ML18153B199
| ML18153B199 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 12/27/1994 |
| From: | Ohanlon J VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 94-695, NUDOCS 9501040183 | |
| Download: ML18153B199 (6) | |
Text
VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 December 27, 1994 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.94-695 SPS/VASETSR8 Docket Nos. 50-280 50-281 License Nos. DPR-32 DPR-37 NRC INSPECTION REPORT NOS. 50-280/94-28 AND 50-281/94-28 We have reviewed your Inspection Report Nos. 50-280/94-28 and 50-281/94-28 dated December 2, 1994, and the enclosed Notice of Violation. The report identified one cited violation for failure to follow administrative procedures during the implementation of a design change.
The reason for the violation was a lack of appropriate procedural guidance for Maintenance Department implementation of Design Change Packages (DCPs). In the subsequent resident inspection, the issue of adequate maintenance work instructions for DCP implementation was raised in the installation of test jacks for Safety Injection logic testing. The corrective actions identified in the enclosed reply to the Notice of Violation will address both issues.
In addition to the violation identified in your report, several other plant assessment activities were discussed. With regard to the steam generator level oscillations, we had previously recognized the impact on operation of the plant. Through a coordinated effort of our station, corporate and NSSS supplier staffs, the affects on plant safety had been thoroughly reviewed. We maintained sensitivity to potential burdens on the operating staff and appreciate the NRC's recognition of this fact noted in the inspection report. With the recent completion of the Unit 1 steam generator cleaning outage, both units have eliminated the source of the steam generator water level oscillations.
During the Unit 1 SGCC outage, the 1 C reactor coolant seal package was replaced.
Extensive tests were performed prior to and during the outage to identify the cause of the indicated seal leakoff flows. We are in the process of undertaking a Root Cause Evaluation on the seal package removed from the pump.
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With regard to the observations of material conditions in the Unit 1 charging pump cubicles, we appreciate the inspector's comments and agree that our high standards for housekeeping were not met in the 18 pump cubicle. Auxiliary building reclamation has been a significant project at the station and we intend to maintain the standards we have achieved. Plant housekeeping remains a priority.
Please contact us if you have any questions or require additional information.
Very truly yours,
~Pew'~
James P. O'Hanlon Senior Vice President - Nuclear Attachment 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
I REPLY TO A NOTICE OF VIOLATION NRC INSPECTION CONDUCTED OCTOBER 2 - NOVEMBER 5. 1994 SURRY POWER STATION UNIT' 1 AND 2 INSPECTION REPORTS NOS. 50-280/94-28 AND 50-281/94-28 NRC COMMENT:
"During an NRC inspection conducted on October 2 through November 5, 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 6.4.D requires that procedures for maintenance operations which have an effect on the safety of the reactor be followed.
Virginia Power Administration Procedure 0801, Maintenance Program, revision 4, Step 6.10.2.b, requires that when a work instruction cannot be followed, the items shall be placed in a safe condition, work stopped, and a new or revised instruction be prepared. Maintenance work orders 272634-03 and 271507-05 required design change 92-27-3 instructions be performed on the Unit 2 B and the Unit 1 A charging pump temperature control valve positioners.
Contrary to the above, personnel did not stop work and revise the procedure or obtain a new procedure after identifying that the work instructions contained in design change 92-27-3 could not be followed. On September 2 and October 21, 1994, the design change to modify the temperature control valve positioner was completed on the Unit 2 B charging pump and the Unit 1 A charging pump, respectively. On both occasions, personnel recognized that the design change instructions could not be followed and subsequently modified the positioners utilizing a method not specified by the procedure.
This is a Severity Level IV violation (Supplement I)."
REPLY TO A NOTICE OF VIOLATION NAC INSPECTION CONDUCTED OCTOBER 2 - NOVEMBER 5, 1994 SURRY POWER STATION. UNIT 1 AND 2 INSPECTION REPORTS NOS. 50-280/94-28 AND 50~281/94&28 Reason for the Violation, or if Contested. the Basis for Disputing the Violation The violation is correct as stated. Although Virginia Power Administration Procedure (VPAP) 0801, Maintenance Program, includes guidance for situations where work instructions cannot be followed during corrective and preventive maintenance, the reason for the violation was a lack of appropriate procedural guidance for Maintenance Department implementation of Design Change Packages (DCPs). This deficiency was compounded by the detailed work instructions provided by the vendor not being directly applicable to the hardware being modified by the DCP.
DCP 92-27-3 was issued to modify the positioner for the charging pump service water system temperature control valves (TCVs). The DCP contained a section of "Special Implementation Requirements" that listed a general outline of activities to be performed on each TCV. These requirements indicated that each valve was to be modified by changing the valve positioner from reverse operating to direct operating in accordance with instructions provided in an appendix to the DCP. The instructions in this appendix were obtained by Design Engineering from the vendor.
It was subsequently determined that the instructions provided by the vendor were not applicable to the positioner being modified. The supplied instructions matched the modification kit but not the positioner.
In implementing the modification the technician determined the instructions contained in the DCP were not directly applicable. The technicians thought the instructions provided in the DCP were guidance consistent with the general nature of the "Special Implementation Requirements" section of the DCP and the recognized skill of the craft.
The technicians believed that their actions to install the positioner in accordance with the vendor drawings versus the instructions were appropriate. The technicians did not realize that the vendor manual instructions in the DCP were intended to be a detailed procedure due to lack of a governing procedure for DCP implementation. Therefore, they proceeded to troubleshoot the positioner within the skill of the craft, successfully developed an alternate method that modified how the positioner actuates, and completed the modification.
The technician notified the design engineer of the discrepancy with the modification of the positioner. The vendor was contacted and their service and engineering staff approved our technician's method of converting the positioner. The vendor agreed to revise their instruction manual accordingly. The valve operated as required during post maintenance testing and was returned to service. A field change to the DCP was issued on October 21, 1994 that incorporated the vendors revised conversion instructions and the evaluation of the positioner conversion kits.
Corrective Steps Which Have Been Taken and the Results Achieved Once identified as a procedural noncompliance, a Deviation Report was submitted on October 21, 1994.
The DCP was field changed to include the correct positioner modification instructions in the vendor manual.
The TCVs were tested satisfactorily prior to being returned to service as required in the DCP.
Maintenance supervisors reviewed the event with their craft personnel and stressed management expectations when work instructions cannot be followed. Management expectations for implementation of the STAR principle ( i.e. Stop, Think, Act and Review) were discussed.
Interim instructions were issued to all maintenance personnel from the Superintendent of Maintenance to ensure that in implementing future DCPs that:
Work orders that merely instruct the user to "Implement the DCP" are not acceptable.
Work orders and the DCPs be reviewed to ensure sufficient information is included in the work order to complete the modification.
Outage and Planning is responsible for taking the required technical and special instruction from the DCP and including it in the work order.
Subsequently, additional instructions have been issued by Station Management to suspend implementation by the Maintenance Department of additional DCPs that do not have approved station procedures until appropriate governing procedural guidance can be incorporated into maintenance program procedures.
Corrective Steps That Will Be Taken to Avoid Recurrence Guidelines for implementing DCPs by the Maintenance Department will be developed and incorporated in Maintenance program procedures prior to any DCPs without approved station procedures being worked by the Maintenance Department. These guidelines will govern the review of DCPs by Maintenance to ensure adequate implementation instructions are provided prior to the implementation of the DCP. The guidelines will include precautions outlining management's expectations when work instructions cannot be followed.
The Quality Assurance department will perform an assessment of recently completed DCPs by the Maintenance department to evaluate if the packages were completed properly.
During the January 1995 Quality Maintenance Team (QMT) sessions, the QMT Coordinator will review with craft personnel management's expected standards when work instructions cannot be followed.
- .f Maintenance and Outage and Planning personnel will be trained on the DCP implementation process and governing procedures.
The Date When Full Compliance wm Be Achieved Full compliance has been achieved. Currently, DCPs will not be performed by the Maintenance Department without approved station procedures or adequate instructions for DCP implementation.