ML18139B760
| ML18139B760 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 02/10/1982 |
| From: | Leasburg R VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML18139B757 | List: |
| References | |
| 011, 11, NUDOCS 8203020331 | |
| Download: ML18139B760 (7) | |
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VIRGINIA ELECTRIC AND PowER CoMP~Y{'.:;~.;'~r-R~,qJg!J.*;
RICHMOND., VIRO):NIA 2 3 2 61
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- 4 Q R.H.LEA.SBURO VICE PB.EBIDENT NUCLEAR 0PEBATlONS February 10, 1982 Mr. James P. O'Reilly Regional Administrator U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303
Dear Mr. O'Reilly:
Serial No. 011 NO/RMT:acm Docket Nos. 50-280 50-281 License Nos. DPR-32 DPR-37 We have review~d your letter of January 4, 1982 in reference to the inspection conducted at Surry Power Station between December 7 and December 11, 1981 reported in IE Report Nos.
50-280/81-32 and 50-281/81-32.
Our responses to the specific infractions are attached.
We have determined 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.
The information contained in the attached pages is true and accurate to the best of my knowledge and belief.
Attachment cc:
Mr. Steven A. Varga, Chief Operating Reactors Branch No. 1 Division of Licensing
- --;--e;-- -
Very truly yours, OL S*J::1
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R. H. Leasburg
-.-8203020331 820223 PDR ADOCK 050.00 280 G
PDR.
RESPONSE TO NOTICE e VIOLATION SURRY POWER STATION REPORT NOS. 50-280/81-32 AND 50-281/81-32 e
Attachment Page 1 Serial No. Oll License Condition Paragraph 3. I requires the licensee to complete the fire protection modifications identified in Paragraphs 3.1.1 through 3.1.30 of the NRG' s Fire Protection Safety Evaluation Report (FPSER) dated September 19, 1981, in accordance with the schedule in Table 3.1 of the FPSER.
If any modifications could not be completed on schedule the licensee was to submit a report explaining the circumstances and purpose, for NRG approval, a revised schedule.
Contrary to the above, the licensee, as of December 11, 1981, had not completed the following modifications which were required to be completed by October 1980 and had not requested a revised completion schedule:
- 1.
Although FPSER Paragraph 3.1.11.(l)(b) requires the plant's fire doors to be provided with electrical supervision or maintained closed by either being locked and inspected weekly, provided with automatic release mechanism and inspected monthly, or provided with self-closing mechanism and inspected daily to verify that the doors are in the correct position, the licensee had not provided electrical supervision for the fire doors nor was an inspection program implemented to inspect the 17 locked fire doors weekly and the 22 self-closing doors daily.
- 2.
Although FPSER Paragraph 3.l.ll.(12)(b) requires the ventilation openings in the lube oil storage room to be upgraded by installing three-hour fire-rated dampers, the licensee had not installed three-hour fire dampers in these openings.
- 3.
Although FPSER Paragraph 3.1.12.(4) requires three-hour fire-rated dampers to be installed in the ventilation duct between the two fire pump rooms, the licensee had not installed fire dampers in the two duct openings in the wall between the two pump rooms.
- 4.
Although FPSER Paragraph 3.1.15.(3) requires the floor drains in the diesel driven fire pump room to be diked to prevent the spread of fuel oil to the motor driven fire pump via the drain system, the licensee had not provided dikes around the diesel pump room floor drains.
- 5.
Although FPSER Paragraph 3.1.24.(l)(f) requires the licensee to verify that all penetrations in the walls of the mechanical equipment room No. 3 were sealed to have a fire rating at least equivalent to the fire hazards described in the licensee's fire hazards analysis report or upgrade the penetration seals to provide a fire resistance equal to the fire severity on both sides of the barrier up to a maximum of three hours, (the licensee had not provided a fire damper in the supply air ventilation opening into the equipment room from the turbine building.)
This is a Severity Level IV Violation (Supplement I.D.3).
Each item shown in the above notice will be addressed separately in the following pages.
NRG COMMENT Attachment Page 2 Serial No. 011
- 1.
Although FPSER Paragraph 3.1.11.(l)(b) requires the plant's fire doors to be provided with electrical supervision or maintained closed,by either being locked and inspected weekly, provided with automatic release mechanism and inspected monthly, or provided with self-closing mechanism and inspected daily to verify that the doors are in the correct position, the licensee had not provided electrical supervision for the fire doors nor was an inspection program implemented to inspect the 17 locked fire doors weekly and the 22 self-closing doors daily.
RESPONSE
- 1.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION.
The violation is partially correct as stated.
The FPSER 3.1.11 Fire Doors states:
(1) Administrative controls will be provided to assure the effectiveness of other fire doors leading to safety-related areas as follows:
(a) Fire doors will be inspected semi-annually to verify that self-closing mechanisms,and latches are in good working order (4.9.1).
(b) Fire doors will be provided with electrical supervision from the control room or maintained closed by one of the following:
0 locked closed and inspected weekly to verify that doors are in the closed position.
The fire brigade commander will have ready access to keys of all locked doors (4.9.1).
0 provided with automatic release mechanisms and inspections monthly to verify that the doorways are free of obstructions (4.9.1).
0 provided with self-closing mechanism and inspected daily to verify that they are in the closed posi-tion (4.9.1).
Of the 38 fire doors referenced, only 23 are fire doors leading to safety-related areas.
Of these 23, fourteen are electrically supervised or provided with automatic release mechanisms, and are inspected monthly.
Of the nine remaining, five are locked closed and inspected weekly to verify that the doors are in the closed position.
The other four doors have self-closing mechanisms and should have been inspected daily to verify they were in the closed position.
(2) THE REASONS FOR THE VIOLATION IF ADMITTED.
Attachment Page 3 Serial No. 011 The four doors not inspected daily provide access between adjacent safety-related areas.
Our interpretation of the SER was that only doors providing access to safety-related areas, not between safety-related areas, were addressed.
These doors were inspected monthly.
(3) THE CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND RESULTS ACHIEVED.
Weekly and daily performance tests (PT's) have been established to verify and document that the doors have been inspected as required.
(4) CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS.
The corrective steps which have been tak~n are adequate to preclude further violations.
(5) THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED.
Full compliance was achieved on.January 30, 1982.
NRC COMMENT
- 2.
Although FPSER Paragraph 3.1.11.(12)(b) requires the ventilation openings in the lube oil storage room to be upgraded by installing three-hour fire-rated Dampers, the licensee had not installed three-hour fire dampers in these openings.
RESPONSE
(1) ADMISSION OR DENIAL OF THE ALLEGED VIOLATION:
The Notice of Violation is correct as stated.
(2) REASONS FOR THE VIOLATION Further review conducted after the issue of the Fire Protection Evaluation Report revealed that the area adjacent to the lube oil storage area fire wall was completely free of any combustibles including cables.
This "free of combustibles" area was well beyond the 20 foot distance regarded in Appendix Ras sufficient distance for redundant cable.
Vepco failed to follow up with a request for re-review of the NRC position.
(3) CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED:
Vepco will install three hour dampers in the lube oil storage room.
A design effort is now underway to correct the deficiency.
(4) CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
Vepco will re-review the FPSER and make a physical verification that all modifications are complete.
(5) DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Dampers will be installed by May 1, 1982.
NRC COMMENT Attachment Page 4 Serial No. 011
- 3.
Although FPSER Paragraph 3.1.12.(4) requires three-hour fire-rated dampers to be installed in the ventilation duct between the two fire pump rooms, the licensee had not installed fire dampers in the two duct openings in the wall between the two pump rooms.
RESPONSE
(1) ADMISSION OR DENIAL OF THE ALLEGED VIOLATION:
The Notice of Violation is correct as stated.
(2) REASONS FOR THE VIOLATION:
During the period of time the designer was preparing the package which would be used to modify the fire dampers, the ventilation duct was removed and, therefore, no dampers appeared to be necessary.
(3) CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED:
The required dampers will be installed. A design effort is now underway to correct the deficiency.
(4) CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
Vepco will re-review the FPSER and make a physical verification that all modifications have been completed.
(5) DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Dampers will be installed by May 1, 1982.
- 4.
NRC COMMENT Although FPSER Paragraph 3.1.15.(3) requires the floor drains in the diesel driven fire pump room to be diked to prevent the spread of fuel oil to the motor driven fire pump via the drain system, the licensee had not provided dikes around the diesel pump room floor drains.
RESPONSE
(1)
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION The Notice of Violation is not correct as stated.
~
Attachment Page 5 Serial No. 011 (2) REASONS FOR THE VIOLATION:
Vepco letter 354G/061478, dated January 14, 1980, proposed covers would be installed over the floor drains.
NRC letter dated December 18, 1980 approved and closed this item.
The covers were fabricated and bolted to the drains.
However, during a maintenance operation, these covers had been removed.
(3) CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED:
Vepco will replace the drain covers and they will be marked with an appropriate caution against removing them.
(4) CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
The corrective steps noted above will preclude further violations.
(5) DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Full compliance will be achieved by March 1, 1982.
NRC COMMENT
- 5.
Although FPSER Paragraph 3.1.24.(l)(f) required the licensee to verify that all penetrations in the walls of the mechanical equipment room No. 3 were sealed to have a fire rating at least equivalent to the fire hazards described in the licensee's fire hazards analysis report or upgrade the penetration seals to provide a fire resistance equal to the fire severity on both sides of the barrier up to a maximum of three hours, the licensee had not provided a fire damper in the supply air ventilation opening into the equipment room from the turbine building.
RESPONSE
(1) ADMISSION OR DENIAL OF THE ALLEGED VIOLATION:
The Notice of Violation is correct as stated.
(2) REASON FOR THE VIOLATION:
A Review of the supply air ventilation opening which was conducted during the damper modifications revealed that there was a very low potential fire loading in the vicinity of the opening (two cable trays) and the possibility of inadvertant closure of the supply air fire damper and the resultant "starving" of cooling air to the equipment in the room was considered to outweigh the concern for fire passing through the opening.
The NRC was not requested to re-review the situation.
The cooling air concern is currently not viewed as not being a critical concern.
(3) CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED:
The required damper will be installed. A design effort is now underway to correct the deficiency.
Attachment Page 6 Serial No. 011 (4) CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
Vepco will re-review the FPSER and make a physical verification that all modifications are complete.
(5) DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Dampers will be installed by May 1, 1982.
APPENDIX B NOTICE OF DEVIATION NRC COMMENT Virginia Electric and Power Company's Fire Protection Systems Review of July 1, 1977 Section III.C Fire Area 28C (Page 111-147) states that initiation of the carbon dioxide system pneumatically closes the ventilation dampers in the fire walls enclosing the oil tank room.
Contrary to the above, initiation of the carbon dioxide system will not pneumatically close the ventilation fire dampers.
- 1)
DESCRIPTION OF CORRECTIVE ACTIONS THAT HAVE BEEN OR WILL BE TAKEN.
"Blow-off" heads have been added and "blow-off" chains have been installed so that the carbon dioxide system will pneumatically close the ventilation fire dampers.
- 2)
CORRECTIVE ACTIONS WHICH WILL BE TAKEN TO AVOID FURTHER DEVIATIONS.
None is required.
- 3)
DATE CORRECTIVE ACTIONS WERE OR WILL BE COMPLETED.
Corrective actions were completed on January 14, 1982.