ML18153B867
| 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.