IR 05000280/1988026
| ML18153B549 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 11/10/1988 |
| From: | Ernst M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Cartwright W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| Shared Package | |
| ML18153B550 | List: |
| References | |
| EA-88-215, NUDOCS 8811220400 | |
| Download: ML18153B549 (4) | |
Text
Docket Nos. 50-280, 50-281 License Nos. DPR-32, DPR-37 EA 88-215 NOV1o'19B8
~irginia Electric and Power Company ATTN:
Mr. W. R. Cartwright, Vice President Nuclear Operations Post Office Box 26666 Richmond, Virginia 23261 Gentleman:
SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY (NRC INSPECTION REPORT NOS. 50-280/88-26, 50-281/88-26, 50-280/88-28, AND 50-281/88-28)
This refers to the Nuclear Regulatory Commission (NRC) inspections conducted by W. E. Holland and L. E. Nicholson at Surry Power Station on June 5 through July 30, 198 These inspections included a review of the cleanliness/foreign material exclusion controls in place for safety-related systems at the Surry Power Station from November 1986 through July 198 Also, the inspections focused on the licensee reported foreign material which was identified in June 1988 in both the Unit 1 and Unit 2 containment sump The reports documenting these inspections were sent to you by letters dated August 12 and August 30, 1988, respectivel As a result of those inspections, significant failures to comply with NRC regulatory requirements were identified, and accordingly, NRC concerns relative to the inspection findings were discussed in an Enforcement Conference held on September 16, 198 The letter summarizing this conference was sent to you on qctober 12, 198 The violation described in the enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Notice) involved failure to ensure that cleanli-ness and foreign material exclusion conditions were maintained during mainte-nance and modification activities, which resulted in degraded safety-related system Testing of one of the Unit 1 Recirculation Spray Pumps in June 1988, resulted in your discovery of foreign material in the pump suction flow paths of both the Recirculation Spray and Safety Injection System This condition existed for an extended period of time and, as you noted during the Enforcement Conference, was probably construction debris from early plant modifications in the 1970 Further, we note that you recently discovered considerable damage to both Inside Recirculation Spray Pumps on Unit Although the damage was partially attributed to the method of surveillance testing, there is a strong potential that this debris contributed to the damage and brought into question the operability of the pump Other more recent examples of inadequate clean-liness controls associated with work on safety-related systems were also note These concerns were identified by both your Quality Assurance organization and independently by the NRC inspectors before and during the inspection perio We are especially concerned about the apparent lack of implementation of your cleanliness controls program as described in your Topical Report (VEP 1-5A),
and the potential impact on operability of safety-related system PDR ADOCK 05000280 G
PNU
Virginia Electric and Power Company
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NOV 1 0 1988 Although the specific cause of this violation was a lack of adequate clean-liness controls when working on safety-related systems, a broader issue is the -
lack of management action in the cleanliness program area that permitted cleanliness and foreign material exclusion problems to go undetected for an extended period of tim Your recognition of the problem in the containment sumps after identification of the condition during testing, and corrective action in this specific area, was appropriat However, potential degradation of multiple safety systems due to a lack of knowledge of the condition of the containment sumps is indicative of an inadequate foreign material exclusion and inspection program over the year To emphasize our concerns with regard to your inadequate implementation of a program which could affect operability of safety-related systems and the period of time in which adequate controls were not in place, I have been authorized, after consultation with the Director, Office of Enforcement, and the Deputy Executive Director for Regional Operations, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty in the amount of Fifty
. Thousand Dollars ($50,000) for the violation described in the enclosed Notic In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1988) (Enforcement Policy),
the violation in the enclosed Notice has been categorized at a Severity Level III. The base civi_l penalty amount for a Severity Level III violation is
$50,00 The escalation and mitigation factors in the Enforcement Policy were considere No mitigation was deemed appropriate for your identification and reporting because the problem in this case was self-disclosing. Although your corrective actions after identification of the problem in the sump area were extensive, any mitigation of the civil penalty for corrective actions was offset by prior notice in that there have been a number of past problems with cleanliness control at the plant that should have caused you to implement broad programmatic changes to prevent the recurrence of such problem Specifically, the presence of foreign materials resulting from inadequate cleanliness control has been a problem both in the reactor coolant system, where fretting of fuel rods was observed, as well as in the main feedwater syste You are required to respond to this letter and the enclosed Notice and should follow the instructions specified therein when preparing your respons* In your response, you should document the specific actions taken and any addi-tional actions you plan to prevent recurrence. After reviewing your response to this Notic~~-including your proposed corrective actions and the results of future inspections, the NRC will determine whether further NRC enforcement action is necessary to ensure compliance with 1 NRC regulatory requirement In accordance with Section 2.790 of the NRC's "Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosure will be placed in the NRC Public Document Roo The responses directed by this letter and its enclosure are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, Pub. L. No. 96-51 *.,...-
Virginia Electric and Power Station
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NOV101988 Should you have any questions concerning this letter, please contact u Enclosure:
Notice of Violation and Proposed Impos-iti on of Civil Penalty ci w/encl:
\\./V_/'L. Benson, Station Manager 1..-N. E. Hardwick, Manager - Nuclear Programs and Licensing Commonwealth of Virginia
Sincerely, ORlGWf:L SIGNED BY
~ --ff lf)]t~d C:: fl211h.~
~lco~l~l~rnst Acting Regional Administrator
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i Virginia Electric and Power Company - 4 -
bee w/encl:
\\/'Senior Resident Inspector -
Surry
~enior Resident Inspector -
North Anna Document Control Desk
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