ML18153A952
| ML18153A952 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 05/18/1994 |
| From: | Ohanlon J VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 94-270, NUDOCS 9405240058 | |
| Download: ML18153A952 (4) | |
Text
VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 May 18, 1994 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D. C. 20555 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS l AND 2 NRC INSPECTION REPORT NO. 50-280/94-08 REPLY TO A NOTICE OF VIOLATION Serial No.94-270 SPS/BCB/ETS Docket Nos.
50-280 License Nos. DPR-32 Your letter dated April 19, 1994, provided the results of NRC Inspection Report No.
50-280/94-08.
The report identified a violation for failure to follow Technical Specifications when returning an isolated reactor coolant loop to service. We have assessed the personnel and procedural aspects of this event and concluded that the event was caused by a failure of the shift personnel to adequately manage the evolution within the Technical Specification time constraints.
Although the review of the procedures revealed no significant deficiencies, the procedures have been enhanced to incorporate the lessons learned from this event.
The attached response to the notice of violation describes the actions we have taken as a result of the violation. Please contact us if you have any questions or require additional information.
Very truly yours, C)7?07/~
J. P. O'Hanlon Vice President - Nuclear Operations Attachment cc:
U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, N.W.
Atlanta, Georgia 30323 Mr. Morris Branch NRC Senior Resident Inspector Surry Power Station 0 A ::; r*< 1 9405240058 940518 PDR ADOCK 05000280 Q
REPLY TO A NOTICE OF VIOLATION NRC INSPECTION CONDUCTED March 6 - April 2, 1994 SURRY POWER STATION UNITS 1 INSPECTION REPORT NO. 50-280/94-08 NRC COMMENT:
During an NRC Inspection conducted on March 6 through April 2, 1994, 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 3.17.5.c requires that the hot and cold leg reactor coolant loop stop valves be fully opened within two hours after filling a loop from the reactor coolant system.
Contrary to the above, on March 1, 1994, the Unit 1 B loop was filled from the reactor coolant system and the hot leg stop valve was not opened within two hours after the loop was declared full. The Bloop was declared full at 8:40 a.m., and the hot leg stop valve was not fully open until two hours and ten minutes later at 10:50 a.m. The B loop cold leg stop valve was opened within two hours after declaring the loop full.
This is a Severity Level IV Violation (Supplement I).
REPLY TO A NOTICE OF VIOLATION NRC INSPECTION CONDUCTED March 6 - April 2. 1994 SURRY POWER STATION UNIT 1 INSPECTION REPORT NO. 50-280/94-08
- 1)
Reason for the Violation. or if Contested. the Basis for Disputing the Violation
- 2)
The reason for this violation was a cognitive personnel error on the part of the licensed Senior Reactor Operators (SRO) on shift. The SROs were aware of the two hour time limit for opening the loop isolation valves, but did not properly manage the evolution to ensure that the time constraints were met. Thus, when unanticipated delays were encountered during the evolution, insufficient time remained to complete the evolution within the Technical specification time constraint. A summary of the event follows.
On March 1, 1994, at approximately 0651 hours0.00753 days <br />0.181 hours <br />0.00108 weeks <br />2.477055e-4 months <br />, Operating Procedure 1-0P-RC-002, "Reactor Coolant System Fill," was initiated to fill the Unit 1 Reactor Coolant System (RCS) Loop "B". At 071 O hours, the Loop "B" cold leg isolation valve, 1-RC-MOV-1593, was opened slightly and the loop began filling from the RCS. At 0840 hours0.00972 days <br />0.233 hours <br />0.00139 weeks <br />3.1962e-4 months <br />, the loop was determined to be full in accordance with 1-0P-RC-002. Procedure 1-0P-RC-002 required that the loop boron concentration be greater than or equal to the RCS boron concentration before the hot and cold leg isolation valves were opened. This condition was verified at 1030 hours0.0119 days <br />0.286 hours <br />0.0017 weeks <br />3.91915e-4 months <br /> and Operations personnel attempted to open the hot and cold leg isolation valves. The hot leg isolation valve, 1-RC-MOV-1592, could not be opened so electricians were dispatched to investigate.
The electricians determined that 1-RC-MOV-1592 would not open due to the interlock with 1-RC-MOV-1593 (1-RC-MOV-1592 can not be opened unless 1-RC-MOV-1593
_ Js closed). The electricians defeated the valve interlock, since it was not required for this evolution, and 1-RC-MOV-1592 was opened at 1050 hours0.0122 days <br />0.292 hours <br />0.00174 weeks <br />3.99525e-4 months <br />.
1-RC-MOV-1593 indicated full open at 1039 hours0.012 days <br />0.289 hours <br />0.00172 weeks <br />3.953395e-4 months <br />.
The unit-was at refueling shutdown and RCS Loop "B" was filled from the active portion of the RCS. The shutdown margin was not affected since the boron concentration of the loop was verified to be equal to that of the RCS before the loop isolation valves were opened. At no time was reactivity management a concern during the evolution.
Corrective Steps Which Have Been Taken and the Results Achieved The personnel involved in this event were counseled on the need to allow sufficient time to respond to contingencies that may be encountered during time sensitive evolutions.
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REPLY TO A NOTICE OF VIOLATION NRCINSPECTION CONDUCTED MARCH 6 - APRIL 2, 1994 SURRY POWER STATION UNIT 1 INSPECTION REPORT NOS. 50-280/94-08 AND 50-281 /94-08 Corrective Steps Which Have Been Taken and the Results Achieved (Continued)
Station SROs were apprised of this event by Operations Department management.
Unit 1 RCS Loops "A" and "C" were filled following the implementation of these corrective actions. The evolutions were properly managed and completed within the specified time constraints.
The Superintendent - Operations presented a synopsis of this event during licensed operator requalification training, with emphasis on the proper on-shift management techniques to ensure compliance with Technical Specification requirements.
corrective Steps That wm be Taken to Avoid Further Violations This was an isolated occurrence and no additional corrective actions are deemed necessary.
- 4)
The Pate when Fun compnance wm be Achieved Full compliance was achieved on March 1, 1994, when the RCS hot leg isolation valve, 1-RC-MOV-1592, was fully opened.