ML18153A293
| ML18153A293 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 04/06/1998 |
| From: | Ohanlon J VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-280-98-01, 50-280-98-1, 50-281-98-01, 50-281-98-1, 98-160, NUDOCS 9804130434 | |
| Download: ML18153A293 (6) | |
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VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 April 6, 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. 50-280/98-01 AND 50-281/98-01 98-160 R2 50-289 50-281 DPR-32 DPR-37 We have reviewed Inspection Report Nos. 50-280/98-01 and 50-281/98-01 dated March 5, 1998, and the enclosed Notice of Violation (NOV) for Surry Units 1 and 2. We share your concern regarding our failure to communicate vital information concerning the significance of degradation of the Number 3 Emergency Diesel Generator (EOG) auxiliary oil pump motor bearing to the appropriate personnel.
- Inadequate communication led to inappropriate prioritization of maintenance, which eventually resulted in the failure of the pump motor.
The corrective actions discussed in the response will strengthen the communication process as well as address the specific violation.
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 9804130434 980406 PDR ADOCK 05000280 G
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cc:
. 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 commitments are made in response to the Notice of Violation in NRC Inspection Report Nos. 50-280/98-01 and 50-281/98-01.
- 1. To ensure consistency, criteria will be established and incorporated into procedures specifying when a DR will be submitted by PAG personnel on equipment determined to be degraded. *
- 2. The Superintendent of Maintenance will review the procedural requirements for dispositioning actions for degraded trends in equipment performance with PAG personnel.
The review will emphasize the need for increased monitoring on equipment with increased vibrations and the importance of communicating degraded trends to the responsible Maintenance Supervisor.
- 3. Station equipment currently identified as degraded, will be reviewed by PAG personnel and Component Engineering to determine the* need to increase the monitoring and to re-evaluate the assigned work priority.
REPLY TO A NOTICE OF VIOLATION NRC INSPECTION CONDUCTED DECEMBER 28, 1997 THROUGH FEBRUARY 7, 1998 SURRY POWER STATION UNITS 1 AND 2 INSPECTION REPORT NOS. 50-280/98-01 AND 50-281/98-01 NRC COMMENT:
"During an NRC inspection conducted from December 28, 1997, through February 7, 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:
10 CFR 50, Appendix B, Criterion XVI, requires, in part, that measures be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.
Contrary to the above, from January 14 to January 29, 1998, the licensee failed to establish measures to assure that conditions adverse to quality were promptly corrected. Specifically, measures were not established to promptly correct a deficient Number 3 Emergency Diesel Generator auxiliary oil pump motor bearing condition when vibration data indicated that the motor bearing was degrading. The vibration data was not communicated to cognizant personnel for evaluation. The motor bearing failure on January 29 rendered the Number 3 Emergency Diesel Generator inoperable.
This is a Severity Level IV violation (Supplement I)."
REPLY TO A NOTICE OF VIOLATION NRC INSPECTION CONDUCTED DECEMBER 28, 1997 THROUGH FEBRUARY 7, 1998 SURRY POWER STATION UNITS 1 AND 2 INSPECTION REPORT NOS. 50-280/98-01 AND 50-281/98-01
- 1.
Reason for the Violation, or, if Contested, the Basis for Disputing the Violation The reason for the violation was the failure to communicate the significance of the degrading trend in the Number 3 Emergency Diesel Generator (EOG) auxiliary oil pump motor bearing vibration data to the appropriate personnel.
Information on the significance of a step increase in associated vibration data was not provided for use in determining the priority of the EOG auxiliary oil pump motor repair work.
The EOG auxiliary oil pumps run continuously, supplying oil to the EOG turbocharger bearings. Failure of the pump renders the EOG inoperable. These pumps are replaced every 18 months during the scheduled maintenance cycle.
The Number 3 EOG auxiliary oil pump and motor were scheduled for replacement in August 1998.
Modifications were made to the Number 3 EOG auxiliary oil pump motor in February 1997 to improve the ability of the pump and motor to maintain proper alignment and acceptable vibration levels.
On February 25, 1997, Predictive Analysis Group (PAG) personnel obtained vibration data on the pump and motor and noted that vibrations had increased from the previous readings. A work request to realign the pump and the motor was submitted noting the increased vibrations.
After discussions with the system engineer and review of the vibration data, the work request was given a priority 3, indicating that work could be done in the future. The basis for this decision was the assumption that a new baseline vibration level had been established with the motor modifications and that monthly monitoring would continue.
Monitoring of the EOG auxiliary oil pump and motor continued to indicate elevated but steady vibration levels. On December 23, 1997, however, vibration data indicated another step increase, with many of the data points exceeding the lower alarm limit set by PAG.
On January 14, 1998, monitoring data again indicated elevated vibration levels.
In addition, PAG personnel noted an increase in the number of frequency peaks in the spectral plot of the vibration data. Another work request was submitted on January 14, 1998, indicating that the motor bearings had degraded and vibration levels were higher than normal.
Verbal communications that took place when the work request was submitted did not convey the sense of urgency or the significance of the degradation.
. Although required by the Maintenance administrative procedure, no change in the monitoring intervals for the Number 3 EOG auxiliary oil pump were implemented and no notification of the degraded condition was made to the responsible Maintenance discipline supervisor.
Upon receipt, the Operation Maintenance Advisor (OMA) reviewed the EOG auxiliary oil pump work request to assign the appropriate work priority, in accordance with Station Administrative Procedure, VPAP 2002, Work Request and Work Order Tasks. No verbal information on the severity of the degradation was transmitted to the OMA to elevate the work priority assignment. Without information on the step increase in the vibration data, the work request was determined not to be critical and was assigned a priority 3.
On January 16, 1998, following delivery of the work request to Station Planning, an electrical planner walked the system down. Pump and motor vibrations and motor bearing noise at that time did not appear to be degraded
- sufficiently to warrant questioning the priority assigned to the work request. History on these motors and pumps indicate that despite elevated vibrations, the pumps continue to operate throughout the 18 month maintenance cycle.
Without intervening maintenance, the pump motor bearing failed on January 29, 1998, rendering Number 3 EOG inoperable.
- 2.
Corrective Steps Which Have Been Taken and the Results Achieved The Number 3 EOG auxiliary oil pump motor was replaced and the diesel was returned to service on January 29, 1998.
To ensure that information on degrading trend data obtained by PAG is communicated to the appropriate personnel, PAG personnel were instructed by the Superintendent of Maintenance to submit DRs when adverse trends are identified on equipment.
The DR process will ensure such conditions are communicated to the appropriate personnel and that corrective actions are promptly implemented.
Station management reinforced expectations with PAG personnel, Maintenance and Operations management on the importance of recognizing developing equipment problems, initiating prompt corrective actions, and following through with those corrective actions to ensure that equipment problems have been properly communicated and actions properly dispositioned.
A Station Deviation Report (DR) was submitted to determine why previous corrective actions had not resolved the Number 3 EOG auxiliary oil pump vibrati~n problems. A Root Cause Evaluation (RCE) determined that while the previous corrective actions reduced the motor weight on the vertical mounts and
. made alignment easier, the pump was still configured in a vertical mount and connected to stationary piping. The RCE recommended that the suction and discharge lines from the pump be replaced with flexible metal hose to reduce loading on each end of the pump due to thermal loading. In addition, to assure alignment, the RCE also recommended that both the motor and the pump be mounted horizontally on a skid. A Design Change Package (DCP) has been developed and issued to implement these changes.
The vibration monitoring interval for the EOG auxiliary oil pumps has been increased until the suction and discharge lines are replaced on the EOG auxiliary oil pumps.
- 3.
Corrective Steps Which Will be Taken to Avoid Further Violations Evaluation of data taken by the PAG group to d~termine equipment degradation requires a review of the data trend, prior experience, industry experience, vendor recommendations, etc. To ensure consistency, criteria will be established and incorporated into procedures specifying when a DR will be submitted by PAG personnel on equipment determined to be degraded.
The Superintendent of Maintenance will review the procedural requirements for dispositioning degraded trends in equipment performance with PAG personnel.
The review will emphasize the need for more frequent monitoring on equipment with increased vibrations and the importance of communicating degraded trends to the responsible Maintenance Supervisor.
Station equipment currently identified as degraded will be reviewed by PAG personnel and Component Engineering to determine the need to increase the monitoring and to re-evaluate the assigned work priority.
. 4.
The Date When Full Compliance Will be Achieved Full compliance will be achieved on May 15, 1998, when criteria are established and incorporated into procedures that specify when a DR will be submitted by PAG personnel on equipment determined to be degraded.