ML18151A015
| ML18151A015 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 08/14/1987 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| 87-447, NUDOCS 8708200280 | |
| Download: ML18151A015 (3) | |
Text
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e VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 August 14, 1987 W. L. STEWART VICE PRESIDENT NUCLEAR OPERATIONS U. S. Nuclear Regulatory Commission Attn:
Document Control Desk*
Washington, D.C.
20555 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS I AND 2 NRC INSPECTION REPORT NOS. 50-280/87-07 AND 50-281/87-07 Serial No.
NO/GDM:pms Docket Nos. :
License Nos.:
87-447 50-280 50-281 DPR-32 DPR-37 We have reviewed your letters of June 17 and July 15, 1987, in reference to the inspection conducted at Surry Power Station on May 4-8, 1987 and reported in Inspection Report Nos. 50-280/87-07 and 50-281/87-07.
Our response to the Notice of Violation is addressed in the attachment
- 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, Attachment cc:
U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, N.W.
Suite 2900 Atlanta, GA 30323 Mr. W. E. Holland NRC Senior Resident Inspector Surry Power Station 8708200280 870814 PDR ADOCK 05000280 G
RESPONSE TO NOTICE OF VIOLATION ITEM REPORTED DURING NRC INSPECTION CONDUCTED ON MAY 4-8, 1987 INSPECTION REPORT NOS. 50-280/87-07 AND 50-281/87-07 NRC COMMENT:
During an NRC inspection conducted on May 4 - 8, 1987, a violation of NRC requirements was reviewed after identification by Virginia Electric and Power Company Licensee _Event Report No. 87-010-00 dated April 10, 1987.
In accor-dance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1987), the violation is listed below:
10 CFR 50.48(b) requires, in part, that all nuclear power plants licensed to operate prior to January 1, 1979, shall satisfy the requirements of 10 CFR Part 50, Appendix R, including specifically,Section III.G, Fire Protection of Safe Shutdown Capability.
Section III.G.2 specifies that, where cables or equipment of redundant trains of systems necessary to achieve and maintain hot shutdown conditions are located within the same fire area outside of primary con-tainment, a means of ensuring that one of the redundant trains remains free of fire damage shall be provided.
Section III. G.3 requires independent of cables, under consideration where requirements of Paragraph an alternative or dedicated shutdown capability systems or components in the specified fire area the protection of systems does not satisfy the G.2.
Contrary to the above, as of March 13, 1987, the power and control cabling for Diesel Generators No. 1 and_ No. 3, the power sources for the Unit 1 alternative shutdown equipment used to satisfy Section III.G.3, were not independent of the specified design basis fire area.
The cabling, as well as the cabling for the Unit 2 safe shutdown equipment, was routed through the Unit 2
Cable Vault and Tunnel (Fire Area 2), the design basis fire area.
This is a Severity Level III violation (Supplement I).
- /
e e
RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-280/87-07 AND 50-281/87-07
RESPONSE
(1) ADMISSION OR DENIAL OF THE ALLEGED VIOLATION:
The violation is correct as stated.
(2) REASONS FOR VIOLATION:
The violation was the result of inadequate design control procedures which allowed the relocation of the Emergency Diesel Generator (EDG) No. 1 power and control cables through the Unit 2 Cable Vault and Tunnel (CV&T).
It was determined that Design Change (DC)83-39A, "Diesel Generator No.
1 Power Cable.Protection", did not adequately investigate routing for EDG-3 to confirm independence from the U-2 CV&T.
(3) CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:
A fire watch inspected the area at least once per shift to ensure that the probability of a fire starting and developing was as low as possible.
A design package (DC~87-14-3) was initiated to reroute EDG-3 control cables out of the Unit 2
CV&T and run them directly from Emergency Switchgear Room (ESGR) No. 2 to ESGR_No. 1.
This design change has been completed.
A complete review of Appendix "R" related design changes was conducted.
This review identified two discrepancies relating to the routing of cables and/or arit£>nnas for the A and B Appendix "R" telecommunication* repeaters.
Modifications were initiated under Engineering Work Requests (EWRs) and the correction of these discrepancies has been completed.
(4) CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
No further corrective actions are planned.
After 1984, when DC 83-39A was implemented, design control procedures were instituted which would make a similar occurrence unlikely.
Procedures for design changes now require a rigorous review against Appendix R criteria.
Cable block diagrams have now been developed and are maintained as controlled documents.
(5) THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Full compliance has been achieved.