ML18153C236
| ML18153C236 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 05/29/1990 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 90-273, NUDOCS 9006040312 | |
| Download: ML18153C236 (4) | |
Text
VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 May 29, 1990 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D. C. 20555 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 Serial No NO/ETS Docket Nos.
License Nos.90-273 50-280 50-281 DPR-32 DPR-37 NRC INSPECTION REPORT NOS. 50-280/90-14 AND 50-281/90-14 We have reviewed your letter of April 27, 1990, in reference to the NRC inspection which was reported in Inspection Report Nos. 50-280/90-14 and 50-281/90-14. Our response to the violations described in the Notice of Violation is provided in the attachment.
We have no objections to this correspondence being a made a matter of public disclosure.
If you have any further questions please contact us.
Very truly yours,
~~
W. L. Stewart Senior Vice President - Nuclear Attachments cc:
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 9006040:312 F'DR A:OOCr<
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REPLY TO NOTICE OF VIOLATION NRC INSPECTION CONDUCTED BETWEEN MARCH 4-31, 1990 INSPECTION REPORT NOS. 50-280/90-14 AND 50-281 /90-14 During the Nuclear Regulatory Commission (NRC) inspection conducted between the period of March 4-31, 1990, a violation of NRC requirements was identified.
In accordance with the "General Statement of Policy and Procedure for N RC Enforcement Actions," 10 CFR Part 2, Appendix C (1989), the violation is listed below:
Technical Specification 6.4.D requires, in part, that detailed written procedures with appropriate checkoff lists and instructions shall be followed for testing of systems and components involving nuclear safety of the station.
- 1.
Contrary to the above, the procedural requirements of Periodic Test 2-PT-23.88, Main Station Battery 28 Cell Voltage Check, dated June 26, 1989, performed on December 12, 1989, were not followed in that station battery 28 was not placed on a 135 hour0.00156 days <br />0.0375 hours <br />2.232143e-4 weeks <br />5.13675e-5 months <br /> equalizing charge and the discrepancy was not noted on the test critique sheet as required by Step 6.2.1.
- 2.
Contrary to the above, the procedural requirements of Periodic Test PT-25.3C, Emergency Service Water Pump (1-SW-P-1 C), dated October 10, 1989, performed on March 20, 1990, were not followed in that electrical readings were not taken in the location specified in Step 5.1 o.
This is a Severity Level IV violation (Supplement I).
Pursuant to the provisions of 10 CFR 2.201, Virginia Electric and Power Company is hereby required to submit a written statement or explanation to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, within 30 days of the date of this Notice. This reply should be clearly marked as a "Reply to a Notice of Violation" and should include:
(1) admission or denial of the violation, (2) the reasons for the violation if admitted, (3) the corrective steps which have been taken and the results achieved, (4) the corrective steps which will be taken to avoid further violations, and (5) the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending the response time. If an adequate reply is not received within the time specified in this Notice, an order may be issued to show cause why the license should not be modified, suspended, or revoked; or why such other action as may be proper should not be taken. Under the authority of Section 182 of the Act, 42 U.S.C. 2232, this response shall be submitted under oath or affirmation.
J.
REPLY TO NOTICE OF VIOLATION NRC INSPECTION CONDUCTED BETWEEN MARCH 4-31. 1990 INSPECTION REPORT NOS. 50-280/90-14 AND 50-281 /90-14 REPLY
( 1 )
(2)
(3)
ADMISSION OR. DENIAL OF THE ALLEGED VIOLATION:
The violation is correct as stated.
REASONS FOR VIOLATION:
- 1.
With regards to Periodic Test 2-PT-23.8B, Main Station Battery 2B Cell Voltage Check: The reason for the violation was that the technician performing the Periodic Test (PT) failed to take appropriate action upon detecting an out of specification reading. The technician also failed to annotate the discrepant condition on the PT Critique Sheet.
- 2.
With regards to Periodic Test 1-PT-25.3C, Emergency Service Water Pump (1-SW-P-1 C): The reason for the violation was that the technician supporting the performance of the periodic test had not performed the test before. The amperage measurement, considered "skill of the craft" was taken at an incorrect location where a stable current reading could not be obtained.
The fluctuating current value was averaged and recorded.
This out-of-specHication value was not questioned by the operator and technician or upon initial supervisory review.
For both of these examples, the errors were detected during system engineering review. In the first example, the error was found during post-testing technical review. For the second example, the error was identified during the system engineer's evaluation, which followed related questions by the resident inspector.
As stated in the Inspection Report, the inspectors did not consider that a programmatic problem exists in the surveillance area.
The inspectors expressed concerns however, about the level of reviews that are conducted by cognizant supervisors who approve the test results on the critique page of the completed surveillances.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED
- 1.
With regards to 2-PT-23.8B, upon discovering the discrepant condition (low cell voltage) during post-testing technical review, the system engineer verified operability of the battery based upon subsequent satisfactory performance of the PT. The person involved was disciplined for his failure to take the specified actions. Shop meetings were held to review the performance of PTs with other personnel.
(4)
- 2.
With regards to 1-PT-25.3C, the pump was declared inoperable based on the out-of specification current reading and a Limiting Condition for Operation was entered in accordance with Technical Specification 3.148. After investigation by the system engineer and identification of the problem the PT was performed again satisfactorily.
The involved personnel were counseled as to the importance of properly recording and reporting surveillance data.
A memorandum was written to Operations Shift Supervisors requiring them to advise the personnel performing PTs to report any out-of-specification or off-normal conditions during testing.
In addition, the Station Manager has promulgated a memorandum to station department heads and supervisors emphasizing the need for the following actions during surveillance testing:
Attention to detail on the part of the person performing the PT Prompt reporting off-normal conditions noted during the conduct of PTs Careful documentation of test results on the "Critique Sheet" attached to a PT.
Thorough initial review on the part of supervisory/reviewing personnel to be alert for out-of-specification results and of normal conditions and action required.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
In order to provide a means to continuously monitor each Emergency "Service Water pump's batteries, a permanent voltmeter installation is in progress. When installed, the PT's for the three Emergency Water Service Pumps (1-PT-25.3A, B, and C) will be modified to utilize the voltmeter reading in place of a clamp on ammeter reading.
The initial and continuing training programs for those personnel involved in the performance of periodic tests (surveillances) will be evaluated and modified as applicable to provide additional emphasis on adherence to procedures and documentation of off-normal conditions.
Similar training will be provided to management and other technical staff members during their third quarter 1990 continuing training.
(5)
THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVE Full compliance has been achieved.
Station management will continue to stress to personnel the need -for attention to detail in the various aspects of station operation.