ML18152B219

Responds to NRC 880824 Ltr Re Violations Noted in Insp Repts 50-280/88-29 & 50-281/88-29.Corrective Actions:Instructions Provided to Control Room Operators to Maintain Constant RCS Temp & Pressure Level When Performing RCS Leak Rate Test

ML18152B219
Person / Time
Site:	Surry
Issue date:	09/23/1988
From:	Cartwright W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
88-592, NUDOCS 8810030373
Download: ML18152B219 (3)

Text

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VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261

• September 23, 1988 U.S. Nuclear Regulatory Commission Serial No.88-592 Attn: Document Control Desk NO/GDM:pms Washington, D.C. 20555 Docket Nos. 50-280 50-281 License Nos. DPR-32 DPR-37 Gentlemen:

VIRGINIA ELECTRIC AND POWER COMPANY SORRY POWER STATION UNITS I AND 2 NRC INSPECTION REPORT NOS. 50-280/88-29 AND 50-281/88-29 We have reviewed your letter of August 24, 1988 in reference to the inspection conducted at Surry Power Station on July 18-22, 1988 and reported in Inspection Report Nos. 50-280/88-29 and 50-281/88-29. Our response to 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.

W. R. Cartwri ht Vice President - Nuclear 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

• ~~~0030373 880923 Q ADOCK 05000280 PNU

RESPONSE TO THE NOTICE OF VIOLATION ITEM REPORTED DURING THE NRC INSPECTION ON JULY 18-22, 1988 INSPECTION REPORT NOS. 50-280/88-29 AND 50-281/88-29 NRC COJ91ENT During the Nuclear Regulatory Commission (NRC) inspection conducted on July 18-22, 1988, a violation of NRC requirements was identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions, 11 10 CFR Part 2, Appendix C (1987); the violation is listed below:

Technical Specification 6.4.A.2 requires procedures for calibration and testing of systems involving the nuclear safety of the station. Technical Specification 3.1.C.2 limits the leakage rate of the reactor coolant system from other than controlled sources to less than one gallon per minute.

Contrary to the above, procedures 1 and 2-PT-10, Reactor Coolant Leakage, issued for use in October 1987, contained errors in constants used to correct for changes in pressurizer level and reactor coolant system temperature during the test. These errors could have led to accepting an unacceptable result.

This is a Severity Level IV violation (Supplement I) .

RESPONSE

• 1.

2.

Admission or Denial of the Alleged Violation:

The violation is correct as stated.

Reason for the Violation:

The constant used to correct for changes in average Reactor Coolant System (RCS) temperature during RCS leakage measurements assumed linearity between two average temperatures and their respective pressurizer levels. As such, it did not properly account for variations in overall RCS volume due to changes in average RCS temperature. Furthermore, the distance between pressurizer level taps was incorrectly specified.

In addition, the correction factors used in the calculation of RCS leakage failed to correct for density differences between the pressurizer and volume control tank.

3. Corrective Steps Which Have Been Taken and the Results Achieved:

Instructions were provided to the control room operators to maintain constant RCS temperature and pressurizer level when performing the RCS leak*

rate test. This constraint ensures conservatism of the test results. If temperature and pressurizer level fluctuations occur during performance of the test, the procedure is considered invalid and must be repeated. These measures will remain in effect until the periodic test (PT-10) for calculating the RCS leak rate is revised to include the appropriate correction factors.

4. Corrective Steps Which Will Be Taken to Avoid Further Violations:

• The periodic test procedure (PT-10) for determining the RCS leak rate is being revised to include correction factors for changes in average RCS temperature. This revision will accurately compensate for changes in overall RCS volume due to variation in average RCS temperature.

An addendum to the engineering work sheet will be prepared to document the evaluation of the distance between the pressurizer level taps and the corrected distance will then be factored into future leakage calculations.

In addition~ the PT will be revised to utilize a mass basis for calculating the RCS leak rate. This will eliminate the need to correct for density differences in the pressurizer and volume control tank. The final leak rate results will be converted to a volumetric value for consistency with the Technical Specifications.

5. . The Date When Full Compliance Will Be Achieved:

Full compliance will be achieved prior to the startup of either unit from its current outage.