ML18153D075
| ML18153D075 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 07/13/1992 |
| From: | Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| Shared Package | |
| ML18153D076 | List: |
| References | |
| EA-92-093, EA-92-93, NUDOCS 9208070025 | |
| Download: ML18153D075 (7) | |
Text
Docket No. 50-280 License No. DPR-32 EA 92-093
. JUL 1 3 1992 Virginia Electric and Power Company ATTN:
Mr. w. L. Stewart Senior Vice President - Nuclear 5000 Dominion Boulevard Glen Allen, Virginia 23060 Gentlemen:
SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY $50,000 {NRC INSPECTION REPORT NOS. 50-280/92-12 AND 50-281/92-12)
This refers to the Nuclear Regulatory Commission {NRC) inspection conducted by Mr. M. Branch on May 11 - 18, 1992, at the Surry Power Station.
The inspection included a review of the facts arid circumstances related to the discovery by your staff on May 11, 1992, that Unit 1 was operating at power with charging/high head safety injection pumps improperly configured at various times during the-period of May 1 to May 11, 1992.
The report documenting thii:;3 inspection was sent to you by letter dated May 22, 1992.
As a result of-this inspection*, a violation of NRC requirements was identified.
An enforcement conference was held on June 10, 1992, in the NRC Region II office to discuss the violation, its cause, and your GOrrective actions to preclude recurrence.
A summary of the enforcement conference was sent to you by letter dated June 19, 1992.
The violation in the enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Notice) resulted from the failure to configure Unit 1 charging/high head safety injection (CH/HHS!)
pumps prior to plant startup on May 1, 1992, so that the "A" pump would automatically operate during a design basis accident.
This condition resulted when control switches for. the CH/HHS!
pumps were aligned such that the "A" pump would trip on an undervoltage condition.
Unit 1 operated at power in an improper CH/HHS! pump configuration from 10:11 p.m. on May 1 to 10:06 a.m.
on May 7; from 5: 55 p.m. on May 7 to 9 :22 p.m. on May. 9; and fr.om 10:29 p.m. on May 9 to 9:30 a.m. on May 11 when the problem was discovered and corrected.
~5~8070025 ~20713 11W o
ADOCK 05000280 PDR
Virginia Electric and Power Company 2 -
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e JUL 1 3 *1992 The root cause of the violation was the inadequate development, review and implementation of-a procedure action request (PAR) to startup procedure 1-GOP-1.3, which failed to identify the particular CH/HHSI configurations required to meet the design
_ basis.
Step 5.3.6 of 1-GOP-1.3 originally required a specific configuration for the CH/HHSI pumps when reactor coolant temperature passed through 350 degrees F.
Due to concerns with the ventilation support system, that configuration was changed by the PAR to allow the shift supervisor*_ to direct the appropriate pump configuration so as to meet Technical Specification (TS) requirements.
When operators subsequently performed that step o:e the procedure as modified by the PAR, they failed-to lift the lead.. for the 11A11 pump under-voltage interlock that was necessary to keep the 11A11 pump operable with the 11 C11 pump in pull-to-lock.
The safety significance of this violation is that the unit was operated outside the design basis for extended periods of time from May 1 to May 11, 1992.
During a design basis accident which includes an undervoltage on the 11H11 emergency bus, the inadequate CH/HHSI pump configuration concurrent with a single failure, such as the loss of the "B" pump, would result-in the unit not having a CH/HHSI pump available for automatic *start.
These pumps supply normal reactor coolant system makeup and reactor coolant pump seal water injection as well as high head safety injection flow in an accident condition.
Therefore, in accordance with the "General Statement of Policy and Procedure for NRCEnforcement Actions, 11 (Enforcement Policy),. 10 CFR Part 2, Appendix C (57 FR 57Ql, February 18, 1992), this violation has been categorized at* Severity Level III.
The staff recognizes that immediate corrective action was taken when the violation wa.s identified.
The "A" pump was declared inoperable, the TS action requirement to be in hot shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> was entered, and the CH/HHSI pumps were properly aligned.
In addition, the Corporate Nuclear Safety staff performed a prompt review of the event, focusing primarily on control room performance, and placards were installed on the control board to caution operators with regard to CH/HHSI pump configuration.
To emphasize the importance of ensuring proper system configura~
tion and ensuring that procedural changes are thoroughly reviewed for technical adequacy and compliance with Technical Specifica-tions, I have been authorized, after consultation with the Director, Office of Enforcement, and the Deputy Executive Director for Nuclear Reactor Regulation, Regional Operations and Research, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty in the amount of $5o;ooo for the Severity Level III violation.
The base value of a civil penalty for a Severity Level III violation is $50,000.
Virginia Electric and Po~er Company 3
e JUL 1 3 1992 The escalation and mitigation factors in the *Enforcement Policy were considered.
Mitigation of so percent was warranted for identification because the.violation was identified by one.of
- your licensed operators*.
We commend the operator who identified the fact that the undervoltage lead had not been pulled, even though other operators had previously questioned the new pump alignment but were told that the controlling procedure was acceptable.
No mitigation was judged appropriate for your corrective actions.
Though your short term corrective actions, as discussed ~ove, were satisfactory, your long-term corrective action did not appear to adequately address one of the primary root causes of the event, i.e., the failure of the PAR review and approval process to identify.the inadequate procedure change..
This is especially important in light* of the commitments made*
following tbe previous enforcement action (EA 91-114).
The base civil penalty was escalated by 50 percent for licensee performance.
In particular, EA 91-114 cited the same problem involving CH/HHSI pump configuration.. The root causes of the two violations have similarities and there.should have been a high level of sensitivity to any actions associated with the CH/HHSI pumps.
Though several shift turnovers failed to identify and correct the pl.imp configuration problem, had adequate procedures (including shift turnover check lists) been put into place following the 1991 violation, the improper alignment may have been discovered during the first shift turnover.
But for your current SALP 1 rating in the operations area, the civil penalty would have been higher because of its repeat nature.. ~he other adjustment factors in the Enforcement Policy were considered and no further adjustment to *the base civil penalty is considered appropriate.
You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response.
In your response, *you should document the specific actions taken and any additional actions you plan to prevent
- recurrence.
Your response should include action to review the
- .Station Nuclear and Safety.Operating Committee. procedure change review process.
After reviewing your response to this Notice, including your proposed corrective actions and the results of future inspections, the NRC will determine whether further NRC enforcement action is necessary*_ to ensure compliance with NRC
- regulatory requirements.
In accordance with 10 CFR 2.790 of the NRC's 0 Rules of Practice,"
a copy of this letter and its enclosure will be placed in the NRC Public Document Room.
e Virginia Electric and Power Company 4 -
JUL 1 3 1992 The responses directed by this letter and the enclosed Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, Pub. L. No.96-511.
Should you have any questions concerning this letter, please contact us.
Enclosure:
Notice of Violation and Proposed Imposition of Civil Penalty cc w/encl:
E.W. Harrell Vice President - Nuclear Services Virginia Electric & Power Company 5000 Dominion Boulevard Glen Allen, VA 23060 J. P. O'Hanlon Vice President - Nuclear Operations Virginia Electric & Power Company 5000 Dominion Boulevard Glen Allen, VA 23060 M. R. Kansler Station Manager Surry Power Station P. 0. Box 315 Surry, VA 23883 M. L. Bowling, Jr., Manager Nuclear Licensing Virginia Electric & Power Co.
5000 Dominion Boulevard Glen Allen, VA 23060 cc w/encl: See Next Page Sincerely, Original signed by LAReyes/for Stewart D. Ebneter Regional Administrator
e Virginia Electric and Power Company cc w/encl con't:
Sherlock Holmes, Chairman 5 -
Board of Supervisors of Surry County Surry, County Courthouse Surry, VA 23683 W. T. Lough Virginia State Corporation Conunission Division of Energy Regulation P.O. Box 1197 Richmond, VA 23209 Michael W. Maupin Hunton and Williams P. 0. Box 1535 Richmond, VA 23212 C. M. G. Buttery, M.D., M.P.H.
State Health Conunissioner Office of the Commissioner Virginia Department of Health P. 0. Box 2448 Richmond, VA 23218 Attorney General Supreme Court Building 101 North.8th Street Richmond, VA 23219 Conunonwealth of Virginia e
JUL 1 3 1992
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e Virginia Electric and Power Company bee w/encl:
PDR SECY CA JSniezek, DEDR SEbneter, RII JLieberman, OE W'I'roskoski, OE JPartlow, NRR Fingram, PA.
Enforcement Coordinators RI, RII, RIII, _ RIV., - RV JGoldberg, OGC BHayes, OI DWilliams, OIG EJordan, AEOD EA File Day File J. Johnson, RII P. Fredrickson, RII B. Buckley, NRR
- Document Control Desk,t NRC-Resident Inspector U.S. Nuclear Regulatory Commission*
Route 1, Box 166 Surry, VA 23883 NRC Resident Inspector U.S. Nuclear Regulatory Commission Route 2, Box 78-A Mineral, VA 23117 OE RII OE:D W'I'r6skoski SEbneter JLieberman 7/
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O'l-08-92 13:55 1504 3431 Virginia Electric and Power Company bee w/encl:
POR SECY CA JSniezek, DEOR SEbneter, RII JLieberman, OE WTroskoski, OE JPartlow, NRR Fingrarn, PA Enforcement Coordinators RI, RII, RIII, RIV, RV JGoldberg, OGC BHayes, OI _
DWilliams, OIG EJordan,.AEOD EA File Day File J. Johnson, RII P. Fredrickson, RII B. Buckley, NRR Document Control Desk NRC Resident Inspector DE U.S. Nuclear Regulatory Commission Route 1, Box 166 Surry, VA 23883 NRC Resident Inspector u.s. Nuclear Regulatory Commission Route 2, Box 78-A Mineral, VA 23117 OE~
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