ML18152B260

Responds to NRC 880929 Ltr Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-280/88-30 & 50-281/88-30.Corrective Actions:Station Deviation Rept Answered by Station Engineering on 880812

ML18152B260
Person / Time
Site:	Surry
Issue date:	10/28/1988
From:	Cartwright W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
88-675, NUDOCS 8811070187
Download: ML18152B260 (5)

Text

VIRGINIA ELECTRIC AND POWER COMPANY

• RICHMOND, VIRGINIA 23261 October 28, 1988 U.S. Nuclear Regulatory Commission Serial No.: 88-675 Attn: Document Control Desk NO/GDM:pmk Washington, D.C. 20555 Docket Nos.: 50-280 50-281 License Nos.: DPR-32 DPR-37 Gentlemen:

VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 NRC INSPECTION REPORT NOS. 50-280/88-30 AND 50-281/88-30 We have reviewed your letter of September 29, 1988 in reference to the inspection conducted at Surry Power Station on August 1-5, 1988 and reported in Inspection Report Nos. 50-280/88-30 and 50-281/88-30. Our response to the Notice of Violation is provided in the attachment.

As noted in the attached response, station engineering reviewed the remaining safety and-. relief valves subject to the ASME Section XI testing requirements and identified one additional relief valve (2-SI-RV-2845A) that had not been tested within the five year time frame. This valve was scheduled to be tested during the appropriate refueling outage within the five year test band; however, due to forced and/or extended outages and the use of the 25% grace period to perform testing, the five year test period was exceeded. This valve has been tested during the present Unit 2 refueling outage with satisfactory results. The corrective actions identified in the attached response to the Notice of Violation should prevent a similar occurrence in the future.

We have. no objection to this inspection report being made a matter of public di s cl os ur*e

• If you have any further questions, please contact us.

W. R. Cartwright 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

RESPONSE TO THE NOTICE OF VIOLATION REPORTED DURING THE NRC INSPECTION ON AUGUST 1-5, 1988 INSPECTION REPORT NOS. 50-280/88-30 AND 50-281/88-30 NRC COMMENT:

During the Nuclear Regulatory Commission (NRC) inspection conducted on August 1-5, 1988, a violation of NRC requirements was identified. In accordance with the General Statement of Policy and Procedure for NRC Enforcement Actions,"

10CFR Part 2, Appendix C (1987), the violation is listed below:

10 CFR 50.55a{g)(4)(ii) requires the performance of inservice tests to verify operational readiness of pumps and valves, whose function is required for safety, in accordance with the American Society of Mechanical Engineers Boiler and Pressure Vessel (ASME B&PV) Code Section XI. ASME B&PV Code,Section XI, 1980 Edition Winter 1980 Addenda (80W80), has been identified as the applicable code for inservice testing of pumps and valves.

1) ASME B&PV Code,Section XI, 80W80 Paragraph IWV-3510 as implemented by Administrative Procedure SUADM-M-18, dated March 15, 1988, requires that. .. at each refueling all valves (safety and relief) which have not been tested during the preceding five year period shall be tested.

2) Administrative Procedure SUADM-M-18 dated December 14, 1987, requires that all deviation reports be presented to the Station Nuclear Safety and Operating Committee (SNSOC), for their review and concurrence with the corrective actions completed or planned, in a timely manner.

Contrary to the above, 1) on February 23, 1988, in response to an NRC request for records of completed valve tests, the licensee discovered that relief valve 2-CH-RV-2209 h~d not been tested during the 1985 refueling outage as required. 2) As of August 5, 1988, Deviation Report SZ-88-0099, which was initiated on February 23, 1988, had not been presented to SNSOC for review and concurrence of planned corrective actions. Therefore, opportunities to test the valve since the finding were ignored and no effort was made to evaluate the valve's capability to perform its intended function until such an evaluation was specifically requested by the inspector.

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

.. u

[.

RESPONSE TO THE NOTICE OF VIOLATION INSPECTION REPORT NO. 50-280/88-30 AND 50-281/88-30

1. Admission or Denial of the Violation:

The violation is correct as stated.

2. Reason for the Violation:

Relief valve 2-CH-RV-2209 was scheduled to be tested within the required time frame; however, the test was cancelled due to scheduling constraints without Engineering's concurrence. Station management did not realize the specific test to be performed was to meet ASME Section XI requirements.

The station deviation report was not completed and reviewed in a timely manner due to the failure of station personnel to fully appreciate the significance of the inoperable relief valve.

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

The station deviation report was answered by station engineering on August 12, 1988. An engineering evaluation was performed to assess the consequences of the relief valve opening below its setpoint or failing to open altogether. This review concluded that neither system integrity nor operation would have been detrimentally affected under either condition.

In addition, this valve will be tested during the present refueling outage.

Engineering also reviewed the remaining safety and relief valves subject to the requirements of ASME B&PV,Section XI, 80W80 Paragraph IWV-3510 to ensure they had been tested within the required time frame. One additional valve, 2-SI-RV-2845A, was also identified as having not been tested within the required five year time frame and is discussed in the cover letter.

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

Additional administrative controls will be implemented to assure adherence to the in-service testing schedule of safety and relief valves subject to ASME Sec ti on XI requirements.

• A station procedure wi 11 be prepared to ensure the test frequency of each valve is reviewed prior to each refueling outage. This procedure will also provide a method of tracking test dates, selecting valves to be tested, and notifying station management upon failure to perform a required test in a timely manner. The procedure will be formatted in such a manner to assure that testing of the scheduled valves has been verified prior to final sign-off of the procedure.

The station administrative procedure (SUADM-0-12) that addresses deviation reports is being revised to provide a method for escalating overdue station deviation responses to senior station management for disposition.

Enhancements to the existing station deviation tracking system are also being considered to improve the timeliness of responses.

5. Date When Full Compliance Will Be Achieved:

'J The new tracking procedure for safety and relief valve testing will be prepared and implemented by March 31, 1989. Station administrative procedure SUADM-0-12 will be revised by December 31, 1988 to provide for the escalation of overdue responses to station deviation reports. Any enhancements to the station deviation tracking system will also be completed by this date .