ML18153C887
| ML18153C887 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 01/29/1992 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 92-011, 92-11, NUDOCS 9202040063 | |
| Download: ML18153C887 (6) | |
Text
VIRGINIA ELECTRIC ANn-*PowER coMPANY RICHMOND, VIRGINIA 23261 January 29, 1992
- United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D. C. 20555 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 REPLY *TO A NOTICE OF VIOLATION Serial No.
SPS/JHR3 Docket Nos.
License Nos.92-011 50:-280 50-281 DPR-32 DPR-37 NRC INSPECTION REPORT NOS. 50-280/91-33 AND 50-281/91-33 We have reviewed your Inspection Report Nos. 50-280/91-33 and-50-281/91-33 dated December 30, 1991 and the enclosed Notice of Violation. Our reply to the Notice of
. Violation is attached.
The potential programmatic nature of the violation has been addressed by completion
, of a previously initiated review of the administrative controls for the piping syst:ems pen_etrating containment. This review was performed for the purpose of documenting (verifying) which valves perform a containment integrity function and the degree of administrative control which is required over those valves.
Our review confirmed that the containment integrity valves are being maintained in the correct position. However, a small percentage of valves were determined to require additional administrative control in order to fully comply with the intent of the Technical Specifications. These controls are now being provided. Futhermore, there were no.
safety consequences as a result of the observed deficiencies in _our administrative controls. Applicable licensing documents will be revised to accurately reflect the
- containment isolation configuration.
Should you have any questions regarding our response, please contact us.. We have no objection to making this reply a matter of public disclosure.
Very truly yours, QPCfl-1~
-~ r- :~n~~~~6!iresident Nuclear"
_ Attachment 9202040063 920129 PDR ADOCK 05000280 G
cc:
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
REPLY TO A NOTICE OF VIOLATION NRC INSPECTION CONDUCTED NOVEMBER 1-30, 1991 SURRY POWER STATION UNITS 1 AND 2 INSPECTION REPORT NOS. 50-280/91-33 AND 50-281/91-33 NRC COMMENT:
"During the Nuclear Regulatory Commission (NRG) inspection conducted on November 1-30, 1991, 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 {1991 ), the violation is listed below:
Technical Specification (TS) 3.8;A requires that containment integrity, as defined in Technical Specification Section 1.0, be *maintained unless the reactor is in the cold shutdown condition..
Technical Specification 1.H.1 requires, in part, that all non-automatic containment isolation valves be locked closed and under administrative control.
Contrary to the above, the main steam trip valves' bypass valves, 1 /2-MS-84, 1 /2-MS-116, and 1 /2-MS-155 are non-automatic containment isolation valves that were not locked closed or under administrative control when open. This condition has existed for an indefinite period of time with Units 1 and 2 in the intermediate shutdown, hot shutdown, or critical conditions.
This is a Severity Level IV violation (Supplement I)".
REPLY TO A NOTICE OF VIOLATION NRC INSPECTION CONDUCTED NOVEMBER 1-30, 1991 SURRY POWER STATION UNITS 1 AND 2 INSPECTION REPORT NOS. 50-280/91-33 AND 50-281/91-33 Reason for the Violation, or, if Contested, the Basis for Disputing the Violation A violation occurred in that the main steam trip valve {MSTV) bypass valves were not locked when closed.
However, these valves were administratively controlled in accordance with the Technical Specifications {TSs) when open. TS 1.H.1 states the following:
"All non-automatic containment isolation valves, except those required for intermittent operation in the performance of normal operational activities, are locked closed and under administrative control. Non-automatic containment isolation valves may be opened intermittently for operational activities provided that they are under administrative control and are capable of being closed immediately if required.".
The MSTV bypass valves are required to be opened during a unit startup to heat up the main steam system and to equalize the pressure across the MSTVs, allowing the MSTVs to be opened. During the time they are open, the MSTV bypass valves are maintained. under administrative control as required by General Operating Procedure
.1/2-GOP-1.4, "Unit 1/2, HSD to 2% Reactor Power." An operator is stationed to locally operate the valves in accordance with instructions from the main control room and is
- responsible for closing the valves immediately if required. After the MSTVs are open, 1/2-GOP-1.4 requires that the MSTV bypass valves be closed and then independently verified to be closed.
Operating Procedure 1 /2-0P-1 G, "Refueling Containment Integrity and RCS Mid loop Containment Closure Checklist" also requires verification that the MSTV bypass valves are closed prior to initiating refueling activities..
Failure to lock the MSTV bypass valves when they wer~ closed was due to inadequate procedural controls. The inadequate procedural control resulted from the lack of clear documentation as to the containment integrity function of the main steam and feedwater system isolation valves.
Although the MSTVs are listed in the TS as containment isolation valves, they are not explicitly listed or discussed as such in the Updated Final Safety Analysis Report {UFSAR).
The main steam and feedwater systems do not provide a credible, direct leakage path from the reactor coolant system or containment atmosphere to the environment following a design basis Loss of Coolant Accident (LOCA). As discussed in our letter dated April 24, 1990 {Serial No.90-179), the Surry containment pressure is returned to subatmospheric within one hour following initiation of a design basis LOCA.
After.the containment pressure becomes subatmospheric, any direct leakage paths would allow in-leakage only and containment out-leakage is assumed to be *effectively terminated. During the period of time that the containment pressure is above atmospheric, the portions of the main steam and feedwater systems inside containment are pressurized to greater than containment pressure. On this basis, the main steam and feedwater system valves
- ~*
have been exempted from 1 O CFR 50, Appendix J, Type C leakage testing.. Due to the
. above considerations, the main steam and feedwater system isolation valves were not generally considered to perform a containment integrity function. However, it was recognized that isolation of the main steam lines was necessary to mitigate the
- consequences of a main steam line break or a steam generato*r tube rupture.
- Therefore, administrative controls were placed on the opening of the MSTV bypass
-valves.to provide assurance that they would not be left mispositioned. On October 31, 1991, during a Unit 2 startup, the stem bushing threads on MSTV E3ypass Valve 2~MS-155 failed. The operating staff recognized that they could no longer comply with th~
stated administrative controls which required the capability to close the valve upon notification from the control room. The operating staff conservatively recognized and declared a loss of containment integrity.
Subsequent evaluations performed to support preparation of the Licensee Event Report resulted in the determination that the MSTV bypass valves should have been classified as containment isolation valves and, therefore, should have been locked closed during routine operation.
Corrective Steps Which* Have Been Taken and the Results Achieved Containment integrity was re-established and the action statement was terminated.
MSTV Bypass Valve 2-MS-155 was closed using a hydraulic jacking device and was
- mechanically blocked closed. Startup of Unit 2 was then resumed.
Licensee Event Report 281191-01 O was submitted to document the event *in
- accordance with 1 O CFR 50. 73.
. In order to determine if any other valves required additional administrative. control, a
- previously initiated review of the piping systems penetrating containment was completed., This review was performed to confirm and document the* valves which perform a containment integrity function and the degree of administrative control which was required over those valves. Pending further analysis of the main steam and
- feedwater systems, the following manual valves will be maintained locked _closed and.
under administrative control as a result of this review in order to fully comply with the intent of TS 3.8.A:
Valve 112-MS-84 112-MS-116 112-MS-155 112-GN-1 112-GN-2 112-GN-3.
112-MS-379 112-MS-378 112-MS-377 112-MS-266 112-MS-268 112-MS-208
. 112-MS-118 1-Sl-30112-Sl-321 1-Sl-31112-Sl-322 112-RS-46 1-RS-5212-RS-53 Function
'MSTV "A" Bypass Valve MSTV "B" Bypass Valve MSTV "C" Bypass Valve SIG "A" Nitrogen Addition Isolation SIG "B" Nitrogen Addition Isolation
- SIG "C" Nitrogen Addition Isolation SIG "A" AFW Pump Steam Supply Isolation Bypass SIG "B" AFW Pump Steam Supply Isolation Bypass SIG "C" AFW Pump Steam Supply Isolation Bypass MSTV "A" Upstream Drain Trap Isolation MSTV "B" Upstream Drain Trap Isolation MSTV "C" Upstream Drain Trap Isolation Decay Heat Release Valve Isolation Safety Injection Suction Isolation Valve Bypass Safety Injection Suction Isolation Valve Bypass Recirculation Spray Suction Isolation Valve Bypass Recirculation Spray Suction Isolation Valve Bypass
~*.
The above valves have been locked closed and placed under administrative control.
With the exception of a small number of documentation discrepancies, other valves required to be closed to perform a containment integrity function were found to be adequately documented and controlled. In no case was a containment integrity valve found to be in an incorrect position.
- Corrective Steps Which Will be Taken to Avoid *Further Violations.* --
. Based on the results of the above review, the containment isolation valve listings in the
- _ UFSAR will be updated and, in accordance with Generic Letter 91-08, a request will be submitted to remove the listings from the Technical Specifications.
In addition, an evaluation will be performed to review the safety functions of the main steam and.feedwater isolation valves. If it is determined that these valves do not
. perform a containment isolation function, the containment isolation valve listing in the UFSAR will be annotated as_ such. The evaluation results and the basis will also be incorporated into the appropriate licensing d_ocuments.
The Date When Full Compliance_ Wi~I be. Achieved Full compliance was achieved on January 29, 1992.