ML18153A066

Forwards Response to Violations Noted in NRC Insp Repts 50-280/96-08 & 50-281/96-08.Corrective Actions:Hydrogen Analyzer Instrument Calibr Procedures Revised to Provide Instructions for Placing FSS on Local & Remote Panels

ML18153A066
Person / Time
Site:	Surry
Issue date:	09/12/1996
From:	Ohanlon J VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
96-425, NUDOCS 9609170471
Download: ML18153A066 (7)

Text

VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 September 12, 1996 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D. C. 20555 Gentlemen:

VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 REPLY TO A NOTICE OF VIOLATION Serial No.96-425 SPS/BCB/GDM R3 Docket Nos.

50-280 50-281 License Nos.

DPR-32 DPR-37 NRC INSPECTlON REPORT NOS. 50-280/96-08 AND 50-281/96-08 We have reviewed your Inspection Report Nos. 50-280/96-08 and 50-281/96-08 dated July 11, 1996, and your August 16, 1996 letter and enclosed Notice of Violation for Surry Units 1 and 2. As discussed in the attachment, the cited violations resulted from inadequate change management when the hydrogen analyzers' calibration procedures were changed. This conclusion is based on the results of a Root Cause Evaluation of the event. We have implemented corrective actions to resolve the specific concerns associated with the violations, as well as more comprehensive actions to ensure that similar concerns do not exist.

Although the violations were precipitated by events that occurred at Surry several years ago, we recognize that the procedure change process should have identified the procedural interface discrepancy. This process was subsequently strengthened in the early 1990s and was recently enhanced further to preclude a similar event.

We have no objection to this letter being made a part of the public record.

Please contact us if you have any questions or require additional information.

Very truly yours,

~?.~

James P. O'Hanlon Senior Vice President - Nuclear Attachment 9609170471 960912 PDR ADOCK 05000280 G

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U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, N.W.

Atlanta, Georgia 30323 Mr. R. A. Musser NRC Senior Resident Inspector Surry Power Station

REPLY TO A NOTICE OF VIOLATION NRC INSPECTION CONDUCTED JUNE 17 - JULY 1, 1996 SURRY POWER STATION UNITS 1 AND 2 INSPECTION REPORT NOS. 50-280/96-08 AND 50-281/96-08 NRG COMMENT:

"During an NRG inspection conducted on June 17 through July 1, 1996, violations of NRG requirements was identified. In accordance with the 'General Statement of Policy and Procedures for NRG Enforcement Actions,' NUREG-1600, the violations are listed below:

A.

Technical Specifications 3.7.G.1 requires that two independent containment hydrogen analyzers be operable during reactor critical or power operation.

Contrary to the above, the Unit 1 and Unit 2 containment hydrogen analyzers were inGperable during reactor critical or power operation from February 28, 1991, and October 21, 1990, respectively, until May 22, 1996, due to the function selector switches being place in the ZERO position following calibration. (01013)

B.

Technical Specifications 6.4.A.1 and 6.4.A.2 require, in part, that detailed written procedures with appropriate instructions be provided for the operation, calibration and testing of all systems and components involving nuclear safety of the station.

Contrary to the above, from October 24 and October 20, 1990 for Units 1 and 2, respectively, Emergency Operating Procedures* 1-E-1 and 2-E-1, 'Loss of Reactor or Secondary Coolant,' and Calibration Procedures 1-IPT-FT-GW-A-104 and 2-IPT-FT-GW-A-204, Containment Hydrogen Analyzer H2A-GW-104(204)

Quarterly Functional Test, did not provide appropriate instructions to place the hydrogen analyzers (systems involving nucle_ar safety of the station) in service.

Specifically, the procedures did not require placing the function selector switches for the-hydrogen analyzers in the SAMPLE position, which is the required position for sampling the containment atmosphere for hydrogen concentration.

(01023)

This is a Severity Level Ill problem (Supplement I)."

L Violation A REPLY TO A NOTICE OF VIOLATION NRC INSPECTION CONDUCTED JUNE 17-JULY 1.1996 SURRY POWER STATION UNITS 1 AND 2 INSPECTION REPORT NOS. 50-280/96-08 AND 50-281/96-08

1.

Reason for the Violation, or, if Contested, the Basis for Disputing the Violation The violation is correct as stated and was caused by inadequate change management.

When the containment hydrogen analyzers' calibration procedures were changed to leave the function selector switch (FSS) on the local and remote panels in the ZERO position, the emergency operating procedures (EOP) did not include instructions to reposition the FSS to the SAMPLE position when placing the hydrogen analyzers in service. Although the ZERO pesition is acceptable for standby operation, the FSS must be in the SAMPLE position for the hydrogen analyzers to be capable of performing their design function.

At the time of the subject change to the calibration procedures, a review of interfacing procedures was not required by the procedure change process.

Consequently, a review of the interfacing procedures was not performed and the need to change the EOPs was not recognized. As a result, a complementary change was not incorporated into the EOPs.

This procedural discrepancy resulted in the FSSs being left in the ZERO position following calibration, thereby rendering the containment hydrogen analyzers inoperable for an extended period of time.

2.

Corrective Steps Which Have Been Taken and the Results Achieved A Deviation Report was submitted to document the subject discrepancy.

l&C and System Engineering personnel reviewed the vendor manual for the hydrogen analyzers to confirm the optimum operational position for the FSSs.

The FSS on the local and remote panels were placed in the SAMPLE position on May 22, 1996.

The hydrogen analyzer instrument calibration procedures were revised to provide instructions for placing the FSS on the local and remote panels in the SAMPLE position following calibration. This is the required position to place the hydrogen analyzers in service using the emergency operating procedures.

2.

Corrective Steps Which Have Been Taken and the Results Achieved (Cont'd.)

A Root Cause Evaluation (RCE) of the event was performed. The results are summarized in Section 1 above.

The RCE also determined that the North Anna Power Station operator watchstation logs periodically verified the position of the hydrogen analyzers' FSSs, and that the Surry logs did not. The Surry operator watchstation logs were subsequently revised to include a periodic verification that the FSSs are positioned correctly.

In addition, a comparative review of the North Anna and Surry Power Stations' operator watchstation logs was performed to evaluate the commonality of equipment checks performed at each station.

No safety equipment inconsistencies were identified.

The Te.cbnical Specifications and emergency and abnormal procedures were reviewed by Operations and l&C personnel to evaluate infrequently performed evolutions and post-accident manual actions to determine whether additional procedural interface concerns existed. No additional examples were identified.

The procedure change process has been revised and improved since the subject hydrogen analyzer calibration procedure changes were processed.

These improvements are discussed in our response to Violation B.

3.

Corrective Steps Which Will be Taken to Avoid Further Violations The corrective actions discussed in Section 2 are sufficient to avoid further violations.

A synopsis of this event is being presented during the current continuing training sessions to enhance the operators' knowledge and understanding of hydrogen analyzer operation. Training will also be conducted for l&C technicians during the next l&C continuing training sessions.

4.

The Date When Full Compliance Will be Achieved Full compliance was achieved on May 22, 1996 when the FSS on the local and remote panels were placed in the SAMPLE position.

Violation B

1.

Reason for the Violation, or, if Contested, the Basis for Disputing the Violation The violation is correct as stated. As discussed in Section 1 of Violation A, a review of interfacing procedures was not performed when the hydrogen analyzers' calibration procedures were changed. The procedure change process in place at the time the position of the FSSs was modified did not ensure that interfacing procedures were considered for potential impact. As a result, when the calibration procedures were changed to specify that the FSSs be left in the ZERO position following calibration, the emergency operating procedures were not changed to provide instructions for placing the FSSs in the SAMPLE position when placing the hydrogen analyzers in service.

2.

Corrective Steps Which Have Been Taken and the Results Achieved As discblSsed in Section 2 of Violation A, the hydrogen analyzer instrument calibration procedures were revised to provide instructions for placing the FSS on the local and remote panels in the SAMPLE position following calibration.

This is the required position to place the hydrogen analyzers in service using the emergency operating procedures.

The procedure change process has been revised and improved since the subject hydrogen analyzer calibration procedure changes were processed. Procedure revisions and upgrades have been centralized under the Procedures Department, and a technical procedures writer's guide has been developed to standardize format, style, content, and human factors considerations.

A technical review is required for new and revised procedures, and technical review guidelines have been established which address procedural methods, instructions, and configuration controls.

In addition, administrative procedure VPAP-0502, "Procedure Process Control,"

has been revised to require an elevated level of review and approval when a procedural revision or change alters the as-left condition of a system or component. This revision also added references to the Licensee Event Report and NRG Inspection Report associated with this violation.

3.

Corrective Steps Which Will be Taken to Avoid Further Violations The corrective actions noted in Section 2 of Violations A and B above are sufficient to avoid similar violations.

4.

The Date When Full Compliance Will be Achieved Full compliance was achieved on September 3, 1996 when VPAP-0502 was revised.