IR 05000280/1997001

Discusses Insp Repts 50-280/97-01 & 50-281/97-01 on 970113 & 17 & Forwards NOV & Proposed Imposition of Civil Penalty in Amount of $55,000

ML20216B211
Person / Time
Site:	Surry
Issue date:	08/29/1997
From:	Reyes L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Ohanlon J VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
Shared Package
ML20216B215	List: IR 05000280/1997001 ML20216B241 ML20216B258
References
50-280-97-01, 50-280-97-1, 50-281-97-01, 50-281-97-1, EA-97-055, EA-97-55, NUDOCS 9709050254
Download: ML20216B211 (7)

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August 29, 1997 EA 97 055 Virginia Electric and Power Company ATTN: Mr. J. Senior Vice President Huclear Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, Virginia 2306r SUBJECT: NOTICE Or VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY -

$55,000 (NRC Inspection Report 50 280/97 01 and 50 281/97 01)

Dear Mr. O'Hanlon:

This refers to the ins >ection conducted between January 13 and 17,1997, at Virginia Electric and >ower Company's (Virginia Power) Surry facility. The inspection included a review of your implementation of the requirements of 10 CFR 50.65, " Requirements for Monitoring the Effectiveness of Haintenance at Nuclear Power Plants" [the Haintenance Rule). The results of the inspection were formally transmitted to you by letter dated February 20, 1997. An open predecisional enforcement conference was conducted in the Region II office on March 11, 1997, with you and members of your staff to discuss the apparent violations, the root causes, and corrective actions to preclude recurrence.

A summary of the conference was sent to you by letter dated March 17, 1997.

Based on the information developed during the inspection and, after evaluation of the information that you provided during the conference, the NRC has determined that violations of NRC requirements occurred. These violations are cited in the enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Notice) and the circumstances surrounding them are described in detail in the subject inspection report.

The violations set forth in the Notice include a serious failure to implement key aspects of the Maintenance Rule. These violations, collectively, represent a programmatic breakdown in the development and implementation of Virginia Power s program to ensure compliance with the regulatory requirements of the Maintenance Rule. Escalated enforcement is warranted due to the significant regulatory concern with the common underlying root causes of the violations. The root causes included: (1) poor management oversight and control of the Maintenance Rule program development and implementation:

(2) ineffective turnover of plans developed in the Virginia Power corporate offices; and (3) the failure to correct deficiencies, found as a result of f Virginia Power audits and self assessments during program development and I implementation.

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! VEPC0 2 The violations in the Notice are directly related to the failure to meet the requirements of the Maintenance Rule. Violation A involved the failure to include the emergency switch gear heating ventilation and air conditioning system in a program to monitor its performance against established goals, as required by 10 CFR 50.65(a)(1). Violation B included seven examples of I failures to demonstrate that the >erformance or condition of structures, systems, and components (SSC) wit 11n the scope of 10 CFR 50.65 had been effectively controlled through the performance of appropriate preventive maintenance, such that the SSC would remain capable of performing its intended function. fhree )rocedural violations. Violations C.(1),=C.(2) and C.(3),

were identified t1at indicated a significant failure to procedurally establish and implement maintenance rule procedures.

The Commission determined that the Maintenance Rule was necessary to ensure that licensees evaluate the effectiveness of maintenance to minimize the likelihood of failure of safety significant equipment that could initiate or adversely affect a transient or accident. Even though the final rule was issued in July 1991, it did not become effective until July 1996. Within this five year period, the NRC staff and industry were to develop implementation and-inspection guidance.provided The followingthe firstyears three two years were to permit licensees to implement the requirements such that by July 10, 1996, all requirements would be satisfied. Full compliance with the maintenance rule by this date is a-requirement set forth in 10 CFR 50.65(c).

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During the five years of guidance development and implementation, the staff and the industry worked towards a common goal of assuring that licensees had good implementation ouidance and clearly understood the manner in which NRC would ins)ect implementation, once the rule became effective. This was accomplis 1ed through multiple public workshops and a pilot inspection program.

Results from these activities were documented and shared with the industry so that licensees would have sufficient time prior to the July 10, 1996 effective date of the rule to develop and implement their programs and processes, In general, Surry has a good performcnce record in the maintenance area and

.significant upgrades in the material condition of the plant were noted in the last systematic assessment of licensee performance report, issued on November 8, 1996, and during'the ins)ection that was the subject of this enforcement action. The NRC also ac(nowledges that Virginia Power had taken significant steps to replace planc equipment found to be unreliable, such as the emergency service water ) umps. Nevertheless, the NRC concludes that your actions taken to implement t1e Maintenance Rule had a number of significant weaknesses, and measures to meet all Rule requirements had not been fully integrated into the appropriate programs at Surry. Thus, the failure to-im lement the requirements of the Maintenance Rule is considered to be a si nificant regulatory concern. It is important to note that the maintenance ru e sets forth requirements for monitorina the effectiveness of maintenance and not for performing maintenance. Surry did-not have adequate measures in place to monitor the results of maintenance to assure plant SSCs remain capable of performing their intended functions. Appropriate performance

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trending, effective cause determinations and risk insights were not incorporated into maintenance monitoring activities to reasonably assure that plant equipment degradation or problems are identified and corrected before they result in significant failures or place the plant in undesirable and risk significant configurations.

An additional issue of concern to the NRC is the weakness with your process for performing assessments for determining the overall effect on the performance of safety functions when removing equipment from service for maintenance. Your staff indicated that the-intent of these assessments was to ensure ; hat the plant is not placed in risk significant configurations.

However, several instances were identified where you underestimated the risk associated with certain plant configurations established for the performance of maintenance. Several weaknesses were found that contributed to this problem. Your probabalistic risk assessment (PRA) specialists were not actively involved in the decision process for taking equi ment out of service.

The matrix used for risk assessment included only 12 of tie 44 PRA risk-

-significant systems. Plant personnel (e.g., operators and maintenance schedulers) assigned to assess plant risk mistakenly believed that the matrix included all PRA risk significant SSCs. In addition, the functional equipment groups used by schedulers did not reflect PRA risk insights. Also, required management approval for a high risk plant configuration was not obtained as required by the Notice. procedure and was therefore identified as Violation II.C,(3) in Therefore, these violations are classified in the aggregate in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG 1600, as a Severity Level III problem.

In accordance with the Enforcement Policy, a base civil penalty in the amount of $55,000 is considered for a: Severity Level III problem occurring on or-continuing after November 12, 1996 (61 Eg eral Reaister 53554). Because your facility pas been the subject of escalatec enforcement actions within the last two years , the NRC considered whether credit was warranted for Identification and Carrective Act100 in accordance with the civil penalty assessment process in Section VI.B.2 of the Enforcement Policy.

With regard to the factor of Identification,-the NRC has determined that overall, credit for identification is warranted for this Severity Level III problem because your staff did identify, through the performance of many

. audits and self assessments, that your implementation of the Maintenance Rule was not sufficient to comply with the requirements of the Rule.

on August 16, 1996, a severity Level III problem was issued relataj to the operability of containment hydrogen analyzers (EA 96 231). on Noveeber 22, 1995, a severity Level 111 problem was issued related to multiple violations associated with the september 1995 unplanned reduction in reactor vessel water level (EA 95 223).

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l VEPC0 4 As to the factor of Corrective Action, your corrective actions for the Maintenance Rule violations, when finally taken, were judged to be comprehensive. After the Maintenance Rule program problems were identified in January 1997, Virginia Power established a dedicated recovery team to revalidate and revise, as necessary, the Maintenance Rule program for both Surry and the North Anna facility. In addition: (1) other similar licensee programs are being exc.;lned to ensure that weaknesses are not present:

(2) deficiency reports will be written on all conditions adverse to quality, including those identified by individuals in the Virginia Power corporata offices; (3) recent self assessments will be reviewed to ensure deficiencies are captured in the corrective action program; and (4) steps are being taken to ensure thorough understanding of Haintenance Rule requirements by both Virginia Power management and staff.

Notwithstanding your comprehensive corrective actions taken to address the Haintenance Rule violations, your actions were not considered )rompt. Your staff failed to take prompt corrective actions following a num>er of audit and self assessment findings that indicated that violations of the Maintenance Rule existed at your facility. Findings, in the assessment that was issued in April 1996, included weaknesses in: (1) the programmatic controls of Maintenance Rule scoping, (2) recording of SSCs data, (3) performing evaluations for goal setting, (4) w nitoring corrective actions (5) use of industry events, and (6) trending of Maintenance Preventable Functional Failures (MPFF). Had you taken prompt effective corrective actions, you could have been in compliance by the effective date of the rule. Your April 1996 assessment concluded that your Haintenance Pilot Program did not meet all regulatory requirements of the Maintenance Rule, Your followup reviews, issued after the date of Haintenance Rule implementation, performed on July 10, 1996, August 21, 1996, and October 16, 1996, noted that many of the discrepancies identified in previous assessments remained uncorrected. Your Maintenance Rule Team Report, issued January 14, 1997, further confirmed the failure to implement the Maintenance Rule adequately. That latter assessment was comprehensive and critical because it found significant deficiencies continued from earlier assessments and identified that corrective actions for previous self assessments had not been promptly implemented. As discussed at the predecisional enforcement conference, your review of this matter revealed that you failed to enter significant conditions adverse to quality, identified during self assessments of the Maintenanco Rule program, into your corrective action program. This process deficiency contributed to your management's inadequate resolution of these conditions and resulted in the failure to meet the requirements of the Haintenance Rule. In view of the delay in taking effective corrective actions once your staff identified the failure to meet the Maintenance Rule, credit is not warranted for corrective action.

Therefore, to emphasize the importance of full compliance with 10 CFR 50.65, the Maintenance Rule, the need for vigorous management oversight to ensure.

that prompt corrective actions are initiated to address significant conditions

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-4 VEPC0 5 adverse to quality, and in co%ideration of enforcement actions, I have been authorized,your previous escalated after consultation with the Commission, to issue the enclosed Notice in the base amount of $55,000 for the Severity Level III problem.

You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. The NRC will use your response, in part, to determine whether further enforcement action is necessary to ensure compliance with regulatory requirements. In particular, since your program to implement the Maintenance Rule was a corporate one, similar deficiencies likely exist at the North Anna facility. Although not specifically the subject of this enforcement action, the NRC expects that future inspection activities at North Anna will provide the NRC an opportunity to examine the complete scope and effectiveness of your corrective actions in correcting any deficiencies that may exist.

In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a co)y of this letter, its enclosure, and your response will be placed in the NR: Public Document Room.

Should you have any questions concerning this letter, please contact us.

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Sincerely, Original Signed by L. A. Reyes Luis A. Reyes Regional Administrator Docket Nos. 50 280. 50 281 License Nos. .DPR 32 DPR 37 Enclosure: Notice of Violation and Proposed Imposition of Civil Penalty

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I J.M. McCaroley, Manager Nuclear Licensing & Operations Support Virginia Electric & Power Company Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen. VA- 23060 David'A. Christian. Manager Surry Power Station Virginia Electric & Power Company 5570 Hog Island Road

.Surry, VA 23883 W. R. Matthews, Manager North Anna Power Station P. O. Box 402 Mineral, VA 23117 Chairman Surry County Board of Supervisors P. O. Box 130.

Dendron, VA- 23839 Dr. W. T. Lough Virginia State Corporation Commission Division of Energy Regulation P. 0.- Box 1197 Richmond, VA 23209

. Michael W. - Maupin-Hunton and Williams-Riverfront Plaza, East Tower 1 951 E. Byrd Street Richmond, VA 23219 State Health Commissioner

.0ffice of the Commissioner Virginia Department of Health P. O. Box 2448 Richmond,.VA:23218-Attorriey General Supreme Court Building.

900 East Main Street Richmond, VA 23219'

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l VEPC0 7 Distribution w/ encl:

PUBLIC LJCallan, EDO HThompson, DEDR AThadani DEDE GTracy, OEDO LChandler, 0GC JGoldberg, OGC RZimmerman, NRR EJulian, SECY BKeeling, CA Enforcement Coordinators RI, RIII, RIV JLieberman, OE OE:EA File (BSummers) (2 letterhead)

MSatorius, OE EHayden, OPA GCaputo, 01 Dross, AE0D HBell, OIG Buryc, RII PFredrickson, RII (IFS Action Required)

GEdison, NRR RReinhart NRR RGibbs, RII KClark, RII RTrojanowski,RII ABelisle, RII NRC Resident Inspector U.S. Nuclear Regulatory Commission Surry Nuclear Power Station 5850 Hog Island Road Surry, VA 23883 NRC Resident Inspector U.S. Nuclear Regulatory Commission 1024 Hale Mineral, yVA Drive 23117 a

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