ML20082G931
| ML20082G931 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 08/14/1991 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 91-420, NUDOCS 9108220110 | |
| Download: ML20082G931 (8) | |
Text
. _ - _ - - _ - _ _ _ - -
Vistuixi A 1:1.1:ri ts a r A N il I'OWllf C untl'A M li trilkItsNil, YllHilNI A Wil2 OI Aug uilt. 14, 1991 United States Nuclear Regulu.'y Commission Serial No.:
91 420 Attention: Document Control Desk NAPS /MPW/TAH: R6 Washington, D.C. 20555 Docket Nos.: 50 338 50 339 License Nos.: NPF 4 NPF 7 Genticmon:
yJBQ1NIA ELECTRIC AND POWER COMPANY MQRTH ANNA POWER S_TATION_ UNITS 1 AND 2 MRC INSPECTION REPORT NOS. 50 33B&339/9110 REPLY TO A NOTICE OF V10LATION We have recolved and reviewed the Notice of Violation dated July 15,1991, which cited two Severity Level IV violations, These violations were identitled during inspections conducted at North Anna Power Station from April 21,1991 through June 15, 1991, and documented in Inspection Report Numbers 50 338&339/91 10. Our responses to the Notice of Violation are attached.
In the Notice of Violation, you specifically expressed concern regarding Violation A as being caused by personnel errors, inattention to detall, and inadequate self check techniques. We share your concern. Our internal self assessment program results have served to direct management attention to the critical area of human performance and we have implemented several actions designed to improve performance in this area. Those actions include an increased station management emphasis on self checking and involvement of our Corporate' Nuclear Safety group to 3rovide an independent perspective to Station Mar.agement, scheduling of an thPO HPES (Human Performance Enhancement System) Assist Visit in September, and increased scrutiny of personnel performance trends and events by Station Management.
Violation B cited a lack of-complete implementation of the Inservice Test (IST)
Program, Again, we agree with your assessment and in May 1991 initiated an extensive self assessment of both the IST program an(the associated implementing procedures. This review led to our identifying the discrepancies which are cited as examples in Violation B. We have developed action plans to improve the IST Program and they are currently being implemented. Additional details of our self assessment and IST Program corrective action plans were provided to the-NRC during our management meeting at White Flint on August 1,1991.
ja8*2386!R M88ge gga/
in
Doch:1 tJos : LO 338 & 339 sznil tJo ;
91 4?O Wo are also providing a responso for an additional examplo of Violation D.
This example was identified on July 3,1991 and documented in NRC Inspection Report 50 338 & 339 /91 14.
If you have any further questions, please contact us.
Very truly yours,
\\
i W. L. Stowart Senior Vice President Nuclear Attachmont pc: U. S. Nuclear Regulatory Commission Region 11 101 Marietta Street, N. W.
Suito 2000 Atlanta, Georgia 30323 Mr. M. S. Lessor NRC Senior Resident inspector North Anna Power Station l
Page 2of 2 1
I r._
t RESEQHSE TO THE NOTICE OF VlQMIlQH INSPECTION HEEORT NOS._50 338/91 10- AND 50 229/91 10 NHC_COMMENI During the Nuclear Regulatory Commission (NRC) Inspection conducted April 21 -
June 15,1991, violations of NRC requiromonts woro identlflod in accordanco with the
General Statomont of Policy and Proceduro for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1991), the violations are listed below:
A.
Technical Specification 6.8.1 req altos that written proceduros be established, implomonted and maintainod covering the applicablo procodutos recommended in Appendix A of Regulatory Guido 1.33, Rovision 2, February 1978.
Contrary to the above, proceduros woro not followed as evidenced by the following examplos:
1.
Operating Procedure 1 OP 26.1, Transferring 4160 Volt Bussos, Rovision 4
14, requires in section 5.2 that the operator close circuit breaker 1581 then open circuit breaker 1582 when the 1B Station Sorvice Bus is being transferrod from the station service transformer to the reserve station service transformer. On May 14,1991, while implementing section 5.2 of 1 OP 26.1, the procedure was not followed in that circuit breaker 15E1 was opened instead of 1502, which caused a loss of electrical power to the 2H omorgoney 4160 Volt Bus.
2, Operating Proceduro 1 OP 5.4, Draining the Reactor Coolant System, Revision 19, requires in section 5.22 that the operator open and place a Special Order Tag on valvo 1. RC 1052, water lovel standpipe isolation, when pressurizar lovelis redaced to 5 percent, in order to monitor reactor _
coolant lovel during conditions of reduced inventory. On May 13,1991 while implomonting section 5.22 of 1 OP 5.4, the procedure was not followed in that 1 RC 1052 was not opened when the pressurizer level was reduced to 5 percont, which resulted in the inoperability of the reactor coolant system standpipo lovol instrument while the draining evolution proceeded until detoctod at a lower system level.
3.
Operating Procedure 1 OP 1,3, Unit Startup from Mode 5 to Mode 4, Revision 27, cautions in step 4.18 and prior to Step 5.20 that pressure should be equalized before oponing a main steam line non return valve to arovent a swoll in steam generator level, On May 20.1991s while mplementing procedure 1 OP 1.3 during plant heatupithe procedure was not followed ;ri that non return valve 1 MS NRV-101C was opened with a :
pressure dii!erential across the_ valve. This resulted in a high high level condition in the C steam generator which caused main and bypass feedwater control valvos to close, breakers for feedwater pump 1 FW P 10 to trip, and the initiation of an auxillary feedwater pump outo start signal, Page 1 of 6
R:sponss to Notbo of Violation IR 50 338 & 339 / 91 10 4.
Periodic Test Procedure 1 PT 82H,1H Emergency Diosol Generator Slow Start Test, Revision 7, requires in section 4.2 that the machine be synchronized with the 1H emergency bus prior to closing output breaker 15H2. On April 26,1991, while implementing section 4.2 of 1 PT 82H, the proceduro was not followed in that output breaker 15H2 was closed botnre synchronization was achieved.
This is a Severity Level IV Violation (Supplement 1).
RESPONSE TO THE NOTICE OF VIOLATION "A" l
1.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION.
Violation "A"is correct as stated.
i v
2.
INASON FOR THE VIOLATION..
Examples 1, 2, and 4 were caused by the failure of operations personnel to employ self checking techniques and their lack of attention to detall.
Examplo 3 was caused by a less than adequato understanding of plant response and ternporaturo control during heatup evolutions.
3.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE flESULTS AC HIE V E D.'
Licensee Event Report, N191012 00, detalling the steam generator swell event was included in the Licensed Operator Requalification Program Cycle 914, TraininD has been completed by the operations shifts, in addition, the Operating Procedures for controlling heatup of the plant have been revised by Procedure Action Requests approved to provide adcitional clarification for Reactor Coolant System (RCS) taat removal techniques. Permanent procedure revisions have been submitted for the Unit 1 & 2 Operating Procedures.
The failure to synchronize the 1H Emergency Diesel Generator prior to closing the output breaker-has been evaluated by the HPES coordinator, The-Investigation determined that the operator was adjusting the generator output voltage, prior to placing the diesel generator on line. The operator, attempting to raise the generator output voltage, inadvertently grasped the generator output breaker control switch handle instead of the generator voltage control handle, which is of similar design. When the operator turned the handle clockwise to:
raise the generator output voltage, the breaker closed. The evaluation indicated:
that although self check failed in this event, strengthening the human's ability at self checking should reduce personnel errors.
Page 2 of 6
+
c
-- +
E.
]
Hsspones to Notbs of Violation in so-338 & 339 / 91 10 l
Operator awaronoss of the self check process has boon olevated to a highor lovol. This was accomplished by addinD "Solf Chock" training to tho Licensed Operator Roqualification Pro 0 ram Cyclo 914. Distribution of self check cards and badges has also occurred.
A memorandum, " Operations Awareness", was issued to Operations Personnel to I
omphasizo the importanco of awareness during performance of routino tasks. A
{
memorandum re omphasizing the importance of self checking during evolutions j
was also issued to Operations Personnel.
An Operations Standard, I
"Indopondent Verification", was issued to provido detailed Instructions on expectations in oporations awareness. Additionally, all personnel performanco problems have boon addressed through the Company disciplinary process.
An INPO HPES Assist Visit has boon requestod to ovaluato human performanco concerns and has boon schedulod for September 911,1991.
A primary focus of the Station Oversight Board is the ovaluation of adverso personnel performance trends.
Station Mana00mont vill continuo to a0grossively pursuo minimizing personnel performanco errors.
The enhanced Solf Chock trainin0 has boon added to the Non Licensed Operator Training Cyclo 914.
4.
CLORRECTIVE STEPS W11LCH WILL BE TAKZN TO AVOID FURTHER ylOL ATIO NS, Loss of aloctrical power to the 2H omergency 4160 Volt Bus was the subject of a Human Porformanco Evaluation System (HPES) assessment. The ovaluation recommendations have been ontored into the commitment tracking program.
5.
THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED.
Full complianco has boon achloved.
Page 3 of 6 b
Rzsponts to Notbo of Vbl: tion In 60 336 8 339 / 91 10 NRC COMMENT During the Nuclear Regulatory Commission (NRC) inspection conducted April 21 -
June 15,1991, violations of NRC requirements were identified. In accordance with the
" General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1991), the violations are listed below:
B.
Technical Specification 4.0.5 requires inservice testing of ASME Code Classes 1, 2, and 3 valves in accordance with Section XI of the ASME Boller Pressure Vessel Code and applicable Addendum except where specific written relief has been granted by the Commission. The licensee is commitfed to accomplish inservice testing in accordance with the 1986 Edition of the Code.
Subsection IWV of Section XI of the ASME Boller Pressure Ve.sel Code requires that each specific valve to be tosted by the rules of this subsection be identified by.
the owner and listed in the plant records and that the current status of the tast program be recorded. The licensee has identified and recorded the cur...,
status of the test program in the Virginia Electric and Power Company North Anna Units 1 and 2 Inservice Test Program Plan for Pumps and Valves, Revision 6, (IST Program).
Contrary to the above, the requirements of the test program were not met as evidenced by the following examples:
1.
Section 2.3.4 of the IST Program requires 1-SI TV-101, containment isolation valve from accumulators to waste gas charcoal filters, to be stroke timed in the open and closed direction. On April 18.1991'the licensee determined that the valve had not been stroked timed in the open direction.
2.
Section 2.3.4 of the IST Program requires 1(2) HV SOV-1200A(B)(C),
control room condenser pump seal cooling water Isolation valves, to ba stroked timed in the open direction.
On May 1,1991 the licensee determined thtt the valves had not been stroke timed.
3.
The IST Program requires 2 SI HCV 2936, waste gas from accumulators to charcoal filters valve, and 2 SI HCV 2853 A(B)(C), accumulators nitrogen supply and vent valves to be tested on a quarterly frequency.
On May 22,1991, the licensee determined that the valves had not been tested since October 21,1990 and had exceeded the surveillance interval.
This is a severity level IV violation (Supplement 1).
e Page 4 of 6
Rtsponse to Notbs of Violatbn IR 50 338 & 3A / 9110 RESPONSE TO T11E NOTICE OF VIOLATION "B" 1.
AQM[SSION OR DENIAL _OF THE ALLEGED V10LATIQL Vlotation D" is correct as stated.
2.
RF.ASQN FOR THE VIOL ATION.
In examplos 1 and 2 of Violation B, the root cause of the failuro to fully implomont the Inservice Test (IST) program was improper change management and, in some cases, lack of sensitivity to program requirements. A major contributor was the extensive program and proceduro changes necessary to implomont the requirements of Generic Letter 89 04c Example 3 was caused by on error in scheduling the periodic test. The error resulted from revising the appilcable modos of the tost from only Modos 5 and 6 to Modos 1 through 6.
An a ional exampo of Violation B Is identified in IR 91 14 and was duo to an incorrect interpretation of program requirements.
3.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED.
A self assessment of the IST Program was Initiated in May 1991 and has now been completed.
This assessment reviewed both our IST Program and procedures used for implomontation. (Examples 1 and 2 of this violation were initially identiflod by our IST personnel during this review.) An action plan has boon developed to incorporato con;ments from this review into our existing procedures.
All non compliances have been addressed throt.gh proceduto change requests.
Containment isolation valvo,1 SI TV 101, and the control room condonsor pump seal cooling water isolation valves,1(2) HV SOV 1200A(B)(C), were successfully testod in the open direction. The implementing procedures were revised by Proceduto Action Requests to include applicable stroke time requirements.
Safety injection hand control valves,2 SI HCV 2853A, B, and C, as well as 2 SI-HCV 2936 wore successfully tested. The implementing procedure has been scheduled correctly in the Periodic Test Scheduling System (PTSS).
Additionally, North - Anna Site EnDineering Services Implementing Procedure NASES 4.03, " Controlling Procedure for Scheduling New, Revised, or Deleted Periodic Test (PT) Procedures", was revised to add a checklist for PT revisions to ensure changes are incorporated into the PT _ Scheduling System.
Page s of 6
-______-_-__a
e ll:Hons) to Notics of VoL* ton In 50 338 A 330 / 91 10 An additional oxample of Violation B was identified on July 3,1991, when the boric acid transfer pump suction pressuto instrumentation was not oporablo and the ASME XI requirements woro ;ulfilled by calculating pump suction pressure.
This is contrary to Revision 6 of the IST Program and resulted in a missed quarterly survoillance which was reported in LER N1/2 91014 00.
Subsequently, the inlet pressuro rotorenco points woro measured and now ASME XI acceptance critoria was generated using the referenco data. The implomonting proceduros have boon revised accordingly.
On August 1,1991 an action plan detailing improvements for the IST Program was reviewed with the NRC.
4.
CORRECTIVE STEPS WHICH WILL DE TAKEN TO AVOID FURTHER VIOL ATIONS.
As an onhancoment to the IST Program, a program and test proceduro cross referenco data baso is being developed as the tool for managing futuro revisions to the program and ensur!ng that the impact from regulatory correspondences are reviewed and incorporated into test proceduros as nocessary, in addition, the adoquacy of IST resources being utilized to overview program implomontation is being assessed. Finally, an IST Basos document is being developed to facilitato proper identification and understanding of the IST program scopo.
5.
I}JE DATE WHEN FULL COMELIARCE..WILL _DE AC111EVED, Full compliance has been achloved.
Page 6 of 6 i
- - _.