ML18153C022

Responds to NRC 891108 Ltr Re Violations Noted in Insp Repts 50-280/89-24 & 50-281/89-24.Corrective Actions:Individuals Involved Terminated & Radiation Area Protection Signs Installed at Selected High Radiation Area Access Points

ML18153C022
Person / Time
Site:	Surry
Issue date:	12/21/1989
From:	Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	NRC OFFICE OF ENFORCEMENT (OE), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
89-816, NUDOCS 8912270134
Download: ML18153C022 (8)

Text

• • VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 December 21, 1989 Director, Office of Enforcement Serial No.89-816 United States Nuclear Regulatory Commission NO/RJS/pmk Attention: Document Control Desk Docket Nos. 50-280 Washington, D.C. 20555 50-281 License Nos. DPR-32 DPR-37 Gentlemen:

VIRGINIA ELECTRIC POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 REPLY TO NOTICE OF VIOLATIONS We have reviewed your letter of November 8, 1989 in reference to the NRC inspections conducted from July 30, 1989 to September 2, 1989, and reported in Inspection Report Nos. 50-280/89-24 and 50-281/89-24. Our detailed response to the Notice of Violations described in the enclosure to your letter is provided

• in Attachment 1.

As discussed at the October 17, 1989, Enforcement Conference, several management initiatives have been undertaken to address underlying reasons for the above violations. Management has reemphasized line management responsibility for evaluating the effectiveness of program management and provided additional administrative support to the Maintenance Department. It is intended that line managers utilize performance-based reviews to ensure that proper knowledge of controls and practices are being provided to the plant staff, and that INPO based self-assessment criteria be developed in order to provide feedback to management.

If you have any questions, please contact us.

Very truly yours, W. L. Stewart Senior Vice President - Nuclear Attachments 8912270134 891221 F'DR ADOCK 05000280 Q PDC

• • cc: Regional Administrator U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, N.W.

Suite 2900 Atlanta, Georgia 30323 Mr. W. E. Holland NRC Senior Resident Inspector Surry Power Station

RESPONSE TO NOTICE OF VIOLATION REPORTED DURING THE NRC INSPECTION FROM JULY 30, 1989 TO SEPTEMBER 2, 1989 INSPECTION REPORT Nos. 50-280/89-24 AND 50-281/89-24 NRG.Comment:

A. 10 CFR 19.12 requires in part that all individuals working in or frequenting any portions of a restricted area shall be instructed in, and instructed to observe, to the extent within the worker's control, the applicable provisions of Commission regulations for the protection of personnel from exposure to radiation occurring in such areas.

Technical Specification 6.4.8.1.e requires that any individual or group of individuals permitted to enter a high radiation area be provided with a radiation monitoring device which continuously indicates the dose rate in the area.

Technical Specification 6.4.D. requires that radiation control procedures be followed and the company's Radiation Protection Plan, Chapter II, Attachment II-1, requires in item 2 that individuals obey posted, verbal, and written Health Physics (HP) instructions.

HP Procedure 5.3.20, Initiating, Using, Extending, and Terminating an RWP, Section 4.3.1.d, requires checkout of a survey meter and high radiation area keys for entry into a high radiation area, if required by RWP.

Contrary to the above, radiological control requirements were not complied with, in that:

1. On August 7, 1989, a contract worker gained entry to a 'locked high radiation area on the 13 elevation of Unit 2 containment by 1

circumventing radiation protection postings and barricades without checking out a high radiation area key or obtaining authorization from HP.

2. On August 9, 1989, two contract workers entered a posted high radiation area on the 27 1 elevation of the Unit 2 containment without a required radiation monitoring device which continuously indicates the radiation dose rate in the area.

This is a Severity Level IV Violation (Supplement IV).

• • RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-280/89-24 AND 50-281/89-24 A. HIGH RADIATION AREA CONTROLS VIOLATION

1. Admission or Denial of the Alleged Violation:

This violation is correct as stated.

2. The Reason for the Violation:

This violation occurred due to lack of attention to the requirements for high radiation area entry on the part of the individuals involved and in one case a disregard of high radiation area entry barriers by a single individual.

3. Corrective Steps Which Have Been Taken and the Results Achieved:

The individuals involved were terminated.

RCA work was stopped and an evaluation of the Health Physics Program High Radiation Area entry requirements was conducted. This evaluation concluded that the Health Physics program was adequate and the events were personnel related.

A plant meeting was held with station personnel to emphasize the importance of following procedures, postings, and radiological controls when working in radiological areas. Workshops were also held for first-line supervisors stressing appropriate access control supervision.

Increased emphasis has been placed on health physics issues in general employee training.

Continued emphasis is being placed on radiation worker individual responsibility.

Radiation area protection signs which automatically provide audio warnings_

and entry requirements have been installed at selected high radiation area access points.

As an enhancement, integrating alarming dosimeters have been placed on order for use by persons entering the RCA.

4. Corrective Steps Which Will Be Taken to Avoid Further Violations:

No further corrective action is required.

5. The Date When Full Compliance Will Be Achieved:

Full compliance has been achieved .

• • B.

RESPONSE TO NOTICE OF VIOLATION REPORTED DURING THE NRG.INSPECTION FROM JULY 30, 1989 TO SEPTEMBER 2, 1989 INSPECTION REPORT NOS. 50-280/89-24 AND 50-281/89-24 10 CFR 50, Appendix B, Criterion XVI, requires that measures be established to assure that conditions adverse to quality are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.

Contrary to the above, corrective action to preclude repetition of significant conditions adverse to quality were inadequate in that:

1. A Notice of Violation issued in November 1988 identified a programmatic breakdown in the controls and procedures used to maintain system foreign material exclusion. Corrective action was taken through the issuance of Maintenance Standing Order No. 88-1. This standing order stated that specific requirements were to be documented in corrective maintenance procedures relating to cleanliness controls. In addition, the standing order required that all personnel performing work that opens a safety-related system or component read and sign to acknowledge that they have read the standing order. During maintenance activities accomplished between July 30 and September 2, 1989, the above standing order requirements were not documented for work on check valves 2-SI-79, 2-SI-81, 2-SI-91, 2-SI-226, and 2-SI-241 as required to ensure foreign material exclusion was being maintained.

2. A Notice of Violation was issued in December 1988 for failure to establish adequate procedures for torquing of fasteners. Corrective action was taken through the issuance of Maintenance Standing Order No.

89-1. This standing. order stated that all torque values listed in procedures will be verified by maintenance engineering prior to torquing and that the maintenance engineer will initial the torque value in the procedure. Also, the standing order* allowed for torque value verification by telephone if the engineering representative was not on site, provided that this verification was noted on the work order or procedure. During maintenance activities accomplished between July 30 and September 2, 1989, the above standing order requirements were not documented as required for work on check valve 2-SI-91 and flow element 1-SI-FE-1946, which resulted in the valve hinge bracket bolts for 2-SI-88 and 2-Sl-91 being over-torqued during these maintenance activities.

3. A Notice of Violation was issued in August 1988 for failure to provide adequate procedures for correct assembly of flanges containing non-reversible orifices which were used for flow indication.

Corrective actions for this violation included extensive walkdowns to identify incorrectly installed orifices and issuance of a new procedure to specifically address correct orientation installation of flow orifices. During walkdowns conducted between July 30 and September 2, 1989, the flow orifice for flow element FE-1946 was discovered to be installed backwards by the NRC inspector. Additional walkdowns by the licensee determined that two additional orifices were installed backwards.

This is a Severity Level IV Violation (Supplement I).

• • RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-280/89-24 AND 50-281/89-24 B.1 FOREIGN MATERIAL EXCLUSION

1. Admission or Denial of the Alleged Violation:

The violation is correct as stated.

2. The Reason for the Violation:

The interim administrative requirements of Maintenance Standing Order No.

88-1 were not being consistently implemented. A contributing factor was lack of appropriate management controls in that a station administrative procedure governing the use of maintenance standing orders did not exist.

3. Corrective Steps Which Have Been Taken and the Results Achieved:

A meeting was conducted with maintenance personnel emphasizing the importance of adhering to administrative and procedural requirements.

Maintenance standing orders will no longer be used.

An administrative procedure revision was completed, patterned after an INPO Good Practice, which replaced the requirements of Maintenance Standing Order No. 88-1.

As a long-term enhancement, foreign material exclusion requirements are being identified in maintenance procedures during the course of the ongoing procedure upgrade program (Ref. VEPCO Ser. No.88-387 dated July 13, 1988).

4. Corrective Steps Which Will Be Taken to Avoid Further Violations:

Maintenance personnel will be trained on the requirements of the revised foreign material exclusion program.

5. The Date When Full Compliance Will Be Achieved:

Maintenance personnel will be trained on the requirements of the revised foreign material exclusion program by January 31, 1990 .

RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-280/89-24 AND 50-281/89-24 B.2 TORQUING CONTROL

1. Admission or Denial of the Alleged Violation:

The violation is correct as stated.

2. The Reason for the Violation:

The interim administrative requirements of Maintenance Standing Order No.

89-1 were not being consistently implemented. A contributing factor was lack of appropriate management controls in that a station administrative procedure governing the use of maintenance standing orders did not exist.

3. Corrective Steps Which Have Been Taken and the Results Achieved:

A meeting was conducted with maintenance personnel emphasizing the importance of adhering to administrative and procedural requirements.

Maintenance standing orders will no longer be used.

The Torque Manual was revised, updated and issued as a station administrative procedure. If a torque value is required which is not specified, a verified torque value must be obtained from Engineering per the Torque Manual requirements.

Maintenance procedures have been reviewed and revised as necessary to verify correct instructions for torquing are provided.

4. Corrective Steps Which Will Be Taken to Avoid Further Violations:

Maintenance shop training sessions will be held to review the requirements of the torquing program with appropriate maintenance personnel.

5. Date When Full Compliance Will Be Achieved:

Maintenance shop sessions will be held to review the requirements of the torquing program with appropriate maintenance personnel by January 31, 1990 .

\ .

RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-280/89-24 AND 50-281/89-24 B.3 FLOW ORIFICE

1. Admission or Denial of the Alleged Violation:

The violation is correct as stated.

2. The Reason for the Violation:

The violation occurred due to personnel error in installation.

3. Corrective Steps Which Have Been Taken and the Results Achieved:

FE-1946 was returned to its proper orientation.

A meeting was conducted with maintenance personnel emphasizing the importance of adhering to administrative and procedural requirements.

The maintenance procedure for orifice removal and installation was revised to require QC verification of proper orifice installation.

Engineering performed a walkdown of those flow elements for which improper orientation could affect their indication and not be readily detected. No additional orifices beyond the two referenced in the violation were identified to be reversed. These two were evaluated to be acceptable as installed.

4. Corrective Steps Which Will Be Taken to Avoid F~rther Violations:

No further corrective action is required.

5. The Date. When Full Compliance Will Be Achieved:

Full compliance has been achieved.