Pcgn 2 Serial No. 071 (3) CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:_

Currently, failures and recurrent failures are reported using Maintenance Reports (MRs), Deviation Reports (DRs), and Engineering Work Requests (EWRs). Frequently problems reported via MRs, DRs and EWRs result in equipment failure evaluations and reviews to determine whether

. replacement components of the same type can be expected to function reliably. A more systematic approach to equipment failure trending will be possible when the initial application of the WPTS is implemented at North Anna.

(4) CORRECTIVE STEPS WHICH WILL BE TAKEN 'O AVOID FURTHER VIOLATIONS:

After the initial application of the WPIS is implemented at North Anna, a program to use WPTS for equipment failure trend analysis will be implemented. The equipment ~ failure trend analysis program will be implemented, described, and controlled by an Administrative Procedure.

A Nuclear Plant Reliability Data System (NPRDS) group has recently been formed. Under current plans, WPTS and NPRDS will be linked for information sharing. NPRDS information will be very useful when performing equipment evaluations and reviews.

(5) THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

The implementation of the first application of WPTS is scheduled for the first quarter of 1984. An equipment failure trend analysis program will be in place within 3 months of WPTS installation. The scope (number of components trended) will grow as the data base grows.

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.Paga 3 Serial No. 071 RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-338/83-01 AND 50-339/83-01 B. NRC COMMENT:

Technical Specification 6.5.3.1.c requires the Quality Assurance (QA)

Department to audit. the results of actions taken to . correct deficiencies occurring in facility equipment, structures, systems, or methods of operation that affect nuclear safety at least once per six months.

Contrary to the above, the QA Department completed an audit of actions taken to correct deficiencies December 1,1981. This audit was not performed again

, until December 1982.

This is a Severity Level IV Violation (Supplement I).

RESPONSE

(1) ADMISSION OR DENIAL OF THE ALLEGED VIOLATION:

The notice of violation is correct as stated.

4 (2) REASONS FOR VIOLATION:

The reason that Audit N82-04 was not completed in a timely manner was an administrative error. The audit was properly scheduled but its completion was overlooked because the responsibic personnel had been shifted to other activities. This delay was not recognized until the next scheduled audit of the area in question.

1 (3) CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:

The Audit in question N82-04 was finally completed during the week of December 27, 1982.

The fact the Audit N82-04 had not been completed as required was reported on Audit N82-12 and documented in deviation report (82-746) dated November 30, 1982. No other corrective actions are required.

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

In the future the appropriate number of auditors will be assigned as needed to assure audits are completed in a timely manner.

(5) THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

Full compliance has been achieved. -

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