ML18153C261

Responds to NRC 900522 Ltr Re Violations Noted in Insp Repts 50-280/90-07 & 50-281/90-07.Corrective actions:as-built Configurations of 120-volt Ac & Dc Vital & Semivital Panel Breaker Installations Verified to Be Acceptable

ML18153C261
Person / Time
Site:	Surry
Issue date:	06/21/1990
From:	Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
90-329, NUDOCS 9006260159
Download: ML18153C261 (8)

See also: IR 05000280/1990007

Text

VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 June 21, 1990 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. NO/RJS Docket Nos. License Nos. NRC INSPECTION

REPORT NOS. 50-280/90-07

AND 50-281/90-07 90-329 R4 50-280 50-281 DPR-32 DPR-37 We have reviewed your Inspection

Report Nos. 50-280/90-07

and 50-281 /90-07 dated May 22, 1990. Our response to the Notice of Violation

enclosed in the report is provided as an attachment

to this letter. We have no objection

to this reply being disclosed

to the public. If you have any further questions, please contact us. Very truly yours,

W. L. Stewart Senior Vice President

-Nuclear Attachment

cc: U. S. Nuclear Regulatory

Commission

Region II 101 Marietta Street, N. W. Suite 2900 Atlanta, Georgia 30323 Mr. W. E. Holland NRC Senior Resident Inspector

Surry Power Station

• ATTACHMENT

Response to Notice of Violation

Reported During the NRC Maintenance

Team Inspection

Inspection

Report Nos. S0-280/90-07

and 50-281 /90-07 NRC Comment: During the Nuclear Regulatory

Commission (NRC) inspection

conducted

on February 26, 1990 -March 30, 1990, a violation

of NRC requirements

was identified.

The violation

involved failures to follow *maintenance

related procedures.

In accordance

with the "General Statement

of Policy and Procedure

for NRC Enforcement

Actions," 1 O CFR Part 2, Appendix C (1986), the violation

is listed below: . 1 O CFR 50, Appendix B, Criterion

V requires activities

affecting

quality be prescribed

by documented

instructions, procedures, or drawings, of a type appropriate

to the circumstances

and shall be accomplished

in accordance

with these instructions, procedures

or drawings.

Surry Power Station Procedure

SUADM-ADM-11, currently

dated 29 November 1989, "Station Drawing Revision and Distribution" requires that responsible

station personnel

identify, process, and implement

drawing revisions

as a result of design changes and identification

of as built conditions

and also that individuals

using drawings or aperture cards of drawings ensure that the drawing was the latest revision.

Surry Power Station Procedure

SUADM-ADM-31, dated 5 December 1985, "Vendor Interface/Control

of Vendor Documents", paragraphs

8.1.1, 8.1.2, and 8.1.3, require that the station implement

applicable

vendor supplied information

by reviewing, tracking, and incorporating

the information

where necessary.

Surry Power Station Procedure M-39, dated 15 December 1989, "Control of Measuring

and Test Equipment," (M&TE) paragraphs

4.3, 6.2, and 7.0, require that: safe storage and protection

be provided for M&TE devices; M&TE devices not requiring

calibration

be so marked; and M&TE devices due for (or suspected)

of requiring

calibration

be returned to the calibration

facility for calibration, respectively.

Contrary to the above, activities

affecting

quality were not accomplished

in accordance

with procedures

as evidenced*

by the following:

1. During the period January 1975 to the present, the licensee accomplished

several quality-affecting, plant modifications

of breaker capacities

in 120 volt vital and semi-vital

AC and D'1 panels that did not result in revision of eleven associated

drawings.

2. On or about 12 March 1990, craft, craft supervision, and the Shift Supervisor, performed

reactor protection

system logic circuitry

troubleshooting, procedure

revision preparation, and establishment

of plant condition

deliberations

by reference

to a "For Reference

Only" logic circuitry

drawing without assuring the drawing was the latest revision.

3. The licensee failed to process vendor supplied information

that could have affected quality work on Motor Operated Valve actuators, received from Limitorque

Corporation

on or about January 1990, and failed to incorporate

test requirements

for the overspeed

trip device of the AFW Terry turbine recommended

by the equipment

technical

manual, in accordance

with applicable

instructions.

4. During the period 1985 to the present, M&TE under Operations

Department

cognizance:

were improperly

stored with calibrated, non-M&TE equipment

that permitted

the damage of M&TE devices, and/or could have resulted in the use of calibrated

equipment

in safety related applications;

were not properly marked as M&TE not requiring

calibration

because the device(s)

were used with M&TE that was properly calibrated;

and were not returned to the calibration

laboratory

for calibration

when due. This is a Severity Level IV violation (Supplement

1 ).

.. * * Response to Notice of Violation

Inspection

Report Nos. 50-280/90-07

and 50-281/90-07

RESPONSE-PART

(1) (1) ADMISSION

OR DENIAL OF THE ALLEGED VIOLATION

The violation

is correct as stated. (2) REASON FOR VIOLATION

(3) This violation

occurred due to a failure to follow administrative

requirements.

The drawing discrepancies

resulted from work performed

that predated Surry's current performance

improvement

efforts which require positive close out of requirements

as detailed in station procedures

.. CORRECTIVE

STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED 120 volt AC and DC vital and semi-vital

panel breaker installations

were compared against applicable

drawings.

The discrepancies

were documented

and evaluated.

The as built configurations

were verified to be acceptable

and the affected station drawings were updated. At the time of discovery, the applicable

design control standard and station procedures

contained

requirements

which collectively

should prevent this occurrence.

(4) CORRECTIVE

STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS

None. Steps have previously

been taken to address this issue and compliance

with the present design control standard and station procedures

should be sufficient

to prevent further violations.

(5) THE DATE WHEN FULL COMPLIANCE

WILL BE ACHIEVED Full compliance

has been achieved .

... * * Response to Notice of Violation

Inspection

Report Nos. 50-280/90-07

and 50-281 /90-07 RESPONSE-PART

(2) (1) ADMISSION

OR DENIAL OF THE ALLEGED VIOLATION

The violation

is correct as stated. (2) REASON FOR VIOLATION

The violation

occurred due to personnel

error in not complying

with existing procedural

requirements.

The individuals

involved recognized

that their action had been inconsistent

with the existing requirements

• when questioned

by the inspector

who had observed the event. (3) CORRECTIVE

STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED The "For Information

Only" drawings that were used were verified to be the latest revisions.

The violation

of procedural

requirements

was reviewed with l&C department

personnel.

(4) CORRECTIVE

STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS

None. The requirement

for procedural

compliance

has previously

been added to both initial and continuing

training lesson plans for station personnel

as well as craft specific continuing

training.

(5) THE DATE WHEN FULL COMPLIANCE

WILL BE ACHIEVED Full compliance

has been achieved .

• * Response to Notice of Violation

Inspection

Report Nos. 50-280/90-07

and 50-281 /90-07 RESPONSE-PART

(3) (1) (2) ADMISSION

OR DENIAL OF THE ALLEGED VIOLATION

The violation, with respect to vendor information, is correct as stated in that engineering

personnel "failed to process vendor supplied information

.. .in accordance

with applicable

instructions" while performing

their review for applicability.

The violation

also states that we "failed to incorporate

test requirements

for the overspeed

trip device of the AFW Terry turbine recommended

by the equipment

technical

manual, in accordance

with applicable

instructions." While overspeed

test requirements

had not yet been proceduralized, measures had been initiated

to provide the capability

to comply with applicable

instructions.

The only method for overspeeding

the turbine involves manual operation

of the governor linkage and is considered

to be a potential

safety hazard. Installation

of new governors

with overspeed

test devices had been planned for the next refueling

outage in order to safely support testing. Test procedure

development

had also been planned to support both post maintenance

and periodic testing of the overspeed

trip devices. The initial implementation

date of the periodic testing was a conscious

engineering

decision based upon operating

history, 1986 and 1988 governor inspections

and maintenance, as well as post maintenance

testing results. Commitment

tracking system items, which identified

and tracked both procedure

development

and overspeed

trip device testing of the Terry turbines, existed and were reviewed with the NRC during the inspection.

These items were to be completed

during the next refueling

outages currently

scheduled

for fourth quarter 1990 and second quarter 1991. Thus, the vendor information

had been identified

by the licensee and action had been initiated

to implement

the information.

REASON FOR VIOLATION

The violation

occurred due to lack of familiarity

with the requirements

for control of vendor information

by MOV testing personnel.

Although the technical

bulletin containing

the information

was forwarded

to corporate

engineering

for review and subsequent

incorporation

into the technical

manuals, station procedures

contained

a requirement

that the information

be forwarded

to station records .

• (3) CORRECTIVE

STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED The Station Manager issued a memo to station personnel

calling their attention

to the existing administrative

requirement

to forward vendor information

to station records upon receipt. The information

provided by Limitorque

has been reviewed by engineering

and forwarded

to station records for incorporation

into the Limitorque

vendor manual. (4) CORRECTIVE

STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS

Affected Limitorque

maintenance

procedures

will be updated to *include applicable

information.

(5) THE DATE WHEN FULL COMPLIANCE

WILL BE ACHIEVED Limitorque

procedures

will be updated by October 1990. As an additional

enhancement, the program for control of vendor information

is being streamlined

and strengthened

as part of the implementation

of the Surry Configuration

Management

Program.

Response to Notice of Violation

Inspection

Report Nos. 50-280/90-07

and 50-281/90-07

RESPONSE-PART

(4) (1) ADMISSION

OR DENIAL OF THE ALLEGED VIOLATION

The violation

is correct as stated. (2) REASON FOR VIOLATION

The violation

occurred due to the Operations

Department

having multiple "cognizant

supervisors" as defined by the administrative

procedure

without a single supervisor

assigned overall responsibility

for Operation's

Measuring

and Test Equipment (M& TE). (3) CORRECTIVE

STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED M&TE segregated

storage locations

have been established

to prevent damage to M&TE. Although the segregation

of M&TE may prevent the use of calibrated

M& TE in safety related applications, two way traceability

for equipment

used in quality work is maintained

by 1) recording

the equipment

and its SQC number Ori the procedure

being used, and 2) recording

the date and the procedure

for which the M&TE was used on the equipment's

Test Equipment

Record card. This traceability

process precludes

the use of calibrated

M& TE in safety related applications.

The Operations

Department

conducted

an inventory

of assigned M& TE. Equipment

which could not be located has been removed from the M& TE program. Since the remaining

Operation's

M&TE requires calibration,. "Calibration

Not Required" stickers were not required to be affixeq. Operators

have been reinstructed

to ensure thaf the use of M&TE is properly documented.

An Operation's

section supervisor

has been assigned responsibility

for ensuring that Operations

Department

M& TE due for calibration

is returned to the calibration

laboratory.

(4) CORRECTIVE

STEPS WHICH. WILL BE TAKEN TO AVOID FURTHER VIOLATIONS

None. (5) THE DATE WHEN FULL COMPLIANCE

WILL BE ACHIEVED Full compliance

has been achieved.