ML20042H057

Responds to NRC 900413 Ltr Re Violations Noted in Insp Repts 50-338/90-04 & 50-339/90-04.Corrective Actions:Leak Test Procedures Will Be Reviewed & Revised to Specify Appropriate Test Boundaries & O-ring Obtained

ML20042H057
Person / Time
Site:	North Anna
Issue date:	05/11/1990
From:	Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
90-226, NUDOCS 9005170128
Download: ML20042H057 (7)

Text

{{#Wiki_filter:._. . _ _, VIRGINIA ELECTRIC AND power COMPANY RICHMOND, VIRGINIA 23261 , May 11, 1990 , U.S. Nuclear Regulatory Commission Serial No. 00 226 Attn: Document Control Desk NAPS /JHL/TAH > Washington, D.C. 20555 Docket Nos. 50-338 ' 50 339 , License Nos. NPF 4 NPF 7 Gentlemen: VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA POWER STATION UNITS 1 AND 2 ' INSPECTION REPORT NOS. 50 338/90 04 AND 50 339/90 04 ' RESPONSE TO THE NOTICES OF VIOLATION  ; We have reviewed your letter of April 13,1990 which refers to the inspection conducted at ' North Anna from February 17,1990 through March 16,1990 and reported in inspection Report Nos. 50 338 & 339/90-04. Our response to the Notices of Violation is attached. > Also, we reviewed and concur with the discussion in the inspection Report pertaining to q the interpretation of the Technical Specifications on A. C. Electrical Distribution. We are currently processing a license amendment changing Technical Specifications 3.8.2.1. This change willincrease the allowable time for an inverter to be out of service and will more closely conform to Standard Technical Specifications for Westinghouse Pressurized  ; Water Reactors.  ; We have no objection to this correspondence being made a matter of public record. If you have any further questions, please contact us. Very truly yours, , W. L. Stewart Senior Vice President - Nuclear , Attachment i cc: U. S. Nuclear Regulatory Commission 101 Marietta Street, N.W. Suite 2900 Atlanta, Georgia 30323  ; Mr. M. S. Lesser NRC Senior Resident inspe.Jor North Anna Power Station

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( . . . RESPONSE TO THE NOTICES OF VIOLATION fLEPORTED DURING THE NRC INSPECTION CONDUCTED BETWEEN FEBRUARY 17. 1990 AND MARCH 16. 1990 W INSPECTION REPORT NOS 50-338/90-04 AND- 50-339/90-04 NRC COMMENT Dunng the Nuclear Regulatory Commission (NRC) inspection conducted on February 17 - March 16,1990,_ violations of NRC requirements were identified. In accordance with the

        " General Statement of Policy and Procedure for NRC Enforcement Aci!ons," 10 CFR Part                 ,

2, Appendix C, (1990), the violations are listed below: j A. Technical Specification 6.8.4.a requires that a program be established, implemented and maintained to reduce leakage from those portions of systems outside v containment that could contain highly radioactive fluids during a serious transient or '! accident to as low as practical levels. The systems include the recirculation spray, safety injection, chemical and volume . control, gas stripper, and -hydrogen recombiners. The program shallinclude the following:- , p (i) Preventive maintenance and periodic visualinspection requirements,land (ii) Integrated leak test requirements for each shutdown at refueling cycle intervals or less. Contrary to the above, the program required by Technical Specification 6.8.4.a was not established, in that the following:

1. An adequate preventive maintenance program has not been developed for those Grinnell valves located in radioactive fluid systems outside containment.

2. Adequate _ testing has not been conducted to identify and reduce leakage trom  !

radioactive fluid systems outside containment, resulting in several personnel gas contaminations. ,_ This is a Severity Level IV violation (Supplement I).. B. 10 CFR 50 Appr,ndix B Criterion XVI requires that measures shall be established to assure that conditions adverce to quality are promptly identified and corrected and ' that tile cause of significant conditions adverse to quality be determined and corrective action taken to preclude repetition. Contrary to the above, a condition adverse to quality was not adequately corrected, and corredve action to preclude repetition and determination of the cause were not < conducted in that, from June 1989 through March 1990,'several seal leaks continued l to be identified on the Unit 1 low head safety injection pump,1-SI P-18, without , satisfactory pennanent iesolution of the problem. In addition, with this history of seal problems, seal packages have not been maintained in. parts storage. This is a Severity Level IV violation (Supplement I and applies to Unit 1.) Page 1 of 6 i

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                                                                                 'NOV 50 338&339/90 04 '   -{

C. ' Technical' Specification 6.8.1.a requires written procedures : be established, implemented and maintained covering those activities contained in Appendix A:of Regulatory Guide 1,33; Revision 2,- February 1978.' This document addresses 1 j radiation protection procedures.  ; 1 c l Mechanical maintenance procedure MMP-C-FL-5," Removal and Reinstallation of the -  ! Reactor Coolant Filter", Revision 7, requires: (1) In a note in' step 5.1, that "Do not  ;' completely drain and vent the filter vessel until immediately prior to filter cover. removal" and l2) In step 7.1.5, that the protection cask be positioned over the filter access hole before the cover is removed. Contrary to the above, procedure MMP C-FL 5 was not implemented in that the following:

1. The filter was isolated at-1100 hours on Febtuary 26,1990, dralned and'ventsd at  !

0730 hours and again at 1100 hours on February 27 -1990, but the filter removal process did not begin until approximately 1120 houtc cn Februar/ 27,1990. <

2. On February 27,1990, the protection cask was not place'd over the access hole until after the cover was removed.

These actions resulted in me contamination of seven personnel. This is a Severity Level IV violation (Supplement I) and applies.to Unit 2. BES,PONSE TO VIOLATION A

1. ADMISSION OR DENIAL OF_ THE ALLEGED VIOLATION-The violation is correct as stated. 1

2. REASON FOR THE VIOLATION The violation for an inadequate preventive maintenance program fo'r' Grinnell valves -

was caused by Maintenance Department Administrative Procedure (MD-ADM) 12.0-improperly requiring the replacement .of all Grinnell valve diaphragms and 0; rings at  ! 5 year intervals. The actual qualified lifetime of the valve ~ diaphragms and 0-rings is every 10 years but for conservatisrn the lifetime was shortened to every 5 years. - The remaining time incorporated-a :5 year shelf life for the materials. The procedural requirement to replace all Grinnell valve diaphragms and 0 rings was unachievable- J due to the large quantity of valves in the program and.the fact that a significant number of the valves are unaccessible during plant operations.  ; t e 3 t Pago 2of 6

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NOV 50 338&339/90 04 E The violation for inadequate leak testing of systems _ outside containment that could contain radioactive fluids was caused by, inadequate-procedures and procedural control. Leak testing procedures did not adequately specify test boundaries and provide a mechanism to prevent changing . test boundaries without first obtaining the appropriate approvals. r -

3. CORRECTIVE STEPS WHICH HAVE BEEN - TAKEN AND THE RESULTS' ACHIEVED

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        ,                       MD-ADM-12.0 was revised to establish the applicable criteria for including a Grinnell-

- valve in the program. As a result, there has been a significant reduction in the

{ number of valves in the program. T Since the revision of MD-ADM-12.0, the entire Grinnell valve diaphragm and 0-ring replacement program has been placed on . hold. The program hold is based on a t recent report published by EPRI (NClG-13, Guidelines for Establishing, Maintaining 3 and Extendin0 the Shelf Life Capability of Limited Life items) that qualified the lifetime of the Grinnell valve diaphragms and O rings for at least 60 years. i y Radioactive gas leaks in the auxiliary building have been repaired thus reducing the  ; number of personnel contamination events. Specifically, l ( - The gas leaks on the flow path from the level instrumentation for the Unit 1 and 2 Volume Control Tank have been repaired. j i g j 1

                                - Leaks on the Jow level waste tank vent into the auxiliary building have been                    i stoppcd.                                                                                     j
                                 - Leaktesting of the gas stripper was performed and identified leaks were repaired.           "

1 PT-57.8 was revised by procedure deviation to require that the primary grade water supply be isolated following gas stripper system pressurization so the pressure 1 7 decrease could be monitored.  ! k 4 - CORRECTIVE STEPS WHICH WILL BE TAKEN1TO AVOID FURTHER VIOLATIDNS . 1 The vendor (Grinnell) was contacted to determine the qualified life of their valve i diaphragms and 0-rings. As a result, Grinnell stated that their valve ~ diaphragms and r O-rings have at least a 10 year lifetime, in addition, a report published by EPRI  ! (NCIG-13, Guidelines for Establishing, Maintaining and Extending the' Shelf Life H Capability of Limited Life items) qualified the lifetime of the Grinnell valve diaphragms L - and 0 rings for at least 60 years. The results of the EPRI report are being confirmed 1 by testing at Wyle Laboratories. Resumption-or permanent removal of the Grinnell Li E-  ? valve diaphragm and 0 ring replacement program will be contingent _upon the b ongoing testing. y Leak test procedures will_ be reviewed and revised, as necessary, to specify appropriate test boundartes. j _ Page 3 of 6

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NOV 50-338&339/90 d Appropriate precautions will be placed in leak test procedures to ensure the test- l boundaries are not changed without prior to use approval.

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An evaluation ~ will be-- performed to establish criteria for performing' additional: Inspections and testing when auxiliary building radioactive gas levels reach a pre-established value. g( i

5. THE DATE WHEN FULL COMPLIANCE W1LL BE ACHIEVED ~l Testing to confirm the results of the EPRI report will be completed by August 1990. 3 The decision to resume or permanently delete the Grinnell valve diaphragm and O- ~

ring replacement program will be contingent upon the test results. Leak test procedures will be reviewed and revised prior to their next scheduled a performance. l 1

              . The evaluation for estab"shing criteria for performing additional inspections and                  l testing when auxiliary building radioactive gas levels reach a pre-established 'v6!ue          :l will be completed by August 1990.                          -

1 RESPONSE 'TO VIOLATION B , 1

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

2. REASON FOR THE VIOLATION The violation was caused by a purchasing error. An 0-ring was the only part needed.

to perform the required maintenance on the Unit 1 B Low Head Safety-Injection Pump (1-SI-P-1B). Due to the purchasing error, the O-ring was oroere'd but the purchase > order was cancelled by the vendor because the purchase order did not meet the minimum billing requirement of $100. The Purchasing Department failed to notify , management of the purchase order cancellation. ' A root cause evaluation was not previously performed because the leakage from the: pump seal was believed to be insufficient to- affect pump operability. 1 -SI-P-1 B continued to meet the operability requirements of Technical Specification 4.6.2.2.1.b. Ei

3. CORRECTIVE STEPS : WHICH HAVE ' BEEN TAKEN A'ND THE -RESULTS ')

ACHIEVED 1 The O-ring to repair the 1-SI P-1B seal was obtained and maintenance on.the pump sealwas completed.1-SI P-1B was tested and returned to service on April 23,1990. Page 4 of 6 i 1i _ --. . . . . . . . ..m.

         #*                                                                           NOV 50 338&339/90-04 e           A detailed failure analysis was performed on the 1-SI-P 1B. The failure analysis                  '

could not ' conclusively determine the cause of the seal leakage. A copy of the'

            - detailed failure analysis report was provided to the NRC Resident inspector.
            . An adequate supply of seal packages for future repair of the low head safety injection .          ;

pumps are being maintained in storage.

4. CORRECTIVE STEPS ~ WHICH WILL BE . TAKEN :,TO AVOID FURTHER -

            -VIOLATIONS
            - A purchasing procedure will be developed to ' preclude the error of not-meeting the

minimum requirements for t illing. In the interim, temporary corrective measures have been put in place to preclude the error of not meeting the minimum requirements for billing.

5. THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED

                                                                                                             .i The purchasing procedure will be developed by June 1990.
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RESPOl19E TO VIOLAT.IO. R_.Q d

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

2. REASON FOR THE VIOLATION ,

The violation was due to personnel falling to follow the requirements of Mechanical Maintenance Procedure MMP-C-FL-5. The causeLof venting and draining the filter ,

            -vessel prior to filter removal was the lack of communications between the Operations Department and the Maintenance and Radiation Protection Departments. Operations

, had vented and drained the filter vessel on the premise that maintenarme was ready to be performed in ac..a v, the radiation work permit had not. been prepared and- ! the pre-job briefing had n.x . '<en place. The cause of not placing the protection cask over the access hole ! the cover was removed was due to failure to follow-k procedure. Personnel failed to follow procedure because of the unavailability of tool extensions which would allow detensioning via the top of the cask.

             .A contributing cause was that a reduced micron filter (2 microns) was being changed-due to a high pressure drop across the filter. Previous filter changeouts were on either 6 micron filters or 2 micron filters (due to radiation levels)._ MMP-C-FL-5 was not      "

specific to a reduced micron filter changeout due to a high differential pressure across the filter. MMP-C-FL-5 did not establish appropriate radiological controls to change a reduced micron filter since additional radiological hazards would be introduced.- , 4 Page 5 of 6 i a

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 , ,. ..-                                                                    NOV 50-3388339/90'-04 A possible cause for personnel getting contaminated during the filter changeout was p            due to inadequate radiological surveys. Health Physics personnel obtained an air.

sample to assess the radiological conditions but did not field analyze the sample. The _ air sample was analyzed after work activities were completed. Hot particle controls were not implemented during the filter changeout because of the anticipated damp condition of the filter, i

3. CORRECTIVE STEPS WHICH:HAVE BEEN TAKEN - AND THE RESULTS }

ACHIEVED # Notifications of the personnel contamination event were voluntarily made to the State i of Virginia and subse'quently to the NRC in accordance with 10CFR50.72. Personnel involved in the personnel contamination event met'with the Station Manager to. discuss the event and; establish appropriate: corrective actions. y Emphasis was placed on the importance of following procedures, p A Radiological incident Report on the personnel contaminations resulting from_the filter changeout was completed and approved by station management. As a result, ., the following corrective actions have been implemented.  : 1

             - The potential impact of reduced micron filters on the job scope and radiologic'al     i controls has been included in job planning,- RWP preparation / review and pre-job briefings.                                                                           '
              - Health Physics Technicians have been reinstructed to field analyze all air samples    !

during filter changeouts, i 4

              - MMP-C-FL 5 and other filter replacement procedures. have been revised to provide sufficient controls for filter replacement.

4. CORRECTIVE STEPS WHICH WILL BE TAKEN TO - AVOID FURTHER VIOLATIONS No further corrective actions are required.

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5. THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED q l

Full compliance has been achieved. ~i q l 1 Page 6 of 6

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