ML18152B754
| ML18152B754 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 06/23/1998 |
| From: | Ohanlon J VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-280-98-04, 50-280-98-4, 50-281-98-04, 50-281-98-4, 98-347, NUDOCS 9806290048 | |
| Download: ML18152B754 (6) | |
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VIRGIMA ELECTRIC AND POWER COMPANY RICHMOND, VIRGl:0...1,\\ 23261 June 23, 1998 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D. C. 20555 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 REPLY TO A NOTICE OF VIOLATION Serial No.
SPS: BAG/GDM Docket Nos.
License Nos.
NRC INSPECTION REPORT NOS. 50-280/98-04 AND 50-281/98-04 98-347 R3 50-280 50-281 DPR-32 DPR-37 We have reviewed Inspection Report Nos. 50-280/98-04 and 50-281/98-04 dated June 3, 1998 and the enclosed Notice of Violation for Surry Units 1 and 2.
The report identified one cited violation for an inadequate procedure used to implement the steam generator power operated relief valve setpoints.
We have evaluated the circumstances that led to the implementation of the inadequate procedure and have determined that the job performance by the procedure writer and the operator who implemented the procedure did not meet our expectations.
Furthermore, the additional controls placed in the procedure were not adequately communicated to the operating staff. The corrective actions discussed in the attached reply will address these specific issues. In addition, the event will be reviewed with the licensed operators to provide continued emphasis on proper communication.
We have no objection to this letter being made part of the public record. Please contact us if you have any questions or require additional information.
Very truly yours, James P. O'Hanlon Senior Vice President - Nuclear Attachment
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US Nuclear Regulatory Commission Region II Atlanta Federal Center 61 Forsyth Street, S.W., Suite 23T85 Atlanta, Georgia 30303 Mr. R. A. Musser NRC Senior Resident Inspector Surry Power Station
SUMMARY
OF COMMITMENTS The following commitment is made in response to the Notice of Violation in NRC Inspection Report Nos. 50.:.280/98-04 and 50-281/98-04.
- 1. Operations' management will present a discussion of this event to the licensed operators.. The discussion will focus on pre-job briefs, especially during non-routine evolutions, and convey management expectations for proper and effective communications.
Discussions with the licensed operators will be completed by August 15, 1998.
REPLY TO A NOTICE OF VIOLATION NRC I_NSPECTION CONDUCTED MARCH 22, 1998 THROUGH MAY 2, 1998 SURRY POWER STATION UNITS 1 AND 2 INSPECTION REPORT NOS. 50-280/98-04 AND 50-281/98-04 NRC COMMENT:
"During an NRC inspection conducted from Marr.h 22, 1998 through May 2, 1998, a violation of NRC requirements was identified.
In accordance with the "General Statement of Policy and Procedures for NRC Enforcement Actions," NUREG-1600, the violation is listed below:
Technical Specification 6.4.A.1 requires that detailed written procedures with appropriate check-off lists and instructions be provided for normal startup, operation, and shutdown of a unit and all systems and components involving nuclear safety of the station.
Procedure 1-GOP-1.2, 'Unit Startup, RCS Heatup from 195 to 345,' Revision 12-0T01, provided written instructions for startup and operation of Unit 1 between 195 and 345 degrees Fahrenheit.
Contrary to the above, on March 28, 1998, Procedure 1-GOP-1.2 did not contain adequate instructions to set the Unit 1 steam generator power operated relief valve controllers in that Step 5.3.3 required that the controllers be verified or adjusted to 50 psig and substep 5.3.3.c actually set the controllers to relieve at 1035 psig.
This is a Severity Level IV Violation (Supplement I)."
REPLY TO A NOTICE OF VIOLATION
. NRC INSPECTION CONDUCTED MARCH 22, 1998 THROUGH MAY 2, 1998 SURRY POWER STATION UNITS 1 AND 2 INSPECTION REPORT NOS. 50-280/98-04 AND 50-281/98-04
- 1.
Reason for the Violation, or, if Contested, the Basis for Disputing the Violation The reason for the violation was personnel error as described below.
A contributing cause was the failure to adequately communicate the additional controls added to the procedure.
During a planned Surry Unit 1 Maintenance Outage in March 1998, a through-wall leak was identified on a Residual Heat Removal (RHR) pipe. To repair the pipe, the RHR system needed to be isolated and drained, and core decay heat removed by flowing reactor coolant through the steam generator (SG) primary side and feeding/steaming on the secondary side.
To control this process, general operating procedure (GOP}, 1-GOP-1.2, Unit Startup, RCS Heatup from 195°F to 345°F, was changed to allow the Reactor Coolant System (RCS) to heatup above 200°F and stabilize between 220°F-250°F using the steam dumps.
While the unit was in this condition for an extended period of time, it was determined that as an additional control, the SG Power Operated Relief Valve (PORV) setpoints would be lowered from the normal setting of 1035 psig to 50 psig. This would ensure that if the steam dumps failed, the SG PORVs would limit the RCS temperature.
The procedure writer modified the GOP by lowering the SG PORV setpoint in a.
high level step; however, due to personnel error, he failed to change the setpoint written in the substeps of the respective high level step.
Operations personnel reviewed the draft procedure changes and noted a discrepancy between the* high level step 5.3.3 (50 psig) and the substeps 5.3.3.a/5.3.3.c (1035 psig) for the SG PORV setpoint.
Accordingly, the procedure was corrected, but the correction only made the change to substep 5.3.3.a, leaving substep 5.3.3.c still specifying 1035 psig. During final review of the change to 1-GOP-1.2, Operations' personnel assumed that all the substeps were corrected, and the procedure was approved for use on March 26, 1998.
On March 27, 1998, 1-GOP-1.2 was implemented and the Unit 1 control room operator was instructed to perform sections of the procedure that could be completed prior to RCS exceeding 200°F. He entered the section of the GOP that verified the SG PORV setpoints, read substep 5.3.3.c which incorrectly
indicated that the setpoint should be set at 1035 psig, verified the normal
.setpoint of 1035 psig, and signed the required sections of the procedure. During this period, the operator was also involved in efforts to resolve RHR flow problems caused by the failure of a flow control valve. Due to personnel error, the operator failed to read high level step 5.3.3 that instructed the operator to lower the SG PORV setpoint to 50 psig.
Reading step 5.3.3 would have provided an opportunity to identify the discrepancy between the two steps in the procedure.
During the pre-job brief, the change to the SG PORV setpoint controllers was not discussed. A contributing factor to the violation was the failure to adequately communicate to the operating staff the additional controls added to the GOP
. procedure to lower the SG PORV setpoints.
- 2.
Corrective Steps Which Have Been Taken and the Results Achieved Substep 5.3.3.c was changed to require the SG PORV setpoints to be lowered to 50 psig. Prior to transferring the RCS cooling from the RHR system to the SGs, the PORV setpoints were lowered in accordance with the changed procedure.
RHR piping repairs were completed. Since this was a one-time-only change to the GOP, no further procedure changes were required.
A station deviation report was submitted.
The procedure writer was coached on the nee.ct to maintain attention to detail.
The operator was coached on the need to read every step in the procedure prior to performing the task.
- 3.
Corrective Steps Which Will be Taken to Avoid Further Violations Although the violation was caused by personnel error on the part of the procedure writer and the operator, the failure to communicate to the operating staff the additional controls in the GOP contributed to the lack of understanding of the intent of the procedure.
To provide continued emphasis on proper communication, Operations' management will present a discussion of this event to the licen,sed operators. The discussion will focus on pre-job briefs, especially during non-routine evolutions, and convey management expectations for proper and effective communications. Discussions with the licensed operators will be
- completed by August 15, 1998.
- 4.
The Date When Full Compliance Will be Achieved Full compliance was achieved on March 28, 1998, when the procedure was.
changed to correct the discrepancy between the high level step and the substep and the SG PORV setpoints lowered to 50 psig.