ML18153A875
| ML18153A875 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 02/25/1994 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 94-016A, 94-16A, NUDOCS 9403090038 | |
| Download: ML18153A875 (4) | |
Text
VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 February 25, 1994 U. S. Nuclear Regulatory Commission Serial No.:
94-01 SA Attn: Document Control Desk Washington, D. C. 20555 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 SPSN AS/GDM R2 Docket Nos.:
50-280 50-281 License Nos.:
DPR-32 DPR-37 SUPPLEMENTAL RESPONSE TO A NOTICE OF VIOLATION NRC INSPECTION REPORT NOS. 50-280/93-26 AND 50-281 /93-26 In response to your February 10, 1994 letter, a supplement to our initial response dated January 28, 1994 (Serial No.94-016) is attached. It provides additional detail regarding the reason for the violation described in Inspection Report Nos. 50-280/93-26 and 50-281 /93-26 and subsequent corrective actions that have been taken.
Should you have any questions or comments, please contact us.
Attachment cc:
Regional Administrator U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, N. W.
Suite 2900 Atlanta, Georgia 30323 Mr. M. W. Branch NRC Senior Resident Inspector Surry Power Station
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REPLY TO A NOTICE OF VIOLATION NBC INSPECTION CONDUCTED NOVEMBER Z - DECEMBER 4, 1993 SURRY POWER STATION UNITS 1 AND 2 IN~PECTION REPORT NOS. 50-280/93-26 AND 50-281 /93-26 NRC COMMENT:
"During an NRC inspection conducted on November 7 through December 4, 1993, a violation of NRC requirements was identified.
In accordance with the "General Statement of Policy and Procedure for. NRC Enforcement Actions," 1 o CFR Part 2, Appendix C, the violation is listed below:
1 O CFR 50, Appendix B, Criterion Ill, as implemented by Operational Quality Assurance Program Topical Report (VEP 1-SA, Section 17.2.3), collectively require that measures be established to assure that the design basis as specified in the license application are correctly translated into specifications, drawings, procedures, and instructions.
Section 2.3.1.2.2 of the Updated Final Safety Analysis Report requires that the two emergency service water pump building doors be equipped with removable watertight seal plates to protect against flooding when the possibility of a flood is anticipated.
Contrary to the above, the seal plates installed in front of the emergency service water pump building doors on August 31, 1993, were not watertight. The seal plates were installed to protect the building against the potential for flooding when Hurricane Emily was projected to be in the area.
. This is a Severity Level IV Violation (Supplement I)."
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REPL V TO A NOTICE OF VIOLATION NBC INSPECTION CONDUCTED NOVEMBER Z - DECEMBER 4, 1993 SURRY POWER STATION UNITS 1 AND 2 INSPECTION REPORT NOS. 50-280/93-26 AND 50-281/93-26
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Reason for the Violation. or. if Contested, the Basis for Disputing the.
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Violation The violation occurred due to an inadequate procedure that provides preparation requirements for abnormal weather conditions. Section 2.3.1.2.2 of the UFSAR states that the ESW pump house doors will be equipped with removable watertight seal plates to protect the ESW pump diesels against flooding when the possibility of a flood is anticipated.
Procedure O-AP-37.01, Abnormal Environmental Conditions, directed installation of the seal plates but did not provide information for ensuring the seal plates were completely watertight.
The procedure had been upgraded on March 28, 1991 to improve site preparations in anticipation of a hurricane. The procedure provided direction to the operations' staff and included a requirement for installing seal plates on the ESW pump house doors. However, the need for guidance to the maintenance staff was not recognized.
Corrective Steps Which Have Been Taken and the Results Achieved After it was determined that the ESW pump house door seal plates were not completely watertight as installed on August 31, 1993, a station Deviation Report was submitted. An engineering walkdown and a review of the installation *and the need for watertightness of the seal plates were performed. Initial engineering evaluations determined that the seal plates as installed would result in only minor inleakage with no effect on the operability of the ESW pump diesels. Pending
- completion of engineering reviews and corrective actions, plastic sheeting and sandbags were staged in the ESW pump house to augment the seal plates.
Further engineering evaluation has determined that it is not necessary for the seal plates to be completely watertight.
Measurements were made and a
- calculation was performed to determine the consequences of inleakage. The engineering evaluation determined that the seal plates are only required to limit inleakage such that operability of the ESW pump diesels and their support equipment would not be affected. Based on this evaluation and with no further operator actions, the seal plates as installed on August 31, 1993 were determined to be adequate for limiting inl~akage such that the ESW pump diesels and support equipment would remain operable during the design base hurricane. A safety evaluation was also completed to document the acceptability of the modified design basis requirements.
In addition, the procedure for abnormal weather conditions was revised to reference a new maintenance procedure that has been implemented to provide the necessary detailed instructions to ensure that installation of the ESW pump house door seal plates restricts inleakage to within acceptable limits.
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Corrective Steps That Will be Taken to Avoid Further Violations Based on the engineering and safety evaluations discussed above, a UFSAR change request has been prepared to clarify the flooding protection requirements and capabilities of the ESW pump house door seal plates.
As we have described in previous correspondence, considerable progress has been achieved in improving the quality of the UFSAR. Management has held training sessions with plant operations, procedures and engineering personnel to increase their sensitivity to compliance with the UFSAR. Similar sessions will be held with maintenance personnel.
When deviations associated with the UFSAR are discovered, they will be documented and evaluated in accordance with our corrective action program. A
- timely evaluation of their safety signif.jcance will be completed and actions initiated based on the conclusions and recommendations of the evaluation.
The Date When Full Compliance Will be Achieved Full compliance was achieved when the safety evaluation that documented the acceptability of the modified design basis and the procedure changes that address seal plate installation were approved. The UFSAR change will be completed and submitted to the NRC in the next UFSAR revision in accordance with the schedule provided in 10 CFR 50.71 (e).