ML19095A728

Presenting Results of Outstanding Questions in IE Bulletins Nos. 75-04 and 75-04A

ML19095A728
Person / Time
Site:	Surry
Issue date:	07/02/1975
From:	Stallings C Virginia Electric & Power Co (VEPCO)
To:	Moseley N NRC/RGN-II
References
IEB-78-004, IEB-78-004A, Serial No. 493/040375
Download: ML19095A728 (5)

Text

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e VIRGINIA ELECTRIC AND POWER COMPANY, RICHMOND, VIRGINIA 23261 July 2,. 1975 Mr. Norman C. Moseley, Director Serial No. 493/040375 Directorate of Regulatory Operations LQA/TES:ell Region II Docket Nos. 50-280 U. S. Nuclear Regulatory Commission 50-281 230 Peachtree Street N. W., Suite 818 License Nos. DPR-32 Atlanta, Georgia 30303 DPR-37 RE: IE:II:NCM 50-280 50-281

Dear Mr. Moseley:

This letter presents the results of our review of outstanding questions in IE Bulletins Nos. 75-04 and 75-04A.

A. IE Bulletin 75-04

1. Review your.overall procedures and system for controlling con-struction activities that interface with reactor operating activities, with particular attention to the installation and testing of seals for electrical cables between compartments of the reactor building, e.g., control room to cable spreading room.

Response: There are no current construction activities at Surry which interface with reactor operations. Techniques for sealing cable sleeves and tray openings have been described in our letter dated May 30, 1975, Serial No. 493/040375.

2. Review the des.ign of floor and wall penetration seals, with particular attention to the flammability of materials.

• Response: This directi~e was responded to in our letter dated May 30, 1975, Serial No. 493/040375.

3. Evaluate your procedures for the control of ignition sources which may be used for leak testing or other purposes in areas containing flammable materials.

Response: .The use of combustible materials is always kept to the bare minimum absolutely necessary for completion. of a task,

SHEET NO.

VIRGINIA ELECTRIC AND POWE-MPANY TO Mr. Norman C. Moseley ,t..rector 2 particularly where ignition sources are required. Permanent or portable fire equipment is nearby during such work. Care is taken that at least one man out of two assigned to a task is familiar with the area or equipment to be worked on. Quality Control personnel monitor a task to verify that only safe procedures are utilized. Ignition sources are not used for leak testing at Surry Power Station.

B. IE Bulletin 75~04A

1. Because the occurrence appears to have resulted from modifications being made to an operating unit, all power reactors with operating licenses should address the actions requested in Bulletin 75-04 as well as the actions described below.

Response: This letter, together with our letter dated May 30, 1975, Serial No. 493/040375, completes our response to IE Bulletin 75-04 and 75-04A.

2. Review your policies and procedures relating to construction or maintenance and modification work to assure that activities which might affect the safety of a unit in operation, including the ability to shut down and cool the unit are properly controlled.

Your review should consider particularly your policy on deferring construc-tien, maintenance or modification work on a unit until a shutdown period except for emergency maintenance vital to con-tinuedsafe operation or safe shutdown of the unit.

• Response: The initial construction activities at Surry have been completed. In regard to maintenance and modification work, it is Vepco policy that during the planning of such work, the possibilities of affecting the safety of a unit in operation are examined, and the work is programmed in such a manner to minimize or eliminate the possibility of interferring with an operating unit. Any such work is monitored by Quality Control to ensure that it is carried out according to plan.

Such work is deferred until the operating unit is shut down, excepting only work on an operating unit which requires emergency maintenance necessary for safe shutdown of the unit.

3. Review your policies and procedures to assure that for construc-tion or modification and maintenance activities during plant operation particular attention is given to the folrowing areas:

a) The degree of safety significance of affected and nearby cabling and piping.

SHEET NO.

VIRGINIA ELECTRIC AND POWE-MPANY To Mr. Norman C. Mose 1e y , . rector 3 b) The use and control of combustible materials.

c) The use and control of equipment that may be an ignition source.

d) The assignment of personnel, knowledgeable of plant arrangement and plant operations, whose sole temporary responsibility is monitoring the safe performance of construction or maintenance and modification work, including attention to otherwise unattend-ed areas adjacent to the work areas.

e) Provision of installed or portable equipment to provide the monitoring personnel with prompt connnunication with the operat-ing staff in the control room.

f) Provision of adequate fire prevention and fire suppression equip-ment, installed or portable, for the following locations:

1. Areas where work is being performed.

2. Areas where occurrence of a fire has high safety significance, even though the probability of occurrence is relatively small.

g) Rec_ognition that a fire, even one involving electrical equipment, may, if of sufficient intensity require water as the ultimate suppression medium.

Response

a) It is Vepco policy to plan maintenance* and modification work so that cabling and piping will not be disturbed, unless the modification or maintenance is on the cabling or piping or if the work requires disturbing cabling or piping. If this is the case, the safety significance is evaluat~d. Quality Control personnel monitor such work to ensure execution according to plan.

b) Combustible materials are used only where necessary for execution of the work. All combustible material such as wood, paper, solvents, and chemicals, are used and controlled in accordance with rules and regulations in the Vepco Accident Prevention Manual.

c) It is Vepco policy to plan work in such a manner that an igni-tion source, or equipment which could be an ignition source, is used only where required and only under planned and controlled conditions. If the work site for such equipment is not near fire extinguishers, portable extinguishers are bro_ught in before initiating such work. Ignition sources are not used for leak

.testing.

d) It is Vepco policy that at least one out of two persons assigned to maintenance or modification work shall be familiar with the area and plant operations.

'* A VIRGINIA ELECTRIC AND POWE-MPANY TO Mr. Norman C. Mosele.irec tor SHEET NO. 4 e) Communication equipment is available on site for work crews to use in contacting the control room. This includes a paging system throughout the station, sound powered phones in some areas, and the normal commerical telephone system.

f) Fire protection equipment has been installed throughout the station. High and low pressure CO 2 systems, fire deluge systems, and portable CO 2 and dry chemical extinguishers are located throughout the station, as well as smoke detectors in some areas.

1. If the work area is not near permanent fire equipment, portable equipment is moved nearby.

2. The location of installed fire equipment was planned from the standpoint of safety significance.

g) The fire deluge systems were built in because of recognition of the requirement for water in case of severe fires.

4. Review your emergency procedures to assure that consideration for alternate methods for accomplishing an orderly plant shutdown and cooldown are provided in case of loss of normal and preferred alter-native shutdown and cooldown systems for any reason (e.g. a fire).

In this connection, assure that the minimum information necessary to assist the operators in such shutdown actions~ the minimum pro-tection system actions required (e.g. scram) and the spectrum of alternative paths available to the operators to supply cooling water and remove decay heat dependent on plant conditions are included in your emergency procedures.

Response: There is the capability at Surry for orderly shutdown from outside the control room. This alternate method is the auxiliary shutdown from the auxiliary panel outside the control room. The hot shutdown condition can be maintained indefinitely utilizing procedures located at the auxiliary panel. It is not possible to go to cold shutdown from the auxiliary panel, but the capability exists for removing heat from the steam generators.

We feel that the results of this review satisfies those questions which were raised in the light of the Browns Ferry incident.

Very truly yours,

'fr;i, 2)1. v11a£~;?~~

.C. M. Stallings Vice President - Power Supply and Production Operation

Letter to N. c. Moseley from Virginia Electric and Power Company dated July 2, 1975. This is a supplemental response~

DISTRIBUTION: 50-200 H. DQ Thornburg, IE 50-281 IE:HQS (5) Reply to IEB 04A

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