ML18139A539

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Responds to NRC Re Violation Noted in IE Insp Repts 50-280/80-20 & 50-281/80-21.Corrective Actions:Trash Removed from Containment Recirculation Sump Screens & Proposed Tech Spec Change Submitted to NRC
ML18139A539
Person / Time
Site: Surry  Dominion icon.png
Issue date: 08/11/1980
From: Sylvia B
VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To: James O'Reilly
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML18139A538 List:
References
644, NUDOCS 8009240701
Download: ML18139A539 (3)


Text

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A 9 * *' 0 August 11,.1980,,,..;

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Mr. James P. O'Reilly, Director Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303

Dear Mr. O'Reilly:

Serial No. 644 NO/RMT:ms Docket No. 50-280 50-281 License No. DPR-32 DPR-37 We have reviewed your letter of July 15, 1980, in reference to the inspection conducted at Surry Power Station on May 5 through June 6, 1980, and reported in IE Inspection Report Nos. 50-280/80-20 and 50-281/80-21.

Our responses to the specific infractions are attached.

We have determineq that.no proprietary information is contained in the reports.

Accordingly, the Virginia Electric and Power Company has no objection to these inspection reports being made a matter of public disclosure.

Attachment cc: Mr. Steven A. Varga, Chief Operating Reactor Branch No. 1 Very truly yours, ffe~~-'

B. R. Sylvia Manager - Nuclear Operations and Maintenance

\\.

RESPONSE TO NOTICE OF VIOLATION CONTAINED IN NRC INSPECTION REPORTS 50-280/80-20 AND 50-281/80-21 ATTACHMENT Page 1 NRC COMMENT A.

As required by Technical Specification 6.4.D, the detailed written pro-cedures with appropriate check-off lists and instructions provided for.

preventive or corrective maintenance operations which would have an effect on the safety of the reactor shall be followed.

Contrary to the above, on May 19, 1980, the inspector observed *. that startup check sheet OP-lB had not been followed prior to Unit 1 startup.

The Operating Procedure lB checklist requires inspections to insure that containment recirculation sump screens are in place and clear of debris; on the above date, a bucket, mops, rags, plastic bags, a cardboard box and assorted trash was found adjacent to the in-place. recirc. sump screens of the operating unit.

This is an infraction and applies to Unit 1.

A similar item was brought to your attention in our letter dated March 28, 1979.

RESPONSE

This item is correct as stated; however, the trash was minimal, identified by Vepco's entry team, and was removed on the same day.

1.

Corrective steps which have been taken and the results achieved:

The assorted trash ~as been removed.

Additional emphasis has been given to insure all unnecessary material has been removed.

Without specific analysis, we cannot conclude if this trash could or would not adversely affect the operability of the recirc. spray pump suction screens.

The results have been effective; however, there have been no major outages since May, 1980.

2.

Corrective steps which will be taken to avoid further non-compliance:

3.

No further action is considered necessary.

Date when full compliance w~ll be achieved:.

We are presently in full compliance.,

NRC COMMENT B.

As required by Criterion III of Appendix B to 10 CFR 50 and Section III of the NPS QA Manual, the design control measures provide assurance and verification of design adequacy by the performance of design reviews. the use of alternate or simplified calculational methods, or by the per-fonnance of a suitable testing program.

The design change procedure requires an engineering evaluation (safety analysis) to determine the effect on plant operation.

  • contrary to the above, the accident reanalysis for Design Change No. 80-S19 was not completed and presented to station management until May 28, 1980.

even though

  • this modification of the containment recirculation spray

ATTACHMENT Page 2 system had been completed prior to Unit 1 startup on May 11, 1980.

Sub-sequent review of containment pressure. and temperature revealed that Un1t 1 had been operated outside the requirements of Technical Specifica-tion 3.8 on several occasions between May 11 and May 28, 1980.

This is an infraction and applies to Unit 1.

VEPCO RESPONSE:

This item is correct as stated.

I.

2.
3.

Corrective steps taken and results achieved:

Architect-Engineer's analysis has resulted in a proposed change to the station Technical Specifications.

The proposed change has been sent to the NRC for review and approval.

Corrective steps which will be taken to avoid further non-compliance:

All future corr*esporidence and analys*is performed by the Architect-Engineer will be addressed to both corporate and station ~ngineering,and man~gement for review.

All future changes to operational limiting conditions will be addressed by a Technical Specification change and temporarily controlled admini-stratively.

Date when full compliance will be achieved:

Full compliance will be achieved by September 1. 1980.

NRC COMMENT C.

As required by Technical Specification.3.10.A.6, at least one residual heat removal (RHR) pump and heat exchanger shall be operable to circulate reactor coolant during refueling operations.

Contrary to the above, Periodic Test 30. 2, RHR System MOV Cycling, was not perfonned to verify that at least one train or subsystem of the RHR system was operable prior to fuel loading on April 19. 1980.

One of the four motor operated valves (MOV 2720B) in the RHR system and PT 30.2 was cycled, timed, and documented on April 20, 1980.

Documentation of the remaining RHR valves was not provided although station personnel stated that the test was completed on these valves.

This is an infraction.

RESPONSE

Incorrect as stated.

Item is considered a deficiency instead of an infraction.

The PT's*to prove operability of the RHR system and its valves were performed.

The documentation, however, cannot be located.

The Superintendent of Opera-

  • tions. had the completed PT in his possession on the date in question.
  • The

-procedure, however, was lost in routing.

The personnel involved in th~ PT performance concur the PT was satisfactorily performed with the exception. of the one valve.

That valve was identified in the complete procedure deviation and then subsequently performed satisfactorily.

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