ML20024J522
| ML20024J522 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 10/06/1994 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20024J521 | List: |
| References | |
| 50-280-94-24, 50-281-94-24, EA-94-173, NUDOCS 9410190062 | |
| Download: ML20024J522 (29) | |
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Virginia Electric and Power Company Docket Nos.: 50-280, 50-281 Surry Unit 1 and 2 License Nos.: DPR-32, DPR 37 EA 94-173 During an NRC Inspection conducted on August 7 through September 2, 1994, 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, the violation is listed below:
10 CFR 50, Appendix B, Criterion XVI, as implemented by the Operational Quality Assurance Program Topical Report (VEP-1-5A, Section 17.2.16) requires that measures be established to assure that conditions adverse to quality are promptly identified and corrected.
Contrary to the above, on June 16, 1994, established measures to assure
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that conditions adverse to quality were promptly identified and corrected, were ineffective.
Specifically, a chemical release occurred -
in containment on June 16, 1994, which resulted in a condition adverse to quality when both trains of the Auxiliary Ventilation Exhaust Filter-system were exposed to materials that degraded.the adsorption efficacy of the inplace charcoal filters.
However, sampling of the filters was not performed until June 28, 1994, for train "A" and July 28, 1994, for train "B".
This _is a Severity level IV violation (Supplement I).
r 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 U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region II, and a copy to the NRC Resident Inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a _" Reply to a Notice of Violation" and should include for each violation:
(1) the reason for the violation, or if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved.
If an adequate reply is not received within the time specified in this Notice, an order or demand for information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.
Dated at Atlanta, Georgia This 6th day of October, 1994 01 006 4 og ENCLOSURE 1 PDR
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n LIST OF ATTENDEES NRC Attendees:
S. D. Ebneter, Regional Administrator, Region II, (RII)
L. A. Reyes, Deputy Regional Administrator, RII B. A. Boger, Acting Deputy Director, Division of Reactor Projects (DRP),.RII B. S. Mallett, Acting Deputy Director, Division of Reactor Safety, RII V. M. McCree, Acting Director, Project-Directorate. II-2, Office of Nuclear Reactor Regulation (NRR)-
J. J. Hayes, Radiation Protection Branch, NRR' R. A. Benedict, Events Assessment Branch, NRR D. M. Verrelli, Chief, Reactor Projects Branch 2, DRP, RII G. A. Belisle, Chief, Reactor Projects Section 2A, DRP, RII T. R. Decker, Chief, Radiological Effluents and Chemistry Section, Division of Radiation Safety and Safeguards, RII S. G. Tingen, Resident Inspector, Surry, DRP, RII L. W. Garner, Project Engineer, DRP, RII B. Uryc, Director, Enforcement and Investigation Coordination Staff (EICS),
RII L. J. Watson,.EICS, RII C. F. Evans, Regional Counsel J. E. Beall, Office of Enforcement
- B. C. Buckley, Senior Project Manager, Project Directorate 11-2, NRR*-
- Attended by telephone conference Licensee Attendees:
J. P. O'Hanlon, Senior Vice President M. L. Bowling, Manager, Nuclear Licensing and Programs L. N. Hartz, Manager, Nuclear Quality Assurance D. A. Christian, Manager, Surry Power Station J. A. Price, Assistant Station Manager, Nuclear Safety and Licensing R. C. Allen, Supervisor, Shift Operations J. L. Downs, Superintendent, Outage and Planning R. M. Berryman, Manager, Nuclear Analysis and Fuels ENCLOSURE 2
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AGENDA e introduction J. P. O'Hanlon Management Perspective D. A. Christian Charcoal Adsorber Event J. A. Price Technical Specifications issue J. A. Price Conclusions R. F. Saunders i
Closing Comments J. P. O'Hanlon 9
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I NUCLEAR SAFETY POLICY Basic Principles Profound Respect for the Reactor Core Event Prevention Requires Conservative Application of Technical Specification Requirements 1
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NUCLEAR SAFETY POLICY Maintain Technical Specification Required Equipment at Highest State.
t of Availability Minimize Time Spent in Technical Specification LCOs Minimize Station Activities During Critical Evolutions Minimize Potential to Reduce Decay Heat Removal or Shutdown Margins Deviations From SAR Require a Safety Analysis (10 CFR 50.59)
Conservative Interpretation of Technical Specifications and Regulatory Requirements Activities Performed with Approved Procedures and Policies Line Management Continually Cognizant of Plant Conditions and Requirements i
Management. Support of Self Check Program-to Reduce Personnel l
Errors
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I 6/05/94 6/16/94 6/20/94 6/21/94 6/25194 I
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SUNDAY 0243 THURSDAY 1030 MONDAY TUESDAY 1845 SATURDAY
-Unit 2 Shut Down
- Hydrazine Concentration in Unit 2 Work Orders Removed Unit 2 On Line for SGCC Atmosphere Conservatively issued to Containment
-Containment Measured at 6 ppm; Ammonia Sample "A" Purge From Purge Measured at 30 ppm and "B" Service to Close Established
- Containment Evacuated Adsorbers Containment
- Deviation Report Submitted Hatch Doors I
1036 Started "B" Fan to Maximize Purge l
1100 Operations Contacted System Engineer Questioning Need to Sample Adsorbers. Engineering Recommended that Both Adsorbers be Sampled and Requested Operations to Secure One Fan I
Charcoal Supplier Indicated that the Measured Concentrations of Hydrazine and Ammonia Would Not Affect the Charcoal l
1830 Secured "B" Fan
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6/28/94 7/15/94 7/22/94 7/28/94 8/04/94 8/05/94 TUESDAY FRIDAY FRIDAY THURSDAY THURSDAY FRIDAY Sampled "A"
- Lab Results "A" Adsorber Sampled "B"
- Lab Results "B" Adsorber Adsorber Retumed. "A" Retumed to Adsorber.
Retumed. "B" Retumed to Adsorber Sample Service after Expedited Sample Adsorber Sample Service after was 93.43%. T.S.
Charcoal Results was 90.7%. T.S.
Charcoal Require 96%
Replacement Require 96%
Replacement Efficiency
- Efficiency
- Deviation Report
- Deviation Report Submitted Submitted
- Operability Of"B" Adsorber Questioned B" Adsorberwas Considered Operable Due to its Low Run Time 1
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INDEPENDENT ASSESSMENTRESULTS Initial Response to the Event was Thorough Nuclear Safety Oversight was Evident Principal Causes Ineffective Communications Lack of Procedural Control to Effectively implement Event Driven (With No Action Statement) Surveillance Contributing Factors Questioning Attitude of Some Plant Personnel was ineffective Ineffective Management Oversight
t STATIONMANAGEMENT PERSPECTIVE Charcoal Adsorber Sampling was Not Handled Consistent with Management's Expectations and High Standards Reasons Charcoal Adsorber Sampling Did Not -
Meet Management Expectations Lack on Ownership by Personnel Assigned to Perform Sampling Sampling Not Assigned Proper Priority Licensed Personnel Did Not Track Performance of Surveillance l
Lack of Management Follow-Up 1
STATIONMANAGEMENT PERSPECTIVE i
i Standard for Sampling Adsorbers Expeditiously Sample Affected Adsorber(s)
Management Lessons Learned Sensitivity to Compliance with Regulatory Requirements is Being Reinforced 4
Communications, Accountability, and " Questioning Attitude" are Being Enhanced i
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VIRGINIA POWER CHARCOAL ADSORBER EVENT J. A. Price Assistant Station Manager Nuclear Safety andLicensing m
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CORRECTIVEACTIONS Submit Deviation Reports Complete Perform Common Mode Failure Review Complete Evaluate Deviation Reports to Determine Reportability.
Complete Submit LER Revise Procedures to Provide Instructions for Sampling Complete
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and Testing Adsorbers Evaluate Other Event Driven (With No Action Statement)
Complete Technical Specification Surveillances and Revise l
Procedures Make a Network Entry to inform Other Utilities of this Complete Event Provide Coaching to Reinforce the Need for Clear Complete Communications and a Questioning Attitude
CORRECTIVEACTIONS Reinforce Nuclear Safety Policy and Sensitivity to Complete e
Compliance with Technical Specification Requirements
= incorporate Lessons Learned from the Unit 2 Prior to SGCC into the Unit 1 SGCC Unit 1 SGCC
. Test Additional Samples from "A"
and "B"
Samples Adsorbers to Verify Charcoal Continues to be Taken.
Within Specifications Testing Expedited
. Evaluate Technical Specifications 4.12 and 4.20 and Evaluation the Associated Licensing Basis.
Submit a
Initiated Technical Specification Change Request to Clarify any Discrepancies identified
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SAFETYSIGNIFICANCE No Safety Significance Associated with this i
Event Since the Charcoal Adsorbers' Degraded Efficiency Ratings Were Above Design Basis Requirements
SAFETYSIGNIFICANCE Applicable Design Basis Accidents (DBA) Reviewed Fuel Handling Accident -- Short Duration Release Assumes Efficiency of 70% for Removal of Elemental lodine and Methyl lodine As Tested Methyl lodine Removal Efficiency of 90.7% Demonstrates Design Requirements were Met Testing Conditions Consistent with DBA Conditions l
Loss of Coolant Accident -- Long Duration Release Assumes Efficiency of 90% for Removal of Elemental lodine lodine Released from ECCS Leakage and Assumed to be Elemental Only. ECCS Leakage is Limited by Technical Specifications At the Tested Removal Efficiency of 90.7% for Methyl lodide, Adsorber Efficiency for Removal of Elemental lodine Would be Greater Than 99 %
Testing Conditions Consistent with DBA Conditions 1
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VIRGINIA POWER TECHNICAL SPECIFICATIONSISSUE J. A. Price Assistant Station Manager Nuclear Safety andLicensing
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TECHNICAL SPECIFICATIONISSUE Issue involves Functional Testing of Reactor Protection and Auxiliary Feedwater System Automatic Initiation Instrumentation Adsorber issue and Testing issue Different Adsorber issue Caused by ineffective l
Communications and Lack of Procedural Controls Testing issues were Promptly Assessed and Timely Actions Initiated Assessments Concluded that Testing Complies with Technical Specifications Based on Review of Licensing Basis l
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CHRONOLOGY H
l 12/80 Virginia Power Submitted Letter to NRC Stating that Auxiliary Feedwater System (AFW) was Not Designed as an Engineered Safety Feature (ESF)
System Specifically with Respect to Testability and Bypass Alarm Functions 1
8/81 NRC Stated that AFW Surveillance Testing was " Acceptable" NRC Technical Evaluation Report Concurred with Virginia l
Power Position that AFW System is Not an ESF System TER Recognized that Complete Functional Testing of AFW-System is Performed Only During Refueling 9/81 Technical Specification Amendments 72/73 issued with AFW Monthly Testing Requirements
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CHRONOLOGY.
8/92 Technical Specification Review Project (TSRP) Implemented by to Engineering Department. Project Monitored by Station Level I 10/93 4
Identified Three Other Unrelated issues Where Design Permitted Complete Testing But was.not Being Performed.
These issues were Promptly Evaluated and Testing was Performed as Necessary.
One LER and Two Supplements-were Submitted i
Identified and Evaluated the Subject Surveillance issues.
Determined Circuitry was Operable and Testing was in l
Compliance with Technical Specifications as Augmented by the Licensing Basis L
9/93 Began Preparation of Technical Specification Change Request to Clarify Surveillance Requirements for Subject issues-
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CHRONOLOGY 10/93 Began Preparation of Procedures which Require More Extensive Testing when Unit Conditions Permit 12/93 Enhanced Testing Performed Prior to Start-Up From Unit 2 Maintenance Outage
CAUSE Management was not Sufficiently Sensitive to the Need for Clarifying the Technical Specifications Based on Review of the Approved Licensing Basis and Assessment of Operability, No Technical Specification Change was Required A Management Decision was Made to Clarify the Technical Specifications i
Decision was Made to Combine the Change with a
Related Technical Specification Change Which was Being Developed The Proposed Change was Placed on the Virginia Power -- Surry Top 10 List Management Perceived the Change to be a Clarification Only and did not Recognize that it was a Potential Point of Confusion The Change was Subsequently Displaced From the Top 10 List by Higher Priority items 9
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.i CORRECTIVEACTIONS Enhance Procedures to Require Testing Complete of Subject Circuits When Entering a
Mode that Permits Testing Review Existing Technical Specification Complete Clarifications to Ensure Consistency and Full Compliance with Associated Technical Specifications Submit a Technical Specification Change Submittal Request as an Enhancement to Clarify is Being the Surveillance Requirements for the Expedited Subject issues i
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SAFETYSIGNIFICANCE No Safety Significance Associated with the Technical Specification Surveillance issue Surry Design and Testing Capability Reviewed and Approved by NRC Testing is Conducted Consistent with Current Regulatory Guidance Testing is Performed to Extent Permitted by Design Circuitry is Fully Tested During Refueling l
Monthly Testing Performed in Accordance with License l
Design Requirements Circuitry is Operable and Complies with Technical Specifications
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CONCLUSIONS Maintained Compliance with Technical Specifications No Safety Significance l
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No Programmatic Breakdowns Sampling of Charcoal Adsorbers was Not Timely.
Corrective Actions have been Initiated and Most have been Completed i
Evaluation of Technical Specification Review Project Recommendations and Need for Technical Specification Changes was Timely and Based on Licensing Basis.
Technical Specification Change Request is Now Being Expedited L.
VIRGINIA POWER
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CLOSING COMMENTS J. P. O'Hanlon Senior Vice President -- Nuclear L---
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