ML20082S744
| ML20082S744 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 09/12/1991 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 91-498, NUDOCS 9109170267 | |
| Download: ML20082S744 (4) | |
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ViscuixiA El,UCTHIC AND POWUH COhil%NY I
HirnMoxo,Vinuixir eriuni September 12, 1991 U.S. Nuclear Regulatory Commission Serial No.91-498 Attn: Document Control Desk NAPS /TAH:R3 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 UhlTS 1 AND 2 INSPECTION REPORT NOS. 50-338/91-14 AND 50-339/91-14 RESPONSE TO THE NOTICE OF VIOLARQH We have reviewed your letter of August 16, 1991 which referred to the inspection conducted at North Anna from June 16,1991 to July 20, 1991 and reported in inspection Report Nos. 50-338/91-14 and 50-339/91-14.
In your cover letter, you expressed concern about the enclosed violation because of the faleure to adequately determine the cause of a motor operated valve (MOV) failure in February 1991. The failure to determine the cause of the MOV failure in February 1991 ultimateh led to a subsequent valve failure four months later. We are also concerned that the proper corrective actions in the event of equipment failure were not implemented.
Virginia Power Administrative Procedure (VPAP) 1501, Station Deviation Reports, specifically delineates ~the requirements for submitting a station deviation report.
Submitting a station deviation report would have led to determining the cause of the MOV f ailure and initiating corrective actions. Personnelinvolved in special testing and subsequent maintenance troubleshooting of the MOV failed to follow established administrative requirements. To reinforce the knowledge of station personnel, training will be given to emphasize the requirements for submitting a station deviation report.
In addition, your letter expressed concern with an additional example of a violation previously identified in NRC Inspection Report 50-3 8,339/91-10, dated July 15,1991, involving the failure to perform a surveillance test in accordance with our Inservice Testing Program for Pumps and Valves. Our Reply to NRC Inspection Report 50-338,339/91-10, Notice of Violation, dated August 14,1991, specifically addressed this additional example, .vhich occurred after the close of that inspection period.
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Dockst Nos.: 50-338 & 339 serial No.: 91-498 Our response to the Notice of Violation is attached. Should you have any questions or r require additionalinformation, please contact us at your earliest convenience.
Very truly yo s,
't
,l W. L. Ste art Senior Vice President - Nuclear :
Attachment pc: U. S. Nuclear Regulatory Commission 101 Marietta Street, N.W.
! Suite 2900 .
Atlanta, Georgia 30323 l
Mr. M. S. Lesser NRC Senior Resident inspector .
North Anna Fower Station I-L 1
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s RESPONSE TO THE' NOTICE OF VIOLATION REPORTED' DURING THE' NRC INSPECTION CONDUCTED BETWEEN JUNE 16. 1991 AND JULY 20. 199_1.
INSPECTION REPORT NOS. 50-338/91-14 ' AND 50-339/91-14 NRC-COMMENT
- During the Nuciear Regulatory Commission (NRC) inspection conducted on June 10 -
- July 20,1991, a violation of NRC requirements was identified. In accordance with the
" General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C,-(1991), the violation is listed below:
Technical Specification 6.8.1_ requires that written procedures be established,-
implemented and maintaine_d covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Procedures
- for the conduct of maintenance activities are addressed in Appendix A of Regulatory Guide 1.33.
VPAP 0808 (sic), Motor Operated Valve (MOV) Program, Revision 2, dated 11/1/90, requires the' Operations Shift Supervisor and the Shift Technical Advisor-to complete an Operations MOV Review Sheet, documenting the initial evaluation following an MOV failure.
Contrary to the above, when 1-SW MOV 101C, B service water header supply isolation to-recirculation spray heat exchanger, torqued out in mid7 position on February 28, 1991, an Operations MOV Review-Sheet was not completed to document the initial evaluation. This resulted in a failure to evaluate and correct the' problem with SW MOV 101C and a-subsequent- failure of the MOV;on July 8,1991.
This is a Severity Level'lV violation (Suppiement 1).
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RESPONSE
- 1. ADMISSION OR DENIAL OF THE ALLEGED VIOLATION The violation is correct as stated.
22 - REASON FOR- THE VIOLATION l
The violation was caused by personnel failing to follow the requirements of Virginia Power Administrative Procedure (VPAP) 1501, Station Deviation Reports and- VPAP-0805, Motor Operated Valve Program. VPAP 1501 specifically delineates the requirements for submittal of a station deviation report.
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NOV 50-338,330/9114 f
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Because 1-SW MOV-101C torqued out at mid position in February 1991, the - !
submittal of a station deviation report was required by VPAP-1501. The station !
< deviation report could then have led to the determination of the cause of the MOV l failure and the initiation of appropriate corrective actions. The repetitive failure - ;
would not have occurred in July 1991. l In addition,' VPAP-0605, Motor Operated Valve Program, requires that when a f
MOV failure is identified,1) the MOV Coordinator is notified, 2) the Operations :
MOV Review Sheet is completed, and 3) a work request is initiated. Personnel notified the MOV Coordinator and initiated a work request due to the MOV problem, but failed.to initiat_e a Operations MOV Review Sheet and station ,
deviation report. The submitted . work request ' resulted ... troubleshooting i
~ activities which failed to duplicate the previous failure. The -valve was_
j subsequently returned to service. However, had a station deviation report and !
Operations MOV _ Review -Sheet been submitted an additional level of management review would have occurred, which we believe would have s precluded the repetitive failure j i
- 3. ~ COPRECTIVE-STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS- ACHIEVED 'j x :
The .importance ,of following established administrative requirements, in i particular, the' requirements for submitting station deviation report 3, has been !
discussed, and re-emphasized, with the appropriate station personnel. !
- 4. CORRECTIVE STEPS'WHICH WILL BE TAKEN TO AVOID FURTHER :
-VIOLATIONS :
As an additional enhancement, Operations, Mechanical and Electrical _
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' Maintenance and Engineering personnel will receive training to emphasize when a station deviation report is required to be submitted.
- 5. THE .DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED !
Full compliance has been achieved.
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