ML18149A445
| ML18149A445 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 11/13/1986 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| 86-688, NUDOCS 8612030539 | |
| Download: ML18149A445 (4) | |
Text
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VIRGINIA ELECTRIC AND PowER CoMPANY RICHMOND, VIRGINIA 23261 W. L. STEWART VICE PRESIDENT NUCLEAR OPERATIONS November 13, 1986 Dr. J. Nelson Grace Regional Administrator Region II U. S. Nuclear Regulatory Commission Suite 2900 101 Marietta St., N.W.
Atlanta, Georgia 30323
Dear Dr. Grace:
VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNIT NOS. 1 AND 2 Serial No.:
NO/WDC:pms Docket Nos.:
License Nos.:
NRC INSPECTION REPORT NOS. 50-280/86-20 AND 50-281/86-20 86-688 50-280 50-281 DPR-32 DPR-37 We have reviewed your letter of October 14, 1986, in reference to the inspection conducted at Surry Power Station on August 3 -
September 6, 1986, and reported in Inspection Report Nos.
50-280/86-20 and 50-281/86-20. Our response to the Notice of Violation is addressed in the attachment.
We would like to request your reassessment of the severity level classification for this Notice of Violation. After a detail review of this event, we feel that a failure to adequately document a safety-related activity does not have more than minor safety or environmental significance. Thus, we believe that the violation should be classified as a severity level V violation.
We have no objection to this inspection report being made a matter of public disclosure.
If you have any further questions, please contact us.
Very truly yours,
~t~~A1 Attachment 8612030539 861113 PDR ADOCK 05000280 G
\\ '-*
cc:
Mr. Lester S. Rubenstein, Director PWR Project Directorate No. 2 Division of PWR Licensing-A Mr. W. E. Holland NRC Senior Resident Inspector Surry Power Station Mr. Chandu P. Patel NRC Surry Project Manager PWR Project Directorate No. 2 Division of PWR Licensing-A
NRC COMMENT:
RESPONSE TO NOTICE OF VIOLATION ITEM REPORTED DURING NRC INSPECTION CONDUCTED ON AUGUST 3 - SEPTEMBER 22, 1986 INSPECTION REPORT NOS. 50-280/86-20 AND 50-281/86-20 During the Nuclear Regulatory Commission (NRC) inspection conducted on August 3
- September 6, 1986, a violation of NRC requirements was identified.
The violation involved failure to provide detailed instructions in maintenance procedures for corrective maintenance of safety-related equipment.
In accordance with the 11General Statement of Policy and Procedure for NRC Enforcement Actions, 11 10CFR Part 2, Appendix C (1986), the violation is listed below:
Technical Specification 6.4.A requires that detailed written procedures with appropriate check-off lists and instructions shall be provided for preventative or corrective maintenance operations which would have an effect on the safety of the reactor.
Maintenance procedures MP-RS-043, 11 Corrective Maintenance Procedure for Recirculating Spray Heat Exchanger Repairs," and MMP-C-G-102, 11Corrective Maintenance Procedure for Expansion Joints in General," provide instructions for the repair of leaking tubes in the heat exchanger and removal of expansion joints on the service water side of the heat exchanger to allow tube plugging, respectively.
Contrary to the above, in the instances cited below, maintenance procedures used for the repair of Unit 2 Recirculation Spray Heat Exchanger 118 11 during the period of July 23-27, 1986, lacked detailed instructions, were not fully followed, and consequently did not provide adequate documentation to show that the work associated with the repair of a safety-related component was accomplished in a quality manner.
- 1. Maintenance procedure MP-C-RS-043 lacked sufficient details for performing the work and did not provide adequate documentation to show that proper equipment and controls were used for pressure testing of the heat exchanger, that proper system retesting had been accomplished, and that the system was properly restored.
- 2.
Maintenance procedure MMP-C-G-102, did not provide adequate documentation to show that inspection for foreign objects and debris in the heat exchangers was verified and that proper system retesting had been accomplished.
This is a Severity Level IV violation (Supplement 1), and applies to Unit 2.
Response
- 1.
Admission or denial of the alleged violation:
The violation is correct as stated. However, as stated in the inspection report, the work and testing associated with the Recirculating Spray Heat Exchanger was completed adequately.
Only detailed documentation of the testing and system restoration was missing.
- 2.
Reason for the violation:
The violation resulted from procedural deficiencies which failed to ensure that the work, which was adequately performed, was documented.
- 3.
The corrective steps that have been taken and the results achieved:
The procedures were deviated prior to reuse and detailed steps were added to properly document the work performed.
- 4.
The corrective step that will be taken to avoid further violations:
Mechanical Maintenance Procedures MMP-C-RS-043 and MMP-C-G-102 are being revised to provide the necessary details.
Use of these procedures prior to issue of the revision will be deviated to include required steps for documentation.
- 5.
The date when full compliance will be achieved:
Full compliance will be achieved by January 31, 1987.