ML20064L412
| ML20064L412 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 06/09/1982 |
| From: | Leasburg R VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | Deyoung R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| Shared Package | |
| ML20064L415 | List: |
| References | |
| 301, NUDOCS 8206160306 | |
| Download: ML20064L412 (4) | |
Text
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t June 9, 1982 USNRC REGDN ".'
A_ ANT A. GECPGL.
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- 4" 02 'pjH IfESIGNATED ORIGINAD V
Certified By mM-)R
-_ m United States Nuclear Regulatory Commission Serial No. 301 Attn: Mr. Richard C. DeYoung, Director N0/RMT:acm Office of Inspection and Enforcement Docket No. 50-280 Washington, D.C. 20555 License No. DPR-32 Gentlemen:
We have reviewed your letter of May 10, 1982 in reference to the inspection conducted at Surry Power Station on February 23 and 24, 1982 and reported in IE Inspection Report No. EA 82-58. Our response to the specific infraction is attached.
While we accept full responsibility for this incident, we believe further consideration should be given by the NRC to the following two items.
(1) This incident was discovered and promptly reported by VEPCO.
(2) The NRC agreed with our earlier actions regarding the August, 1980 incident which caused a 25 percent increase in the civil penalty. The preventive measures implemented as a result of that incident were prudent measures and could be reasonably expected to prevent items in the future.
The preventive measures were vigorously implemented.
We believe the above two items, properly considered by the NRC should cause remission or mitigation of the penalty. We would be pleased to discuss this further if necessary.
We have determined that no proprietary information is contained in the report.
Accordingly, the Virginia Electric and Power Company has no objection to this inspection report being made a matter of public disclosure. The information contained in the attached pages is true and accurate to the best of my knowledge and belief.
Very t ul ours R. H. Leasburg Enclosures i
- 1. Response to Notice of Violation
- 2. Voucher Check No. 23825 in payment of Civil Penalty cc: Mr. James P. O'Reilly Regional Administrator, Region II l
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Attachmint Serial No. 301 RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-280/82-58 NRC COMMENT Technical Specification 6.4.D requires the licensee to follow procedures established in compliance with Technical Specifications 6.4. A. Procedure 5.2 of Section 14 of the Quality Assurance Manual was established to implement 6.4.A.
Paragraph 5.2.2 of this procedure requires that jumpers not controlled by an approved procedure shall not be used anywhere in the station without the,
Shif t Supervisor's prior knowledge and approval.
Technical Specification 3.7.B requires the licensee to have an operable high steam flow channel in each main steamline when the reactor coolant system temperature is above 543*F.
Contrary to the above, on February 21, 1982 the licensee did not implement procedure 5.2 of Section 14 of the approved Quality Assurance Manual in that fuses were pulled without the benefit of an approved procedure and without the knowledge and approval of the Shift Supe rvisor.
Jumpers as used in this procedure include, but are not limited to electrical lif ted leada.
In this instance, the removal of fuses is considered the equivalent of lifting electrical leads. As a consequence Unit I was operated, between 4:00 p.m. on February 21 and 2:45 a.m. on February 22, without an operable high steam flow channel in "A" main steamline when the reactor coolant system temperature was above 543*F.
This is a Severity Level III Violation (Supplement I)
(Civil Penalty - $50,000)
_ PEEP 0NSE:
1.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION:
The violation is correct as stated.
It is important to note that the error in each case was licensee identified before the reactor had reached the power range and the absence of the fuses would have been self-disclosing.
Immediate caYrective action was taken. Additionally, the incident resulted from failure to follow procedures which had been modified to preclude such an event.
In light of the above, Vepco considers these events not to be symptomatic of basic flaws in the Safety Program but rather isolated occurrences admittedly similar in nature.
2.
REASONS FOR VIOLATION:
The violation is resultant from an individual's failure to follow procedural controls.
3.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:
Subsequent to this event additional procedural centrols were implemented to 1) clarify the requirement for using approved jumpers for pulled fuses.
and 2) include a pre-start up checklist to be performed by an Instrument Supervisor which verifies proper alignment of all reactor protection and engineered safeguards instrumentation.
In addition, emphasis on procedural compliance has been stressed to all station employees. These
Attcchrant Page 2 Se7 1 No. 301 actions have pro &Cded an effective program that ensures proper system alignment and operator awareness of procedural requirements and system status.
4.
CORRECTIVE STEPS WHICH Wilt BE TAKEN TO AVOID FURTHER VIOLATIONS:
Engineering is conducting a review to determine if design changes to this and similar systems will mitigate the opportunity for this type of incident.
5.
DNrt wHEN FULL COMPLIANCE WILL BE ACHIEVED:
Full compliance has been achieved.
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vcmiA sucTac c:3 co4:2 comyA=v CMILE UCHth SANK NO 25 curex no 28825 oAri 06/02/82 vi~oom no not
.lN E CATE INVOICE NO/OR DESCRIPTION GROSS AMOUNT DISCOUNT NET AMOUNT 1 05/10/82
-ENFORCEMENT CIVILPENALT 50,000.00 0.00 50,000 00 ATTACHED CHECK ISSUED AS PAYMENT OF ITEMS USTED ABOVE PLEASE DETACH STUB AND CASH CHECK PROMPTLY 96 $89 VinainA EtscTnic Ano Powen COMPANY BANK OF VIRGINIA
/OID IF NOT CASHED IN 90 DAYS 03301 25 0028825 00005000000 PAY FIFTY THOUSAND AND 00/100 DDLLARS O, UNITED STATES NUCLEAR oace= REGULATORY COMMISSION 25 28825 Ob/02/82 3 331
$50,000.00
' NUCLEAR REG C DC 20555 04 b 03301 25 0028825 00005000000 FD29255&F s:0 5 &l.0 58 90s: 5 5 2=' ? 110810e x..
w a net I
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