ML18142A202
| ML18142A202 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 02/20/1985 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML18142A201 | List: |
| References | |
| 85-078, 85-78, NUDOCS 8503140304 | |
| Download: ML18142A202 (4) | |
Text
W1I.LL4M L STEWART '-
Vice President Nuclear-Operations Dr. J. Nelson Grace Regional Administrator Region II February 20, 1985 U. S. Nuclear Regulatory Commission 101 Marietta Street, Suite 2900 Atl~nta, Georgia 30323 Gentlemen:
A 9: 58 Serial No.
NO/HLM:dln Docket Nos.
License Nos.
Nuclear Operations Department Post Office Box 26666-0ne]ames River Plaza Richmond, Virginia 23261 VIRGINIA POWER 85-078 50-280 50-281 DPR-32 DPR-37 We have reviewed your letter of January 22, 1985 in reference to the inspection conducted at Surry Power Station on November 5-30, 1984, and reported in IE Inspection Report Nos.
50-280/84-34 and 50-281/84-34. Our response to the specific violation is attached.
We have determined that no proprietary information is contained in the report.
Accordingly, Virginia Power has no objection to this inspection being made a matter of public disclosure. The information contained in the attached pages is true and accurate to the best of my knowledge and belief.
Attachment cc:
Cw/attachment)
Mr. Steven A. Varga, Chief Operating Reactors Branch No. 1 Division of Licensing Mr. D. J. Burke NRG Resident Inspector Surry Power Station 8503140304 850307 PDR ADOCK 05-000280 G
PDR Very truly yours, W. L. Stewart
('
RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-280/84-34 and 50-281/84-34 VIOLATION Technical Specification 6.4.B requires that detailed written proce-dures with appropriate check-off lists and instructions be provided for normal startup, operation, and shutdown of a unit, and for all systems and components involving operation and shutdown of a unit, and for all systems and c.omponents involving nuclear safety of the station, including actions to be taken for specific and foreseen mal-functions of systems or components, including alarms, shall be followed.
Contrary to the above, the following operating and administrative procedures were not properly followed during the Unit 2 restart to full power operation:
- 1.
Operating Procedure OP-lA, Startup Checklist, requires the signature (permission).of the Superintendent of Operations before exceeding three startup hold points; prior to exceeding 200 degrees Fahrenheit, pr.ior to raising the plant temperature and pressure above 350 degrees Fahrenheit and 450 psig, and prior to criticality and power operations.
In addition, identified systems which undergo significant maintenance during the outage are listed at these hold points to ensure adequate valve check-lists are performed.
Contrary to the above requirements, only the final hold point (criticality and power operation) was properly signed off via telecommunications with the Superintendent of Operations, and no valve checklists were listed at any of the three OP-lA hold points, although Unit 2 was shutdown for approximately three weeks du.ring replacement of the "A" reactor coolant pump motor and seals.
Engineered Safeguards and Reactor Coolant System (RCS) checklists were performed as detailed in the Shift Order Book.
The Unit 2 reactor tripped from 20 percent power on November 20, 1984, due to a low water level condition in the "c" steam generator.
The manual isolation valves (2-FW-16, 47, and 78) in the main feedwater lines were found closed, and manual isolation valve 2-FW-85 in the feedwater bypass line was partially (75%) closed.
- 2.
Administrative Procedure ADM-29.3, Operation Department Logs and Records, requires the logging of annunciator alarms which extend beyond shift change, require maintenance, or have safety significance, in the Annunciator Logbook.
In addition, ADM-29.3 requires a weekly review of the Annunciator Logbook by management personnel.
Contrary to the above requirements, fifteen control room safety-related alarms were annunciated during and subsequent to the Unit 2 restart without being properly logged in the Annunciator Logbook.
In addition, the logbook review was documented on November 13, and November 26, 1984, and not during the week of the restart when the alarms were outstanding.
The inspectors did verify that the operators were monitoring the alarms and initiating corrective actions on them, and that none of the alarms resulted in Technical Specification violations for equipment operability.
This is a Severity Level IV violation (Supplement I), and applies to Unit 2.
RESPONSE
(1)
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION:
The violation is correct as stated.
However, some clarification of the examples cited is required.
Operating Procedure lA was followed during the restart of Surry 2 in that numerous valve checklists specified by the Superintendent of Operations were performed prior to leaving 350 degrees Fahrenheit/450 psig.
(The main feedwater valve checklist was not one of those specified).
It is agreed that mode changes authorized via telecon were not properly transcribed into the startup procedure; however, the proper authorizations were obtained.
The subsequent reactor trip is not attributable to such irregularities in the OP-lA, but to the failure of operators to properly track abnormal plant status.
Each of the 15 annunciators cited in Example 2 was fully discussed by the Shift Supervisor and the Superintendent of Operations.
(2)
REASONS FOR VIOLATION:
The reason for the violation is operator and supervisory
inattention to details of required paperwork.
The reasons and corrective action for the reactor trip are provided in LER 84-016.
(3)
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:
Operations personnel have been reinstructed in the necessity for procedural compliance.
(4)
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
It is the position of Virginia Power Co. that full compliance is met with current procedures.
However, to further enhance our program, OP-lA will be modified by *April 15, 1985, to require updating/reviewing the annunciator response log prior to each mode change.
(5)
THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Full compliance has been achieved.