IR 05000280/1984011
| ML20107H077 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 07/27/1984 |
| From: | Jape F, Lenahan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20107H070 | List: |
| References | |
| 50-280-84-11, 50-281-84-11, NUDOCS 8411080403 | |
| Download: ML20107H077 (6) | |
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NUCLEAR REIULATORY COMMISSION L[
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101 MARIETTA STREET, N.W.
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ATLANTA, GEORGIA 30303
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' ' Report Nos.: 50-280/84-11 and 50-281/84-11'-
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Licensee: Virginia' Electric and Power Company R1chmond, VA 23261'
Docket Nos.: 50-280 and 50-281 License Nos.: DPR-32 and DPR-37 Facility Name: Surry 1 and 2 Inspection at Surry site near Will amsburg, Virginia Inspector:
7 /27 1[
J. J. Lenahan (/
Date Signed Approved by:
Om A7
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F. Jape, Section Chief Date Signed Engineering Program Branchg /
Division of Reactor Safety SUMMARY Inspection on March 20 - 23, 1984 Areas Inspected This routine, unannounced inspection involved 27 inspector-hours on site in the areas of licensee action on previous inspection findings and testing of snubbers.
Results ln the two areas inspected, no violations or deviations were identified in one area; one apparent violation was found in one area (Inadequate Snubber Service Life Monitoring Program, paragraph 4).
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8411080403 840925 PDR ADOCK 05000280
PDR l
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-REPORT DETAILS-1.=
' Persons Contacted
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.LicenseeEmplohees
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- R. H. Blount, Performance Engineer
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- R.- Cartwright, Manager of Nuclear Operations
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- M. 'R. Kansler,~ Superintendent, Technical-Services -
J." Patrick, Superintendent of Maintenance :
- R..'F. Saunders,' Assistant Station Manager
- W. L. Stewart, Vice-President, Nuclear 0perations
"*J. L. ~ Wilson, Station Manager D. Wong, Mechanical Engineer-
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Other licensee employees contacted included 3 engineers and 2 mechanics..
NRC'~ Resident Inspectors-
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- D. J. Burke
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- M. J. Davis
- Attended exit interview
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- Participated in March 28, 1984 Conference Call
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- Attended exit interview and participated in March 28 Conference Call
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'2.
Exit Interview The inspection scope and find _ings were summarized _ on March _23,1984, with those persons indicated in paragraph 1 above._ Subsequent to the inspection,
on March 28,1984, -the inspection findings listed below were discussed with the individuals listed in paragraph 1 above ~during a telephone conference call.
The licensee acknowledged the inspection findings and ' committed to take immediate action to correct the violation.
Violation 280/84-11-01. and 281/84-11-01, Inadequate Snubber _ Service Life Monitoring Program - Paragraph 4.
Unresolved Item 280/84-11-02 and 281/84-11-02, Resolution of QA Audit
Findings - Paragraph 4.
y Unresolved Item 280/84-11-03 and 281/84-11-03, snubber Maintenance
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Program - Paragraph 5.
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Unresolved: Items I
Unresolved items are matters about which more information is required to
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.tions..New unresolved items identified during this inspection are discussed -
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.in paragraphs 4 and 5.
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4.. ~ Licensee Action on' Previous 1 Enforcement Matters j
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.(Closed) Unresolvea Item (280/78-13-06 and (281/78-13-06.1 Establish Seal
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e Lifetime.for Non EP-Seals.nThis item concerned -the: need to establish the -
seal lifetime-(service. life) for. snubber seals fabricated from non-ethylene
. propylene materials. l Subsequent to the inspection when this unresolved item
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was,1dentified, Technical : Specification -(TS) u4.17 was amended : to require that 'a ~ service life be established = and monitored for allJ snubbers (TS __
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- Amendments 79 and 80;-is' sued August:17,1982).. During ' previous inspections-(280/83-32 and 281/83-33, November 14 - 17, 1983;~280-281/84-03, January 30
- February 2,1984; and 280-281/84.-08,. March -51-8,' 1984), the 1.nspectorf
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' reviewed and discussed the c snubber ' service life monitoring _ program;with-licensee. engineers' and licensee management personnel. : Licensee personnel stated that a L5_ year -service life -is used for hydraulic snubbers, and that.
all1 hydraulic snubbers -had been rebuilt during the' steam generator replace-;
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ment: project (JulyL1980 for_ Unit 2 and July 1981' for Unit 1) using seals '
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fabricated from EP materials.
The licensee monitored the; snubber servfce life using a computer-printout which. listed the snubber'serialinumber, the i
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snubber installation location, and the date when.the' snubber had'last been
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reconditioned or-rebuilt.
As. discussed in Inspection : Report Number
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280-281/84-08, more than 30 percent of the 136 :hydraul.ic. snubbers -from
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Unit I which were functionally tested failed. to meeti the acceptance i
criteria.
Ten of these snubbers failed to lockup.during: testing., That is, these snubbers were totally inoperable.
Functional testing of_ the Unit 2
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snubbers was in - progress during this-inspection.
The snubbers were experiencing a failure rate of-greater than 20 percent.. (Subsequent'to the completion of the. inspection, the licensee ' reported that more than
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25 percent of the 191 hydraulic snubbtes from Unit 2 which were functionas ly" tested failed to meet the acceptance criteria.
Nine -of these snubbers
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failed to lockup during testing.)
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On March 16, 1984, the licensee disassembled and inspected seven. snubbers which failed to meet the functional acceptance criteria. These inspections,.
which were performed in the presence of the NRC resident inspector disclosed
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that five snubbers had seals fabricated from non-EP materials. Some of the seals were badly deteriorated.
The ~ licensee disassembled and -inspected
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additional snubbers which failed the functional tests during this inspec-tion, including two snubbers from Unit 2.
The visual inspections disclosed that additional snubbers - had seals fabricated from Non-EP materials, including one of the Unit 2 snubbers. The seal problem appear to
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be confined to the ITT Grinnel Lynair snubbers.
After the inspections performed on March 16. disclosed that some snubbers had non-EP seals, the licensee perfonned a detailed review of snubber mainte-u nance - records.
This review disclosed-that numerous Unit 1 snubbers i
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apparently-had not been completely rebuilt during the steam generator replacement. project as the licensee believed when the ~ snubber service life monitoring program was established per the-requirements of the August 1982 l
TS 4.17 amendment.
At this time, the licensee cannot provide a reason for this. discrepancy, but. the problem may be related to the method of snubber
identification used in July 1981.
There are approximately 51 Unit 1 Lynair E
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snubbers'affected by the d'iscrepancy in the maintenance recordsJ The number of Unit:2 pnubberstaffected by the. same_ problem has :not been ascertained.
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-However,1 since= this: problem appears;to involve only the Lynair snubbers, the
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- licensee is replacing.or. rebuilding:all the Unit 2 Lynair snubbers.
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Based _ on the. problems discussed 'above,.the inspector concluded. thatc the.
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o snubber service ~ life; monitoring ' program establ_ished byithe; licensee to :
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comply with LTechnical1 Specification _4.17.F has been inadequate.. This=1s-.
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identified as a violation.
Unresolved. Item' 280-281/78-13-06 is clo' sed andi upgraded to1 Violation-Item 280-281/84-11-01, Inadequate Snubber Service. Life t Monitoring Program.
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Discussions'with licensee management during the exit : interview disclosed that2
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problems with the. snubber service' life program had been identified by. VEPC0
_QA audit personnel. : A copy of. audit report S83-07,(which was' completed in A
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December 1983, was presented tof the.. inspector.
The inspector reviewed the audit in. the RII. office and concluded that the' audit finding was similar to-l
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the violation' discussed above.
However,:itL appears that prompt corrective
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action-to resolve the audit finding was' not initiated.'L. Following :the.
inspection,' the licensee was notified. via telephone,'~ that. the _ failure to take prompt and adequate 1 corrective action to resolve the audit. finding.is an Unresolved Item 280-281/84-11-02, Resolution.of. QA Audit Finding._ Foll_ow -
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up on this. item will be conducted on a future inspection.
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5.
Snubber Surveillance Programs, Units 1 and 2 (61729)
The. inspector examined procedures and quality records related to the snubber surveillance. program and inspected selected snubbers on safety-related piping systems. Acceptance criteria utilized by the inspector are specified,
in Technical Specification 4.17.
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- Review of Snubber Surveillance Procedures - Unit 2 The inspector examined the following procedures which control the Unit 2 snubber surveillance activities:
(1) Procedure number 2-PT-39A-1, Visual Inspection Accessi$le
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Snubbers - As Left (2) Procedure number 2-PT-398-1, Visual Inspection Acchssible:
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Snubbers - As Found (3) Procedure f number 2-PT-39A-2, Visual Inspection - Inaccessible Snubbers - As Left (4)rProcedure number 2-PT-39B-2, Visual Inspection - Inaccessible Snubbers - As Found n
(5) Procedure number PT-39.2, Snubber Functional Testing
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(6) Procedure number 2-PT-39.3, Mechanical -Snubber Functional Testing
- (7)~ Procedure number 2-PT-39.4,_ Snubber Functional Test
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.-Inspection ofySnubbersi
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,5 u _The sinspector 'peYformedha Nisual : 1nspectioncof; the 0 nit 1Lsnubbersi
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211sted ;belowTandLverifiedithat, snubbers were;,not_ damaged,i that
. attachment to the supporting ~ structure and piping was.secureethat.the?
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- fluidslevels in' hydraulic: snubbers.was higher; than target.levelsrand.=
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that leakage of: fluid was.not occurring. :
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(1) Snubber 1numbersJ 1-SHP-HSS-37;38,39',51A*,51B*, ' 52A*,54A*,54B* 'on-h
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(2) Sn'ubber;numbersE1-WFPD-HSS-20.and 21A on-lthe main' feed system
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=(3) Snubber numbers: 1-WAPD-146, and '148 on. the. auxiliary feed - system
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'(4) Snubber number 1-WCMU-HSS-100'on the make-up system'
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- Den 6tes mechanical' snubber.. All-others listed are; hydraulic.
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Review of Quality Records A
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The inspector reviewed the quality records documenting Lthe results. of :
functional - testing performed.on ' Unit 1 snubbers ~ during : the February 24:- March 9,1984, ma'intenance outage.
These results are
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currently being evaluated by the. licensee based on revised acceptance criteria developed by the licensee's design engineers and A/E, Stone &l
'j; Webster.
The revised acceptance criteria appear.in procedure ADM
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89.14. ~More than 30 percent of the snubbers tested did not meet the
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revised functional test acceptance criteria.. Thefinspector also
a verified that the serial-number of Unit 1 snubbers examined byl the..
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inspector (listed in paragraph 5.b above) were accurately documented in
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the snubber tables and records, j
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Examination of Disassembled Snubbers
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L The inspector witnessed disassembly and inspection of snubbers that l
failed the functional tests.
The disassembly was performed by Wyle
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Laboratory. mechanics.
Wyle Lat's is the contractor performing the-
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removal, functional testing, and re-installation 'of snubbers.
The inspection of the disassembled-snubbers is being performed by licensee i
F engineers. Snubbers examined by the inspector-were as follows:
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l (1) ' Snubber serial numbers 8634, 11457, 11460, and 11482. These were
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Snubber number 11460 and 11482 which are PSA i <
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have bent screw rods and miscellaneous loose small metal parts ~
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L (washers, spacers,-and metal chips) in the internal mechanism of-E the snubbers.
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(2) Hydraulic snubbers ~ numbers 1-CC-HSS-3408, 2-RH-HSS-21, and 2-RC-HSS-113.-
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Snubber 2-RH-HSS-21' had seals fabricated from non-EP material.
During.the inspection, the license. ' disassembled and repaired additional.
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hydraulic snubbers.
Several of these snubbers also had non-EP seals.. In addition, two, snubbers, Nos.1-RC-HSS-107, and 1-RC-HSS-108, had popet
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valves installed upside down. The inspector reviewed the. licensee's snubber i
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maintenanco1. procedure. and discussed the-snubber rebuilding program with
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j licensee ma.ihtenance personnel.
These -individuals' could not explain. the
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reason for the discrepancy (non-EP. seals and improperly installed popet y
valves) found in.the ITT Lynair snubbers.
The. inspector concluded that these problems may be related to snubber
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maintenance program.
Pending a detailed NRC review of the snubber mainte-nance program in a future inspection, this problem was ' identified to the licensee;as unresolved items 280,281/84-11-03, Snubber Maintenance Program Adequacy.-
Within the area inspected, no violations or deviations were identified,
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