ML18153D375
| ML18153D375 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 07/02/1993 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 93-371, NUDOCS 9307070094 | |
| Download: ML18153D375 (4) | |
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VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 July 2, 1993 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 REPLY TO A NOTICE OF VIOLATION NBC INSPECTION REPORT NOS.: 50-280/93-12 AND 50-281/93-12 Serial:
93-371 SPS/RCB/ETSR1 Docket Nos.:
50-280 50-281 License Nos.: DPR-321 DPR-37 We have reviewed your Inspection Report Nos. 50-280/93-12 and 50-281/93-12 dated June 4, 1993, and the enclosed Notice of Violation. We share your concern over the inadequate procedural controls which contributed to the violation and are taking corrective actions to preclude such occurrences in the future. Our reply to the Notice of Violation is attached.
Please contact us if you have any questions or require additional information.
Very truly yours, W. L. Stewart Attachment cc: U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, N.W.
Atlanta, Georgia 30323 Mr. M. W. Branch NRC Senior Resident Inspector Surry Power Station G600S6 9307070094 930702 PDR ADOCK 05000280 G
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REPLY TO A NOTICE OF VIOLATION NRC INSPECTION CONDUCTED SURRY POWER STATION UNITS 1 AND 2 INSPECTION REPORT NOS. 50-280/93-12 AND 50-281/93-12 NRC COMMENT:
During an NRC Inspection conducted on May 3-7, 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:
10 CFR 50, Appendix 8, Criterion V, and Section 17.2.5 of the Virginia Electric and Power Company's Operational Quality Assurance Program Topical Report (VEP 1-SA, Updated) require, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, and shall be accomplished in accordance with these instructions, procedures, or drawings.
Paragraph 4.1 of the Surry Power Station Administrative Procedure SUADM-ADM-11, Station Drawing Revision and Distribution, lists the requirements for specifying the station controlled drawings as either 15-day priority drawings or 90-day drawings. Paragraph 6.2 requires that prior to a component or system being declared operable following work under a design change package (DCP), an operational readiness review (ORR) shall be performed and a drawing change request shall be initiated. Changes to the drawings shall be made within their respective 15-day (priority drawings) and 90-day (90-day drawings) limits.
Contrary to the above, on May 6, 1993, 15-day priority drawing 11448-FE-1 A for DCP 93-20 had not been updated within the required 15-day period following its ORR dated April 8, 1993.
In addition, no drawing change request was initiated for the four 15-day priority drawings 11548-ESK-SP, SQ, SR, and SS for DCP 92-64 following the ORR dated April 9, 1993. Consequently, these 15-day priority drawings were not updated within the required 15-day period following the ORR.
This is a Severity Level IV Violation (Supplement I).
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(1)
REPLY TO A NOTICE OF VIOLATION NRC INSPECTION CONDUCTED SURRY POWER STATION UNITS 1 AND 2 INSPECTION REPORT NOS. 50-280/93-12 AND 50-281/93-12 Reason for the Violation. or. if Contested, the Basis for Disputing the Violation The operational readiness review (ORR) is the vehicle used by Virginia Electric and Power Company to identify and document that a design change has been installed and that the affected structure, system, or component (SSC) is ready for return to service. Station procedures describe the process and require that this review be performed prior to declaring the affected SSC operable.
Included in this review is a verification of the status of priority documentation which includes updated drawings, if they are part of the modification. The violation occurred because, in several isolated instances, personnel responsible for performing the ORRs failed to properly identify the drawings requiring revision and did not document them on the ORR in accordance with procedural requirements.
As a result, several priority drawings were not identified as requiring revision and for several other drawings the Drawing Update Group was not notified of the 15-day update requirement.
(2)
Corrective Steps Which Have Been Taken and the Results Achieved Station deviation reports were prepared to document the discrepant conditions, and the drawings were properly updated on May 6, 1993. Because of the concerns raised by these two events, the Station conducted a review of ORRs initiated during the previous 90 days to ascertain the status of priority drawings.
This review encompassed the recently completed Unit 2 refueling outage and included 211 ORRs for 45 design change packages and 49 engineering work requests.
A total of 267 priority drawings were identified which required revision. Of these 267 drawings, twelve were identified which had not been updated within the administrative time limits. These additional drawings were also properly updated once they were identified. Because of the Controlled Document Review and Revision (CORR) process, which is performed following the completion of the ORR, we believe that these discrepancies would have been detected at that time had they not been identified. during this special review.
A memorandum from the Superintendent, Station Engineering, was issued to Engineering Department personnel which outlined the discrepancies found and described the lessons to be learned. The memorandum emphasized the need for heightened awareness and procedural compliance during the design change process. The Superintendent also discussed the event at meetings with appropriate members of the Engineering Department.
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Governing procedures were changed to eliminate the 15-day priority classification. After this change, only two drawing classifications exist: "priority drawings," which require updating prior to completion of the ORR, and "updated controlled drawings," which require updating within 90 days of initiation of the CORR.
Also, the drawing classification series designated as priority were reviewed and reduced in number where possible. These changes will simplify the ORR process and administrative tracking requirements.
(3)
Corrective Steps That Will be Taken to Avoid Further Violations The corrective measures taken thus far will be monitored for effectiveness and modified as necessary to assure continued compliance with governing procedures.
( 4)
The Date When Full Compliance Will be Achieved Full compliance was achieved when the necessary drawing update reviews were completed on May 24, 1993, in accordance with station procedures.