ML18153A848

Responds to NRC 950518 Ltr Re Violations Noted in Insp Repts 50-280/95-06 & 50-281/95-06.Corrective Actions:Mechanical Heise Gauges Not Compensated for Temp Removed from M&TE Program & Transmitter Calibr Procedure Revised

ML18153A848
Person / Time
Site:	Surry
Issue date:	06/15/1995
From:	Ohanlon J VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
95-278, NUDOCS 9506220193
Download: ML18153A848 (7)

See also: IR 05000280/1995006

Text

• VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 June 15, 1995 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. SPS/BCB/ETS

Docket Nos. License Nos.95-278 R7 50-280 50-281 DPR-32 DPR-37 NRC INSPECTION

REPORT NOS. 50-280/95e06

AND 50&281/95-06

We have reviewed Inspection

Report Nos. 50-280/95-06

and 50-281/95-06

dated April 14, 1995 and your May 18, 1995 letter and enclosed Notices of Violation

for Surry Unit 2. We share your concern regarding

the effectiveness

of the Measuring

and Test Equipment (M&TE) Program and the resolution

of the two Deviation

Reports which documented

discrepancies

associated

with the pressurizer

protection

instrument

channels.

We have implemented

actions to strengthen

our performance

in these areas. As discussed

at our April 24, 1995 enforcement

conference, a special Quality Assurance (QA) Audit of the Measuring

and Test Equipment (M&TE) Program was performed

to evaluate the overall program and its implementation.

This QA audit has recently been completed

and concluded

that portions of the M& TE Program do not fully meet our Operational

QA Program for the Control of M&TE Equipment

and that portions of the program implementation

have been ineffective.

The preliminary

QA audit findings have been presented

to management

and are being finalized.

These preliminary

findings are discussed

in the attached response to the violations.

Based on management's

concern for the implementation

of appropriate

corrective

actions, a Root Cause Evaluation (RCE) of the Corrective

Action Program was initiated

in late 1994. The RCE was completed

in April, 1995 and concluded

that the Corrective

Action Program is effective

at identifying, documenting, and determining

the cause of station deviations.

However, opportunities

to improve the Corrective

Action Program were identified

and actions to implement

these opportunities

are underway.

These efforts are also discussed

in the attached response to the violation.

9506220193

950615 PDR ADDCK 05000280 ' \ Q PDR i ~\,

e * 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, r:?d ,J~ Jor James P. O'Hanlon Senior Vice President

-Nuclear Attachment

cc: U.S. Nuclear Regulatory

Commission

Region II 101 Marietta Street, N.W. Atlanta, Georgia 30323 Mr. M. W. Branch NRG Senior Resident Inspector

Surry Power Station ~I

• * REPLY TO A NOTICE OF VIOLATION

NRC INSPECTION

CONDUCTED

JANUARY 22 -FEBRUARY 11, 1995 SURRY POWER STATION UNITS 1 AND 2 INSPECTION

REPORT NOS. 50-280/95-03

AND 50-281/95-03

Violation

A 1 . Reason for the Violation, or, if Contested, the Basis for Disputing

the Violation

2. The violation

occurred as a result of the Unit 2 pressurizer

pressure protection

transmitters

being calibrated

using a pressure gauge that was not temperature

compensated

and without accounting

for subatmospheric

containment

conditions.

The net effect of these two factors resulted in each of the three pressurizer

pressure protection

transmitters

being miscalibrated

high by approximately

15 psi from June 24, 1994 to February 3, 1995. The Root Cause Evaluation (RCE) Team, established

to investigate

this event, concluded

that the Maintenance

Department

Metrology

Laboratory

personnel's

lack of knowledge

led to the purchase and use of a pressure gauge that was not temperature

compensated.

The RCE Team also concluded

that the effects of subatmospheric

conditions

were not accounted

for in the calibration

procedures.

A copy of the RCE was provided to the NRG. Additional

details were also provided in Licensee Event Report 50-281/95-003-01.

Corrective

Steps Which Have Been Taken and the Results Achieved A multidiscipline

Root Cause Evaluation (RCE) Team* investigation

was initiated

on February 23, 1995 to determine

the cause of this event and to recommend

corrective

actions. Approved corrective

actions resulting

from the RCE include: * Mechanical

Heise gauges that are not compensated

for temperature

have been removed from the M&TE Program. * Equipment

calibrations

that were performed

with mechanical

Heise gauges that are not compensated

for temperature

have been reviewed.

No safety significant

equipment

required re-calibration.

• Transmitter

calibration

procedures

have been revised to include a precautionary

statement

to preclude their use at subatmospheric

conditions.

• Quality Assurance (QA) performed

an audit of the Measuring

and Test Equipment (M&TE) Program. The M&TE audit concluded

that portions of the M& TE Program do not fully meet the Operational

QA Program for the Control of M& TE Equipment

and portions of the program are not being effectively

• implemented.

Corrective

actions resulting

from the audit are discussed

in Section 3. 3. Corrective

Steps Which Will be Taken to Avoid Further Violations

The following

corrective

actions are being implemented, as discussed

at the April 24, 1995 enforcement

conference

and in Licensee Event Report 50-281 /95-003-01.

• A review of equipment

calibrations

that were performed

with digital gauges that are not compensated

for temperature

will be completed

by the end of , July 1995. * M& TE data sheets will be revised by the end of June 1995 to specify the purchase of temperature

compensated

gauges only. * Training programs are being revised to include a detailed discussion

regarding

the use of temperature

compensated

gauges and gauges that are not compensated

for temperature.

This action will be completed

by October 1995 * Transmitter

calibration

procedures

will be revised by October 1995 to provide instructions

for performing

calibrations

in subatmospheric

conditions.

Prior to any calibrations

above cold shutdown conditions

the current calibration

procedures

will be revised to include instructions

for performing

calibrations

in subatmospheric

conditions.

Management

has reviewed the results of the QA audit of the M&TE Program. The audit identified

weaknesses

in the following

areas: * M&TE Program controls * Use of uncalibrated

standards

and M& TE * Recording

of usage data * Performance

of evaluations

to determine

the need for retesting

• Storage and identification

of M& TE * Failure to trend M&TE related deficiencies

These audit findings are being finaliz~d

and will be resolved in accordance

with the QA Program. The resulting

corrective

actions will be provided to the NRC Resident Inspectors.

4. The Date When Full Compliance

Will be Achieved Full compliance

was achieved when the Unit 2 pressurizer

pressure protection

transmitters

were calibrated

on February 10, 1995 .

'* Violation

B 1. Reason for the Violation, or, if Contested, the Basis for Disputing

the Violation

Instrumentation

and Controls (l&C) Department

personnel

submitted

Deviation

Report (DR) S-94-1352

on June 24, 1994 which identified

an indication

discrepancy

between the Unit 2 pressurizer

pressure control and protection

channels.

l&C personnel

investigated

the condition

and concluded

that an error may have occurred when the pressurizer

pressure protection

transmitters

were calibrated.

This determination

was supported

by the personnel

involved, who indicated

that the Heise gauge may have been misread. Therefore, the transmitters'

calibration

was checked, found to be low by approximately

30 psi, and was adjusted on June 24, 1995. Operations

Department

personnel

submitted

DR S-94-1353

on June 25, 1994 to document a pressurizer

low pressure alarm that was received during the unit startup. The DR also noted that the pressurizer

protection

channels were indicating

approximately

15 to 20 psi higher than the pressurizer

control channels.

DRs S-94-1352

and S-94-1353

were assigned to the l&C Department

to determine

the cause of the identified

conditions

and to implement

appropriate

corrective

actions. l&C Department

personnel

reviewed each DR and concluded

that the DRs reported the *same condition.

Several factors lead to this conclusion.

The DRs were in sequential

order, submitted

by different

departments, and were assigned to the l&C Department

on the same day. In addition, DR S-94-1352

did not describe the exact nature of the discrepancy

that had been noted between the Unit 2 pressurizer

pressure control and protection

channels.

DR S-94-1353

was closed on July 14, 1994, since it was mistakenly

believed to be redundant

to DR S-94-1352.

DR S-94-1352

was closed on August 4, 1994 based on the l&C Department's

conclusion

that a personnel

error in reading the pressure gauge when the transmitters

were initially

calibrated

had caused the transmitters

to be out of adjustment

on June 24, 1994. The actual causes of the discrepancies

documented

by DRs S-94-1352

and S-94-1353

were identified

in April 1995 by the Root Cause Evaluation (RCE) Team that was established

to investigate

the calibration

discrepancies

identified

in February, 1995. The RCE Team determined

that the transmitters

were out of calibration

on June 24, 1994 as a result of binding in the pressure gauge used to calibrate

the transmitters

and a zero shift that had occurred in the transmitter

calibration

as the unit had heated up. These factors accounted

for a total error of 30 psi.

• 1. Reason for the Violation, or, if Contested, the Basis for Disputing

the Violation (continued)

The RCE Team also determined

that the discrepancy

that had been noted between the pressurizer

pressure control and protection

channels on June 25, 1994 (DR S-94-1353)

resulted from the Unit 2 pressurizer

pressure protection

transmitters

being calibrated

on June 24, 1994 using a pressure gauge that was not temperature

compensated

and without accounting

for subatmospheric

containment

conditions.

The net effect of these two factors resulted in each of the three pressurizer

pressure protection

transmitters

being miscalibrated

high by approximately

15 psi. Although there were several mitigating

circumstances

as described

above, both DRs were closed by August, 1994 without identifying

the actual causes of the discrepancies.

In reviewing

both DRs, the l&C Department

concluded

that the DRs documented

the same deviating

condition

and did not adequately

question the need for additional

investigation

of the second DR. Their investigation

of these deviating

conditions

led to the belief that the cause for the anomalous

but common indications

exhibited

by the pressure protection

channels was understood

and had been corrected

by the calibration

at Hot Shutdown.

The DR disposition

was subsequently

reviewed and closed in accordance

with the corrective

action process. 2. Corrective

Steps Which Have Been Taken and the Results Achi.eved

The concerns and management

initiatives

related to our Corrective

Action Program were discussed

with NRG staff at a Virginia Power requested

management

meeting on January 25, 1995. As stated at that meeting, several continuing

initiatives

were instituted

to communicate

and reinforce

management's

expectations

and standards:

• Coaching to reinforce

the need for clear communications

and a questioning

attitude * Emphasizing

the Nuclear Safety Policy and sensitivity

to compliance

with requirements

• Ensuring degraded conditions

are identified

and corrective

actions are promptly initiated

• Emphasizing

the need for personnel

to exhibit ownership

As a result of management's

awareness

and concern regarding

the implementation

of appropriate

corrective

actions, RCE 94-21, Corrective

Action Process, was initiated

in late 1994. RCE 94-21 assessed the effectiveness

of the corrective

action process in the resolution

of recent station events. The RCE was completed

in April 1995 and concluded

that the Corrective

Action Program is effective

at identifying, documenting, and determining

the cause of station deviations.

The RCE recommended

certain actions to improve the preparation

of a Deviation

Report (DR) and the evaluation

of the deviating

condition.

,. ' * ' 2. Corrective

Steps Which Have Been Taken and the Results Achieved (continued)

As part of the actions outlined during the management

meeting on January 25, 1995, management

is stressing

the need for exhibiting

a questioning

attitude and conservative

decision making through coaching on activities

to resolve deviating

conditions.

In addition to documenting

an inoperable

condition, a DR is prepared to document degraded and/or alert conditions.

Communications

among the disciplines

involved in resolving

a problem is emphasized.

Expectations

and ownership

are established

early. These techniques

were utilized effectively

to enhance nuclear safety during the 1995 Surry Unit 2 Refueling

Outage and other significant

activities

in 1995. A memorandum

has been issued to station employees

by the station manager outlining

the expectations

of each employee for information

that is to be supplied in preparing

a DR. The memorandum

also reinforces

maintaining

a low threshold

for identification

of deviating

conditions.

Expectations

for utilizing

a questioning

attitude during evaluation

of a deviating

condition

are outlined and explained.

The techniques

for evaluating

the deviating

condition

include an examination

of any recent and previous DR concerning

the same equipment.

Supervisors

will review this memorandum

with their employees.

3. Corrective

Steps Which Will be Taken to Avoid Further Violations

In addition to the ongoing management

coaching and the management

memorandum

on the Deviation

Reporting

process, training will be provided to appropriate

station personnel

during 1995. This training will reinforce

understanding

of the deviation

reporting

process. 4. The Date When Full Compliance

Will be Achieved The RCE on the Corrective

Action Program concluded

that the program was effective

at identifying, documenting, and determining

the cause of station deviations.

The improvements

recommended

in the RCE, as discussed

above, are ongoing and will be completed

by December 31, 1995. Full compliance

was achieved upon completion

of the Root Cause Evaluation

on the Corrective

Action Process in April, 1995 .