ML18153B804
| ML18153B804 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 07/06/1989 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 89-436, NUDOCS 8907130045 | |
| Download: ML18153B804 (4) | |
Text
,/'
VIRGINIA ELECTRIC AND*POWER.COMPANY
- RICHMOND, VIRGINIA 23261 July 6, 1989 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. 50-280/89-12 AND 50-281/89-12 89-436 R2 50-280 50-281 DPR-32 DPR-37 We have* reviewed yciur letter of June 7, 1989 in reference to the inspection conducted at Surry Power Station on April 10-14 and May 10-12, 1989 and reported in Inspection Report Nos. 50-280/89-12 and 50-281/89-12.
Our response to the violation 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,
[jL ~-e..:t-
- w. L. Stewart
. Senior Vice President - Power 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 8907130045 890706 PDR ADOCK 05000280 Q
Response to Notice of Violation Re§orted in Inspection Report Nos. 50-280/89-12 an 50-281/89-12 During the Nuclear Regulatory Commission (NRC) inspection conducted on April 10-14, 1989 and May 10-12, 1989, a violation of NRC requirements was identified.
In accordance with the 11General Statement of Policy and Procedure for NRC Enforcement Actions, 11 10 CFR-Part 2, Appendix C (1989), the violation is listed below:
10 CFR 50.12 permits requests for exemption from_specific requirements of Appendix R.
Section III.G2(d) requiring redundant cables and equipment be separated by 20 horizontal feet with no intervening combustibles.
An SER dated September 16, 1987 approved Exemption No. 6 which required_ cable tray covers to be installed on cable trays in the vicinity of the cable vault tunnel penetration area of both uni~
containments.
Contrary to the above, on March 10, 1989 a station deviation report was issued identifying several instances where cable tray covers had been found missing.
This is a Severity Level IV violation (Supplement II).
- 1.
Response to Notice of Violation Reaorted in Inspection Report Nos. 50-280/89-12 an 50-281/89-12 Admission or Denial of the Violation:
The violation is correct as stated.
- 2.
Reason for the Violation:
The missing cable tray covers were not reinstalled after construction or maintenance activities because procedures for cable installation did not adequately address cable tray cover reinstallation.
Additionally, the periodic test for verification of cable tray cover installation did not adequately identify where cable tray_covers were required to be installed.
- 3.
Corrective Steps Which Have Been Taken and the Results Achieved:
An engineering evaluation and work procedure has been written to install covers on the affected cable trays.
To date cable tray covers have been restored in the required locations in Unit 1 containment~
The completion of this effort reestablishes Appendix R compliance for cable tray covers, redundant cable separation and fire stops in this fire area.
In addition, the station administrative procedure for preparing Engineering Work Requests has been revised adding instructions which require verification by Quality Control personnel that cable tray covers have been properly reinstalled.
- 4.
Corrective Steps Which Will Be Taken to Avoid Further Violations:
Cable -trays will be marked to indicate whether covers are/are not required.
Required covers for the Unit 2 containment cable trays will be installed prior to Unit 2 restart from the current outage.
The fire areas outside of containment which require cable tray covers will be addressed subsequent to the startup of Units 1 & 2.
In the interim, fire watches will be posted as required in these areas until the necessary cable tray covers have been reinstalled.
Additionally,* new drawings are being developed to show each cable tray and cable tray cover installation requirements.
Applicable station procedures and the Engineering specification for electrical cable installation are being revised to incorporate_ a verification by Quality Control personnel of proper cable tray cover reinstallation. The periodic test that verifies that cable tray covers are properly* install~d is also being revised to specifically list the cable*
trays which require covers and will reference the new station cable tray drawings.
- 5.
Date When Full Compliance Will Be Achieved:*
Cable tray cover reinstallation for Unit 1 containment is complete.
The Unit 2 containment cable tray cover work will be completed prior to restart from the present Unit 2 outage.
The fire areas outside containment which
. require cable tray covers will be addressed by October 31, 1989.
Fire watche,s will be posted in these areas until the necessary covers have been installed.
The applicable station procedures and Engineering specification will be revised by 8/31/89, and the periodic test procedure(s) will be revised by December 31, *1989.
The cable tray markings indicating whether special covers are required will be completed for the Unit 2 in-containment trays prior to Unit 2 startup.
The Unit 1 in-containment trays will be completed during the next refueling outage.
Marking of the Unit 1 and Unit 2 out of containment cable trays will be completed by October 31, 1989.
The new drawings.showing cable trays and cable tray cover requirements will be completed within two months of the respective unit startups.
The completion dates provid~d for mark1ng the cable trays supersede the previous schedule of within two months of our respective unit startups as stated in our letter (Seri~l No.89-337) dated May 9, 1989.
Full. compliance will have been achieved upon completion of the activities delineated in this section.
I