ML18153C855
| ML18153C855 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 12/20/1991 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 91-648A, NUDOCS 9201020121 | |
| Download: ML18153C855 (8) | |
Text
VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261
- D.ecem.ber 20, 1991 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
- REPLY TO A NOTICE OF VIOLATION (SUPPLEMENT)
Serial No.:
91-648A SPS/RCB/ETS Docket Nos.: 50-280 281 License Nos.: DPR32 DPR-37 NRC INSPECTION REPORT NOS. 50-280/91-24 AND 50-281/91-24 Per our December 4, 1991, discussion we are providing additional information with*
regard to our reply to the Notice of Violation identified in Inspection Report Nos. 50-280/91-24 and 50-281 /91-24.
Our revised response is attached, with side bars denoting the areas where the response has been supplemented.
Increased management attention has been placed_ on the use of manual operator actions.
- We are currently reassessing our position on the acceptability of manual operator actions for interim measures or mitigating actions. This assessment, which is
_ being performed with the assistance of an outside consultant, will specifically address the impact of manual actions on safety system operability.
We expect that this assessment will be completed by March 31, 1992. On.ce the assessment has been performed, we will develop a policy with regard to acceptable operator manual intervention which is consistent with the Technical Specification definition of operability.
Separately, a task team is evaluating the emergency diesel generator governor and control circuits to ensure that consistent, reliable automatic speed and
- load control are provided by the system. This task team is using consultants, as necessary, to provide additional technical expertise to assure that the previous control system setting concerns have been properly understood arid adequately corrected.
Increased management attention is also being focused on the Post Maintenance Testing Program and its implementation. The Post Maintenance Testing Program has been evaluated by Quality Assurance and Station Engineering.
Enhancements identified during this evaluation are presently being addressed, as appropriate, in accordance with the station's corrective action program.
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If you have any further questions, please contact us.
Very truly yours,
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W l-_S;~~w:X W. L Stewart Senior Vice President - Nuclear Attachment
- 1. Revised reply to Notice of Violation cc:
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 Surry Power Station
REPLY TO A NOTICE OF VIOLATION NRC INSPECTION CONDUCTED AUGUST 2-26, 1991 SURRY POWER STATION UNITS 1 AND 2*
INSPECTION REPORT NOS. 50-280/91-24 AND 50-281/91-24 NRC COMMENT:
"During a NRC inspection conducted on August 2-26, 1991, violations of NRC requirements were identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1991)~ the Nuclear Regulatory Commission proposes to impose two civil. penalties pursuant to Section 234 of the Atomic Energy Act of 1954, as amended (Act), 42 U.S.C. 2282, and 1 O GFR 2.205.
- The particular violations and associated civil penalties are set forth below:
A.
Technical Specification (TS) 3.16.B.1 requires that when the Unit's dedicated Emergency Diesel Generator (EOG) or shared backup EOG is inoperable, the operability of the other EOG be demonstrated daily, and that the inoperable EOG be returned to service within seven days or the reactor brought to a cold shutdown.
Contrary to the above,.after maintenance rendered the shared backup EOG automatic safety function inoperable on May 9, 1991,.the dedicated EDGs in Units 1 and 2 were not tested daily nor were the units placed in cold shutdown within the required seven day period. The shared backup EOG automatic safety function remained inoperable until August 2, 1991. From May 9 to August 2, 1991, Unit 1 operated without satisfying the above TS Action Statement. Unit 2 operated June 1 ahd 2, June 5 through 11 and July 2 through August 2, 1991, without satisfying the above TS Action Statement.
This is a Severity Level Ill violation (Supplement I).
Civil Penalty - $75,000.
B.
TS 3.3.B.2 requires, in part, that, if two of the three charging pumps in a unit are out of service, one of the inoperable pumps shall be restored to an operable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. If one of the inoperable pumps is not restored within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, then the reactor shall be shut down.
Contrary to the above, since 1980, Units 1 and 2 charging pumps were routinely aligned such that the "A" and "C" charging pumps in each unit were inoperable in excess of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the units were not brought to shutdown. The pumps would not automatically start during an accident that required safety injection.
with a loss. of off-site power. Recent examples when this condition existed for Unit 1 were April 26 through May 26, June 20 through August 2, and August 19 through August 21, 1991 and for Unit 2, March 8 through 30, 1991 and July 3 through 5, 1991.
This is a Severity Level Ill violation (Supplement I).
Civil Penalty - $50,000."
REPLY TO A NOTICE OF VIOLATION SURRY POWER STATION UNITS 1 AND 2 INSPECTION REPORT NOS.* 50-280/91-24 AND 50-281/91-24 ITEM A.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION
- The violation is correct as stated.
REASON FOR THE VIOLATION The dedicated Emergency Diesel Generators (EDGs) in Units 1 and 2 were not tested daily nor were the units placed in cold shutdown within the required seven-day period because station personnel were unaware that maintenance on the governor, Which had been performed on May 9; 1991, had rendered #3 EOG incapable of automatically performing its safety function and that the EOG had not received the proper post maintenance testing.
The Woodward UG-8 governor had been replaced by a team consisting of a vendor representative and appropriate Virginia Power personnel. The EOG exhibited slight load drift during return to service testing and governor adjustments were made to stabilize the drift.
Following the.se adjustments and a test run, during which the governor and load remained stable, the EOG was declared operable and returned to service.
The work order used by the team was augmented by supplementary instructions which had been approved by the Station Nuclear Safety and Operating Committee (SNSOC).
These instructions specified that Operations Department personnel be requested to perform a fast start of the EOG following governor change out. However, the post-maintenance testing (PMT) follower included in the work package did not contain the fast start requirement. Rather, it specified the normal return-to-service Performance Test (PT) which does not involve fast starting of the EOG. Accordingly, there existed a
. conflict in the work-governing documentation which went undetected by the personnel involved. Poor communications between Maintenance, Engineering, and Operations Department personnel also obscu-red the conflicting directions, and none of the parties involved recognized that a specified step had not been performed. As a result, a test
.which could have revealed the problem with the governor setting was not conducted.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED Upon identification of the cause for #3 EDG's low speed condition, its *governor was readjusted and two consecutive. fast starts were performed to verify operability.
- In addition, the #1 and #2 EDGs were fast start tested and their operability was verified.
The governor gearing and speed knobs for #1 and #2 EOG were scribed or match-marked at the 900 RPM setting (#3 EDG's gearing a*nd speed knob had been scribed earlier). A "see-through" cover plate hc1s been installed on each governor limit switch enclosure so that the scribed match-marks may be observed without cover removal.
The match-mark alignment is checked each shift to verify tt:ie proper 900 RPM setting.
Since the diesel governors' gearing and speed knobs ~ave been match-marked, monthly fast starts of the diesels have been satisfactorily completed.
- Each diesel satisfactorily reached rated speed and voltage in accordance with the performance test.
Increased management at.tention. is being applied to PMT.
Specifically, the. po_st-maintenance testing matrices for the EDGs have been revised to provide specific fast start testing requirements following governor maintenance.
The procedures for
- governor maintenance and fast start operation were upgraded. The program is also being expanded to include previously excluded areas, such as important non-safety-related equipment and Instrumentation and Control Equipment. Furthermore, both the
- Station Engineering Department and the Quality Assurance Department have conducted evaluations of the Post Maintenance Testing Program and its implementation.
The evaluations identified several areas where program enhancements could be implemented. These enhancements are being addressed through the station's corrective action program and the Corporate Level 1 Program.
The actions specified in the Corporate Level 1 are cur~ently scheduled to be completed by March 31, 1992.
The Station Manager has issued a memorandum describing the event to supervisors and department heads which emphasized the. importance of procedural compliance and attention to detail.. The memorandum also pointed out the necessity for plant operating and maintenance personnel to feel a strong sense of ownership toward plant systems and components. The importance of proper post-maintenance testing in verifying equipment operability was also stressed.
The event and its generic implications were also reviewed by senior corporate rT]anagement at recent Employee
- Update Meetings held at the station.
CORRECTIVE STEPS THAT WILL* BE TAKEN TO AVOID FURTHER VIOLATIONS Selected station personnel will receive specific training on the EOG governors in order to acquire a better understanding of the function and proper maintenance of this equipment. The governor's vendor will participate in this t~aining. In order to verify the effectiveness of corrective actions taken thus far, monthly EDG fast start testing will be conducted through December 1991. In addition, Event Review and Component Failure Analysis Teams are reviewing root causes to ensure continued EOG reliability and availability. The Failure -Analysis Team is in the process of evaluating the emergency diesel generator governor and control circuits to ensure that consistent, reliable automatic speed and load control are provided. This team is using the vendor(s) and independent consultants to reassess previous control system problems to *ensure they are understood and have been adequately corrected.
Management oversight and controls continue to be emphasized with regard to *safety-related activities. In addition to SNSOC review of off-normal evolutions, the station Management Review Board (MRB) meets routinely to assess and direct station activities. These meetings include reviews of the results of quality assurance audits and performance assessments. The MRB also reviews information discerned from analysis of station deviation trends and the status of regulatory compliance activities and implementatlon of station initiated corrective action. The focus of the meetings is on effective implementation of programs, resolution of problems, and identification of emerging issues and plans for special evolutions. A standard has been developed to provide consistent management oversight of infrequent or complex tests or evolutions that have the potential to significantly affect the margin of nu~lear safety. Detailed implementation and development of procedures have been initiated.
THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance was achieved on September 24, 1991, when operating logs were revised to require visual verification of governor match-marks once per shift.
rrEM B.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION The violation is correct as stated.
REASON FOR THE VIOLATION The violation was a result of inadequate review of the Charging Pump/High Head Safety Injection (HHSI) Pump interlocks during a design modification implemented in -
1981. At that time, it was recognized that operator intervention would be required to assure Safety Injection performance in certain pump configurations. This contingency action is addressed in the Emergency Operating Procedures (EOP). Operators w~re trained on the appropriate response in the EOPs and were also trained in the system's design and the associated interlocks. The effectiveness of the training and required operator actions have recently been revalidated on the Surry plant simulator. 0 n further review, however, it has been determined that charging pump configurations which would require such intervention were outside the design basis of the plant.
- Although the violation is correct as stated, it should be noted that only one charging pump on each unit was affected by the interlock.
When in service, each pu_mp remained available to perform its safety function and could have been started by the operators from the control room in approximately 15 seconds in accordance with the-immediate actions of the EOPs with no effect on accident analyses.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED I
The procedures governing changes to plant systems and operating philosophy have been significantly strengthened in recent years with increased. emphasis on understanding the design basis requirements and industry guidance. The Nuclear Design Control Program evolved in the early 1980's, culminating with the issuance of a Virginia Power Nuclear Design Control Manual. The specific guidelines provided in this manual and increased sensitivity on the part of those personnel responsible for preparation and review of Safety Analyses are expected to be of major value in avoiding future violations.
In addition, an Engineering Technical Bulletin has been issued by the Vice President of Engineering to Engineering personnel describing the event and emphasizing the need to ensure solutions to design issues do not inappropriately substitute manual operator actions for automatic design functions.
The process for reviewing events which have occurred at one of the Virginia Power stations for applicability at the other includes the following: 1) Significant events or issues are discussed on the daily conference calls held among _ management personnel at both stations and the corporate office, 2) In-depth reviews of significant
-events* are normally conducted by Corporate
- Nuclear Safety personnel and documented in formal reports. These assessments consider the applicability of the event causes to the other station. 3) Reports of significant events are provided to the other station and corporate management. The Station Nuclear Safety group reviews these reports to identify issues that require prompt resolution.
- 4)
The Corporate Nuclear Safety Section now performs a formal, in-depth analysis of NRC violations, Licensee Event Reports, Root Cause Evaluations, and Human Performance Enhancement Evaluations as a part of the Operating Experience Review Program; These reviews focus on the applicability of the event or incident to the other_ station.
Any recommendations resulting from the above reviews are evaluated by management!
and, if approved, are tracked to verify effective implementation.
The Unit 1 charging pumps were promptly placed in a configuration which would not require operator action. The Unit 2 pump configuration was satisfactory. Operational controls were established to pr_eclude inappropriate alignments.
A review of Emergency Operating Procedures was performed to determine if other major critical plant components relied on manual operator action in lieu of design automatic action in order to perform their intended function during a des*ign basis accident. This review identified no additional concerns.
CORRECTIVE. STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS Procedure changes will be made as necessary to ensure that the pumps are aligned in a configuration where automatic HHSI actuation capability is maintained. As plant procedures are revised through the on-going procedure upgrade process, they will be reviewed with respect to design basis requirements. We are reassessing the issue of manual operator actions with respect to safety system operability with the assistance of an outside consultant. This assessment will be completed by March 31, 1992. Once the assessment has been performed, we will develop a policy with regard to acceptable operator manual intervention which is consistent with the Technical Specification definition of operability. Our goal is the development of a policy with regard to acceptable operator manual intervention which is consistent with the
- Technical *specification definition of operability and recent NRC guidance provided by
- Generic Letter 91-18. Following policy development, appropriate training of operating and engineering personnel will be undertaken.
THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance was achieved on August 21, 1991, when the Charging/HHS! Pumps were placed in a configuration not requiring operator action.