ML18139A300
| ML18139A300 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 06/09/1980 |
| From: | Spencer W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8006120197 | |
| Download: ML18139A300 (5) | |
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VIRGINIA ELECTRIC AND POWER COMPANY. RICHMOND, VIRGINIA 23261 Mr. James P. 0 1 R~illy, Director Office of Inspection & Enforcement U. S. Nuclear Regulatory Commission Region I I 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303
Dear Mr. O'Reilly:
June 9, 1980 Seri a 1 No. 462 PSE&C/RHWUI :bmt Docket No. 50-280 License No. DPR-32 This letter is in response to your letter of May 16, 1980.
The Ncitice of Devia-tion, 280/80-12-01, enclosed as Appendix A to your 1e.tter, expressed your con-cern that certain activities appear to deviate from commitments to the Commission, and have safety significance. The concerns of your staff as stated in the referenced letter and in the Inspection Report No. 50-280/80-12 and 50~281/80-13 are addressed in the attachment to this letter.
Should you have any questions concerning this letter, please contact us.
Attachment Very tr~,ly yours,
-. : :*~::::;~fi2,, '- cc> 7-~-----
- w. C. ~-pencer Vice President - Powe'r Station Engineering and Construction Services cc:
Mr. Victor Stello, Director Office of Inspection & Enforcement Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation 80061-20 10\\7
e e
Attachment to letter Serial No. 462, dated June 9,1980 Response to May 16, 1980 Notice of Deviation 280/80-12-01.
Surry Power Station, Unit 1 NRC Concern:
- Notice of Deviation Based on the results of the U.S. Nuclear Regulatory Commission inspection conducted on April 16-18, 1980, certain of your activities appear to deviate from your commitments to the Commission as indicated below:
VEPCO letter Serial No. 725 dated September 5, 1979, stated that 11accessible supports will be upgraded expeditiously as deficiencies
. are noted during. plant operation... as required by IE Bulletin 79-02.
11 This letter..further stated that,.!.'We plan to fully comply.
with the intent and schedule of Bulletin 79-02... . A letter from Region II to VEPCO dated September 7, 1979, confirming actions to be taken by VEPCO related to returning Unit 1 to service stated that, 11 It is our understanding that after you commence operation of Unit 1, you will continue the inspections required by IEB 79-02 for accessible systems."
NRC Inspection Report 50-280/79-53, dated September 28, 1979, reiterated that the expeditious "Completion of the remaining inspections, tests, analyses and repairs as specified in IEB 79-02" wasexpected.
Contrary to the above, as of April 18, 1980 none of the additional inspections or testing required for IE Bulletin 79-02 had been initiated.
No procedure had been prepared for performance of this work.
- VEPCO Response Our letter Serial No. 725 dated September 5, 1979 stated that, "The accessible supports will be upgraded expeditiously as deficiencies are noted during plant operation and non-accessible supports will be upgraded during the steam generator replacement outage as required by I.E.Bulletin 79-02." This letter further stated that, "We plan to fully comply with the intent and schedule of Bulletins 79-02 and 79-14 and to opetate Unit No. 1 in compliance with the-restrictions bf the lifting of the Order to Show Cause dated August 22, 1979."
Compliance with IE Bulletin 79-02 is predicated on the completion of the p1p1ng and pipe support analyses associated with IE Bulletin 79-14 and the Order to Show Cause of March 13, 1979, which generate the loads requ{red for base plate analysis for flexibility and the determination of anchor bolt design loads.
During the period of interim operation since October 1979 we have*been proceeding expeditiously with the p1p1ng and support analyses for IE Bulletin 79-14, iricluding the base plate analy-sis for IE Bulletin 79-02.
A total of about one thousand supports have been analyzed
e during this ~eriod resulting in approximately 500 modifications.
Associated with these supports are the analyses of 276 base plates which include 116 base plate modifications resulting from the IE Bulletin 79-14 analysi.s.
In February 1980 Surry Unit 1 was shut doi,,m* as a result of nonconformances identified by IE Bul-letin 79-14, The modifications installed during the shutdown period include base plate modifications for some of these supports.
Furthermore, as stated in our letter of January 30, 1980, Serial No. 9438/110879, 18 supports were identi-fied as being attached to masonry walls and were upgraded by removing the supports from the block walls and resupported as a result of IE Bulletin 79-02, Revision 2, We feel that this work complies with our commitment to upgrade expeditiously the accessible supports as deficiencies are noted and shows that some inacce~sible supports have been upgraded prior to the steam generator replacement outage.
Our response for completing IE Bulletin 79-02 as provided in our letter of December 7, 1979, Serial No. 943A/110879 responding to Revision 2 of the bulletin stated:
"Item 7 of the revised Bulletin requires the provision of a schedule that details the completion dates for IE Bulletin No. 79-02, Revision 2, items 1, 2, and 4 which address base plate flexibility~ factors of safety, and anchor bolt testing, respectively.
Completion of these items is dependent upon the ongoing piping and support analyses associated with the NRC Order to Show Cause of March 13, 1979 and IE Bulletin No. 79-14.
The base plate 11 footprint 11 loads which are generated by these analyses are required to perform the base plate flexibility analyses and calcu-lations of anchor bolt loads necessary to determine anchor bolt test loads which would ensure the factors of safety required by the Bulletin.
Based on the anticipated availability of these base plate 11footprintfl loads the scheduled completion dates for IE Bulletin No. 79~02, Revision 2 are as noted below.
For Surry Unit 1 our current schedule indicates base plate flexibility analysis starting on December 3, 1979 for the piping associated with IE Bulletin No. 79-14 and on May 19, 1980 for the piping associated with the NRC Order to Show Cause of March 13, 1979.
The verification of factors of safety and ani::hor* bolt inspection and testing would° begin when anchor bolt loads are available for an entire piping*system.
The inspection and testing would begin outside the containment and would shift inside the containment during an outage.
These efforts will continue through 1980.
11 As of the NRC inspection of April 16-18, 1980, analysis had not been, and still has not been, completed for an entire system.
Based on the NRC concerns expressed during this inspection, the procedure for inspection and testing of anchor bolts has been generated and the inspection and testing program initiated.
These actions
- are documented ln your NRC Inspection Report 50-280/80-18 and 50-281/80-18 for
'q,"
e during this period resulting in approximately 500 modifications.
Associated with these supports are the analyses of 276 base plates which include 116 b~se plate modifications resulting from the IE Bulletin 79-14 analysts.
In February 1980 Surry Unit 1 v,as shut dm*rn as a result *of nonconformances identified by IE Bul-letin 79-14.
The modifications installed during the shutdown period include base plate modifications for some of these supports.
Furthermore, as stated in our letter of January 30, 1980, Serial No. 9438/110879, 18 supports were identi-fied as being attached to masonry walls *and were upgraded by removing the supports.
from the block walls and resupported as a result of IE Bulletin 79-02, Revision 2, We feel that this work complies with our commitment to upgrade expeditiously the accessible supports as deficiencies are noted and shows that some inaccessible supports have been upgraded prior to the steam generator replacement outage.
Our response for completing IE Bulletin 79-02 as provided in our letter of December 7, 1979, Serial No. 943A/110879 responding to Revision 2 of the bulletin stated:
"Item 7 of the revised Bul1 etin requires the provision of a schedule that details the completion dates for IE Bulletin No_ 79-02, Revision 2, items 1, 2, and 4 which address base plate flexibility, factors of safety, and anchor bolt testing, respectively.
Completion of these items is dependent upon the ongoing piping and support analyses associated with the NRC Order to Show Cause of March 13, 1979 and IE Bul1etin No. 79-14.
The base plate "footprint" loads which are generated by these analyses are required to perform the base plate flexibility analyses and ca1cu..,.
lations of anchor bolt loads necessary to determine anchor bolt test 1 oads which would ensure the factors of safety required by the Bulletin.
Based on the anticipated availabi1ity of these base plate "footprint" loads the scheduled completion dates for IE Bulletin No. 79-02, Revision 2 are as noted below.
For Surry Unit 1 our current schedule indicates base plate flexibility analysis starting on December 3, 1979 for the piping associated with IE Bulletin No. 79-14 and on May 19, 1980 for the piping associated with the NRC Order to Show Cause of March 13, 1979.
The verification of factors of safety and anchor* bolt inspection and testing wou1d begin \\'/hen anchor bolt loads are available for an entire piping system.
The inspection and testing would begin outside the containment and would shift inside the containment during an outage.
These efforts 1.vil 1 continue through 1980.
11 As of the NRC inspection of April 16-18, 19AO, analysis had not been, and still has not been, completed for an entire system.
Based on the NRC concerns expressed during this inspection, the procedure for inspection and testing of anchor bolts has been generated and th~ inspection and testing program initiated.
These actions are documented tn your NRC Inspection Report 50-280/80-18 and 50-281/80-13 for
e April 29-May 2, 1980 transmitted to us by your letter of May 20, 1980.
These actions show that we have initiated action which started the anchor bolt inspection and testing ahead of the schedule provided on December 7, 1980.
The letter from Region II to VEPCO, dated September 7, 1979 confirming actions to be taken by VEPCO related to returning Unit 1 to service stated that, 11 It is our understandihg that after you commence operation of Unit 1, you will continue the inspections required by IEB 79-02 for accessible systems.
11 NRC Inspection Report 50-280/79-53, dated September 28, 1979, reiterat~d that the expeditious 11Completion of the remaining inspections, tests, analyses and repairs as specified in IEB 79-02 11 was expected.
Item 6 of your Report Nos.
50-280/80-12 and 50-281/80-13 reported, 11 It is noted that the licensee did perform an inspection of accessible base plates in November 1979 to identify gross nonconformances such as missing or broken bolts or nuts, cracked grout, excessive skewing, etc.
11 The results of the anchor bolt sampling programs con-ducted for Surry Unit 1 and reported to you in our letters of July 24, 1979, Serial No. 146/030879C, September 5, 1979, Serial No. 725, and October. 4, 1979, Serial No. 817, indicated that anchor bolt inspection results, without confirmatory tension test results and corresponding analyses for anchor bolt loads, did not provide meaningful results tQ ensure anchor bolt adequacy.
There.fore, we feel that the inspection and testing must be based on the results of the base plate analysis efforts and it is in this area where our efforts have been concentrated.
Your Notice, as quoted above, stated that none of the additional inspection and testing had been initiated and no procedure had been prepared for performance*
bf this work.
As of April 18, 1980 no procedure had been prepared, but meetings between VEPCO and Stone & Webster were held to discuss procedures on January 22, 1980 and March 10, 1980.
Procedure STF-16, 11 Program for Inspection and Testing of Existing E:<pansion Anchor B0lts 11 was issued on April 26!> 1980 and inspection and testing initiated on April 26, 1980.
In addition, the procedure was revised to reflect the discussi~ns held with your Inspector as reported in NRC Report Nos.
50-280/80-18 and 50-281/80-18.
Tilis procedure has been issued, STF-16, Revision 1.
In response to your letter of May 16, 1980, corrective actions that have been taken include the preparation of a procedure for *anchor bolt inspection and test-.
ing, STF-16, dated April 25, 1980, and initiation of the t~sting program starting April 26, 1980.
Corrective actions which will be taken to avoid further deviations include the expediting of base plate analysis efforts to generate anchor bolt design loads and a continuing anchor bolt inspection and testing program implemented for Surry Unit 1.
The date corrective actions were completed was April 26, 1980 for the initial imple- *
- mentation of the anchor bolt inspection and testing program.
Actions*associated with IE Bulletin 79-02 will be completed by the time of the completion of the Surry Unit 1 steam generator replacement outage.