ML18153A211
| ML18153A211 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 12/24/1997 |
| From: | Reyes L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Ohanlon J VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| Shared Package | |
| ML18152A209 | List: |
| References | |
| 50-281-97-09, 50-281-97-9, EA-97-474, NUDOCS 9801210303 | |
| Download: ML18153A211 (5) | |
See also: IR 05000280/1997009
Text
December 24, 1997
EA 97-474
Virginia Electric and Power Company
ATTN:
Mr. J. P. O'Hanlon
Senior Vice President-Nuclear
Innsbrook Technical Center
5000 Dominion Boulevard
Glen Allen, Virginia 23060
SUBJECT:
(NRC INTEGRATED INSPECTION REPORT 50-280/97-09, 50-281/97-09)
Dear Mr. O'Hanlon:
This refers to an inspection conducted during the period of August 24 through
October 4, 1997, at your Surry facility. The inspection included a review of
Virginia Electric and Power Company's (VEPCO) compliance with the requirements
of 10 CFR Part 50, Appendix R regarding electrical isolation and protection
and circuit breaker coordination provided for the vital electrical bus panels
in the event of a control room fire. The results of the inspection were sent
to you by letter dated October 30, 1997. * An open, predecisional enforcement
conference was conducted in the Region II office on December 4, 1997, with
members of your staff, to discuss the violations, the root causes, and your
corrective actions to preclude recurrence. A list of conference attendees and
copies of the Nuclear Regulatory Commission's (NRC) and VEPCO's 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
involves the failure to meet the requirements of 10 CFR 50, Appendix R.
Section III.G, for vital bus isolation. Specifically, inadequate means were
available for isolating 120 volt alternating current (VAC) power panels for
both Units 1 and 2 in the control room complex from their respective,
uninterruptable power supply CUPS) panels. As a result, an electrical fault
involving the vital buses could trip the breaker or fuse to the affected UPS
panel resulting in the loss of power to indications on the Appendix R remote
shutdown panel and to Appendix R communications equipment. Violation B
involves the failure to take adequate corrective action for this issue in a
timely manner.
In 1992, the licensee initially identified the failure to meet
Appendix R design requirements due to the vital bus isolation issue: however,
adequate compensatory measures were not implemented until 1997 and appropriate
modifications to achieve compliance were not completed .
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As discussed at the conference,. the root cause of Violations A and B appeared
to be the lack of understanding of Appendix R licensing and design bases with
respect to the implementation of compensatory measures.
As a result of the
failure of VEPCO's engineering staff to identify the vital bus isolation issue
as being outside the Surry Unit 1 and Unit 2 design bases. the issue received
inappropriate prioritization. and fully effective corrective actions were
delayed.
The NRC recognizes that the probability of an Appendix R fire affecting the
vital bus panels is low due to the continuously manned Control Room, the fire
protection features associated with construction of the Control Room. and the
installed fire detection and suppression components provided for the area.
However. the potential safety consequences of such a fire resulting in the
inability to isolate the vital 120 VAC bus panels are high and could result in
loss of power to the Unit 1*and Unit 2 remote shutdown panels and the loss of
emergency communications equipment.
In such an event, power to the vital
buses could not be restored until the fault conditions were identified,
corrected, and any open fuses replaced.
After initial identification of the issue in 1992, VEPCO considered the
continuously manned Control Room to be an adequate compensatory measure for
the design deficiency.
In 1993, procedures were revised to address the
isolation issue requiring disconnection of cabling in the event of a fire.
In
March and June 1997, further evaluations by VEPCO resulted in recognition of
the Appendix R compliance issues, and improved compensatory measures were
implemented by August 1997 and formally approved by the NRC by letter dated
September 25, 1997.
The NRC considers the failure to have adequate bus
isolation or adequate compensatory fire protection measures in place for an
extended period of time to be a significant regulatory concern.
In the event
of an Appendix R fire. these deficiencies could have significantly impacted
your ability to achieve and maintain hot shutdown of both Surry Unit 1 and
Unit 2.
Additionally, the NRC is concerned that flaws in your initial
engineering characterization of the regulatory and design basis significance
of this issue adversely affected subsequent decision-making and delayed timely
resolution of the issue. Therefore. Violations A and B have been categorized
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 $55,000 is considered for a Severity Level III problem.
Because your
facility has been the subject of escalated enforcement actions 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
1 On August 29, 1997, a Severity Level III problem with a base civil penalty was issued related to
maintenance rule implementation (EA 97-055).
On August 16, 1996, a Severity Level III problem was
issued related to the operability of containment hydrogen analyzers (EA 96-231).
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).
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described in Section VI.B.2 of the Enforcement Policy.
NRC determined that
credit was warranted for Identification because your staff identified the
issues requiring corrective action. With regard to the factor of Corrective
Action, at the conference your staff stated that upon recognition of the
significance of the issue, corrective actions were initiated which included:
(1) development of a Justification for Continued Operation and expansion of
compensatory measures; (2) implementation of a corrective modification on
Unit 2 in October 1997 with planned implementation for Unit 1 in October 1998;
(3) completion of a root cause investigation; (4) assessment of existing non*
standard compensatory measures and revision of administrative procedures to
address such measures; (5) performance of a review of selected design changes
to verify that Appendix R requirements remain in effect; (6) planned multi-
utility assessment of the Appendix R program; and (7) implementation of
improvements to the corrective action program including the prioritization of
Deficiency Reports by multi-disciplined teams.
Based on these facts, the NRC
concluded that credit was warranted for the factor of Corrective Action.
Therefore. to encourage prompt identification and comprehensive correction of
violations. I have been authorized, after consultation with the Director.
Office of Enforcement. not to propose a civil penalty in this case. However.
significant violations in the future could result in a civil penalty.
In addition, Violation C in the enclosed Notice has been categorized as a
Severity Level IV violation for the failure to report conditions properly that
resulted in the plant being outside of its design basis to the NRC.
At the
conference, your staff stated that a one-hour report was not required because
at the time of discovery of the condition, VEPCO had implemented compensatory
measures approved by NRC and was within its design basis. Compensatory
measures are only an interim step to either restoring operability or
justifying continued operations until final corrective actions are completed
to bring the plant back within its design basis. Although the NRC approved
the compensatory measures developed to address the out of design basis
condition. the measures themselves did not bring the plant back within its
design basis. Therefore. a one-hour report was required at the time of
discovery.
The significance of the violation was mitigated by the fact that
NRC was fully cognizant of the issue and the compensatory measures in place.
Additionally, the apparent violation regarding the failure to provide adequate
breaker coordination for vital bus branch circuits and associated vital bus
main panel breakers has been recharacterized as a deviation. Specifically,
VEPCO failed to meet commitments to replace main circuit breakers in each
vital bus panel with non-automatic molded case switches to ensure adequate
breaker coordination in the event of a design basis fire.
You are required to respond to this letter and should follow the instructions
specified in the enclosed Notices 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 .
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4
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of
this letter, its enclosures. and your response will be placed in the NRC
Public Document Room (PDR).
If you have any questions regarding this letter, contact Mr. George A.
Belisle, Chief, Special Inspection Branch at (404) 562-4621.
Sincerely,
Original Signed by L.A. Reyes
Luis A. Reyes
Regional Administrator
Docket Nos:
50-280, 50-281
License Nos:
Enclosures: 1. Notice of Violation
2.
Notice of Deviation
3.
List of Predecisional Enforcement
Conference Attendees
4.
VEPCO Presentation Materials
5.
NRC Presentation Materials
cc w/encls:
J. H. McCarthy, Manager
Nuclear Licensing & 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
Chairman
Surry County Board of Supervisors
P. 0. Box 130
Dendron, VA 23839
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
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
~----"
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Distribution w/encls 1 and 2:
PUBLIC
LJCallan, EDD
HThompson, DEDR
AThadani, DEDE
LTrocine, DEDO
LChandler, OGC
JGoldberg, OGC
RZimmerman, NRR
EJulian, SECY
-BKee l i ng , CA
_
Enforcement Coordinators
RI. RIII, RIV
Jlieberman, OE
TReis, OE
EHayden, OPA
GCaputo, 01
TMartin, AEOD
HBel 1, DIG
Jlyons, NRR
GEdison, NRR
CEvans, RI!
ABol and, RI!
GBelisle (IFS Action Required)
WMi 11 er, RI!
HWhitener, RII
KCl ark, RI!
RTrojanowski, RII
BCrowley, RI!
GHopper, RII,
LGarner, RII
RGibbs, RII
-PFill ion, RI!
RAiello, RI!
OE:EA File (BSummers) (2 letterhead)
NRC Resident Inspector
5
Surry Nuclear Power Station
5850 Hog Island Road
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Surry, VA 23883
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NRC Resident Inspector
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U.S. Nuclear Regulatory Commission\\(l~~~
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1024 Ha 1 ey Drive
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Mineral, VA 23117
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