ML18153B040
| ML18153B040 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 08/17/1994 |
| From: | Ohanlon J VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 94-450, NUDOCS 9408240130 | |
| Download: ML18153B040 (7) | |
Text
VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 August 17, 1994 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D. C. 20555 Serial No.
SPS/NS&L Docket Nos.94-450 R1 50-280 50-281 License Nos. DPR-32 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNIT 1 AND UNIT 2 REPLY TO A NOTICE OF VIOLATION DPR-37 NRC INSPECTION REPORT NOS. 50-280/94-17 AND 50-281/94-17 Your letter dated July 17, 1994, provided the results of NRC Inspection Report No. 50-280/94-17 and 50-281/94-17. The report identified two violations. Our reply to the Notice of Violation is attached.
With respect to the foreign material exclusion (FME) violation, we agree with the concern noted in the inspection report. We are committed to a strong FME program and had already planned an assessment of a deviation report trend that demonstrated FME standards appeared to be declining. The deviation on the Component Cooling (CC) heat exchanger was a significant event relating to FME controls. The planned assessment was escalated to a task team which was promptly formed to evaluate the heat exchanger event and the noted trends. The conclusions of the task team indicate the CC heat exchanger event was not due to a programmatic breakdown.
The increasing trend noted in deviations associated with FME controls was determined to result primarily from the level of sensitivity or awareness for FME standards on the part of individuals not directly involved in the implementation of FME controls. We conclude that the programmatic actions.taken previously are.effective for FME close out inspections. We are implementing the task team recommendations to reinforce FME standards and strengthen the awareness of station personnel not directly involved in implementation of FME controls.
Please contact us if you have any questions or require additional information.
Very truly yours,
~f.OV~
James P. O'Hanlon Senior Vice President - Nuclear Attachment 9408240130 940817 PDR ADOCK 05000280 Q
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 JUNE 1 - JULY 2, 1994 SURRY POWER STATION UNIT 1 AND 2 INSPECTION REPORTS NOS. 50-280/94-17 AND 50-281/94-17 NRC COMMENT:
A.
Technical Specification (TS) 3.2.F requires that makeup water isolation valve 2-CH-212 be secured closed during refueling or cold shutdown conditions except during planned boron dilution or makeup activities, the valve shall be secured.
Contrary to the above, on June 17, 1994, with the Unit 2 in cold shutdown, valve 2-CH-212 was not secured closed within 15 minutes following the makeup activities. Makeup activities were secured closed at 12:14 p.m. and the valve remained open until 4:22 p.m., a period of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and 8 minutes. This exceeded the TS limit by 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and 53 minutes.
This is a Severity Level IV violation (Supplement I).
- 8.
10 CFR 50, Appendix 8, criteria XVI, as implemented by the Operational Quality Assurance Program Topical Report (VEP 1-5A, Section 17.2.16),
requires that measures be established to assure that conditions adverse to quality are promptly identified and corrected, and in the case of significant conditions adverse to quality, the measures shall assure the cause of the condition is determined and corrective taken will preclude repetition.
Contrary to the above, actions taken since 1992 to correct deficiencies associated with foreign material exclusion (FME) controls have not precluded repetition. On June 1 O and 17, 1994, FME cleanliness covers were either missing or not properly installed over open reactor coolant piping and on.June 22, 1994, scaffold material was found on the service water side of a *component cooling water heat exchanger.
This is a Severity Level IV violation (Supplement I).
Page 1 of 5
REPLY TO A NOTICE OF VIOLATION NRC INSPECTION CONDUCTED JUNE 1
- JULY 2. 1994 SURRY POWER STATION UNIT 1 AND 2 INSPECTION REPORTS NOS. 50-280/94-17 AND 50-281/94-17 VIOLATION A Reason for the Violation, or if Contested. the Basis for Disputing the Violation The violation is correct as stated. Valve 2-CH-212 was not secured closed within 15 minutes following the day shift makeup activity. The cause of the event was personnel error on the part of the licensed Reactor Operators (RO) who failed to adequately communicate the responsibility for closure of the valve.
The involvement of a trainee and the lack of procedural controls contributed to the failure of the ROs to communicate and to verify the proper closure of the valve.
Corrective Steps Which Have Been Taken and the Results Achieved Upon identification, valve 2-CH-212 was immediately isolated and secured.
The primary boron concentration in the Unit 2 RCS was sampled and verified to be stable and within Technical Specification limits.
The license trainees were restricted from performing in-plant training evolutions until the cause was determined and corrective actions implemented.
Operations Department management apprised the licensed operating staff of this event and reviewed with them the responsibilities and management expectations for communications and control of license trainee activities.
The Operations Department management and the Training Department reviewed with license trainees their responsibility to work under the guidance and control ot a licensed.operator. when performing in-plant tasks. During in-plant periods, a pre-job brief with a licensed operator will be expected prior to a trainee performing any evolutions.
Following the management briefing the license operator trainees were returned to the plant to complete their in-plant period training. No further problems have been experienced with trainee activities.
Unit 2 was returned to service on June 25, 1994. No further problems were experienced with cold shutdown makeup activities during the remainder of the outage.
Page 2 of 5
corrective Steps That wm Be Taken to Avoid Further Violation Procedural controls have been implemented to ensure that the dilution valve will be secured and its closure and Limiting Condition for Operation {LCO) clock formally tracked upon completion of makeup activities while the plant is in cold shutdown/refueling conditions.
The RO/SRO Training Program briefing given to trainees prior to their in-plant periods will be enhanced to emphasize the responsibilities of the trainee working under the guidance and direction of a qualified licensed individual.
Prior to each initial license trainee in-plant period, Operations management will review with the licensed operating staff, the responsibilities and management expectations for communications and* control for license trainee activities. A general pre-job brief between the trainees and the licensed individuals will be expected prior to any required training tasks being performed.
The Date When Full compliance wm Be Achieved Full compliance was achieved when 2-CH-212 was isolated and secured. The enhanced procedural controls were implemented on July 26, 1994 to ensure that the dilution valve will be secured and its closure and LCO clock tracked upon completion of makeup activities while the plant is in cold shutdown/re.fueling conditions.
The above noted enhancement to the training program briefing and the Operations Department Management briefing to the operating staff will be implemented prior to the next group of license trainees performing their initial on shift duties. The next scheduled in-plant period is September 25, 1994.
VIOLATION B Reason for the Violation. or if Contested. the Basis for Disputing the Violation Through trending of deviation reports from early 1994, a potential declining performance.standard was identified in the area *of* Foreign Material Exclusion (FME). Although the deviation reports were of minor significance individually, the trend coupled with the NRC weakness noted in IR 94-08, resulted in management requesting a Quality Assurance assessment of the FME program.
The assessment was scheduled to start in June.
On June 21, when the violation of FME program requirements in the performance of maintenance on the Component Cooling (CC) heat exchanger was discovered, management directed formation of a task team to investigate the event, determine its cause and identify corrective actions. The team was also instructed to examine the declining performance standard and determine actions for enhancing or reinforcing FME standards.
Page 3 of 5
The team determined that the foreign material left in the CC heat exchanger was the result of personnel error. The team concluded that the CC heat exchanger was an isolated example and corrective actions implemented in response to IR 92-07 are effective at dealing with foreign material exclusion (FME).
The 1992 violation resulted from inadequate implementation of programmatic controls for system close out. The corrective steps implemented in 1992 increased administrative controls for documenting the FME close outs.
The maintenance personnel, involved with the CC heat exchanger example, failed to implement the FME requirements in the maintenance procedure.
Specifically, a close-out inspection of the heat exchanger for foreign material was not performed.
The team's review of deviation reports from 1990 to 1994 determined that some of the deviations were caused by station personnel who were not involved in establishing or implementing FME control(s). The increasing trend of deviati.on reports associated with FME are indicative of inadequate sensitivity or awareness of personnel not involved in the implementation of FME control measures. Specifically, the controls were unintentionally disturbed or violated by personnel not directly involved in their implementation.
The conclusion reached by the task team was that the FME program is adequate and that a standard for identification of FME boundaries should be implemented. This will improve the identification of in place FME controls to those not directly involved in the FME Program.
Corrective Steps Which Have Been Taken and the Results Achieved The individuals involved with the CCHX event were disciplined.
The Quality Control Department increased their surveillances on FME close out inspections, performing close out inspections until the cause of the recent FME events was determined and resolved.
A task team was established to review the recent Foreign Material Exclusion (FME) incidents and to evaluate. the overall program.. The team reviewed station deviation reports* associated with FME controls for the calendar years.
1990-1994. Interviews were conducted with station maintenance and Nuclear Site Services (NSS) personnel to discuss their knowledge of the FME Program and its adequacy.
Meetings were held between Surry and North Anna personnel to discuss the adequacy of the FME procedure (VPAP-1302).
Maintenance procedures were reviewed to determine if proper FME compliance controls were required by the procedure.
The reviews and evaluations performed by the task team have concluded that the FME Program and the associated procedures are adequate to implement foreign material exclusion. A review of the deviations since 1990, indicates an adequately low threshold for submitting FME related deviations reports.
Interviews with station maintenance and NSS personnel indicate that they have Page 4 of 5
ri
~-
adequate knowledge and understanding of the FME program and a high sensitivity to FME standards. As stated above, one of the events discussed in the inspection report was the result of personnel error.
The other events discussed in the report were consistent with inadequate sensitivity or awareness of FME standards by individuals not directly involved in the implementation of FME controls.
The discussions from lessons learned from the FME events have been included in the quarterly Lessons Learned document provided to station supervision by the Human Performance Evaluation System (HPES) Coordinator.
This document provides performance information to supervision to be used in discussions with department personnel.
Corrective Steps That Will Be Taken to Avoid Further Violations Maintenance management will review the recent FME events, the FME administrative procedure VPAP-1302, and management expectations with maintenance supervision, lead I & C Technicians, Nuclear Site Services (NSS) supervision, maintenance engineers and QA personnel.
Maintenance craft personnel and NSS contractors will also review the recent FME events, the specifics of the FME Program and management expectations of FME Program controls.
Other station personnel (Health Physics, Operations, Engineering) will review FME requirements during their continuing training. This training will cover the general requirements of the FME Program as listed in VPAP-1302, Foreign Material Exclusion Program and the recent FME events.
The Station Manager has issued a memorandum to station personnel indicating management's expectations for FME compliance.
VPAP-1302, Foreign Material Exclusion Program, will be updated to standardize the posting of FME areas or the identification of FME boundaries.
The Date When Full Compliance Will Be Achieved Full compliance-was achieved when-the foreign material was removed from the CC heat exchanger and the FME boundaries for the reactor coolant piping were re-established.
Station management has reinforced FME expectations with station personnel.
VPAP-1302 will be updated to standardize the posting of FME areas and identification of FME boundaries by October 30, 1994.
Page 5 of 5