ML20072L882

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Responds to NRC Re Violations Noted in IE Insp Repts 50-280/83-09 & 50-281/83-09.Corrective Actions: Abnormal Procedure AP-17 Included in Apr 1983 Review & Administrative Procedure 37 Revised
ML20072L882
Person / Time
Site: Surry  
Issue date: 05/20/1983
From: Stewart W
VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To: James O'Reilly
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20072L872 List:
References
266, NUDOCS 8307140228
Download: ML20072L882 (3)


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May 20, 1983 Mr. James P. O'Reilly Serial No. 266 Regional Administrator N0/WDC:acm Region II Docket Nas.50-280 U. S. Nuclear Regulatory Ccenission 50-281 101 Marietta Street, Suite 2900 License Nos. DPR-32 Atlanta, Georgia 30303 DPR-37

Dear Mr. O'Reilly:

We have reviewed your letter of April 21, 1983 in reference to the inspection conducted at Surry Power Station between March 21 and March 25, 1983 and reported in IE Inspection Report No. 50-280/83-09 and 50-281/83-09.

Our responses to the specific irifractions are attached.

Ne have determined that no proprietary infora tion is contained in the report.

Accordingly, the Virginia Electric and Power Company has no objection ta this inspection report being made a natter of public disclosure.

The 1:. formation centained in the attached pages is true and accurate to the best of my knowledge and belief.

Very truly yours, W. L. Stewart Attachment cc:

Mr. Steven A. Varga Mr. D. J. Burke NRC Resident Inspector Surry Power Station 9

6 8307140228 830628 PDR ADOCK 05000200 0

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s Attachment Page 1 Serial No. 266 RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-280/83-09 AND 50-281/83-09

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NRC COMMENT:

As a result of the inspection conducted March 21-25, 1983, and in accordance with the NRC Enforcement Policy, 47 FR 9987 (March 9, 1982), the following violations were identified.

A.

10 CFR 55 Appendix A.

Paragraph 3.d, states that the requalification program shall include on-the-job training so that each licensed operator and senior operator reviews the contents of all abnormal and emergency procedures on a regularly scheduled basis.

The licensee's submitted requalification program (VEPCO Licensed Operator Requalification Program, dated July, 1980), Paragraph 4,

states that abnormal and emergency procedures shall be reviewed on an annual basis.

Contrary to the above, each licensed operator and senior operator have not teviewed all abnormal and emergen:.y procedures os an annual basis, Abnormal Procedure (AP)-17, Restoration and Loading of an Emergency Diesel Generator, has not been included in the annual review since this procedure was issued in March, 1981.

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

RESPONSE

(1) ADMISSION OR DENIAL OF THE ALLEGED VIOLATION:

The violation is correct as stated.

(2) REASONS FOR VIOLATION:

The reason for the violation was that the review of the current procedures listing was inadequate when compiling the procedure review list for 1982.

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

Abnormal Procedure (AP)-17 has been included in the 1983 annual review for the month of April, therefore it will have been reviewed by all licensed operatorc upon completion of their April 1983 procedure review.

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

The revised Vepco Licensed Operator Requalification Program will include i

a paragraph which specifically directs the Program Coordinator to prepare

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the list based on all current Abnormal and' Emergency Procedures as of January 1 of that year, i

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

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The revised Licensed Operator Requalification Program will be implemented j

prior to December 31, 1983.

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Attachmtnt Page 2 Serial No. 266 RESPONSE TO K0TICE OF VIOLATION INSPECTION REPORT NOS. 50-280/83-09 AND 50-281/83-09 NRC COMMENTi q

B.

10 CFR 50 Appendix B, Criterion V and the Quality Assurance Program (VEP-1-4A) state that activities affecting quality shall be prescribed by documented procedures and shall be accomplished in accordance with these procedures.

ADM-37, Station - Drawing Revision and Distribution dated 9/16/82, Section 37.3.3, requires supervisors to assure that their controlled drawing files are updated to reflect the latest drawing received.

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Contrary to the above, based on a total sample of 108 drawings reviewed j

at 5 specific areas containing controlled drawings, 10 drawings were not

.the correct revision or were missing from the files.

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

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RESPONSE

(1) ADMISSION OR DENIAL OF THE ALLEGED VIOLATION:

i The violation is correct as stated.

1 (2) REASONS FOR VI0IATION:

1 The violation occurred because inadequate attention was given, in scme cases, to maintaining the controlled drawing files up-to-date.

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

i An inventory of a random sampling to the 95% confidence level of each controlled drawing set on the station was conducted to determine the error rate in each area.

Any errors detected were corrected.

Complete inventories were conducted of these sets with an excessive statistical error rate and any errors found were corrected.

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

l Administrative. Procedure 37 has been revised to require annual inventories of each controlled drawing file.

Over a period of twelve months a complete set of controlled drawings will be inventoried and

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corrected to' ensure they are current.

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

4 Full compliance has'been achieved.

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