ML18153A444
| ML18153A444 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 09/26/1997 |
| From: | OHANLON J P VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | LIEBERMAN J NRC OFFICE OF ENFORCEMENT (OE) |
| References | |
| 50-280-97-01, 50-280-97-1, 50-281-97-01, 50-281-97-1, 97-516, NUDOCS 9710020031 | |
| Download: ML18153A444 (14) | |
See also: IR 05000280/1997001
Text
- * ---------VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 Mr. James Lieberman, Director Office of Enforcement
September
26, 1997 United States Nuclear Regulatory
Commission
One White Flint North 11555 Rockville
Pike Rockville, MD 20852-2738
Serial No. SPS/BCB Docket Nos. License Nos. Vu \ol1L (~'tx)r.,,5 97-516 R2.1 50-280 50-281 DPR-32 DPR-37 Dear Mr. Lieberman:
- 97 OCT ~1 A10 :19 VIRGINIA ELECTRIC AND POWER COMPANY Puuuc DOCU!-i[NT
r:1: SURRY POWER STATION UNITS 1 AND 2 REPLY TO A NOTICE OF VIOLATION
NRC INSPECTION
REPORT NOS. 50-280/97-01.
50-281/97-01
We have reviewed Inspection
Report Nos. 50-280/97-01
and 50-281/97-01
dated February 20, 1997, and your August 29, 1997 letter and enclosed Notice of Violation
for Surry Units 1 and 2. While plant safety and materiel condition
have been maintained
at a high level, we recognize
that our implementation
of the Maintenance
Rule was not adequate.
We have carefully
re-examined
our approach to the implementation
-of the Maintenance
Rule program and have conducted
an independent
assessment
of the management
factors involved.
As discussed
at the March 11, 1997, predecisional
enforcement
conference, we have addressed
the identified
weaknesses
and have implemented
a recovery plan to address the specific Maintenance
Rule program issues. In addition, we have clarified
the self-assessment
program requirements
to ensure that identified
deviating
conditions
are resolved through the corrective
action program. As part of the recovery plan, a dedicated
team was established
to revise and revalidate
Virginia Power's Maintenance
Rule program. The team essentially
redeveloped
the entire program to ensure consistency
with NUMARC 93-01 and compliance
with 10 CFR 50.65. Independent
assessments
were also performed
during the course of the recovery effort to confirm and enhance the program redevelopment.
The results of the recovery team effort were discussed
with the NRC at the Region II office on August 4, 1997. Additional
programmatic
corrective
actions and enhancements
are discussed
in the attached violation
response, as well as the corrective
actions related to the specific examples cited in the violations.
These actions have achieved and will enable us to maintain compliance
with the Maintenance
Rule . ,~---------
-~ ------------I 11111111111111111111111111111111
Ill llll *&&SC&F*
- 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 No additional
commitments
are made in response to the Notice of Violation
in NRC Inspection
Report Nos. 50-280/97-01
and 50-281/97-01.
Attachment
cc: Regional Administrator
U.S. 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
REPLY TO A NOTICE OF VIOLATION
NRC INSPECTION
CONDUCTED
JANUARY 13 -17, 1997 SURRY POWER STATION UNITS 1 AND 2 INSPECTION
REPORT NOS. 50-280/97-01, 50-281/97-01
NRC COMMENT: "During an NRC inspection
conducted
between January 13 and 17, 1997, violations
of NRC requirements
were identified.
In accordance
with the 'General Statement
of Policy and Procedures
for NRC Enforcement
Actions,'
NUREG 1600, the NRC proposes to impose a civil penalty pursuant to Section 234 of the Atomic Energy Act of 1954, as amended (Act), 42 U.S.C. 2282, and 10 CFR 2.205. The particular
violations
and associated
civil penalty are set forth below: A. 1 O CFR 50.65(a)(1)
requires, in part, that the holders of an operating
license shall monitor the performance
or condition
of structures, systems, or components (SSCs) within the scope of the rule as defined by 10 CFR 50.65(b), against licensee-established
goals, in a manner sufficient
to provide reasonable
assurance
that such structures, systems, and components, are capable of fulfilling
their intended functions.
Such goals shall be established
commensurate
with safety. When the performance
or condition
of a structure;
system, or component
does not meet established
goals, appropriate
corrective
action shall be taken. Contrary to 10 CFR 50.65(a)(1), as of January 13, 1997, the licensee failed to monitor the performance
and establish
goals commensurate
with safety for the emergency
switch gear heating ventilation
and air conditioning
system, as required by 10 CFR 50.65(a)(1), in a manner sufficient
to provide reasonable
assurance
that such a structure, system, and component, was capable of fulfilling
its intended functions.
The emergency
switch gear heating ventilation
and air conditioning
system is a system required in order for the facility to shut down the reactor and maintain it in a safe shutdown condition.
(01013) B. 10 CFR 50.65(a)(1)
requires, in part, the holders of an operating
license shall monitor the performance
or condition
of SSCs, as defined by 10 CFR 50.65(b), against licensee-established
goals, in a manner sufficient
to provide reasonable
assurance
that such structures, systems, and components
are capable of fulfilling
their intended functions.
When the performance
or condition
of a structure, system, or component
does not meet established
goals, appropriate
corrective
action shall be taken. 10 CFR 50.65(a)(2)
requires, in part, that monitoring
as specified
in 10 CFR 50.65 Section (a)(1) is not required where it has been demonstrated
that the performance
or condition
of a structure, system, or
- * * component
is being effectively
controlled
through the performance
of appropriate
preventive
maintenance, such that the structure, system, or component
remains capable of performing
its intended function.
Contrary to 1 O CFR 50.65(a)(2), as of July 10, 1996, the time that the licensee elected to not monitor the performance
or condition
of certain SSCs against licensee-established
goals pursuant to the requirements
of Section (a)(1 ), the licensee failed to demonstrate
that the performance
or condition
of SSCs within the scope of 10 CFR 50.65 had been effectively
controlled
through the performance
of appropriate
preventive
maintenance, as evidenced
by the following
examples, each of which would constitute
a separate violation:
(1) The licensee failed to demonstrate
that the performance
of the significant, direct current power, emergency
switch gear heating, ventilation
and air conditioning (chillers), and service water systems, and the non-risk-significant
emergency
lighting and condensate
polishing
systems, had been effectively
controlled
through the performance
of appropriate
preventive
maintenance
in accordance
with the requirements
Specifically, the licensee failed to evaluate the appropriateness
of the performance
of preventive
maintenance
on these systems prior to placing these SSCs under Section (a)(2). The evaluation
of the appropriateness
of the preventive
maintenance
system failures was not adequate because it failed to consider system failures prior to July 10, 1996. Without an evaluation
of the appropriateness
of preventive
maintenance
performed
on these systems prior to July 10, 1996, the licensee was unable to demonstrate
that the performance
or condition
of. these systems were effectively
controlled
through the performance
of appropriate
preventive
maintenance, such that the SSCs remain capable of performing
their intended functions.
(2) The licensee failed to demonstrate
that the performance
of the risk-significant
radiation
monitors had been effectively
controlled
through the performance
of appropriate
preventive
maintenance
in accordance
with the requirements
Specifically, the licensee failed to adequately
evaluate the appropriateness
of the performance
of preventive
maintenance
on the radiation
monitors prior to placing these SSCs under Section (a)(2). The evaluation
of the appropriateness
of the preventive
maintenance
was not adequate because it had failed to identify that maintenance
performed
on the system had not prevented
excessive
inoperability
and unavailability
of the radiation
monitors such that the monitors may not have been capable of performing
- ,* ., r--~ *, " I, ** * 't_ :J> -* -* --' * * * T ,0 --* ,.* -* * * --,
- (3) (4) (5) their intended function of either (1) alerting the licensee that radiological
set points had been exceeded, or (2) initiating
an automatic
safety system actuation.
The licensee failed to demonstrate
that the performance
of the significant
reactor protection
system (RPS) and safety injection
actuation
system (SIAS) were being effectively
controlled
through the performance
of appropriate
preventive
maintenance
in accordance
with the requirements
Specifically, the licensee failed to demonstrate
it had established
adequate measures to evaluate the effectiveness
of preventive
maintenance
on these risk significant
SSCs prior to placing these SSCs under Section (a)(2) in that it used a standard that would allow up to three maintenance
preventable
functional
failures (MPFF) per operating
cycle. Allowing three MPFFs for the significant
RPS and SIAS would not demonstrate
that the performance
of the SSCs were being effectively
controlled
through appropriate
preventive
maintenance.
The licensee failed to demonstrate
that the performance
of the significant
component
cooling water pumps and the instrument
air compressor
had been effectively
controlled
through the performance
of appropriate
preventive
maintenance
in accordance
with the requirements
Specifically, the licensee failed to establish
any measure to evaluate the appropriateness
of the performance
of preventive
maintenance
on the component
cooling water pumps and the instrument
air compressor
prior to placing these SSCs under Section (a)(2). Measures to evaluate the appropriateness
of the preventive
maintenance
were necessary
to demonstrate
that the performance
or condition
of the components
were being effectively
controlled
through appropriate
preventive
maintenance
such that the component
cooling water pumps and the instrument
air compressor
remain capable of performing
their intended function.
The licensee failed to demonstrate
that the performance
of the significant
reactor coolant system code safety valves had been effectively
controlled
through the performance
of appropriate
preventive
maintenance
in accordance
with the requirements
Specifically, the licensee had failed to establish
adequate measures to evaluate the appropriateness
of the performance
of preventive
maintenance
on the reactor coolant system code safety valves prior to placing these SSCs under Section (a)(2). The measures used in the evaluation
of the appropriateness
of the preventive
maintenance
were not adequate
- (6) (7) -----------because they failed to consider set point drift of the valves. Measures for the evaluation
of set point drift were necessary
because, if preventive
maintenance
fails to preclude change to the set point of the reactor coolant system code. safety valves, the valves may not be capable of performing
their intended function of protecting
the reactor coolant system from over pressurizing
and failing. The licensee failed to demonstrate
that the performance
of the significant
emergency
service water system had been effectively
controlled
through the performance
of appropriate
preventive
maintenance
in accordance
with the requirements
Specifically, the licensee failed to adequately
evaluate the appropriateness
of the performance
of preventive
maintenance
on this system prior to placing this SSC under Section (a)(2). The evaluation
of the appropriateness
of the preventive
maintenance
system failures was not adequate because it failed to consider failures of periodic tests for system operability
prior to July 10, 1996. Without an evaluation
of the appropriateness
of preventive
maintenance
performed
on this system prior to July 10, 1996, the licensee was unable to demonstrate
that the performance
of the system was effectively
controlled
through the performance
of appropriate
preventive
maintenance, such that this SSC remains capable of performing
its intended function.
The licensee failed to demonstrate
that the performance
of standby function of the electro-hydraulic
control system, bearing cooling system, boric acid transfer pumps (emergency
boration mode), auxiliary
building heating, ventilation
and cooling system, and the control room emergency
ventilation
system had been effectively
controlled
through performance
of appropriate
preventive
maintenance
in accordance
with the requirements
of 1 O CFR 50.65(a)(2).
Specifically, the licensee failed to establish
any measures to evaluate the appropriateness
of the performance
of * preventive
maintenance
on these SSCs prior to placing these SSCs under Section (a)(2). Without any measures to evaluate these standby functions, the licensee was unable to demonstrate
that the performance
or condition
of these SSCs were effectively
controlled
through the performance
of appropriate
preventive
maintenance, such that these SSCs remain capable of performing
their intended function.
(01023) C. Technical
Specification (TS) 6.4, Unit Operating
Procedures, states in Part A.7, that detailed written procedures
with appropriate
checkoff lists and instructions
shall be provided for preventive
or corrective
~~****~**
~*-:""'* -.... -~ -.-.. --,* ............
-.~-.. -... -*.
- * maintenance
operations
which could have an effect on the safety of the reactor. Part D of TS 6.4 states that all procedures
described
in Specification
6.4.A shall be followed.
Virginia Power Station Administrative
Procedure
VPAP-0815, Maintenance
Rule Program, Revision 3, and VPAP-2001, Station Planning and Scheduling, were established
to provide instructions
for preventive
and corrective
maintenance
operations.
(1) (2) VPAP-0815, Revision 3, included the screening
criteria for cause determinations
of Maintenance
Preventable
Functional
Failures (MPFF), an activity which could have an effect on the safety of the reactor. Section 4.11 of VPAP-0815
included a requirement
that a SSC within the scope of the Rule must experience
a failure which resulted in a loss of risk-significant
or standby train function and/or loss of a non-risk-significant
system function that affected plant level monitoring
criteria prior to screening
for a MPFF. Contrary to the above, as of January 13, 1997, the instructions
provided in Virginia Power Station Administrative
Procedure
VPAP-0815, Revision 3, were not appropriate, in that VPAP-0815
did not prescribe
adequate instructions
regarding
cause determinations
for MPFFs in the main feedwater, chemical and volume control, and radiation
monitoring
systems. Specifically, Section 4.11 of VPAP-0815 did not provide instructions
to allow for screening
of MPFFs for a SSC within the scope of the Rule without experiencing
a failure which resulted in a loss of risk-significant
or standby train function and/or loss of a non-risk-significant
system function that affected plant level monitoring
criteria.
During the inspection, examples of MPFFs were identified
for the main feedwater, chemical and volume control, and radiation
monitoring
systems which had not been identified
by the licensee due to this procedure
inadequacy.
Limiting the screening
of functional
failures to failures that actually cause plant transients
does not provide assurance
that the main feedwater
system, the chemical and volume control system, and the radiation
monitoring
system remain capable of performing
their intended function thereby affecting
the safety of the reactor. (01033) VPAP-0815, Revision 3, Section 5.12, requires the Maintenance
Rule Working Group to develop, review, and approve performance
criteria for risk significant
and Maintenance
Rule structures, systems, and components.
Contrary to the above, the licensee failed to follow VPAP-0815
in that the performance
criteria for the reactor protection
system, a system where performance
has an effect on the safety of the reactor, was changed on January 16, 1997 without approval of the Maintenance
Rule Working Group as required by Section 5.12 of VPAP-0815.
(01043) (3) VPAP-2001, Revision 3, Section 6.7.2, requires that the approval of the Assistant
Station Manager Operations
and Maintenance
be obtained whenever two or more risk-significant
systems or components
are to be unavailable
which are not addressed
in the site matrix for removing equipment
from service during on line operations.
Contrary to the above, the licensee failed to obtain approval from the Assistant
Station Manager Operations
and Maintenance
on October 17, 1996, when one pressurizer
power operated relief valve was blocked and an instrument
air compressor
was unavailable (both risk-significant
components
whose removal from service would have an effect on the safety of the reactor and not addressed
in the site matrix) as required by Section 6.7.2 of VPAP-2001. (01053) These violations
represent
a Severity Level Ill problem (Supplement
I). Civil Penalty -$55,000" !". ** **.* .. * ** "': *.* * .,_ ** , -.---*
~-----=--~~
-~-. Violation
A REPLY TO A NOTICE OF VIOLATION
NRC INSPECTION
CONDUCTED
JANUARY 13 -17. 1997 SURRY POWER STATION UNITS 1 AND 2 INSPECTION
REPORT NOS. 50-280/97-01, 50-281/97-01
1. Reason for the Violation, or, if Contested, the Basis for Disputing
the Violation
The violation
is correct as stated. As discussed
at the predecisional
enforcement
conference
at the NRC Region II office on March 11, 1997, Virginia Power failed to adequately
implement
the Maintenance
Rule. This failure was caused by weaknesses
in the development
and execution
of Virginia Power's Maintenance
Rule program that resulted from 1) management's
insufficient
knowledge
of the industry guidelines (i.e., NUMARC 93-01), 2) inadequate
management
oversight, 3) the lack of program ownership, and 4) the absence of a well defined implementation
plari. Due to the development
and implementation
weaknesses
described
above, the Maintenance
Rule program was not consistent
with the guidelines
of NUMARC 93-01 and did not comply with all of the requirements
of 10 CFR 50.65. As a result of these program deficiencies, we failed to properly monitor performance
and establish
goals for some structures, systems, and components (SSCs), as required by 10 CFR 50.65(a)(1
), including
the emergency
switch gear (ESG) heating, ventilation, and air conditioning (HVAC) system. 2. Corrective
Steps Which Have Been Taken and the Results Achieved As discussed
at the March 11, 1997, predecisional
enforcement
conference, a recovery plan was developed
to address the Maintenance
Rule program issues. As a part of the recovery plan, a dedicated
Maintenance
Rule Recovery Team was established
to revise and revalidate
Virginia Power's Maintenance
Rule program. The team essentially
redeveloped
the entire program to ensure consistency
with NU MARC 93-01 and compliance
with 10 CFR 50.65. The results of the recovery team effort were discussed
with the NRC at the Region II office on August 4, 1997. Although normal maintenance
and testing ensured the operability
of the ESG HVAC system, the specific requirements
were not satisfied.
To address the deficiencies
cited in Violation
A, appropriate
goals and monitoring
were established
for the ESG HVAC air handling units (AHUs) in accordance
with 10 CFR 50.65(a)(1).
The (a)(1) goals were subsequently
met * 1, "':" ... --"f;" 7 -.---.--** * ............
-.,-.... -* ... ---
- and the AHUs were recently returned to the normal (a)(2) performance
monitoring
category.
An evaluation
of the performance
of the ESG HVAC chillers was also completed.
Based on this evaluation, the chillers were placed in the (a)(1) performance
monitoring
category and appropriate
goals and monitoring
were established
in accordance
with 10 CFR 50.65(a)(1).
These actions, in conjunction
with routine maintenance
and testing, provide reasonable
assurance
that the ESG HVAC system will remain capable* of fulfilling
its intended functions.
3. Corrective
Steps Which Will be Taken to Avoid Further Violations
As described
at the August 4, 1997, meeting with the NRC, the revised Maintenance
Rule program presently
implemented
provides the framework
to ensure future compliance
with 10 CFR 50.65 and should preclude similar violations.
4. The Date When Full Compliance
Will be Achieved Full compliance
with the Maintenance
Rule was achieved on June 30, 1997, and was confirmed
in our letter to the NRC, * dated July 23, 1997 (Serial No.97-410) .
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 the response to Violation
A, implementation
weaknesses
resulted in the development
of a Maintenance
Rule program that was not consistent
with the guidelines
of NUMARC 93-01 and did not comply with all of the requirements
of 10 CFR 50.65. Due to these program deficiencies, we failed to demonstrate
that , the performance
or condition
of some SSCs had been effectively
controlled
through the performance
of appropriate
preventive
maintenance, as required by 10 CFR 50.65(a)(2), including
the examples cited in Violation
B. 2. Corrective
Steps Which Have Been Taken and the Results Achieved The Maintenance
Rule Recovery Team revised/established
the performance
criteria for the structures, systems, and components (SSCs) within the scope of the Maintenance
Rule. This effort corrected
the specific issues identified
in the seven examples associated
with Violation
B and* the related programmatic
deficiencies
that allowed these examples to occur. The performance
criteria were revised/established
on a functional
level and were validated
by the Maintenance
Rule Expert Panel to ensure consistency
with the latest Probabilistic
Safety Analysis models and the NUMARC 93-01 criteria.
The Maintenance
Rule Recovery Team concurrently
conducted
a review of the previous three year's internal and external operating
experience
for the Maintenance
Rule SSCs to collect reliability
and unavailability
data. This data was evaluated
relative to the SSC performance
criteria and the SSCs were placed in the (a)(1) or (a)(2) performance
monitoring
category, as appropriate.
The programmatic
corrective
actions discussed
in Section 2 of the response to Violation
A are also applicable
to Violation
B. 3. Corrective
Steps Which Will be Taken to Avoid Further Violations
As discussed
in Section 2 above, the revised Maintenance
Rule program provides the framework
to ensure future compliance*
with 10 CFR 50.65 and should preclude similar violations.
4. The Date When Full Compliance
Will be Achieved Full compliance
with the Maintenance
Rule was achieved on June 30, 1997, and was confirmed
in our letter to the NRC, dated July 23, 1997 (Serial No.97-410).
Violation
C 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 the response to Violation
A, implementation
weaknesses
resulted in the development
of a Maintenance
Rule program that was not consistent
with the guidelines
of NUMARC 93-01 and did not comply with all of the requirements
of 10 CFR 50.65. These program deficiencies
were largely responsible
for the examples cited in Violation
C. The specific causes are discussed
below. The procedural
inadequacies
described
in Example No. 1 of Violation
C were caused by the improper and non-conservative
application
of the guidelines
of NUMARC 93-01 during the development
of the Maintenance
Rule program. Example No. 2 of Violation
C was caused by a personnel
error. Although the changes to the performance
criteria for the reactor protection
system had been discussed
by the Maintenance
Rule Working Group, the changes were not formally approved before the Maintenance
Rule database was revised. The lack of training with respect to Maintenance
Rule program responsibilities
and the resulting
insufficient
knowledge
level led to the procedural
compliance
deviations
described
in Example No. 3 of Violation
C. In addition, we identified
that the SSC matrix that was being used to assess on-line maintenance
risk was incomplete
and did not address certain equipment
configurations.
2. Corrective
Steps Which Have Been Taken and the Results Achieved The corrective
actions that addressed
the Maintenance
Rule program development
and implementation
weaknesses
are discussed
in Section 2 of the response to Violation
A and are also applicable
to Violation
C. The specific corrective
actions related to the examples cited in Violation
C are discussed
below. Example No. 1 Station Administrative
Procedure
VPAP-0815, "Maintenance
Rule Program," has been carefully
evaluated
and revised by the Maintenance
Rule Recovery Team to ensure that the program is consistent
with NUMARC 93-01. The resulting
procedural
changes appropriately
define maintenance
rule functional
failures (MRFFs) and maintenance
preventable
functional
failures (MPFFs). The MRFF/MPFF
evaluation
forms in VPAP-0815
were also enhanced to ensure that the screening
process is performed
properly.
2. Corrective
Steps Which Have Been Taken and the Results Achieved (Continued)
The corrective
steps described
in Section 2 of the response to Violation
B ensured that MPFFs in the main feedwater, chemical and volume control, and radiation
monitoring
systems were identified
and evaluated
with respect to their performance
criteria, goals, and monitoring.
Example No. 2 The performance
criteria for the reactor protection
system was reviewed and approved by the Maintenance
Rule Working Group. Training was conducted
for appropriate
personnel
regarding
their responsibilities
in the implementation
of the Maintenance
Rule program, as delineated
in VPAP-0815.
This corrective
action also addressed
Example No. 3. The Senior Vice-President, Nuclear, issued a memorandum
to Nuclear Business Unit personnel, reinforcing
management's
expectations
for complete compliance
with the Maintenance
Rule program. This corrective
action also addressed
Example No. 3. Example No. 3 Station Administrative
Procedure
VPAP-2001, * "Station Planning and Scheduling," has been revised to improve on-line maintenance
practices.
The procedural
changes clarified
the responsibilities
for assessing
the risk associated
with the performance
of on-line maintenance
and changed the work planning/scheduling
processes
to ensure that risk is appropriately
evaluated
and that availability
and reliability
are reasonably
balanced.
- To facilitate
the assessment
of on-line maintenance
risk, additional
tools have been developed
which provide a complete list of PSA risk significant
components
and an expanded PSA evaluation
of on-line maintenance
configurations.
Appropriate
Outage and Planning and Operations
Department
personnel
have been trained in the use of these new tools. 3. Corrective
Steps Which Will be Taken to Avoid Further Violations
The corrective
steps described
in Section 2 of the response to Violation
C are sufficient
to preclude similar violations . ... -.. ... . **: .. ' .--. .,,..... .. ........ ' . -. . . *--. -*-... . ..
4. The Date When Full Compliance
Will be Achieved Full compliance
with the Maintenance
Rule was achieved on June 30, 1997, and was confirmed
in our letter to the NRC, dated July 23, 1997 (Serial No.97-410). *,, ";"<** * *~.--.--*, *T-,, --*-~-,. *