ML18152A472
| ML18152A472 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 01/20/1998 |
| From: | OHANLON J P VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-280-97-09, 50-280-97-9, 50-281-97-09, 50-281-97-9, 97-745, NUDOCS 9801270034 | |
| Download: ML18152A472 (13) | |
See also: IR 05000280/1997009
Text
- * VIRGINIA ELECTRIC AND PowER CoMPANY RICHMOND, VIRGINIA 23261 January 20, 1998 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. SPS/CGL Docket Nos. License Nos. NRC INSPECTION
REPORT NOS. 50-280/97-09
AND 50-281/97-09 97-745 R2" 50-280 50-281 DPR-32 DPR-37 We have reviewed Inspection
Report Nos. 50-280/97-09
and 50-281 /97-09 dated December 24, 1997, and the enclosed Notice of Violation (NOV) and Notice of Deviation
for Surry Units 1 and 2. In response to the issues raised in the inspection
report, we have taken corrective
actions and plan additional
actions. The actions focus on restoring
vital bus isolation
and providing
breaker coordination, heightening
personnel
awareness
relative to Appendix R, ensuring that a situation
similar to the vital bus isolation
issue does not exist, and continuing
our programmatic
review of the Appendix R program. The commitments
made in this letter are summarized
below. We have no objection
to this letter being made part of the public record. Please contact us if you have any questions
or require additional
information.
Very truly yours, James P. O'Hanlon Senior Vice President
-Nuclear Attachment
9801270034
980120 PDR ADOCK 05000280 G PDR * '-' .J ... , I llll/111/111111111111
lflll//l/111111111
- .i !:ii C 7 * o/
1---* * * cc: US Nuclear Regulatory
Commission
Region II Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, Georgia 30303 Mr. R. A. Musser NRC Senior Resident Inspector
Surry Power Station SUMMARY OF COMMITMENTS
The following
commitments
are made in response to the Notice of Violation
and Notice of Deviation
in NRC Inspection
Report Nos. 50-280/97-09
and 50-281/97-09:
1 . The modifications
to address the vital bus isolation
and breaker coordination
issues will be completed
on Unit 1 during the next refueling
outage. The required compensatory
measures will remain in place until the modifications
are completed
on Unit 1. [October -November 1998 refueling
outage] 2. Appendix R awareness
training will be conducted
for appropriate
personnel
in the Nuclear Business Unit. This training will focus on the Appendix R design and licensing
bases, as well as Appendix R compliance
and implications.
The awareness
training will include a discussion
of how insufficient
communication
contributed
to the inappropriate
prioritization
and delay in implementation
of the modification.
[First Quarter 1998] 3. A memorandum
will be issued to appropriate
Nuclear Business Unit personnel
describing
how the use of ambiguous
language contributed
to the delay in implementation
of the required modifications
and reinforcing
the need for and management
expectation
of effective
communication.
[February
1998] 4. A multi-utility
assessment
of our Appendix R Program will be conducted
using the applicable
portions of the draft Fire Protection
Functional
Inspection (FPFI) Temporary
Instruction
2515/xxx, which was used during the recent River Bend FPFI. [April 1998 -Reference:
Letter S/N 98-020] 5. A multi-disciplined
review of portions of the Appendix R Report will be conducted.
This review which will include Chapters 3 and 4 will assess the accuracy of the Appendix R Report relative to the current plant configuration, and will validate compliance
with the Appendix R requirements.
[July 15, 1998] 6. The fire protection
administrative
procedure
will be expanded to include the original bases for the existing compensatory
measures.
Consistent
with the guidance in Information
Notice 97-48, the fire-watch-only
compensatory
measures will be reviewed for possible expansion
to include other interim measures, such as operator briefings, temporary
repairs or procedures, installation
and use of temporary
fire barriers, and additional
detection
and suppression, as appropriate.
[July 1, 1998]
- REPLY TO A NOTICE OF VIOLATION . NRC INSPECTION
CONDUCTED
AUGUST 24, 1997 THROUGH OCTOBER 4, 1997 SURRY POWER STATION UNITS 1 AND 2 INSPECTION
REPORT NOS. 50-280/97-09
AND 50-281/97-09
NRC COMMENT: "During an NRC inspection
conducted
on August 24 through October 4, 1997, violations
of NRC requirements
were identified.
In accordance
with the "General Statement
of Policy and Procedures
for NRC Enforcement
Actions," NUREG-1600, the violations
are listed below: A. 10 CFR 50.48 states, in part, that each operating
nuclear plant licensed to operate prior to January 1, 1979, shall satisfy the requirements
of 10 CFR 50, Appendix R, Section 111.G. Both Surry units were licensed prior to January 1, 1979. 10 CFR 50, Appendix R, Section 111.G.1.(a)
requires fire protection
features to be provided for structures, systems and components
important
to safe shutdown to limit fire damage such that one train of systems necessary
to achieve and maintain hot shutdown conditions
from either the control room or emergency
control station(s)
is free from fire damage. 1 O CFR 50, Appendix R, Section 111.G.2 requires the protection
of one redundant
shutdown train from fire damage which could result in hot shorts, open circuits or shorts to ground during an Appendix R type fire. Contrary to the above, from July 1988 for Unit 1 and September
1989 for Unit 2 until August 29, 1997, the licensee failed to provide adequate fire protection
features for structures, systems and components
important
to safe shutdown in that adequate means were not available
to isolate the circuits from 120 volt alternating
current power panels VB 1-1 and VB 1-11 I and panels VB 2-1 and VB 2-111, located in the respective
Unit 1 and 2 computer rooms in the control room complex, from the uninterruptable
power supply (UPS) panels. Electrical
faults from a 10 CFR Part 50, Appendix R, fire in the control room complex could cause the loss of power from UPS panels 1A-1, 1A-2, 2A-1 and 2A-1 [should be 2A-2]. These UPS panels provide power to the Appendix R remote shutdown panels, located in each unit's emergency
switchgear
room and in the cable spreading
room; and, supply power to the Appendix R communication
equipment
located adjacent to the auxiliary
shutdown panels in each emergency
switchgear
room. The Appendix R panels contained
the instrumentation
required for performing
a plant shutdown from outside the main control room and included instrumentation
for steam generator
level, reactor coolant system pressure and temperature, and pressurizer
level. (01013) Page 1
- * B. Surry Operating
License Section 2.1 for Units 1 and 2 provides that the licensee is required to implement
and maintain the administrative
controls identified
in Section 6. of the Fire Protection
Safety Evaluation . The Surry Fire Protection
Program is described
in the Surry Appendix R Report. Chapter 12, Section C of the Surry Appendix R Report describes
the Quality Assurance
program that is applicable
to the fire protection
program. Section C.8 states that measures established
to ensure* that conditions
adverse to fire protection, such as failures, malfunctions, deficiencies, deviations, defective
components, uncontrolled
combustible
materials
and noncomformances, are promptly identified, reported and corrected.
Contrary to the above, as of August 29, 1997, the licensee failed to identify fully and correct a noncompliance
with Appendix R requirements
for the control room associated
with a vital bus isolation
issue discovered
by the licensee in 1992. Specifically, because the licensee failed to recognize
the significance
of the issue and the fact that the plant was outside the design basis, adequate corrective
actions and compensatory
measures were not implemented
until 1997. (01023) These violations
constitute
a Severity Level Ill problem (Supplement
I). C. 1 O CFR 50. 72(b)(1 )(ii)(B) requires the licensee to notify the NRC of identified
plant conditions
that are outside the design basis of the plant. The notification
is to be made as soon as practical
but within one hour of the occurrence.
Contrary to the above, on September
30, 1997, the licensee failed to notify the NRC within one hour of the occurrence, of conditions
outside the design basis of the plant. Specifically, on this date, the licensee determined
that Surry Units 1 and 2 had been outside its Appendix R design basis due to a 120 VAC vital bus isolation
issue. Although the licensee concluded
that the outside of design basis condition
was a past condition, the Units were in fact still outside the design basis and a one-hour report was required.
(02014) This is a Severity Level IV violation (Supplement
I)." Page 2
- * * REPLY TO A NOTICE OF VIOLATION
NRC INSPECTION
CONDUCTED
AUGUST 24. 1997 THROUGH OCTOBER 4.1997 SURRY POWER STATION UNITS 1 AND 2 INSPECTION
REPORT NOS. 50-280/97-09
AND 50-281/97-09
Violation
A 1. Reason for the Violation, or, if Contested, the Basis for Disputing
the Violation
2. The violation
is correct as stated. The vital bus* isolation
issue was identified
in 1992, and a station deviation
was issued. Following
identification
of this issue, a modification
was planned to restore vital bus isolation
in the event of a Main Control Room (MCR) fire. It was then considered
that the MCR being continuously
manned was an acceptable
compensatory
measure until the modification
was implemented.
A foundational
error occurred in 1992 in that these compensatory
measures were believed to be equivalent
to compliance
with the Appendix R design basis. Inappropriate
prioritization
of the required modification
resulted from this error. Contributing
causal factors were written and verbal communication.
Specifically, the documentation
regarding
the vital bus isolation
issue used ambiguous
language, which contributed
to the foundational
error. In addition, the significance
of the vital bus isolation
issue was not effectively
communicated
verbally, which also contributed
to the foundational
error. Corrective
Steps Which Have Been Taken and the Results Achieved As discussed
during the predecisional
enforcement
conference
on the December 4, 1997, a number of corrective
actions have been completed.
The completed
corrective
actions, which are summarized
in the following
paragraphs, focused on restoring
vital bus isolation
and ensuring that a situation
similar to the isolation
issue does not exist: -The design change implementing
the modification
to restore vital bus isolation
in the event of a MCR fire was completed
on Unit 2 during the October 1997 refueling
outage. With this design change completed
on Unit 2, the current capabilities
relative to vital bus isolation
are that: hot shutdown can be achieved and maintained
on both units with no repairs or compensatory
measures, cold shutdown can be achieved on Unit 1 without compensatory
measures, and cold shutdown can be achieved on Unit 2 using the compensatory
measures currently
in place. These compensatory
measures will remain in Page 3
- place until the modification
is completed
on Unit 1 during the next refueling
outage, scheduled
to begin in October 1998. -A Category 1 RCE was conducted
to determine
the root cause and contributing
causal factors in the untimely corrective
action associated
with the vital bus isolation
issue. The conclusions
from the RCE are incorporated
in the above discussion
of Reason for the Violation.
A number of corrective
actions related to the RCE have been approved for implementation, some of which are listed below in Item 3. -The fire protection
administrative
procedure
has been revised to address the implementation
of non-standard
compensatory
measures.
Non-standard
compensatory
measures are those actions that had not previously
been defined in the fire protection
administrative
procedure.
In contrast, standard compensatory
measures for anticipated
conditions, such as the action required when a fire barrier is found to be breached, are those that have been previously
defined and approved in the administrative
procedure.
Based on the recent administrative
procedure
revision, implementation
of a non-standard
compensatory
measure now requires an engineering
technical
evaluation, which considers
defense in depth, design basis, and safety significance
in defining the required actions. Briefings
were conducted
with on-shift Shift Technical
Advisors to familiarize
them with the revision to the administrative
procedure.
-An assessment
of the existing non-standard
compensatory
measures currently
in place was conducted.
This review identified
no issues or concerns.
-The Operating
Experience
group completed
a review of Information
Notice 97-48, titled Inadequate
or Inappropriate
Interim Fire Protection
Compensatory
Measures.
That review identified
the lack of guidance for implementation
of non-standard
compensatory
measures.
The administrative
procedure
revision discussed
above addresses
this observation.
Our December 4, 1997 presentation
included identification
of approximately
thirty design changes and engineering
work requests that were completed
primarily
in the 1984 to 1987 time to address the initial Appendix R requirements.
These design changes have been reviewed to verify that the Appendix R features installed
by these changes remain intact. * Page 4
-* * Independent
of the Appendix R issues, the corrective
action program was recently revised to reflect an enhanced process to prioritize
deviation
reports. A multi-disciplined, multi-departmental
team reviews the deviation
report assignments
and significance
levels proposed by the initial screening.
This team has been trained to recognize
issues of safety and regulatory
significance.
3. Corrective
Steps Which Will be Taken to Avoid Further Violations
The December 4, 1997 predecisional
enforcement
conference
included discussion
of a number of corrective
actions that are planned. The planned corrective
actions, which are summarized
in the following
paragraphs, focus on heightened
awareness
relative to Appendix R and effective
communication, as well as continued
programmatic
review of the Appendix R program: -Appendix R awareness
training will be conducted
for appropriate
personnel
in the Nuclear Business Unit. This training will focus on the Appendix R design and licensing
bases, as well as Appendix R compliance
and implications.
The awareness
training will include a discussion
of how insufficient
communication
contributed
to the inappropriate
prioritization
and delay in implementation
of the modification.
It is expected that this training will occur during the first quarter of 1998. -A memorandum
will be issued to appropriate
Nuclear Business Unit personnel
by February 1998 describing
how the use of ambiguous
language contributed
to the delay in implementation
of the required modifications
and reinforcing
the need for and management
expectation
of effective
communication.
A multi-utility
assessment
of our Appendix R Program will be conducted
using the applicable
portions of the draft Fire Protection
Functional
Inspection (FPFI) Temporary
Instruction
2515/xxx, which was used during the recent River Bend FPFI. This assessment
had been scheduled
for January 1998. We recently advised the NRC that this assessment
has been postponed
until April 1998. [Reference:
Letter S/N 98-020] -A multi-disciplined
review of portions of the Appendix R Report will be conducted.
This review will include Chapters 3, "Safe Shutdown Systems Analysis," and 4, "Appendix
R Section 111.G Compliance
Summary." For the chapters being reviewed, the accuracy of the Appendix R Report will be assessed relative to the current plant configuration, and compliance
with the Appendix R requirements
will be confirmed.
This review is scheduled
for completion
by July 15, 1998. Related to Information
Notice 97-48, titled Inadequate
or Inappropriate
Interim Fire Protection
Compensatory
Measures, a review of the fire protection
administrative
procedure
noted that the standard compensatory
measures as they currently
exist (in the administrative
procedure)
vary depending
on the equipment
that is inoperable.
The administrative
procedure
will be expanded to include the original bases for the existing compensatory
measures.
Page 5
Consistent
with the guidance in Information
Notice 97-48, the fire-watch-only
compensatory
measures will be reviewed for possible expansion
to include other interim measures, such as operator briefings, temporary
repairs or procedures, installation
and use of temporary
fire barriers, and additional
detection
and suppression, as appropriate.
This additional
review and revision is scheduled
for completion
by July 1, 1998. 4. The Date When Full Compliance
Will be Achieved . In view of the current capabilities
relative to vital bus isolation, which are outlined in Item 2 above, compliance
with Appendix R requirements, as well as with the Surry Appendix R design basis requirements, was achieved when the modification
was completed
on Unit 2 during the last refueling
outage ending in November 1997. Upon completion
of the Unit 1 modification
during the refueling
outage scheduled
to begin in October 1998, compliance
with the Surry Appendix R . licensing
basis will also be achieved.
Violation
B 1. Reason for the Violation, or, if Contested, the Basis for Disputing
the Violation
The violation
is correct as stated. As noted in the response to Violation
A, a foundational
error occurred in 1992 in that these compensatory
measures were believed to be equivalent
to compliance
with the Appendix R design basis. Inappropriate
prioritization
of the required modification
resulted from this error. Therefore, implementation
of the modification
required to restore vital bus isolation
was delayed. The delay in correcting
the vital bus isolation
issue is attributed
to the fact that the postponement
was not sufficiently
challenged
in view of the foundational
error that compensatory
measures suffice for compliance.*
2. Corrective
Steps Which Have Been Taken and the Results Achieved As noted in the response to Violation
A, a number of corrective
actions have been taken related to the vital bus isolation
issue. The actions directly associated
with the delay in accomplishing
the modification
to restore vital bus isolation
are the following:
-The recent Category 1 RCE was conducted
to determine
the root cause and contributing
causal factors in the untimely corrective
action associated
with the vital bus isolation
issue. The conclusions
from the RCE are reflected
in the above discussion
of Reason for the Violation.
A number of corrective
actions related to the RCE have been approved for implementation, some of which are listed below in Item 3. Page 6
- * * 3. 4. Independent
of the Appendix R issues, the corrective
action program was recently revised to reflect an enhanced process to prioritize
deviation
reports. A multi-disciplined, multi-departmental
team reviews the deviation
report assignments
and significance
levels proposed by the initial screening.
This team has been trained on significance
levels. Corrective
Steps Which Will be Taken to Avoid Further Violations
As noted in the response to Violation
A, a number of corrective
actions are planned related to the vital bus isolation
issue. The actions directly associated
with heightened
sensitivity
related to the timeliness
of Appendix R corrective
_ actions are the following:
-Appendix R awareness
training will be conducted
for appropriate
personnel
in the Nuclear Business Unit. This training will focus on the Appendix R design and licensing
bases, as well as Appendix R compliance
and implications.
The awareness
training will include a discussion
of how insufficient
communication
contributed
to the inappropriate
prioritization
and delay in implementation
of the modification.
It is expected that this training will occur during the first quarter of 1998. -A memorandum
will be issued to appropriate
Nuclear Business Unit personnel
by February 1998 describing
how the use of ambiguous
language contributed
to the delay in implementation
of the required modifications
and reinforcing
the need for and management
expectation
of effective
communication.
The Date When Full Compliance
Will be Achieved In view of the current capabilities
relative to vital bus isolation, which are outlined in Item 2 of the response to Violation
A, compliance
with Appendix R requirements, as well as with the Surry Appendix R design basis requirements, was achieved when the modification
was completed
on Unit 2 during the last refueling
outage ending in November 1997. Upon completion
of the Unit 1 modification
during the refueling
outage scheduled
to begin in October 1998, compliance
with the Surry Appendix R licensing
basis will also be achieved.
Violation
C 1. Reason for the Violation, or, if Contested, the Basis for Disputing
the Violation
The violation
is correct as stated. On September
30, 1997, when it was determined
that Surry had been outside the Appendix R design basis due to the vital bus isolation
issue, adequate compensatory
measures were in place. With those compensatory
measures in place, the required Appendix R function of achieving
and maintaining
safe shutdown conditions
could have been ac,complished
in the event of a MCR fire. Page 7
- * Additionally, with the compensatory
measures in place, it was believed we were in compliance
with the Appendix R design basis. Therefore, a one-hour report was not made to the NRC. Instead, a Licensee Event Report was issued on October 30, 1997. Based on the NRC input provided in Inspection
Report 97-09, we recognize
that 1 OCFR50, Appendix R, Section 111.G.1.(a)
requires that hot shutdown conditions
be achieved and maintained
without repairs, in contrast to Section 111.G.1.{b)
which allows repairs to achieve and maintain cold shutdown conditions.
At that time, the compensatory
measures in place required the disconnection
of a UPS cable and the possible replacement
of fuses (i.e., repairs) to achieve and maintain hot shutdown conditions
on both units. Therefore, in this case, a one-hour report should have been made when it was determined
that Surry had been outside the Appendix R design basis due to the vital bus isolation
issue and prior to the modification
being completed
on Unit 2 during the last refueling
outage ending in November 1997. 2. Corrective
Steps Which Have Been Taken and the Results Achieved We have reviewed the NRC's comments regarding
reportability
in Inspection
Report 97-09 in view of Surry's current configuration.
As noted in the response to Violation
A, with the design change completed
on Unit 2, the current capabilities
relative to vital bus isolation
are that: hot shutdown can be achieved and maintained
on both units with no repairs or compensatory
measures, cold shutdown can be achieved on Unit 1 with no compensatory
measures, and cold shutdown can be achieved on Unit 2 using the compensatory
measures currently
in place. Therefore, relative to vital bus isolation, compliance
with the Appendix R requirements, as well as with the Surry Appendix R design basis requirements, was achieved when the modification
was completed
on Unit 2. So a one-hour report was no longer necessary
as of the completion
of the Unit 2 refueling
outage in November 1997. 3. Corrective
Steps Which Will be Taken to Avoid Further Violations
As noted in the response to Violation
A, a number of corrective
actions are planned related to the vital bus isolation
issue. The action directly associated
with the reportability
aspects of the vital bus isolation
issue is the following:
Appendix R awareness
training will be conducted
for appropriate
personnel
in the Nuclear Business Unit. This training will focus on the Appendix R design and licensing
bases, as well as Appendix R compliance
and implications.
It is expected that this training will occur during the first quarter of 1998. Page 8
4. The Date When Full Compliance
Will be Achieved In view of the current capabilities
relative to vital bus isolation, which are outlined in Item 2 of the response to Violation
A, compliance
with Appendix R requirements, as well as with the Surry Appendix R design basis requirements, was achieved when the modification
was completed
on Unit 2 during the last refueling
outage ending in November 1997. Upon completion
of the Unit 1 modification
during the refueling
outage scheduled
to begin in October 1998, compliance
with the Surry Appendix R licensing
basis will also be achieved.
Page 9
' REPLY TO A NOTICE OF DEVIATION . NRC.INSPECTION
CONDUCTED
AUGUST 24, 1997 THROUGH OCTOBER 4, 1997 SURRY POWER STATION UNITS 1 AND 2 INSPECTION
REPORT NOS. 50-280/97-09
AND 50-281/97-09
NRG COMMENT: "During an NRG inspection
conducted
on August 24 through October 4, 1997, a deviation
of your Updated Final Safety Analysis Report (UFSAR) was identified.
In accordance
with the "General Statement
of Policy and Procedures
for NRG Enforcement
Actions," NUREG-1600, the deviation
is listed below: UFSAR Section 9.10.1 states that the station's
fire protection
program satisfies
the regulatory
criteria set forth in General Design Criterion 3, in 10 CFR 50 Appendix R (Sections
111.G, 111.J, 111.L and 111.0), and in Appendix A to Branch Technical
Position APCSB 9.5-1 dated August 23, 1976. Compliance
with these criteria is contained
in the 10 CFR 50 Appendix R Report, Surry Power Station Units 1 and 2. The 10 CFR 50 Appendix R Report, Surry Power Station, Units 1 and 2, Revision 11, Chapter 9, Electrical
Distribution
System Coordination
Study, Section 9.1, states that coordination
of circuit protective
devices to prevent unnecessary
outages of power supplies needed for safe shutdown is required to conform to the requirements
of Appendix R. The Appendix R Report states that components
involved in critical circuits were investigated
and data gathered to facilitate
verification
of the capability
of the interrupting
devices to operate selectively
and to continue to supply power to all critical circuits not affected by the postulated
fire. Section 9.2 of Chapter 9 concluded
that miscoordination
existed on the 120 volt alternating
current (VAC) bus system due to the maximum half cycle instantaneous
current supplied by the bypass transformers.
The Appendix R report states that, to assure coordination, the Square D 100 ampere (amp) trip main circuit breakers in each vital bus panel will be replaced with non-automatic
molded case switches.
Contrary to the above, the 100 amp breakers were not replaced with non-automatic
switches as committed
to in the Appendix R Report to ensure compliance
with UFSAR Section 9.10.1. This resulted in inadequate
breaker coordination
between the vital bus branch circuits and vital bus main panel breaker of the vital bus panels supplying
circuits installed
in the Units 1 and 2 emergency
switchgear
rooms and the Turbine Building.
Each of these panels supply Appendix R and safe shutdown related components." Page 10
I * REPLY TO A NOTICE OF DEVIATION
NRC INSPECTION
CONDUCTED
AUGUST 24. 1997 THROUGH OCTOBER 4. 1997 SURRY POWER STATION UNITS 1 AND 2 INSPECTION
REPORT NOS. 50-280/97-09
AND 50-281/97-09
1. Reason for the Deviation, or, if Contested, the Basis for Disputing
the Deviation
The deviation
is correct as stated. Although breaker coordination
is not required to comply with the Appendix R design base, it is assumed in the Appendix R Report and therefore
is a commitment
consistent
with the Appendix R licensing
basis for Surry. The breaker coordination
issue was identified
in 1993, and a station deviation
was , issued. When this issue was identified, it was recognized
that a postulated
high fault current and the resultant
potential
breaker miscoordination
was a highly unlikely event. In addition, the potential
loss of a single vital bus was a condition
addressed
by procedure.
The modification
required to address breaker coordination
was coupled with the modification
planned to address the vital bus isolation
issue and included in a single design change package. As stated in the responses
to Violations
A and B, the modification
required to restore vital bus isolation
was inappropriately
prioritized
and the implementation
was delayed. Therefore, it followed that the modification
required to address breaker coordination
was also inappropriately
prioritized
and its implementation
was also delayed. 2. Corrective
Steps Which Have Been Taken and the Results Achieved The design change implementing
the modification
to address the breaker coordination
issue was completed
on Unit 2 during the October 1997 refueling
outage. 3. Corrective
Steps Which Will be Taken to Avoid Further Violations
4. The design change is scheduled
to be completed
on Unit 1 during the next refueling
outage, scheduled
to begin in October 1998. The compensatory
measures currently
in place will remain in place until the modification
is completed
on Unit 1. The Date When Full Compliance
Will be Achieved Full compliance
will be achieved regarding
the breaker coordination
issue when the required modification
is implemented
on Unit 1 during the next refueling
outage scheduled
to begin in October 1998. Page 11