ML18152A472

Responds to NRC 971224 Ltr Re Violations Noted in Insp Repts 50-280/97-09 & 50-281/97-09.Corrective Actions:Appendix R Awareness Training Will Be Conducted for Appropriate Personnel in Nuclear Business Unit

ML18152A472
Person / Time
Site:	Surry
Issue date:	01/20/1998
From:	Ohanlon J VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-280-97-09, 50-280-97-9, 50-281-97-09, 50-281-97-9, 97-745, NUDOCS 9801270034
Download: ML18152A472 (13)

Text

• VIRGINIA ELECTRIC AND PowER CoMPANY RICHMOND, VIRGINIA 23261 January 20, 1998 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/CGL Docket Nos. License Nos. NRC INSPECTION REPORT NOS. 50-280/97-09 AND 50-281/97-09 97-745 R2" 50-280 50-281 DPR-32 DPR-37 We have reviewed Inspection Report Nos. 50-280/97-09 and 50-281 /97-09 dated December 24, 1997, and the enclosed Notice of Violation (NOV) and Notice of Deviation for Surry Units 1 and 2. In response to the issues raised in the inspection report, we have taken corrective actions and plan additional actions. The actions focus on restoring vital bus isolation and providing breaker coordination, heightening personnel awareness relative to Appendix R, ensuring that a situation similar to the vital bus isolation issue does not exist, and continuing our programmatic review of the Appendix R program. The commitments made in this letter are summarized below. We have no objection to this letter being made 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 9801270034 980120 PDR ADOCK 05000280 G PDR * '-' .J ... , I llll/111/111111111111 lflll//l/111111111

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• cc: US Nuclear Regulatory Commission Region II Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, Georgia 30303 Mr. R. A. Musser NRC Senior Resident Inspector Surry Power Station

SUMMARY

OF COMMITMENTS The following commitments are made in response to the Notice of Violation and Notice of Deviation in NRC Inspection Report Nos. 50-280/97-09 and 50-281/97-09:

1 . The modifications to address the vital bus isolation and breaker coordination issues will be completed on Unit 1 during the next refueling outage. The required compensatory measures will remain in place until the modifications are completed on Unit 1. [October -November 1998 refueling outage] 2. Appendix R awareness training will be conducted for appropriate personnel in the Nuclear Business Unit. This training will focus on the Appendix R design and licensing bases, as well as Appendix R compliance and implications.

The awareness training will include a discussion of how insufficient communication contributed to the inappropriate prioritization and delay in implementation of the modification.

[First Quarter 1998] 3. A memorandum will be issued to appropriate Nuclear Business Unit personnel describing how the use of ambiguous language contributed to the delay in implementation of the required modifications and reinforcing the need for and management expectation of effective communication.

[February 1998] 4. A multi-utility assessment of our Appendix R Program will be conducted using the applicable portions of the draft Fire Protection Functional Inspection (FPFI) Temporary Instruction 2515/xxx, which was used during the recent River Bend FPFI. [April 1998 -

Reference:

Letter S/N 98-020] 5. A multi-disciplined review of portions of the Appendix R Report will be conducted.

This review which will include Chapters 3 and 4 will assess the accuracy of the Appendix R Report relative to the current plant configuration, and will validate compliance with the Appendix R requirements.

[July 15, 1998] 6. The fire protection administrative procedure will be expanded to include the original bases for the existing compensatory measures.

Consistent with the guidance in Information Notice 97-48, the fire-watch-only compensatory measures will be reviewed for possible expansion to include other interim measures, such as operator briefings, temporary repairs or procedures, installation and use of temporary fire barriers, and additional detection and suppression, as appropriate.

[July 1, 1998]

• REPLY TO A NOTICE OF VIOLATION . NRC INSPECTION CONDUCTED AUGUST 24, 1997 THROUGH OCTOBER 4, 1997 SURRY POWER STATION UNITS 1 AND 2 INSPECTION REPORT NOS. 50-280/97-09 AND 50-281/97-09 NRC COMMENT: "During an NRC inspection conducted on August 24 through October 4, 1997, violations of NRC requirements were identified.

In accordance with the "General Statement of Policy and Procedures for NRC Enforcement Actions," NUREG-1600, the violations are listed below: A. 10 CFR 50.48 states, in part, that each operating nuclear plant licensed to operate prior to January 1, 1979, shall satisfy the requirements of 10 CFR 50, Appendix R, Section 111.G. Both Surry units were licensed prior to January 1, 1979. 10 CFR 50, Appendix R, Section 111.G.1.(a) requires fire protection features to be provided for structures, systems and components important to safe shutdown to limit fire damage such that one train of systems necessary to achieve and maintain hot shutdown conditions from either the control room or emergency control station(s) is free from fire damage. 1 O CFR 50, Appendix R, Section 111.G.2 requires the protection of one redundant shutdown train from fire damage which could result in hot shorts, open circuits or shorts to ground during an Appendix R type fire. Contrary to the above, from July 1988 for Unit 1 and September 1989 for Unit 2 until August 29, 1997, the licensee failed to provide adequate fire protection features for structures, systems and components important to safe shutdown in that adequate means were not available to isolate the circuits from 120 volt alternating current power panels VB 1-1 and VB 1-11 I and panels VB 2-1 and VB 2-111, located in the respective Unit 1 and 2 computer rooms in the control room complex, from the uninterruptable power supply (UPS) panels. Electrical faults from a 10 CFR Part 50, Appendix R, fire in the control room complex could cause the loss of power from UPS panels 1A-1, 1A-2, 2A-1 and 2A-1 [should be 2A-2]. These UPS panels provide power to the Appendix R remote shutdown panels, located in each unit's emergency switchgear room and in the cable spreading room; and, supply power to the Appendix R communication equipment located adjacent to the auxiliary shutdown panels in each emergency switchgear room. The Appendix R panels contained the instrumentation required for performing a plant shutdown from outside the main control room and included instrumentation for steam generator level, reactor coolant system pressure and temperature, and pressurizer level. (01013) Page 1

• B. Surry Operating License Section 2.1 for Units 1 and 2 provides that the licensee is required to implement and maintain the administrative controls identified in Section 6. of the Fire Protection Safety Evaluation . The Surry Fire Protection Program is described in the Surry Appendix R Report. Chapter 12, Section C of the Surry Appendix R Report describes the Quality Assurance program that is applicable to the fire protection program. Section C.8 states that measures established to ensure* that conditions adverse to fire protection, such as failures, malfunctions, deficiencies, deviations, defective components, uncontrolled combustible materials and noncomformances, are promptly identified, reported and corrected.

Contrary to the above, as of August 29, 1997, the licensee failed to identify fully and correct a noncompliance with Appendix R requirements for the control room associated with a vital bus isolation issue discovered by the licensee in 1992. Specifically, because the licensee failed to recognize the significance of the issue and the fact that the plant was outside the design basis, adequate corrective actions and compensatory measures were not implemented until 1997. (01023) These violations constitute a Severity Level Ill problem (Supplement I). C. 1 O CFR 50. 72(b)(1 )(ii)(B) requires the licensee to notify the NRC of identified plant conditions that are outside the design basis of the plant. The notification is to be made as soon as practical but within one hour of the occurrence.

Contrary to the above, on September 30, 1997, the licensee failed to notify the NRC within one hour of the occurrence, of conditions outside the design basis of the plant. Specifically, on this date, the licensee determined that Surry Units 1 and 2 had been outside its Appendix R design basis due to a 120 VAC vital bus isolation issue. Although the licensee concluded that the outside of design basis condition was a past condition, the Units were in fact still outside the design basis and a one-hour report was required.

(02014) This is a Severity Level IV violation (Supplement I)." Page 2

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• REPLY TO A NOTICE OF VIOLATION NRC INSPECTION CONDUCTED AUGUST 24. 1997 THROUGH OCTOBER 4.1997 SURRY POWER STATION UNITS 1 AND 2 INSPECTION REPORT NOS. 50-280/97-09 AND 50-281/97-09 Violation A 1. Reason for the Violation, or, if Contested, the Basis for Disputing the Violation

2. The violation is correct as stated. The vital bus* isolation issue was identified in 1992, and a station deviation was issued. Following identification of this issue, a modification was planned to restore vital bus isolation in the event of a Main Control Room (MCR) fire. It was then considered that the MCR being continuously manned was an acceptable compensatory measure until the modification was implemented.

A foundational error occurred in 1992 in that these compensatory measures were believed to be equivalent to compliance with the Appendix R design basis. Inappropriate prioritization of the required modification resulted from this error. Contributing causal factors were written and verbal communication.

Specifically, the documentation regarding the vital bus isolation issue used ambiguous language, which contributed to the foundational error. In addition, the significance of the vital bus isolation issue was not effectively communicated verbally, which also contributed to the foundational error. Corrective Steps Which Have Been Taken and the Results Achieved As discussed during the predecisional enforcement conference on the December 4, 1997, a number of corrective actions have been completed.

The completed corrective actions, which are summarized in the following paragraphs, focused on restoring vital bus isolation and ensuring that a situation similar to the isolation issue does not exist: -The design change implementing the modification to restore vital bus isolation in the event of a MCR fire was completed on Unit 2 during the October 1997 refueling outage. With this design change completed on Unit 2, the current capabilities relative to vital bus isolation are that: hot shutdown can be achieved and maintained on both units with no repairs or compensatory measures, cold shutdown can be achieved on Unit 1 without compensatory measures, and cold shutdown can be achieved on Unit 2 using the compensatory measures currently in place. These compensatory measures will remain in Page 3

• place until the modification is completed on Unit 1 during the next refueling outage, scheduled to begin in October 1998. -A Category 1 RCE was conducted to determine the root cause and contributing causal factors in the untimely corrective action associated with the vital bus isolation issue. The conclusions from the RCE are incorporated in the above discussion of Reason for the Violation.

A number of corrective actions related to the RCE have been approved for implementation, some of which are listed below in Item 3. -The fire protection administrative procedure has been revised to address the implementation of non-standard compensatory measures.

Non-standard compensatory measures are those actions that had not previously been defined in the fire protection administrative procedure.

In contrast, standard compensatory measures for anticipated conditions, such as the action required when a fire barrier is found to be breached, are those that have been previously defined and approved in the administrative procedure.

Based on the recent administrative procedure revision, implementation of a non-standard compensatory measure now requires an engineering technical evaluation, which considers defense in depth, design basis, and safety significance in defining the required actions. Briefings were conducted with on-shift Shift Technical Advisors to familiarize them with the revision to the administrative procedure.

-An assessment of the existing non-standard compensatory measures currently in place was conducted.

This review identified no issues or concerns.

-The Operating Experience group completed a review of Information Notice 97-48, titled Inadequate or Inappropriate Interim Fire Protection Compensatory Measures.

That review identified the lack of guidance for implementation of non-standard compensatory measures.

The administrative procedure revision discussed above addresses this observation.

Our December 4, 1997 presentation included identification of approximately thirty design changes and engineering work requests that were completed primarily in the 1984 to 1987 time to address the initial Appendix R requirements.

These design changes have been reviewed to verify that the Appendix R features installed by these changes remain intact.

• Page 4

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• Independent of the Appendix R issues, the corrective action program was recently revised to reflect an enhanced process to prioritize deviation reports. A multi-disciplined, multi-departmental team reviews the deviation report assignments and significance levels proposed by the initial screening.

This team has been trained to recognize issues of safety and regulatory significance.

3. Corrective Steps Which Will be Taken to Avoid Further Violations The December 4, 1997 predecisional enforcement conference included discussion of a number of corrective actions that are planned. The planned corrective actions, which are summarized in the following paragraphs, focus on heightened awareness relative to Appendix R and effective communication, as well as continued programmatic review of the Appendix R program: -Appendix R awareness training will be conducted for appropriate personnel in the Nuclear Business Unit. This training will focus on the Appendix R design and licensing bases, as well as Appendix R compliance and implications.

The awareness training will include a discussion of how insufficient communication contributed to the inappropriate prioritization and delay in implementation of the modification.

It is expected that this training will occur during the first quarter of 1998. -A memorandum will be issued to appropriate Nuclear Business Unit personnel by February 1998 describing how the use of ambiguous language contributed to the delay in implementation of the required modifications and reinforcing the need for and management expectation of effective communication.

A multi-utility assessment of our Appendix R Program will be conducted using the applicable portions of the draft Fire Protection Functional Inspection (FPFI) Temporary Instruction 2515/xxx, which was used during the recent River Bend FPFI. This assessment had been scheduled for January 1998. We recently advised the NRC that this assessment has been postponed until April 1998. [

Reference:

Letter S/N 98-020] -A multi-disciplined review of portions of the Appendix R Report will be conducted.

This review will include Chapters 3, "Safe Shutdown Systems Analysis," and 4, "Appendix R Section 111.G Compliance Summary." For the chapters being reviewed, the accuracy of the Appendix R Report will be assessed relative to the current plant configuration, and compliance with the Appendix R requirements will be confirmed.

This review is scheduled for completion by July 15, 1998. Related to Information Notice 97-48, titled Inadequate or Inappropriate Interim Fire Protection Compensatory Measures, a review of the fire protection administrative procedure noted that the standard compensatory measures as they currently exist (in the administrative procedure) vary depending on the equipment that is inoperable.

The administrative procedure will be expanded to include the original bases for the existing compensatory measures.

Page 5 Consistent with the guidance in Information Notice 97-48, the fire-watch-only compensatory measures will be reviewed for possible expansion to include other interim measures, such as operator briefings, temporary repairs or procedures, installation and use of temporary fire barriers, and additional detection and suppression, as appropriate.

This additional review and revision is scheduled for completion by July 1, 1998. 4. The Date When Full Compliance Will be Achieved . In view of the current capabilities relative to vital bus isolation, which are outlined in Item 2 above, compliance with Appendix R requirements, as well as with the Surry Appendix R design basis requirements, was achieved when the modification was completed on Unit 2 during the last refueling outage ending in November 1997. Upon completion of the Unit 1 modification during the refueling outage scheduled to begin in October 1998, compliance with the Surry Appendix R . licensing basis will also be achieved.

Violation B 1. Reason for the Violation, or, if Contested, the Basis for Disputing the Violation The violation is correct as stated. As noted in the response to Violation A, a foundational error occurred in 1992 in that these compensatory measures were believed to be equivalent to compliance with the Appendix R design basis. Inappropriate prioritization of the required modification resulted from this error. Therefore, implementation of the modification required to restore vital bus isolation was delayed. The delay in correcting the vital bus isolation issue is attributed to the fact that the postponement was not sufficiently challenged in view of the foundational error that compensatory measures suffice for compliance.*

2. Corrective Steps Which Have Been Taken and the Results Achieved As noted in the response to Violation A, a number of corrective actions have been taken related to the vital bus isolation issue. The actions directly associated with the delay in accomplishing the modification to restore vital bus isolation are the following:

-The recent Category 1 RCE was conducted to determine the root cause and contributing causal factors in the untimely corrective action associated with the vital bus isolation issue. The conclusions from the RCE are reflected in the above discussion of Reason for the Violation.

A number of corrective actions related to the RCE have been approved for implementation, some of which are listed below in Item 3. Page 6

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• 3. 4. Independent of the Appendix R issues, the corrective action program was recently revised to reflect an enhanced process to prioritize deviation reports. A multi-disciplined, multi-departmental team reviews the deviation report assignments and significance levels proposed by the initial screening.

This team has been trained on significance levels. Corrective Steps Which Will be Taken to Avoid Further Violations As noted in the response to Violation A, a number of corrective actions are planned related to the vital bus isolation issue. The actions directly associated with heightened sensitivity related to the timeliness of Appendix R corrective

_ actions are the following:

-Appendix R awareness training will be conducted for appropriate personnel in the Nuclear Business Unit. This training will focus on the Appendix R design and licensing bases, as well as Appendix R compliance and implications.

The awareness training will include a discussion of how insufficient communication contributed to the inappropriate prioritization and delay in implementation of the modification.

It is expected that this training will occur during the first quarter of 1998. -A memorandum will be issued to appropriate Nuclear Business Unit personnel by February 1998 describing how the use of ambiguous language contributed to the delay in implementation of the required modifications and reinforcing the need for and management expectation of effective communication.

The Date When Full Compliance Will be Achieved In view of the current capabilities relative to vital bus isolation, which are outlined in Item 2 of the response to Violation A, compliance with Appendix R requirements, as well as with the Surry Appendix R design basis requirements, was achieved when the modification was completed on Unit 2 during the last refueling outage ending in November 1997. Upon completion of the Unit 1 modification during the refueling outage scheduled to begin in October 1998, compliance with the Surry Appendix R licensing basis will also be achieved.

Violation C 1. Reason for the Violation, or, if Contested, the Basis for Disputing the Violation The violation is correct as stated. On September 30, 1997, when it was determined that Surry had been outside the Appendix R design basis due to the vital bus isolation issue, adequate compensatory measures were in place. With those compensatory measures in place, the required Appendix R function of achieving and maintaining safe shutdown conditions could have been ac,complished in the event of a MCR fire. Page 7

• Additionally, with the compensatory measures in place, it was believed we were in compliance with the Appendix R design basis. Therefore, a one-hour report was not made to the NRC. Instead, a Licensee Event Report was issued on October 30, 1997. Based on the NRC input provided in Inspection Report 97-09, we recognize that 1 OCFR50, Appendix R, Section 111.G.1.(a) requires that hot shutdown conditions be achieved and maintained without repairs, in contrast to Section 111.G.1.{b) which allows repairs to achieve and maintain cold shutdown conditions.

At that time, the compensatory measures in place required the disconnection of a UPS cable and the possible replacement of fuses (i.e., repairs) to achieve and maintain hot shutdown conditions on both units. Therefore, in this case, a one-hour report should have been made when it was determined that Surry had been outside the Appendix R design basis due to the vital bus isolation issue and prior to the modification being completed on Unit 2 during the last refueling outage ending in November 1997. 2. Corrective Steps Which Have Been Taken and the Results Achieved We have reviewed the NRC's comments regarding reportability in Inspection Report 97-09 in view of Surry's current configuration.

As noted in the response to Violation A, with the design change completed on Unit 2, the current capabilities relative to vital bus isolation are that: hot shutdown can be achieved and maintained on both units with no repairs or compensatory measures, cold shutdown can be achieved on Unit 1 with no compensatory measures, and cold shutdown can be achieved on Unit 2 using the compensatory measures currently in place. Therefore, relative to vital bus isolation, compliance with the Appendix R requirements, as well as with the Surry Appendix R design basis requirements, was achieved when the modification was completed on Unit 2. So a one-hour report was no longer necessary as of the completion of the Unit 2 refueling outage in November 1997. 3. Corrective Steps Which Will be Taken to Avoid Further Violations As noted in the response to Violation A, a number of corrective actions are planned related to the vital bus isolation issue. The action directly associated with the reportability aspects of the vital bus isolation issue is the following:

Appendix R awareness training will be conducted for appropriate personnel in the Nuclear Business Unit. This training will focus on the Appendix R design and licensing bases, as well as Appendix R compliance and implications.

It is expected that this training will occur during the first quarter of 1998. Page 8

4. The Date When Full Compliance Will be Achieved In view of the current capabilities relative to vital bus isolation, which are outlined in Item 2 of the response to Violation A, compliance with Appendix R requirements, as well as with the Surry Appendix R design basis requirements, was achieved when the modification was completed on Unit 2 during the last refueling outage ending in November 1997. Upon completion of the Unit 1 modification during the refueling outage scheduled to begin in October 1998, compliance with the Surry Appendix R licensing basis will also be achieved.

Page 9

' REPLY TO A NOTICE OF DEVIATION . NRC.INSPECTION CONDUCTED AUGUST 24, 1997 THROUGH OCTOBER 4, 1997 SURRY POWER STATION UNITS 1 AND 2 INSPECTION REPORT NOS. 50-280/97-09 AND 50-281/97-09 NRG COMMENT: "During an NRG inspection conducted on August 24 through October 4, 1997, a deviation of your Updated Final Safety Analysis Report (UFSAR) was identified.

In accordance with the "General Statement of Policy and Procedures for NRG Enforcement Actions," NUREG-1600, the deviation is listed below: UFSAR Section 9.10.1 states that the station's fire protection program satisfies the regulatory criteria set forth in General Design Criterion 3, in 10 CFR 50 Appendix R (Sections 111.G, 111.J, 111.L and 111.0), and in Appendix A to Branch Technical Position APCSB 9.5-1 dated August 23, 1976. Compliance with these criteria is contained in the 10 CFR 50 Appendix R Report, Surry Power Station Units 1 and 2. The 10 CFR 50 Appendix R Report, Surry Power Station, Units 1 and 2, Revision 11, Chapter 9, Electrical Distribution System Coordination Study, Section 9.1, states that coordination of circuit protective devices to prevent unnecessary outages of power supplies needed for safe shutdown is required to conform to the requirements of Appendix R. The Appendix R Report states that components involved in critical circuits were investigated and data gathered to facilitate verification of the capability of the interrupting devices to operate selectively and to continue to supply power to all critical circuits not affected by the postulated fire. Section 9.2 of Chapter 9 concluded that miscoordination existed on the 120 volt alternating current (VAC) bus system due to the maximum half cycle instantaneous current supplied by the bypass transformers.

The Appendix R report states that, to assure coordination, the Square D 100 ampere (amp) trip main circuit breakers in each vital bus panel will be replaced with non-automatic molded case switches.

Contrary to the above, the 100 amp breakers were not replaced with non-automatic switches as committed to in the Appendix R Report to ensure compliance with UFSAR Section 9.10.1. This resulted in inadequate breaker coordination between the vital bus branch circuits and vital bus main panel breaker of the vital bus panels supplying circuits installed in the Units 1 and 2 emergency switchgear rooms and the Turbine Building.

Each of these panels supply Appendix R and safe shutdown related components." Page 10 I

• REPLY TO A NOTICE OF DEVIATION NRC INSPECTION CONDUCTED AUGUST 24. 1997 THROUGH OCTOBER 4. 1997 SURRY POWER STATION UNITS 1 AND 2 INSPECTION REPORT NOS. 50-280/97-09 AND 50-281/97-09

1. Reason for the Deviation, or, if Contested, the Basis for Disputing the Deviation The deviation is correct as stated. Although breaker coordination is not required to comply with the Appendix R design base, it is assumed in the Appendix R Report and therefore is a commitment consistent with the Appendix R licensing basis for Surry. The breaker coordination issue was identified in 1993, and a station deviation was , issued. When this issue was identified, it was recognized that a postulated high fault current and the resultant potential breaker miscoordination was a highly unlikely event. In addition, the potential loss of a single vital bus was a condition addressed by procedure.

The modification required to address breaker coordination was coupled with the modification planned to address the vital bus isolation issue and included in a single design change package. As stated in the responses to Violations A and B, the modification required to restore vital bus isolation was inappropriately prioritized and the implementation was delayed. Therefore, it followed that the modification required to address breaker coordination was also inappropriately prioritized and its implementation was also delayed. 2. Corrective Steps Which Have Been Taken and the Results Achieved The design change implementing the modification to address the breaker coordination issue was completed on Unit 2 during the October 1997 refueling outage. 3. Corrective Steps Which Will be Taken to Avoid Further Violations

4. The design change is scheduled to be completed on Unit 1 during the next refueling outage, scheduled to begin in October 1998. The compensatory measures currently in place will remain in place until the modification is completed on Unit 1. The Date When Full Compliance Will be Achieved Full compliance will be achieved regarding the breaker coordination issue when the required modification is implemented on Unit 1 during the next refueling outage scheduled to begin in October 1998. Page 11