ML18153B867

Responds to NRC 890724 Ltr 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)

See also: IR 05000280/1988032

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 -50-280 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 ( t 1--C-( : ;. __ SL \,:,.) i \tj /\'.-_J's, 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 , I

• • * 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 11 open 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.