ML18153A547

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Discusses Insp Repts 50-280/95-20 & 50-281/95-20 & Forwards Notice of Violation.Violations Involved Failures of Operating Staff to Maintain Mgt Oversight & Control of Operating Activities
ML18153A547
Person / Time
Site: Surry  Dominion icon.png
Issue date: 11/22/1995
From: Ebneter S
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To: Ohanlon J
VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
Shared Package
ML18151A648 List:
References
EA-95-223, NUDOCS 9512110461
Download: ML18153A547 (4)


See also: IR 05000280/1995020

Text

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November 22, 1995

EA 95-223

Virginia Electric and Power Company

ATTN:

Mr. James P. O'Hanlon

Senior Vice President-Nuclear

Innsbrook Technical Center

5000 Dominion Boulevard

Glen Allen, VA

23060

SUBJECT:

NOTICE OF VIOLATION

(NRC INSPECTION REPORT NOS. 50-280/95-20 and 50-281/95-20)

Dear Mr. O'Hanlon:

This refers to the inspection conducted on September 14 through October 4,

1995 at t~e Surry facility.

The inspection included a review of the

circumstances associated with the September 13 and 14, 1995, unplanned

reduction of Unit 1 reactor vessel water level.

The results of this

inspection were sent to you by letter dated October 19, 1995.

A closed

predecisional enforcement conference was conducted in the Region II office on

November 6, 1995, to discuss the apparent violations, the root causes, and

your corrective actions to preclude recurrence.

A list of conference

attendees, NRC slides, and a copy of your presentation summary are enclosed.

Based on the information developed during the inspection and the information

your staff provided during the conference, the NRC has determined that

violations of NRC requirements occurred.

These violations are cited in the

enclosed Notice of Violation (Notice) and the circumstances surrounding them

are described in detail in the subject inspection report.

The three

violations, described in the enclosed Notice, involved: (1) failures of the

operating staff to maintain management 6versight and control of operating

activities; (2) failure of the operating staff to properly confirm and control

plant configuration affecting approved maintenance activities; and,

(3) failure to follow procedures for the control of pressurizer relief tank

(PRT) venting activities.

As a result of the deficiencies noted in

Violation A, approximately 4,500 gallons of water were inadvertently drained

from the reactor vessel.

The roqt causes of the three violations included deficiencies in operator

training, poor control and oversight of plant evolutions being conducted in

the control room, weak communication practices and lack of control of field

activities by the licensed operations staff. Specifically, weak operator

training in the operational characteristics of the reactor vessel water level

standpipe indication led to a deficiency in the operators' understanding of

its operation. This contributed to failures of the licensed control room

staff to recognize that the method of reactor vessel water level indication

provided a false level indication when the reactor vessel head vent was

isolated to accommodate installation of the reactor cavity seal ring.

The

licensed operator controlling reactor water level did not maintain a

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questioning attitude when he continued with a rate of letdown in excess of

makeup over a period of almost five hours due to the false water level

indication.

Senior reactor operators failed to question and oversee this

evolution.

Communication deficiencies were a characteristic of all three

violations.

The violations included the failure to maintain adequate turnover

logs of the status of required equipment, poor operating crew turnovers of

plant status, and lack of communication among the senior reactor operators and

operating shifts.

It is also significant that the procedure for venting the

PRT was not followed.

The NRC is particularly concerned that although the

licensed control room operators were aware of the PRT venting evolution, they

did not ensure the evolution was conducted using the approved procedure and

failed to provide proper oversight.

The violations cited occurred shortly after the reactor was shutdown for

refueling.

In addition, at the time, reactor vessel water level was below the

level of the reactor vessel flange and the reactor coolant loops were

.

isolated; thus, there was a reduced inventory of water available for core

cooling.

During this period of time, sufficient reactor coolant system water

inventory is essential in ensuring adequate decay heat removal.

Violation A

resulted in a significant unanticipated reduction in a reactor safety margin,

i.e., reactor water level. All three violations indicate a lack of proper

control of operational activities during a critical time period.

While the

individual violations were not of significant safety consequence, the NRC is

concerned that continuing performance at this level could lead to incidents of

greater safety significance.

Collectively, these violations are cause for

significant regulatory concern and represent a serious lack of attention to

licensed responsibilities. Therefore, these violations are classified in the

aggregate in accordance with the "General Statement of Policy and Procedure

for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600, as a

Severity Level III problem.

In accordance with the Enforcement Policy, a base civil penalty in the amount

of $50,000 is considered fo~ a Severity Level III problem.

Because your

facility has not been the subject of escalated enforcement actions within the

last two years, the NRC considered whether credit was warranted for Corrective

Action in accordance with the civil penalty assessment provision in Section

VI.B.2 of the Enforcement Policy.

Your corrective actions were comprehensive

and included improvements in a broad spectrum of areas as discussed in your

handout provided to the NRC at the predecisional enforcement conference

(Enclosure 4). These corrective actions included training initiatives,

procedure revisions, reinforcement of management expectations for Operations

personnel, revisions to your outage plans and strengthening of management

oversight of operational activities. The NRC determined that credit was

warranted for the factor of Corrective Action.

Therefore, to encourage prompt, comprehensive correction of violations and in

recognition of the absence of previous escalated enforcement action, I have

been authorized, after consultation with the Director, Office of Enforcement,

not to propose a civil penalty in this case.

However, significant violations

in the future could result in a civil penalty.

. *

VEPCO

3

You are required to respond to this letter and should follow the instructions

specified in the enclosed Notice when preparing your response.

In your

response, you should document the specific actions taken and any additional

actions you plan to prevent recurrence.

After reviewing your response to this

Notice, including your proposed corrective actions and the results of future

inspections, the NRC will determine whether further NRC enforcement action is

necessary to ensure compliance with NRC regulatory requirements.

In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of

this letter, its enclosures, and your response will be placed in the NRC

Public Document Room (PDR).

To the extent possible, your response should not

include any personal privacy, proprietary, or safeguards information so that

it can be placed in the PDR without redaction.

The responses directed by this letter and the enclosed Notice are not subject

to the clearance procedures of the Office of Management and Budget as required

by the Paperwork Reduction Act of 1980, Pub. L. No.96-511.

Docket No. 50-280

License No. DPR-32

Enclosures:

1.

Notice of Violation

2.

List of Attendees

3.

NRC Slides

Sincerely,

Original signed by

Jon R. Johnson for

Stewart D. Ebneter

Regional Administrator

4.

Virginia Power Presentation Summary.

5.

Surry Unit 1 CSD and RSD

Critical Parameters, 9/13/95

6.

Surry Unit 1 CSD and RSD

Critical Parameters, 9/14/95

cc w/encls: (See next page)

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VEPCO

cc w/encls:

M. L. Bowling, Manager

Nuclear Licensing & Operations

Support

Virginia Electric & Power Company

Innsbrook Technical Center

5000 Dominion Boulevard

Glen Allen, VA

23060

David A. Christian, Manager

Surry Power Station

Virginia Electric & Power Company

5570 Hog Island Road

Surry, VA

23883

Ray D. Peace, Chairman

Surry County Board of Supervisors

P. 0. Box 130

Dendron, VA

23839

Dr. W. T. Lough

Virginia State Corporation

Commission

Division of Energy Regulation

P. 0. Box 1197

Richmond, VA

23209

Michael W. Maupin

Hunton and Williams

Riverfront Plaza, East Tower

951 E. Byrd Street

Richmond, VA

23219

Robert B. Strobe, M.D., M.~.H.

State Health Commissioner

Office of the Commissioner

Virginia Department of Health

P. 0. Box 2448

Richmond, VA

23218

Attorney General

Supreme Court Building

900 East Main Street

Richmond, VA

23219

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