ML18152B052
| ML18152B052 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 07/13/1988 |
| From: | Cruden D VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| 88-386, NUDOCS 8807190262 | |
| Download: ML18152B052 (6) | |
Text
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D.S.CRUDEN VICE PRESIDENT-NUCLEAR VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 July 13, 1988 U. S. Nuclear Regulatory Commission Attn:
Document Control Desk Washington, D.C.
20555 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 NRC INSPECTION REPORT NOS. 50-280/88-04 AND 50-281/88-04 Serial No.
NO/GDM:pms Docket Nos.
License No.88-386 R2 50-280 50-281 DPR-32 DPR-37 We have reviewed your letter of June 13, 1988 in reference to the inspection conducted at Surry Power Station on February 1-27, 1988 and reported in Inspection Report Nos. 50-280/88-04 and 50-281/88-04.
Our response to the violations described in the Notice bf Violation is provided in Attachment 1.
Payment of the assessed civil penalty is provided in Attachment 2~
We have no objection to this inspection report being made a matter of public disclosure.
If you have any further questions, please contact us.
Very truly yours,
~u1 <IJPhJw,d_ /oi Attachments 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 Surry Power Station
RESPONSE TO THE NOTICE OF VIOLATION ITEMS REPORTED DURING NRC INSPECTION CONDUCTED ON FEBRUARY 1-27, 1988 INSPECTION REPORT NOS. 50-280/88-04 AND 50-281/88-04 NRC COMMENTS During an NRC inspection conducted during the period of February 1-27, 1988, violations of NRC requirements were identified.
In accordance with the "General Statement of Policy ahd Procedure for NRC Enforcement Actions," 10CFR Part 2, Appendix C (1988), the Nuclear Regulatory Commission 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.
Technical Specifications (TS) 3.2.B.5 and 3.2.C.5 for one unit and two unit operation of the Chemical and Volume Control System (CVCS),
respectively, require that two channels of heat tracing be operable for boric acid flowpaths requiring heat tracing.
TS 3.2.D.3 states that one heat tracing circuit may be inoperable for a period not to exceed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> provided that immediate attention is directed to repairing the circuit.
Contrary to the above, as of February 19, 1988, heat tracing circuits on both channels required for the eves boric acid flowpaths to Unit 1 and Unit 2 were inoperable for periods in excess of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
B.
Technical Specification (TS) 4.1.A, Table 4.l-2A, Item 12, requires that the eves Boric Acid Tracing Circuits be verified as operable on a monthly basis.
TS 6.4.A.2 requires written -procedures with appropriate instructions for testing of components and systems involving nuclear safety of the station.
Contrary to the above, from December 1984 for Unit 1 and May 1985 for Unit 2 until February 19, 1988, surveillance procedures l-PT-27H, l-PT-27I, and 2-PT-27G, required by TS 6.4.A.2 and which were used to verify eves Boric Acid Tracing Circuits system operability on a monthly basis, were determined to be inadequate in* that these procedures did not test the boric acid flowpath heat trace control circuits, and did not enable verification of operability in accordance with TS Table 4.l.A-2A, Item 12.
Collectively these violations have been categorized as a Severity Level III problem (Supplement I).
RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-280/88-04 AND 50-281/88-04 ITEM A A.
Heat tracing circuits inoperable for periods in excess of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
- 1.
ADMISSION OR DENIAL OF ALLEGED VIOLATION The violation is correct as stated.
- 2.
REASONS FOR THE VIOLATION The failure to assure operability of the heat tracing circuits resulted primarily from an inadequate surveillance procedure due to an inadequate understanding of the system design.
Specifically, the surveillance procedures did not verify proper operation of the heat trace control circuitry.
These procedures did verify proper performance of the heat tape for each heat trace circuit by measuring the power consumed by each section of tape.
Following a major redesign of the heat tracing system in 1981, the heat tape surveillance tests were revised to reflect changes in the heat tape design parameters.
However, it was not recognized that the electronic control circuits added to the system in the redesign required periodic testing.
Appropriate post modification testing of control circuits was performed following system installation, and again following design ch~nges in
- 1984 and 1985.
- However, this testing was not incorporated into the monthly surveillance program.
A contributing factor was inadequate follow-up of the "CVCS Heat Trace Trouble" annunciator in the control room.
Due to routine plant operations and a system design that incorporates 214 heat trace circuits into six control panels which feed one common control room annunciator, this annunciator was often lit. Additionally, any *operability problems associated with either T.S. or non T.S. heat trace tape (e.g., failed tape or control circuits) would cause the control room annunciator to light.
Due to the persistence of alarms which did not reflect inoperable Technical Specifications circuits, both the control room operators and management became desensitized to the importance of the heat trace trouble annunciator.
It was not until it was discovered that the heat tracing control circuitry required a periodic surveillance that system operability was questioned.
Prior to this determination, appropriate action,,.
statements were enter.ed and heat* tape repairs were performed to maintain operable boric acid flow paths as required by Technical Specifications based on the heat tape performance surveillance testing.
- 3.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED Once the over/under temperature setpoint discrepancies and control circuit problems were identified, an aggressive program to address these issues was implemented.
An initial recalibration and functional test of the control and alarm circuits for the required Technical Specifications flowpaths was performed, followed by similar testing of the remaining heat. tracing circuits in the six eves heat tracing panels.
During testing, components in the control circuits were replaced as necessary.
Throughout this calibration and functional
- testing, Technical Specification action.statements were entered as discrepancies were noted Corrective ~ctions were implemented and temperatures of the required flow paths were monitored to ensure operability of the boric acid flow paths.
A new monthly surveillance program for under/over temperature setpoint and control relay verification has been implemented in addition to the heat tape performance monitoring.
The annunciator response procedure for the control room alarm was also revised to require local verification of T.S.
required circuit status and initiate appropriate actions when the alarm is received.
An operational checklist was developed to monitor circuit status.
In addition, to focus attention on alarm status the Shift Technical Advisors have implemented a program that provides a weekly technical review of control room annunciator status.
This review includes identification of the reason for the alarm to assess its importance and *a determination of the status of the associated corrective actions to assess persistence of the problem and ensure adequate attention is being directed to resolution. These results are reported to management.
- 4.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS None required.
- 5.
THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance has been achieved.
RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-280/88-04 AND 50-281/88-04 ITEM B B.
Inadequate surveillance procedures for boric acid heat tracing circuits.
- 1.
ADMISSION OR DENIAL OF THE VIOLATION The violation is correct as stated.
- 2.
REASONS FOR THE VIOLATION As noted in the response to Violation A, following a system redesign in 1981 the survei 11 ance procedure used to verify operability of eves heat tracing was not changed to include control circuitry.
It was not recognized that the electronic control circuits required periodic testing therefore, monthly testing continued to only verify heat tape performance.
- 3.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED
- 4.
A surveillance test was developed to verify proper control setpoints and control relay operation.
This test has been added to the periodic test scheduling* system, and has been performed on a monthly basis since March 1988.
Recognizing the importance of properly translating system design changes into appropriate.revisions to procedures, several enhancements to the design control process had previously been implemented.
These included more detailed review of modifications for procedural impact, increased emphasis on completion of required. procedure changes prior to restoring modified systems to operation, and formal tracking of procedure changes when such changes could not be made prior to returning systems to service.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS None required.
- 5.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance has been achieved.
I Pay To The Disb.
VIRGINIA ELECTRIC AND POWER CDMPANY Bank Number 01 Number Ollllf 8 b Date 06/24/88 Invoice Number Or Description Gross Amount 000117 so,ooa.oo PAYMENT OF CIVIL PENALTY 50,000-00 Attached Check Issued As Payment Of Items Listed Above-Please Detach Stub And Cash Check Promptly.
Discount VIRGINIA POWERi NORTH CAROLINA POWER V'/achov,a Bani<, and Trust Company i'J A Accounts Payable Check As11ev1ile. ~Jorn, Carolina Void If Not Cashed In 90 Days Vendor Number 066001.f Net Amount 50,000.oo 50,ODO -DD 66-35 531 EXACTLY FIFTY THOUSAND AND N0/100**********~***********************************
D1sb.
Bk Number TREASURER OF THE UNITED STATES..
- 01 I 01lf lf86 RECTOR OFFICE Of ENFORCEMENT TED STATES REGULATORY MMISSION WASHINGTON DC 20555 Da1e Vendor Number Amount
$50,000-00 J