ML18153A025
| ML18153A025 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 07/11/1996 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18153A024 | List: |
| References | |
| 50-280-96-08, 50-280-96-8, 50-281-96-08, 50-281-96-8, NUDOCS 9607230215 | |
| Download: ML18153A025 (8) | |
See also: IR 05000280/1996008
Text
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I I
Docket Nos:
License Nos:
Report No:
Licensee:
Facility:
Location:
Dates:
Inspectors:
Approved by:
9607230215 960711
ADOCK 05000280
G
50-280, 50-281
50-280/96-08, 50-281/96-08
Virginia Electric and Power Company
Surry 1 & 2
5570 Hog Island Road*
Surry, VA 23883
June 17 - July l, 1996
M. Branch, Senior Resident Inspector
W. Poertner, Resident Inspector
G. Belisle, Chief, Reactor Projects Branch 5
Division of Reactor Projects
Enclosure 1
EXECUTIVE SUMMARY
Surry Power Station
NRC Inspection Report Nos. 50-280/96-08, 50-281/96-08
This special inspection was conducted on-site to review and evaluate the
circumstances associated with information contained in Licensee Event Report
(LER) 50-280/50-281/96-004-00 involving inoperable containment hydrogen
analyzers.
Operations
One Apparent Violation was identified involving inoperable containment
hydrogen analyzers on both units during operation.
A visiting operator
from your North Anna facility observed that switch positions on the
hydrogen analyzers were different than those at North Anna.
Subsequent.
licensee followup revealed that the hydrogen analyzers were inoperable,
. and this condition potentially existed for approximately ten years .
01
Conduct of Operations
01.1
General Comments (71707)
Report Details
I. Operations
The inspectors reviewed and evaluated the circumstances associated with
information contained in Licensee Event Report (LER) 50-280/50-281/96-
004-00.
One notable example of operator awareness was the
identification that the switch positions on the hydrogen analyzers were
different than those at North Anna.
02
Operational Status of Facilities and Equipment
02.1
Inoperable Hydrogen Analyzers
a.
Inspection Scope
(40500, 71707, 92700)
On May 22, 1996, the licensee determined that the Instrumentation and
Control (I&C) procedures for testing the hydrogen analyzers incorrectly
placed the Function Selector Switches (FSSs) on both the local and
remote panels in the ZERO position following calibration. This switch
position renders the hydrogen analyzers incapable of monitoring
containment hydrogen concentration if placed in service as directed by
the Emergency Operating Procedures (EOPs).
The inspectors reviewed the
licensee's characterization of the event described in the LER.
The
Updated Final Safety Analysis Report (UFSAR), EOPs, and vendor manual
for the hydrogen analyzer equipment operation were also reviewed.
Additionally, the inspectors reviewed the past operability implications
of the improper switch positions and the licensee's actions to correct
and document the discrepancy.
b.
Observations and Findings
On May 10, 1996, Unit 1 was operating at 100 percent power and Unit 2
was at cold shutdown for a scheduled Refueling Outage.
While performing
a routine walkdown in the Auxiliary Building, an operatorr on loan from
North Anna, noticed that the FSSs on the Hydrogen Analyzer Local and
Remote Panels for both units were in the ZERO posttion which was not
consistent with the switch positions at North Anna.
After further investigation by the operator, system engineering was
notified of this condition at 3:21 a.m., on May 22, 1996.
Engineering
concluded, that in order for the hydrogen analyzers to take and analyze
containment air samples following a Loss of Coolant Accident (LOCA), the
main power switch on the Main Control Room (MCR) Post Accident
Monitoring (PAM) panel had to be in the ANALYZE position and the FSS on
the local or remote panels controlling the hydrogen analyzers must be in
2
the SAMPLE position. Actions were taken to place th~ FSSs in the
correct position at 6:00 p.m. on May 22, 1996.
Description of Equipment
The two Technical Specification (TS) required containment hydrogen
analyzers, located in the Auxiliary Building, are shared between
Units 1 and 2.
The MCR PAM panel provides indication and controls
for the hydrogen analyzers.
The main power switch on the MCR PAM
panel has three positions: OFF, STANDBY, and ANALYZE.
In the OFF
position, no power is applied to the hydrogen analyzers.
The
STANDBY position energizes hot box heaters in the local analyzer
panels.
The hot box heaters mediates a sample's temperature
between 275 and 300 degrees Fahrenheit so the hydrogen analyzers
can operate at their design accuracy.
The ANALYZE position draws
an air sample from inside containment through the hydrogen
analyzer.
The main power switch is maintained in the STANDBY
position during normal operation.
EOPs place the main power
switch in the ANALYZE position in response to a LOCA.
The local and remote panels are located in the Auxiliary Building
and the Control Room Annex, respectively. These panels contain a
local/remote push button that determi.nes which panel controls the
hydrogen analyzer. Additionally, each panel has a FSS with three
settings: ZERO; SPAN and SAMPLE.
The ZERO position is used to
calibrate the analyzer cell and hydrogen concentration meter
responses to a known gas sample.
The SPAN position is a
calibration mode used to adjust the full scale.deflection of the
hydrogen concentration meter.
The SAMPLE position supplies oxygen
reagent gas to the hydrogen analyzer so the hydrogen concentration
in containment can be determined.
For a hydrogen analyzer to test containment air for hydrogen, .the
main power switch must be in the ANALYZE position and the FSS at
the panel controlling the hydrogen analyzer must be in the SAMPLE
position.
Hydrogen analyzers became a requirement for plant operation on October
15, 1984, by TS Amendments 100 and 99 (Unit 1 and Unit 2, respectively).
The purpose of these amendments was to specify operability requirements
for a Hydrogen Monitoring System that would analyze containment air
samples during a response to a LOCA.
TS 3.7.G.l states "Two independent
containment hydrogen analyzers shall be operable during Reactor Critical
or Power Operations."
Review of instrument calibration procedures concluded Calibration
Procedure, CAL-GW-175, H2A-GW-104 Containment Hydrogen Monitor, dated
January 14, 1982, was the initial governing procedure for positioning
the hydrogen analyzer switches.
Return to service in CAL-GW-175 placed
the FSSs in the SAMPLE position which is the correct position.
Between
October 22, 1986, and October 24, 1990, for Unit 1 and between
C.
3
November 26, 1985, and October 20, 1990, for Unit 2, the calibration
procedures required the hydrogen analyzer to be placed in standby with
no position specified for the FSSs during return to service actions.
I&C personnel could not recollect what position the FSSs were left in at
the completion of testing during these time periods.
A subsequent
procedure change on October 24, 1990, for Unit 1 and October 20, 1990,
for Unit 2 left the return to service position of the FSSs in the ZERO
position.
Thus, the TS 3.7.G.l requirement for operable hydrogen
analyzers had not been met due to the FSSs being procedurally positioned*
incorrectly since these procedural revisions were implemented on
February 28, 1991, for Unit 1 and October 21, 1990, for Unit 2.
Due to
the lack of procedural controls, this condition may have existed for
approximately ten years.
The licensee evaluated the safety consequences and implications of this
event as part of their LER process.
The potential for hydrogen
generation following a design basis LOCA has been analyzed and is
addressed in the UFSAR.
As shown in UFSAR Figure 6.2-6, a hydrogen
level of four percent, the minimum combustible hydrogen level, would be
reached approximately three days after a LOCA.
Following a LOCA,
operations performs EOP l-E-1, Loss of Reactor or Secondary Coolant,
revision 13.
Step 18 of EOP 1-E-l directs chemistry to obtain samples
of containment atmosphere and sample for hydrogen.
The licensee stated
that, upon review of the sample results indicating hydrogen in
containment, it would be determined that the hydrogen analyzers were
inoperable and that operator actions would be taken to restore hydrogen
monitoring prior to hydrogen reaching the combustible level.
The
inspectors acknowledged that the operators may be presented an
opportunity to detect the inoperable hydrogen analyzers and correct this
condition.
This action could be performed from the control room annex
which is assessable post LOCA.
The licensee attributed this event to procedural deficiencies caused by
personnel error. A station deviation report was issued.
Permanent
changes to hydrogen analyzer instrument calibration procedures were
- implemented.
These changes reflect the return to service position of
the FSSs as SAMPLE on the local and remote panels for the hydrogen
analyzers.
The licensee is developing a reverification plan to ensure
that other standby equipment is in the proper configuration.
The inspectors determi~ed that another root cause 6f this event was a
lack of a knowledge by the I&C technicians.
Specifically, I&C
technicians who routinely performed the procedure demonstrated a lack of
familiarity with operation of the hydrogen analyzers by not questioning
the appropriateness of leaving the FSSs in the ZERO position.
Conclusions
The inspectors determined that with the FSSs in the ZERO position
neither hydrogen analyzer would be operable when the MCR PAM main power
switch was turned from STANDBY to the ANALYZE position.
This condition
existed from February 28, 1991, for Unit 1 and October 21, 1990, for
4
Unit 2 until May 22, 1996.
This condition may have existed for
approximately ten years.
The failure to maintain the hydrogen analyzers
in a condition that would allow them to perform their intended safety
function is identified .as EEi 50-280, 281/96-08-01, Unit Operation With
Inoperable Containment Hydrogen Analyzers.
V. Management Meetings
Xl
Exit Meeting Summary
The inspectors presented the inspection results to members of licensee
management at the conclusion of the inspection on July l, 1996.
The licensee*
acknowledged the findings presented.
The ins~ectors asked the licensee whether any m~terials examined during the
inspection should be considered proprietary.
No proprietary information was
i dent.if i ed.
PARTIAL LIST OF PERSONS CONTACTED
Licensee
W. Benthal, Supervisor, Procedures
D. Christian, Station Manager
M. Crist, Superintendent of Operations
C. Lovett, Supervisor, Licensing
R. Saunders, Vice President, Nuclear Operations
J. Yaffey, System Engineer
IP 40500:
IP 71707:
IP 92700:
Opened
~
EEi
INSPECTION PROCEDURES USED
Effectiveness of Licensee Controls in Identifying, Resolving, and
Preventing Problems
Plant Operations
Onsite Followup of Written Repofts of Nonroutine Events at Power
Reactor Facilities
. ITEMS OPENED, CLOSED, AND DISCUSSED
Item Number
50-280, 281/96-08-01
Status
Open
Description and Reference
Unit Operation With Inoperable
Hydrogen Analyzers .
j ,
I
'
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34386
Federal Register / Vol. 60, No. 126 / Friday,. June 30, 1995 / Notices
factors in arriving at the appropriate
severity level will be dependent on the
circumstances of the violation.
However, if a licensee refuses to correct
a minor violation within a reasonable
time such that it willfully continues, the
violation should be categorized at least
at a Severity Level IV.
D. Violations of Reporting Requirements
The* NRC expects licensees to provide
complete, accurate, and timely
- * * *
information and reports. Accordingly,
unless otherwise categorized in the
Supplements, the severity level of a
violation involving the failure to make
a required report to the NRC will be
based upon the significance of and the
circumstances surrounding the matter
that should have been reported.
However, the severity level of an
untimely report, in contrast to no report,
may be reduced depending on the
circumstances surrounding the matter.
A licensee wilJ not normally be cited for
a failure to report a condition or event
unless the licensee was actually aware
of the condition or event that it failed
to report. A licensee will, on the other
. hand, normally be cited for a failure to
report a condition or event if the
licensee knew of the information to be
reported, but did not recognize that it
was required to make a report.
V. Predecisional Enforcement
Conferences
Whenever the NRC has learned of the
existence of a potential violation for
whir.h escalated enforcement action
appears to be warranted, or recurring
nonconformance on the part of a
vendcir, the NRC may provide an
opportunity for a predecisional.
enforcement conference with the
licensee, vendor, or other person before
taking enforcement action. The purpose
of the conference is to obtain
information that will assist the NRC in
determining the appropriate
enforcement action, such as: (1) A
common understanding of facts, root
causes and missed opportunities
associated with the apparent violations,
(2) a common understanding of
corrective action taken or planned, and
(3) a common understanding of the
significance of issues and the need for
lasting comprehensive correctiye action.
If tlie NRC concludes that it has
sufficient information to make an
informed enforcement decision, a
conference will not normally be held
unless the licensee requests it. However,
an opportunity for a conference will
normally be provided before issuing an
order based on a violation of the rule on
Deliberate Misconduct or a civil penalty
to an unlicensed person. If a conference
is not held, the licensee will normally
be requested to provide a written
response to an inspection report, if
issued, as to the licensee's views on the
apparent violations and their root
causes and a description of planned or
implemented corrective action.
During the predecisional enforcement
conference,.the licensee, vendor, or
other persona will be given an : 19~ ., ; .:r,11
opportunity to provide information
consistent with the purpose of the
conference, including an explanation to
the NRC of the immediate corrective
actions (if any) that were taken
following identification of the potential
violation or nonconformance and the
long-term comprehensive actions that
were taken or will be taken to prevent
recurrence. Licensees, vendors, or other
persons will be told when a meeting is
a predecisional enforcement conference.
A predecisional enforcement
conference is a meeting between the
NRC and the licensee. Conferences are
normally held in the regional offices
and are not normally open to public
observation. However, a trial program is
being conducted to open approximately
25 percent of all eligible conferences for
public observation, i.e., every fourth
eligible conference involving one of
- three categories of licensees (reactor,
hospital, and other materials licensees)
will be open to the public. Conferences
will not normally be open to the public
if the enforcement action being
contemplated:
(1) Would be taken against an
individual, or if the action, though not
taken against an individual,-tums on
whether an individual has committed
wrongdoing;
(2) Involves significant personnel
failures where the NRC has requested
that the individual(s) involved be
present at the conference:
(3) Is based on the findings of an NRC
Office of Investigations report: or
(4) Involves safeguards information,
Privacy Act information, or information
which coµld be considered proprietary;
In addition, conferences will not
normally be open to the public if:
(5) The conference involves medical
misadministrations or overexposures
and the conference cannot be conducted
without disclosing the exposed
individual's name; or
(6) The conference will be conducted
by telephone or the conference will be
conducted at a relatively small
licensee's facility.
Notwithstandmg meeting any of these
criteria, a conference may still be open
if the conference involves issues related
to an ongoing adjudi..:litory proceeding
with .one or more intervenors or where
the evidentiary basis for the conference
8
is a matter of public record, such as an
adjudicatory* decision by the
. . . .
Department of Labor.~ additio~. ~th_ .
the app~val of the Executive ~or
for Operations, conferences will not be
open to the public where good cause has
been shown after balancing the benefit
of the public observation asainst ~~-- .
potential iJnna..t = ............ a.-.* -.I',;~ '
--~~-
..... ~1ru,~ma,
ep{01J:81Denl actl.~ . . _
.that.. ~
.
. As soon.as it is
ed
a . ; .
conference will be open*fu public . *. ":.
observation, the NRC will notify the
licensee that the conference will be
open to public observation as part of the
agency's trial program. Consistent with
the agency's policy on open meetings,
"Staff Meetings Open to Public,"
published September 20, 1994 (59 FR
48340), the NRC intends to announce
open conferences normally at least 10
working days in advance of conferences
through (1) notices*posted in the Public
Document Room, (2) a toll-frss
telephone recording at 800-952-9674,
and (3) a toll-free electronic bulletin
board at 800-952-9676. In addition, the
NRC will also issue a press release and
notify appropriate State liaison officers
that a predecisional enforcement
conference has been scheduled and that
it is open to public observation.
The public attending open
conferences under the trial program may
observe but not participate in the
conference. It is noted that the purpose
of conducting open conftirences under
the trial program is not to maximize
public attendance, but rather to
determine whether providing the public
with opportunities to be informed of
NRC activities is compatible with the
NRC's ability to exercise its regulatory
and safety responsibilities. Therefore,
members of the public will be allowed
access to the NRC regional offices to
attend open enforcement conferences in
accordance with the Standard
Operating Procedures For Providing
Security Support For NRC Hearings And
Meetings," published November 1, 1991
(56 FR 56251). These procedures
provide that visitors may be subject to
personnel screening, that signs, banners,
posters, etc., not larger than 18" be
permitted, and that disruptive persons
may be removed.
Members of the public attending open
conferences will be reminded that (1)
the apparent violations discussed at
predecisional enforcement conferences
are subject to further review and may be
subject to change prior to any resulting
enforcement action and (2) the
statements of views or expressions of
opinion made by NRC employees at
predecisioniil enforcement conferences,
or the lack thereof, are not intended to
represent final determinations or beliefs.
Enclosure 2
Federal Register i Vol. 60, No. 126 / Friday, June 30, 1995 / Notices
~4387
Persons attending open conferences will
be provided an opportunity to submit
written comments concerning the trial
program anonymously to the regional
office. These comments will be
subsequently forwarded to the Director
of the Office of Enforcement for review
and consideration.
When needed to protect the public
health and safety or common defense
and security. escalated enforcement
action, such as the issuance of an
immediately effective order, will be
taken before the conference. In these
cases, a conference may be held after the
escalated enforcement action is taken.
VI. Enforcement Actions
This section describes the
enforcement sanctions available to the
NRC and specifies the conditions under*
which each may be used. The basic
enforcement sanctions are Notices of
Violation, civil penalties, and orders of
various types. As discussed further in
Section VI.D, related administrative
actions such as Notices of
Nonconformance, Notices of Deviation,
Confirmatory Action Letters, Letters of
Reprimand, and Demands for
Information are used to supplement the *
enforcement program. In selecting the
enforcement sanctions or administrative
actions, the NRC will consider
enforcement actions taken by other
Federal or State regulatory bodies
having concurrent jurisdiction, such as
in transportation matters. Usually,
whenever a violation of NRC
requirements of more than a minor
concern is identified, enforcement
action is taken. The nature and extent of
the enforcement action is intended to
reflect the seriousness of the violation
involved. For the vast majority of
violations, a Notice of Violation or a
Notice of Nonconformance is the normal
action.
A Notice of Violation is a written
notice setting forth one or more
violations of a legally binding
requirement. The Notice of Violation
normally requires the recipient to
provide a written statement describing
(1) the reasons for the violation or, if
contested, the basis for disputing the
violation; (2) corrective steps that have
been taken and the results achieved; (3)
correctiv~ steps that will be taken to
prevent recurrence; and (4) the date
when full compliance will be achieved.
The NRC may waive all or portions of
a written response to the extent relevant
information has already been provided
to the NRC in writing or documented in
an NRC inspection report. The NRC may
require responses to Notices of Violation
to be under oath. Normally, responses
under oath will be required only in
corinection with Severity Level I, II, or
ill violations or orders.
The NRC uses the Notice of Violation
as the usual method for formalizing the
existence of a violation. Issuance of a
Notice of Violation is normally the only
enforcement action taken, except in
cases where the criteria-for issuance of
civil penalties and orders, as set forth in
Sections VI.Band VI.C, respectively, are
met. However, special circumstances
regarding the violation fmdings may
warrant discretion being exercised such
that the NRC refrains from issuing a
Notice of Violation. (See Secti"on VII.B,
"Mitigation of Enforcement Sanctions.")
In addition, licensees are not ordinarily
cited for violations resulting from
matters not within their control, such as
equipment failures that were not
avoidable by reaso,;iable licensee quality
assurance measures or management
controls. Generally, however, licensees
are held responsible for the acts of their
employees. Accordingly, this policy
should not be construed to excuse
personnel errors.
B. Civil Penalty
A civil penalty is a monetary penalty
that may be imposed for violation of (1)
certain specified licensing provisions of
the Atomic Energy Act or
supplementary NRC rules.or orders; (2)
any requirement for which a license
~ay be revoked; or (3) reporting .
requirements under section 206 of the
Energy Reorganization Act. Civil
penalties are designed to deter future
violations both by the involved licensee
as well as by other licensees conducting
similar activities and to emphasize the
need for licensees to identify violations
and take prompt comprehensive
corrective action.
Civil penalties are considered for
Severity Level III violations. In addition,
civil penalties will normally be assessed
for Severity Level I and II violations and
knowing and conscious violations of the
reporting requirements of section 206 of
the Energy Reorganization Act.
Civil penalties are used to encourage
prompt identification and prompt and
comprehensive correction of violations,
to emphasize compliance in a manner
that deters future violations, and to
serve to focus licensees' attention on
violations of significant regulatory
concern.
Although management involvement,
direct or indirect, in a violation may
lead to an increase in the civil penalty,
the lack of management involvement
may not be used to mitigate a civil
penalty. Allowing mitigation in the
latter case could encourage the lack of
9
management involvement in licensed
activities and a decrease in protection of
the public health and safety.
1. Base Civil Penalty
The-NRC imposes different levels of .
penalties for different severity level
violations and different classes of
licensees, vendors, and other perso~s'.
Tables 1A ~d.tB show,~e~-~-~q
penalties for various reai:fur?ffijel "Y'"'e;
materials, and vendor programs. (Civil
penalties issued to individuals are
determined on a case-by-case basis.) The
structure of these tables generally takes
into account the gravity of the violation
as a primary COJ;lsideration and the
ability to pay as a secondary
considef'3.tion. Generally, operations
involving greater nuclear material
inventories and greater potential
consequences to the public and licensee
. employees receive higher civil
penalties. Regarding the secondary
factor of ability of various classes of
licensees to pay the civil penalties, it *is
not the NRC's intention that the
economic impact of a civil penalty be so
severe that it puts a licensee out of
busines.s (orders, rather than civil
penalties, are used when the intent is to
suspend or terminate licensed activities)
or adversely affects a licensee's ability
to safely conduct licensed activities.
The deterrent effect of civil penalties is
best served when the amounts of the
penalties take into account a licensee's
ability to pay. In determining the
amount of civil penalties for licensees
for whom the tables do not reflect the
ability to pay or the gravity of the
violation, the NRC will consider as
necessary an increase or decrease on a
. case-by-case basis. Normally, ifa
licensee can demonstrate financial
hardship, the NRC will consider
payments over time, including interest,
rather than reducing the amount of the
civil penalty. However, where a licensee
claims financial hardship, the licensee
will normally be required to address
why it has sufficient resources to safely
conduct licensed activities and pay
license and inspection fees.
2. Civil Penalty Assessment
In-an effort to (1) emphasize the
importance of adherence to
requirements and (2) reinforce prompt
self-identification of problems and root
causes and prompt and comprehensive
correction of violations, the NRC
reviews each proposed civil penalty on
its own merits and, after considering all
relevant circumstances, may adjust the
base civil penalties shown in Table 1A
and 1B for Severity Level I, n, and III
violations as described below.