ML18152A463

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Summarizes 950424 Enforcement Conference in Atlanta,Ga Re Apparent Violation of Plant TSs in Area of Pressurizer Pressure Instrumentation Calibr.List of Attendees & VEPCO Presentation Encl
ML18152A463
Person / Time
Site: Surry Dominion icon.png
Issue date: 05/05/1995
From: Merschoff E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To: Ohanlon J
VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
References
EA-95-053, EA-95-53, NUDOCS 9505110048
Download: ML18152A463 (32)
v • d • e


Text

May 5, 1995 EA 95-053 Virginia Electric and Power Company ATTN: Mr. J. P. O'Hanlon Senior Vice President - Nuclear Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060

SUBJECT:

MEETING

SUMMARY

- SURRY ENFORCEMENT CONFERENCE ON PRESSURIZER PRESSURE TRANSMITTER CALIBRATION (NRC INSPECTION REPORT NO. 50-281/95-06)

Gentlemen:

This refers to the enforcement conference conducted at our request at the NRC Region II office in Atlanta, Georgia, on April 24, 1995.

The purpose of the enforcement conference was to discuss an apparent violation of Unit 2 Technical Specifications in the area of pressurizer pressure instrumentation ca.l i brat ion.

A list of attendees and a copy of your slides are enclosed.

In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this summary and its enclosures will be placed in the NRC Public Document Room.

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

Docket No. 50-281 License No. DPR-37 EA 95-053 Sincerely, Ofig ~igned by Ellis W. Merschoff Ellis W. Merschoff, Director Divisinn of Reactor Projects

Enclosures:

1.

List of Attendees

2.

VEPCO Presentation cc w/encls:

See page 2 9505110048 950505 PDR ADOCK 05000281 G

PDR

VEPCO cc w/encls:

M. L. Bowling, Manager Nuclear Licensing & Programs

  • Virginia Electric & Power Company Innsbrook Technical Center 5000 Dominion Boulevard Glen Allen, VA 23060 David A. Christian Station Manager Surry Power Station P. 0. Box 315 Surry, VA 23883 Ray D. Peace, Chairman Surry County Board of Supervisors P.O. Box 130 Dendron, VA 23839 Dr. W. T. Lough Virginia State Corporation Commission Division of Energy Regulatfon P. 0. Box 1197 Richmond, VA 23209 Michael W. Maupin Hunton and Williams Riverfront Plaza, East Tower 951 E. Byrd Street Richmond, VA 23219 Robert B. Strobe, M.D., M.P.H.

State Health Commissioner Office of the Commissioner Virginia Department of Health P. 0. Box 2448 Richmond, VA 23218 Attorney General Supreme Court Building 101 North 8th Street Richmond, VA 23219 2

VEPCO Distribution w/encls:

J. Lieberman, OE B. Buckley, NRR G. Hallstrom, RII OE: EA PUBLIC 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 Route 2, Box 78-A Mineral, VA 23117 3

  • FOR PREVIOUS CONCURRENCE SEE ATTACHED I

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NO

VIRGINIA POWER SURRY POWER STATION ENFORCEMENT CONFERENCE APRIL 24, 1995

  • Enclosure 2

. VIRGINIA POWER INTRODUCTION R. F. Saunders Vice President -- Nuclear Operations

AGENDA

  • Introduction
  • Management Perspective
  • Sequence of Events
  • Root Cause Team Conclusions
  • Corrective Actions and Safety Significance
  • Closing Comments R. F. Saunders D. A. Christian J. A. Price J. D. Carson J. A. Price R. F. Saunders

VIRGINIA POWER MANAGEMENT PERSPECTIVE D. A. Christian Station Manager

.~

MANAGEMENT PERSPECTIVE Virginia Power Personnel Identified in February 1995 that As-Found Calibration Data for the Unit 2 Pressurizer Pressure Protection Transmitters was Out of Calibration Management Thoroughly Reviewed the Issue to Assess the Safety Significance and Determine the Causes Nuclear Analysis and Fuel Department Assessment Root Cause Team Evaluation No Safety Significance was Associated with the Event

MANAGEMENT PERSPECTIVE No Problems were Identified with the Unit 1 Pressurizer Pressure Protection Transmitters or Other Unit 2 Instrumentation The Root Cause Team Identified:

The Sources of the Pressurizer Pressure Protection Transmitter Calibration Offset Weaknesses in the Implementation of the Measuring and Test Equipment Program Corrective Actions have been Initiated.

Management and Staff have been Coached on the Lessons Learned

VIRGINIA POWER SEQUENCE OF EVENTS J. A. Price Assistant Station Manager Nuclear Sa/ ety and Licensing

SEQUENCE OF EVENTS

  • . Three New Pressurizer Pressure Protection Transmitters were Installed During the June 1994 Unit 2 SGCC Outage Bench Calibration Check Field Calibration Using Gauge No. SQC-437 at Cold Shutdown The Pressurizer Pressure Protection Channels were Indicating Approximately 30 psig Lower than the Pressurizer Pressure Control Channels on June 24, 1994, with Unit 2 at Hot Shutdown. Deviation Report S-94-1352 was Submitted l&C Personnel Investigated the Conditio.n and Determined that an Error in Reading the Gauge Occurred During the Previous Transmitter Calibration Calibration Adjustments were Made Using Gauge No.

SQC-437

SEQUENCE OF EVENTS

  • . On June 25, 1994, Shortly After Placing the Unit on Line, the Pressurizer Low Pressure Annunciator Alarmed.

Deviation Report S-94-1353 was Submitted to Document the Alarm and Noted that the Pressurizer Pressure Protection Channels Indicated 15 to 20 psig Higher than the Pressurizer Pressure Control Channels The Deviation Reports were Closed when it was Determined that the Calibration Discrepancy was Caused by an Error in Reading the Test Gauge Unit 2 Operated until the Start of the Refueling Outage on February 3, 1995

SEQUENCE OF EVENTS

  • The Technical Specification Required Calibration was

. Performed on the Transmitters at Cold Shutdown on February 10,1995 The As-,Found Calibration Data for the Pressurizer Pressure Protection Transmitters was Not within the Allowable Tolerance Due to the As-Found Data, a Second Calibration was Performed Using a Different Gauge Deviation Report No. S-95-0365 was Submitted The Nuclear Analysis and Fuel (NA&F)

  • Department was Contacted for Assistance in Assessing the Condition. NA&F Concluded that Unit Operation at Rated Power was Bounded by the Existing Safety Analyses and was within the Plant's Design Basis

SEQUENCE OF EVENTS

  • Management Established a Root Cause Evaluation (RCE)

. Team on February 23, 1995 The Pressurizer Pressure Protection Channels. were Determined to be Inoperable.

Licensee Event Report 50-281/95-003 was Submitted On March 18, 1995, with Unit 2 at Hot Shutdown, Pressurizer

.Pressure Protection Channels were Noted to Indicate 1 O to 15 psig Lower than the Pressurizer Pressure Control Channels, but were within Technical Specification Limits The Category I Root Cause was Completed and Approved by Management on April 19, 1995

VIRGINIA POWER ROOT CAUSE TEAM CONCLUSIONS J. D. Carson Assistant I&C Supervisor

ROOT CAUSE TEAM EVALUATION

  • The Root Cause Team Evaluated the Following Areas Transmitter Installation Process Transmitter Shift Due to Temperature Effects Calibration Procedures M& TE Program Gauge Calibration Process Gauge Inventory Gauge Procurement Process Effects of Temperature on Gauge No. SQC-437 Instrumentation Calibrated Using Gauges that are Not Compensated for Temperature Operating Experience I

r ROOT CAUSE TEAM CONCLUSIONS

  • Principal Causes Gauge Used During Field Calibration at Hot Shutdown was Not Compensated for Temperature Knowledge of Metrology Laboratory Personnel was
  • Insufficient Environmental Requirements were Not Specified on the Purchase Order for Gauge No. SQC-437 The Effect of Sub-Atmospheric Conditions on the Rosemount Model 1154SH was Not Accommodated in the Calibration Procedures 1154SH Transmitters are Sealed on the Low Side. The Low Side of Previously Installed Transmitters was Vented to Containment Atmosphere

ROOT CAUSE TEAM CONCLUSIONS

  • Contributing Factors Transmitter Calibration Shift Associated with an Increase in Temperature Inadequate Torque of the Bourdon Tube Assembly During the Manufacturing Process Resulted in Intermittent Gauge Binding {SQC No. 437)

Questioning Attitude During June 1994 Transmitter Field Calibration I & C Technician Training Includes Only a Limited Discussion Regarding Temperature Compensation and

-Indicates that Only Temperature Compensated Gauges are Used in the M& TE Program

r ROOT CAUSE TEAM CONCLUSIONS

  • Contributing Factors (Continued)

Review and Disposition of Discrepancies Noted Between Pressurizer Pressure Protection and Control Indications in June 1994 After Obtaining Non-repeatable Calibration Results for Gauge No. SQC-437, An Inadequate M&TE Evaluation was Performed for the Equipment Calibrated with the Gauge

VIRGINIA POWER

  • CORRECTIVE ACTIONS, AND SAFETY SIGNIFICANCE J. A. Price Assistant Station Manager Nuclear Sa/ ety and Licensing

CORRECTIVE ACTIONS Submit a Deviation Report Complete Perform a Root Cause Evaluation Complete Perform a Safety Assessment Complete Verify the Operability of Associated Complete Components in Each Protection Channel Remove Mech*anical Heise Gauges that are Complete Not Compensated for Temperature from the M& TE Program Review Other Equipment Calibrations that Complete were Performed with Gauges that are Not for Analog Compensated for Temperature July 1995 for Digital

CORRECTIVE ACTIONS

  • Submit a Licensee Event Report and Supplement Revise M& TE Data Sheets to Specify the Purchase of Temperature Compensated Gauges Only Revise Training Programs to Include a Detailed Discussion Regarding the Use of Temperature.

Compensated Gauges and Gauges that are Not Compensated for Temperature Revise Procedures for Calibrating Transmitters at Sub-Atmospheric Conditions Quality Assurance to Perform an Audit of the M& TE Program Complete June 1995 October 1995 October 1995 June 1995

SAFETY SIGNIFICANCE

  • . The Impact of Three Pressurizer Pressure Protection Transmitters Not Calibrated within the Allowable Tolerance
  • was Evaluated The Evaluation Concluded that Unit Operation at Rated Power Remained Bounded by the Previously Docketed Safety Analyses The Transmitter Safety Functions would have Occurred, Although Delayed. *However, Technical Specification Setpoint Limits would have been Exceeded Pressurizer Low Pressure Reactor Trip Actuation

(> 1860 psig)

Pressurizer Low-Low Pressure Safety Injection Actuation

(> 1700 psig)

Current Operation is within Technical Specification Limits

CONCLUSIONS

  • Based on the Information Available at the Time, Disposition of

. the June 1994 Transmitter Calibrations was *Appropriate.

However, Questions Generated During Reviews did Not Detect All Facts as Determined by the Root Cause Team

  • The Root Cause has been Determined Comprehensive Corrective Actions have been Initiated No Safety Significance Technical Specification Limits are Currently Being Met.

Transmitter Shift Beyond Manufacturer's Tolerance is Being Evaluated

VIRGINIA POWER CLOSING COMMENTS R. F. Saunders Vice President -- Nuclear Operations

(INCREASING TRIP FUNCTION)

~ -

jl_ __

TA = (SAL -

ACTUAL TRIP SETPOINT)

YARGIN =- (TA -

CSA)

SAFETY LIMIT SAFETY AN.ALYSIS LIMIT (SAL)

MAXIMU¥ T.S. LIMIT EXISTING T.S. LIMIT M.AXIMUY TRIP SETPOINT UPPER CALIBRATION LIMIT ACTUAL TRIP SETPOINT LOWER CALIBRATION 1..n.nT UPPER OPERATING CONmoL LIMIT NOMINAL OPERATING VALUE 21 I

8 I.

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a

~

CSA -

SE +/- [ EA + Pl!A + PEA + (SCA + Sl,iTE) + SD + SPE + STE + (RCA + RYTE) +

RD*+ R~ + RRA.

1

] E 111 OR a

8 a

a I

a I

CSA = SE +/- [ EA + PYA + PEA + (SCA + SMTE) +* SD + SPE + STE + (M1 + RMTE) +... +

(l.!n + RMTE) * + RD 1 + RTE 1 + 'RF.A. J t'"

NOTE 1:

THE MAXDlUM T. S. LIMIT ENCOMPASSES THE RACK ERROR COl,O>ONENTS.

NOTE 2:

CALIBRATION ACCURACY; + /- (RC.A. + RCSA) OR + /- ( Ml +... l.£n )

OR a

I 1/1 I

I I,..

+/- ( RCA + RCSA ) E OR +/- ( M:1 +... + lln ) E NOTE 3:

SAFETY ANALYSIS UNCERTAINTIES (i.e. PROCESS DELAYS, TIW!: RESPONSE, eu:. )

NOTE 4:

DETERMINED BY CONTROILER SETTINGS AND/OR ALARM SETPOINTS

  • I

.STABLISHMENT OF SAFETY RELATED TRIP SETPOINTS (INCREASING TRIP FUNCTION)

BREAKDOWN OF CSA ERROR TERMS SAFETY ANALYSIS LIMIT E--

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g

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0 E-<

MAXIMUM T.S. LIMIT (ALLOWABLE VALUE)

MAXIMUM TRIP SETFOINT SYSTEMATIC ERROR (SE) -

TREATED AS A BIAS PROCESS MEASUREMENT ACCURACY (PMA)

PRIMARY ELEMENT ACCURACY (PEA)

SENSOR CALIBRATION ACCURACY & M&TE (SCA + SMTE) rn u -

r:cl SENSOR DRIFT (SD) u ----

z: :

g SENSOR PRESSURE EFFECTS (SPE)

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SENSOR TEMPERATURE EFFECTS (STE)

E-,

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E-,

i/.l RACK TEMPERATURE EFFECTS (RTE)

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r:cl z z ttl ----

u RACK MEASURING & TEST EQUIPMENT (RMTE)

RACK COMPARATOR SETTING ACCURACY (RCSA)

RACK CALJBRATION ACCURACY (RCA) OR (Ml+M2+... Mn)

RACK DRIFT (RD)

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0 E t:I t:I

.AL TRIP SETPOINT ""',. < ""',.

.RY POWER STATION PRESSURIZER HIGH PRESSURE RX TRIP E--

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0 E--

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--~ ---r C) c.!l (INCREASING TRIP FUNCTION)

SAFETY LIMIT = 2735 PSIG = > 5.000 VDC SAFETY ANALYSIS LIMIT (SAL) = 2410.3 PSIG = 4.552 VDC MAXIMUM T.S. LIMIT = 2403.58 PSIG = 4.518 VDC MAXIMUM TRIP SETPOINT = 2394.62 PSIG = 4.4 73 VDC EXISTING T.S. LIMIT = 2385 PSIG = 4.425 VDC SURVEILLANCE LIMIT = 2376.96 PSIG = 4.395 VDC

~

______ --1 UPPER C.ALIERATION LIMIT = 2374.0 PSIG = 4.370 voe ACTUAL TRIP SETPOINT = 2370.0 PSIG = 4.350 voe LOWER C.ALIERATION LIMIT = 2366.0 PSIG = 4.330 voe

__ l_ __

UPPER OPERATING CONTROL LIMIT = 2250.0 PSIG = 3.750 VDC NOMINAL OPERATING VALUE = 2235 PSIG = 3.675 VDC

MANAGEMENT PERSPECTIVE Unit 2 Pressurizer Pressure Protection Transmitter Offsets

+ 30 pslg

+ 15 psig Nominal Calibratlo

-15 pslg

- 30 pslg n

II Powe/dperatlpn 6/25/94 to 2/03/95 6/18/94 Cold Shutdown Callbratlon at CallbratJon at Cold Shutdown Hot Shutdown

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6/24/94 Hot Shutdown 2/09/95 Cold Shutdown I

I I

Callbratlon at Cold Shutdown 3/17/95 II Cold Shutdown II

\\

Refuellng Outage

\\

\\

3/18/95 Hot Shutdown Power Operations I I II

SEQUENCE OF EVENTS Unit 2 Pressurizer Pressure Protection Transmitter Offsets 6/25/94 Unit Startup Callbratlon at

+ 15 psig _______

D_R_S-_9_4_-1_3,..53_s_u_b_m_ltt_ed_-+-,,._ ______

--+--'C=o=ld::....:S=h=u=td=o=wn,_,____ _________

Power Operation 6/25/94 to 2/03/95 2/10/95 Callbratlon at

  • Callbratlon at Submitted 2/23/95 RCETeam Established Refueling Outage Power Operations

-15 pslg -------\\---1----------------------+------1--1'----

3/18/95

-30 pslg --------4l------------------------

6/24/94 Hot Shutdown DR S-94-1352 Submitted C

  • ROOT CAUSE TEAM CONCLUSIONS Unit 2 Pressurizer Pressure Protection Transmitter Offsets

+ 30 pslg

+ 15 pslg Nomlnal Callbratlo

-15 pslg

  • 30 pslg 2/09/95 Cold SI utdown I

Transmltte1 Power Operation Shift 6/25/94 to 2/03/95 II I"

II Gauae Not Temnerature

.._ Compensated (10 pslg) 6/18/94 Sub-Atmospheric Cold Shutdown 1.,

Containment (5 pslg) n Callbratlon at Cold Shutdown Gauge Callbratlon at Hot Shutdown

\\

Tra:~':;!tter \\

\\

6/24/94 Hot Shutdown I

Callbratlon at Cold Shutdown 3/17/95 II Cold Shutdown 7 /

\\

Refuellng Outage

\\ Tra~!:tter

\\

Power Operations I I I

II 3/18/95 u... -

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