ML18152B321
| ML18152B321 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 12/09/1988 |
| From: | Cartwright W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| 88-765, NUDOCS 8812200170 | |
| Download: ML18152B321 (7) | |
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VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261
~.R.CABTWRIOHT VICE PRESIDENT NuCLEA.R December 9, 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:pmk Docket Nos.
License Nos.
NRC INSPECTION REPORT NOS. 50-280/88-28 AND 50-281/88-28 REPLY TO A NOTICE OF VIOLATION 88-765 50-280 50-281 DPR-32 DPR-37 We have reviewed your letter of November 10, 1988 in reference to the inspection conducted at Surry Power Station from June 5 to July 30, 1988 and reported in Inspection Report Nos.
50-280/88-28 and 50-281/88-28.
Our response to the violation described in the Notice of Violation is provided in Attachment I.
Payment of the assessed civil pena 1 ty is provided in Attachment II.
We have no objection to this inspection report being made a matter of public disclosure.
If you have any further questions, please contact us
- Attachments 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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NRC COMMENT:
e RESPONSE TO NOTICE OF VIOLATION REPORTED DURING THE NRC INSPECTION FROM JUNE 5 TO JULY 30, 1988 e
INSPECTION REPORT NOS. 50-280/88-28 AND 50-281/88-28 During the Nuclear Regulatory Commission (NRC) inspection conducted between the period of June 5 to July 30, 1988, a violation of NRC requirements was identified.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix. C ( 1988),
the Nuclear Regulatory Commission proposes a civil penalty pursuant to Section 234 of the Atomic Energy Act of 1954, as amended (Act),
42 U.S.C.
- 2282, and 10 CFR 2.205.
The particular violation and associated civil penalty are set forth below:
10 CFR 50, Appendix B, Criterion V, as implemented by the licensee's Topical
- Report, VEP 1-5A, requires that activities affecting quality shall be prescribed by documented procedures of a type appropriate to the circumstances and shall be accomplished in accordance with these procedures.
The procedures shall include appropriate quantitative or qualitative acceptance criteria
- for determining that important activities have been satisfactorily accomplished.
Contrary to the above, maintenance and modification activities affecting quality were either accomplished without adequate procedures or acceptance criteria to assure adequate cleanliness and foreign material.
exclusion control or such procedures and acceptance criteria were not prQperly implemented.
Specific examples include:
(1)
In June 1988, the 1icensee found foreign material in the Unit 1 inside recirculation spray pump IA test strainer, both Unit 2 inside recirculation spray pump containers, and both Unit 2 low head safety injection pump suction lines.
The foreign material which resulted from various inadequate maintenance and modification activities included screws, nuts, pieces of metal, wire, various non-metallics, one angle grinder head, and one ten inch wrench *
(2).During the April - June 1988 Unit 1 refueling outage, the following modifications were accomplished on safety-related systems without specification or assurance of cleanliness or foreign material exclusion prior to system closure:
(a)
(b)
(c)
Design Change (DC) 88-01-1, "Inside Recirculation Spray Pump Full Flow Test Line";
Design Change (DC) 87-22-1, TIReplacement of Containment Recirculation Spray Coolers";
Design Change (DC) 86-13-1, "R.G.
1.97 -
Containment Spray Flow and Pressurizer Heater Status."
(3)
In April 1988, the following work orders were accomplished in the Unit 1 containment sump on a safety-related system without procedures, controls, or specification of cleanliness or foreign material exclusion requirements:
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(a)
(b) e e
Work Order Job Number 3800062569, "Remove RS Sump Grating,"
4/18/88; Work Order Job Number 3800062573, "Inst RS Sump Blnk (Sump)
PT-16.4, 11 4/18/88.
(4)
On July 5, 1988, using Special Test Procedure 1-ST-214, "Operability of IRS Pumps," system and test spoolpieces were removed and installed on the Unit 1 inside recirculation pump.
The procedure did not specify verification that cleanliness or foreign material exclusion was maintained during the reassembly of the system, nor were the flange ends of the system spoolpiece on the discharge side blanked as required by the procedure.
(5)
During the fall, 1986, Unit 2 refueling outage, the following safety-related work orders were accomplished without procedures and controls to assure cleanliness or material accountability control in the containment sump:
(a)
Work Order Job Number (WOJN) 3800040809, 11Rem./Inst. RS Sump Grating," dated 10/10/86.
(b)
WOJN 3800040816, "Inst/Remv 12 11 Suet Fng Pen 68, 11 dated 10/10/86.
(c)
WOJN 3800040817, "Inst/Remv Suet Fng Pen 69, 11 dated 10/10/86.
(d)
WPJN 3800046068, "Inst. RS Sump Grating," dated 11/24/86.
This is a Severity Level III violation (Supplement I).
Civil penalty - $50,000. _
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RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-280/88-28 AND 50-281/88 1)
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION:
The violation is correct as stated.
- 2)
REASONS FOR THE VIOLATION:
The examples cited in the violation resulted from the failure to implement an adequate foreign material exclusion program for plant maintenance and modifications.
Additional contributing factors which precluded timely identification_ of the containment sump debris included the lack of a containment sump and screen inspection procedure and the absence of periodic flow testing of the inside recirculation spray (IRS) pumps due to the original design pipe configuration.
- 3)
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:
Immediate corrective actions specific to the containment sump debris issue included the following:
- 1) cl~aning of both the Unit 1 and 2
- 2) repair and replacement of the sump screens, 3)_ inspection of the IRS, outside recirculation spray (ORS),
and low head safety injection (LHSI) pumps*
suction piping, and
- 4) evaluation of the operability of the IRS, ORS, and LHSI pumps subjected to the debris.
Generic corrective actions included revision of construction work pro.cedures to include appropriate cleanliness constraints to ensure that systems which have been opened for construction will remain free of foceign objects.
- Also, the nuclear engineering.standard for the preparation of design change packages (DCP) has been revised to provide direction for referencing the applicable construction procedures noted above in DCPs.
In addition, the Superintendent of Maintenance issued a standing order to maintenance personnel which provides directions to ensure that foreign material is prevented from entering a system or component during the performance of maintenance activities. The standing order addresses the use of temporary covers for openings, 4the posting of personnel at openings that cannot be covered, the performance of visual inspections, as well as additional compensatory measures.
The standing order will remain in effect throughout the present Unit 1 and 2 outages.
At the completion of the outages, the requirements of* the standing order will be incorporated into a station administrative procedure.
To ensure that personnel were adequately informed of the cleanliness issue and management's expectations in this area, training sessions were conducted for maintenance* and contractor personnel to describe the previous cleanliness problems and to specify the requirements for maintaining cleanliness during ongoing and future work activities.
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- 4.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
As noted above, the requirements of the Maintenance Department's standing orders will be incorporated into a station administrative procedure. Applicable maintenance procedures will also be revised to include specific cleanliness statements/steps as part of the overall station procedure upgrade program.
In addition, a technical specification change will be submitted to provide for a periodic surveillance of the containment sumps.
- 5.
THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
The completed corrective actions are sufficient to maintain foreign material control for work activities in progress until the long term corrective actions are completed.
The long term corrective actions are as follows:
- 1) the station administrative procedure will be revised by February 28, 1989;
- 2) the applicable maintenance procedures will be revised in concert-with the procedure upgrade program previously committed to the NRG in a letter dated July 13, 1988, (Serial No.88-387); and, 3) the Technical Specification change request will be submitted by January 31, 1989.
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