ML18153C036
| ML18153C036 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 12/28/1989 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 89-837, NUDOCS 9001080162 | |
| Download: ML18153C036 (4) | |
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- VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261
- December 28, 1989 United States Nuclear Regulatory Commission Attention: Document Co.ntrol Desk Washington, D. C. 20555 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY
- SURRY POWER STATION UNITS 1 AND 2 RESPONSE TO "NOTICE OF VIOLATION Serial No, NUCGL:vlh Docket Nos.
License Nos.
NRC INSPECTION REPORT NOS. 50-280/89-31 AND 50-281 /89-31 89-837 50-280 50-28.1 DPR-32 DPR-37 We have reviewed your letter of November 28, 1989 in reference to the inspection conducted at Surry Power Station on October 1 through 28, 1989 and reported in Inspection Reports 50-280/89-31 and 50-281/89-31. Our response to the Notice of
- Violation (applicable to Unit 2) is attached.
We have no objection to this correspondence being made a matter of public record.
If you have further questions, please contact us.
Very truly yours, A'--~~ J)-=> vi,'\\__
Vt,. L Stewart nior Vice P*resident - Nuclear Attachment 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
.,t'*
- RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-280/89-31 AND 50-281/89-31 DESCRIPTION OF VIOLATION During the Nuclear Regulatory Commission (NRC) inspection conducted between the period of October 1 to October 28, 1989, a violation of N RC requirements was identified.
In accordance with the "General Statement of Policy and Procedures for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1989), the violation is listed below:
A.
Technical Specification 6.4 requires, in part; that detailed written procedures with appropriate checkoff lists and instructions shall be provided* and followed for operations and testing of systems and components involving nuclear safety.
Contrary to the above, procedures and instructions were not followed in that the following:
- 1.
On October 8, 1989, testing of Unit 2 train B auxiliary feedwater pu*mp 2-FW-P-3B was not performed in accordance with periodic test procedure 2-PT-15.1 B resulting in an inadvertent isolation of the train A pump, 2-FW-P-3A..
- 2.
On October 25, 1989, licensed operators failed to comply with procedure 2-0P-5.1.1 and previous training instructions resulting in an unplanned dilution of the Unit 2 reactor coolant system without proper establishment
- of
- containment integrity, a violation of Technical Specification 3.8.A.6.
This is a Severity Level IV violation (Supplement I) and applies to Unit 2 only~
RESPONSE
(1)
Admission or Denial of the Alleged Violation A.1 The violation is correct as stated.
A.2 The violation is correct as stated.
(2)
Reasons for Violation
,A.1 Inadvertent isolation of the train A auxiliary feedwater pump.
- The failure to follow the procedure, which resulted in the incorrect auxiliary feedwater pump valve alignment, was an individual performance problem. A pre-job brief had been conducted, the same periodic test had. just been satisfactorily performed on the other unit, and the procedure being used was adequate; however, the operator did not correctly follow the approved procedure.
RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-280/89-31 AND 50-281/89-31 *
(CONTINUED)
A.2 Unplanned dilution of the RCS without proper establishment of containment integrity.
- Not establishing containment integrity during the initial boron dilution event was due to a misinterpretation of the Technical Specification by the SRO jnvolved. The RO and SRO erroneously thought that it was acceptable to return RCS boron concentration from 2300 ppm to the initial concentration of 2127 ppm without establishing containment integrity.
Both the initial and subsequent boron dilution events were due to failure of the operators to operate the blender in accordance with approved procedures.
The oncoming shift failed to verify the concentration of the blender makeup and blender settings when first informed of the RCS dilution.
(3)
Corrective Steps Which Have Been Taken and the Results Achieved A.1 Inadvertent isolation of the train A auxiliary feedwater pump.
The i'ndividual and his supervisor were removed from shift duties in accordance with normal statiqn procedures. An investigation and review of the incident were completed, and the individuals were reinstructed in appropriate adherence to procedures.
A.2 Unplanned dilution of the RCS without proper establishment of containment integrity.
When the error in the blender setting was discovered, the blender was properly set up using the nomographs to match RCS boron concentration.
Sampling of the RCS was continued to verify that the dilution had been stopped.
Operation of the blender system is considered a "skill of the craft." This designation means that a task is so routine that it may be performed by a licensed operator without the use of detailed procedures. As a result of the errors made in these evolutions, operators were instructed to commence using the written. procedure for blender operations on an interim basis. After a period of approximately eight weeks, blender operations as "skill of the craft" were resumed on December 5, 1989.
Licensed operators were also reminded by memorandum that containment integrity must be set prior tp dilution of the RCS.
RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-280/89-31 AND 50-281/89-31 (CONTINUED)
(4) Corrective Steps* Which Will Be Taken to Avoid Further Violations The shift briefing at the beginning of each shift and the pre-job briefs that are performed prior to significant evolutions, including Periodic Tests, will continue to
- reinforce the importance of adherence to procedures.
The Licensed Operator Retraining Program (LORP) and the Non-licensed Operator Continuing Training Program (NLOCTP) will continue to emphasize adherence to procedural requirements.
(5) The Date When Full Compliance Will Be Achieved Full compliance has been achieved on the examples cited in this Notice of Violation. Continued emphasis on procedural adherence and attention to detail will be necessary to avoid further violations of this nature.