ML18153A044
| ML18153A044 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 08/16/1996 |
| From: | Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Ohanlon J VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| Shared Package | |
| ML18153A045 | List: |
| References | |
| EA-96-231, NUDOCS 9608270322 | |
| Download: ML18153A044 (6) | |
See also: IR 05000280/1996008
Text
- '
August 16, 1996
EA 96-231
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
SUBJ":CT:
(NRC Special Inspection Report Nos. 50-280 and 50-281/96-08
Dear Mr. O'Hanlon:
This refers to the inspection conducted on June 17 through July 1, 1996, at
the Surry facility.
The inspection included a review of the circumstances
surrounding the inoperability of the Unit 1 and Unit 2 containment hydrogen
analyzers.
On June 10, 1996, you formally notified the NRC of this condition
in Licensee Event Report No. 50-280 and 50-281/96-004-00.
The results of our
inspection were sent to you by letter dated July 11, 1996.
A predecisional
enforcement conference was conducted in the Region II office on August 7,
1996, to discuss the apparent violation, the root cause, and your corrective
actions to preclude recurrence.
This conference was open for public
observation in accordance with the Commission's trial program for conducting
conferences as discussed in the Federal Register, 57 FR 30762, July 10, 1992,
and 59 FR 36796, July 19, 1994.
A list of conference attendees, NRC slides,
and a copy of Virginia Electric and Power Company's (VEPCO) presentation
materials are enclosed.
Based on the information developed during the inspection and the information
that was provided during the conference, the NRC has determined that
violations of NRC requirements occurred.
The violations are cited in the
enclosed Notice of Violation (Notice), and the circumstances surrounding them
are described in detail in the subject inspection report.
Violation A
involved the inoperability of the Unit 1 and Unit 2 containment hydrogen
analyzers for a period greater than that allowed by Technical Specifications
(TSs).
The inoperable condition existed for at least five and a half years
(from October 1990 through May 1996), and may have existed as long ago as
October 1986 and November 1985, for Unit 1 and 2, respectively.
Although the
containment hydrogen analyzer hardware was capable of performing its intended
function, the system was not capable of performing its design function given
the as-left, standby system configuration (function selector switch in the
ZERO position), the in-place procedural requirements for calibration and
system operation, and the lack of operator awareness of system operation.
Violation B involved the failure to establish adequate procedures to assure
the operability of the containment hydrogen analyzers.
Specifically,
Instrumentation and Control (I&C) Procedures and Emergency Operating
Procedures (EOPs) lacked the continuity necessary to assure operation of the
9608270322 960816
ADOCK 05000280
G
2
system during an emergency.
Since October 1990, I&C Procedures have required
that the function selector switches (FSS) at the remote and local containment
hydrogen analyzer panels be placed in the ZERO position.
For the hydrogen
analyzers to operate properly, the FSS position on either the remote or local
hydrogen analyzer panel must be in SAMPLE, and the post-accident monitoring
(PAM) main power switch in the Control Room must be in ANALYZE.
Although the
system does not automatically start and could be operated manually with FSSs
in an initial position of ZERO or SAMPLE, the EOPs did not address the need to
verify or switch the FSS position from ZERO to SAMPLE in order to initiate
containment sampling.
Only the position of the PAM main power switch was
described in the EOPs.
Further, operators were unaware of the FSS required
position.
In their as found configuration in May 1996, the hydrogen analyzers
would not have indicated actual hydrogen atmospheric concentration when
aligned to containment.
Although the inoperability of the containment hydrogen analyzers did not have
a significant consequence to safety because they were not called upon to
operate during this period, the violations are nonetheless of significant
regulatory concern.
Notwithstanding the fact that the equipment was
technically capable of performing its function, recognition of the FSS
mispositioning by operations, I&C, or other support personnel would have been
required during an emergency and the switch repositioned for proper system
operation.
Although other means would have been available to determine
hydrogen concentration following an accident, the degree to which operators
would have relied upon the erroneous information from the hydrogen analyzers
and for how long, to make decisions regarding start-up of the hydrogen
recombiners to reduce hydrogen levels in containment, is uncertain.
In
addition, the NRC is concerned about the length of time this condition went
undetected and the procedural revision and review processes which failed to
uncover this condition.
Therefore, these violations are classified in the
aggregate in accordance with the "General Statement of Policy and Procedures
for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600, as a Severity
Level III problem.
In accordance with the Enforcement Policy, a base civil penalty in the amount
of $50,000 is considered for a Severity Level III problem.
Because your
facility has been the subject of an escalated enforcement action within the
last two years, 1 the NRC considered whether credit was warranted for
Identification and Corrective Action in accordance with the civil penalty
assessment process in Section VI.B.2 of the Enforcement Policy.
In this case,
credit is warranted for Identification in that you identified the violation.
The attentiveness and questioning attitude of the visiting North Anna operator
who initially identified the mispositioned FSSs is particularly noteworthy.
With regard to Corrective Action, your immediate actions included verification
of the proper configuration and placement of the FSSs in the SAMPLE position.
At the conference, you stated that additional corrective actions included:
1 On November 22, 1995, a Severity Level III problem was issued related
to multiple violations associated with the September 1995 unplanned reduction
in reactor vessel water level (EA 95-223).
3
(1) revision of the calibration procedures to require that the FSSs be left in
the SAMPLE position; (2) addition of the containment hydrogen analyzer FSS
position verification to the operator logs; (3) comparison of Surry and North
Anna operator logs to identify inconsistencies; (4) review of the TS and
Emergency and Abnormal Procedures to determine if other procedural interface
inadequacies existed on other safety related equipment; and (5) review of the
procedure change process.
At the conference, you indicated that no similar
issues were identified as a result of these efforts.
Based on the above, the
NRC determined that your corrective actions were prompt and comprehensive, and
credit was warranted for this factor.
Therefore, to encourage prompt identification and comprehensive correction of
violations, I have been authorized, after consultation with the Office of
Enforcement, not to propose a civil penalty in this case.
However,
significant violations in the future could result in a civil penalty.
At the predecisional enforcement conference you offered three clarifications
related to the content of NRC Inspection Report Nos. 50-280, 281/96-08.
These
comments were:
(1) At various locations in the Inspection Report it is
indicated that the mispositioned FSSs resulted in a loss of safety function.
You stated that although the containment hydrogen analyzers were declared
inoperable, the overall safety function was not lost; (2)
Page 2, the 5th
Paragraph of the report states "Return to service in CAL-GW-175 placed the
FSSs in the SAMPLE position which is the correct position."
You stated that
the sentence should state" ... which is one of two correct positions;" and (3)
Page 3, the 3rd Paragraph of the report states that NRC concluded that an
additional root cause of this event was a lack of knowledge by the I&C
technicians.
You clarified that this was not a licensee position, and that
I&C personnel fully understood the system, they just were not knowledgeable of
the procedural interface deficiency which existed with the EOPs.
Operations
personnel, however, were unfamiliar with the requirements for FSS positions.
We have evaluated your comments and acknowledge that the total safety function
for analyzing post accident hydrogen concentration in containment was not lost
as a result of the inoperability of the hydrogen analyzers.
Specifically, the
hydrogen analyzer hardware was functional, and redundant containment sampling
means were available.
However, the certainty with which these redundant
methods would have been employed is unknown.
In addition, we have determined
that your position with respect to Items (2) and (3) above are not valid.
Specifically, the appropriate system alignment to permit operation of the
containment hydrogen analyzers from the Control Room Annex or the Auxiliary
Building is with the FSSs in the SAMPLE position.
In addition, I&C personnel
were not knowledgeable of the relationship between the as-left configuration
of the containment hydrogen analyzers and the EOPs.
We do agree that
operations personnel also exhibited a lack of knowledge with respect to the
required position of the FSS.
Lack of operator knowledge was not specifically
addressed as a root cause in the Inspection Report; however, no addendum to
the Inspection Report is required, in that, the report reflects NRC
understanding at the time the report was issued.
This letter and enforcement
action corrects NRC's understanding with respect to the acceptable positions
of the FSSs and the root causes of the violations.
=-==--=--=-
---
- --
4
You are required to respond to this letter and should follow the instructions
specified in the enclosed Notice when preparing your response.
The NRC will
use your response, in part, to determine whether further enforcement action is
necessary to ensure compliance with regulatory requirements.
In accordance with 10 CFR 2.790 of the NRC's Rules of Practice," a copy of
this letter, it enclosures, and your response will be placed in the NRC Public
Document Room (PDR).
Docket Nos. 50-280 and 50-281
License Nos. DPR-32 and DPR-37
Enclosures:
1.
cc w/encls:
2.
3.
4.
Conference Attendees (not to be published in NUREG-0940)
NRC Slides (not to be published in NUREG-0940)
VEPCO Presentation Materials (not to be published in
M. L. Bowling, Manager
Nuclear Licensing and Operations Support
Virginia Electric & Power Company
Innsbrook Technical Center
5000 Dominion Boulevard
Glen Allen, VA
23060
David A. Christian, Manager
Surry Power Station
Virginia Electric & Power Company
5570 Hog Island Road
Surry, VA
23883
W. R. Matthews, Manager
North Anna Power Station
P. 0. Box 402
Mineral, VA
23117
Ray D. Peace, Chairman
Surry County Board of Supervisors
P. 0. Box 130
Dendron, VA
23839
cc w/encls:
(Cont'd on Page 5)
cc w/encls (Cont'd):
Dr. W. T. Lough
Virginia State Corporation Commission
Division of Energy Regulation
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
P. 0. Box 2448
Richmond, VA
23218
Attorney General
Supreme Court Building
900 East Main Street
Richmond, VA
23219
5
Distribution w/encls:
JTaylor, EDO
JMil hoan, DEDR
SEbneter, RII
LChandler, OGC
JGoldberg, OGC
RZimmerman, NRR
EJulian, SECY
BKeeling, CA
Enforcement Coordinators
RI, RI II, RIV
Jlieberman, OE
OE:EA File (BSummers) (2 letterhead)
MSatorius, OE
EHayden, OPA
GCaputo, OI
EJordan, AEOD
HBell, OIG
CEvans, RII
BUryc, RII
KClark, RII
RTrojanowski, RII
EMerschoff, RII
GBelisle, RII (IFS Action)
PHopkins, RII
LGarner, RII
GEdison, NRR
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
1024 Haley Drive
Mineral, VA
23117
NA
COPY?
OFFICIAL RECORD
6