ML18152A792
| ML18152A792 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 03/25/1988 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| 88-109, NUDOCS 8803310012 | |
| Download: ML18152A792 (5) | |
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VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 W. L. STEWART VICE PBESIDENT NUCLEAB 0PEBATlONS March 25, 1988 U. S. Nuclear Regulatory Commission Attn:
Document Control Desk Washington, D.C.
20555 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 Serial No.
NO/GDM:pms Docket Nos.
License Nos.
NRC INSPECTION REPORT NOS. 50-280/88-01 AND 50-281/88-01 88-109 50-280 50-281 DPR-32 DPR-37 We have reviewed your letter of February 25, 1988 in reference to the inspection conducted at Surry Power Station on January 3-31, 1988 and reported in Inspection Report Nos. 50-280/88-01 and 50-281/88-01.
Our response to the two violations described in the Notice of Violation is provided 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
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e RESPONSE TO THE NOTICE OF VIOLATION ITEMS REPORTED DURING NRC INSPECTION CONDUCTED ON JANUARY 3-31, 1988 INSPECTION REPORT NOS. 50-280/88-01 AND 50-281/88-01 During the Nuclear Regulatory Commission (NRC) inspection conducted between the period of January 3 to January 31, 1988, violations of NRC requirements were identified.
The violations involved failure to follow procedure during performance of surveillance testing by plant operators, and failure to provide adequate procedure in the implementation of design control over substitution of material for safety-related components.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions", 10 CFR Part 2, Appendix C (1986), the violations are listed below:
A.
Technical Specification 6.4 requires detailed written procedures with appropriate check-off lists and instructions shall be provided and fo 11 owed for operation and testing of components and systems i nvol vi ng nuclear safety of the station.
Technical Specification 6.4 further requires temporary changes to applicable procedures may be made, provided such changes are approved prior to implementation.
Contrary to the above, detailed written procedures were not followed by either complyfng with the steps or implementing a change prior to proceeding.
This resulted in the failure to properly establish the initial conditions listed below:
- 1.
On January 9, 1988, Periodic Test Procedure 1-PT-29.1, "Turbine Inlet Valve Test", was performed without meeting initial condition 3.5 of the test.
Initial condition 3.5 required the rod control system to be in the automatic control mode.
The test was performed with the rod control system in the manual mode.
- 2.
- On January 9. and 23, 1988, Unit 1 and Unit 2 respectively, were ramped down from 100% to less that 75% power in accordance with Operations Procedure OP-2.1. 2, "Decreasing Power From Existing Power Level to 2%", without meeting initial condition 3.4 of the procedure.
Initial condition 3.4 required the portable narrow range steam generator level indicators to be in place and operating.
3..
On January 9, 1988, Unit 1 was ramped down from 100% to less than 75%
power in accordance with Operations Procedure OP-2.1.2, Decreasing Power From Existing Power Level to 2%", without performing steps
- 3. 7.1 through 3. 7. 4 of the procedure.
These steps required that jumpers be installed to remove the seal-in function from controllers of moisture separator reheater steam supply isolation valves.
This is a Severity Level IV Violation (Supplement 1), and applies to both units.
e B.
10 CFR 50, Appendix B, Criterion V as implemented by the licensee's accepted Quality Assurance Program (Virginia Power Topical Report VEP-1-5A, Section 17.2.5), requires that activities affecting quality shall be prescribed by procedures appropriate to the circumstances.
Contrary to the above, as of January 3, 1988, measures for the selection and review for* suitability of application of materials, parts, and equipment that are essential to the safety-related functions of components were not adequately prescribed by procedures.
This condition contributed to the failure mechanism, which was identified in December, 1987, of safety-related valve 2-CH-MOV-2289B.
This is a Severity Level V Violation (Supplement 1), and applies to both units.
RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-280/88-01 AND 50-281/88-01 ITEM A
- 1.
Admission or Denial of the Alleged Violation The violation is correct as stated.
- 2.
Reason for the Violation The reason for the violation was a misunderstanding by operations personnel of the signtficance of properly completing or documenting deviations to initial conditions.
- 3. Corrective Steps Which Have Been Taken and the Results Achieved The station policy regarding procedure deviations was modified to strengthen the steps required prior to procedure changes.
Any change to the purpose, initial conditions, or precautions and limitations sections of the procedure is now defined as a change of intent and requires prior SNSOC approval in order to make the change. A memorandum from the station manager to station supervisors was issued highlighting this change.
Furthermore, operations personnel have had face-to-face meetings with the station manager to discuss the examples described in the violation.
The pol icy change was addressed and direction given on the proper use of procedur~s, including the documentation of deviations before the steps are performed.
- 4.
Corrective Steps Which Will Be Taken to Avoid Further Violations Operating procedures are being improved as part of the normal procedure review and revision process in order to ensure and confirm appropriate initial conditions.
- 5.
The Date When Full Compliance Will Be Achieved Full compliance has been achieved.
The policy change regarding adherence to, and proper deviation of, procedures has been fully implemented.
Operating procedure enhancements will be completed by December 31, 1989.
- e RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-280/88-01 AND 50-281/88-01 ITEM B
- 1.
Admission or Denial of the Alleged Violation The violation is correct as stated.
- 2.
Reason for Violation Administrative procedures and department guidelines were not sufficiently explicit with respect to the level of review required when using replacement parts other than the original design for safety related equipment.
- 3.
Corrective Steps Which Have Been Taken and the Results Achieved The maintenance on 2-CH-MOV-2289B. and the parts installation occurred in 1985.
Since that time, significant upgrades in maintenance procedures and philosophies have occurred including extensive Quality Maintenance Team training for mechanics, welders and electricians.
In addition, to preclude a similar occurrence and to ensure proper guidelines, administrative procedure SUADM-M-16, "Operation of the Maintenance Department", was revised on March 3, 1988.
Specifically, a paragraph has been added to the procedure that specifies that if any replacement part on safety related components or equipment described in the UFSAR is not specific original design, construction, or material, then documentation from Engineering is required to justify the substitution.
Any material or part substitution, including plant fabricated parts or materials for safety related equipment, requires proper documentation from Engineering.
Maintenance is also required by administrative procedure (SUADM-M-27) to notify Engineering prior to performing a safety related component repair/replacement.
- 4.
Corrective Steps Which Will Be Taken to Avoid Further Violations No additional steps are needed at this time.
- 5.
The Date When Full Compliance Will Be Achieved Full compliance was achieved on March 3, 1988.