ML18153B998
| ML18153B998 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 11/08/1989 |
| From: | Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18153B997 | List: |
| References | |
| 50-280-89-24-01, 50-280-89-24-1, 50-281-89-24, NUDOCS 8912050238 | |
| Download: ML18153B998 (3) | |
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I NOTICE OF VIOLATION Virginia Electric and Power Company Surry Power Station Docket Nos. 50-280, 50-281 License Nos. DPR-32, DPR-37 During the Nuclear Regulatory Commission (NRC) inspection conducted on July 30 through September 2, 1989, violations of NRC requirements were identified. In accordance with the 11Genera 1 Statement of Po 1 icy and Procedure for NRC Enforcement Actions, 11 10 CFR Part 2, Appendix C (1989), the violations are listed below:
A.
10 CFR 19.12 requires in part that all individuals working in or frequenting any portions of a restricted area shall be instructed in, and instructed to observe, to the extent within the worker's control, the applicable provisions of Commission regulations for the protection of personnel from exposure to radiation occurring in such areas.
Technical Specification 6.4.8.1.e requires that any individual or group of individuals permitted to enter a high radiation area be provided with a radiation monitoring device which continuously indicates the dose rate in the area.
Technical Specification 6.4.D. requires that radiation control procedures be followed and the company's Radiation Protection Plan, Chapter II, Attachment II-1, requires in item 2 that individuals obey posted, verbal, and written Health Physics (HP) instructions.
HP Procedure 5.3.20, Initiating, Using, Extending, and Terminating an RWP, Section 4.3.1.d, requires checkout of a survey meter and. high radiation area-keys for entry into a high radiation area, if required by RWP.
Contrary to the above, radiological control requirements were not complied with, in that: *
.1.
On August 7, 1989, a contract worker gained entry to a locked high radiation area on the 13' elevation of Unit 2 containment by circum-venting radiation protection postings and barricades without checking out a high radiation area key or obtaining authorization from HP.
- 2.
On August 9, 1989, two contract workers entered a posted high radiation area on the 27' elevation of the Unit 2 containment without a required radiation monitoring device which continuously indicates the radiation dose rate in the area.
This is a Severity Level IV violation (Supplement IV).
8912050238 891108 PDR ADOCK 05000280 G'~
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Virginia Electric and Power Company Surry Power Station 2
I I
Docket Nos. 50-280, 50-281 License Nos. DPR-32, DPR-37 B.
10 CFR 50, Appendix B, Criterion XVI, requires that measures be established to assure that conditions adverse to quality are promptly identified and corrected.
In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.
Contrary to the above, corrective act ion to preclude repetition of significant conditions adverse to quality were inadequate in that:
- 1.
A Notice of Violation issued in November 1988 identified a program-matic breakdown in the controls and procedures used to maintain system foreign material exclusion.
Corrective action was taken through the issuance of Maintenance Standing Order No. 88-1.
This standing order stated that specific requirements were to be documented in corrective maintenance procedures relating to cleanli-ness controls.
In addition, the standing order required that all personnel performing work that opens a safety-related system or component read and sign to acknowledge that they have read the standing order.
During maintenance activities accomplished between July 30 and September 2, 1989, the above standing order requirements were not documented for work on check valves 2-SI-79, 2-SI-81, 2-SI-91, 2-SI-226, and 2-SI-241 as required to ensure foreign material exclusion was being maintained.
- 2.
A Notice of Violation was issued in December 1988 for failure to establish adequate procedures for torquing of fasteners. Corrective action was taken through the issuance of Maintenance Standing Order No. 89-1.
This standing order stated that all torque values listed in procedures will be verified by maintenance engineering prior to torquing and that the maintenance engineer will initial the torque value in the procedure. Also, the standing order allowed for torque value verification by telephone if the engineering represent-ative was not on site, provided that this verification was noted on the work order or procedure.
During maintenance activities accomplished between July 30 and September 2, 1989, the above stand-ing order requifements were not documented as required for work on check valve 2-SI-91 and flow element 1-SI-FE-1946, which resulted in the valve hinge bracket bolts for 2-SI-88 and 2-SI-91 being over-torqued during these maintenance activities.
~
- 3.
A Notice of Violation was issued in August 1988 for failure to provide adequate procedures for correct assembly of flanges containing non-reversible orifices which were used for flow indication.
Corrective actions for this violation included extensive walkdowns to identify incorrectly installed orifices and issuance of a new procedure to specifically address correct orientation installation of flow orifices.
During walkdowns conducted between July 30 and September 2, 1989, the fl ow orifice for fl ow e 1 ement FE-1946 was discovered to be installed backwards by the NRC inspector. Additional walkdowns by the licensee determined that *two additional orifices were installed backwards.
Virginia Electric and Power Company Surry Power Station 3
Docket Nos. 50-280, 50-281 License Nos. DPR-32, DPR-37 This is a Severity Level IV violation (Supplement I)
Pursuant to the provisions.of 10 CFR 2.201, Virginia Electric and Power Company is hereby required to submit a written statement or explanation to the Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC
- 20555, with a copy to the Regional Administrator, Region II, and a copy to the NRC Resident Inspector, within 30 days of the date of the letter transmitting this Notice.
This reply should be clearly marked as a "Reply to a Notice of Violation" and should include for each violation:
(1) admission or denial of the violation, (2) the reason for the violation if admitted, (3) the corrective steps which have been taken and the results achieved, (4) the corrective steps which will be taken to avoid further violations, and (5) the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending the response time.
If an adequate reply is not received within the time specified in this Notice, an order may be issued to show cause why the license should not be modified, suspended, or revoked or why such other action as may be proper should not be taken..
FOR THE NUCLEAR REGULATORY COMMISSION
~te(J'lw'"'a~rt""'/ E?{l~L Regional Administrator T ~
Dated at Atlanta, Georgia this 8th day of November 1989