ML20127F804

Responds to NRC Re Violations Noted in Insp Repts 50-338/85-01 & 50-339/85-01.Corrective Actions:Loop Delta T Protection Channels Rescaled to Core Power,Establishing Normalization of Channel Error to Actual Core Conditions

ML20127F804
Person / Time
Site:	North Anna
Issue date:	03/25/1985
From:	Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20127F777	List: IR 05000338/1985001 ML20127F804
References
85-154, NUDOCS 8505200598
Download: ML20127F804 (3)

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e tDi. 771 4781 3 gg i all t 08 March 25, 1985 Dr. J. Nelson Grace Serial No.85-154 7

i-Regional Administrator N0/sbe b

. Region II-Docket Nos. 50-338 L

'U..S. Nuclear Regulatory Commission 50-339

- 101'Marietta Street Suite 2900 License Nos. NPF-4

-Atlanta, Georgia 30323 NPF-7 l

Dear Dr. Grace:

We have' reviewed your le'tter of February 22, 1985, in reference'to the inspection at North Anna Power Station conducted from January 6 to Febru-ary. 5, 1985 and ' reported in IE Inspection Report 50-338/85-01 3 and i

50-339/85-01. Our response to the Notice of Violation is addressed in the ya' attachment.

We have determined that no proprietary information is. contained in the

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-report. Accordingly, Virginia Power has no objection to this inspection l

report-being made a matter of public disclosure.. ' The information con-tained'in the attached pages is true and accurate to the best of my know-ledge and belief.

Very truly yours, f

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4.I %ewart

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Attachmenti ce;,Mr. Roger D. Walket, 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

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' RESPONSE TO NOTICE OF VIOLATION ITEM REPORTED DURING NRC INSPECTION CONDUCTED FROM JANUARY 6 TO FEBRUARY 5, 1985 REPORT 50-338/85-01 AND 50-339/85-01 NRC COMMENT Channel Check'as defined in Section.1.4' of theLTechnical Specifications, states, inLpart, "A Channel Check shall be the qualitative assessment'of.

channel behavior.during operation by ' observation. This determination shall include, where possible, comparison of. the channel indication and/or status with other indication and/or status derived from instrumen-tation channels measuring the same parameter."

Technical Specification 4.3.1.1.1 requires in Table 4.3-1 that overten-perature Delta T. and overpower Delta T protection be verified operable every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by the performance of a Channel Check.' Additionally, tech-nical specification 4.3.3.5 requires in table 4.3-6 that auxiliary shut-down panel steam generator level be verified operable every 31 days by the -

performance of a Channel Check.

. Contrary to the above, the licencee failed to meet the surveillance requirements in that:

A. Unlike parameters were compared when performing the Channel Checks of Delta T instruments TI-1-412A, TI-1-422A and TI-1-432A (TI-2-412, TI-2-422A and TI-2-432A for Unit 2)

B. When performing-the Channel Checks of Steam Generator Level inst-rument LI-1477B, LI-1487B and LI-1497B (LI-2477B, LI-2487B and LI-2497B for Unit 2) unlike parameters were also compared.

This is a Severity Level IV violation and applies to both Units.

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RESPONSE

1. ADMISSION OR DENIAL OF THE ALLEGED VIOLATION.

This violation is correct as stated.

2. REASON FOR THE VIOLATION This violation was the result of a procedural error. For over-l temperature Delta.T the procedure incorrectly required the comparison of these channels which were not normalized to full

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power and did not have inherent independence from the other channels.

For the single Steam Generator wide range level indication, the procedure incorrectly required comparison between generators.

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3. CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED Each loop Delta T protection channel was rescaled to core power.

This established a normalization of the channel error to the actual core conditions. As such, the channels now independently measure like parameters and meet the Technical Specification requirement for a channel check.

4. CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS A study of the channel checks, required to meet Technical Specification requirements,.is being conducted to identify any additional areas in which unlike parameters are compared. To date, no additional items have been identified. In addition, a comparison of the Channel Check allowed tolerance to the tolerance used in the UFSAR is being made to ensure compliance with the assumptions of the safety analysis.

The periodic test that establishes loop specific values of Delta Temperature will be revised to require rescaling of these channels following each refueling outage.

The periodic tests that incorrectly required the comparison of the Steam Generator level channels will also be revised to ensure the Channel Checks are made to specific loops.

5. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The study and the procedure revisions will be completed by April 30, 1985.

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