ML18153A488
| ML18153A488 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 02/10/1997 |
| From: | Ohanlon J VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 97-036, 97-36, NUDOCS 9702180288 | |
| Download: ML18153A488 (6) | |
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VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 February 10, 1997 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D. C. 20555 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNIT 1 AND UNIT 2 REPLY TO A NOTICE OF VIOLATION Serial No.
SPS:JDK/GDM Docket Nos.
License Nos.
NRC INSPECTION REPORT NOS. 50-280/96-12 AND 50-281/96-12 97-036 R4 50-280 50-281 DPR-32 DPR-37 We have reviewed Inspection Report Nos. 50-280/96-12 and 50-281/96-12 dated January 13, 1997, and the enclosed Notice of Violation (NOV) for Surry Units 1 and 2.
The report identified a violation for an inadequate procedure that resulted in the Alternate Alternating Current (AAC) Diesel Generator not being capable of operation from the control room following a station blackout. As described in our attached reply to the NOV, we have concluded that this event was caused by personnel error during the procedure revision process. *corrective actions have been taken to correct this concern and to preclude a similar violation in the future.
We have no objection to this letter being made part of the public record.
No new commitments are intended as a result of this letter. Please contact us if you have any questions or require additional information.
- Very truly yours,
~?~
James P. O'Hanlon Senior Vice President - Nuclear Attachment 180098
e cc:
U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, N.W., Suite 2900 Atlanta, Georgia 30323 Mr. R. A. Musser NRC Senior Resident Inspector Surry Power Station e
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e REPLY TO A NOTICE OF VIOLATION NRC INSPECTION CONDUCTED NOVEMBER 10 - DECEMBER 14, 1996 SURRY POWER STATION UNITS 1 AND 2 INSPECTION REPORT NOS. 50-280/96-12 AND 50-281/96-12 NRC COMMENT:
"During an NRC inspection conducted on November 10 through December 14, 1996, a violation of NRC requirements was identified.
In accordance with the 11General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG.-1600, the violation is listed below:
Technical Specification 6.4.A.1 requires that written procedures with appropriate check-off lists and instructions shall be provided for the normal startup, operation, and shutdown of all systems and components involving nuclear safety of the station.
Contrary to the above, procedure O-MOP-AAC-002, Return to Service of the AAC Diesel Generator, Revision 1, did not contain appropriate instructions to return the AAC (Alternate Alternating Current) Diesel Generator to service on September 20, 1996. The procedure failed to provide adequate instructions to return the AAC Diesel Generator output breaker control switch to the auto position after racking the output breaker to the correct position. This procedure error resulted in the system being incapable of operation from the control room from September 20 to November 13, 1996.
This is a Severity Level IV Violation (Supplement I).".
--- e REPLY TO A NOTICE OF VIOLATION NRC INSPECTION CONDUCTED NOVEMBER 10- DECEMBER 14, 1996 SURRY POWER STATION UNITS 1 AND 2 INSP=CTlON REPORT NOS. 50-280/96-12 AND 50-281/96-12
- 1.
Reason for the Violation, or, if Contested, the Basis for Disputing the Violation The violation is correct as stated. The reason for the violation was personnel error in the procedure revision process. This error resulted in the AAC Diesel Generator (DIG) output breaker control switch not being procedurally returned to the Auto-After-Trip position after racking the output breaker to the correct position.
Revisions to maintenance operating procedures O-MOP-AAC-001, "Removal From Service of the AAC Diesel Generator," and O-MOP-AAC-002, "Return to Service of the AAC DIG," were prepared as a result of design changes to add the Unit 1 tie-in from the AAC DIG to the transfer buses. In accordance with the procedure revision process, operations personnel reviewed and validated the revisions prior to their approval. On May 17, 1996, the revised procedures were approved by station management. The revision to O-MOP-AAC-001 included steps for placing the AAC DIG output breaker control switch in the Pull-To-Lock position, racking out and tagging the breaker. The revision to O-MOP-AAC-002 provided steps for removing the tag and racking in the breaker. However, it did not provide a step to remove the control switch from Pull-To-Lock by placing it in the Auto-After-Trip position. Additionally, revisions O and 1 to O-MOP-AAC-002 have a step to perform required Post Maintenance Testing (PMT).
If the maintenance performed affected operability of the AAC DIG, the AAC DIG would be run as part of the PMT. Procedures for testing and operating the AAC DIG would have placed the output breaker control switch in the Auto-After-Trip position.
On September 17 and September 24, 1996, the AAC DIG was removed from service to perform work which did not affect the operability of the AAC DIG. The use of O-MOP-AAC-002, Revision 1 for returning the AAC DIG to service resulted in the control switch for the AAC DIG output breaker being left in the Pull-To-Lock position. This rendered the AAC DIG inoperable from the control room because the output breaker would not automatically close and energize the transfer bus as designed.
On November 13, 1996, an operator tagging out the AAC DIG identified that the control switch for the AAC DIG output breaker was already in Pull-To-Lock.
Subsequent investigation identified that the AAC DIG had been inoperable from the control room since removal from service on September 17, 1996.
- 2.
e Corrective Steps Which Have Been Taken and the Results Achieved A station deviation report was submitted. As a result of investigations performed to address the deviation report, two actions were taken. A special report was voluntarily submitted in accordance with station administrative procedure, VPAP-2802, "Notifications and Reports."
Secondly, a Category II Root Cause Evaluation (RCE) was performed and approved by SNSOC on January 2, 1997.
The root cause of this event was determined to be the omission of relevant information during the revision of procedure O-MOP-AAC-002.
Procedure O-MOP-AAC-002 was changed to return the control switch for the AAC DIG output breaker to the Auto-After-Trip position.
The change was completed and approved on November 15, 1996.
Operator logs were revised by adding special instructions to check the position of control switches which could prevent the AAC DIG from loading onto a transfer bus.
Supervisory personnel have reviewed this event with staff in the Operations and Procedures Departments. The specifics of the violation were discussed, and the procedure process requirements for ensuring the completeness and validity of new and revised procedures were reinforced. Management expectations for the procedure writer and the validator, as well as the key role each performs in the procedure revision process, were reviewed.
Training was completed for Operations shift personnel on the AAC Diesel Generator. This training included pre-start checks, performing a set of startup logs, starting the AAC DIG without paralleling to a bus using O-OP-AAC-001,
"AAC DIG Operation," shutting down the AAC DIG, and placing the AAC DIG in standby. Job Performance Measures (JPMs) were also performed locally and on the simulator. This training familiarized the operators with the operation of the AAC DIG and provided the knowledge level to instill a questioning attitude.
- 3.
Corrective Steps Which Will be Taken to Avoid Further Violations The completed corrective actions discussed in Section 2 above are sufficient to avoid further violations.
As an enhancement for the operators' knowledge and understanding of AAC DIG operation, additional training on this event will be conducted for Licensed and Non Licensed Operators during 1997.
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- 4.
The Date When Full Compliance Will be Achieved Full compliance was achieved with respect to the cited violation when the change to O-MOP-AAC-002 was completed, and the AAC D/G was returned to service using the changed procedure on November 16, 1996.