ML18153B381
| ML18153B381 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 11/19/1993 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 93-712, NUDOCS 9312020467 | |
| Download: ML18153B381 (4) | |
Text
VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 November 19, 1993 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 REPLY TO A NOTICE OF VIOLATION NRC INSPECTION REPORT NOS. 50-280/93-23 AND 50-281 /93-23
- Serial No.:
SPS/RCB/ETS Docket Nos.:
- License Nos.:
.93-712 R1 50-280 50-281 DPR-32 DPR-37 We have reviewed your Inspection Report Nos. 50-280/93-23 and 50-281/93-23 dated October 28, 1993, and the enclosed Notice of Violation. We share your concern over the nature of the cited violation and recognize that lapses in strict procedural compliance can result in conditions adverse to quality. As described in the attached reply to the notice of violation, we have evaluated the circumstances which led to the violation. Based on our.
eva*luation, we revised our tagging policy which we believe will significantly reduce the potential for similar problems.
Should you have any questions or comments, please contact us.
Very truly yours, qPOyJ~~
{a r w. L. Stewart Attachment cc:
Regional Administrator U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, N. W.
Suite 2900 Atlanta, Georgia 30323 Mr. M. W. Branch NRC Senior Resident Inspector su*rry Power Station 9312020467 931119 PDR ADOCK 05000280 P
REPL V TO A NOTICE OF VIOLATION NBC INSPECTION CONDUCTED SEPTEMBER s -OCTOBER 2, 1993 SURRY POWER STATION UNITS 1 AND 2 INSPECTION REPORT NOS. 50-280/93-23 AND 50-281/93-23 NRC COMMENT:
During a NRC inspection* conducted on September 5 through October 2, 1993, a violation of N RC requirements was identified.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violation is listed below:
1 O CFR 50, Appendix B, Criterion V, as implemented by Operational Quality Assurance Program Topical Report (VEP 1-5A, Section 17.2.5) requires, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
. Operations Program Administrative Procedure (OPAP)-0010, Tag-Outs, dated March 1; 1993, requires tagging records to be established and implemented and the qualified operator, assigned the task of independent verification, shall verify alignment of the components listed on the tagging record. Tagging record number (S)1-93-EP-0053 was established on September 28, 1993, to prescribe removal of fuses, 1-EP-FUSE-EH-14H1-6 and 1-EP-FUSE-EJ-14H1-6, on safety-related load center 1 H1.
Contrary to the above,_ on September 28, 1993, activities affecting quality were not.
accomplished in accordance with prescribed instructions, in that, fuses 1-EP-FUSE-EH-14H-6 and 1-EP-FUSE-EJ-14H-6 were removed in place of the specified fuses and the components' alignment was not properly independently verified. As a result, the A train Low Head Safety Injection Pump supply breaker trip circuit and the A train Inside Recirculation Spray Pump supply breaker closing circuit were rendered inoperable for several minutes.
This is a Severity Level IV Violation (Supplement I).
(1)
REPLY TO A NOTICE OF VIOLATION
- NBC INSPECTION CONDUCTED SEPTEMBER 5 - OCTOBER 2. 1993 SURRY POWER STATION UNITS 1 AND 2 INSPECTION REPORT NOS. 50-280/93-23 AND 50-281/93-23 Reason for the Violation, or, If Contested. the Basis for Disputing the Violation The Station electricians who were assigned the task of removing fuses misidentified the circuit breaker to be defused and, as a result, removed the wrong fuses. A number of factors were identified which contributed to the error.
Self-checking and independent verification of the work was not properly performed. Specific examples include:
The Tag Out Request and Tagging Record were not compared for possible disagreements/errors.
Station drawings were not used to verify fuse location.
None of the personnel who were most familiar with the task, i.e., those who had researched, reviewed, or approved the Tag-Out, accompanied the electricians to the job site.
The fuses which were removed were rated at 15 amps rather than the -
anticipated 30 and 35 amps. However, contrary to station policy and training, no follow-up investigation was initiated.
The station electricians involved in this event were qualified to perform duties normally assigned to their craft, such as lifting of leads, removal of fuses, installation of grounding devices and ground placement tags. They had not, however, been adequately trained or properly qualified to install and verify electrical danger tags.
An administrative error in preparing the Tag Out Request identified the breaker location as 14H-6 rather than the correct location of 14H1-6.
Although this error was corrected on the Tagging Record, the electricians performing the task erroneously used the Tag Out Request to identify the breaker. By procedure, personnel placing or removing tags are required to have a copy of the Tagging Record with them in the field.
The electricians performing the task may have rushed to complete the job since they were nearing the end of their assigned work shift and perceived a sense of urgency in completing the work.
l (2)
(3)
Corrective Steps-Which Have Been Taken and the Results Achieved Immediately upon discovering the discrepancy in the indicating lights for the Low Head Safety Injection Pump, corrective action was taken to reinstall the fuses.
This action returned the "A" Low Head Safety Injection Pump and the "A" Inside Recirculation Spray Pump to full operability. The discrepant condition existed for approximately 30 minutes.
Corrective Steps That Will be Taken to Avoid Further Violations As a result of this event and the similar occurrences in the past, Station Management directed a review of tagging practices to determine how current policies could be strengthened.
After the review, it was determined that, henceforth, only Operations Department personnel will hang or remove electrical or mechanical danger tags. The station tagging policy was subsequently revised.
(4)
The Date When Full compliance wm be Achieved Full compliance was achieved when the incorrectly removed fuses were replaced and the affected equipment was restored to full operability.
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