ML18153B867

Responds to NRC Re Deviations Noted in Insp Repts 50-280/88-32 & 50-281/88-32.Corrective Actions:Calibr Procedure CAL-466 Updated to Include Torque Requirements for Transmitter Vent & Drain Valves

ML18153B867
Person / Time
Site:	Surry
Issue date:	08/23/1989
From:	Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
89-565, NUDOCS 8908310012
Download: ML18153B867 (10)

Text

VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 August 23, 1989 United States Nutlear*Regulatory Commission Attention:

Document Control Desk Washington, D. C.

20555 Gentlemen:

VIRGINIA ELECTRIC AND POWER COMPANY SORRY POWER STATION UNITS 1 AND 2 RESPONSE TO NOTICE OF DEVIATION Serial No.

NL/CGL:vlh Docket Nos.

License Nos.

NRC INSPECTION REPORT NOS. 50-280/88-32 AND 50-281/88-32 89-565 Rev. 2 280 50-281 DPR-32 DPR-37 We have reviewed your letter of July 24, 1989 in reference to the inspection conducted at Surry Power Station on September 12-16, September 26-30 and November 14-18, 1988 and reported in Inspection Reports 50-280/88-32 and 50-281/88-32.

Our response to the two deviations described in the Notice of Deviation is provided in the attachment.

We have no objection to this inspection report being made a matter of public disclosure.

If you have further questions, please contact us.

Very truly yours, t

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w. l.. s tewa rt Senior Vice President - Power Attachment Copy:

U. S. Nuclear Regulatory Commission Regional Administrator Region II 101 Marietta Street, N. W.

Suite 2900 Atlanta, Georgia 30323 Mr. W. E. Holland NRC Senior Resident Inspector Surry Power Station 9900310012 giggE~eo PDR ADOCK PNU G

DEVIATION A RESPONSE TO NOTICE OF DEVIATION INSPECTION REPORT NOS. 50-280/88-32 AND 50-281/88-32 Description of the Deviation:

Nuclear Regulatory Commission Generic Letter 83-28 dated July 8, 1983, required actions based on generic implication of the Salem ATWS event.

Paragraph 2.2.

of the Enclosure requires that for vendor interface, licensees establish, implement, and maintain a continuing program to ensure that vendor information for safety-related components is complete, current and controlled throughout the life of their plants, and appropriately referenced or incorporated in plant instructions and procedures.

Virginia Power responses to this Generit Letter (Serial No. 617, dated November 4, 1983; Serial No.85-063, dated February 8, 1985; Serial No.85-211, dated May 20, 1985; and Serial No.85-63B, dated August 30, 1985) detailed the program which was implemented for Surry and North Anna Nuclear Plants.

Virginia Power response 85-063 states that revised administrative procedures which improve the availability and adequacy of vendor reference information are in use at each station. These procedures implement the means of collecting and controlling vendor information for use by personnel involved in maintenance, replacement and repair activities.

It further states that controlling Administrative Procedure 93, Vendor Interface Control Documents, at Surry, and Administrative Procedure 6.18, Control of Vendor Manuals, V~ndor Files and Interface, at North Anna, provide the primary activity for controlling vendor information for safety-related equipment.

These procedures provide a method of accumulating reference information.and making the information available to the various work activities. These procedures are currently in.use.

Contrary to the above, the requirements of this program are not being followed, in that, the following examples were identified where appropriate vendor information had not been included in site procedures:

1. Calibration procedure CAL

466, used to calibrate Rosemount transmitters, does not provide the vendor manual required closing torque (90 in-lbs) for the detector vent and drain valves.

2.

There are no site procedures to implement vendor manual (Limitorque) required mechanical preventive maintenance for valves 01-CW-MOV-lOOA, B,

C, D;

01-CW-MOV-106A, B,

C, D;

02-CW-MOV-200A, B,

C, D; or 02-CW-MOV-206A, B, C, D.

3.

Site procedures do not include the following Emergency Service Water Diesel vendor recommendations:

a.

The vendor manual requires a 20 minute wait after running the diesel for a check of the oil level.

b.

The vendor manual requires a periodic cleaning of the diesel cooling system using a radiator cleaning compound followed by a reverse flush with fresh water.

RESPONSE TO NOTICE OF DEVIATION

• 1NSPECTION REPORT NOS. 50-280/88-32 AND 50-281/88-32

c.

The vendor manual requires a periodic check of ihe ~rankc~se pressure.

d. The vendor manual requires a periodic cleaning of the air box check valves followed by blow out of the lines.

e.

The vendor manual requires a periodic inspection and cleaning of the blower screen.

f.

The vendor manual requires a periodic check/change of the lubrication in the reduction gear.

g.

The vendor manual requires verifying oil pressure is increasing.

h.

The vendor manual requires checking for oil leaks during pump runs.

4.

The Joseph Oats Corporation's Installation, Operation and Maintenance manual for Recirculation Coolers, Revision 2A, states recommendations for a desiccant maintenance program and rust requirements.

Visual observation of Recirculation Spray Heat Exchangers (RSHXs) prior to their being placed into containment identified ripped or torn covers on the RSHXs nozzles and rusting on bolts and flanges.-

Site procedures did not address these vendor recommendations.

DEVIATION A RESPONSE TO NOTICE OF DEVIATION

'INSPECTION REPORT NOS. 50-280/88-32 AND 50-281/88-32 (1). ADMISSION OR DENIAL OF THE ALLEGED DEVIATION:

The deviation is correct with the exceptions noted in (3) below.

(2)

REASON FOR THE DEVIATION:

Procedure revisions to address identified vendor recommendations did not*

incorporate or adequately document the subject vendor requirements.

(3)

CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:

The specific concerns of the deviation are addressed as follows:

Item 1:

Calibration procedure CAL-466 has been updated to include torque requirements for the transmitter vent and drain valves.

Temporary procedure changes will be used to include and document torque requirements in other Rosemount transmitter calibration procedures until the procedures are-revised under the procedure upgrade program.

A memo explaining this requirement has been written and placed in the Instrument Department required reading book.

Item 2:

A mechanical preventive maintenance procedure, which performed vendor technical manual maintenance activities, was implemented in October 1988.

Specific vendor recommended maint~nance was satisfied on the subject valves during the recent outages by performing either the necessary preventive or corrective maintenance.

An upgraded mechanical preventive maintenance procedure for the subject valves based on vendor recommendations, industry standards, and operational experience was implemented in July 1989.

The new procedure includes activities which address specific vendor manual recommendations.

This procedure will be used to perform subsequent mechanical preventive maintenance work on the subject valves.

Item 3a:

The specific wait period for the oil level check has been incorporated into the operating procedure which starts and stops the engine, as well as the applicable periodic test procedures.

The preventive maintenance procedure will be revised as noted in (4) below.

Item 3b:

The heat exchanger for each engine was disassembled and inspected during maintenance performed after the NRC inspection.

The heat exchangers

RESPONSE TO NOTICE OF DEVIATION INSPECTION REPORT NOS. 50-280/88-32 AND 50-281/88-32 were found to be clean and unobstructed.

The visible por.tions of both the raw water and the coolant water portions of the system were found to be clean.

Chemical cleaning of the coolant system was determined to be unnecessary (based on visual inspection) and was not performed.

The disassembly and inspection of the heat exchanger was added to the present

• preventive maintenance procedure, which is scheduled to be performed on a 12 month frequency.

Chemical cleaning will be done, if necessary, as a result of visual inspection.

Item 3c:

The engine crankcase pressure was measured during maintenance performed after the NRC inspection and found to be within specification.

A check of crankcase pressure was also added to the current preventive maintenance procedure for the engines, which is scheduled to be performed on a 12 month frequency.

Item 3d:

Emergency Service Water Pump Diesels at Surry Power Station are not equipped with air box check valves.

The vendor manual is written for engines with a variety of applications and options.

This option would likely be used in a turbocharged diesel; the subject engines are not turbocharged.

Therefore, this item is not applicable.

Item 3e:

The blower screen for each engine was cleaned during maintenance performed after the NRC inspection.

No unsatisfactory conditions were noted.

Inspection of the blower screen was added to the existing preventive maintenance procedure, which is scheduled to be performed on a 12 month frequency.

Item 3f:

The reduction gear referred to in the Emergency Service Water Pump Diesel technical manual is not part of equipment installed at Surry.

Therefore, this item is not applicable.

Item 3g:

Specific instructions to verify increasing oil pressure immediately after starting the engine were added to applicable operating procedures and periodic tests.

If the oil pressure indication is not within specification, the engine is to be shut down immediately and the cause of the indication determined before the engine is started again.

The preventive maintenance procedure will be revised as noted in (4) below.

Item 3h:

RESPONSE TO NOTICE OF DEVIATIUN INSPECTION REPORT NOS. 50-280/88-32 AND 50-281/88-32 Checking for oil leaks whi1e the engine is running was included in the preventive maintenance procedure in place at the time of the NRC inspection.

The applicable operating and periodic test procedures will be revised as noted in (4) below.

Item 4:

The site procedure SUADM-MM-05, * "Storage of Material at the Station Warehouse and Storeroom", addresses the requirements for maintenance of storage items.

However, this procedure was not the controlling document at*the time of the NRC inspection. A design change package controlled the requirements to be followed prior to installation. The vessels had been shipped from the vendor with anticipation for immediate field preparation for installation.

The desiccant program was not implemented because the vessels were not being stored; instead they were being prepared for installation.

The nozzle covers had been installed at the factory to m1n1m1ze foreign material intrusion.

Prior to installation, the covers were removed and an inspection was performed to ensure cleanliness, as required by the design change contro 11 i ng procedure.

The i den ti fi ed rust was removed from bolts and flanges and the bolts were painted, per the design change controlling procedure.

(4)

CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER DEVIATIONS:

The preventive maintenance procedure for the Emergency Service Water Pump Diesels will be revised to include a 20 minute wait period after starting the diesel before checking the oil level and verifying an increasing oil pressure after starting the engine.

The applicable operating and periodic test procedures will be revised to require checking the Emergency Service Water Pump Diesels for oil leaks when in operation.

A procedure upgrade program, which will include more thorough review and documentation of vendor recommendations, has been initiated.

The calibration procedures for Rosemount transmitters will be revised under this program to include the torquing requirements referenced above.

In addition, the administrative procedure SUADM-ADM-05, "Procedure Review Standard", contains the following items on the procedure review checklist:

Verify that the referenced documents and vendor technical manuals are current and applicable.

Incorporate vendor recommendations, if applicable.

By this procedure, a review must be conducted no less than once every two years.

Site receiving procedures will be reviewed relative to the need to incorporate interim storage requirements.

RESPONSE TO NOTICE OF DEVIATION

'INSPECTION REPORT NOS. 50-280/88-32 AND 50-281/88-32 (5)

THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

The preventive_ maintenance, periodic test, and operating procedures referenced in ( 4) above will' be revised by October 31, 1989.

The Rosemount transmitter calibration procedures will be progranmatically revised to include the applicable torquing requirements under the procedure upgrade program.

(

Reference:

Letter Serial No *.88-387 dated July 13, 1988).

Site receiving procedures wi.l l be reviewed by October 31, 1989.

DEVIATION B RESPONSE TO NOTICE OF DEVIATION INSPECTION REPORT NOS. 50-280/88-32 AND 50-281/88-32 Description of-the Deviation:

The Updated Final Safety Analysis Report (UFSAR) Section 7.2.1, states that the reactor protection system and engineered safeguards are designed in accordance with IEEE-279, Standard Nuclear Power Plant Protection System, dated August 1968.

Paragraph 4.13 of this Standard states that if the protective action of some parts of the system has been bypassed or deliberately rendered inoperable for any purpose, this fact shall be continuously indicated in the control rogm.

Contrary to the above, portions of the service water systems can be bypassed and this condition is not continuously indicated in the control room.

Specifically, the recirculation spray inlet and outlet valves SW-104A, B, C, D

and SW-105A, B,

C, D have a bypass function that allows for manually closing the valves during a Consequence Limiting Safeguards HI-HI condition.

DEVIATION B RESPONSE TO NOTICE OF DEVIATION INSPECTION REPORT NOS. 50-280/88-32 AND 50-281/88-32 (1)

ADMISSION OR DENIAL OF THE ALLEGED DEVIATION:

The deviation is incorrect as stated.

The following items form the basis for the discussion of continuous indication of a bypassed action associated with protective systems:

A.

The Surry Power Station UFSAR (Section 7.2.1, page 7.2-3) indicated that IEEE 279-1968 is the design basis.

B.

The following definitions and sections are given in IEEE 279-1968:

Protective Action:

An action initiated by the protective system when a limit is exceeded.

A protective action can be at channel or system level.

Protective Function:

A system protective action which results from the protective action of the channels monitoring a particular plant condition.

Section 4.13 Indication of Bypasses:

If the protective action of some part of the system has been bypassed or deliberately rendered inoperative for any purpose, this fact shall be continuously indicated in the control room.

Section 4.16 Completion of Protective Action Once It Is Initiated:

The protective system shall be so designed that, once initiated, a protection system action shall go to completion.

Return to operation shall require subsequent deliberate operator action.

During review of the design change for the Recirculating Spray Heat Exchanger Isolation Valve Logic

Change, the NRC inspectors identified that the design change incorporated a manual override feature which bypassed the Consequence Limiting Safeguards (CLS)

HI-HI signal in the 11open 11 control circuitry for recirculation spray heat exchanger (RSHX) service water isolation valves (MOV-SW-104A, B,

C, D;

MOV-SW-105A, B,

C, D;

MOV-SW-204A, B, C, D; and MOV-SW-205A, B, C, D).

The manual override feature is initiated by the manual control switch for the valves and is accomplished by simply operating the manu~l control switch to the 11 CLOSE 11 position after the CLS HI-HI signal has fully opened the valve.

Plant operators are required to isolate a RSHX by an Abnormal Procedure when the RSHX radiation monitors indicate that there is high radiation present in the service water discharging from the RSHXs.

The 11 protective action 11 is the opening of the RSHX SW isolation valves which cannot be bypassed and the valves will fully open upon a CLS HI-HI signal.

The requirement of Section 4.13 is satisfied by the fact that the opening of the valves (i.e., the protective action) cannot be bypassed.

Section 4.16 allows the actuated component to "return to operation 11 by deliberate action of a control room operator and no annunciation requirement is specified for that case.

RESPONSE TO NOTICE OF DEVIATION INSPECTION REPORT NOS. 50-280/88-32 AND 50-281/88-32 This position is also consistent with the guidance provided in Regulatory Guide 1.47, 11 Bypassed and Inoperable Status Indication for Nuclear Power Plant Safety Systems 11.