ML18153C985
| ML18153C985 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 04/27/1992 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 92-226, NUDOCS 9204300132 | |
| Download: ML18153C985 (5) | |
Text
I.
e VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 April 27, 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:
92-226 SPS/RCB/GDM RS Docket Nos.:
50-280 50-281 License Nos:
DPR-32 DPR-37 NBC INSPECTION REPORT NOS. 50-280/92-04 AND 50-281/92-04 We have reviewed your Inspection Report Nos. 50-280/92-04 and 50-281 /92-04 dated March 26, 1992. Our response to the Notice of Violation is provided in the attachment.
We understand your concern over the performance of the high-head safety injection pump lube oil temperature control valves. To date, our efforts to rectify this condition have included replacement of valve internals to reduce galvanic attack and periodic flushing of the valves to prevent silt build-up. While these measures have improved valve reliability, we continue to experience occasional difficulties. Therefore, we will continue to monitor valve performance and will take appropriate* actions to resolve any identified concerns. Additional corrective actions have been initiated to replace the valves and controllers. After the modifications are complete, an (nspection program will be established to evaluate their effectiveness. If required, additional corrective measures will be implemented.
. If you have any further questions, please contact us.
Very truly yours,
\\~l~~
W. L. Stewart Senior Vice President - Nuclear Attachment 9204300132 920427 PDR ADOCK 05000280 0
PDR re O 1
'I'
Copy to:*
U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, N.W.
- Suite 2900 Atlanta, Georgia 30323 Mr. M. W. Branch N RC Senior Resident Inspector Surry Power Station e
e e
REPLY TO A NOTICE OF VIOLATION NRC INSPECTION CONDUCTED FEBRUARY 2 - MARCH 7,- 1992 SURRY POWER STATION. UNITS 1 AND 2 INSPECTION REPORT NOS. 50-280/92-04 AND 50-281/92-04 NRC COMMENT:
During the Nuclear Regulatory Commission (NRC) inspection conducted on February 2 through March 7, 1992, 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:
1 O CFR 50, Appendix B, Criterion XVI, as implemented by Operational Quality Assurance Program Topical Report (VEP 1-SA, Section 17.2.16), requires, in part, that measures be established to* assure that conditions adverse to quality be promptly identified and corrected, and in the case of significant conditions adverse to quality, these measures shall assure that the cause of the condition is determined and corrective actions be taken to preclude repetition.
Contrary to the above, actions taken since 1990 to correct recurring failures associated with the temperature control valves that regulate service water flow to the high head safety injection pumps' lube oil coolers have not been fully effective. Malfunctions continue to occur, the most recent failures occurring on March 2, and 6, 1992, and on September 10, November 11, and December 3, 1991. In all instances, these failures either rendered the automatic lube oil temperature control feature inoperable or resulted in degraded operation.
This is a Severity Level IV Violation (Supplement I).
e REPLY JO A NOTICE OF VIOLATION NRC INSPECTION CONDUCTED FEBRUARY 2 - MARCH 7, 1992 SURRY POWER STATION UNITS 1 AND 2 INSPECTION REPORT NOS. 50-280/92-04
- AND 50-281/92-04
< 1 > Reason for the Violation or, If contested. the Basis for Disputing the Violation The original high head safety injection pump air-operated lube oil temperature control valves (TCVs) were not adequately designed for the application in which they were employed. As a consequence, they were subject to corrosion and fouling in service. The temperature controllers have also had a history of operational. difficulties.
Although these discrepant conditions. had been recognized and thoroughly documented in our corrective action program, previous efforts to correct the conditions have achieved only limited success.
(2)
Corrective Steps Which Have Been* Taken and the Results Achieved As documented in the Inspection Report, five of the six TCVs had their internals replaced with different materials in an effort to reduce corrosion and binding.
Since the issuance of the Inspection Report, the sixth TCV has also been modified. Also, the valves are flushed on a biweekly frequency to reduce silt build-up and fouling.
These steps have resulted in some improvement in reliability, but problems with the systems continue to occur.
(3)
Corrective Steps That Will be Taken to Avoid Further Violations Biweekly flushing of the existing TCVs will be continued, and a periodic inspection of valve internal conditions will be initiated. Flushing and inspection intervals will be adjusted appropriately when results of the inspections have been evaluated.
We believe *that these measures, along with continued operator alertness to nonconforming conditions, will assure valve performance in the interim period until valve replacement is accomplished.
A design change is underway which will replace the TCVs with valves better adapted to the working conditions. After replacement, the new valves will also be flushed on a regular frequency, and an inspection program will be established to evaluate the effectiveness of the modification. The temperature controllers will also be replaced.
Methods currently in use for TCV post-maintenance testing, TCV periodic surveillance testing, and TCV controller set point and span establishment will also be reviewed, evaluated, and strengthened, as appropriate.
F e
( 4 > The Date When Full Compliance wm be Achieved Full compliance will be achieved when the TCVs have been replaced. This replacement is currently scheduled for completion by July 31, 1992. The temperature controllers will also be replaced to further improve system operation. The controllers are scheduled for replacement by the end of 1992.