ML18153D095

Responds to Violations Noted in Insp Repts 50-280/92-12 & 50-281/92-12 & Forwards Payment of Civil Penalty in Amount of $50,000.Corrective Actions:Standing Order,Governing Control of Undervoltage Trip of Charging Pump A,Issued

ML18153D095
Person / Time
Site:	Surry
Issue date:	08/12/1992
From:	Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	NRC OFFICE OF ENFORCEMENT (OE), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
92-475, NUDOCS 9208180215
Download: ML18153D095 (6)

Text

VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 August 12, 1992 Director, Office of Enforcement Serial No.: 92-475 U. S. Nuclear Regulatory Commission SPS/RCB/GDM R9 Attn.: Document Control Desk Docket Nos.: 50-280 Washington, D. C. 20555 50-281 License Nos.: DPR-32 DPR-37 Gentlemen:

VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 REPLY TO A NOTICE OF VIOLATION NRC INSPECTION REPORT NOS. 50-280/92-12 AND 50-281 /92-12 We have reviewed your letter dated July 13, 1992 which forwarded a Notice of Violation and a proposed imposition of a $50,000 civil penalty. Our reply to the Notice of Violation and a check for the payment of the civi.1 penalty are provided as attachments to this letter..

We concur that the configuration of the charging/high head safety injection pumps which led to the current violation was similar to that for which we were cited in NRC Inspection Report 91-24. However, we would like to reiterate that the two violations do not have similar root causes. The earlier violation occurred because manual operator intervention was accepted as an alternative to automatic action, whereas the second violation resulted from the inadequate development and . implementation of a procedure change.

• Station management sensitivity, at all levels, to adequately controlling the change process has been increased. Currently, a comprehensive review of the change control process is in progress at the station to evaluate management involvement and control. Any we_aknesses or shortfalls identified during this review will be evaluated, and appropriate enhancements will be made within the various programs that govern changes to procedures, programs, or plant systems. This review will be completed in September 1992 and briefed to the NRC resident inspectors .

• *9200100215 PDR G

ADOCK 6~ggb~eo PDR

• • • We have no objections to this reply being disclosed to the public.

If you have any further questions, please contact us.

Very truly yours,

~

q.Pcy/a..vJL-.

y W. L. Stewart . *

• Senior Vice President - Nuclear Attachments:

1. Reply to the Notice of Violation

2. Check for payment of the Civil Penalty Copy to: 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

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REPLY TO A NOTICE OF VIOLATION NRC INSPECTION CONDUCTED MAY 11-18, 1992 SURRY POWER STATION UNITS 1 - AND 2 INSPECTION REPORT NOS, 50-280/92-12 AND 50-281/92-12 NRC COMMENT:

During an NRC inspection conducted on May 11-18, 1992, a violation of NRC requirements was identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (57 FR 5791, February 18, 1992), the Nuclear Regulatory Commission proposes to impose a civil penalty pursuant to Section 234 of the Atomic Energy Act of 1954, as amended_ (Act),

42 U.S.C. 2282, and 10 CFR 2.205. The particular violation and associated civil penalty are set forth below:

Technical .Specification 3.3.B.2 requires, in part, 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 />, theri the reactor shall be shut down.

Contrary to the above, between May 1 and May 11, 1992, the charging pumps for Unit 1 were routinely aligned such that the "A" and "C".charging pumps 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 unit was not brought to shutdown.

This condition existed from about 10:11 p.m. on May 1, 1992 to 10:06 a.m. on May 7; from 5:55 p.m. on May 7, 1992 to 9:22 p.m. on May 9; and from 10:29 p.m. on May 9 to 9:30 a.m. on May 11.

This is a Severity Level Ill violation (Supplement I).

Civil Penalty - $50,000

REPLY TO A NOTICE OF VIOLATION NRC INSPECTION CONDUCTED MAY 11-18. 1992 SURRY POWER STATION UNITS l AND 2 INSPECTION REPORT NOS. 50-280/92-12 AND 50-281/92-12 Admission or Denial of the Alleged Violation The violation is correct as stated.

Reason for the Violation The violation resulted from the inadequate* preparation and implementation of a change to a startup procedure. Because of concerns which arose from an earlier Notice of Violation (NRG Inspection Report 50-280,281/91-24) that also involved charging pump alignment, the station had implemented a design change to simplify charging pump operation. This change directed placing the three charging pumps in the automatic mode, thus eliminating a previous restriction that no more than two pumps be in the automatic mode. Operators were trained on this new alignment and were expecting it to be in place when Unit 1 was restarted following the refueling

• outage.

Prior to startup, station engineering personnel determined that the ventilation system needed to be tested prior to implementing the design change to verify the ability of the system to adequately ventilate the charging pump cubicles with the new pump alignment. Station management decided to perform the ventilation test after startup, and the previously referenced startup procedure was changed to return to the original pump alignment until ventilation testing could be completed. The change permitted Shift Supervisor discretion with regard to charging pump alignment pending validation of the ventilation system. Various charging pump manipulations were conducted during the startup process, and a pump alignment was inadvertently established which rendered the system vulnerable to a single mode failure. This configuration, which should have mandated entry into a twenty-four-hour Technical Specification action statement to shut do_wn for Unit 1, went undetected during several periods of critical plant operation between May 1 and May 11, 1992. Since the charging pump configuration was different from the alignment discussed in operator training, several operators in the control room questioned the charging pump alignment. However, an in-depth investigation was not conducted until May 11, 1992 when the improper configuration was discovered .

..... - ----=-

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Corrective Steps Which Have Been Taken and the Results Achieved Upon discovery of the improper alignment, the Unit 1 charging pumps were immediately placed in- a configuration which comp1ied with the Technical Specifications, and the Unit 2 charging pump configuration was verified to be satisfactory. A Root Cause Evaluation (RCE) was conducted for this incident and provided corrective actions. The following corrective actions recommended by the RCE were implemented: *

• A Standing Order governing control of the undervoltage trip of the "A" Charging Pump was issued pending procedure revision. * * *

• The Control Room Minimum Equipment List was updated to address the "A" Charging Pump undervoltage configuration.

• "Caution" tags were placed o"n the main control boards.

• Applicable procedures were revised to specify proper pump configuration.

• Operating shifts were briefed on the event by station management.

These corrective steps assure that the charging pumps will remain in their proper

.configuration. Testing of the ventilation system to verify that the system could adequately ventilate the charging pump cubicles has also been performed, and the units are currently operating with the three charging pumps out of pull-to-lock.

Also, the policy on the *use of manual operator action in lieu of automatic initiation has been issued, and Quality Assurance management personnel are currently attending the Station Nuclear Safety and Operating Committee (SNSOC) meetings to monitor the change management process and the possible impact of changes being considered.

• Corrective Steps That Will be Taken to Avoid Further Violations As a result of this event, management sensitivity to the change control issue has been increased. Station management has initiated a review of the various processes which change or modify procedures, programs, or plant systems. The purpose of this review is to assure these processes receive adequate management oversight and that proper administrative controls are established. Included in these controls will be determination of ownership, accountability for change approval, and coordination among the various organizations involved with change. The responsibilities of SNSOC in the procedure change review process will be reviewed as part of this effort.

Upon completion of this review, an action plan will be developed to implement corrective actions identified and strengthen management* control over the change process .

' * * . Training on the policy on use of operator action in lieu of automatic initiation is in progress for SNSOC members and alternates, operating shifts, selected engineering groups, and procedure writers. This training is being conducted by the Assistant .

Station Manager for Nuclear Safety and Licensing to appr~se cognizant personnel of the provisions of the policy and their responsibilities with regard to these provisions.

The Date When Full Compliance Will be Achieved Full compliance was achieved on May 11, 1992, when proper pump configuration was restored. *

• An action plan to enhance the station's change control process will be implemented following the change control. review described above. Completion of the review is scheduled by September 30, 1992.

Training on the operator action policy is scheduled to be completed by September 30, 1992.