ML18153A353
| ML18153A353 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 01/14/1998 |
| From: | Ohanlon J VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-280-97-10, 50-281-97-10, 97-736, NUDOCS 9801220136 | |
| Download: ML18153A353 (5) | |
Text
VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 January 14, 1998 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D. C. 20555 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNIT 2 REPLY TO A NOTICE OF VIOLATION Serial No.97-736 SPS/BCB/GDM R1 Docket No.
50-281 License No.
DPR-37 NRC INSPECTION REPORT NOS. 50-280/97-10, 50-281/97-10 We have reviewed Inspection Report Nos. 50-280/97-10 and 50-281/97-10 dated December 15, 1997, and the enclosed Notice of Violation (NOV) for Surry Unit 2. As described in our attached reply to the NOV, we have taken actions to apprise our technical staff of the lessons learned from this violation. In addition, we are evaluating procedural enhancements to avoid the recurrence of similar violations.
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,
~VBJJ~
James P. O'Hanlon Senior Vice President - Nuclear Attachment 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 Res!dent Inspector Surry Power Station 9801220136 980114 PDR ADOCK 05000280 G
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4
SUMMARY
OF COMMITMENTS The following commitment is being made in response to the Notice of Violation in NRC Inspection Report Nos. 50-280/97-10 and 50-281/97-10.
As an enhancement and additional barrier, applicable procedures will be reviewed and revised, as appropriate, to ensure that adequate instructions are provided for the verification of any limiting conditions or special requirements assumed by a Safety Evaluation. These actions will be completed by June 30, 1998.
REPLY TO A NOTICE OF VIOLATION NRC INSPECTION CONDUCTED OCTOBER 5-NOVEMBER 15, 1997 SURRY POWER STATION UNITS 1 AND 2 INSPECTION REPORT NOS. 50-280/97-10 AND 50-281/97-10 NRC COMMENT:
"During an NRC inspection conducted from October 5 through November 15, 1997, 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.7 requires detailed written procedures with appropriate instructions shall be provided for preventive or corrective maintenance operations which would have an effect on the safety of the reactor.
Work Order 00375660-02, Procedure O-ECM-1801-01, 'Westinghouse Type BF or BFD Relay Replacement' Revision 10, and Temporary Modification (TM)
S2-97-8 provided written procedures for the replacement of Relay 1812 in the Unit 2 'B' Consequence Limiting Safeguards (CLS) logic train.
Safety Evaluation 97-138 for TM S2-97-8 stated that train 'B' of Safety Injection would be defeated during the Relay 1812 replacement and that a formal tracking mechanism be used to ensure that this condition was met.
Contrary to the above, on October 11, 1997, written procedures with appropriate instructions were not provided for maintenance operations on the Unit 2 'B' CLS logic train. Work Order 00375660-02, O-ECM-1801-01, and TM S2-97-8 did not require the train 'B' of Safety Injection be defeated nor did they require a formal tracking system be used to ensure this condition was met as stated in Safety Evaluation 97-138 for the replacement of relay 1 B 12.
This is a Severity Level IV Violation (Supplement I)."
REPLY TO A NOTICE OF VIOLATION NRC INSPECTION CONDUCTED OCTOBER 5 - NOVEMBER 15, 1997 SURRY POWER STATION UNITS 1 AND 2 INSPECTION REPORT NOS. 50-280/97-10 AND 50-281/97-10
- 1.
Reason for the Violation, or, if Contested, the Basis for Disputing the Violation The violation is correct as stated and was caused by personnel error in that the assumed limiting conditions in Safety Evaluation 97-138 for the replacement of relay 2-CLS-RL Y-1 B 12 were not properly tracked or incorporated into the appropriate implementing documents.
The potential for the initiation of a Hi.. CLS signal during the replacement of 2-CLS-RL Y-1 B 12 had been properly recognized and addressed in Safety Evaluation 97-138. The Safety Evaluation also recognized that a Hi-CLS signal would initiate an SI system actuation, but noted that the Unit 2 "B" train of the SI system would be defeated by a procedurally controlled temporary modification (TM S2-97-8), which was associated with an unrelated maintenance activity.
The use of the TM to prevent a potential SI system actuation was valid.
However, the Safety Evaluation preparer failed to utilize an adequate tracking mechanism, as required by Station Administrative Procedure VPAP-3001, "Safety Evaluations," to ensure that the TM would be in place during the relay replacement. This failure to specify tracking of the TM during relay replacement was also not detected by those personnel who reviewed and approved the Safety Evaluation. As a result, the personnel involved with the replacement of 2-CLS-RL Y-1 B 12 were not aware that the TM had been removed when the relay replacement began. The absence of the TM allowed the SI system to actuate when a spurious Hi-CLS signal was initiated during the relay replacement.
- 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 lessons learned from this event were provided to Safety Evaluation preparers/reviewers. The cause of this violation was also discussed in Technical Staff Continuing training.
- 3.
Corrective Steps Which Will be Taken to Avoid Further Violations The corrective actions noted in Section 2 above are sufficient to preclude recurrence of the violation. However, as an enhancement and additional barrier, applicable procedures will be reviewed and revised, as appropriate, to ensure that adequate instructions are provided for the verification of any limiting conditions or special requirements assumed by a Safety Evaluation.
These actions will be completed by June 30, 1998.
- 4.
The Date When Full Compliance Will be Achieved Full compliance was achieved upon completion of the training noted in Section 2 above.