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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217K4391999-10-18018 October 1999 Provides Response to RAI to Support USI A-46 Program Submittal for North Anna Power Station,Units 1 & 2.Rev 10 to BNL Rept 52361,encl ML20217H3301999-10-14014 October 1999 Forwards Rev 0 to COLR for North Anna 2 Cycle 14 Pattern Su. No New Commitments Intended by Ltr ML18152B3541999-10-12012 October 1999 Requests Use of Code Case N-532 & N-619,per Provisions of 10CFR50.55a(a)(3).Detailed Info Supporting Request,Encl. Attachment 2 Includes Technical White Paper That Provides Further Technical Info ML20216K1681999-10-0101 October 1999 Forwards Vols I-VIII of Rev 35 to UFSAR for Naps.Rev Also Includes Update to Chapter 17 of Ufsar,Which Contains Operational QA Program.Changes to Program Description Do Not Reduce Commitments Contained Therein ML20212J9101999-10-0101 October 1999 Forwards SE Accepting Licensee 990916 & 27 Relief Requests IWE-3 for Plant.Se Addresses Only IWE-3 Due to Util Urgent Need for Relief.Requests IWE-7 & IWE-8 Will Be Addressed at Later Date ML18152B3391999-09-27027 September 1999 Forwards Revised Relief Request IWE-3,which Now Includes Addl Visual Exam Requirement After post-repair or Mod Pressure Testing Is Completed,Per Telcon with NRC ML20212G5091999-09-22022 September 1999 Forwards in Triplicate,Applications for Renewal of Licenses for Listed Individuals.Encls Withheld,Per 10CFR2.790(a)(6) ML18152B6671999-09-17017 September 1999 Forwards Two NRC Forms 536,containing Info on Proposed Site Specific Operator Licensing Exam Schedules & Estimated Number of Applicants Planning to Take Exams And/Or Gfes,In Response to NRC Administrative Ltr 99-03 ML18152B3331999-09-17017 September 1999 Forwards Revised 180-day Response to NRC GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves ML18152B3341999-09-16016 September 1999 Requests Relief from Specific Requirements of Subsection IWE of 1992 Edition with 1992 Addenda of ASME Section XI Re Containment Liner Examination Requirements,For North Anna & Surry Power Stations ML20216E6661999-09-10010 September 1999 Forwards Analysis of Capsule W Virginia Power North Anna Unit 1 Nuclear Power Plant Reactor Vessel Matl Surveillance Program, for Capsule Withdrawn on 980922 ML20211N2531999-09-0808 September 1999 Responds to Request to Exceed 60,000 Mwd/Mtu Lead Rod Burnup in Small Number of Fuel Rods in North Anna Unit 2.Informs That NRC Offers No Objection to Requested Use of Rods in Reconstituted Fuel Assembly.Se Supporting Request Encl ML20211L9151999-09-0101 September 1999 Forwards Response to NRC Request for Comments Re Closure of Review of Response to GL 92-01,Rev 1,Suppl 1, Reactor Vessel Structural Integrity ML18152B4471999-09-0101 September 1999 Requests That NRC Remove Listed Labels from Distribution ML18151A6301999-09-0101 September 1999 Submits Summary of 990812-13 Training Managers Conference on Recent Changes to Operator Licensing Program.Meeting Covered Changes to Regulations,Examination Stds,New Insp Programs & Other Training Issues.List of Attendees Encl ML20211J2211999-08-31031 August 1999 Approves Request to Remove Augmented ISI (Aii) Program for RCS Bypass Lines from North Anna Licensing Basis.Se Re Request to Apply LBB to Eliminate Augmented Insp Program on RCS Bypass Lines Encl ML18152B3701999-08-30030 August 1999 Informs That Virginia Electric & Power Co Hereby Granted Approval to Submit Original & One Paper Copy & 6 CD-ROM Copies of Updates to FSAR as Listed,In Response to ,Requesting Exception to 10CFR50.4(b)(6) ML20211H4131999-08-27027 August 1999 Informs That Util Revised Encl Bases for TS 2.2.1, Reactor Trip Sys Instrumentation Setpoints, Discussing Steam Flow/ Feed Flow Mismatch Portion of Steam Flow/Feed Flow Mismatch & Low SG Water Level Reactor Trip Setpoint ML18152B3811999-08-23023 August 1999 Forwards Safety Evaluation,Granting Relief Request IWL-3 Re ISI Programs,Per Util ML20138B3241999-08-23023 August 1999 Forwards Draft Response to Question 1 Re NAPS USI A-46 ML20211D9041999-08-20020 August 1999 Forwards Revised Pages to Third Ten Year ISI Program & Relief Requests, Replacing Pages in 990408 Submittal ML20211B3871999-08-17017 August 1999 Requests Permission to Routinely Discharge from SW Reservior to Waste Heat Treatment Facility Under Existing Vpdes Permit Through Outfalls 108 & 103.Discharges Are Scheduled to Commence on 990907,due to High Priority Placed on Project ML20210T0671999-08-13013 August 1999 Informs of Completion of Review of Proposed Revs of Schedule for Withdrawal of Rv Surveillance Capsules Submitted by VEPCO on 981217.Approves Proposed Revs.Forwards Safety Evaluation ML20210Q9841999-08-12012 August 1999 Forwards Rev 1 to Vepc COLR for North Anna Unit 2,Cycle 13 Pattern Ud, Per TS 6.9.1.7.d.COLR Was Revised to Include Temp Coastdown Operation at End of Cycle 13 ML18152B4081999-08-0606 August 1999 Forwards Response to NRC 990520 & 0525 RAIs Re North Anna & Surry Responses to GL 95-07, Pressure Locking & Thermal Binding of SR Power-Operated Gate Valves ML20210Q7661999-08-0606 August 1999 Requests Exception to 10CFR50.4 Requirement to Provide Total of Twelve Paper Copies When Submitting Surry & North Anna UFSAR Updates.Seek Approval to Submit Only Signed Original & One CD-ROM Version,Per Conversation with J Skoczlas ML20210N2921999-08-0505 August 1999 Discusses Which Submitted Proposed TSs Bases Change for Containment Leakage. Licensee Changes to Bases May Be Subj to Future Insps or Audits ML18152B4091999-08-0505 August 1999 Forwards Vepc semi-annual fitness-for-duty Program Performance Data Rept for 990101-990630,IAW 10CFR26.71(d) ML18152B3731999-08-0505 August 1999 Informs That NRC Plans to Administer Gfes of Written Operator Licensing Exam on 991006 at North Anna & Surry. Requests Info Re Individuals Taking Exam,Personnel Who Will Have Access to Exam.Sample Registration Ltr Encl ML20210J8861999-08-0202 August 1999 Provides Clarification to Commitment Made in Identifying Extent by Which Existing Plant Design Complied with RG 1.97,specifically Re Variable, Radiation Exposure Rate ML20210F6121999-07-28028 July 1999 Forwards Supplemental Info on Proposed Irradiation of Fuel Rods Beyond Current Lead Rod Burnup Limit,Documenting Info Provided During 990624 Meeting & Suppl Original Submittal ML18152B3971999-07-26026 July 1999 Provides Estimates of Licensing Actions Expected to Be Submitted in Fys 2000 & 2001,in Response to NRC AL 99-02 ML20209E7621999-07-0909 July 1999 Provides Addl Info to Justify Use of Less than One Gpm Detectable Leakage Rate to Establish Required Margin for Crack Stability in LBB Analysis,Per 980623 Application on Reactor Coolant Loop Bypass Lines ML20209E3711999-07-0202 July 1999 Forwards Insp Repts 50-338/99-03 & 50-339/99-03 on 990425-0605.Violations Being Treated as Noncited Violations ML18152B4401999-07-0101 July 1999 Informs NRC That on 990511,Dominion Resources,Inc,Executed Amended & Restated Agreement & Plan of Merger with Consolidated Natural Gas Co ML18152B3951999-06-30030 June 1999 Informs That Effective 990706,GE Edison Has Been Assigned as Project Manager,Project Directorate II-1,for North Anna Power Station.Edison Will Continue in Assignment as Project Manager for Surry Power Station ML18152B4371999-06-24024 June 1999 Forwards Response to NRC Request for Clarification of Relief Requests Submitted on 990212,requesting Relief from Performing Hydrostatic Testing for Certain Small Diameter Class 1,RCS Pressure Boundary Connections ML20196G2581999-06-23023 June 1999 Discusses Closure of GL 92-01,rev 1,suppl 1,reactor Vessel Structural Integrity ML20196F1151999-06-22022 June 1999 Forwards Relief Requests NDE-047 & NDE-048 for North Anna Power Station,Unit 1 Re ASME Section XI ISI Program ML20212J2951999-06-22022 June 1999 Forwards Corrected Markup & Typed Version of Affected Pages. Requests That Attached Pages for Those Previously Provided in 990506 Submittal Be Replaced & Incorporated Into NRC Review of Proposed TS ML18152B4361999-06-22022 June 1999 Forwards Response to RAI Re Surry & North Anna Power Stations,Units 1 & 2,per GL 96-06 ML20196G2211999-06-21021 June 1999 Forwards Licensee Sampling & Testing Obligations Re Vpdes Permit VA0052451 Reissuance Application.Details of Requests for Sampling & Testing Waivers,Included ML20195J7011999-06-15015 June 1999 Forwards Revised EPIP 2.01 Which Corrects Typo That Was Found in Step 10 of Procedure.Rev Does Not Implement Actions That Decrease Effectiveness of EP ML20195J1391999-06-11011 June 1999 Submits Addl Info as Addendum to Original Application Which Proposed Use of Three Chemicals in Bearing Cooling Tower at North Anna Power Station,Per Reissuance of Vpdes Permit ML18152B4301999-06-0303 June 1999 Informs of Util Intention to Revise Schedule for Submittal of License Renewal Applications for Surry & North Anna Power Stations to March 2002 ML20195C6601999-06-0101 June 1999 Forwards Response to NRC 990216 RAI Re Summary Rept of USI A-46 Program ML18152B4261999-05-28028 May 1999 Provides Formal Notification of Effect of Recent Organizational Restructuring on OLs of North Anna & Surry Power Stations,Per NRC 990513 Telcon Request ML20207C9851999-05-28028 May 1999 Requests Regrading of RT Robinson 990408 Written Exam,Based on Listed Reasons.Answer C for Question 18 Is Requested to Be Reconsidered as Correct or Question Be Deleted ML18152B4221999-05-27027 May 1999 Forwards Info Concerning Changes to ECCS Evaluation Models & Application in Existing Licensing Analyses for Surry & North Anna Power Stations,Units 1 & 2 ML18152B4231999-05-26026 May 1999 Informs That Vepc Will Revise 180 Day Response to NRC GL 96-05,within 120 Days of Date of Ltr to Incorporate Commitment to Participate in Joint Owners Group Program as Applicable 1999-09-08
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML20217K4391999-10-18018 October 1999 Provides Response to RAI to Support USI A-46 Program Submittal for North Anna Power Station,Units 1 & 2.Rev 10 to BNL Rept 52361,encl ML20217H3301999-10-14014 October 1999 Forwards Rev 0 to COLR for North Anna 2 Cycle 14 Pattern Su. No New Commitments Intended by Ltr ML18152B3541999-10-12012 October 1999 Requests Use of Code Case N-532 & N-619,per Provisions of 10CFR50.55a(a)(3).Detailed Info Supporting Request,Encl. Attachment 2 Includes Technical White Paper That Provides Further Technical Info ML20216K1681999-10-0101 October 1999 Forwards Vols I-VIII of Rev 35 to UFSAR for Naps.Rev Also Includes Update to Chapter 17 of Ufsar,Which Contains Operational QA Program.Changes to Program Description Do Not Reduce Commitments Contained Therein ML18152B3391999-09-27027 September 1999 Forwards Revised Relief Request IWE-3,which Now Includes Addl Visual Exam Requirement After post-repair or Mod Pressure Testing Is Completed,Per Telcon with NRC ML20212G5091999-09-22022 September 1999 Forwards in Triplicate,Applications for Renewal of Licenses for Listed Individuals.Encls Withheld,Per 10CFR2.790(a)(6) ML18152B3331999-09-17017 September 1999 Forwards Revised 180-day Response to NRC GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves ML18152B6671999-09-17017 September 1999 Forwards Two NRC Forms 536,containing Info on Proposed Site Specific Operator Licensing Exam Schedules & Estimated Number of Applicants Planning to Take Exams And/Or Gfes,In Response to NRC Administrative Ltr 99-03 ML18152B3341999-09-16016 September 1999 Requests Relief from Specific Requirements of Subsection IWE of 1992 Edition with 1992 Addenda of ASME Section XI Re Containment Liner Examination Requirements,For North Anna & Surry Power Stations ML20216E6661999-09-10010 September 1999 Forwards Analysis of Capsule W Virginia Power North Anna Unit 1 Nuclear Power Plant Reactor Vessel Matl Surveillance Program, for Capsule Withdrawn on 980922 ML18152B4471999-09-0101 September 1999 Requests That NRC Remove Listed Labels from Distribution ML20211L9151999-09-0101 September 1999 Forwards Response to NRC Request for Comments Re Closure of Review of Response to GL 92-01,Rev 1,Suppl 1, Reactor Vessel Structural Integrity ML20211H4131999-08-27027 August 1999 Informs That Util Revised Encl Bases for TS 2.2.1, Reactor Trip Sys Instrumentation Setpoints, Discussing Steam Flow/ Feed Flow Mismatch Portion of Steam Flow/Feed Flow Mismatch & Low SG Water Level Reactor Trip Setpoint ML20138B3241999-08-23023 August 1999 Forwards Draft Response to Question 1 Re NAPS USI A-46 ML20211D9041999-08-20020 August 1999 Forwards Revised Pages to Third Ten Year ISI Program & Relief Requests, Replacing Pages in 990408 Submittal ML20210Q9841999-08-12012 August 1999 Forwards Rev 1 to Vepc COLR for North Anna Unit 2,Cycle 13 Pattern Ud, Per TS 6.9.1.7.d.COLR Was Revised to Include Temp Coastdown Operation at End of Cycle 13 ML20210Q7661999-08-0606 August 1999 Requests Exception to 10CFR50.4 Requirement to Provide Total of Twelve Paper Copies When Submitting Surry & North Anna UFSAR Updates.Seek Approval to Submit Only Signed Original & One CD-ROM Version,Per Conversation with J Skoczlas ML18152B4081999-08-0606 August 1999 Forwards Response to NRC 990520 & 0525 RAIs Re North Anna & Surry Responses to GL 95-07, Pressure Locking & Thermal Binding of SR Power-Operated Gate Valves ML18152B4091999-08-0505 August 1999 Forwards Vepc semi-annual fitness-for-duty Program Performance Data Rept for 990101-990630,IAW 10CFR26.71(d) ML20210J8861999-08-0202 August 1999 Provides Clarification to Commitment Made in Identifying Extent by Which Existing Plant Design Complied with RG 1.97,specifically Re Variable, Radiation Exposure Rate ML20210F6121999-07-28028 July 1999 Forwards Supplemental Info on Proposed Irradiation of Fuel Rods Beyond Current Lead Rod Burnup Limit,Documenting Info Provided During 990624 Meeting & Suppl Original Submittal ML18152B3971999-07-26026 July 1999 Provides Estimates of Licensing Actions Expected to Be Submitted in Fys 2000 & 2001,in Response to NRC AL 99-02 ML20209E7621999-07-0909 July 1999 Provides Addl Info to Justify Use of Less than One Gpm Detectable Leakage Rate to Establish Required Margin for Crack Stability in LBB Analysis,Per 980623 Application on Reactor Coolant Loop Bypass Lines ML18152B4401999-07-0101 July 1999 Informs NRC That on 990511,Dominion Resources,Inc,Executed Amended & Restated Agreement & Plan of Merger with Consolidated Natural Gas Co ML18152B4371999-06-24024 June 1999 Forwards Response to NRC Request for Clarification of Relief Requests Submitted on 990212,requesting Relief from Performing Hydrostatic Testing for Certain Small Diameter Class 1,RCS Pressure Boundary Connections ML20196F1151999-06-22022 June 1999 Forwards Relief Requests NDE-047 & NDE-048 for North Anna Power Station,Unit 1 Re ASME Section XI ISI Program ML18152B4361999-06-22022 June 1999 Forwards Response to RAI Re Surry & North Anna Power Stations,Units 1 & 2,per GL 96-06 ML20212J2951999-06-22022 June 1999 Forwards Corrected Markup & Typed Version of Affected Pages. Requests That Attached Pages for Those Previously Provided in 990506 Submittal Be Replaced & Incorporated Into NRC Review of Proposed TS ML20195J7011999-06-15015 June 1999 Forwards Revised EPIP 2.01 Which Corrects Typo That Was Found in Step 10 of Procedure.Rev Does Not Implement Actions That Decrease Effectiveness of EP ML18152B4301999-06-0303 June 1999 Informs of Util Intention to Revise Schedule for Submittal of License Renewal Applications for Surry & North Anna Power Stations to March 2002 ML20195C6601999-06-0101 June 1999 Forwards Response to NRC 990216 RAI Re Summary Rept of USI A-46 Program ML20207C9851999-05-28028 May 1999 Requests Regrading of RT Robinson 990408 Written Exam,Based on Listed Reasons.Answer C for Question 18 Is Requested to Be Reconsidered as Correct or Question Be Deleted ML18152B4261999-05-28028 May 1999 Provides Formal Notification of Effect of Recent Organizational Restructuring on OLs of North Anna & Surry Power Stations,Per NRC 990513 Telcon Request ML18152B4221999-05-27027 May 1999 Forwards Info Concerning Changes to ECCS Evaluation Models & Application in Existing Licensing Analyses for Surry & North Anna Power Stations,Units 1 & 2 ML18152B4231999-05-26026 May 1999 Informs That Vepc Will Revise 180 Day Response to NRC GL 96-05,within 120 Days of Date of Ltr to Incorporate Commitment to Participate in Joint Owners Group Program as Applicable ML20195B5381999-05-14014 May 1999 Forwards Rev 8,Change 2 to North Anna Units 1 & 2 IST Programs for Pumps & Valves. Summaries of Program Changes Provided for Each Unit IST Program.Relief Requests Have Been Removed from IST Programs ML18152A3701999-05-13013 May 1999 Submits Proposal to Use Provisions of ASME Section XI Code Case N-597 for Analytical Evaluation of Class 1,2 & 3 Carbon & Low Alloy Steel Piping Components Subjected to Wall Thinning as Result of Flow Accelerated or Other Corrosion ML20206H0221999-05-0303 May 1999 Informs That Licensee Changes Bases for TS 3/4.6.1.2, Containment Leakage. Changes Allow Use of Other NRC Staff Approved/Endorsed Integrated Leak Test Methodologies to Perform Containment Leakage Rate Testing.Ts Bases Page,Encl ML20206G9481999-05-0303 May 1999 Informs NRC That Insp of 58 Accessible safety-related Pipe Supports Completed in Response to NOV from Insp Rept 50-338/98-05 & 50-339/98-05.Commitments Made Include Plans to Perform Assessment of Welding & Welding Insp ML20205T1181999-04-16016 April 1999 Requests NRC Approval Prior to Proposed Irradiation of Fuel Rods Beyond Current Lead Rod Burnup Limit.Nrc Concurrence with Irradiation Program Requested by End of June 1999 ML20205P1891999-04-0808 April 1999 Forwards ISI Program for Third ten-yr ISI Interval for North Anna Unit 1 for Class 1,2 & 3 Components & Component Support.Third ten-yr Insp Interval for North Anna Unit 1 Begins on 990501.Page 2-26 of Encl Not Included ML20205K3631999-04-0505 April 1999 Requests That Relief Request IWE-3 Be Removed from 980804 Relief Requests Submitted to Nrc.Subject Relief Request Was Inadvertently Retained in Attachment 1 for Unit 1 ML20205K2191999-04-0101 April 1999 Forwards Response to NRC 990106 RAI Re Util Summary Rept on USI A-46 Program,Submitted 970527.Calculations & Corrected Table 11.1-1,encl ML18151A5851999-03-31031 March 1999 Forwards Rept on Status of Decommissioning Funding for Each of Four Nuclear Power Reactors,Per 10CFR50.75(f)(1) ML18152A2801999-03-30030 March 1999 Forwards Summary of Structural Integrity Evaluation of Thermally Induced Over Pressurization of Containment Penetration Piping During DBA for SPS & Naps,Units 1 & 2,per GL 96-06.Draft Proposed UFSAR Revised Pages,Encl ML20204H0331999-03-17017 March 1999 Forwards Rev 5 to PSP for Surry & North Anna Power Stations & Associated Isfsis.Description & Justification for Changes Included with Plan Rev.Rev 5 to PSP Withheld Per 10CFR73.21 ML20205E2701999-02-25025 February 1999 Forwards Rept on Status of Decommissioning Funding for North Anna Power Station,Units 1 & 2.Trust Agreement Between Old Dominion & Bankers Trust Co,Effective 990301,attached ML20207A8741999-02-25025 February 1999 Draft Response to NRC Telcon Re Licensee Request for Approval of LBB Evaluation in Support of Elimination of Augmented Insp Program on RCS Loop Bypass Lines.Response Justifies Use of Less than One Gpm Detectable Leakage Rate ML18152B5401999-02-11011 February 1999 Requests Relief from Specific Requirements of Subsection Iwl of 1992 Edition with 1992 Addenda of ASME Section Xi,Per 10CFR50.55a(a)(3) ML20203C8181999-02-0505 February 1999 Forwards Response to NRC 981217 Telcon RAI Re risk-basis of Nitrogen Accumulator Action Statement to Complete NRC Review of 951025 Proposed TS Changes 1999-09-27
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VIHOINIA 15LECTHIC AND POWEH COMPANY HICilMOND, VIRGINIA 202 GI February 5, 1997 U. S. Nuclear Regulatory Commission Serial No.97-029 Attention: Document Control Desk NAPS /JHL R4 Washington, D. C. 20555 Docket Nos. 50-338 50-339 License Nos. NPF-4 NPF-7 i
Gentlemen: l VIRGINIA ELECTRIC AND POWER COMPANY i NORTH ANNA POWER STATION UNITS 1 AND 2 l lNSPECTION REPORT NOS. 50-338/96-12 AND 50-339/96-12 REPLY TO THE NOTICES OF VIOLATION 1
We have reviewed your letter of January 6,1997, which referred to the inspection i conducted at North Anna Power Station from November 3,1906 through December 7, !
1996, and the associated Notices of Violation which were reported in Inspection Report Nos. 50-338/96-12 and 50-339/96-12. Our reply to the Notices of Violation is attached.
Section E1.1b of the inspection Report indicates that the manufacturer's Quality Control inspector identified a discrepancy in the bolts at various column flanges and the bowls ,
for the replacement service water pumps. However, it should be noted that the discrepancy was with the bolt material used in the vendor's seismic analysis report.
The service water pump bowl assemblies were constructed with A307 material as required by the Bill of Materials specified by the vendor, but the vendor's seismic analysis report erroneously used an A325 bolt material in its calculation. The discrepancy between the seismic analysis report and the bolt material actually installed in the pump was identified by a Virginia Electric and Power Company vendor surveillance representative. As a result of this clarification to the Inspection Report, it is requested that Notice of Violation B be reconsidered for categorization as a Non-Cited Violation. We believe categorization as a Non-Cited Violation is justified in this case because Virginia Electric and Power Company discovered the discrepancy, a
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subsequent evaluation for structural adequacy confirmed structural integrity and _
function, and corrective action has Loen implemented to prevent recurrence.
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9702100393 970205 DR ADOCK0500g8
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No new commitments are intended as a result of this letter. If you have any further
, questions, please contact us.
i
- Very truly yours, -
i ,
l James P. O'Hanlon !
Senior Vice President - Nuclear Attachment cc: U. S. Nuclear Regulatory Commission Region ll 101 Marietta Street, N.W.
Suite 2900 Atlanta, Georgia 30323 Mr. R. D. McWhorter NRC Senior Resident Inspector North Anna Power Station
REPLY TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-338/96-12 AND 50-339/96-12 NRC COMMENT During an NRC inspection conducted on November 3,1996 through December 7,1996, violations of NRC requirements were identified. In accordance with the " General ;
Statement of Policy and Procedure for NRC Enforcement Actions," NUREG 1600, the l
violations are listed below:
A. 10 CFR 50, Appendix B, Criterion ill, and the licensee's accepted Quality l Assurance Program (Updated Final Safety Analysis Report, Section 17.2.3) require the licensee to establish measures to ensure that applicable regulatory requirements for the design basis described in licensee documents be implemented.
Contrary to the above, although measures were established, they were inadequate. Since early in plant life until May 1996, the licensee failed to ensure that safeguards area walls met the design basis for containing pump sealleakage as described in Updated Final Safety Analysis Report, Section 15.4.1.8. Specifically, a hole existed between the Unit 2 safeguards area and the Unit 2 quench spray area where the design required that the safeguards area be fully separated. Additionally, holes designed to exist between pump cubicles and the safeguards area sump were plugged, where the design required the proper drainage of pump seal leakage.
This is a Severity Level IV violation (Supplement I).
B. 10 CFR 50, Appendix B, Criterion Ill, and the licensee's accepted Quality !
Assurance Program (Updated Final Safety Analynic Report, Section !
17.2.3) require that measures shall be established to ensure the design basis are correctly translated into drawings. They also require that measures shall also be established for the review for suitability of application of matarials essential to the safety-related functions.
Contrary to the above, although measures were established, they were ,
inadequate. As of November 21, 1996, the design bases were not correctly transleted into drawings and reviews for suitability of application of materials were inadequate, in that, the bill-of-material for the replacement Service Water pumps specified one-inch diameter, A307, low strength, non-dynamic loading, bolts for the column flanges and bowls flange connections instead of one-inch diameter, A325, high strength 1 1 of 8
i 1
- 1 bolts. This resulted in a Unit 2 pump being installed with bolts that did not :
conform to the applicable code requirements. '
This is a Severity Level IV violation (Supplement 1). !
C. 10 CFR 50, Appendix B, Criterion V, and the licensee's accepted Quality Assurance Program (Updated Final Safety Analysis Report, Section 17.2.5) require that activities affecting quality shall be accomplished in accordance with documented drawings. l 1
Drawing No. N-96014-3-S-001, Sheet 1, required that the tolerance on the dimensions of anchor bolts for the Component Cooling Water surge tank supports be minus zero inches, plus two inches.
Contrary to the above, as of November 21, 1996, an activity affecting quality was not accomplished in accordance with documented drawings.
Actual dimensions of the anchor bolts for the Component Cooling Water surge tank exceeded the specified minus tolerance by one and one-half inches and the plus tolerance by one and one-quarter inches.
This is a Severity Level IV violation (Supplement 1).
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fLEPLY TO NOTICE OF VIOLATION A ;
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- 1. REASON FOR THE VIOLATION The reason for the violation appears to be a design error from initial plant construction. During original plant design and construction, a penetration between the Unit 2 Quench Spray (OS) and Safeguards sump areas appears to j have been purposely left open to allow liquid to migrate from the QS basement to the Safeguards sump. However, the open penetration resulted in a potential l unfiltered release path to the environment following a design basis accident if '
leakage into the Safeguards sump was allowed to backflow into the Quench )
Spray Pump House. In addition, personnel error resulted in the holes in the cubicle floor for the Unit 2 "B" Low Head Safety injection (LHSI) pump and the "B" Outside Recirculation Spray (ORS) pump being grouted closed sometime in the past. This would have initially prevented pump seal leakage from draining to the Safeguards area sump. There was no safety impact associated with this j condition because leakage would accumulate in the pump cubicle and then drain ;
through the discharge piping penetration in the pump cubicles to the Safeguards '
area sump. In addition, the Safeguards Area Ventilation System will continue to process the ventilation discharge through the charcoal filters.
- 2. CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED l Both trains of safeguards ventilation were declared inoperable and Technical Specification 3.0.3 was entered following the discovery of the open penetration between the Unit 2 Quench Spray and Safeguards sump areas. i Licensee Event Report 50-339, 96-001-00 was issued on June 5,1996 to ,
document the discrepancy with the open penetration between the Unit 2 Quench Spray and Safeguards areas.
4 The open penetration was sealed by implementation of a temporary modification and both trains of safeguards ventilation were declared operable. The temporary modification was monitored on a periodic basis until permanent repairs were implemented.
Design Change 96-179 was implemented to provide permanent isolation of the penetration between the Unit 2 Quench Spray and Safeguards sump areas.
The floor drain holes for the "B" LHSI pump and the "B" ORS pump cubicles to the safeguards area sump were opened.
A review of the Unit 1 Quench Spray and Safeguards areas was performed and no similar discrepancies were identified.
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i Design controls, which have been strengthened since original plant construction, should prevent recurrence.
- 3. CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER i VIOLATIONS No further corrective actions are required.
- 4. THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance has been achieved.
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REPLY TO NOTICE OF VIOLATION B l
- 1. REASON FOR THE VIOLATION j The primary reason for the violation was the failure on the part of the pump l vendor to thoroughly implement their quality assurance program.
It should be noted that the Inspection Report indicates that the manufacturer's Quality Control inspector identified a discrepancy in the bolts at various column flanges and the bowls for the replacement service water pumps. However, as discussed below, identification of this deviation was discovered when a discrepancy between the vendor's seismic analysis report and the bolt material actually installed in the pump bowl assemblies was identified by a Virginia Electric and Power Company vendor surveillance representative. l Virginia Electric and Power Company selected a safety related component supplier to manufacture four replacement SW pumps or bowl assemblies in accordance with the Quality Assurance Program requirements of 10 CFR 50, Appendix B, Criterion IV. The vendor by accepting the purchase order agreed to l ensure that the designed components are correctly translated into drawings and i to the physical components. The Specification (NAP-0042) supplied to the vendor for manufacturing the pump bowl assemblies provided general design requirements but did not specify materials other than a stainless ste.elimpeller. It is Virginia Electric and Power Company's expectation that the safety related l pump vendor design the pump bowl assemblies in accordance with the general specification and in compliance with Appendix B of 10 CFR 50. The Bili of Materials is then created by the vendor to specify the materials necessary to manufacture the new replacement SW pump bowl assemblies.
Although Virginia Electric and Power Company entrusts the safety related vendor with the responsibility for designing the pump bowl assemblies, vendor surveillance activities are performed to ensure construction to specifications. In fact, a discrepancy between the vendor's seismic analysis report and the bolt material actually installed in the SW pump bows assemblies was discovered by a Virginia Electric and Power Company vendor surveillance representative. A l Virginia Electric and Power Company vendor surveillance representative was visiting the pump vendor facilities to witness in-process inspections and to perform documentation reviews. During the visual inspection and dimensional check of additional pump bowl assemblies being manufactured, the bolting material discrepancy was identified. The Virginia Electric and Power Company vendor surveillance representative then contacted Engineering coriceming the bolting material issue.
A review of the vendor's seismic analysis report identified that the properties of A325 bolting material was used for the analysis. However, this was not S of 8
consistent with the bolting material the vendor had actually installed in the pump bowl assemblies. The pump bowl assemblies were actually constructed with A307 botting material as specified by the vendor in the Bill of Materials. When this discrepancy was discovered, appropriate corrective actions were initiated immediately.
- 2. CORRECTIVE STEPS WHICh HAVE BEEN TAKEN AND THE RESULTS ACHIEVED An engineering evaluation was performed to document the structural adequacy of the flange bolts for the service water pump column. The evaluation concluded: 1) the stresses in the A307 flange bolts of the pump column will remain within basic allowable stresses in normal operating conditions, 2) the stresses in the A307 flange bolts of the pump column will exceed allowable stresses during an operational basis earthquake (OBE) and design basis earthquake (DBE), but no gross deformation would occur at the flange joints and the joints will maintain structural integrity, and 3) minor leakage may occur at flange connections during a seismic event but a significant loss of inventory is not expected. Since an earthquake greater than or equal to an OBE may cause minor leakage at flange connections, Abnormal Procedure 0-AP-36, Seismic Event, was revised to include a step to have the SW pumps checked for abnormal conditions and vibrations. In addition, the procedure step initiates an engineering evaluation of the pumps following a seismic event to check for any flange connection leakage that might affect the pump casing in the long term.
When the bolt material is changed for each of the SW pump bowl assemblies,0-AP-36 will be revised to remove the requirements that were implemented as a result of the engineering evaluation.
As a precaution, Specification NAP-0042 was revised to specify the use of ASTM A193 Gr. B7 bolt material with ASTM A194 Gr. 7 nut material rather than leaving the material selection to the pump vendor.
A Purchase Order BNT-527771 change order was issued to the pump vendor for the bnits and nuts replacement on the SW pump bowl assemblies currently being manufactured The bolts and nuts for the bowl and column flange connections on 1-SW-P-1 A (which has been delivered to the site but not installed) have been replaced with ASTM A193 Gr. 87 bolt material with ASTM A194 Gr. 7 nut material.
Design Change 95-015 was revised to incorporate the changes made to Specification NAP-0042, the Bill of Materials, and require stronger bolt and nut material for the SW pump bowl assemblies.
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l The pump vendor has been advised about the bolting material issue and the l vendor is incorporating the new bolting material in the current version of the I stress analysis report. The revised stress report will be submitted to Virginia l Electric and Power Company for review.
The bolts and nuts on 2-SW-P-1 A (installed in 1995) will be replaced with the )
revised materials. In addition, the bolts and nuts for the other SW pump bowl assemblies, which are being manufactured by the pump vendor, will be ;
constructed with the revised materials. These activities are being controlled by i the implementation of Design Change 95-015. l A review was performed to determine whether the discrepancy required reporting under the criteria of 10 CFR 21. This review concluded that because the SW system could perform its overall function and each station's SW pumps are essentially custom made, the discrepancy made by the pump vendor should not be considered a generic issue. Therefore, a substantial safety hazard was not l created and the discrepancy was determined to be riot reportable.
Personnelin the design engineering organization have been alerted to this issue and advised to provide more attention to detail when reviewing critical technical information provided by equipment vendors.
- 3. CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS No further corrective actions are required. !
- 4. THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance has been achieved. l 1
l l
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l BEPLY TO NOTICE OF VIOLATION C
- 1. REASON FOR THE VIOLATION The reason for the violation was personnel error. Personnel did not provide ,
sufficient attention to detail in determining the location for installing a brace on the baseplate in relation to the anchor bolts for the component cooling water ;
system surge tank. Specifically, personnel failed to accurately incorporate !
numerous drawing dimensional tolerances that were specified on construction drawings.
- 2. CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED Engineering personnel reviewed calculation CE-1092 to qualitatively determine the effect of the out of tolerance condition. It was determined that sufficient design margin exists to accommodate the minor dimensional discrepancies. !
Operability of the component cooling water system was maintained.
The results of the discrepancy were discussed with appropriate craft personnel.
More detailed pre-job briefs are being conducted on projects involving complex welded supports.
Quality inspectors were coached on performing thorough field inspections and having a questioning attitude.
- 3. CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS No fortner corrective actions are required.
- 4. THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance has been achieved.
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