ML20070A282

Responds to NRC Re Violations Noted in IE Insp Repts 50-280/82-10 & 50-281/82-10.Corrective Actions: Process Vent Sys Mod Designed & Administrative Procedure 56 Amended Re safety-related Areas

ML20070A282
Person / Time
Site:	Surry
Issue date:	07/16/1982
From:	Leasburg R VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20070A270	List: ML20070A277 ML20070A282 ML20070A290
References
359, NUDOCS 8212090218
Download: ML20070A282 (4)

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R. H. LE ASSimt Vaca Posewomar July 16, 1982 Nocasan Ortmarrows Mr.' James P. O'Reilly Serial No. 359 Regional Administrator N0/RMT:acm Region 11 . Docket Nos. 50-280 U. S. Nuclear Regulatory Commission 50-281 10,4 Marietta Street, Suite 3100 License Nos. DPR-32 Atinnta,. Georgia 30303 DPR-37

Dear Mr. O'Reilly:

i We hav,e reviewed your letter of Juae 7, 1982 in reference to the inspection conducted at Surry Power Station on April 1-30, 1982, and reported in IE Inspection Report Nos. 50-280/82-10 and 50-281/82-10. Our response to the specific infractions are attached.

• We Chave determined that no proprietary information is contained in the f,ceports. Accordingly, the Virginia Electric and Power Company has no

<bjection to these inspection reports being made a matter of public disclosure. The information contained in the attached pages is true and

( , ,, accurate to the best of my knowledge and belief.

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Attachment cc: Mr. Steven A. Varga, Chief Operating Reactors Branch No. 1 Division of Licensing e ,

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8212090218 821119 PDR ADOCK 05000280 G PDR L

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, Attcchment P gs 1 Serial No. 359 RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-280/82-10 AND 50-281/82-10 NRC COMMENT:

As a result of the inspection conducted on April 1-30, 1982, and in accordance with the NRC Enforcement Policy, 47 FR 9987 (March 9, 1982), the following violations were identified.

A. Technical Specification 5.4.A.3 and 6.4.0 requires that the detailed written procedures provided for actions to be . taken for specific and foreseen malfunctions of systems or components, including alarms shall be-followed.

Contrary to the above, on April 19, 1982, Abnormal Procedure (AP) 5.16

" Process Vent Particulate and Gaseous Radiation Monitor Malfunction," was not followed or implemented when the Process Vent Filter fault alarm was annunciated. The inspector observed . the filter fault light on when reviewing the April 18, 1982, unplanned radioactive gaseous release event. Water was found in the Process Vent radiation monitors CW-101 and 102, ccnfirming the fault alarm.

This is a Severity Level V Violation (Supplement I).

RESPONSE

(1) ADMISSION OR DENIAL OF THE ALLEGED VIOLATION:

The allegation is correct as stated.

(2) REASONS FOR VIOLATION:

On the 19th of April, 1982, with the unit at 100 percent power, the Process Vent particulate radiation monitor filter fault alarm was noted to be dimly lit.

Investigation disclosed the presence of water which impregnated the filter paper causing it to swell enough to prevent ~ advancement. The moisture also caused damage to the filter fault switch resulting in a reduction in voltage to the alarm light. This created a dimly lit alarm i

light and as such was not immediately observed.* The failure of the filter paper to advance effectively made the particulate monitor j inoperative, as the filter paper in the flow path is only monitored as it

leaves the Process Vent Sample flow path.

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' The cause of this event was the water released into the Process Vent System by the lif ting of relief valve, RC-GW-107, (LER 1-82-047/01T-0) and (LER-1-82-046/03L-0).

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., Attachment Page 2 Serial No. 359 (3) CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:

The Process Vent System was secured as per AP-5.16. The radiation monitor was dried out, the damaged filter paper was replaced, and the filter fault switch was replaced. As soon as RM-GW-101 and 102 were returned to service and verified as operational, the Process Vent System was returned to service as per OP-23.1.

(4) CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:

A Process Vent System modification has been designed and material procurement is in process as reported in earlier correspondence. This modification is expected to improve the overall reliability of the Process Vent System.

(5) THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

Full Compliance has been achieved.

NRC COMMENT:

B. Technical Specification 6.4.J requires that the facility fire protection program and implementing procedures which have been established for the station shall be implemented. One of these implementing procedures, Surry Power Station procedure ADM-56, "Special Processes Involving Ignition Sources" defines any and all flammable and/or combustible materials as Transient Fire Loads. Paragraph 56.2.2 of ADM-56 states that Transient Fire Loads may be stored in any area of the plant provided they are intended for timely use and the cognizant superintendent has received written consent from the Station Fire Marshal.

Contrary to the above, ADM-56 was not implemented in that an adequate fire load study for the steam generator refurbishment building was not performed prior to the April 17, 1982, fire. The Station Fire Marshal l had not issued written consent for the storage of transient fire loade or for the contam.Inated material drying process utilizing electrical hear.:.rs within tents in the building. Flammable materials such as mopheads, protective clothing, wooden pallets, cardboard containers, filters, and drycleaning solvents were present in the building and contributed to the

. fire that occurred in the building on April 17, 1982.

This is a Severity Level V Violation (Supplement I).

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= Attcchment Paga 3 Serial No. 359

RESPONSE

(1) ADMISSION OR DENIAL OF THE ALLEGED VIOLATION:

The alleged violation is correct, but with mitigating circumstances.

(2) REASONS FOR VIOLATION:

Administrative Procedure 56, Special Process Involving Ignition Sources, was written to prescribe procedures and controls for ignition sources at the station. Both safety related and non-safety related areas were addressed. Through oversight, the unqualified requirement for written consent from the Fire Marshal to store transient fire loads was not addressed specifically to safety related areas. This was the intent, and historically the practice in interpreting paragraph 56.2.2. Monitoring fire hazards in non-safety related areas has been accomplished as stated in paragraph 56.7, which states: "A general inspection form shall be used by the Fire Marshal's Office to periodically check all areas of the plant site for fire hazards..... This inspection shall occur at least once a month."

There are six paragraphs in section 56.2. One classifies transient fire loads. One specifically exempts the station storeroom and warehouse from the provisions of ADM-56. Paragraph 56.2.2 is quoted above. The other three paragraphs address safety related areas, as paragraph 56.2.2 should have.

The violation occurred because we failed to effectively communicate what we meant.

(3) CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:

Administrative Procedure 56 has been amended to clearly prescribe what is required for safety related areas and what is required for non-safety related areas. Hopefully, the ambiguity has been removed.

(4) CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:

i No further action is necessary.

i (5) THE PATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

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[ Full Compliance has been achieved.

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