ML18153A296
| ML18153A296 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 04/14/1998 |
| From: | Ohanlon J VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-280-97-12, 50-281-97-12, 98-068A, 98-68A, NUDOCS 9804200514 | |
| Download: ML18153A296 (7) | |
Text
Vrncr~u ELECTRIC A1'iD PowER CoMPANY RicH:\\10Ni>, VIRGINIA 23261 April 14, 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 SUPPLEMENTAL REPLY TO A NOTICE OF VIOLATION Serial No.
SPS/BCB Docket Nos.
License Nos.
- NRC INSPECTION REPORT NOS. 50-280/97-12, 50-281/97-12 98-068A R2 50-280 50-281 DPR-32 DPR-37 In a letter dated February 25, 1998 (Serial No.98-068), we responded to the Notice of Violation for Surry Units 1 and 2 associated with Inspection Report Nos. 50-280/97-12 and 50-281/97-12 dated January 26, 1998. With respect to the reason for Violation C, our response focused exclusively on the root cause that was identified through our Root Cause Evaluation program.
The attached supplemental response provides a more complete discussion of the root and contributing causes of Violation C and supercedes the previous response to Violation C in its entirety.
We have no objection to this letter being made a 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 9804200514 980414 PDR ADOCK 05000280 G
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cc:
U.S. Nuclear Regulatory Commission Region II Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, Georgia 30303 Mr. R. A. Musser NRC Senior Resident Inspector Surry Power Station
SUMMARY
OF COMMITMENTS The following commitments are being made in response to the Violation C in NRC Inspection Report Nos. 50-280/97-12 and 50-281/97-12.
- 1.
A case study of this event will be performed with appropriate Maintenance personnel. The study will examine the factors that led to the procedural compliance failure and the actions necessary to preclude the recurrence of such a failure.
- 2.
Additional training regarding turbine governor maintenance will be provided to Mechanical Maintenance supervisors.
This training will specifically address adjustment of turbine governor compensation by station Maintenance personnel.
- 3.
O-MCM-1403-01 will be revised to divide Subsection 6.12 into smaller, more logical units of work. This change will reduce the potential for confusion and miscommunication.
- 4.
The PMT matrix will also be revised to more clearly specify the PMT requirement for adjusting turbine governor compensation.
- 5.
Although this violation is not indicative of any PMT programmatic concerns, an assessment will be performed to ensure that the PMT program is effective and is implemented properly. This assessment is being performed as an enhancement and will be completed by July 31, 1998.
SUPPLEMENTAL REPLY TO A NOTICE OF VIOLATION NRC INSPECTION CONDUCTED NOVEMBER 16 - DECEMBER 27, 1997 SURRY POWER STATION UNITS 1 AND 2 INSPECTION REPORT NOS. 50-280/97-12 AND 50-281/97-12 NRC Comment-Violation C
Technical Specification 6.4.A. 7 requires that detailed written procedures with appropriate check-off lists and instructions be provided for preventive or corrective maintenance operations which would have an effect on the safety of the reactor.
Technical Specification 6.4.D requires that all procedures described in Technical Specification 6.4.A be followed.
Work Order 00310109-01 and Procedure O-MCM-1403-01, Terry Turbine Overhaul, 1-FW-T-2 and 2-FW-T-2,' Revision 8, provided written procedures for the replacement of the Unit 2 Turbine Driven Auxiliary Feedwater Pump Governor.
The Post Modification Testing Requirements of Work Order 00310109-01 specified that the Governor Post-Maintenance and Operational Checks listed in Section 6.12 of Procedure O-MCM-1403-01 be performed.
Contrary to the above, on October 20, 1997, written procedures were not followed, in that, Governor Post-Maintenance and Operational Checks listed in Section 6.12 of Procedure O-MCM-1403-01 were not performed.
This is a Severity Level IV Violation (Supplement I)."
SUPPLEMENTAL REPLY TO A NOTICE OF VIOLATION NRC INSPECTION CONDUCTED NOVEMBER 16 - DECEMBER 27, 1997 SURRY POWER STATION UNITS 1 AND 2 INSPECTION REPORT NOS. 50-280/97-12 AND 50-281/97-12 Violation C
- 1.
Reason for the Violation, or, if Contested, the Basis for Disputing the Violation The violation is correct as stated and was caused by a Maintenance supervisor's misunderstanding of responsibilities. Procedure and process weaknesses also contributed. These causes are discussed in more detail below.
Several maintenance activities were performed on the Unit. 2 turbine-driven auxiliary feedwater pump (TDAFWP) during the 1997 Unit 2 refueling outage.
These activities were implemented by several different work orders 0JV0s). The post-maintenance/post-modification testing (PMT) for five of the WOs needed to be performed while the TDAFWP was operating.
Therefore, Operations scheduled a TDAFWP run to enable the PMT for these five WOs to be performed concurrently.
The Operations Department returned three of the five WOs (310109-01, 310109-03, 367066-01) to the Maintenance Department on October 24, 1997, to obtain the required engineering review. These three WOs were subsequently misplaced and were not returned to Operations before the TDAFWP run occurred. The other two WOs (367059-01 and 364450-01) were provided to the Maintenance supervisor for PMT on October 31, 1997. Since WOs 310109-01, 310109-03, and 367066-01 had been misplaced, the Maintenance mechanic had in his possession only WOs 367059-01 and 364450-01. when the TDAFWP run was performed.
WO 367059-01, which inspected the overspeed trip mechanism and changed the turbine governor oil, was implemented partially through the performance of Mechanical Corrective Maintenance procedure O-MCM-1403-01, "Terry Turbine Overhaul, 1-FW-T-2 and 2-FW-T-2.". Subsection 6.12 of this procedure is comprised of several steps, which provide instructions for various post-maintenance and operational checks. The need to perform each of the steps is dependent upon the type of maintenance activity. The maintenance performed by WO 367059-01 required the performance of some of the steps in Subsection 6.12, but did not require the performance of Steps 6.12.2 through 6.12.10, which adjust the turbine governor compensation.
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- 1.
Reason for the Violation, or, if Contested, the Basis for Disputing the Violation (Continued)
The other WO in the mechanic's possession, 364450-01, adjusted the TDAFWP packing and, likewise, did not require adjustment of the turbine governor compensation.
The PMT requirements of WO 310109-01, which replaced the turbine governor, specified the performance of Subsection 6.12 of O-MCM-1403-01. This activity required that the turbine governor compensation be adjusted (i.e., Steps 6.12.2 through 6.12.10). However, these steps were not performed when the TDAFWP was operated for the following reasons:
- 1)
The responsible Maintenance supervisor had the misconception that the turbine governor compensation adjustment was not a Maintena_nce Department function.
This misconception resulted from the following factors:
The TDAFWP vendor had previously performed this maintenance activity.
The responsible Maintenance Supervisor and his mechanical crew had not received training regarding turbine governor compensation adjustment when this activity was incorporated into O-MCM-1403-01.
As revealed through the investigation of this violation, the same Maintenance supervisor had also failed to recognize his responsibility to perform the turbine governor compensation adjustment for the Unit 1 TDAFWP during the 1997 Unit 1 refueling outage. (Note: the Unit 1 TDAFWP turbine governor compensation was subsequently evaluated by the vendor and determined to be acceptable.)
- 2)
The Maintenance mechanic did not have WO 310109-01 when the TDAFWP was operated. Therefore, none of the WOs in the mechanic's possession required that the turbine governor compensation be adjusted.
On October 31, 1997, the Operations Maintenance Advisor (OMA) checked the status of the maintenance activities for the TDAFWP in the PMT tracking database. The database specified the PMT requirement for WO 310109-01 (i.e.,
Subsection 6.12 of O-MCM-1403-01) and indicated that the PMT was not complete.
The OMA recognized that the TDAFWP run had occurred and questioned the responsible Maintenance mechanic as to whether Subsection 6.12 had been performed (Note: The OMA did not make specific reference to WO 310109-01).
The Maintenance mechanic responded, without specific reference to a WO, that Subsection 6.12 had been performed referring only to the portions performed for the other work orders. He then authorized the OMA to update the PMT status in the database. Based on the mechanic's response, the OMA changed the database to reflect that the PMT for WO 310109-01 was complete. The TDAFWP was subsequently returned to service.
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- 1.
Reason for the Violation, or, if Contested, the Basis for Disputing the Violation (Continued)
A contributing cause was the structure of Subsection 6.12 of O-MCM-1403-01, which performs multiple, activity-dependent functions.
This procedural weakness led to the miscommunications between the OMA and the responsible Maintenance mechanic, and resulted in the TDAFWP being returned to service*
before all of the PMT requirements were satisfied. The confusion regarding the requirements of Subsection 6.12 and the resulting error in the PMT tracking database also impeded the Maintenance supervisor from identifying the missed PMT requirements when performing the final review of WO 310109-01.
- 2.
Corrective Steps Which Have Been Taken and the Results Achieved A Deviation Report was submitted to document the deviating condition and to ensure appropriate corrective actions were implemented.
The turbine governor was replaced on December 6, 1997 and was satisfactorily tested and returned to service.
The personnel involved in this violation were counseled.
A Category I Root Cause Evaluation (RCE) was performed to determine the cause of this violation and to recommend corrective actions. The actions to be taken as a result of the RCE are addressed in the following section.
- 3.
Corrective Steps Which Will be Taken to Avoid Further Violations A case study of this event will be performed with appropriate Maintenance personnel. The study will examine the factors that led to the procedural compliance failure and the actions necessary to preclude the recurrence of such a failure.
Additional training regarding turbine governor maintenance will be provided to Mechanical Maintenance supervisors.
This training will specifically address adjustment of turbine governor compensation by station Maintenance personnel.
O-MCM-1403-01 will be revised to divide Subsection 6.12 into smaller, more logical units of work. This change will reduce the potential for confusion and miscommunication. The PMT matrix will also be revised to more clearly specify the PMT requirement fat adjusting turbine governor compensation.
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- 3.
Corrective Steps Which Will be Taken* to Avoid Further Violations (Continued)
The corrective actions noted above are sufficient to preclude recurrence of the violation.
Although this violation is not indicative of a programmatic concern with PMT, an assessment will be performed to ensure that the PMT program continues to be effective and properly implemented. This assessment is being performed as an enhancement and will be completed by July 31, 1998.
- 4.
The Date When Full Compliance Will be Achieved Full compliance will be achieved by June 1, 1998, when the corrective actions described in Section 3 are completed.