ML18152B154
| ML18152B154 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 05/23/1988 |
| From: | Cruden D VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| 88-237, NUDOCS 8805270261 | |
| Download: ML18152B154 (8) | |
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VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 May 23, 1988 D.S.CRUDEN VICE PRESIDENT-NUCLEAR U. S. Nuclear Regulatory Commission Attn:
Document Control Desk Washington, D.C.
20555 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 Serial No.
NO/GDM:pms Docket Nos.
License Nos.
NRC INSPECTION REPORT NOS. 50-280/86-12 AND 50-281/86-12 88-237 50-280
. 50-281 DPR-32 DPR-37 We have reviewed your letter of April 22, 1988 in reference to the inspection conducted at Surry Power Station on June 16-20, 1986 and reported in Inspection Report Nos. 50-280/86-12 and 50-281/86-12.
Our response to the violations described in the Notice of Violation is provided in the attachment.
We have no objection to this inspection report being made a matter of public disclosure.
If you have any further questions, please contact us.
Attachment cc:
U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, N.W.
Suite 2900 Atlanta, GA 30323 Mr. W. E. Holland NRC Senior Resident Inspector Surry Power Station 8805270261 880523
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RESPONSE TO THE NOTICE OF VIOLATION ITEMS REPORTED DURING NRC INSPECTION CONDUCTED ON JUNE 16-20, 1986 INSPECTION REPORT NOS. 50-280/86-12 AND 50~281/86-12 During the Nuclear Regulatory Commission (NRC) inspection conducted on June 16-20, 1986, violations of NRC requirements were identified.
In accordance with the "General Statement of Pol icy and Procedure.for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1987), the particular violations are set forth below:
A.
10 CFR 50.49(f) requires each item of electrical equipment important to safety to be environmentally qualified by testing and/or analysis.
10 CFR 50.49(k) establishes (in accordance with CLI-80-21 and operating license dated prior to May 23, 1980) the DOR Guidelines as the basic requirement for Surry Nuclear Plant.
DOR Guidelines, Section 5.2 and 5.2.1 require testing that would envelope the accident environment, including temperature and pressure steam conditions.
Contrary to the above, at the time of the inspection, pressure trans-mitters important to safety (Tag Nos. PT-1474, 1475, 1476, 1484, 1485, 1486, 1494, 14~'5, and 1496 for Unit 1; and PT-2474, 2475, 2476, 2484, 2485, 2486, 249S, and 2496 for Unit 2) were not environmentally qualified in that the qualification testing did not envelope the accident environ-ment for a Main Steam Line Break (i.e., testing at the elevated tempera-tures that woulrl be experienced).
This is a Sever.ty Level IV violation (Supplement I).
B.
10 CFR 50.49(f) requires each item of electrical equipment important to safety to be en'*ironmentally qualified by testing and/or analysis.
10 CFR 50.49(j) requires a record of qualification be maintained in an auditable form.
Contrary to the above, at the time of the inspection, Rockbestos cables of formulation KXL-760 and KXL-50 used in instrument circuity were not en-vironmentally qualified *in that there were no test reports or analysis in the EQ files to show that the cables were qualified.
This is a Severity Level IV violation (Supplement I).
C.
10 CFR 50, Appendix B, Criterion V requires that procedures shall include appropriate quantitative or qualitative acceptance criteria for deter-mining that important activities have been satisfactorily accomplished.
Contrary to the above, at the time of the inspection, the *licensee did not h~ve an adequate program to ensure maintenance was performed at time in-tervals specified in their EQ test reports in order to maintain the equfp-ment *environmentally qualified.
An example of this was the High Head Safety Injection Pump Motors (Tag Nos. 1-and 2-CA-P-lA, B,
- C) lube** oil replacement was scheduled semiannually; however, the test report required replacement after 2040 hours0.0236 days <br />0.567 hours <br />0.00337 weeks <br />7.7622e-4 months <br />.
There w~s no 1 og or record of run ti me available to track the hours to ensure the _specified tim~ was. not exceeded, thereby causing the pumps to not be environmentally qualified.
This is a Severity Level IV violation (Supplement I).
D.
10 CFR 50.49(f), (k) and DOR Guidelines 5.2.2 require each item of elec-trical equipment important to safety to be qualified by testing and/or analysis and the differences between tested and installed equipment be evaluated and reconciled in the qualification documentation.
Contrary to the above, at the time of the inspection, Raychem splice in-sulation sleeves on safety-related cables in conduits (e.g., for solenoid valve Tag No. TV-CW-1128) were not qualified in that they were not in a configuration that was tested.
The sleeves were excessively bent with bend radii less than the minimum specified by Raychem specifications and the qualification file did not contain the appropriate evaluation to de-monstrate similarity to the tested configuration.
This is a Severity Level IV Violation (Supplement I).
. ITEM A
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RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-280/86-12 AND 50-281/86-12 (1) ADMISSION OR DENIAL OF ALLEGED VIOLATION The violation is correct as stated.
(2) REASONS FOR VIOLATION The initial engineering evaluation of the effects of a high energy line break on the environmental qualification (EQ) of equipment in the Main Steam Valve House did not adequately consider the effects of superheated steam on the main steam pressure transmitters noted in the violation.
(3) CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED The following transmitters were relocated to a different environmental zone which is not subject to the effects of superheated steam:
PT-1474, 1475, 1476, 1484, 1485, 1486, 1494, 1495, and 1496 in Unit 1 and PT-2474, 2475, 2476, 2484, 2485, 2486, 2494, 2495, and 2496 for Unit 2.
A technical report (Technical Report PE-0003) was also prepared to document final resolution of the issues i dent i fi ed in I.E. Notice 84-90, Main Steam Line Break Effect on Environmental Qualification of Equipment.
In addition, Regulatory Guide 1.97 instrumentation within this zone was reviewed for EQ impact.
As a result, valve position indication for those R.G. 1.97 valves located in this zone is being provided by alternate indication for a main steamline break accident in this zone.
Also, the following programmatic changes were made:
the review/evaluation process for industry and NRC EQ information was enhanced and the potential problem review process was strengthened.
(4) CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS None required.
(5) THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance has been achieved.. The.,transmitters listed in item (3) above were relocated prior to the Ul and U2 startups on July 18, 1986 and July 3, 1986 respectively.
RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-280/86-12 AND 50-281/86-12 ITEM B (1) ADMISSION OR DENIAL OF ALLEGED VIOLATION The violation is correct as stated.
(2) REASONS FOR VIOLATION In their May 27, 1986 letter, Rockbestos identified the different cable insulation formulations supplied under various station purchase orders and indicated the applicable test report to demonstrate qualification.
At the time of the NRC audit (June 16-20, 1986), the May 27, 1986 Rockbestos letter was not incorporated into the Rockbestos Cable QDR.
The Rockbestos Cable QDR did address all cable insulation formulations known to be supplied to the Virginia Electric and Power Company prior to the May 27, 1986 Rockbestos letter.
(3) CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED QDR-S-6.1 was revised to include the May 27, 1986 Rockbestos letter and the applicable test report, and to address the additional formulations.
(4) CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS None required.
(5) THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance has been achieved.
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RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-280/86-12 AND 50-280/86-12 ITEM C (1) ADMISSION OR DENIAL OF ALLEGED VIOLATION The violation is correct as stated.
(2) REASON FOR THE VIOLATION The required motor lube oil change out frequency specified in the QDR-S-4.1 for the High Head Safety Injection (HHSI) Pump motors was not updated in the applicable maintenance procedure.
(3) CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED Electrical and mechanical maintenance of environmentally qualified equipment directed by QDRs is scheduled and tracked by the station's preventive maintenance (PM) program.
The admi ni strati ve procedure
- governing the PM program has been revised to ensure the approval by engineering and the Station Nuclear Operating and Safety Committee prior to deferral of any QDR related PM.* In addition, PMs that are QDR related are specifically identified as such on the monthly and yearly PM schedule to clearly identify the need for timely completion.
The instrument department work procedures maintenance and replacement of EQ equipment comprehensive administrative procedure is being scheduling and tracking of EQ instrumentation.
presently address the under its purview.
A developed to enhance the To ensure qualification with the revised maintenance requirements, the motor lube oil on the Unit 1 and Unit 2 HHS! pumps was changed prior to the Unit 1 and Unit 2 startups on July 18, 1986 and July 3, 1986 respectively.
The appropriate maintenance proced~res were changed to accurately reflect the QDR-S-4.1 requirements.
Hour meters have been i nsta 11 ed on the HHS! pump breakers to a 11 ow oil sampling based on an actual
- run time basis rather than the more conservative quarterly basis.
QDR distribution changes were initfated to ensure that the station EQ Coordinator directly receives and distributes QDR revisions.
(4) CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS As a programmatic enhancement, an administrative procedure is being developed to strengthen the scheduling and tracking of QDR-related maintenance of EQ instrumentation.
(5) THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance has been achieved.
The comprehensive procedure for tracking and scheduling QDR-related maintenance of EQ instrumentation will be completed by September, 1988.
i
'1 RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-280/86-12 AND 50-281/86-12 ITEM D (1) ADMISSION OR DENIAL OF ALLEGED VIOLATION The violation is correct as stated.
(2) REASONS FOR VIOLATION
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The procedures utilized for Raychem installations did not address bend radii.
(3) CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED The electrical installation specification for Surry Power Station (NUS-2030) has been revised to address bend radius and give detailed guidance on installing (and specifying) Raychem inline splices.
An inspection of Raychem splices was performed per I.E. Notice 86-53 and any deficient splices identified were repaired/replaced.
The example noted in the violation was replaced during this effort.
In addition, a technical report (Technical Report EQ-0032) was generated to summarize the testing performed by various utilities and to provide justification for Raychem noc installed in accordance with the Raychem Application Guide.
This terhnical report has been added to QDR-S-16.2.
(4) CORRECTIVE STEP~ WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS None required.
(5) THE DATE WHEN FIILL COMPLIANCE WILL BE ACHIEVED Full compliance has been achieved.