ML18153A404
| ML18153A404 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 05/06/1997 |
| From: | Ohanlon J VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-280-97-02, 50-280-97-2, 50-281-97-02, 50-281-97-2, 97-219, NUDOCS 9705150183 | |
| Download: ML18153A404 (13) | |
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VIRGINIA ELECTRIC AND PowER CoMPA,:y RICHMOND, VIRGINIA 23261 May 6, 1997 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D. C. 20555 Serial No.97-219 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 REPLY TO A NOTICE OF VIOLATION SPS:BAGNLA/GDM R2 Docket Nos.
50~280 50-281 License Nos.
DPR-32 DPR-37 NRC INSPECTION REPORT NOS. 50-280/97-02 AND 50-281/97-02 We *have reviewed Inspection Report Nos. 50-280/97-02 and 50-281/97-02 dated April 7, 1997, and the enclosed Notice of Violation (NOV) for Surry Units 1 and 2. We share your concern regarding the cited violations and are implementing corrective actions to appropriately address the identified weaknesses.
Our response to Violation A describes the actions we have taken to ensure that engineering transmittals are reviewed for potential impact on station procedures, and our response to Violation B discusses the actions we have taken to strengthen our verification of accuracy process for outgoing correspondence.
Regarding the multiple examples of failure to adhere to radiation protection (RP) procedures identified in Violation C, we have taken corrective actions with particular emphasis on the first two examples since they involved supervision. The third example identified individuals who entered areas of the station without the required Digital Alarming Dosimeter as required by the Radiation Work Permit (RWP). Even though these entries resulted in no dose consequence and individuals, in* all cases, wore their permanently assigned thermo-luminescent dosimeter, corrective actions have been implemented to further sensitize workers to the need for self-checking and mandatory f 1.
compliance with RWPs.
The commitments made in this letter are provided below. We have no objection to this
/;'
letter being made part of the public record. Please contact us if you have any questions j { U{
or rec:;:.iire additional information.
Very truly yours,
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,James P. O'Hanlon SeniorVice President - Nuclear 150009 970~150183 970506 PDR ADOCK 05000280 G
PDR I If I/II II/II Ill/I II/II II/II 111111111 /llf -
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- e Attachment 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 COMMlTMENTS The following commitment is made in response to Violation C included in the Notice of Violation in NRC Inspection Report Nos. 50-280/97-02 and 50-281/97-02.
- 1. An evaluation will be completed by June 30, 1997, to ensure that the controls are adequate to avoid recurrence and to recommend any further modifications to RCA in-processing.
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REPLY TO A NOTICE OF VIOLATION NRC INSPECTION CONDUCTED JANUARY 26. 1997 THROUGH MARCH 8. 1997 SURRY POWER STATION UNITS 1 AND 2 INSPECTION REPORT NOS. 50-280/97-02 AND 50-281/97-02 NRC COMMENT:
"During an NRC inspection conducted from January 26, 1997 through March 8, 1997, violations of NRC requirements were identified.
In accordanc£ with the "General Statement of Policy and Procedures for NRC Enforcement Actions," NUREG-1600, the violations are listed below:
A.
10 CFR 50, Appendix B, Criterion V and the iicensee s accepted Quality Assurance Program, Updated Final Safety Analysis Report, Section 17.2.5, Instructions, Procedures and Drawings, collectively _require that activities affecting quality shall be prescribed by documented instructions or procedures of a type appropriate to the circumstances.
Contrary to the above, the licensee failed to prescribe activities affecting quality in
- documented instructions or procedures as evidenced by the following examples:
- 1.
On October 8, 1996, a Maintenance Engineering Transmittal Record was issued to specify the limit for backward rotation of safety-related ventilation fans.
However, this limitation was not included in the fan Operating Procedures.
- 2.
During 1988, Maintenance Engineering determined that Duxseal was not suitable for use in safety-related ventilation systems.
This information was verbally transmitted, but never documented, and as a result, on February 20, 1997, Duxseal was installed on the Auxiliary Ventilation Filter Train.
This is a Severity Level IV violation (Supplement I).
B.
10 CFR 50.9(a) requires, in part, that information provided to the Commission by a licensee shall be complete and accurate in all material respects.
Contrary to the above, on February 14, 1997, Licensee Event Report 50-280, 281/97-002 was submitted to the Commission and was not accurate in all respects. Specifically, the reverse rotation limitation of the 58B fan had not been included in the February 7, 1997, Shift Orders as stated in the Additional Corrective Action Section (5.0) of the Licensee Event Report.
This is a Severity Level IV violation (Supplement I).
C.
Technical Spe~:fication (TS) 6.4.B requires that procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR 20 and shall be adhered to for all operations involving personnel radiation exposure.
Health Physics Procedure HP-1081.2, Radiation Work Permits: RWP Briefing and Controlling Work, required, in part, that if individual worker Digital Alarming Dosimeter (DAD) dose and dose rate alarm setpoints are to be used, then the dPsired alarm settings are to be recorded on the RWP Briefing Attendance Roster and that the alarm settings are to be entered into the Personnel Radiation Exposure Management System (PREMS).
RWP 96-1-0012 for Unit 2 containment entries required, in part, that DADs be set to alarm when the accumulated dose reached 100 mrem, that all members of the entry team were to evacuate upon receiving any DAD alarm, and that a special RWP_ 1;Vc1.s _to be written for any ta$kJ~at an individual's dose is expected to exceed 1'6o'rrirem per entry.
Virginia Power Administrative Procedure VPAP-2101, Radiation Protection Program, Revision 11, stipulates that a Radiation Work Permit (R.WP) is required for entry into or work in a Radiological Controlled Area (RCA), that workers shall wear dosimetry required by their RWP, and that workers shall comply with the RWP requirements, instructions, and precautions.
Contrary to the above, TS 6.4.B required personnel radiation protection procedures were not adhered to for all operations including personnel radiation exposure as evidenced by the following examples:
- 1.
On August 17, 1996, the requirements of HP-1081.2 were not followed, in that, the licensee inappropriately used the "Revised DAD Alarm Setpoint" column of the RWP Briefing Attendance Roster to reflect that the DAD alarm setpoint had changed to 250 nirem/hour when in fact it had not.
- 2.
On August 17, 1996, the requirements for RWP 96-1-0012 were not followed, in that, the licensee failed to write a special RWP for the expected doses in excess of 100 rnrem, and workers tailed to exit containment when their accumulated dose exceeded 100 mrem and their DADs alarmed.
- 3.
The requirements of VPAP-2101 were not followed, in that, on September 6, 1996, September 13, 1996, October 4, 1996, December 23, 1996, January 10, 1997, and February 3, 1997, individuals entered the RCA without wearing DADs as required by their RWP.
This is a Severity Level IV violation (Supplement I)."
REPLY TO A NOTICE OF VIOLATION NRC INSPECTION CONDUCTED JANUARY 26, 1997 THROUGH MARCH 8, 1997 SURRY POWER STATION UNITS 1 AND 2 INSPECTION REPORT NOS. 50-280/97-02 AND 50-281/97-02 Violation A
- 1.
Reason for the Violation, or, if Contested, the Basis for Disputing the Violation The violation is correct as stated for both examples, except for the qualification discussed below regarding the use of Duxseal sealant.
Backward Rotation of Safety Related Fans The _ca11s~""'":9.f this event was the lack of guidance for revie.~!ng'.£9:glnt~nance engineering transmittal records for their potential effect on operating procedures.
Maintenance Engineering Information Transmittal Records were used to document required actions for degraded conditions.
On October 31, 1996, maintenance engineering issued an Information Transmittal Record concerning backward rotation of safety related ventilation tans. The transmittal stated that, as a good practice, the fan motors should not be allowed to exceed 120 RPM backward rotation. It was not recognized by operations personnel that this good practice would h~ve an impact on the operating procedures.
Appropriate guidance was not in place at that time to ensure that the technical information contained in the Maintenance Engineering Information Transmittal Record was reviewed for incorporation into the operati:ig procedures for the tan.
Improper Use of Duxseal The cause of the second event was personnel error. Maintenance personnel used a sealant material (Duxseal) that was not authorized for use by the work order or the procedure and was not approved by engineering.
The consequences of using Duxseal in the Auxiliary Ventilation Filter Train were not understood by the personnel performing the maintenance on February 19, 1997.
However,. when returning the Auxiliary Ventilation Filter Train to service, operations recognized the need to contact the ventilation system engineer concerning the appropriateness of using Duxseal.
Engineering instructed maintenance personnel to remove the Duxseal, and the Duxseal was removed from the Auxiliary Ventilation Filter Train before it was returned to service.
Work orders were reviewed back to 1985, and there is no history of the use of Duxseal on the Auxiliary Ventilation Filter Train.
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- 2.
- 3.
Corrective Steps Which Have Been Taken and the Results Achieved Backward Rotation of Safety Related Fans Engineering Transmittal S-97-0103 was developed on March 20, 1997 to specify reverse rotation limits and conditions of applicability. Operations Periodic Test, O-OPT-VS-002, Auxiliary Ventilation Filter Train
- Test, was revised on March 24, 1997.
The revision provides explicit criteria for determination of auxiliary ventilation filter ex~::-:ust fan operability if counter clockwise (reverse) rotation is noted. The revision also provides appropriate actions to be taken if reverse rotation limits are exceeded.
The Maintenance Engineers were retitled Component Engineers and were transferred from Maintenance to the Engineering organization on November 1, 1996. Maintenance Engineering Information Transmittal Records are no longer written.
Engineering Transmittals arE:1 developed to d...,..,ument repair/resto_r_ation instructions aod to tr~nsmit technical informatioxi.
They are_.,,c*,
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lifetime design documents. Engirieeririg Transmittals are written in accordance with a detailed Engineering standard.
Management issued direction that Engineering Transmittals will be reviewed to ensure that procedural impacts are assessed. Those Engineering Transmittals assessed as potentially affecting procedures are scoped, and appropriate procedure changes are incorporated pursuant to the procedure revision process.
Improper Use of Duxseal The Duxseal was removed from the Auxiliary Ventilation Filter Train before it was returned to service.
The maintenance supervisor involved in this event was counseled as to the use of a sealant material that was not authorized for use by the work order..:.
procedure and was not approved by engineering.
In addition, mechanical maintenance supervisors have been cautioned concerning the use of Duxseal and other consumables where the application is not routine.
Corrective Steps Which Will be Taken to Avoid Further Violations The corrective actions documented in Section 2 are considered adequate to avoid recurrence. No further actions are required.
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- 4.
The Date When Full Compliance Will be Achieved Full compliance was achieved regarding the documentation of limitations on backward fan rotation when Operations Periodic Test, O-OPT-VS-002, Auxiliary Ventilation Filter Train Test, was revised on March 24, 1997. Full compliance was achieved regarding the inappropriate use of Duxseal when the Duxseal was removed from the Auxiliary Ventilation Filter Train on February 20, 1997.
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Violation B
- 1.
Reason for the Violation, or, if Contested, the Basis for Disputing the Violation The violation is correct as stated.
The cause of this event was personnel error.
The individual preparing the Licensee Event Report (LER) relied on verbal input when preparing the subject LER_ and failed to verify that written documentation existed indicating that a change to the shift orders was made. This information was actually included in a Shift Supervisor log entry on February 7, 1997, rather than the shift orders.
- 2.
Corrective Steps Which Have Been Taken and the Results Achieved The LER was supplemented and sut>mitted to the NRC on April 8, 1997. Th~
supplemental LER stated that the* operating logs were revised to address the operability concern associated with reverse rotation of the ventilation fans.
The station licensing personnel that process outgoing correspondence have reviewed the requirements in 10 CFR 50.9 and 10 CFR 50. 73 and have been coached on the importance of ensuring that written documentation is reviewed and available to establish the verification of accuracy of each NRC submittal.
Subsequent to identification of the inaccuracy in the subject LER, an additional example was identified in another LER, which addressed a reactor shutdown due to a stea;;1 drain line weld leak. This LER erroneously indicated that the plant had been borated to cold shutdown conditions.
In accordance with the Corrective Action Program, an LER supplement is being prepared to correct this error.
Based on these two LER inaccuracies, a more thorough review was conducted of other selected LERs.
As a result of this review, a deviation report wa$
submitted documenting identified errors. The majority of the discrepancies found were minor in nature. No significant concerns regarding content or verification of accuracy were identified. Any required LER supplements will be* prepared in accordance with the Corrective Action Program.
Guidance to strengthen the verification of accuracy process for outgoing correspondence was issued to station licensing personnel by supervision. This guidance includes direction that verification of accuracy items will be documented.
- 3.
Corrective Steps Which Will be Taken to Avoid Further Violations The corrective actions documented in Section 2 are considered adequate to avoid recurrence. No further actions are required.
- 4.
The Date When Full Compliance Will be Achieved Full compliance was achieved when the LER was supplemented and submitted to the NRC on April 8, 1997.
_-1 Violation C
- 1.
Reason for the Violation, or, if Contested, the Basis for Disputing the Violation The violation is correct as stated.
Containment Entry Failure to Follow Procedures The root cause for failing to adhere to radiation protection procedures during the August 17, 1996 containment entry, was the failure of the individual Health Physics Shift Supervisor (HPSS) to be fully knowledgeable of, and comply with, Radiation Work Permit (RWP) requirements.
Specifically, the HPSS was not cognizant of the requirement to write a special RWP when the expected doses exceeded 100 mrem. Furthermore, he believed that it was permissible for him to make field changes to the RWP. When the Digital Alarming Dosimetry (DAD) of the workers directly under the HPSS's control alarmed during the containment entry, he evaluated the radiological hazards and continued the job.
Failure to Follow RP Procedures for Obtaining DADs As Required by the RWP On September 6, 1996, an individual entered the outer gate at the Low Level Waste Storage Facility to verify that corrective actions, required as a result of a hurricane, had been implemented.
The individual understood the RWP requirements for entry into the area, but elected to enter without his DAD because of the urgency to verify the corrective actions. He reported the event to his supervisor and submitted a station deviation report.
The cause of the deviation was an error in judgment by the individual.
Separately, after several procedural violations were identified for entry into the RCA without DADs, a Category I Root Cause Evaluation (RCE) was initiated to determine the cause and recommend corrective actions. The RCE determined the following to be the causes for the failure to adhere to radiation protection procedures for obtaining a DAD prior to Radiological Control Area (RCA) entry:
The layout in the area for processing into the plant RCA and the number of tasks required for entry distracted workers. Specifically, entry into the RCA may require workers to complete a number of tasks including, notification of Radiation Protection personnel, RWP review, obtain1ng dosimetry, review of recent survey data, donning of protective clothing, obtaining respirator, or obtaining radiation survey instr'uments, as required.
The flow path for accomplishing these tasks was not arranged to eliminate distractions and to focus on obtaining dosimetry. In addition, rio positive controls were in place to ensure that the workers comply with thsse requirements.
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Despite the numerous signs instructing the workers to verify compliance with their RWP arid to ensure that they obtained the proper dosimetry, individuals failed to demonstrate adequate self checking to prevent entry into the RCA without proper dosimetry.
Corrective Steps Which Have Been Taken and the Results Achieved Containment Entry Failure to Follow Procedures This failure to follow procedure was identified and documE.;.ted on a station deviation report. An investigation was initiated to determine the cause of the event.
Disciplinary action was administered to the individual HPSS who failed to follow RP procedures and who inappropriately changed the DAD alarm setpoint on the RWP Briefing Attendance Roster. The individual involved was assigned to a non-supervisory position outside the Health Physics (HP)
Operations organization.
The f.ollowing additional corrective actions have been implemented:
HP Operations personnel were briefed on this event.
Management expectations and verbatim compliance to procedural requirements were stressed.
An investigation of past non-compliance events was performed to ensure that a more programmatic problem did not exist. Dosimetry history for work under Standing RWPs was reviewed to determine the frequency of DADs exceeding alarm setpoints. Procedures were also reviewed to verify that the instructions clearly precluded fielc;I changes to RWPs.
The investigation concluded that the event was caused by personnel error on the part of the individual HPSS and that a programmatic problem did not exist.
Information on the event and the results of the investigation were placed in HP Operations required reading.
The station manager issued a memo to all station personnel that stressed management expectations for procedural compliance and personal accountability.
Failure to Follow RP Procedures for Obtaining DADs As Required by the RWP Station deviation reports were submitted to d9cument each event.
Disciplinary action has been administered to the individual who entered the outer.
gate at the Low Level Waste Storage Facility without a DAD. The deviation report and corrective action response were placed in HP Operations required reading.
Following the February 3, 1997 event, where an individual entered the RCA without a DAD, n temporary program was implemented to physically verify that all personnel entering the plant RCA complied with the dosimetry requirements of their RWP.
The program required an individual, from various station departments, to monitor. the entrance to the. plant RCA during periods of high activity. During the Unit 1 refueling outage, an individual was stationed at the entrance to the plant RCA on dayshift and nightshift to monitor compliance with dosimetry requirements.
The flowpath used to process personnel into the RCA was temporarily reorganized to focus on the completion of entry requirements until an evaluation is completed to verify that the controls are adequate to prevent recurrence.
As noted in item 1 above, a multi-disciplined Category I Root Cause Evaluation (RCE) was initiated. The RCE also determined that the non-compliance rate for entry into the RCA without a DAD was 0.004% for the period of evaluation. The dose assiqned from these events was one mrem to one of the individuals. The individual~ iriv;l~~d in these events w~~e *a thermo-luminescent dosimeter (TLD) as the primary means of measuring dose. The RCE was completed and the appropriate corrective actions are discussed in Section 3.
A Station Alert posting detailing changes to RCA in-processing and a memo from the station manager stressing compliance with dosimetry requirements was issued to station personnel.
There have been no further deviations where entries were made to the RCA without the RWP required DAD.
- 3.
Corrective Steps Which Will be Taken to Avoid Further Violations Containment Entry Failure to Follow Procedures The corrective actions documented in Section 2 are considered adequate to avoid recurrence. No further actions are required.
Failure to Follow RP Procedures for Obtaining DADs As Required by the RWP While the corrective actions tal<en to date have served to sensitize station personnel to the dosimetry requirements for entry into the RCA and for the need for the individual to self check, an evaluation of the flow path associated with entry into the RCA will be completed to ensure that the controls are adequate to avoid recurrence.
In addition to the concerns mentioned above, other events involving compliance with RP procedures have been documented and reviewed. While these events
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-*1 had negligible consequences, actions are being taken to address these issues through the corrective action program.
- 4.
The Date When Full Compliance Will be Achieved Corrective actions for the failure to comply with RP procedures for containment entry in August 1996 are complete and full compliance has been achieved.
Short term actions have been taken to increase sensitivity of the requirements to wear DADs in the RCA. An evaluation will be completed by June 30, 1997, to ensure that the controls are adequate to avoid recurrence and to recommend any further modifications to RCA in-processing.
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