ML18139B507

Responds to NRC 810715 Ltr Re Violations Noted in IE Insp Repts 50-280/81-18 & 50-281/81-18.Corrective Actions: Procedures Prepared for IE Bulletin 80-11 Requirements & Importance of Accurate as-built Drawings Stressed

ML18139B507
Person / Time
Site:	Surry
Issue date:	08/13/1981
From:	Leasburg R VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML18139B506	List: ML18139B507
References
447, IEB-80-11, NUDOCS 8109010495
Download: ML18139B507 (3)

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RICHMOND,. VIRGINIA 23261 CJ 81/'ci.JGl7 A8*J R.H.Lll:ASBURG August 13, 1981 Vxcn PRESIDENT NUCLEAR 0PEHA'I.'IONS Mr. James P. O'Reilly, Director Serial No. 447 Office of Inspection and Enforcement NO/RMT:acm U. S. Nuclear Regulatory Commission Docket Nos. 50-280 Region II 50-281 101 Marietta Street, Suite 3100 License Nos. DPR-32 Atlanta, Georgia 30303 DPR-37

Dear Mr. O'Reilly:

We have reviewed your letter of July 15, 1981 in reference to the inspection conducted at Surry Power Station on June 17-18, 1981 and reported in IE Inspection Report Nos. 50-280/81-18 and 50-281/81-18. Our response to the specific infraction is attached.

We have determined that no proprietary information is contained in the re-ports. Accordingly, the Virginia Electric and Power Company has no objection to these inspection reports being made a matter of public disclosure. The information contained in the attached pages is true and accurate to the best of my knowledge and belief.

Very t:~you/,

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R.H. Leasburg Attachment City of Richmond Commonwealth of Virginia -c.,L Acknowledged before me this / 3 day of ~ ' 19.R_i Notary Public My Commission expires: o=? - ;)... (::, 19 is-SEAL cc: Mr. Steven A. Varga, Chief Operating Reactors Branch No. 1 Division of Licensing

.1' 8109010495 810820~

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e Attachment Page 1 SURRY POWER STATION RESPONSE TO NOTICE OF VIOLATION NRC COMMENT:

10 CFR 50, Appendix B, Criterion V, as implemented by Section 5 of the VEPCO QA Manual requires "Activities affecting quality shall be prescribed by documented instructions, procedures or drawings or a type appropriate to the circumstance, and shall be accomplished in accordance with these instruction, procedures, or drawings.

Contrary to the above:

1. The procedures developed to implement IE Bulletin 80-11 requirements were not appropriate in that the procedures were not adequate to assure that all masonry walls in the vicinity of safety-related equipment were identi-fied and re-evaluated for their conformance to design requirements.

2. The preparation and QC review of as-built drawings for wall numbers 1C18-4-1, 1C18-4-2, and 1Cl8-4-3 were not accomplished in accordance with the requirements of Procedure BWP-4 in that some details shown on the approved as-built drawings were incorrect.

This is a Severity Level V Violation (Supplement I.E.).

RESPONSE

• 1. ADMISSION OR DENIAL OF THE ALLEGED VIOLATION *

1. The violation as stated is correct. The procedures initially used to implement IE Bulletin 80-11 requirements were inadequate to assure that all masonry walls in the vicinity of safety-related equipment were identified. However, additional procedures were implemented in January and March of 1981, and all walls were identi-fied prior to the NRC Inspection of June 17-18, 1981.

2. The violation is correct as stated.

2. REASONS FOR THE VIOLATIONS IF ADMITTED.

1. The initial identification of masonry walls in the vicinity of safety-related equipment was performed by a review of station drawings with field verification. The drawing review was not adequate to identify all affected masonry walls. Subsequent field inspection procedures were used to identify all walls.

2. The incorrect as-built details resulted from using typical notes and drawings which were prepared to facilitate preparation of the as-built drawings. Details not typical were not delineated when the as-built was prepared or QC reviewed *

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e e Attachment Page 2

3. THE CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED *

• 1. Procedures BWP-8 and BWP-10 were implemented to provide field identi-fication and documentation for all masonry walls. The inspections that had been performed utilizing these procedures had been completed prior to the NRC Inspection of June 17-18, 1981 and were reviewed by the NRC Inspector as indicated in Item 5 of NRC Report Nos. 50-280/81-18 and 50-281/81-18.

2. The as-built details for walls lC-18-4-1, lC-18-4-2 and lC-18-4-3 were corrected, reviewed by Quality Control, reevaluated for structural adequacy and found to be acceptable. As-builts of the other walls, which were similar, with typical notes and details were rereviewed and found to be acceptable. All work on this effort performed by the QC Inspector who reviewed the as-builts on the above walls was rereviewed and found to be acceptable. The as-built discrepancies of these walls is an isolated case and does not constitute a breakdown in the QA program.

4. CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS.

1. Procedures have been prepared and are being followed for the work on IE Bulletin 80-11. Additional procedures will be prepared, approved, and implemented as the need arises.

2. The importance of accurate as-built drawings has been stressed and will be reiterated for any additional as-built drawings which may

• 5.

be required

• THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED.

1. The identification of masonry walls in the vicinity of safety-related equipment was completed prior to the NRC Inspection of June 17-18, 1981. Inspection procedures and results were reviewed with the NRC Inspector.

2. Actions taken to correct the as-built discrepancies and review the as-built program as described in item 3 were completed prior to June 25, 1981.

Since corrective actions have been completed for these items, we consider full compliance to have been achieved and no further corrective action required *