ML20095A176
| ML20095A176 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 04/09/1992 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 92-186, NUDOCS 9204160131 | |
| Download: ML20095A176 (8) | |
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April 9
92 U 8. Nuclear Regulatory Commission Serial No.92-180 Attention: Document Control Desk NL&P/TAH:R17 Washington, D. C. 20555 Docket Nos. 50-338 50-339 License Nos. NPF-4 NPF-7 Gentlemen:
ylRGINIA ELE _CTRIC AILD_.P_QXER C_QM.P ANY NORTH ANNA POJ/ER STATION UNITS 1 AND 2 INSPECTION REPORI RQS. 50-338/92-03 ANR_50 3391M-03
_FLESPONSES TO THE NQJ_I_QES OF VIOL AllOf{
We have reviewed your letter of March 10, 1992, which referred to the inspection conducted at North Anna between January 12,1992 and February 15,1992, as reported in Inspection Report Nos. 50 338/92-03 and 50-339/92-03 Our responses to the Notices af Violation are attached.
In your letter that transmitted the Notices of Violation, you expressed concern with Violation A because the extonsive correctiw actions previously taken to address recerit trends of operator errors and equipmant mispositions should have prevented the enclosed violations. We agree with your concern and are implementing additional actions to enhance operator attention to detail.
These actions include ass'.gning, on an interim basis, a Peer Coach to monitor shift operating practices and coach less experiericed operators The Peer Coach also publishes " Operations Alert's" to help operations personnel perform work activities correctly. In addition, management has met with Operations Department personnel to discuss the recent adverse trend iri personnel errors and a memorandum was l
distributed to underscore managemert's expectations. Finally, the Quality Assurance l-department has been witnessing the performance of safety related independent verification activities. To date over 38,000 observadons have been conducted..
The purpose of the Quality Assurance irvolvement was to enhance the independent l
verification program and raise the awareness of operations personnel to the necessity l
of a consistently high standard of performance. Tnts effort has also generated an extensive data base on operator personnel perforraance which is being evaluated l
under the Human Performance Enhancement System (HPES). An independent third l
- pa.1y is assisting us in th 3 evaluation.
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Dodet IJoe 50a3Bs3M 00 oi th 9;' 166 Page2et3 You also expressed concern with '% tion B, which involved the untimely corrective a:: tion taken ;n tosponse to a s '.acor allctin The irmpectio Report noted Wednnesses in our engineering management controls, an.nitial inadequate engineering evaluahon, apparent lack of sansmvity for potenua'ly safety signibcant issues. thu oversigt t of our indtatry operatina wperience review prograni, and the effectiveness in promptly evaluating operabiht, concoms con monsurato vath sofo'y significance. A!! hough ve agree with the c ted violation, we fee' that some 01 ino above stated concurns were in fact resultant symptoms of the bas c underlying causes of Violation B
'(our concerns resulted from a change ma,1e in the schedule to delay inil;nting the evaluation of a vendor identified issue with only minimal engineere,g management leview. Also, a weakness was e/ident in the oversight of our Industry Operating Experience Review Program, the comequence of whir,h was the faduie to ident;fy the significanco cf thet delay, However, in general, we beheve that the implementation of it.e Engireerinu Potential Problem Reponmg program has been effective in evaluating potential design issues.
To prevent rer:urrence, we t,awi strengthened our review prncesses and proposed pmccJore changes to better tiack the progress and completion of irdustry operating event re'iaw actions and schedules This includes timely assignment of actions and folinw ups for potential safety signihcant issues to ensure that Engineenng Potential Problem Peport; and/,sr Station Deviation Repcrts are iriitiated it also incluoes menagement status repcri cg with emphats on overdue itou in addit.on, the Cotporate Nuclear Safety group and the Station Nuciear Safety grcup will conhnue to coordinate :ndustry ment review action items and pnarities to ensure the moct effective reviews art noucted. Finally. the Industry Operating Egerience Review program is current sing independently evaluated by the Quakty Assurarco Dapartment These changes, which are d:scussed m greater detail in the attachment, prov:de the nocessaiy ccrrective actions to ensure an adequate rev,ew, pnontization and schedubng of safoty significan; concenis.
li you have any further questions, please contact us.
Very truly yours, 0 P i
(/lJ'G%n/ki, rJ f.
a f a e W. L. Stewart Senior Vice President Nuclear Mtachment
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o Docket b.is. 50 3388339 SonalNo.
9? 100 Page 3 of 3 cc; U. S. Nuctoar Regulatory Cornmist.lon i
101 Marietta Street, N.W.
. Suite 2900 Atlanta, Geoigia 30323
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l Mi'. M. S. Luset NHC Sviler Resident inspector Nor'h Anna Power Station l
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BES P.011SE_.IQ._I1JE_tlQIl0 IL DE_V10LAIlR11 11EEQHIRD_DUBJtKt_IllE_flRC 111SEECI1RILuollRVRIED DEMEEILJ AtlVHi_Y__1.L_ WL.MID_.fERRU_A R Y 15,._1332 llLSPECII.Q.tLEEP_QIlL_ tics. 50 3.3EER-13._.Mit_ED. 323122 02 tRQ _CD014tdMil During the Nuclear Regulatory Commission (NRC) inspection conducted on Jan tary 12 February, 15,1992, violations of NPC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Apperidix C,1991, the violationn ara listed bolow-A. Technical SpecifMation 6.8.1.a requires written procedures to be established, imNemented and maintained covering activities referenced in Appendix A of Regulatory Guide 1.33. Revision 2 February 1978, to include operatmg procedures.
Cperating Procedures 1 OP-26.5, Revision 6,120 v :t Vital Bus Distribution, Step o
5.6, provides instructions for transferring vital bus I-IV from inverter I IV to a regulating transformer. Operating Procedure 1 OP 6 5A, Revision 11,1H and 1J Emergency Diesel Generator Post Operationt.1 Check, Step 5.4.4.e requirus the EDG exhaust muffler bypass valve to be opened and !acked.
Contrary to the above, operating ptocedures were not implemented proper'-
'n that:
- 1. On January 21, 1992, while performing,1 OP 26.5, an auxiliary operator assioned to transfer %s ! IV to its regulating transformer, incorrectly transferred bus I 11 which resulted in de energWng the 111120 volt AC vital bus.
- 2. On January 25,1992, while per*orming 1 OP 6.SA to return the 1J EDG to service, an auxiliary operator failed tu open and lock the EDG e>haust multier bypass valve.
This is a Severity Level I/ Violatim applicable to Unit 1 only (Supolement 1).
B.
10 CFR 50, Appendix B, Criterion XVI as implemented by section 17.2.16 of Operational Quality Assurance Prograrn Topical Report (VEP 1-5A), requires in part that measurer be established to assure that conditions adverse to quality are promptly identified and correcxd.
Contrary to the above, establishea measures including the Deviation Report and Potential Problem Report ayctems failed to assure prompt and adequato corrective action of a poten+ial RHR system overpressure vulnerability Substantial action to correct the adverse cundition was not initiated until January 22,1992, although the Mcense6 had been notified of the concern on February 21,1990 This is a Seventy Level IV Violation (Supplement I).
m Docket Nos. 50 330&339 Serial No.
92 180 Attachtnent. Page 2 of 5 flESPONSE TO VLOL ATIQ.tLA 1
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ADMISSIOil OR DEMIM OF THE ALLEGED VIOLATION The violation is corre:.
. Cted 2
REASON FOR THE VIOLAT*0N The reason for the violation was operator wor chuaed by inattention to detail. In the first example, an operator did not adequately sc;l check when switchirg vital bus I IV to its transformer. The operator inadvertently swhched vital bus 111 to a de-energi:.ed SOLA transformer In the second example, the operator initialled the procedure step ind!ceting that '.he EDG exhaust mutiler bypass valve was open and locked, but then failed to actually perform the required action.
- 3. CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED As a result of the first example of the Notice of Violction. the following actions have been initialed:
Operating Procedurc,1 OP 26.5, was revised to require simultaneous verification due to the component's sensitivity.
A Human Performance Enhancement System (HPES) evaluation was performed on the event.
Recommendations as a result of the HPES evaluation include painting the vital bus transfer switch cabinet covers and enhancing of the caution signs on 'ho transfer switch cabinets.
The operator involved in the event was disciplined appropriately.
As a result of the second example of the Notice of Violation, the following actions have been initiated:
The section of the chain on the EDG exhaust muffler bypass valve operators where they lock to the stanchion have been painted and labels have been installed in the EDG room indicating that the muffler bypass is open when the L
padlock is secured throu0 the red chaiti links.
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- The governing procedure for the evolution,-1 OP-6.5A.- has been revised to require independent verification following valve repositioning.
The operator involved in the ever1 was disciplined appropriately.
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Docket Nos 50 30B&339 SenalNo.
92 l'10 Atu. chm 9nt: Pa00 3 of 5 Iri addition to the above corrective actions associated with the specific events, the following actions are bc!np '.aken to reverse the trend of Operations Department personnel errors:
A top pedorming licensed reactor operator has been taken ott shift and temporarily ascigned as a " Peer Coach". This individual monitors watch-i standing practicos end coache: less experienced operators. This individual also publishes Operations Alert's to help operations persnnnel perform work activiiles correctly.
Management has met with the Operations Depart 1ent to discuss the adverso i
trend of personnot errors in addition, a rnemorar um was sent to Opea;ons Pop 9ttnient_ perscrmel expirmining the adverse trend ano mat a0ement's expectations.
The Gunlity Assur ince Department has been witnossing the performance of safety related independent verifical.on activities.
This cnhances the independent verification program anc raises the awateness of operations aersonnoi to the necessity or a consistently high siandard of perto'nv.nce. Tc date over 38,00n bservat;ons have been conducted. Quality Assurance will o
continue to witness the pe"lormance of colected safety rel&d independent verification activities until station managenient is satist,0d 'that operational performance will consistently meet the high standards that are expccted.
The accumulated data base of observationc is aump consnildated and reviewed under our HPES Program for root cause and areas for aoditional management attenticn.
- 4. CORRECTIVE STEPS WHICH WILL DE TAKEN TO AVOl0 FURTHErj VIOLATIOt1S No turthcr corrective actions are required.
- 5. THE DATE-WHEN FULL COMPLIANCE WILL BE ACillEVED Full compliance has been achieved.
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..,.m Dodut Nos 50 333&339 Senat No 9216G AMximn;nt Page 4 ot 5 HESEQfJSflO_ylQLGQILQ 1.
ADMISSIOt1 OR DEtJIAL OF THE ALLEGED VIOLATIOt1 1rie violation is correct as stated except that some of the concerns stated in the inspection report wole in f act resultant symptoms of the basic underlying causcs of the violation.
These re'ulted from a enange made ir, the schedulo to delay the evale. tion of the vondor issue with only mmimal engineering management review.
Also, a w?akness was evidont in the oversight of our Indur:ry Operating Experience Review Prcyva, the consequence of which was the failure to identify i
the significance of that delay. However, the implemen;ation of the Engineenng PoWritml Problem Reporting program oilectively evaluated the potent at design t
issues.
4 2.
REASOt1 FOR THE VIOLATIOt1 The violation was caused by a charge in the schedule to delay engineering evaluallan activities for a condition reported as potentially causnig an adverse Residual Heat Removal (RHR) System condition without full consideration for safety and operabihty concerns, and the Industry Operating Experience Review Program 5 failure to identify the significance of that delay.
The basis for that change was that the Westinghouse correspondence stated that Westinghouse believed that 1:10 ;ssue did not impose a significant hazard to plant safety because the operating time that the RHR System is at temperature conditions at which maxicaum relief valve backpressure occurs during plant cooldown is relatively short. Therefore, the probabihty of an overpressure event that may impair '.he operation of the RHR relief valve is relatively low. Also, conservatisms had been built into the RHR System piping and component designs i
which allows the system to withstand pressure inueases to greater than 110 percent et desion pressure. Westinghouse concluded that the integnty of tho RHR 1
System shauld not be challenged.
The initial screening and assignment of this issue was performed in accordance o
with ouc Industry Operating Experience Review Progam. However, oversight by our Industry Operating Experience Review Program wcs inadequate in that it did not cetermine that the schedule deferral was inconsistent with the potential sately issues.
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- 3. CORRECTIVE STEPS WHICH HAVE BEET 1 TAKEt1 AtJD THE RESU LT S ACHIEVED The processes go'.erning the evaluation of vendor and industry experience information have been strengmened to ensure proper orioritization and tracking.
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Docket Nos 50 3365339 Seral ta 9216n i
Attacturent Page 5 of 5 Tne initial evaluation of a vendor information notice or an industry event report is now performed by Corporate Nuclear Safety (CNS) working with Station Nuclear Safe'y (SNS) and/or other c'.,rporate departments.
CNS makes an ini;iat
?ssessment of the safety significance and the need foi an operability determination, Based on this initial assessnwnt, action will be mitiated with the affe"ted station's) hnd/or other corporate departments tn generate a Station Deviation Report or an Engineciing Potontial Problern Report, as cppropriate. CNS will then esti.M3h an action plan for a detSiled evaluWion %3ed on potential operability ano safety significanco. Once action items have been assigned and schedules established, any extensions to the schedules or delays in the complet on of these action iteras will be reviewed by CNS and reported to manag3 ment.
Also, CNS now serves as the focal pnint for 'he screening of industry experience documents.
Thereiore, parallel reviews being conducted by Corporate Engineering and Station Engmeenng, as was done in this case, will be properly coordmated, in addition, the implementation followup program has been strengthened throu;)h the use of manegemern status reponing. These reports are used '.o request action for completing assignments for which the required due dates have not been mot and for providing overdue and backlog aatos te management.
A comprehensive technical analysis of the RHR System overprecsurization issue has bean performed. Tne results of this analysis confirms that the North Anna RHR System ana relief val /es meet the original casign basin and ar9, in fact, not vulnerable to the overpressure concerns raised in the onginal Westinghouse correspondence.
- 4. CORDECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOL ATIONS CNS procedures will be epgraded to fully incorporate the enhanced program controls by August 31,1992.
Quality Assurance, as part of a Corrective Action Audit, is evaluating the industry Operating Experience Pro 0 ram with special emphasis on program tiraeliness and oversight.
Engineering management will :ssue a technical bulletin to heighten the awareness of engineering personnel to the impertance of operability and safety concerns when considering changes to corrective actions or schedules for completion of assignrnents.
- 5. THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full wmpliance has been achieved.
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