ML18153A581
| ML18153A581 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 01/29/1996 |
| From: | Ohanlon J VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 96-013, 96-13, NUDOCS 9601310242 | |
| Download: ML18153A581 (6) | |
Text
VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 January 29, 1996 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.96-013 SPSNLA/GDM R6 Docket Nos.
50-280 50-281 License Nos.
DPR-32 DPR-37 NRC INSPECTION REPORT NOS. 50-280/95-22 AND 50-281/95-22 We have reviewed your Inspection Report Nos. 50-280/95-22 and 50-281/95-22 dated December 29, 1995, and the enclosed Notice of Violation (NOV).
The inspection report identified a cited violation for missed Technical Specification surveillances.
To determine the causes for the missed surveillances and the lack of effectiveness of the corrective actions previously taken, we have performed a Root Cause Evaluation (ACE) of the missed surveillances, the electrical maintenance surveillance program and its implementation at the station.
The ACE made recommendations for improvements in the electrical maintenance periodic test scheduling and tracking program, and these actions have been completed. We have also reviewed the specific issues identified in the inspection report relative to the timeliness and effectiveness of the previous corrective actions associated with the missed surveillances. Corrective actions identified in our attached response to the violation address these concerns.
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, Ref /J~ g~.
James P. O'Hanlon Senior Vice President - Nuclear Attachment 9601310242 960129 PDR ADOCK 05000280 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
REPLY TO A NOTICE OF VIOLATION NRC INSPECTION CONDUCTED NOVEMBER 5 THROUGH DECEMBER 2, 1995 SURRY POWER STATION UNITS 1 AND 2 INSPECTION REPORT NOS. 50-280/95-22 AND 50-281/95-22 NRC COMMENT:
"During an NRC Inspection conducted on November 5 through December 2, 1995, a violation of NRC requirements was identified.
In accordance with the 'General Statement of Policy and Procedure for NRC Enforcement Actions,' 1 O CFR Part 2, Appendix C, the violation is listed below:
Technical Specification (TS) 4.18.A.1 requires, in part, that fire detection instruments in specified zones be demonstrated operable at least once per six months by a channel functional test.
TS 4. 6. C. 1. b requires that the voltage for each cell in each station battery be measured and recorded each month.
TS 4.0.2 permits specified surveillance time intervals to be adjusted plus or minus 25 percent to accommodate normal test schedules.
Contrary to the above, Units 1 and 2 semi-annual smoke detector functional tests were not performed as required during the period from May 25, 1994, to January 9, 1995.
Additionally, the monthly station battery cell voltage measurement was not performed on the Unit 1, 1 B station battery during the period from February 21 to April 4, 1995.
This is a Severity Level IV violation (Supplement I)."
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REPLY TO A NOTICE OF VIOLATION NRC INSPECTION CONDUCTED NOVEMBER 5 THROUGH DECEMBER 2, 1995 SURRY POWER STATION UNITS 1 AND 2 INSPECTION REPORT NOS. 50-280/95-22 AND 50-281/95-22 Reason for the Violation, or if Contested, the Basis for Disputing the Violation The violation is correct as stated. The reasons for the two missed surveillances (periodic tests) are discussed below.
Each surveillance procedure is followed to completion by the responsible departmental tracking program. Individual responsibility is assigned by supervision to ensure the work is completed within the allowable surveillance window. The responsible department supervisor or designee is required to perform both an administrative and a technical review to ensure the proper completion of the surveillance procedure. In both of these events, this final review was not completed adequately due to programmatic issues and/or weaknesses in personal accountability and supervisory oversight within the Electrical Maintenance Department.
Smoke Detectors Surveillance On January 10, 1995, it was identified that the surveillance procedure O-EPT-0904-04 for the six month smoke detector test, due by January 5, 1995, had not been performed. The smoke detectors in both units' cable tray rooms and the low level intake structure fuel oil tank room had not been tested within the allowed six month interval between surveillance tests. The smoke detectors were satisfactorily tested on January 10, 1995, five days after the allowed test interval.
As a result of the missed surveillance, the Electrical Maintenance Department initiated an evaluation of their surveillance tracking controls. The results of the evaluation identified programmatic weaknesses in the administrative process for verifying completion of periodic tests (PTs) in the Electrical Maintenance Department.
Specifically, the Maintenance Department Administrative Guideline (MDAG-3),
11Maintenance Department PT Schedule and Tracking (Electrical),
11 did not assign specific responsibilities and guidelines for PT scheduling and tracking within Electrical Maintenance.
Station Batteries Surveillance To demonstrate operability, the voltage of each station battery's cells is checked on a monthly basis through performance of an electrical periodic test (EPT) O-EPT-0102-
- 01. This EPT checked both the Unit 1 and Unit 2 station batteries' cell voltages. As part of post maintenance restoration of the station battery 1A, O-EPT-0102-01 was satisfactorily completed for station battery 1 A on March 4, 1995. The part of the procedure that tested the Unit 1 1 B station battery and the two Unit 2 station batteries
was not performed. However, the PT data sheet used to track completion of the required monthly testing was signed off as complete for all four station batteries by an Electrical Maintenance Supervisor. Due to this inadequate review, the EPT was processed as fully complete and credit was taken for the Unit 1 1 B battery and the two Unit 2 station batteries for the March monthly surveillance test. The EPT was not completed for the station batteries for both Units 1 and 2 until the next scheduled monthly surveillance on April 4, 1995, five days after the allowed test interval.
On May 23, 1995, while conducting a PT trending review, it was identified that O-EPT-0102-01 had not been completely performed during March 1995 for the Unit 1 1 B and Unit 2 station batteries. As a result of this partial EPT performance, Unit 1 station battery 1 B had not been tested within the allowed surveillance interval. The Unit 2 batteries had been coincidentally tested under a separate refueling test procedure that met the monthly battery voltage cell surveillance requirement.
The missed surveillance for station battery 1 B was caused by cognitive personnel error. The Electrical Maintenance Supervisor did not verify that the post-maintenance testing associated with the work order that tested the 1 A station battery also met the requirements of the monthly PT for the other station batteries as well. The review of the completed PT by the Electrical Maintenance Coordinator was also not effectively implemented.
Corrective Steps Which Have Been Taken and the Results Achieved O-EPT-0904-04, Six Month Smoke Detector Test (Pyrotronics), was performed satisfactorily for the required smoke detectors on January 10, 1995. O-EPT-0102-01, Monthly Station Battery Cell Voltage Check, was performed satisfactorily for station battery 1 B on April 4, 1995.
The individuals involved (including supervision) with these two incidents were counseled on the inappropriate actions which caused the missed surveillances.
A Root Cause Evaluation (RCE) was performed to investigate the causes of the missed battery surveillance and to determine why corrective actions taken for the missed smoke detector surveillance were not effective in precluding the second missed surveillance incident. The RCE determined that the failure of the initial corrective actions to prevent recurrence was primarily due to weaknesses in personal accountability and supervisory oversight within the Electrical Maintenance Department. The RCE was recently reevaluated to ensure that the corrective actions identified in the report were appropriate to address the entire scope of these missed surveillance events.
This reevaluation determined that the corrective actions identified in the RCE were appropriate and that no additional actions were deemed necessary.
Based on the recommendations of the RCE, MDAG-3 was revised to assign specific responsibilities and guidelines for PT scheduling and tracking within Electrical Maintenance. An additional individual has been assigned responsibility to assist in the operation and maintenance of PT scheduling and tracking. In addition, PTs that are rescheduled within the 25_% grace period will be carried over from one month to
- f.
- the next on the internal Electrical Maintenance PT schedule. Additional controls were also added to. MDAG-3 to strengthen the PT completion responsibilities of the Electrical Maintenance Department Supervisors.
The Maintenance Department Administrative Guidelines were further evaluated and revised to reflect the requirements of Administrative Procedure, VPAP 1102, Periodic Testing.
The monthly cell voltage surveillance for the station batteries was divided into individual procedures for each of the Unit 1 and Unit 2 batteries.
Quality Assurance (QA) performed an assessment of the tracking process in various departments which perform surveillance testing. The assessment concluded that barriers needed to be strengthened regarding the implementation of the PT program.
The corrective actions identified in this response address the concerns noted in the QA Assessment.
Corrective Steps That Will Be Taken to Avoid Recurrence Previous corrective actions taken in response to the Electrical Maintenance Department's missed surveillances, including the RCE and the related QA Assessment, were reviewed in response to this Notice of Violation. The corrective actions described above are sufficient to prevent recurrence. Furthermore, we have reviewed the barriers in place related to the implementation of periodic tests by other departments and deviation reports issued since 1994 that were associated with the periodic test program. Based on this review, we have determined that the barriers in place are sufficient to prevent missed surveillances as discussed above. However, to further strengthen the overall station PT program, VPAP 1102 will be revised by April 15, 1996, to require administrative and technical reviews be completed within the PT test interval.
The Date When Full Compliance Will Be Achieved Full compliance was achieved upon completion of the Six Month Smoke Detector Test (Pyrotronics) on January 10, 1995, and the Monthly Station Battery Cell Voltage Check for the 1 B station battery on April 4, 1995.