ML18153A066
| ML18153A066 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 09/12/1996 |
| From: | OHANLON J P VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 96-425, NUDOCS 9609170471 | |
| Download: ML18153A066 (7) | |
See also: IR 05000280/1996008
Text
12, 1996 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.96-425 SPS/BCB/GDM
R3 Docket Nos. 50-280 50-281 License Nos. DPR-32 DPR-37 NRC INSPECTlON
REPORT NOS. 50-280/96-08
AND 50-281/96-08
We have reviewed your Inspection
Report Nos. 50-280/96-08
and 50-281/96-08
dated July 11, 1996, and your August 16, 1996 letter and enclosed Notice of Violation
for Surry Units 1 and 2. As discussed
in the attachment, the cited violations
resulted from inadequate
change management
when the hydrogen analyzers'
calibration
procedures
were changed. This conclusion
is based on the results of a Root Cause Evaluation
of the event. We have implemented
corrective
actions to resolve the specific concerns associated
with the violations, as well as more comprehensive
actions to ensure that similar concerns do not exist. Although the violations
were precipitated
by events that occurred at Surry several years ago, we recognize
that the procedure
change process should have identified
the procedural
interface
discrepancy.
This process was subsequently
strengthened
in the early 1990s and was recently enhanced further to preclude a similar event. 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 Attachment
9609170471
960912 PDR ADOCK 05000280 G PDR ~--** .~. -*
1----:--cc: U.S. Nuclear Regulatory
Commission
Region II 101 Marietta Street, N.W. Atlanta, Georgia 30323 Mr. R. A. Musser NRC Senior Resident Inspector
Surry Power Station
- REPLY TO A NOTICE OF VIOLATION
NRC INSPECTION
CONDUCTED
JUNE 17 -JULY 1, 1996 SURRY POWER STATION UNITS 1 AND 2 INSPECTION
REPORT NOS. 50-280/96-08
AND 50-281/96-08
NRG COMMENT: "During an NRG inspection
conducted
on June 17 through July 1, 1996, violations
of NRG requirements
was identified.
In accordance
with the 'General Statement
of Policy and Procedures
for NRG Enforcement
Actions,'
NUREG-1600, the violations
are listed below: A. Technical
Specifications
3.7.G.1 requires that two independent
containment
hydrogen analyzers
be operable during reactor critical or power operation.
Contrary to the above, the Unit 1 and Unit 2 containment
hydrogen analyzers
were inGperable
during reactor critical or power operation
from February 28, 1991, and October 21, 1990, respectively, until May 22, 1996, due to the function selector switches being place in the ZERO position following
calibration.
(01013) B. Technical
Specifications
6.4.A.1 and 6.4.A.2 require, in part, that detailed written procedures
with appropriate
instructions
be provided for the operation, calibration
and testing of all systems and components
involving
nuclear safety of the station. Contrary to the above, from October 24 and October 20, 1990 for Units 1 and 2, respectively, Emergency
Operating
Procedures*
1-E-1 and 2-E-1, 'Loss of Reactor or Secondary
Coolant,'
and Calibration
Procedures
1-IPT-FT-GW-A-104
and 2-IPT-FT-GW-A-204, Containment
Hydrogen Analyzer H2A-GW-104(204)
Quarterly
Functional
Test, did not provide appropriate
instructions
to place the hydrogen analyzers (systems involving
nucle_ar safety of the station) in service. Specifically, the procedures
did not require placing the function selector switches for the-hydrogen analyzers
in the SAMPLE position, which is the required position for sampling the containment
atmosphere
for hydrogen concentration.
(01023) This is a Severity Level Ill problem (Supplement
I)."
L__ ---Violation
A REPLY TO A NOTICE OF VIOLATION
NRC INSPECTION
CONDUCTED
JUNE 17-JULY 1.1996 SURRY POWER STATION UNITS 1 AND 2 INSPECTION
REPORT NOS. 50-280/96-08
AND 50-281/96-08
1. Reason for the Violation, or, if Contested, the Basis for Disputing
the Violation
The violation
is correct as stated and was caused by inadequate
change management.
When the containment
hydrogen analyzers'
calibration
procedures
were changed to leave the function selector switch (FSS) on the local and remote panels in the ZERO position, the emergency
operating
procedures (EOP) did not include instructions
to reposition
the FSS to the SAMPLE position when placing the hydrogen analyzers
in service. Although the ZERO pesition is acceptable
for standby operation, the FSS must be in the SAMPLE position for the hydrogen analyzers
to be capable of performing
their design function.
At the time of the subject change to the calibration
procedures, a review of interfacing
procedures
was not required by the procedure
change process. Consequently, a review of the interfacing
procedures
was not performed
and the need to change the EOPs was not recognized.
As a result, a complementary
change was not incorporated
into the EOPs. This procedural
discrepancy
resulted in the FSSs being left in the ZERO position following
calibration, thereby rendering
the containment
hydrogen analyzers
for an extended period of time. 2. Corrective
Steps Which Have Been Taken and the Results Achieved A Deviation
Report was submitted
to document the subject discrepancy.
l&C and System Engineering
personnel
reviewed the vendor manual for the hydrogen analyzers
to confirm the optimum operational
position for the FSSs. The FSS on the local and remote panels were placed in the SAMPLE position on May 22, 1996. The hydrogen analyzer instrument
calibration
procedures
were revised to provide instructions
for placing the FSS on the local and remote panels in the SAMPLE position following
calibration.
This is the required position to place the hydrogen analyzers
in service using the emergency
operating
procedures.
' . I I
- 2. Corrective
Steps Which Have Been Taken and the Results Achieved (Cont'd.)
A Root Cause Evaluation (RCE) of the event was performed.
The results are summarized
in Section 1 above. The RCE also determined
that the North Anna Power Station operator watchstation
logs periodically
verified the position of the hydrogen analyzers'
FSSs, and that the Surry logs did not. The Surry operator watchstation
logs were subsequently
revised to include a periodic verification
that the FSSs are positioned
correctly.
In addition, a comparative
review of the North Anna and Surry Power Stations'
operator watchstation
logs was performed
to evaluate the commonality
of equipment
checks performed
at each station. No safety equipment
inconsistencies
were identified.
The Te.cbnical
Specifications
and emergency
and abnormal procedures
were reviewed by Operations
and l&C personnel
to evaluate infrequently
performed
evolutions
and post-accident
manual actions to determine
whether additional
procedural
interface
concerns existed. No additional
examples were identified.
The procedure
change process has been revised and improved since the subject hydrogen analyzer calibration
procedure
changes were processed.
These improvements
are discussed
in our response to Violation
B. 3. Corrective
Steps Which Will be Taken to Avoid Further Violations
The corrective
actions discussed
in Section 2 are sufficient
to avoid further violations.
A synopsis of this event is being presented
during the current continuing
training sessions to enhance the operators'
knowledge
and understanding
of hydrogen analyzer operation.
Training will also be conducted
for l&C technicians
during the next l&C continuing
training sessions.
4. The Date When Full Compliance
Will be Achieved Full compliance
was achieved on May 22, 1996 when the FSS on the local and remote panels were placed in the SAMPLE position .
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 Violation
A, a review of interfacing
procedures
was not performed
when the hydrogen analyzers'
calibration
procedures
were changed. The procedure
change process in place at the time the position of the FSSs was modified did not ensure that interfacing
procedures
were considered
for potential
impact. As a result, when the calibration
procedures
were changed to specify that the FSSs be left in the ZERO position following
calibration, the emergency
operating
procedures
were not changed to provide instructions
for placing the FSSs in the SAMPLE position when placing the hydrogen analyzers
in service. 2. Corrective
Steps Which Have Been Taken and the Results Achieved As discblSsed
in Section 2 of Violation
A, the hydrogen analyzer instrument
calibration
procedures
were revised to provide instructions
for placing the FSS on the local and remote panels in the SAMPLE position following
calibration.
This is the required position to place the hydrogen analyzers
in service using the emergency
operating
procedures.
The procedure
change process has been revised and improved since the subject hydrogen analyzer calibration
procedure
changes were processed.
Procedure
revisions
and upgrades have been centralized
under the Procedures
Department, and a technical
procedures
writer's guide has been developed
to standardize
format, style, content, and human factors considerations.
A technical
review is required for new and revised procedures, and technical
review guidelines
have been established
which address procedural
methods, instructions, and configuration
controls.
In addition, administrative
procedure
VPAP-0502, "Procedure
Process Control," has been revised to require an elevated level of review and approval when a procedural
revision or change alters the as-left condition
of a system or component.
This revision also added references
to the Licensee Event Report and NRG Inspection
Report associated
with this violation.
3. Corrective
Steps Which Will be Taken to Avoid Further Violations
The corrective
actions noted in Section 2 of Violations
A and B above are sufficient
to avoid similar violations.
- * * 4. The Date When Full Compliance
Will be Achieved Full compliance
was achieved on September
3, 1996 when VPAP-0502
was revised .