ML18153C379

Suppls Response to Violations Noted in Insp Repts 50-280/90-21 & 50-281/90-21.Corrective Actions:Importance of Prejob Briefs Stressed & Will Be Emphasized by Plant Mgt

ML18153C379
Person / Time
Site:	Surry
Issue date:	09/28/1990
From:	Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
90-467A, NUDOCS 9010090059
Download: ML18153C379 (3)

Text

VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 September 28, _1990 United States Nuclear Regulatory Commission Serial No. *90-467A

. Attention: Document Control Desk

• NO/WRB

. Washington, D. C. 20555 Docket Nos. 50-280 50-281 License Nos. DPR-32 DPR-37 Gentlemen:

VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 NRC INSPECTION REPORT 50-280/90-21 AND 50~281/90-21 SUPPLEMENTAL INFORMATION Violation 50-280/90-21-01 was considered to be a repeat violatio*n concerning a failure to follow procedures during the performance of a periodic test on a turbine-driven auxiliary feedwater pump. The violation was identified by Virginia Electric and Power Company and resulted from personnel error. In our response to this violation (Serial No.90-467 dated August 22, 1990), we stated that our evaluation concluded that the violation was an isolated incident. We concluded thar the ongoing programmatic corrective actions initiated after the original violation coupled with the actions identified in the recent response are proving effective in terms of improving procedural utilization at Surry. The purpose of this letter is to further discuss the programmatic corrective actions as well as other specific actions directed toward improving procedure compliance as a supplement to the response.

Following the August 1, 1989 occurrence of this violation, the Superintendent of Operations communicated the details of the infraction (i.e,. the deviation, safety concerns, the violation and associated corrective actions) to Operations Department personnel. The Superintendent of Operations also reviewed the significance of the repeat nature of the recent violation at a periodic meeting held with Operations supervisory personnel.

The importance of pre-job briefs has been stressed and continues to be emphasized by plant management. A pre-job briefing is held prior to any test or evolution involving equipment which is safety-related or important to safety. Involved personnel are required to review the applicable procedure so that they fully understand what actions are required and.are cognizant of the limitations and precautions associated with the activity. Communications requirements are also identified during the pre-job brief.

Training programs for Operations Department personnel are now designed to continually emphasize the importance of procedure compliance and pre-job briefs.

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Training programs for other departments, as well as General Employee Training, place emphasis on procedure compliance. Station Management notifies persc;rnnel of

. procedure violation incidents and the need for strict attention to detail in periodic station-wide employee update meetings. As the result of a recent Quality Assurance audit follow-up review, the Station Manager or an Assistant Station Manager will participate in the monthly General Employee Retraining to provide further emphasis of employee accountability for procedure utilization. In addition, the third quarter 1990 technical staff and manager training included presentations on procedure adherence.

Following the most recent occurrence oJ the violation, the Station Manager issued a directive to station supervisors stating the need to continually stress proper procedure utilization. The memorandum communicates four key rules for effective procedure utilization: (1) understand the procedure prior to implementation, (2) question or clarify inadequate or incomplete procedure guidance, (3) review impact on safety .

systems and instrumentation, and (4) adhere to a procedure while performing work.

The Station Manager again stressed the importance of prejob briefs as an aid to achieving effective procedure utilization. As part of the ongoing evaluation of our

• training programs, these rules will be reviewed to ensure that they are adequately covered during initial and periodic retraining for Operations and other areas.

Other station initiatives are directed, at least in part, toward improving procedure compliance. The technical procedure upgrade program is improving the technical content of procedures as well as applying human factors principles to minimize

.. opportunities for error. Performance-based assessments by the Quality Assurance Department provide station management with indicators .of the level of. compliance and

• the effectiveness of implementation of procedures and programs.

As a further example of station management's commitment to promptly assess and act on operational incidents, including assessing for procedural performance concerns, a special performance assessment of several operational events was undertaken in August, 1990. The goal of the assessment was to determine if a common thread such as a lack of procedure compliance was evident in the events. The assessment concluded that no common thread existed. The assessment also reinforced previously identified actions which are underway to stress intra and interdepartmental communication and attentiveness to job tasks.

Station deviation reports are examined to evaluate trends in personnel errors which are reported to management for corrective action. Review of completed periodic tests by system engineers has resulted in the identification and correction of discrepancies in the execution of test procedures. This review program has been cited as a strength by the NRG and was the mechanism whereby Violation 280/90-21-01 was identified.

Ro.ct cause evaluations and the Human Performance Enhancement System (HPES) are utilized to determine the underlying causes of personnel errors and to develop corrective actions to prevent recurrence.

• Most importantly, we believe that an improved safety attitude has been developed throughout the station staff. Sensitivity toward off-normal conditions such* a.s equipment out of service and procedural non-compliance has increased and conservative corrective actions are initiated when required.

In summary, the violation is considered an isolated* incident. Aggressive action has been and continues to be taken to enhance the safe operation of Surry Power Station.

Many of these initiatives are contributing to the identification and correction of procedure problems and enhancement of personnel performance.. The program is flexible and management is attentive to trends and taking appropriate actions. Our commitment to reduce human errors to the lowest possible level will continue to be of the highest priority.

Please contact us if you have any questions.

truly a

/'

St~wart

• 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. Holiand NRC Senior Resident Inspector Surry Power Station