ML20045H933
| ML20045H933 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 06/21/1993 |
| From: | Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| Shared Package | |
| ML20045H934 | List: |
| References | |
| EA-93-094, EA-93-94, NUDOCS 9307220132 | |
| Download: ML20045H933 (6) | |
See also: IR 05000338/1993017
Text
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JUN 21 1993
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Docket Nos.
50-338, 50-339
EA 93-094
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
(NRC INSPECTION REPORT N0. 50-338/93-17 AND 50-339/93-17)
This refers to the Nuclear Regulatory Commission (NRC) inspection conducted by
Mr. M. Lesser on April 16 - 23, 1993, at the North Anna Power Station. The
inspection included a review of the facts and circumstances related to actions
tak-
by operators following the Unit 2 reactor trip on April 16,.1993, in
which the automatic start function of the auxiliary feedwater (AFW) pumps was
defeated for at least 18 minutes while a valid start signal was present. The
report documenting the NRC inspection was sent to you by letter dated May 10,
1993. An enforcement conference was conducted in the NRC Region II office on
May 20, 1993, to discuss a number of potential violations, their~ causes, and
your corrt.ctive actions to preclude recurrence. This enforcement conference
was open for public observation in accordance with the Commission's trial
program for conducting open enforcement conferences as discussed in the
Federal Register, 57 FR 30762, July 10,1992. A summary of the enforcement-
conference was sent to you by letter dated May 28,~1993.
Violation A described in the enclosed Notice of Violation (Notice) involved
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defeating the automatic actuation function of'the AFW pumps. After an
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automatic reactor trip due to a main generator voltage regu'ator circuitry
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problem, all safety systems responded as designed. Approximately nine minutes
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into the event, a reactor operator defeated the automatic actuation function
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of the AFW system by placing the motor driven AFW pump switches in pull-to-
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lock and isolating steam to the turbine driven AFW pump in order to arrest the
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primary plant cooldown. At the time the pump switches were placed in pull-to-
. lock, a valid AFW pump start signal from a low-low steam generator level was
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still present. Approximately 18 minutes later, the condition was identified
by another operator as an incorrect alignment and the. AFW system was ~
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immediately returned to automatic standby.
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At the time of the reactor trip, the crew initiated Emergency Procedure 2-E-0,
Reactor Trip and Safety Injection, to stabilize plant conditions, and after
approximately three minutes transitioned to Procedure 2-ES-0.1, Reactor Trip
Response. The AFW pumps had automatically started and total AFW flow reached
1425 gpm with all throttle valves fully open as a result of a valid initiation
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9307220132 930621
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Virginia Electric and
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JUN 2 I 1993
Power Company
signal due to steam generator level decrease. This high AFW flow rate to the
steam generators caused the reactor coolant system (RCS) temperature to
decrease below the no-load value of 547'F, which was noted by the primary
plant reactor operator who alerted the Unit 2 supervisor of the condition.
The Unit 2 supervisor, intent on arresting primary plant cooldown, recognized
that AFW flow had to be reduced. The Unit I supervisor, acting as the
procedure reader, requested to read aloud the procedural steps designed to
accomplish that task. .Rather than allowing the steps to be read, the Unit 2
supervisor commenced shifting steam generator feeding from AFW to main
feedwater by giving the balance-of-plant (B0P) operator permission to secure
the AFW system at nine minutes into the event. The Unit 2 supervisor's
interpretation of the word " secure" was to close the AFW valves to stop flow.
However, the B0P operator had a different interpretation and secured the AFW
system by placing both motor driven AFW pumps in pull-to-lock and closing the
steam supply trip valves to the turbine driven AFW pump. The B0P operator
then commenced to feed two of the three steam generators through main
feedwater bypass valves and after approximately 18 minutes the primary
temperature and pressure stabilized at acceptable values.
The actions taken above did not conform with those specified in the applicable
procedure. The NRC is concerned that two licensed operators on the same crew
would fail to consult their procedures and, notwithstanding the communications
problem in securing AFW, failed to recognize the existence of a bypassed
safety system upon receipt of the annunciator alarm when the turbine driven
AFW pump was defeated. This is of particular concern considering your recent
development and distribution of the policy statement on defeating automatic
safety system actuations. The NRC is also concerned with the poor
communication between the Unit 2 supervisor and the B0P operator. This lack
of effective communication directly contributed to the defeating of the
automatic safety function of the AFW system.
Approximately 27 minutes after initiation of the event, the Unit I supervisor
observed that the AFW pump switches were in the pull-to-lock position and
notified the shift supervisor, who directed that the switches be immediately
placed in the automatic start position.
Based on the fact that the automatic
actuation function of the AFW system was defeated when the pump switches were
placed in the pull-to-lock position and the supply trip valves were closed,
the auxiliary feedwater system was inoperable and incapable of automatic
actuation as required by Technical Specifications for approximately 18
minutes.
The NRC understands that the actual safety consequence of this event was minor
because the steam generators were adequately fed and an adequate heat sink was
quickly achieved and maintained. However, as stated above the NRC considers
the failures of the operating crew to be a significant regulatory concern.
Therefore, in accordance with the " General Statement of Policy and Procedure
for NRC Enforcement Actions," (Enforcement Policy) 10 CFR Part 2, Appendix C,
this violation has been categorized at Severity Level III.
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Virginia Electric and
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Power Company
In accordance with the " General Statement of Policy and Procedure for NRC
Enforcement Actions," (Enforcement Policy) 10 CFR Part 2, Appendix C, a civil
penalty is considered for a Severity Level III violation. The base civil
penalty for a Severity Level III violation is $50,000. However, after
consultation with the Director, Office of Enforcement, and the Deputy
Executive Director for Nuclear Reactor Regulation, Regional Operations and
Research, I have decided that a civil penalty will not be proposed for this
case. The escalation and mitigation factors in the Enforcement Policy were
considered.
Escalation was warranted based on the factor of prior opportunity
to identify because your training and guidance in response to NRC Information Notice 92-47 and the two earlier events at Surry (EA 91-141 and 92-093) were
not effectively communicated to all licensed personnel. However, that
escalation was more than offset by the mitigation warranted based on the
factors of identification, corrective action, and licensee performance.
The enclosed Notice also contains Violation B, cited at Severity Level IV, for
the operator's failure to follow the established procedures. The NRC
considered combining this violation with Violation A as a Severity Level III
problem. However, in order to emphasize the particular significance with
which the NRC views the operation of a safety system without its automatic
actuation function, the violations have been cited separately.
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. After reviewing your response to this
Notice, including your proposed corrective actions and 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 " Rules of Practice," a copy of
this letter and its enclosure will be placed in the NRC Public Document Room.
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.
Sincerely,
O"Idnsi Signed Dy-
Stourt D. Ebner
Stewart D. Ebneter
Regional Administrator
Enclosure:
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Virginia Electric and
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JUN 2 l 1993
Power Company
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cc w/ encl:
M. L. Bowling, Jr., Manager
Nuclear Licensing
Virginia Electric & Power Company
5000 Dominion Boulevard
Glen Allen, VA 23060
G. E. Kane, Station Manager
North Anna Power Station
P. O. Box 402
Mineral, VA 23117
Executive Vice President
Old Dominion Electric Cooperative
4201 Dominion Boulevard
'
Glen Allen, VA 23060
Dr. W. T. Lough
Virginia Corporation Commission
Division of Energy Regulation
P. O. Box 1197
Richmond, VA 23209
William C. Porter, Jr.
County Administrator
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Louisa County
P. 0. Box 160
Louisa, VA 23093
,
Michael W. Maupin, . Esq.
Hunton and Williams
Riverfront Plaza, East Tower
951 E. Byrd Street
Richmond, VA 23219
Attorney General
Supreme Court Building
101 North 8th Street
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Richmond, VA 23219
Robert B. Strobe, M.D., M.P.H.
State Health Commissioner
Office of the Commissioner
P. O. Box 2448
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Richmond, VA 23218
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JUN 2 l 199.3
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