EA-96-231 - Surry 1 & 2 (Virginia Electric & Power Co.)

August 16, 1996

EA 96-231

Virginia Electric and Power Company
ATTN: Mr. J. P. O'Hanlon
Senior Vice President - Nuclear
Innsbrook Technical Center
5000 Dominion Boulevard
Glen Allen, VA 23060

SUBJECT: NOTICE OF VIOLATION (NRC Special Inspection Report Nos. 50-280 and 50-281/96-08

Dear Mr. O'Hanlon:

This refers to the inspection conducted on June 17 through July 1, 1996, at the Surry facility. The inspection included a review of the circumstances surrounding the inoperability of the Unit 1 and Unit 2 containment hydrogen analyzers. On June 10, 1996, you formally notified the NRC of this condition in Licensee Event Report No. 50-280 and 50-281/96-004-00. The results of our inspection were sent to you by letter dated July 11, 1996. A predecisional enforcement conference was conducted in the Region II office on August 7, 1996, to discuss the apparent violation, the root cause, and your corrective actions to preclude recurrence. This conference was open for public observation in accordance with the Commission's trial program for conducting conferences as discussed in the Federal Register, 57 FR 30762, July 10, 1992, and 59 FR 36796, July 19, 1994. A list of conference attendees, NRC slides, and a copy of Virginia Electric and Power Company's (VEPCO) presentation materials are enclosed.

Based on the information developed during the inspection and the information that was provided during the conference, the NRC has determined that violations of NRC requirements occurred. The violations are cited in the enclosed Notice of Violation (Notice), and the circumstances surrounding them are described in detail in the subject inspection report. Violation A involved the inoperability of the Unit 1 and Unit 2 containment hydrogen analyzers for a period greater than that allowed by Technical Specifications (TSs). The inoperable condition existed for at least five and a half years (from October 1990 through May 1996), and may have existed as long ago as October 1986 and November 1985, for Unit 1 and 2, respectively. Although the containment hydrogen analyzer hardware was capable of performing its intended function, the system was not capable of performing its design function given the as-left, standby system configuration (function selector switch in the ZERO position), the in-place procedural requirements for calibration and system operation, and the lack of operator awareness of system operation.

Violation B involved the failure to establish adequate procedures to assure the operability of the containment hydrogen analyzers. Specifically, Instrumentation and Control (I&C) Procedures and Emergency Operating Procedures (EOPs) lacked the continuity necessary to assure operation of the system during an emergency. Since October 1990, I&C Procedures have required that the function selector switches (FSS) at the remote and local containment hydrogen analyzer panels be placed in the ZERO position. For the hydrogen analyzers to operate properly, the FSS position on either the remote or local hydrogen analyzer panel must be in SAMPLE, and the post-accident monitoring (PAM) main power switch in the Control Room must be in ANALYZE. Although the system does not automatically start and could be operated manually with FSSs in an initial position of ZERO or SAMPLE, the EOPs did not address the need to verify or switch the FSS position from ZERO to SAMPLE in order to initiate containment sampling. Only the position of the PAM main power switch was described in the EOPs. Further, operators were unaware of the FSS required position. In their as found configuration in May 1996, the hydrogen analyzers would not have indicated actual hydrogen atmospheric concentration when aligned to containment.

Although the inoperability of the containment hydrogen analyzers did not have a significant consequence to safety because they were not called upon to operate during this period, the violations are nonetheless of significant regulatory concern. Notwithstanding the fact that the equipment was technically capable of performing its function, recognition of the FSS mispositioning by operations, I&C, or other support personnel would have been required during an emergency and the switch repositioned for proper system operation. Although other means would have been available to determine hydrogen concentration following an accident, the degree to which operators would have relied upon the erroneous information from the hydrogen analyzers and for how long, to make decisions regarding start-up of the hydrogen recombiners to reduce hydrogen levels in containment, is uncertain. In addition, the NRC is concerned about the length of time this condition went undetected and the procedural revision and review processes which failed to uncover this condition. Therefore, these violations are classified in the aggregate in accordance with the "General Statement of Policy and Procedures for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600, as a Severity Level III problem.

In accordance with the Enforcement Policy, a base civil penalty in the amount of $50,000 is considered for a Severity Level III problem. Because your facility has been the subject of an escalated enforcement action within the last two years,¹ the NRC considered whether credit was warranted for Identification and Corrective Action in accordance with the civil penalty assessment process in Section VI.B.2 of the Enforcement Policy. In this case, credit is warranted for Identification in that you identified the violation. The attentiveness and questioning attitude of the visiting North Anna operator who initially identified the mispositioned FSSs is particularly noteworthy. With regard to Corrective Action, your immediate actions included verification of the proper configuration and placement of the FSSs in the SAMPLE position. At the conference, you stated that additional corrective actions included: (1) revision of the calibration procedures to require that the FSSs be left in the SAMPLE position; (2) addition of the containment hydrogen analyzer FSS position verification to the operator logs; (3) comparison of Surry and North Anna operator logs to identify inconsistencies; (4) review of the TS and Emergency and Abnormal Procedures to determine if other procedural interface inadequacies existed on other safety related equipment; and (5) review of the procedure change process. At the conference, you indicated that no similar issues were identified as a result of these efforts. Based on the above, the NRC determined that your corrective actions were prompt and comprehensive, and credit was warranted for this factor.

Therefore, to encourage prompt identification and comprehensive correction of violations, I have been authorized, after consultation with the Office of Enforcement, not to propose a civil penalty in this case. However, significant violations in the future could result in a civil penalty.

At the predecisional enforcement conference you offered three clarifications related to the content of NRC Inspection Report Nos. 50-280, 281/96-08. These comments were: (1) At various locations in the Inspection Report it is indicated that the mispositioned FSSs resulted in a loss of safety function. You stated that although the containment hydrogen analyzers were declared inoperable, the overall safety function was not lost; (2) Page 2, the 5th Paragraph of the report states "Return to service in CAL-GW-175 placed the FSSs in the SAMPLE position which is the correct position." You stated that the sentence should state "... which is one of two correct positions;" and (3) Page 3, the 3rd Paragraph of the report states that NRC concluded that an additional root cause of this event was a lack of knowledge by the I&C technicians. You clarified that this was not a licensee position, and that I&C personnel fully understood the system, they just were not knowledgeable of the procedural interface deficiency which existed with the EOPs. Operations personnel, however, were unfamiliar with the requirements for FSS positions.

We have evaluated your comments and acknowledge that the total safety function for analyzing post accident hydrogen concentration in containment was not lost as a result of the inoperability of the hydrogen analyzers. Specifically, the hydrogen analyzer hardware was functional, and redundant containment sampling means were available. However, the certainty with which these redundant methods would have been employed is unknown. In addition, we have determined that your position with respect to Items (2) and (3) above are not valid. Specifically, the appropriate system alignment to permit operation of the containment hydrogen analyzers from the Control Room Annex or the Auxiliary Building is with the FSSs in the SAMPLE position. In addition, I&C personnel were not knowledgeable of the relationship between the as-left configuration of the containment hydrogen analyzers and the EOPs. We do agree that operations personnel also exhibited a lack of knowledge with respect to the required position of the FSS. Lack of operator knowledge was not specifically addressed as a root cause in the Inspection Report; however, no addendum to the Inspection Report is required, in that, the report reflects NRC understanding at the time the report was issued. This letter and enforcement action corrects NRC's understanding with respect to the acceptable positions of the FSSs and the root causes of the violations.

You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. The NRC will use your response, in part, to determine whether further enforcement action is necessary to ensure compliance with regulatory requirements.

In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter, it enclosures, and your response will be placed in the NRC Public Document Room (PDR).

Sincerely, Stewart D. Ebneter Regional Administrator

Docket Nos. 50-280 and 50-281
License Nos. DPR-32 and DPR-37

Enclosures:
1. Notice of Violation
2. Conference Attendees (not to be published in NUREG-0940)
3. NRC Slides (not to be published in NUREG-0940)
4. VEPCO Presentation Materials (not to be published in NUREG-0940)

cc w/encls:
M. L. Bowling, Manager
Nuclear Licensing and Operations Support
Virginia Electric & Power Company
Innsbrook Technical Center
5000 Dominion Boulevard
Glen Allen, VA 23060

David A. Christian, Manager
Surry Power Station
Virginia Electric & Power Company
5570 Hog Island Road
Surry, VA 23883

W. R. Matthews, Manager
North Anna Power Station
P. O. Box 402
Mineral, VA 23117

Ray D. Peace, Chairman
Surry County Board of Supervisors
P. O. Box 130
Dendron, VA 23839

Dr. W. T. Lough
Virginia State Corporation Commission
Division of Energy Regulation
P. O. Box 1197
Richmond, VA 23209

Michael W. Maupin
Hunton and Williams
Riverfront Plaza, East Tower
951 E. Byrd Street
Richmond, VA 23219

Robert B. Strobe, M.D., M.P.H.
State Health Commissioner
Office of the Commissioner
Virginia Department of Health
P. O. Box 2448
Richmond, VA 23218

Attorney General
Supreme Court Building
900 East Main Street
Richmond, VA 23219

---

NOTICE OF VIOLATION

Virginia Electric and Power Company Docket Nos. 50-280 and 50-281 Surry Power Station License Nos. DPR-32 and DPR-37 EA 96-231

During an NRC inspection conducted on June 17 through July 1, 1996, violations of NRC requirements was identified. In accordance with the "General Statement of Policy and Procedures for NRC Enforcement Actions," NUREG-1600, the violations are listed below:

A. Technical Specification 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 inoperable 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 placed 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 nuclear 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 III problem (Supplement I).

Pursuant to the provisions of 10 CFR 2.201, Virginia Electric and Power Company is hereby required to submit a written statement or explanation to the U. S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D. C. 20555 with a copy to the Regional Administrator, Region II, and a copy to the NRC Resident Inspector at the Surry Power Station, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a "Reply to Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previously docketed correspondence, if the correspondence adequately addresses the required response. If an adequate reply is not received within the time specified in this Notice, an order or Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken. Where good cause is shown, consideration will be given to extending the response time.

Under the authority of Section 182 of the Action, 42 U.S.C. 2232, this response shall be submitted under oath or affirmation.

Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

Dated at Atlanta, Georgia
this 16th day of August

---

^1. On November 22, 1995, a Severity Level III problem was issue related to multiple violations associated with the September 1995 unplanned reduction in reactor vessel water level (EA 95-223).