ML18139B891

Responds to NRC 820510 Ltr Re Violations Noted in IE Insp Rept 50-280/82-58.Corrective Action Is:Prestartup Checklist Will Be Performed by Instrument Supervisor & All Employees Counseled Re Procedural Compliance

ML18139B891
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)
References
301, NUDOCS 8206160306
Download: ML18139B891 (3)

See also: IR 05000280/1982058

Text

• • ,,/' * e * VIRGINIA ELECTRIC AND POWER COMPANY RlCHMOND.., VJRGlNlA 23261 R. H. LEASBURO VJCE PRESIDENT

NuCLEAJ< OPERATIONS

June 9, 1982 United States Nuclear Regulatory

Commission

Attn: Mr. Richard C. DeYoung, Director Office of Inspection

and Enforcement

Washington, D.C. 20555 Gentlemen:

IE HQ Fl'LE *OOP'r Serial No. 301 NO/RMT:acm

Docket No. 50-280 License No. DPR-32 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. Enclosures

1. Response to Notice of Violation

2. Voucher Check No. 28825 in payment of Civil Penalty cc: Mr. James P. O'Reilly Regional Administrator, Region II 8206160306

820609 PDR ADOCK 05000280 _9~_*. _*__ _ PDR

J J ;, J.,. * * * e RESPONSE TO NOTICE OF VIOLATION

INSPECTION

REPORT NOS. 50-280/82-58

Attachment

Serial No. 301 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 Shift 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 knowl~dge

and approval, of the Shift* Supervisor.

Jumpers a1? used in this procedure

include, but are not limited to electrical

lifted leads. In this instance, the removal of fuses is considered

the equivalent

of lifting electrical

leads. As a consequence, Unit 1 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) RESPONSE:

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

corrective

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:

3. The violation

is resultant

from an individual's

failure to follow procedural

controls.

CORRECTIVE

STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:

Subsequent

to this event additional

procedural

controls 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 __ J

--. J . * * * * e Attachment

Page 2 Serial No. 301 actions have provided an effective

program that ensures proper system alignment

and operator awareness

of procedural

requirements

and system status. 4. CORRECTIVE

STEPS WHICH WILL 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. DATE WHEN FULL COMPLIANCE

WILL BE ACHIEVED:

Full complia~ce

hap been achieved . -~1 I