ML18139A358
| ML18139A358 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 06/23/1980 |
| From: | Sylvia B VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 515, NUDOCS 8006240283 | |
| Download: ML18139A358 (4) | |
Text
VIRGIN!~ *E~Eo.:ri.uG l.]S"D Po~ER co;iPA.NY. :.'
~
- R10HMON;1J,VUiGINIA 232E>l,
- June 23_,. i980.**
Mr.* James *P. O'Reilly~* 'Director
' Office of Inspection and Enforcement:
U *.. S ~ Nuclear Regulatory* C~:nmnis~ion *..
- lle~ion II*.
101 Marietta Stre-et, Suite. 3100*,* -,/ -
4,i:lanta ~ Georgia,.- 30303 *-
. -Deai* Mr;, O_'~illy:
.'*.*f'
- . >.. Serial Number *515 *,
NO/~!T/j~j
, Docket.No~:50~281
' ; License N~~ DPR...::ri
. * 'we have reviewed your l~tter of Hay 30, 1980 in. referenc~, to.*th~ inspection*
,. conducted*,a't' *Surry. Power. :statioii 'on',NaY'.*5"'.'~;
- 1980 and r.eporJed.).n: IE Inspection
- Repor.t:No~ 50~281/80"".2().,- Our *reaporise~J:o 'th~, ape,:d.fic infrad:.ion 1$. attached *.
~ '.
.. ' -~. ~ *..
t>Je 'hav~*cie~~rndnei:that~o*_'prc>pri~t~ry inf~rmiltiCJn is -co~tained'. ip. th~- repo~~./-
- Accordingly,"_the,Yirginie. Electric. and Power:.Cpinpany' h~o-rio *oJ?jection to this' insRection report being made a* lllB.tter* *of: public* disc_loaure. -
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- : Yery~ tr~i-:_y6~s}>
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-Attrichment
. *-__ ~- _* -*.. ~
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cc':. :Mr. Stev~n A.' Varga*, Chief ; :, ',':
' 'NRC Office' of*, Nuclear 'Reac*~or_ Regui~tion
'.Operating Rea<::t'c,rs' Branch No*/).:: ','
. Divisio~ of Licensing**.. **,..... -
Washington~ D ~
- C *.
- 20555
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NRG Statement:
SURRY POWER STATION RESPONSE TO NOTICE OF VIOLATION IN I.E. INSPECTION REPORT 50-281/80-20 Attachment, Page l As required by Technical Specifications 6.4.A.7 and 6.4.D, detailed written procedures with appropriate check-off lists and instructions shall be provided and followed for preventive or corrective maintenance operations which would have an effect on the safety of the reactor.
Contrary to the above, the "A" reactor coolant loop hydrostatic test procedure (DC 50006-P-4-U2A) performed on January 30, 1980 did not:
- a.
Specify the position of all boundary valves associated with the test.
- b.
Incorporate field changes discovered during the "B" and "C" hydrostatic tests though the action specified by the field changes was taken.
- c.
Specifically identify removal of all procedure installed test equipment.
- d.
Satisfactorily review that the alpha-numeric valve designators applied to the valve descriptions.
This is an infraction.
Response
Item (a.) is not entirely correct as stated.
The details of the inspection report state that 2-HCV-2557B, 2-HCV-2557C were found not positioned/checked positioned in the valve position checklist.
The first sentence in attach-ment II of*S0006-P-4-U2A mandates "hot and cold leg drains on Band C loop must be complete and shut". It is conceded_ that valve designations with sign off blanks would have been preferrable.
The details of report 80-20 also cite 2-RC-23, 82 as similar discre.pancies.
2-RC-82 is the "C" loop hot leg drain and the above response applies.
2-RC-23, FE-2490 isolation valve was errantly omitted from the valve checkoff list.
Item (b.) is not entirely correct as stated.
The details of the inspection report cites,:
Field changes 20 and 24 closed the No. 1 seal water leakoff flow control valves (2-HCV-2303 series) to the non-hydrostatically tested reactor coolant pumps (RCP) during the "C" and '.'B" reactor coolant loop hydro tests respectively to prevent backflow through
Attacp..ment, Page 2 the RCP seals.
A similar valve arrangement was made during the "A" loop hydrostatic test without* the necessary-authorization :in the instructions.
This statement is incorrect.
The field change was incorporated into "A" hydro test procedure prior to its approval by the Station Nuclear Safety and operating Committee.
HCV-2203B,C are closed by step 6.2.9 if P-4-U2A.
The report also cites:
Field changes 18 and 21 modified the requirements of
Attachment:
VII to the "c" and "B" reactor coolant loop hydrostatic tests*
respectively to allow adding additional strip heaters to the reactor coolant piping crossover loop.
Application of the strip heaters was to prevent the steam generator channel head tempera~
ture from dropping below the brittle fracture temperature limi~
of 150°F when the water of this pipe was forced into the steam generator during pressurization.
No provision for this appl:i:c:.a-tion was made for the "A" loop hydrostatic test, however the heaters were attached to the crossover loop piping.
-This statement is correct.
Item (c.) of the inspection report states that P-4~U2A of ETA 50006:, does not speci,:ically identify removal of all procedure* installed test equipment..
On the contrary, step 6. 7. 3. states:
- 6. 7.~:
Close valves 2-RC-15, 2-RC-19 and remove the test reli:cl valves installed in steps 6.1.6 and 6.1.7.
Close valves 2-RC-14, 2-RC-16 and remove the spool pieces installed, :in step 6.1.8 Replace blanks using gaskets in accordance "With
- NUS-20.
Removal of the hydrostatic test gage is accomplished by Part II of Attachment I which reads:
Equipment and tools have been removed foi::i.lowed by a Q.C. hold.
(NOTE:
These same provisions are in P-4-U2B,C of ETA 50006.)
Item. (d.) of_the inspection report cites:
The alpha-numeric designator for valve 2-RC-24 appeared twice in the required valve position checklist (Attachment II) of the procedure.
The first appearance identified the valve as an RTD discharge valve.
The second time as an "A" primary loop flow transmitter leg isolation valve.
The second appearance of the.
designator should have been identified as 2-RC-27.
Even though incorrectly designated, the flow transmitter isolation valve ~vas initialed by the positioning operator as positioned.
A procedure deviation was not written against the attachment for resolution..
This statement is correct as written.
Attachment~ Page 3
- 1.
Corrective Acti.on Taken To Prevent Further Non-Compliance
- operators and engineers involv~d have been reinstructed on the importance of procedural and administrative compliance.
In addition~
increased emphasis will be applied in SRO and RO retraining sessions on adherence to procedures, and proper documentation.
- 2.
Date When Full Compliance Will Be Achieved Full compliance has been achieved.