ML18153A848
| ML18153A848 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 06/15/1995 |
| From: | OHANLON J P 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 .