IR 05000280/1979065

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IE Insp Repts 50-280/79-65 & 50-281/79-85 on 791126-30. Noncompliance Noted:Failure to Follow Surveillance Test Procedure & Review & Retain Instrument Calibr Procedures
ML18139A128
Person / Time
Site: Surry  Dominion icon.png
Issue date: 12/27/1979
From: Moon B, Upright C
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML18139A123 List:
References
50-280-79-65, 50-281-79-85, NUDOCS 8004040289
Download: ML18139A128 (7)


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UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION II

101 MARIETTA ST., N.W., SUITE*3100 ATLANTA, GEORGIA 30303.

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Report Nos. 50-280/79-65 and 50-281/79-85 Licensee:

Virginia Electric and Power Company Richmond, Virginia 23261 Facility:

Surry Nuclear Plant Docket Nos. 50-280 and 50-281 License Nos. DPR-32 and DPR-37 SUMMARY Inspection on November 26-30, 1979 Areas Inspected j

Virginia

/.2 - 2 7~ 7*1 Date Signed This routine, unannounced inspection involved 33 inspector-hours on site in the areas of calibration of in-plant instrumentation required by technical specifi-cations; calibration of measuring and test equipment used on safety-related systems; and surveillance of in-plant equipment require,d by technical specifica-tion Results

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Of t:he three areas inspected, no it:ems of noncompliance or deviations were identified in one area; two apparent items of noncompliance were found in two areas [Infraction - failure to follow surveillance test procedure - paragraph 6; Deficiency - failure to review and retain instrument calibration procedures -

paragraph 5].

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DETAILS Persons Contacted Licensee Employees

  • W. L. Stewart, Station Manager
  • J_. L. Wilson, Superintendent Operations
  • R. F. Saunders, Superintendent Maintenance
  • T. A. Peebles, Superintendent Technical Services
  • M. R. Kansler, Engineering Supervisor
  • R.H. Blount, II, Performance Engineer
  • J. Horhutz, Jr., Instrument Supervisor
  • F. L. Rentz, Resident Q. C. Engineer I
  • C. M, Driskell, Q. '

~M. D. Tower, Corporate Q. *E. P. Dewandel, Staff Assistant Other licensee employees contacted included technicians, operators, mechanics and office personne NRC Resident Inspector

  • D. J. Burke
  • Attended exit intervew Exit Interview The inspection scope and findings were summarized on November 30, 1979, with those persons indicated in Paragraph 1 above. The noncompliance items discussed in paragraphs.5 and 6, were acknowledged by the licensee. With regard to the issue of retaining the test and measuring equipment usage cards covered in paragraph 5, the licensee made a commitment that they will retain the usage cards at least one year following each calibration of the test and measuring equipmen.

Licensee Action on Previous Inspection Findings Not inspecte.

Unresolved Items U~resolved items were not identified during this inspectio *

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e-2-Calibration The inspector conducted a review of the calibration procedures and results as follows:

PT-1.2, NIS Trip Channel Test.During Power Operation-Unit 2 PT-2.11, Overpower-Overtemperature-Protection (T-2-412),Units 1 and 2 PT-2.2, Reactor Coolant Flow 2.2 (F-1-414)-Unit 1 PT-2.3, Pressurizer Level (L-459)-Unit 1 PT-2.4, Pressurizer Pressure Protection (P-455)-Unit 1 PT-2.5, Steam Generator Level (L-474)-Unit 1 PT-2.6, Steam Line Pressure (P-474)-Unit 1 PT-2.7, Steam Header Pressure (P-464)-Unit 1 PT-2.8, First Stage Pressure-Unit 1 PT-2.9, Steam Flow (F-474)-Unit 1 PT-2.10, *Feedwater Flow (F-476)-Unit 1 PT-2.11, Containment Pressure (P-LM-200)-Unit 2 PT'-3.0, Incore TC-RTD Cross Calibration-Unit 1 PT-28.6, Core Quadrant Power Balance-Unit 2 PT-28.9, Incore-Excore NI Calibration-Unit 1 PT-35., Reactor Power Calibration-Unit 2 The inspector monitored the performance of portions of the following cali-brations:

PT-2.1, Overpower-Overtemperature Protection (T-1-432)

PT-2.9, Steam Generator C Steam Flow (F-1-495)

PT-2.10, Feedwater Flow (F-1-496)

The calibrations above were reviewed to verify:

Reviews and approvals were being conducted, and data was recorded and evaluate Test instruments were listed and identified in test result Adherence to required technical specifications and limiting conditions for operatio Technical contents of the procedure were correc Verification of return of equipment to service and removal of test equipment was accomplished.,

~he inspector conducted an inspection of Instrument Calibration Shop, and Instrument Storage area~ The facilities were inspected to verify:

That standard test instruments were labeled and included in the cali-bration progra i e

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-3-Instruments wer~ being calibrated on schedule and labeled with calibration statu /

Storage facilities were proper for protecting the equipmen Certification and calibration records were available and being maintained for test equipmen The inspector used one or more of the following acceptance criteria for evaluating the above items in the calibration program:

Technical Specifications, Section 6.5. N~clear Power Station Quality Assurance Manual, Section 11.5.3, Periodic Test Program..

Nuclear Power Station Quality Assurance Manual, Section 12, Control of Measuring and Test Equipmen ANSI N18.7 (1972), Administrative Controls for Nuclear Power Plant ANSI N45.2 (1971), Quality Assurance Program Requirements for Nuclear Power Plants.

Industry Practic Within the areas inspected, one apparent item of noncompliance was identifie During the monitoring of PT-2.10 performed on 11/27/79, the inspector noted that the procedures were kept in transparent plastic envelopes which were bound into a book and permanently located in the relay roo Sections 1 through 6 of the procedure were initialed and/ signed by the performer in grease pencil on the plastic cover as it was complete The licensee stated that this procedure was not to be submitted for a review of its

.completeness and would be reused next tim The critique sheet and data sheet were completed in the control room in ink and were submitted for a revie The inspector sampled the PT's 2.1 through 2.11 generated between 1/1/79 and 11/27 /79 and found that sections 1 through 6 of the PT' s were not retained in the station file room. '

10 CFR SO, Appendix B~ Criterion V, requires activities affecting quality be accomplished in accordance with written instructions.* Topical Report Quality Assurance Program (VEP-1-3A) as implemented by the Nuclear Power Station Quality Assurance Manual (Sections 11.5.3.4 and 11.5.3.5) requires that the individual performing a periodic test (PT) is responsible for i;nitialing each step and affixing his signature and date on the procedure in ink upon completion of the test, and the cognizant supervisor ano perfor-mance engineer are responsible for reviewing the test, including critique sheet and procedure for completeness and accuracy. Technical specifications 6.5 requires that these PT records be retained for 5 years. The inspector found the lic_ensee failed to conduct PT' s 2~ 1 through 2.11 (which were,

-4-generated between 1/1/79 and 11/27/79) in accordance with their procedures in that sections 1 through 6 of the PT's were not reviewed by the cognizant supervisor and performance engineer, initialed and signed in ink, and retained in the station file room for five year The licensee was informed that the failure to conduct the PT's in accordance with their procedures was an item of noncompliance (281/79-85-01, 280/79-65-02).

The inspector also found that the licensee had been maintaining usage information of measuring and test equipment (M&TE) for about three wonths; after that, the M&TE is recalibrated and the usage information card is discarde This is in order to facilitate the required evaluation of tests and measurements conducted within the three-month period should the M&TE be found to be out of calibration. Most of the laboratory calibration standards used to calibrat~ these M&TE's, are checked only once annually. The current three-~onth retention interval, however, could pose a problem for the safety evaluation if a calibration standard is found to be out of calibration at the annual checkup, which was the case for the digital voltmeter (SQC-V0-28)

recalibrated on 8/25/79. * This is because the M&TE may have been calibrated with the faulty standard for the entire year and, in turn, may have been used to calibrate safety-related systems (instruments) in plant all along, which may not be traced back except the last three-month period. Appropriate re-tention information is not contained in sections 12. 4. 3 and 12. 5. 2. 3*. 6 of the quality assurance manua The inspector stated that the M&TE usage information cards are needed to be retained at least one year so that an adequate safety evaluation can be performed on systems (or components)

affected tracing back to the entire yea The licensee agreed to retain the information cards at least one year. This item will be followed in future inspections (280/79-65-03, 281/79-85-02). Surveillance Test Procedure and Results Verification The inspector conducted a review of-the following surveillance procedures and results:

PT-2.17, Boric Acid Control (F-113)-Unit 2 PT-5.1, Analog Rod Position Instrumentation-Unit 1 PT-8.3A, Safety Injection System Logic (Normal Conditions)-Unit 2 PT-15.0, Steam Generator Auxiliary Feedwater Pump-Unit 1 PT-21.0, 4KV Voltage & Frequency-Unit 2

PT-22.3A, Diesel Generator No. 1 Test-Unit 1 PT-23.1, Station Batteries-Unit 1 PT-23.lA, Fire Pump Diesel Battery-Units 1 and 2 PT-24.1, Fire P~otection Water Pump-Unit 1 PT-38.9, Chemistry Sampling-Spent Fuel Pit-Unit 1 PT-14.2, Main Steam Trip VLV's and Main Steam Non-Return Valves-Unit 1 PT-16.4, Containment Isolation Valve Leakage-Unit 1 PT-17.1, Containment Spray*system-Units 1 and 2

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e e-5-PT-17.3, Containment Outside Recirculation Spray Pump-Unit 1 -

PT-18.5, Flushing of Sensitized Stainless Steal Piping-Unit 1 PT-18.6, Monthly Testing of Safety Related MOV's-Unit 1 PT-18.8, Charging Pump Component Cooling & Service Water Pump Performance Test-Unit 1

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PT-19.1, RWST Chem. Add. Tank and Containment Spray System MOV's-Unit 1 PT-41.1, Component Cooling Water Pump Operability and Performance-Unit 1 The inspector also monitored, on 11/28/79, the performance, of portions of surveillance testing_ conducted in accordance with PT_.35, Reactor Power Calibration, and PT-34, Electrical Penetration Leakage Tes The test procedures and test results were reviewed to verify:

That test prerequisites and plant conditions were specified and reviewed, and approvals had been performed;

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I That contents of the procedures were correct and the tests were pe~formed on schedule; That test instruments were listed in the procedures and instruments used were identified in the results; That test results were recorded and compared with acceptance criteria; and, The return of the system/equipment to service and removal of test equipment was verified upon completion of the tes The 1nspector used one or more of the following acceptance criteria for the above items:

ANSI N18.7 (1972), Administrative Controls for Nuclear Power Plant Nuclear Power Station Quality Assurance Manual Technical Specifications, Section 6. ANSI N45.2 (1971), Quality Assurance Program Requirements for Nuclear Power Plants Industry Practice Within the areas inspected, one apparent item of noncompliance was identifie During the review of PT-18.6 performed on 10/13/79, the inspector found that two auxillary feed pump discharge valves (MOV~FW-151C and MOV-FW-151E) exceeded the valve opening reference time given in the procedure by 25%, The *inspector also,found that this deviation from the acceptance criteria was not noted on the critique sheet which had received two levels of review and no station deviation was submitted for these valve *

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-6-Technical specification 6.4.D, requires that PT procedures be followe Section 6.1 of PT-18.6 (Monthly Testing of Safety-Related MOV's) requires the individual performing the PT to submit a station deviation if any test valve* exceeds the 25% lim1t, and to note the deviation on the critique shee The licensee was informed that the failure to follow the PT in accordance with section 6.1 of the procedure was an item of noncompliance (280/79-65-01).