ML18152A208
| ML18152A208 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 12/24/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18152A209 | List: |
| References | |
| 50-280-97-09, 50-280-97-9, 50-281-97-09, 50-281-97-9, EA-97-474, NUDOCS 9801210311 | |
| Download: ML18152A208 (34) | |
Text
NOTICE OF DEVIATION Virginia Electric and Power Company Surry Power Station Docket Nos. 50-280 and 50-281 License Nos. DPR-32 and DPR-37 EA 97-474 During an NRC inspection conducted on August 24 through October 4, 1997, a deviation of your Updated Final Safety Analysis Report (UFSAR) was identified.
In accordance with the "General Statement of Policy and Procedures for NRC Enforcement Actions," NUREG-1600, the deviation is listed below:
UFSAR Section 9.10.1 states that the station's fire protection program satisfies the regulatory criteria set forth in General Design Criterion 3, in 10 CFR 50 Appendix R (Sections III.G, III.J, III.Land III.O), and in Appendix A to Branch Technical Position APCSB 9.5-1 dated August 23, 1976.
Compliance with these criteria is contained in the 10 CFR 50 Appendix R Report, Surry Power Station Units 1 and 2.
The 10 CFR 50 Appendix R Report. Surry Power Station, Units 1 and 2.
Revision 11, Chapter 9, Electrical Distribution System Coordination Study, Section 9.1, states that coordination of circuit protective devices to prevent unnecessary outages of power supplies needed for safe shutdown is required to conform to the requirements of Appendix R. The Appendix R Report states that components involved in critical circuits were investigated and data gathered to facilitate verification of the capability of the interrupting devices to operate selectively and to continue to supply power to all critical circuits not affected by the postulated fire.
Section 9.2 of Chapter 9 concluded that miscoordination existed on the 120 volt alternating current (VAC) bus system due to.the maximum half cycle instantaneous current supplied by the bypass transformers. The Appendix R report states that, to assure coordination, the Square D 100 ampere (amp) trip main circuit breakers in each vital bus panel will be replaced with non-automatic molded case switches.
Contrary to the above, the 100 amp breakers were not replaced with non-automatic switches as committed to in the Appendix R Report to ensure compliance with UFSAR Section 9.10.1. This resulted in inadequate breaker coordination between the vital bus branch circuits and vital bus main panel breaker for the vital bus panels supplying circuits installed in the Units 1 and 2 emergency switchgear rooms and the Turbine Building.
Each of these panels supply Appendix Rand safe shutdown related components.
Please provide to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, D.C. 20555, with a copy to the Regional Administrator, Region II. and a copy to the NRC Resident at Surry, in writing within 30 days of the date of this Notice, (1) the reason for the deviation, or if contested, the basis for disputing the deviation. (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further deviations, and (4) the date when your corrective action will be completed.
Where good cause is shown, consideration will be given to extending the response time.
Dated at Atlanta, Georgia this 24th day of December 1997 9801210311 971224 PDR ADOCK 05000280 G
LIST OF PREDECISIONAL ENFORCEMENT CONFERENCE ATTENDEES December 4. 1997 Virginia Electric & Power Company (VEPCO)
M. Kansler, Vice President Nuclear Operations D. Christian, Station Manager R. Blount. II. Assistant Station Manager, Nuclear Safety and Licensing*
J. Collins, Director, Nuclear Oversight L. Hartz. Manager. Nuclear Engineering J. McCarthy, Manager, Nuclear Licensing and Operations Support L. Kidd, Supervisor, Nuclear Engineering Configuration Control B. Stanley, Supervisor, Station Licensing B. Mallett. Acting Deputy Regional Administrator, RII J. Jaudon, Director, Division of Reactor Safety (DRS). RII L. Plisco, Deputy Director, Division of Reactor Projects CORP), RII C. Evans. Regional Counsel A. Boland, Director, Enforcement and Investigations Coordination Staff (EICS),
RII G. Belisle, Chief, Special Inspection Branch, DRS,RII R. Haag, Chief, Reactor Projects Branch 5, DRP, RII J. Lyons, Director, Project Directorate II-1, Office of Nuclear Reactor Regulations (NRR)*
G. Edison, Project Manager, NRR P. Madden, Senior Fire Protection Engineer, NRR R. Musser, Senior Resident Inspector, DRP, RII W. Miller, Reactor Inspector, DRS*
- Participated by telephone.
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VIRGINIA POWER Pre-Decisional Enforcement Conference December 4, 1997
. Opening Comments M. R. Kansler Vice President -
Nuclear Operations
Agenda VIRGINIA POWER Opening Comments Issues, Past Events, and Past Perspective Recent Events, Current Perspective, and Corrective Actions Closing Comments M. R. Kansler D. A. Christian Ro H. Blount M. R. Kansler
Issues, Past Events, and Past Perspective D. A. Christian Station Manager
VIRGINIA POWER Path to Appendix R Compliance
- Approach to Address Appendix R Requirements
- Defense in Depth Concept
- Extensive Modifications
-Approximately 30 Design Changes and Engineering Work Requests In1plemented Prin1arily During 1984 to 1987
VIRGINIA POWER DCP No.83-039 83-045/-046 84-001 84-008 84-020/-021 84-022/-023 84-024 84-042/-043 84-056/-057 84-063 Path to Appendix R Compliance ( continued)
Title Complete*d App. R EDG Control Mods 11/86 App. R MCC Control Transformer Fuse Prat.
1/85, 6/85 App. R ESGR Halon System 12/85 App. R Power Source 8/85 Hot Leg Temp. Indicator at RMP 12/84, 6/85 App. R Mod Containment Instrumentation 12/84, 6/85 App. R. Addition of Emergency Lights 12/85 App. R RH Pump Radiant Energy Shields 12/84, 5/85 App. R Spurious Operation of Hi-Lo PB Valves 12/84, 6/85 App. R Emergency Communications Upgrade 10/85 I,
VIRGINIA POWER DCPNo.
84-064/-065 84-066 84-067 84-068 84-075 84-077 /-078 84-085/-086 89-010 91-050 93-022 Path to Appendix R Compliance* ( continued)
Title Completed App. R. MIS System Valves FP 8/85, 6/85 App. R ESGR Vent. Equipment Isolation 11/86 App. R Charging Pump SW Piping Replacement 4/89 App. R Aux. Bldg. Fan Cable Reroute 6/86 App. R. CC and RH Circuit Isolation 10/85 App. R RC Letdown Line IA Mods 7/.86, 6/85 App. R Coordination Study Fuse Replacement 2/86, 6/85 App. R Smoke Detection System Additions 3/95 VS Vent Valve Addition to App.RAO Dampers 6/93 BS Cable Vault Fire Barriers for App. R 8/95
VIRGINIA POWER Path to Appendix R Compliance ( continued)
EWRNo.
Title Completed 84-356 App. R Emergency Radio Communications Upgrade 12/84 85-589 Relocation App. R Locker & Ice Vest Freezers 2/87 86-001.
Additional Containment Cable Tray Fire Stops 2/86 86-190 App. R MSVH Emergency Lighting Mod 3/87 87-207 App. R Lighting Mod 5/88 87-222 App. R Communications Cable Reroute 6/87 89-704 Evaluate App. R Cable Sep. in ESGR & Relay Room 8/90 91-034 Emergency Light Walkdown/Update of App. R Report 11/93
Apparent Violations VIRGINIA POWER
- Failure to Meet Appendix R Requirements for Breaker Coordination
- Failure to Provide Vital Bus Isolation to Meet Appendix R
- Failure.to Promptly Correct Appendix R Discrepancies Identified in 1992 and 1993
- Failure to Properly Report Appendix R Discrepancies Outside Design Basis
VIRGINIA POWER Breaker Coordination Issue Description
- Breaker Coordination Issue
-Postulated High Fault Current
-Main Vital Bus Breaker Could Trip -
Si111ultaneously With or In Lieu of Branch Breakers
-Appendix R Report Indicates Coordination Required
VIRGINIA POWER Breaker Coordination Issue.Events
- 1/93 DR Identified Breaker Coordination Issue
- 6/93 Type 1 Engineering Report
- DCP 94-018 Addressed Both Isolation and Coordination Issues
- Issue Identified and Driven by Corrective
- Action Program Commensurate with Safety Significance
- Breal(er Coordination VIRGINIA POWER Issue Events ( continued)
- Recently Determined to Not Be Outside Design Basis
- Cable Length Precludes Except For Fires in Four Fire Areas
- Loss of. Single Vital Bus For Fires in Four Fire Areas as Result of Lack of Coordination
- Loss of Single Vital Bus Addressed by Procedure
- DCP 94-018 Included Replacement of Main Breakers with Non-automatic Switches
- Implemented on Unit 2 During October 1997 RFO
- Scheduled on Unit 1 During October 1998 RFO
VIRGINIA POWER Vital Bus Isolation Issue Description
- Vital Bus Isolation.Issue
- No Means to Isolate Vital Bus Panels in MCR from UPSs in ESGR For MCR Fire
- Loss of UPS Affects Indication in MCR and on Remote Monitoring Panel (RMP)
- Auxiliary Shutdown Panel Controls Remain Available
- 4160V/480V Power Supplies
- Pumps, Motors, and Valves
- Loss of RMP Outside Appendix R Design Basis
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Vital Bus Isolation Issue - Past Events VIRGINIA POWER
- 8/85 - Installation of Appendix R Isolation Feature (DCP 84-008)
- 11/92 - Design Change Process Initiated to Reinstall Isolation Devices
- 6/93 - Revi_sed Fire Contingency Action (FCA) Procedure to Address Isolation
- DCP 94-018 Included Reinstallation of Isolation Devices
-. Implemented on Unit 2 During October 1997 RFO
- ScheduJed on Unit 1 During October 1998 RFO
Past Perspective VIRGINIA POWER
- Foundational Error Occurred in 1992
- Modification Planned to Restore Isolation
- Continuously Manned Control Room Considered Acceptable Compensatory Measure
- Mindset of Compensatory Measures Being Equal to Compliance with Design Basis
- Inappropriate Prioritization of Modification Resulted
- Regulatory Objective - Reasonable Assurance of Public Health and Safety - Deemed to be Met
VIRGINIA POWER
- Timeliness Past Perspective
( continued)
- Risk Informed Perspective: Limiting Fire Probability Extremely Low
- Potential for DCP 94-018 to Challenge Operations
- Perceived Adequacy of Compensatory Measures
- Continuously Manned Control Room
- Detection and Fire Extinguishers Immediately Available
- Although Inappropriately Prioritized, Corrective Action Program Continued to Drive and CTS Tracked
Recent Events, Current Perspective, and Corrective Actions R.H. Blount Assistant Station Manager -
Nuclear Safety & Licensing
~
VIRGINIA POWER Vital Bus Isolation Issue - Recent Events
- 3/97 DR Identified as Appendix R Non-compliance
- 6/97 - Reassessment of DCP Initiated
- 7 /97 - NRC IN 97-48 Issued
- 7 /30/97 and 8/5/97 Conference Calls with NRC
- 8/27 /97 Letter to NRC Discussing Issue, Compensatory Measures, Planned Modifications
- 9/25/97 Letter from NRC Accepting Compensatory Measures Until Compliance Achieved
- 10/97 - LER Reporting Outside Appendix R. Design Basis
Current Perspective VIRGINIA POWER
- Mindset of Comp~nsatory Measures Being Equal to Compliance with Design Basis Carried Forward from 1992 into 1997
- In Preparation for Upcoming Outage and In View of Different Perspective and IN 97-48
- Isolation Issue Reexamined
- DCP 94-018 Reassessed
VIRGINIA POWER Current Perspective
( continued)
- Upon Recognition of Significance, Took Decisive
- and Comprehensive Actions
- JCO Approved, FCAs/Compensatory Measures Expanded, and Equipment/Tools Staged
- As Understanding Evolved, Kept NRC Informed Through Resident, Conference Calls, and Letter
- Upon Recognition of Being Outside Appendix R Design Basis, Reported in Accordance With 10CFR50.73
Current Perspective VIRGINIA POWER
( continued)
- With DCP 94-018 Completed on Unit 2
- Can Achieve and Maintain Hot Shutdown on Both Units With No Repairs or Compensatory Measures
- Can Achieve Cold Shutdown on Unit 1 With No Compensatory Measures
-Can Achieve Cold Shutdown on Unit 2 Using Compensatory Measures Currently in Place
36'-0" CABLE VAULT HOT STORAGE CORRIDOR AIR CONO RH UNIT I AIR CONO RM UNIT 2 COMPUTER ROOM N0.2 VB 2-1 VB 2-III D
CONTROL ROOM 36'-0" I
PART. PLAN -
EL. 27'-0 11 SCALE:NONE
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LEGEND:
© -FIRE EXTINGUISHER
@ - FIRE/SHOKE DETECTOR
VIRGINIA POWER Current Perspective
( continued)
- Main Control Room Features
- Layout and Intervening Walls/Doors.
- Detection and Suppression Equipment
- Continuously Manned
- - Operations Staff Training as Fire Brigade Members
- Fire Resulting in Loss of Vital Bus Panels That Could Impact Power Supply to RMPs and MCR Evacuation -
Extremely Low Probability Event Based on PRA Calculation
Corrective Actions VIRGINIA POWER
- Completed Actions
- Category 1 Root Cause Evaluation
- Root Causes
- Contributing Causal Factors
- Recommended Actions
- Assessment o*f Existing Non-Standard Compensatory Measures Currently in Place
-VPAP-2401 Revision to Address Implementation of Non-Standard Compensatory Measures
Corrective Actions*
( continued)
VIRGINIA POWER
- Completed Actions_( continued)
Familiarization Briefings Regarding VPAP-2401
- Revision Review of Selected Design Changes to Verify That Appendix R Features Retnain Intact Corrective Action Program Revision Operating Experience Review of NRC IN 97-48
VIRGINIA POWER
- Planned Actions Corrective Actions
( continued)
Multi-Utility Assessment Using Appendix R Portion of Pilot FPFI Module Nuclear Business Unit Training to Address
- Appendix R Design Basis and Implications Set -Standard for Written Communication Multi-Disciplined Review of Portions of Appendix R Report VPAP-2401 Revision for Standard Compensatory Measures
- Closing Comments M. R. Kansler Vice President -
Nuclear Operations
Closing Comments VIRGINIA POWER
- Breaker Coordination and Vital Bus Isolation Issues
- Technically Correct As Stated In Inspection Report
- Self-identified Deficiencies
- Low Probability and Safety Significance
- Compliance Status
- Coordination - In Compliance on Unit 2
- Isolation - In Compliance on Unit land in Partial Compliance on Unit 2
- Remaining Modifications Scheduled for Oct. 1998
- t
VIRGINIA POWER
- Corrective Action Closing Comments
( continued)
- Modification Driven by Program and Tracked by CTS
- Untimely Due to Inappropriate Prioritization
- Reporting
- Coordination
- Not Outside Design Basis, But Deviation from Commitment
- Isolation
- Due to Foundational Error Did Not Recognize Outside Design Basis Earlier
- Reported in Accordance With 10CFR50.73 Upon Recognition
ENFORCEMENT CONFERENCE AGENDA SURRY NUClEAR STATION DECEMBER 4, 1997, AT 10:30 A.M.
NRC REGION II OFFICE, ATLANTA, GEORGIA I.
OPENING REMARKS AND INTRODUCTIONS B.
Ma 11 ett Acting.Deputy Regi ona 1 Administrator I I.
NRC ENFORCEMENT POLICY A Boland. Director Enforcement and Investigation Coordination Staff III.
SUMMARY
OF THE ISSUES B.
Mallett Acting Deputy Regional Administrator IV.
STATEMENTS OF CONCERNS/ APPARENT VIOLATIONS J. Jaudon. Director Division of Reactor Safety V.
. LICENSEE PRESENTATION VI.
BREAK/ NRC CAUCUS VII.
NRC FOLLOW UP QUESTIONS VIII.
CLOSING REMARKS B.
Mallett Regional Administrator
I A.
ISSUES TO BE DISCUSSED Inadequate means available to isolate 120 VAC power panels VB 1-I and VB 1-III and panels VB 2-I and VB 2-III located in the control room complex from the UPS pan~ls.
Electrical faults from an Appendix R fire in the control room complex could cause the loss of power to the Appendix R remote shutdown panels and Appendix R communication equipment.
B.
Inadequate breaker coordination provided for vital bus branch circuits and associated vital bus main panel breaker.
C.
Failure to identify and correct the noncompliance with the Appendix R requirements for the control room. identified by the licensee in 1992. and inadequate breaker coordination issues. identified in 1993.
D.
Failure to notify the NRC. as required by 10 CFR 50.72(b)(l)(ii)(B) and 50.73(a)(2)(ii)(B). of plant conditions which were identified in 1992. 1993 and 1997 to be outside the basis of design.
NOTE: The apparent violation discussed in this PREDECISIONAL enforcement conference is subject to further review and is subject to change prior to any resulting enforcement action.