ML18152B046
| ML18152B046 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 07/07/1988 |
| From: | Cruden D VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| 88-375, NUDOCS 8807190077 | |
| Download: ML18152B046 (5) | |
Text
l VIJRGINIA ELECTRIC AN]) PowJER Co:ixt.PANY R.XCEL~l:QND, VIRGXNIA 23261 July 7, 1988 D-. §. CEl!Jl!l>lEN VICE PEre:SIDBt.r'll"-NUCJI.EAB U.S. Nuclear Regulatory Commission Attn:
Document Control Desk Washington, D.C.
20555 Gentlemen:
VIRGHUA EUECTRIC t~~D IJ>OWfR COi'1?AWV SURRY POWER STATION U~ITS 1 AND 2 rJRC Ul§tt>>[CTION REPORT NOS. 50-280/88-ll AND 50-281/88-11 Serial No.
NO/GDM:pms Docket Nos.
License Nos.88-375 50-280 50-281 DPR-32 DPR-37 We have reviewed your letter of June 7, 1988 in reference to the inspection conducted at Surry Power Station on March 28 - April I and April 11-15, 1988 and reported in Inspection Report Nos. 50-280/88-11 and 50-281/88-11.
Our response to the violations described in the Notice of Violation is provided in the attachment.
We have no objection to this inspection report being made a matter of public disclosure.
If you have any further questions, please contact us.
Attachment cc:
U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, N.W.
Suite 2900 Atlanta, GA 30323 Mr. W. E. Holland NRC Senior Resident Inspector 8807190077 880707 PDR ADOCK 05000280 Q
PDC 9
RESPQNSE TO THE NOTICE OF VIOLATION ITEMS REPORTED DURING NRC INSPECTION CONDUCTED ON MARCH 28 - APRIL I AND APRIL 11-15. 1988 INSPECTION REPORT NOSL 50-280/88-11 AND 50-281/88-11 During the Nuclear Reguh.tory Commission (NRC) inspection conducted on March 28 -
April 1 and April 11-15, 1988, violations of NRC requirements were identified.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Act1ons 9 " 10 CFR Part 2, Appendix C (1988), the violations are listed below:
A.
- 8.
10 CFR 50 Appendix E requires that each applicant for an operating license include in the Final Safety Analysis Report plans for coping with emergencies.
The licensee, s Emergency Pl an, Table 4. IA, states an in-tentional reduction in power, load, or temperature because the unit has entered a Technical Specification Action Statement or will exceed a Limiting Condition for Operation is an initiating condition for a Notifi-cation of Unusual Event.
Contrary to *the above, on March 5, 1988, the Emergency Pl an was not ade-quately implemented, in that the licensee declared a Notification of Unusual Event (NOUE) at 0307 and terminate it at 0432, when in fact, the condition causing the NOUE still existed.
This condition involved in-operability of the B and D control rod banks.
This condition was not corrected until successful testing of both control rods banks was com-pleted at 0548.
This is a Severity Level IV violation (Supplement 1).
Technical Specification 3.12.C.3 states that if more than one rod assembly in a given bank is out of service because of a single failure external to the individual rod drive mechanism 7 (i.e programming circuitry), the pro-visions of Specifications 3.12.C.l and 3.12.C.2 shall not apply and the reactor may remain critical for a period not to exceed two hours provided immediate attention is directed toward making the necessary repairs.
In the event the affected assemblies cannot be returned to service within this specified period the reactor will be brought to hot shutdown condi-tions.
Contrary to the above, on March 5, 1988, Unit 2 remained critical from 0302 until 0530 with either control rod bank B or Dor a combination of both banks inoperable due to a defective phase control card in the 1BD power cabinet.
This event initiated at 0102 when a control rod urgent failure alarm was received.
This is a Severity Level IV vio1ation (Supplement 1).
RESPONSE TO NOTICE OF VIOLATION lNSPECTION REPORT NOS. 50-280/88-11 AND 50-281/88-11 ADMISSION OR DENIAL OF THE ALLEGED VIOLATION:
The violation is correct as stated.
REASONS FOR VIOLATIO~:
The cause w~s due to a misinterpretation of Tech~ical Specifications. Control bank Dis the only bank of control rods that is used to control reactor power when critical. Control bank Bis normally fully withdrawn and is used to shut down the reactor.
At all times, during this event, this bank was capable of being inserted into the core upon receipt of a reactor trip signal.
The failed phase control card in the IBO cabinet controls the operation of control bank B rods.
When this card was replaced, control bank D was successfully tested. Since the movement of this bank is used to control reactor power and temperature, it was determined that the condition that caused the notification of unusual event had been corrected. Subsequent testing of control bank B yielded a second random failure of the same circuit card.
The emergency plan was correctly entered when a reduction in power was initiated in accordance with T.S. 3.12.C.3. It was exited on the belief that the control bank D prob-lem had been corrected and that control bank B was operable because it could still perform its intended shutdown function.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:
Additional review of actions surrounding the entrance to and exit from Tech-nical Specification LCOs is being performed.
Shift Technical Advisors (STA) revie~-a station deviations and are notified by the shift supervisors of any emergency plan implementation.
The STAs report to the Assistant Station Manager - Nuclear Safety and Licensing.
This constitutes an immediate inde-pendent review of operational events and should provide additional guidance on Technical Specification interpretations.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
The requirement for SROs to adequately assess and test components prior to declaring the component operable wi11 be reinforced by issuing written guid@nce to SROs.
THE DATE WHEN FUll COMPLIANCE WILL BE ACHIEVED:
Full compliance will be achieved by July 31, 1988.
RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 5~88-11 AND 50-281/88-11 ITEM B ADMISSION OR DENIAL OF THE_ALLEGED VIOLATION:
The violation is cQrrect, in that a continuous reduction of reactor power was not maintained for the entire period from expiration of the two hour allowance at 0302 until the successful testing of both control rod banks Band D at 0530.
We believe the intent of this Technical Specification is to allow two hours of full power operation while attempting to correct the problem associated with rod control circuitry and then, if unsuccessful, to require the initiation of an orderly reactor shutdown.
Otherwise, a reading of this specification to require the unit to be shutdown at the end of the two hour time period would not allow time for problem resolution, and would necessitate a reactor trip.
REASONS FOR VIOLATION:
In addition to the reason noted in our response to Item A, the specific re-quirements associated with the implementation of the unit shutdown were not clear. Several Surry Technical Specifications contain a requirement to shut-down the reactor if an out-of-service time allowance is exceeded, but do not specify a time to reach hot shutdown.
Other Technical Specifications do not explicitly require a shutdown upon expiration of the out-of-service time allowance.
In these cases, the time limits of T.S. 3.0.1 (six hours to hot shutdown) are invoked.
Station practice has been to immediately initiate a ramp in those cases where an explicit shutdown requirement was included, and to use the six hour time period of T.S. 3.0.1 as guidance for the maximum allowable duration of the power reduction.
In this case~ which was compli-cated by the requirement to perform a power reduction without rod control, turbine and reactor power were reduced from 0302 to 0409.
At 0409~ the ramp was stopped in order to test the control rods following replacement of the failed card.
Following successful testing of control bank D, it was deter-mined that the condition that caused the urgent failure alarm had been corrected, and that the requirements of T.S. 3.12.C.3 had been satisfied.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:
The event was included as part of operations required reading. Additional review of actions surrounding the entrance into and exit from Technical Speci-fication LCOs is being performed by the Shift Technical Advisor (STA) con-current with shift activities during the event. Shift Supervisors are now required to inform the STA of any emergency plan implementation.
The STAs review of operational events wi11 provide additional guidance on Technical Specification interpretations. The STAs report to the Assistant Station Manager, Nuclear Safety Licensing, and are therefore in a position to provide independent review of Technica1 Specification interpretations.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
Written guidance is being developed to reinforce the requirement for SROs to adequately assess and test a component prior to declaring a component opE;"i:lbfo.
In gddition, Surry Technical Specifications will be reviewed, and in those cases where currently a reactor shutdown is required upon expiration of an
-out-of~servics time allowance, revisions to specify time requirements will be proposed.
THE DATE WHEN FULL COMPLIANCE Will BE ACHIEVED:
Full compliance has been achieved. The written guidance will be provided to the shift by July 31, 1988.