ML18153C827
| ML18153C827 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 11/20/1991 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 91-648, NUDOCS 9111270083 | |
| Download: ML18153C827 (7) | |
Text
e e
VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, ViRGINIA 23261
. November 20, 1991 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 REPL V TO A NOTICE OF* VIOLATION Serial No.:
91-648 SPS/RCB/ETS R-7 Docket Nos.:
50-280 50-281 License Nos.: DPR32 DPR-37 NRC INSPECTION REPORT NOS. 50-280/91-24 AND 50-281 /91-24 We have reviewed your Inspection Report Nos. 50-280/91-24 and 50-281/91-24 dated October 21, 1991, and our reply to the Notice of Violation is provided in Attachment 1.
We have reemphasized and are strengthening management oversight and controls to enhance coordination of and. sensitivity to safety related activities.
The Station Manager has also alerted plant personnel to the details of the diesel event and reiteriated management's expectation that established programmatic controls be followed.
We plan to further assess the acceptability of manual operator actions for interim.
measures or mitigating actions. This assessment, which will be performed with the assistance of an outside consultant, will specifically address the impact of manual actions_ on safety system operability. Our intent is to develop a policy with regard to
. acceptable operator manual intervention which is consistent with the Technical
-Specification definition of qperability.
Separately, a task team is evaluating the emergency diesel generator governor and control circuits to ensure that consistent, reliable automatic speed and load control are provided by the system. This task team is using consultants, as necessary, to provide additional technical expertise to assure that the previous control system setting concerns have been properly understood and adequately corrected. Increased management attention is also being focused on the Post Maintenance Testing Program and its implementation. The Post Maintenance Testing Program is currently being evaluated by Quality Assurance during the ongoing maintenance follow-up assessment and Engineering is implementing an action plan to enhance the program.
9 i :L 120
() '.:i C) 0 (> :::::: ()
F'DF~
e A check for the payment of the Civil Penalty is attached to this lett~r. We have no objection to this reply being disclosed to the public.
If you have any furth_er questions, please conta_ct us.
Very truly yours, Wl5~--
- w. L.. Stewart Senior Vice President - Nuclear Attactimerits
- 1. Reply to Notice of Vioiation
- 2. Check for payment of Civil Penalty
. cc:
U. S. Nuclear Regulatory Commission
. Region II 101 Marietta Street, N.W.
Suite 2900
.Atlanta, Georgia 30323 Mr. M. W Branch
- NRC Senior Resident Inspector Surry Power Station
i REPL V TO A NOTICE OF VIOLATION NRC INSPECTION CONDUCTED AUGUST 2-26, 1991 SURRY POWER STATION UNITS 1 AND 2 INSPECTl'ON REPORT NOS. 50-280/91-24 AND 50-281/91-24 NRC. COMMENT:
"During a NRC inspecti-on conducted on August 2-26, 1991, violations of NRC requirements were identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 1 O CFR Part 2, Appendix C (1991 ), the Nuclear Regulatory Commission proposes to impose two civil penalties 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 penalties are set forth below:
A.
Technical Specification (TS) 3.16.B.'1 requires that when the Unit's dedicated Emergency Diesel Generator (EOG) or shared backup EOG is inoperable, the
- operability of the other EOG be demonstrated daily, and that the inoperable EDG be returned to service within seven days or the reactor brought to a cold shutdown.
Contrary to the above, after maintenance rendered the shared backup EDG automatic safety function inoperable on May 9, 1991, the. dedicated EDGs in Units 1 and 2 were not tested daily nor were the units placed in cold shutdown Within the required seven day period. The shared backup EOG automatic safety
- function remained inoperable until August 2, 1991. From May 9 to August 2, 1991, Unit 1 operated without satisfying the above TS Action Statement." Unit 2 operated June 1 and 2, June 5 through 11 and July 2 through August 2, 1991, with.out satisfying the above TS Action Statement.
- This is a Severity Level Ill violation (Supplement I).
Civil Penalty - $75,000.
B.
TS 3.3.B.2 requires, in part, that, if two of the.three charging pumps in a unit are out of service, one of the inoperable pumps shall be restored to an operable
- status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. If one of the inoperable pumps is not restored within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, then the reactor shall be shut down.
Contrary to the above, since 1980, Units 1 and 2 charging pumps were routinely aligned such that the "A" and "C" charging pumps in each unit were inoperable in excess of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the units were not brought to shutdown. The: pumps would not automatically start during an accident that required safety injection with a loss of off-site power. Recent examples when this condition existed for Unit 1 were April 26 through May 26, June 20 through August 2, and August 19 through August 21, 1991 and for Unit 2, March 8 through 30, 1991 and July 3 through 5, 1991.
This is a Severity Level Ill violation (Supplement I).
Civil Penalty - $50,000."
e REPLY iO A NOTICE OF VIOLATION SURRY POWER STATION UNITS 1 AND 2 INSPECTION REPORT NOS. 50-280/91-24 AND 50-281/91-24 ITEM A.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION The violation is correct as stated.
REASON FOR THE VIOLATION The dedicated Emergency Diesel Generators (EbGs) in Units 1 and 2 were not tested
- daily nor were the units placed in cold shutdown within the required seven-day period because station personnel were unaware that maintenance on the governor, which
. had
- been performed on May 9, 1991, had rendered #3 EOG* incapable* of automatically performing its safety function and that the EOG had not received the proper post maintenance testing.
The Woodward UG-8 governor had been replaced by a team consisting of a vendor *
- representative and* appropriate Virginia Power personnel. The EOG exhibited slight load drift during return to service testing and governor adjustments were made to stabilize the drift.
Following these adjustments and a test run, during which the governor and load remained stable, the EOG was declared operable and returned to se*rvice.
The approved work order steps being used by the team specified that Operations Department personnel be requested to perform a fast, start of the EDG following governor change out. However, the post-maintenance testing (PMT) follower included in the work package did* not specifically require an EOG fast start.
Communication difficulties between the Maintenance, Engineering, and Operations Department personnel resulted in a slow start test rather than the requested fast start test being performed. A fast start of the EOG should have revealed the problem with the governor setting.
- CORRECTIVE STEPS WHICH HAVE BEEN* TAKEN AND THE.
RESULTS ACHIEVED Upori identification of the cause for #3 EDG's low speed condition, its governor was readjusted and two consecutive fast starts were* performed to verify operability. In
- addition, the #1
- and #2 EDGs were fast start tested and their operability was verified.
The governor gearing and speed knobs for #1 and #2 EOG were scribed or match-.
marked.at the 900 RPM setting (#3 EDG's gearing and speed knob had been scribed earlier). A "see-through" cover plate has been installed on each governor limit switch enclosure so that the scribed match-marks may be observed without cover removal.
The match-mark alignment is checked each shift to verify the proper 900 RPM setting.
The post-maintenance testing matrix for the EDGs has been revised to provide specific
- fast start testing requirements following any governor maintenance. The procedures for governor maintenance and fast start operation have also been upgraded. The Station Manager has issued a memorandum describing the event to supervisors and department heads which emphasized the importance of procedural compliance and attention to detail.. The event was also reviewed by senior Corporate management at
- recent Employee Update Meetings held at the station.
page 1 of 3
e e
CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER.
v1o*LATIONS Selected station personnel will receive specific training on the EOG governors in order to acquire a better understanding of the function and prc;,per maintenance of this equipment. The governor's vendor will participate in this training. In order to verify the effectiveness bf corrective actions taken thus far, monthly EOG fast start testing will be conducted through December 1991.
In addition, Event Review and Component
. Failure Analysis Teams are reviewing root causes to ensure continued EOG reliability and availability. A task team is in the process of evaluating the emergency diesel generator governor and control-circuits to ensure that consistent, reliable automatic speed and load control are provided. This task team is using the vendor(s) and independent consultants to reassess-previous control system problems to ensure they are understood and have been adequately corrected.
Furthermore, the Quality Assurance Department will evaluate the Post Maintenance Testing*. Program and its implementation during the ongoing Maintenance Follow-up Assessmenf THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance was achieved on September 24, 1991, when* operating.logs were revised to require visual verification of governor match-marks once per shift.
page 2 of 3
e ITEM 13.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION The violation is correct as stated.
REASON FOR THE VIOLATION The violation. was a result of inadequate review of the Charging Pump/High Head
- Safety Injection (HHSI) Pump interlocks during a design modification implemented in 1981. At that time, it was recognized that operatqr intervention would be required to assure Safety Injection performance in certain pump configurations. This contingency action is addressed* in the Emergency Operating Procedures (EOP). Operators were trained on the appropriate response in the EOPs and were also trained in the system's design and the associated interlocks. The effectiveness of the training and required opemtor actions have recently been revalidated on the Surry plant simulator. 0 n further review, however, it has been determined that charging pump configurations which would require such intervention were outside the design basis of the plant.
Although the violation is correct as stated, it should be noted that only one charging pump on each unit was affec;:ted by the interlock.*.When in service, each pump remained available to perform its.safety function and could have been started by the operators from the control* room in approximately 15 seconds in accordance with the immediate actions of the EOPs with no effect on accident analyses.
CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED
- The Unit 1 charging pumps were promptly placed in a configuration which would not require operator action. The Unit 2 pump configuration was satisfactory. Operational controls were established to preclude inappropriate alignments.
CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER.
. VIOLATIONS Procedure changes will be made* as *necessary to ensure that the pumps are aligned in a configuration where automatic HHSI actuation capability is maintained.
In addition, a review has been initiated to determine if other major plant components require manual operator action which is inconsistent with design basis operation. We
- will readdress the issue of manual operator actions With respect to safety system operability with the assistance of an outside consultant. Our goal is the development of a policy with regard to acceptable operator manual intervention which is consistent with the Technical Specification definition of operability.
- THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance was achieved ori August 21, 1991, when the Charging/HHS! Pumps were placed in a configuration not requiring operator action.
page 3 of 3