ML18152A999
| ML18152A999 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 06/13/1988 |
| From: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Cruden D VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| Shared Package | |
| ML18152B000 | List: |
| References | |
| EA-88-074, EA-88-74, NUDOCS 8806240049 | |
| Download: ML18152A999 (4) | |
Text
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~/.1._.*1..,,-V JUN 131988 Docket Nos.
50-280 and 50-281 License Nos.
DPR-32 and DPR-37 EA 88-74 Virginia Electric and Power Company vct"TN:
Mr. D. S. Cruden, Vice President, Nuclear Operations Post Office Box 26666 Richmond, Virginia 23261 Gentlemen:
SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY (NRC INSPECTION REPORT NOS. 50-280/88-04 AND 50-281/88-04)
This refers to the Nuclear Regulatory Commission (NRC) inspection conducted by W. E. Holland at Surry Power Station on February 1-27, 1988.
The inspection included a review of the heat trace circuitry installed on the Chemical Volume and Control System (CVCS) boric acid piping which supplies required flow paths to the charging pump suction piping.
The report documenting this inspection was sent to you by letter dated March 21, 1988.
As a r*esult of this inspection, failures to comply with NRC requirements were identified, and accordingly, NRC concerns relative to the inspection findings were discussed in an Enforcement Conference held on Ma"rch 28, 1988.
The letter summarizing this conference was sent to you by letter dated May 4, 1988.
The violations described in the enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Notice) involved a failure to verify operability of required boric acid piping heat tracing circuits on a monthly basis as required by Technical Specifications (TS). This failure resulted in the inoperability of these heat tracing circuits going undetected for an extended period of time. This condition existed since December 1984 for Unit 1 and May 1985 for Unit 2.
The NRC is concerned that an annunciator in the main control room on the common alarm panel, which provided appropriate warning of the heat tracing circuit problems, had been in the alarm condition for an extended period without an adequate evaluation of the condition. Adequate corrective actions were not implemented by your staff to investigate the heat trace problems until the NRC Resident Inspectors reviewed the alarm condition and voiced a concern. It was noted that, although other abnormalities existed, in addition to control room annunciator alarms during this period (i.e., local panel indications, temperature readouts of individual circuits, procedure reviews after testing, etc.), your staff's lack of understanding of the system contributed to these problems.
Only minimal response action was taken by the operators who had been relying on inappropriate surveillance testing results to establish operability of the heat trace circuits.
Although one cause of these violations was the lack of adequate procedures and testing to periodically verify operability of the heat trace system, the broader 8806240049 880613 PDR ADOCK 05000280 Q
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Virginia Electric and Power Company JUN 13 1982 NRC issue is the management tolerance which permitted this condition to go uncorrected for an extended period of time.
Management did not initiate adequate action to assess the situation until the NRC Resident Inspectors began inquiring into the problem and voicing concerns about the operability of the system.
With the number of deficiencies identified in the heat tracing system, it was fortuitous that a combination of failures did not occur that would hav*e caused a flow blockage in the boric acid piping.
To emphasize the importance of meeting Technical Specification operability and surveillance requirements and because of the extended period of time in which these requirements were not being met, I have been authorized, after consultation with the Director, Office of Enforcement, and the Deputy Executive Director for Regional Operations, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty in the amount of Fifty Thousand Dollars ($50,000) for the violations described in the enclosed Notice.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions, 11 10 CFR Part 2,'Appendix C (1988) (Enforcement Policy),
the violations described in the enclosed Notice have been categorized in the aggregate as a Severity Level III problem.
The base value of a civil penalty for a Severity Level III violation or problem is $50,000.
The escalation and mitigation factors in the Enforcement Policy were considered and no adjustment has been deemed appropriate.
Your extensive corrective actions once the problem was identified by the NRC and understood and your past performance in the area of plant operations and surveillance are offset by the extended length of time that the problem existed and opportunities to identify and correct the problem earlier.
You are required to respond to this letter and the enclosed Notice and should follow the instructions specified therein when preparing your response.
In your response, you should document the specific actions taken and any additional actions you plan to prevent recurrence.
These should include actions to be taken for enhancing management's attentiveness and participation in assuring the effective and timely correction of problems as they arise to preclude having them persist for extended periods of time. After reviewing your response to this Notice, including your proposed corrective actions and the results of future inspections, the NRC will determine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory requirements.
In accordance with Section 2.790 of the NRC 1s "Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosure will be placed in the NRC Public Document Room.
The responses directed by this letter and its enclosure are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, Pub. L. No.96-511.
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Virginia Electric and Power Company JUN 1 3 19F-' *.
Should you have any questions concerning this letter, please contact us.
Enclosure:
Notice of Violation and Proposed Imposition of Civil Penalty ere w/ encl:
vD.. L. Benson, Station Manager 1Jr:'* E. Hardwick, Manager - Nuclear Programs and Licensing Sincerely, ORIGlNAl SIGNED BY:
t, NELSON GRACE J. Nelson Grace Regional Administrator
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