ML18153A472
| ML18153A472 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 06/24/1996 |
| From: | Ohanlon J VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 96-298, NUDOCS 9606270098 | |
| Download: ML18153A472 (5) | |
Text
VIRGINIA ELECTRIC AND POWER COMPA~Y RICHMOXD, VIRGINIA 23261 June 24, 1996 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.
SPS Docket Nos.
License Nos.
NRC INSPECTION REPORT NOS. 50-280/96-03 AND 50-281/96-03 96-298 R4' 50-281 DPR-37 We have reviewed Inspection Report Nos. 50-280/96-03 and 50-281/96-03 dated May 31, 1996 and the enclosed Notice of Violation for Surry Unit 2. We share your concern regarding the open fire boundary door and have reviewed the circumstances of this event with respect to a similar event in 1991.
The 1991 event involved a lack of understanding and sensitivity to the requirements and safety significance of fire boundary doors. Although both events were caused by personnel error, the corrective actions from the previous event were effective because the individual recently involved was fully aware of the requirements to maintain the door in a closed position. However, upon his departure through the rear exit door, it is believed that welding leads inadvertently fell between the door and doorjamb causing the door to remain ajar. The additional corrective actions discussed in this response will prevent further incidents involving these boundary doors.
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 960627AOD009C: 6~88~~80 PDR PDR G
cc:
U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, N.W.
Atlanta, Georgia 30323 Mr. M. W. Branch NRC Senior Resident Inspector Surry Power Station
REPLY TO A NOTICE OF VIOLATION NRC INSPECTION CONDUCTED MARCH 24 - MAY 4, 1996 SURRY POWER STATION UNITS 1 AND 2 INSPECTION REPORT NOS. 50-280/96-03 AND 50-281/96-03 NRC COMMENT:
"During an NRC inspection conducted on March 24 through May 4, 1996, a violation of NRC requirements was identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below:
Technical Specification (TS) 3.21.A.5 requires that the low pressure carbon dioxide system be operable to the extent that when equipment in the emergency diesel generator (EOG) rooms is required to be operable, fire suppression can be provided upon demand. TS 3.21.B.4 requires that with the required system in TS 3.21.A.5 inoperable, a continuous fire watch be established within one hour.
Contrary to the above, on April 8, 1996, the low pressure carbon dioxide system for number 2 EOG room was inoperable when the EOG was required to be operable and a continuous fire watch was not established within one hour.
This is a Severity Level IV violation (Supplement I)."
- 1.
REPLY TO A NOTICE OF VIOLATION NRC INSPECTION CONDUCTED MARCH 24 - MAY 4, 1996 SURRY POWER STATION UNIT 2 INSPECTION REPORT NOS. 50-280/96-03 AND 50-281/96-03 Reason for the Violation, or, if Contested, the Basis for Disputing the Violation The violation is correct as stated.
The Emergency Diesel Generator (EOG) No. 2 room doors are posted as Carbon Dioxide Boundary Fire Doors. Blocking or holding the doors open is not permitted, and putting the door on its automatic blow off device requires prior permission of an operations shift supervisor. Access into EOG No. 2 room is provided from the Unit 2 turbine building hallway and is restricted by the use of a keycard. The EOG No. 2 room rear door exits to the Unit 2 alleyway, but cannot be entered from the alleyway.
To support the tie-in of the new EOG fuel oil supply lines, welding leads were supplied from the Unit 2 alleyway, supported along the outside wall above the rear exit door to EOG No. 2 room and routed through the doorway into the EOG No. 2 room.
While the door was open, a fire watch was posted as a compensatory measure to comply with Technical Specification (TS) 3.21.B.4.
On April 8, 1996, following the completion of construction work, the welding leads were removed from the doorway and coiled outside the rear door for temporary storage. The door was closed and the operations shift supervisor was notified. The fire watch was released at approximately 0850 hours0.00984 days <br />0.236 hours <br />0.00141 weeks <br />3.23425e-4 months <br />.
At approximately 1130 hours0.0131 days <br />0.314 hours <br />0.00187 weeks <br />4.29965e-4 months <br />, the rear door to the EOG No. 2 room was verified as closed by Safety and Loss Prevention personnel. Another entry was made into the EOG No. 2 room at 1135 hours0.0131 days <br />0.315 hours <br />0.00188 weeks <br />4.318675e-4 months <br />, and the individual exited the rear exit door at approximately 1145 hours0.0133 days <br />0.318 hours <br />0.00189 weeks <br />4.356725e-4 months <br />. When interviewed, the individual indicated he saw the door closing but did not verify that it fully shut.
The welding leads supported above the rear exit door had loosened and, upon the individual's exit, fell between the door and the doorjamb.
The cause of this event is attributed to cognitive personnel error on the part of 1) the personnel who secured the welding leads above the EOG No. 2 room rear exit door, and 2) the individual who exited the door without ensuring that the door was fully closed. The rear exit doors are labeled as carbon dioxide boundary fire doors and instructions on the door plainly state that the door is not to be blocked or held open. Personnel responsible for planning and implementing the EOG No. 2 room construction work recognized that the doors could not be blocked open without compensatory actions, and the individuals interviewed concerning this event were aware of the requirements.
- 2.
Corrective Steps Which Have Been Taken and the Results Achieved Upon discovery that the rear exit door was not closed, the control room was notified. An operator removed the welding leads from the doorway and closed the rear exit door to the EOG No. 2 room.
A station Deviation Report was submitted.
Construction management reviewed the event with personnel involved with the EOG fuel oil line replacement construction work, the pipe fitter craft, and the construction foreman.
The requirements to maintain the carbon dioxide boundary fire door closed was re-emphasized.
Prior to the fuel oil line construction work, personnel passage through the EOG room rear exit doors was prohibited. To expedite the fuel oil line replacement work, these restrictions had been relaxed. Upon completion of the construction work, personnel passage through the EOG room rear exit doors was again prohibited.
To reduce the risk of recurrence, the rear exit doors have been posted as an Emergency Exit Only. In addition, alarms on all of the EOG rooms rear exit doors have been activated.
Furthermore, the carbon dioxide boundary doors in other areas, which provide a boundary function similar to the EOG No. 2 rear exit door, have also been evaluated to determine if further corrective actions were required to ensure that the doors do not inadvertently remain open.
The evaluation concluded that sufficient controls are in place to preclude a similar incident.
- 3.
Corrective Steps Which Will be Taken to Avoid Further Violations The corrective actions taken above are appropriate to prevent a recurrence of the inoperability of the EOG fire suppression system due to an inadvertent opening of the rear exit doors, as well as to prevent an inadvertent opening of carbon dioxide boundary doors in other areas.
- 4.
The Date When Full Compliance Will be Achieved Full compliance was achieved when the EOG No. 2 room rear exit doors were closed and the EOG No. 2 room Fire Suppression System was returned to operable status.
_,