ML20205R910
| ML20205R910 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 03/31/1987 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| RTR-REGGD-01.097, RTR-REGGD-1.097 87-042A, 87-42A, GL-85-15, GL-86-15, IEIN-84-90, NUDOCS 8704060477 | |
| Download: ML20205R910 (6) | |
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VINGINIA ELecTHIC AND l'OWEN COMPANY Rica Moxx),VIHOINIA 20261 W.L.Srawaar vic= P===in==v March 31, 1987 10CFR2.201 Noctuan OPERATIONS United States Nuclear Regulatory Commission Serial No.
87-042A Attention: Document Control Desk N0/RMK:jmj Washington, D.C.
20555 Docket Nos.
50-338 50-339 License Nos.
NPF-4 NPF-7 Gentlemen:
VIRCINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNITS 1 AND 2 RESPONSE TO THE NOTICE OF VIOLATION NRC INSPECTION REPORT NOS. 50-338/86-28 AND 50-339/86-28 We have reviewed your letter of January 29, 1987 in reference to the inspection conducted at the North Anna Power Station between November 17, 1986 and January 11, 1987, and reported in Inspection Report Nos. 50-338/86-28 and 50-339/86-28. Our responses to violations A and B in the Notice of Violations were addressed in our letter dated March 2, 1987 (Serial No.87-042). The commitment to provide our response to violation C by March 31, 1987 was also documented in our March 2,1987 letter. Accordingly, our response to violation C is addressed in the attachment.
Very truly yours, C--
g W. L.
rt Attachments 8704060477 870331 PDR ADOCK 05000338 G
PDR b'T 1
cc:
U. S. Nuclear Regulatory Commission 101 Marietta Street, N.W.
Suite 2900 Atlanta, GA 30323 Mr. J. L. Caldwell NRC Senior Resident Inspector North Anna Power Station 4
I
I RESPONSE TO THE NOTICE OF VIOLATION ITEM REPORTED DURING THE NRC INSPECTION-CONDUCTED FROM NOVEMBER 17, 1986 TO JANUARY 11, 1987 INSPECTION REPORT NOS. 50-338/86-28 AND 50-339/86-28 NRC COD 9fENT C.
10 CFR 50, Appendix B, Section XVI, states the following:
"XVI Corrective Action - Measures shall be established to assure that conditions adverse to
- quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.
In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and correctiva action taken to preclude repetition.
The identification of the significant condition adverse to quality, the cause of the cond ion, and the corrective action taken shall be documented and reported to appropriate levels of management."
Contrary to the above, appropriate action was not taken by the licensee to ensure that safety related equipment in the Main Steam Valve House (MSVH) had the proper analysis for Environmental Qualification (EQ) until December 31, 1986, even though they had been notified of the potential for the problem by Westinghouse in June of 1984 and by the NRC in Inspection and Enforcement Information Notice (IEIN) 84-90, dated December 7,
1984.
The licensee's corporate engineering department performed an analysis in October of 1986 but appropriate actions were not taken until December 31, 1986.
This is a Severity Level V violation (Supplement 1) and applied to both units.
RESPONSE
1.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION The Company has actively pursued resolution of the issue of the effects of superheated steam on equipment since notification of a potential problem was received from Westinghouse in June, 1984. The activities carried out by the Company since that time are summarized below. A station Deviation Report was not initiated, however, until after the analysis of the impact of superheated steam on safety-related equipment had been completed.- We recognize that notwithstanding the efforts that were being made over the time period in question, a Deviatioa Report documenting this problem should have been generated earlier than December, 1986.
Accordingly, the violation is admitted.
l 2.
REASON FOR THE VIOLATION A thorough review has been conducted of the activities carried out by the i
Company from the time that we were notified by Westinghouse of a potential equipment qualification concern (June, 1984). This review confirmed that evaluations of this concern and analyses of the consequences of subjecting certain equipment to a superheated steam environment, along with determinations of failure modes, effects, and available alternative equipment, were being performed and pursued during the period from June 1984 to the present.
Nevertheless, these activities were not being conducted within the structure of the established corrective action system.
Therefore, the root cause of this violation is that this concern was not entered into the corrective action system, and thereby brought to the attention of the appropriate levels of management, in a timely manner.
The following is a summary of the activities carried out to resolve this equipment qualification concern from the time that it was identified by Westinghouse. This summary also addresses the questions specified in Inspection Report 86-28 regarding the evaluations that were performed in 1984 and the reasons why it appears that the Company had not evaluated IE Information Notice (IEIN) 84-90 until October 1986.
Evaluations were conducted and documented by the Company soon after receipt of the Westinghouse notification, in June 1984, and IEIN 84-90, in December 1984, as required by established practices. Both evaluations concluded that the peak environmental temperature resulting from a Main Steam Line Break (MSLB) in the Main Steam Valve House (MSVH), including the effect of the release of superheated steam, would be bounded by the peak temperature to which equipment in the MSVH was qualified. The conclusions of both of these evaluations were later determined to be invalid, since the increase in the temperature of the superheated steam had not bee.. adequately taken into account. Following the issuance of the second evaluation, a decision was made to perform specific calculations using representative mass and energy release rates for the purpose of validating the conclusions of this second evaluation.
The results of these scoping calculations showed that the peak environmental temperature in the MSVH could exceed 450*F in the event of an MSLB in that location with superheated steam, well above the calculated peak temperature of 330*F, the value used for qualification of equipment in this zone.
At this point in time, July 1985, a station Deviation Report identifying this concern should have been initiated.
Initiation of a Deviation Report results in a condition adverse to quality, potential or actual, being entered into the station's corrective action system and therefore would have ensured that the subject condition would have been reported to the appropriate levels of management and that corrective actions would have been taken in a timely manner.
Instead, the Safety Analysis organization within the Nuclear Engineering Department initiated an analysis of the impact of a higher peak environmental temperature on safety-related equipment required to mitigate the consequences of an MSLB. This analysis included identification of safety-related equipment required to detect, isolate, and recover frem an MSLB outside the containment building.
This analysis also included a determination of the identified equipment's capability to perform its safety function under superheated steam environmental conditions. The results of this analysis, issued in October
1986, were then to be evaluated by the Design Control and Proj ect Engineering organizations also within the Nuclear Engineering Department for the purposes of determining the impact of the conclusions of the safety l
analysis on equipment operability, regulatory requirements, and initiating j
appropriate corrective actions, including the issuance of Deviation i
Reports, if found necessary.
I Due to oversight on the part of the Nuclear Operations Department and other high priority work in progress within the Design Control and Proj ect Engineering organizations, the safety analysis results were not subjected i
to a thornugh evaluation in a timely manner.
The appropriate Deviation Reports were finally initiated - one of which identified the lack of qualification for the solenoid valve associated with the turbine-driven auxiliary feedwater pump steam supply valve - in late December 1986, once the impact of the conclusions of the safety analysis on equipment operability was recognized.
3.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED Deviation Reports identifying the adverse condition that the existing environmental qualification of certain equipment in the MSVH was no longer valid, were initiated and reviewed by the station on December 31, 1986.
The solenoid valves described above were the only equipment listed on the qualification master list identified by the Deviation Reports for which operability was required by Technical Specifications. The other identified equipment was required to be qualified either by our commitments to NRC Regulatory Guide 1.97 or by determinations that the equipment was within the scope of 10CFR50.49.
In accordance with the guidance provided by NRC Generic Letters 85-15 and 86-15, the solenoid valves and the associated turbine-driven auxiliary feedwater pumps for both Units were declared inoperable and alternate indication was identified for the remaining affected post-accident equipment on December 31, 1986.
A Justification for Continued Operation for the solenoid valves was prepared, reviewed, and approved within the time allowed by Technical Specifications.
4.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS The criteria for the initiation of a Deviation Report, covering the identification of potential and actual conditions adverse to quality, will be clarified to the Engineering organizations. The criteria will also be re-emphasized to station and corporate Nuclear Operations Department personnel.
These activities will be completed by July 1,
1987.
Furthermore, the Engineering Department procedure for evaluating NRC Information Notices, vendor notifications, and other pertinent operating information has been revised, and a formal operating experience review program has been established within the Nuclear Operations Department, since the issuance of IEIN 84-90.
Within the Engineering Department, the Nuclear Engineering Department organization is now responsible for the coordination of evaluations of this type of information with respect to on-going and future design work.
Evaluation of this type of information with respect to operating systems is the responsibility of the Nuclear Operations Department, with evaluations turned over to the Engineering
- .i..J Department on an as-needed basis. The Nuclear Engineering organization is then responsible for coordinating these eraluations, including the identification of any potential' adverse impact on operating _ systems.
In this way the timeliness of the identification of conditions adverse to quality should be enhanced.
5.
MTE MIEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance will be achieved by July 1, 1987.
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