ML20207T595

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Responds to NRC Re Violations Noted in Augmented Insp Team Repts 50-280/86-42 & 50-281/86-42.Corrective Actions:Mechanical Maint Procedure MMP-C-MS-002 Revised Re Correct Handling of Main Steam Trip Valves
ML20207T595
Person / Time
Site: Surry  Dominion icon.png
Issue date: 03/11/1987
From: Stewart W
VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
87-079, 87-79, NUDOCS 8703240166
Download: ML20207T595 (3)


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U. S. Nuclear Regulatory Commission Serial No:

87-079 Suite 2900 N0/WDC:pms 101 Marietta St., N.W.

Docket Nos.: 50-280 Atlanta, Georgia 30323 50-281 License Nos: DPR-32 Gentlemen:

DPR-37 VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 NRC AUGMENTED INSPECTION TEAM REPORT N05. 50-280/86-42 AND 50-281/86-42 We have reviewed your letter of February 10,

1987, in reference to the inspection conducted at Surry Power Station on December 9, 1986 through January 14, 1987 and reported in Augmented Inspection Team Report Nos. 50-280/86-42 and 50-281/86-42. Our response to the Notice of Violation is addressed 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.

Very truly yours, 6&

k L. Stewart Attachment cc:

Mr. Lester S. Rubenstein, Director PWR Project Directorate No. 2 Division of PWR Licensing-A Mr. W. E. Holland NRC Senior Resident Inspector Surry Power Station Mr. Chandu P. Patel NRC Surry Project Manager PWR Project Directorate No. 2 Division of PWR Licensing-A B703240166 870311 PDR ADOCK 05000290 Q

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RESPONSE TO NOTICE OF VIOLATION ITEM REPORTED DURING NRC INSPECTION CONDUCTED ON SEPTEMBER 22-26, 1986 INSPECTION REPORT NOS. 50-280/86-42 AND 50-281/86-42 NRC COMMENT:

During the Nuclear Regulatory Commission (NRC) inspection conducted between the period of December 9,

1986, to January 14, 1987, a violation of NRC requirements was identified. The violation, which was identified during the licensee's evaluation of the cause of the failure of the main steam trip valve, involved failure to provide detailed instructions in maintenance procedures for corrective maintenance of safety related equipment.

In accordance with the "Ceneral Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1986), the violation is listed below:

Technical Specification 6.4.A requires that detailed written procedures with appropriate checkoff lists and instructions shall be provided for preventive or corrective maintenance operations which would have an effect on the safety of the reactor.

Corrective Maintenance Procedure MMP-C-MS-002,

" Corrective Maintenance Procedure for Inspection of Main Steam Valve TV-MS " provides instructions for the overhaul / repair of the main steam trip valves.

Contrary to the above, in the instances cited below, the maintenance procedure used to overhaul main steam trip valve 2-MS-TV-201C during the period of October 23-28, 1986, lacked detailed instructions, was not fully followed, and did not provide adequate documentation to show that the work associated with the repair of a safety related component was accomplished in a quality manner.

1.

Step 5.4.8 of MMP-C-MS-002 requires installation of two radius levers to the rock shaft without proper control to assure correct alignment during reassembly. During valve disassembly after the event, the radius levers were determined to be misaligned on the rock shaft.

2.

Step 5.4.12 of HMP-C-MS-002 verifies that the arc opening of the valve after reassembly was 80 degrees. During valve disassembly after the event, the arc opening was checked and was determined to be 75 degrees.

3.

Step 5.4.15 of MMP-C-MS-002 requires that the valve cover be reinstalled, but it does not specify adequate control to assure correct alignment during reassembly. During valve disassembly after the event, the cover was determined to be misaligned preventing full opening of the trip valve during plant operation.

4.

Step 6.3 of HMP-C-MS-002 requires that appropriate post maintenance testing be identified to establish acceptability of the equipment; however, no testing was specified which would have identified the deficient reassembly of the trip valve.

This is a severity Level IV violation (Supplement 1).

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RESPONSE

1.

Admission or denial of the alleged violation:

The violation is correct as stated.

2.

Reason for the violation:

The violation resulted from procedural deficiencies which failed to ensure that adequate detailed instructions existed for proper disassembly, inspection and reassembly of the main steam trip valve.

3.

The corrective steps that have been taken and the results achieved:

Mechanical Maintenance Procedure MMP-C-MS-002 was revised, with the assistance of the manufacturer, to include detailed instructions for correct disassembly, inspection and reassembly of the main steam trip valves (MSTVs). In addition, a post maintenance testing step was added to the procedure to verify that the valve will travel to its full open position.

The six MSTVs (three per unit) were disassembled, inspected, and reassembled using the revised procedure. Periodic Test Procedure PT 14.2, which tests operability of the main steam trip valves, has been revised to ensure that the trip valve disc opens as designed.

4.

The corrective steps that will be taken to avoid further violations:

Safety related procedures are being reviewed on a biannual basis.

The review program involves approximately 2000 procedures and is on schedule for completion by September 1, 1987 as stated in our October 2,

1985 (Serial No.

85-529A) supplemental response to Generic Letter 83-28.

The procedure reviews are designed to incorporate appropriate information from the latest revisions of vendor technical manuals.

In addition, the program is designed to assure that procedures include post maintenance testing requirements that adequately verifies operability of the equipment.

5.

The date when full compliance will be achieved:

Full compliance has been achieved. Long term corrective actions will be completed by September 1, 1987.

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