IR 05000280/1989017
| ML18153B803 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 06/30/1989 |
| From: | Holland W, Larry Nicholson, York J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18153B802 | List: |
| References | |
| 50-280-89-17, 50-281-89-17, NUDOCS 8907120136 | |
| Download: ML18153B803 (24) | |
Text
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UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, ATLANTA, GEORGIA 30323 Report Nos.:
50-2~0/89-17 and 50-281/89-17 Licensee:
Virginia Electric and Power Company Glen Allen, VA 23060 Docket Nos.:
50-280 and 50-281 License Nos.:
DPR-32 and DPR-37 Facility Name:
Surry 1 and 2 Inspection Conducted:
April 30 - June 3, 198 '-1)1. S DAte ITgned /3,,/0 Da'te 1-(gned Approved SUMMARY Scope:
This routine resident inspection was conducted on site in the areas of plant operations, plant maintenance, plant surveillance, licensee event report review, and followup on inspector identified item A special evaluation of the licensee's program which was used to walk down selected systems pri-0r to unit restart was documented in the last four resident reports and this inspection effort is completed for Unit 1 in this inspection repor Certain tours were conducted on backshifts or weekend Backshift or weekend tours were conducted on April 30, May 2, 4, 7, 11, 13, 14, 15, 20, 21, 29 and June Results:
During this* inspection period, one violation (paragraph 8) was identified for failure to provide for continuous review of all operational and safety aspects of the nuclear facility as specified in TS 6.1.C.2. This violation indicated a weakness in the licensee's program to_provide for continuing independent review 8907120136 890630 PDR ADOCK 05000280
- of the operational and safety aspects of the nuclear facility from the corporate offices. However, the licensee's onsite review corrmittee did conduct necessary reviews in accordance with requirements which allowed for a conclusion that the overall program was adequate. for unit restar The licensee's ongoing operational readiness program appears to be adequate and has been completed with regards to identification of Unit 1 restart issue The licensee plans to resolve all applicable issues prior to unit restar During a review of an LER with regards to an inadvertent start of an EOG, a weakness in the licensee's past corrective action program was identified. This
- weakness is considered as an addi_tional example of past corrective action problems, which were identified in enforcement actions issued on May 18, 198 In addition, one non-cited violation (paragraph 7) was identified for failure to provide an adequate procedure for a safety-related maintenance activity.
REPORT DETAILS Persons Contacted Licensee Employees
- R~
- * * Benthall, Supervisor, Licensing Bilyeu, Licensing Engineer Blount, Superintendent of Technical Services Cartwright, Vice President Nuclear Operations Christian, Assistant Station Manager Erickson, Superintendent of Health Physics Grecheck, Assistant Station Man~ger Kansler, Station Manager McCarthy, Superintendent of Operations Miller, Licensing Coordinator, Surry Ogren, Superintendent of Maintenance Sowers, Superintendent of Engineering Saunders, Licensing Manager (Corporate)
Pannell, Director, Safety Evaluation & Control Price, Site Quality Assurance Manager (Corporate)
Other licensee employees contacted included control room operators, shift technical advisors, shift supervisors and other plant personne *Attended exit intervie On May 22, 1989, a management meeting was held at the Surry Power Station to review the status of the licensee's actions with regards to issues identified requiring resolution prior to restart of the unit NRC management in attendance at the meeting were:
S. Ebneter, Regional Administrator, RI!
H. Berkow, Director, Project Directorate II-2, NRR C. Hehl, Deputy Director, DRP, RII -
E. Merschoff, Deputy Director, DRS, RII P. Fredrickson, Acting Branch Chief, DRP, RII B. Buckley, Project Manager, NRR *
The meeting focused on the statu_s of issues identified in the Confirmation of Action Letter that was sent to the licensee dated March 9, 198 In addition, the licensee discussed issues relating to electrical cable s~paration, component cooling water system, instrument cable replacement, procedures status, and trainin The NRC was satisfied with the licensee's progress on resolution of issues to date and will continue to monitor the licensee's actions in preparation for restar On June 1, 1989, the Surry Senior Resident Inspector attended a Surry County Board of Supervisors meetin During the meeting, the. Surry Station Manager provided the board with an update on the status of
activities ongoing at the Surry Power Statio In addition, the Station Manager provided his insight with regards to the increased NRC oversite* of the facilit He also stated that the first unit would restart during the month of June after all corrective actions with regards to identified deficiencies have been complete Acronyms and initial isms used throughout this report are listed in the last paragrap.
Plant Status Unit 1 began the reporting period in cold shutdow The licensee completed their operational reviews and maintenance activities which were required for unit restar Operation aGtivities accomplished during this period included fi 11 and vent of the RCS, establ i s.hment of proper primary plant chemistry, and drawing of a pressurizer bubble. * At the end of the inspection period the unit remained in.cold shutdow Unit 2 began the reporting period in cold shutdow The unit remained in
- cold shutdown for 'the duration of the inspection period while substantial operational reviews and maintenance activities were being conducte.
Operational Safety Verification (71707) Daily Inspections The inspectors conducted daily inspections in the following areas:
contra l room staffing, access, and operator behavior; operator adherence to approved procedures, technical speci ficati on*s, and limiting conditions for operations; examination of panels containing instrumentation and other reactor protection system elements to determine that required channels are operable; and review of control room operator logs, operating orders, plant deviation reports, tagout logs, jumper logs, and tags on components to verify compliance with approved procedure The inspectors specifically focused on the initial RCS fill and vent*
evolution on Unit 1, which occurred during the week of May 8. This evolution represented the first major integrated plant evolution from a long shutdown and was characterized by an increased involvement by the control room operations staff. The inspectors witnessed filling the last remaining reactor coolant loop, filling the RCS to a solid plant condition, pressurizing the RCS to facilitate a RC pump run and jogging the reactor coolant pumps to sweep entrained gasses from the RC These actions were controlled by Operations Procedure 1-0P-1.1, Unit Startup Operation - Ambient Temperature To 195 Degrees F, and Operations Procedures 1-0P-5.1.1, Filling The Reactor Coolant System.
The control room staff displayed an adequ~te awareness an~ control of the plant during this major evolution., Procedure compliance was evident and communications between all participants was observed as satisfactor No discrepancies were identified during this inspection effor The inspectors will continue to maintain, an increased presence during the upcoming unit startu Weekly Inspections The inspectors conducted weekly inspections in the following areas:
verification of operability of selected ESF systems by valve alignment, breaker positions, condition of equipment or components, and operability.of instrumentation and support items essential to system actuation or performance. Plant tours were conducted which included observation of general plant/equipment conditions, fire protection and preventative measures, control of activities in progress, radiation protection controls, physical security controls,
- plant housekeeping conditions/cle*anliness, and missile haz_ard The inspectors routinely monitored the temperature of the auxiliary feedwater pump* discharge * piping to ensure steam binding was prevente Biweekly Inspections The inspectors conducted biweekly inspections in the following areas:
verification review and walkdown of safety-related tagouts in effect; review of sampl irig program {e.g., primary and secondary coolant samples, boric acid tank samples, plant liquid and gaseous samples);
observation of control room shift turnover; review of implementation of the plant problem identification system; verification of selected portions of containment isolation lineups; and verification that notices to workers are posted as required by 10 CFR 1 During this inspection period, the licensee implemented a new program in the operations area to maintain a better control of plant status condition The new program involves the use of Plant Status Logs for each-unit and a third log for common system These logs are located in the control room and are updated as required to provide for a status of all major equipment or components required to safely operate the unit The program requires that each operating shift review the logs and make changes whenever a change in equipment status is note The new program also uses multicolored magnets to identify equjpment status at control points in the control roo The new identifiers have already had a positive impact on the control of plant status and identification of system flowpath The inspector considers that this new program will provide for better configuratiorr control after'all operators are fully familiar with requirement \\' **
d *.
Areas Inspected Inspections included areas in the Units 1 and 2 cable vaults, vital battery rooms, steam safeguards areas, emergency switchgear rooms, diesel generator rooms, control room, auxiliary building, Units 1 and 2 containments, cable penetration areas, independent spent fuel storage facility, low level intake.structure, and the safeguards valv~ pit and pump pit areas. Reactor coolant system leak rates were
_reviewed to ensure that detected or suspected leakage from the system was recorded, investigated, and evaluated; and that appropriate actions were taken, if require The inspectors routinely indepen-dently calculated RCS leak rates using the NRC Independent Measure-ments Leak Rate Program ( RCSLK9).
On a regular basis, RWPs were reviewed and specific work activities were monitored to assure they were being conducted per the RWP.Selected radiation protection instruments were periodically checked, and equipment operability and calibration frequency were verifie Physical Security Program Inspections In the course of monthly activities, the inspectors included a review of the licensee's physical security progra The performance of various shifts of the security force was observed in the conduct of daily activities to include: pro~ected and vital areas access controls; searching of personnel, packages and vehicles; badge issuance and retrieval; escorting of visitors; and patrols and compensatory post Licensee 10 CFR 50.72 Reports (1)
On May 15, 1989, the licensee made a report in accordance with 10 CFR 50.72 regarding problems ideptified during a design revie The design review was conducted in response to an NRC EQ commitment and focused*on cable insulation resistanc The review identified Continental cable insulation resistance values for a LOCA condition to be low and determined that certain safety-related trip circuits (steam generator narrow range and pressurizer pressure) were fabricated with cable manufactured by Continental and could experience excessive insulation leakage currents during a harsh environment conditio This excessive leakage condition could pr~vent trip signals from being initiated due to the high leakage current masking the trip level current. Licensee corrective action includes replacement of the leakage cable prior to restart of the respective units.* Reviews are ongoing to determine if additional cables, which are used to monitor accident parameters in accordance with the licensee's commitment to Regulatory Guide 1.97, are also affecte Five additional cables were determined to require replacement and
.these cables were al so scheduled to be replaced prior to restart..
' **
(2)
(3)
On May 16, 1989, the licensee made a report in accordance with 10 CF~ 50.72 regarding the potential failure of the CCW piping as~ociated with cooling to the RCP * thermal barrier heat exchange Failure of a tube in this heat exchanger could potentially allow for leakage of reactor coolant to the CCW system in excess of 1400 gallons per minut The relief valve protection installed on the CCW piping to protect from this occurrence did not have sufficient capacity to ensure that the CCW.piping would not fail from overpressur Failure of the CCW piping could potentially provide a path for the RCS leakage through containment to the auxiliary buildin The licensee is currently evaluating courses of action and will correct the deficiency prior to restart of the respective units. This area was addressed in-NRC Inspection Report 280 1281/89-1 On May 17 1 1989, the licensee made a report in accordance with 10 CFR 50.72 regarding an inadvertent ESF actuation of the No. 2 EOG during periodic testing following maintenanc The EDG fast started when the local selector switch was placed in AUT The cause of this inadverteni start was associated with a failure to reset the appropriate relays prior to placing the EDG selector switches in AUT The licensee conducted a reviewof this event and concluded that the procedures for returning of the EDGs to service after maintenance (i.e. PTs and DPs) needed ~dditional enhancement to ensure that all relays were rese This issue will *be reviewed after the licensee submits the LER for this even * Main Control Room Envelope Ventilation System
- The licensee documented via station deviation report (Sl-88-937)
dated September 9, 1988, that the main control room and emergency switchgear room air conditioning system can no longer maintain nonnal, design room temperatures when operating in the designed configura-tio This deviation conclud~d that the ability of the existing -
equipment to perform its intended function was indeterminate based on the following:
The actual chiller capacities were significantly less than the procurement documentatio This issue was addressed in NRC Inspection Report 280,281/88-41. The upgrade of the chi 11 er motors to meet original design capacities was completed in May. 198 The emergency switchgear. room heat loads have increased by the addition of new equipment over -the year It 'is apparent t.hat *
the design change process did not track and account for the routine addition of heat load The materia*l condition of this system has significantly degraded since original installatio *
Several additional problems with this system have been identified during the past severa 1 month The licensee made a 10 CFR 50. 72 report to the NRC on November 2, 1988, identifying that a problem also existed with the ability of this system to function as required to meet certain 10 CFR 50.49 and Appendix R scenarios. - These discrepancies were detailed in LER 280-88-033, dated December 2, 198 The licensee documented in a letter to the NRC (Serial No. 88-689A)
dated January 6, 1989, the inadequacy of the main control room and emergency switchgear room air conditioning system. They subsequently submitted a TS change request (Serial No. 88-689E) dated March 20, 1989, This issue was also discussed during several meetings between the NRC and liceniee, and was identified as requiring resolution prior to unit restart in a Confirmation of Action Letter dated March 9, 198 The*system consists of three chiller units with three service water pumps that supply cooling to each chiller condense Each chiller has a chilled water pump that circulates chilled water to a set of air handling units. All three chiller units are located in the same room, which was designated as a harsh environment are The air handling units utilize a motor driven fan to pass air over the-chilled water coils and out"a system of ductwor A normal train consists of a chiller providing water to one of two sets of air handling unit The third chiller was designed as a swing chiller to supply either train. This system provides for removal of heat during normal and accident conditions in the main control room and emergency switchgear roo A failure of this system could result in equipment damage and failure due to overheatin The licensee has taken credit for the station's Central Chiller Units to provide backup chilled water in the everit of a HELB in the Unit 2_
turbine building and during a fire in the main control room envelope chiller equipment roo It was dircovered during the review of thi system that the Central Chiller System has inadequate capacity (55 tons actual versus 100 tons required) to perform the intended backup functio In addition to the above 'problems, the licensee identified via station deviation (Sl-89-1111) dated May 9, 1989, that the original design of the main control room air handling units was inadequate in
_that a single failure could prevent adequate cooling of the main control roo The main control room is cooled by four air handling unit Two are powered by the Unit 1 1H 1 emergency bus and the other two are powered from the Unit 2 1H1 emergency bu Given one air handling unit out of service and the failure of the opposite unit 1s 1H1 bus EOG in an accident, the control room would be cooled by only one remaining air handling-unit.
The licensee has determined that, to maintain design basis temperatures, a permanent modification must be implemented to replace undersized equipment with new, higher capacity equipmen Due to the long lead time of th-e custom designed equipment required for this-upgrade, an interim fix using the existing equipment is necessar This interim fix has been i~plemented during the current outage per Design Change 88-36, Control Room Envelope HVAC Interim Modificatio The intent of this change was to upgrade the existing equipment to produce the maximum cooling possible, as well as provide alternate power sources to enable the system to remain operable following s fngl e fa i 1 ure of an emergency bu The HELB concern was corrected by isolating the chiller room from the Unit 2 turbine building and the Appendix R concern resulted in a fire watch being stationed in the chiller room:
In addition, the licensee proposed additional operational constraints as identified in their TS change request noted abov *
The inspector verified that the various* commitments and corrective actions that were identified both formally to the NRC and withil"! the licensee's programs have been satisfactorily implemented. This inspection effort included both witnessing the hardware modifications in the field and reviewing training and administrative controls implemented as a result of the above problem Various portions of this inspection have been performed during previous months and* are doc-umented in NRC Inspection Reports 280,281/88-12, 88-36, 88-41, 88-51, 89-06 and 89-0 The inspector witnessed post modification functional testing and surveillances as detailed in paragraph 6 of this repor The inspector concluded that the licensee's interim corrective actions are in accordance with their previously listed submittal An overall assessment of the issues surrounding this system indicate a variety of contributor The original design was weak in that*
adequate redundant power supplies were not provide A -lack of station management insistence that equipment be properly maintained became evident as the various components were disassembled for cleaning and repai The station has operated for years without challenging the fact that both trains of this redundant system were required to maintain an adequate heat removal. - Finally, the plant modification program failed to recognize and consider the impact of heat 1 oad addi ti ans on the v_enti 1 ati on syste The above issues were addressed in the enforcement package transmitted to the licensee on May 18 ~ 198.
Operational Readiness Program Review (71710)
The inspectors continued to review the licensee's operational readiness program as discussed in NRC Inspection Reports 280,281/88-51, 89-06, 89-08, and 89-1 This effort is being performed in accordance with EWR 88-584, System Review For Startup, and includes both field walkdowns and a review of outstanding issues by the system engineer The resident
,
inspectors are routinely monitoring all aspects of this readiness progra The following summarizes specific,inspection are*as and findings from this review. - Offsite Problem Identification
_ On* May 18, the inspectors attended a meeting of the Management Problem Review Team held at the licensee's corporate office to review outstanding PPR As part of the above EWR, a review was to be conducted for any outstanding PPRs that should be evaluated for unit restar The PPR process is a formal method for offsite engineering and staff to identify potential problems that warrant additional review and evaluatio The inspector reviewed Nuclear Design Control Manual 6.1, Problem Reporting System, dated May 12, 1989, which is the implementing procedure for this progra In addition, the inspector discussed the implementation of this program with the staff involved -and reviewed a printout of outstanding items identified relating to Surr The program appears to be adequate with no discrepancies identifie ~-
Disposition of Identified Dfscrepancies The primary focus of the inspection effort during this period was directed toward the licensee review and verifi.cation. that i terns identified as restart discrepancies were adequately corrected or resolve Each deficiency that was deemed a startup item was added to a restart lis This restart 1 ist was reviewed and updated-several times a week in a status meeting with the plant manager and key staff personne To remove an item from the restart list, a form had to be submitted stating that either the final disp6sition had been completed or a justification for further action after unit restart. The May 31 reitart list contained 493 total items, of which 226 items remained outstandin The inspectors attended most of the restart meetings and reviewed selected item disposition form The inspectors concluded that the licensee's method for tracking and closing ide~tified items from the above EWR was adequat No inspector concerns or discrepancies were identifie * Summary of Inspection Efforts During the last half oi 1988, several problems were -identified which resulted in questioning the design basis of the service water system and the known confi~uration of other safety-related system As a result of these problems, the licensee, in a meeting in.NRC headquarters on December 22, 1988, stated that they would conduct a safety system review to ensure comprehensive search and resolution of probl~ms prior to the initial unit startup. This review effort was sorted by systems that are referenced in the EOPs and assigned to the newly formed systems engineering group al the statio The licensee
presented a broad overview of the review and concluded that a* SNSOC review and acceptance *of the findings would be required prior to restar In conjunction, the licensee stated that the site QA group would perform an independent asse!?sment of the review activitie The controlling document for this effort was EWR 88-584, System Review for Startup/Surry/Units 1 and The stated purpose of this EWR was to bolster confidence that systems will operate as expecte The scope of this EWR outlines the overall method in which this task is to be performed as follows:
(1) Determination of Systems to Be Include (2)
Plant Configuration Confirmatio (3)
Power Supply and Train Independence Confirmatio (4) Assessment of Outstanding Issues for Each Syste (5)
Functional Testin (6)
Documentation and Acceptance of-Result The resident inspectors and Region II and Headquarter's specialists have reviewed the tasks outlined and have reported the results of these reviews in NRC Inspection Report Nos. 280,281/88-51, 89-01, 89-06, 89-08, and 89-1 As a result of these inspections the following was concluded about each of the six area (1)
The systems determined to be included in the EWR were reviewed and the method used for making this determination was found to be adequat (2)
The inspectors observed the walkdown by systems engineers on several of the key system In addition, an independent walkdown and identification of potential deficiencies were performed by the inspectors on portions of several systems and compared with the deficiencies found by the licensee. * The inspectors determined that the licensee's i.dentification of potential deficiencies and the threshold for categorizing these deficiencies for itartup were adequat (3)
The licensee's testing of the power supply and the Unit 1 emergency 11 H" bus has been observed and was considered adequat A test similar to the 11 H" bus test is to be performed on the Unit 1 11 J 11 bus and will be observed by the inspector (4)
The inspectors reviewed the licensee program to search and evaluate all outstanding issues that had been identified through various method The scope of this search was determined to be
sufficient enough to surface any previous concerns or iecom-mendations that had gone uncorrecte The inspectors consider the licensee's actions in this area to be adequat Programmatic improvement is warranted regarding a formalized method of impl~menting engineering recommendation (5)
The inspectors monitored specifjc special testing evolutions and also reviewed selected periodic test This evaluation was conducted to ensure that adequate testing was accomplished, and components and systems performed as require The inspectors noted some weaknesses in the coordination of the testing program, however, the testing was adequate in demonstrating system/component operabilit (6)
The inspectors closely monitored the licensee's method for documenting and closing discrepancies identified by this review proces This area was determined to be adequate with no outstanding concerns identifie *
The inspectors have concluded that the licensee has performed an adequate evaluation in the previously listed area Maintenance Inspections (62703*& 42700)
During-the reporting period, ~he inspectors* reviewed maintenance activities to assure compliance with the appropriate procedure Inspection areas included the following:
- Evaluation of Maintenance/Modification On The Low Head Safety Injection Pump (1-SI-P-lA)
Replica parts or non-original equipment manufacturer parts were discussed in NRC Inspection Report 280,281/88-5 Some replica parts (sleeves, bushings, bearings and shafts) thought to be removed from VEPCO warehouse inventory during a 1983 identification of a potential problem were found in inventor An examination of the records revealed that one low head SI punip {1-SI-P-lA), one spent fuel cooling pump, and one component cooling water pump had replica parts installed.during previous maintenanc Engineering evaluation only required the replica parts to be replaced in the low head SI pump during this outag The 1 i_censee comp 1 eted rep 1 a cement of the replica parts in the SI pump, reassembled the pump, and placed the pump into its operational location. The motor was run uncoupled from the pump and the results were acceptable; however, the maintenance crew could not turn th~ pump by han The pump was partially removed from the casing and a number of measurements were made for engineering evaluatio The measurements determined that the pump was binding because its mounting plate was not level with the mounting surface of the outer containe As of June 3, the licensee was machining the flange on the container and was evaluating whether
- to machine the flange on the discharge heade The inspectors consider that the licensee's actions to refurbish this pump is adequate and will observe post maintenance testing for returning this component to servic This effort will be documented in the next resident inspector's repor During the replacement of the parts in the SI pump, the licensee
. detennined that all replica parts had not been purged from the supply system. This resulted in an additional inspection of all the suspect safety-related parts located in the warehous The results were that one additional replica part was *identified. After this search, the QC department performed a search of all the safety-related parts in the warehouse and found no additional replica parts. The inspectors consider that the-licensee's replica parts issue has been properly dispositioned with regards to being a restart issu Underground Fuel Oil Storage Tank No. 1-EE-TK-2B During this inspection period, the inspector reviewed the licensee's evaluation and correcti~e actions concerning a potential problem for leakage from one of the two safety-related EDG fuel oil tanks. This evaluation was documented in EWR 89-246, Evaluate EE Tanks (1-EE-TK-2A&B).
The statement of the problem in the EWR was as follows:
"Station Operation_s has reported a leak in the underground 20,000 gallon fuel oil storage tank no. 1-EE-TK-2 The leak rate is*
estimated at a maximum rate of 400 gal./ho~r, at mqximum tank volum The leak is apparently in the upper two feet of this ten foot diameter tank as the volume stabilizes at approximately 85% fill.*
There is no measurable decrease in tank level beyond this point."
This fuel oil tank was_ drained and nondestructive testing was perfonned with the following results:
Visual inspection did not reveal any holes or crack Liquid penetrant inspection of selected areas revealed no holes or crack Ultransonic testing on a random location basis did not re~eal any significant wall thinnin.
.
. Pressure testing using a combination air and helium result~d in no identifiable lea The licensee concluded from these tests that the tank did not have a leak and was in good conditio The indication of a leak was believed to be caused by air pockets at the top of the tank between internal stiffener The licensee dri 11 ed vent ho 1 es in these
stiffeners to alleviate the proble The licensee also drained the second underground fuel storage tank and drilled vent holes in the tank's internal stiffeners. * Because a potential leak existed in the fuel oil tank, an additional test was required by the State of Virginia. This test, America.n Petroleum Institute Standard "Precision Test", ~as conducted with the tank full of fuel oil and ~howed no detectable leak rat The detectable leak rate lower limit using this test is 0.05 gal/h The inspector reviewed the licensee's evaluation process, conducted several observations at the tank test site, and monitored the corrective action work in progres The ins-pector considers that the licensee conducted an extensive evaluation and testing program and that the documentation completed to resolve this issue was adequat.
Surveillance Inspections (61726 & 42700)
Dur*ing the reporting period, the inspe~tors reviewed various surveillance activities to assure compliance with the appropriate procedures as follows:
Test prerequisites were me Tests were performed in accordance with approved procedure Test procedures appeared to perform their intended.function *.
Adequate coordination existed among personnel involved in the tes Test data was p*roperly collected and recorde '.: * '1 -
lnspection areas included the following:
a.. Testing of IRS Pump 2-RS-P-lA On May 1, 1989, the inspect6r witnessed additional flow testing of the Unit 2 IRS Pump 2-RS-P-l The test was accomplished in accordance with 2-ST-223, Operability of IRS Pumps, and was being accomplished after replacement of one of the test valves which had resulted in unsatisfactory test performance (high system vibrations during previous testing).
The inspector attended the pretest briefi.ng, which was conducted prior to test performance*, and
- witnessed the test inside the Unit 2 containmen The inspector verified that initial conditions were satisfied prior to test performance, that test instrumentation was in calibration, and that
- the test data was properly recorded during performance of the tes The inspector specifically noted that vibration data being recorded was well within the full operability range and concluded that the licensee's corrective action for unsatisfactory test results during
~revious testing was resolved.
After completion of testing and appropriate licensee.reviews ~f the test results, the inspector reviewed a copy of the completed test procedure to ensure that it appropriately documented satisfactory testing of the subject pum Fail Safe Testing of Air Operated Valves On May 8, 1989, the inspector witnessed testing of Unit 1 air operated containment isolation valves in accordance with special test procedure 1-ST-245, Slow Air Bleed Down Fail Safe Testing of Safe Shutdown Air Operated Valves~
This test was conducted following a review of instrument air problems per NRC Generic letter 88-14 *
. The test objective was to demonstrate that a slow bleed down of the inst.rument air system pressure would not inhibit the safe shutdown air operated valves from* failing to their designed fail safe positio The inspector witnessed actual testing and reviewed the special test procedur The licensee had completed approximately 50%
of the Unit 1 valves with no identified failure No discrepancies were identified by the inspecto Charging Pump 1-CH-P-lC The. inspector reviewed periodic test 1-PT-18. 7, Charging Pump Operability and Performance Test, dated August 31, 198 The purpose of this surveillance was to demonstrate the operability of the charging pump following maintenanc Also, the surveillance implements the requirements of TS 4.11.B.1, which requires that the charging pumps be tested monthly or during periods of extended outages prior to startu *
On May 7, the inspectors attended the pre:..briefing with the SRO and ROs to.discuss the running of ihe charging pum On this same date, observations were made of the running of th~ pump, measurement of the pump vibration level, recording of the pressure level, and opening~
of several valves to achieve the desired flow pat The vibrational levels were approximately 0.1 in./sec., with acceptance levels being equal to or less than 0.3 in./se Data showed that the vibration level decreased after rebuilding the pump Low Head Safety Injection Pump (2-SJ-P:..lA)
On May 12, the.inspecior witnessed portions of the monthly surveil-lance test of the Unit 2 low head SI pump 2-SI-P-lA in accordanc~
with test procedure 2-PT -18.1, dated April 26, 198 The ove.ra 11 purpose o"f this test was to verify operability of the pump as well as
- operability of various system check valves to open and allow adequate flo The results of this test indicated that the total pump head was within the operable rang The recorded flow was too low to verify operability of the check valves.
The inspector observed the operations staff's evaluation of this situation and noted *that the appropriate system engineer was contacted to assis The licensee concluded that the specific plant conditions at the time of testing prohibited adequate flow to verify check valve operation The inspector discussed this situation with the personnel involved and considers that the evaluation was adequat No discrepancies were noted during this inspectio Main Control Room Envelope Ventilation Functional Test The inspectors reviewed the post-modification testing to be perfonned on the main control room envelope ventilation system following extensive maintenance and modifications during this outage (detailed in paragraph 3). This effort involved a_review of the following test procedures:
Special Test ST-235, Control Room Chiller Equipment Performance Test,.dated December 22, 198 Design Change 88-36-3, Control Room Envelope HVAC System Interim Mods, dated January 19, 198 Periodic Test PT-32.16, Control Room,Envelope Air Conditioning System, dated April 21, 198 In addition to the above procedure reviews, the inspector also witnessed testing per ST-235, which was ongoing when the inspection period ende The scope of the testing appears t~ be adequate with no discrepancies identifie Instrument Air System Surveillance The inspector witnessed daily surveillance testing of the instrument air system per test procedure STP-31, Instrument Air Quality Tes This daily test was implemented on May 15, 1989, following the licensee's response to NRC Generic Letter 88-1 The test measures the dewpoi nt of the IA system so that an assessment of adverse effec*ts from moisture intrusion on safety-related components could be conducte The inspector witnessed the test performed on May 2 The test procedure specifies that a satisfactory dewpoint is l_ess than 35 degree The dewpoint just downstream of the IA dryer was measured on May 24 to be 72 degree A review of the previous test results indicated that the IA system dewpoint was initially measured to be out of specification at 1400 hours0.0162 days <br />0.389 hours <br />0.00231 weeks <br />5.327e-4 months <br /> on May 19, and had been generally trending u The inspector expressed concern that a station deviation was not submitted when the IA system dewpoint was initially measured as unsatisfactor The chemistry department that performed the test was submitting a 11Noti fi cation -
Out Of Specification Condition 11 report to the shift supervisor with the corrective actions annotated that new IA dryers were being installe_d.
This notification did not require an evaluation of the potential adverse effects of elevated dewpoints on the syste The licensee discussed the inspector comments and submitted a station deviation (Sl-89-1246) on May 24, 1989. The inspector concluded that, although the 1 i censee has implemented interim measures in response to the above Generic Letter, there still appeared to be a lack of understanding of the effects of moisture in the IA syste Within the areas inspected, no violations were identifie.
Licensee Event ~eport Review (92700)
The inspectors reviewed the LER's listed below to ascertain whether NRC reporting requirements were being met and to determine appropriateness of the corrective action The inspector's review also included followup on implementation of corrective action and review of licensee documentation that all required corrective actions were complet LERs that identify violations of regulations and that meet the criteria of.
10 CFR, Part 2, Appendix C, *section V shall be identified as NCV in the fo 11 owing closeout paragraphs. *. NCVs are considered first-time o"ccurrence violations which meet the NRC Enforcement Policy for exemption from, issuance of a Notice of Vibl~tio These items are identified to allow for proper evaluations of corrective actions in the event that similar events occur in the fut~re~
- *
(Closed) LER 280/88-11, Inoperable PORVs Due to Inadequate Procedur The
. issue involved a failure of the subject valves to open when the selector switch was placed in the open positio Licensee investigation revealed that the cause of the PORV failures was inadequate maintenance of the actuator diaphrag Specifically, the maintenance procedure did not specify torque values for the diaphragm holddown screws and bolt Corrective action included proper torquing of the fasteners and appropriate testing to verify operability. Additional corrective actions included adding required torque values to maintenance procedure The inspector verified that the procedures were revised to specify torque,
value This item is identified as an NCV 280/89-17-02 for failure to provide an adequate procedure for a safety-'related maintenance activit This LER is close *
(Closed) LER 280/88-13, EOG Auto Start Due to Performance of Multiple Procedures Concurrentl The issue involved EOG No. 3 inadvertently starting during performance of post maintenance testing involving the use of multiple procedures.. At the time of this occurrence, the licensee concluded that the cause of the inadvertent start was the result of performing multiple procedures concurrently, without adequate review for*
.conflicting requirements in the procedure During this inspection period, another inadvertent start of the No. 2 EOG occurre This inadvertent start was also very similar to this LER; however, the licensee's evaluation for the second start concluded that the procedure was inadequate because it d1d not ensure that all auto start signals were
cleared -prior to placing the selector switches in AUT Based Ori the licensee 1s most recent evaluation and conclusions, the inspector consider that adequate corrective a:ctions to prevent recurrence of this LER were not implemented. This issue is identified as a weakness in the licensee 1s past programs with regards to corrective actions and is considered an additional-example of past corrective action problems which were identified in enforcement actions issued.on May 18, 198 This LER is close _(Closed) LER 280/89-02, Gamma~Metrics Excore Neutron Flux Detector Not Qualified Due to Leaking Cable The issue involved a problem identified in the subject detectors by a 10 CFR Part 21 repor The 1 i censee' s corrective action and inspection effort is addressed in the discussion below. This LER is close (Closed) P2188-03, Gamma-Metrics Ex core Neutron Flux Detector Not Qualified Due to Leaking Cables. Gamma-Metrics issued a notice that excore flux monitoring system cables had a potential for leaks at solder joints of the metal hose in.the cable assemblies. The licensee performed a leak test on the two excore flux monitoring system cables for each unit. The test results indicated that certain sold~r joints leaked in each of the four cables and resulted in leak rates that exceeded the acceptance criteri While the excore flux monitors do not perform a protection function, they are used to provide information to aid operators in assessing plant conditions during a nuclear accident and therefore need to be environmentally qualifie Since a leaking cable would not provide an environmentally qualified system, the licensee implemented corrective actions to replace the cables per EWR No. 89-01 The inspectors reviewed documentation -that indicated the work was complet This item is close (Closed) P2188-07, Morrison-Knudson EMO 999 D/G Systems Have Potential for Field Breaker Trip Due to Combined Ajr Temperature and Field Amps Heatin This deficiency was identified following a 24-hour load test run in which the field. excitation circuit tripped. The EDG was carrying a load of 2950 kW at 0.8 p.f. while the current at the field excitation circuit breaker and at the generator field were measured at 96A (ac) and 112A (de),
respectivel The circuit breaker, a General Electric type RED136100 rated lOOA continuous, is located in the generator control pane Subsequent investigation revealed that the ambient temperature in the generator control panel exceeded the 40 degrees C design temperature of the circuit breake The licensee reviewed this problem and implemented corrective actions to replace the breaker and associated wiring per EWR 88-578, EOG Excitation Breaker Replacemen Although the EDGs at Surry utilize the EMO Model 999 Systems, the configuration-differs somewhat from the station that had the problem in that the Surry engines utilize a drive fan that forces a large air fl ow through the room and aids in cooling the room ambien The inspector witnessed. the replacement of the breaker for one EDG and reviewed the completed documentation for all three EOGs at Surr No violations or deviations were identified. This item is closed.
(Closed) P2189-0l, Brown Boveri K-Line Circuit Breakers Delivered Prior to 1974 Need Rebound Spring Added to Slow Close Pi This issue was identified to the NRC and licensee as a 10 CFR Part 21 notice in
. January, 198 The issue involved a recorrunendation from the subject vendor with regards to installation of a rebound spring to all safety-related K-Line electrically operated K-225 through K-2000 circuit breakers manufactured before mid-197 The licensee's corrective action included preparation of an EWR to evaluate and install the rebound springs on all applicable safety-related K-Line breaker The inspector reviewed the licensee's evaluation as documented in EWR 89-28 The inspector also verified that the rebound springs were installed in accordance with the EW The verification included procedure review and witnessing of installation of the rebound spring on breaker 24H The inspector considers that the licensee's actions in this area are satisfactory to close this issue. This item is close.
Evaluation of licensee*Self Assessment Capability (40500)
The inspectors perfo~med an evaluation to determine the effectiveness of the licensee's self-assessment program The focus of this particular inspection involved a performance review of the licensee's onsite and offsite review co1T111ittees in station oversight, assessment, communica-
. tions~ and followu Station Nuclear Safety and Operating Committee During this inspection *period, the inspectors have routinely monitored meetings held onsite by the SNSOC in preparation for restar The purpose of the SNSOC is to provide for a continuous onsite review of all operational and safety aspects of the nuclear facility and to advise the Station Manager on all matt~rs r~lated.to nuclear safet In addition, the inspectors reviewed selected minutes from SNSOC meetings to verify compliance with T The inspectors found that the onsite safety committee was functioning as required by Technical Specifications. The inspectors reviewed the SNSOC meeting minutes for the month of March and noted that the licensee was averaging about 2.4 SNSOC meetings per da It was obvious from the minutes that a large portion of the SNSOC duties is spent approving deviations from previously approved pro~edures to enable compliance during plant operation and maintenanc This reinforces the need to upgrade the station procedures as discussed in previous inspection report Offsite Independent Review Corrmittee The corporate committee is designated the Independent/Operational Event Review Group with the various requirements and duties mandated in Surry (TS) 6.1.C.2. On May 8, 1989, the Surry inspectors, along with the North Anna Senior Resident Inspector, went to VEPCO Headquarters to observe an offs i te independent review committee (
meeting and to evaluate the effectiveness of this independent review functio The committee, during. this meeting, listened to presenta-tions concerning the establishment of a new independent review group and various safety topjc The inspectors observed that there was minimal interchange between the speakers and the conmittee, and that the offsite review group's role was not ~viden The inspectors reviewed Nuclear Operations Standard No. NODS-LR-04, Standard for Independent Review Requirements, dated May 5, 1988, and Safety Evaluation and Control Administrative Procedure N SEC-ADM-2.1, Processing and Criteria for Independent Reviews, dated January 31, 1986. * The inspectors used TS 6.1.C.2 as the reference document during this inspection and dfscussed the TS requirements with the supervisor of the IOER grou The following deficiencies were identified during these discussions:
TS 6.1.C.2.e.1 requires that the IOER Group review written safety evaluations of changes in the stations as described in the Safety Analysis Report, changes in procedures as described in,the Safety Analysis Report, and tests or experiments not described 1n the Safety Analysis Report which are completed without prior NRC approval under the provisions of 10 CFR 50.59(a}(l}.
The inspectors were informed that only the Design Control Packages were reviewed by the IOER Group in accordance with. this requiremen The inspectors consider that all sifety related plant change documents and special test documents (EWRs, STs, etc.) are required to be reviewed* in order to comply with this requiremen TS 6.1.C.2.e.4(a) requires that the IDER Group review violations of applicable codes, regulations, order, Technical Specifications, license requirements or internal procedures or instructions having safety significanc The inspectors were informed that only some of these requirements were being reviewed by_the IOER Grou TS 6.1.C.2.e.4(c) requires that the IOER Group review all reportable event The inspectors were informed that all reportable events were not being reviewed by the IOER Grou TS 6.1.C.2.e.7 requires that the IOER Group review reports and meeting minutes of the Station Nuclear Safety and Operating Committe The inspectors were informed that the IOER Group does not review all of the SNSOC meeting minute Surry Technical Specification, Section 6.1.C.2 requires that an IOER Group provide a continuing review of the operational and safety aspects of the nuclear facility and shall function to provide independent review of designated activities. The failure to provide for continuous review of all operational and safety aspects of the nuclear facility as specified in TS 6.1.C.2 is a violation {280, 281/89-17-01).
- After reviewing the above find1ngs, the inspectors conducted an exit -
meeting with the Manager of Nuclear Licensin In that meeti.ng* the inspectors discussed their findings and stated that they considered that the IDER Group was not conducting reviews as required. by TS 6.1. The Manager of Licensing stated that they were in the process of reviewing this area for improvement in the futur The Surry inspectors also expressed similar concerns over the management control of the independent review activity as described in the North Anna NRC Inspection Report 338,339/89-1 Within the areas inspected, one violation was identifie.
Action on Previous Inspection Findings (92701)
(Closed) IFI 280 1281/88-41-02 1 Followup on Loss of PRT Water *Even The subject event occurred on October 4, 1988 and resulted in approximately 250 gallons of water leaking from a pressurizer safety valve on Unit The unit was in a refueling outage with the RCS at mid-nozzle level. The inspector was concerned that the full implications and possible consequences of this event were not immediately eviden The licensee performed a detailed engineering study of the event and reported their conclusions via memorandum dated April 30, 198 The subject event was initiated when the control room operator, using an approved procedure, attempted to simultaneously vent all three safety*
injection accumulators into the process vent system. It.was at this point that the control room operator noticed fluctuations.in the RCS standpipe level and an increase in PRT pressur The PRT level was noted to decrease from 13 to 10 percent during the event, thus translating to a loss of inventory from the PRT of approximately 250 gallon The operator secured the accumulator vent and noted that the RCS standpipe level indication had returned to norma The accumulators were at 53% level and 420 psig of nitrogen pressure at the initiation of this even The licensee had been venting the reactor for several days by maintaining the reactor coolant system at mid-nozzle and degassing through an empty pressurizer, int6 the pressure relief tank, and out the same process vent syste The pressurizer code safety valves were removed for testing and had a gasket material installed over their flanges for debris control. It was determined that the venting of the accumulators to the process vent system at the.same time as the PRT was venting caused a pressurization of the PRT and resulted in approximately 250 gallons of water being pushed up the pressurizer code safety relief lines and out the gasketed fl~nge The duration of this event was estimated to be one to two minute The licensee also evaluated a postulated scenario where the pressurizer safeties are installed and the thimble guide tubes disconnected at the seal table with their low pressure seals installe The calculated pressure increase in the over~ll RCS from a vent of all three accumulators would be approximately 190 psi This pressure would be more than enough to force RCS inventory up through the seal table, and would be of sufficient pressure to blow out the low pressure seals on the thimbl guide tube The design pressure of the incore thimble guide tube low pressure seals are 30 feet or 13 ps Allowing the safety injection accumulators to continue to vent will ultimately produce enough pressure in the PRT to rupture the PRT rupture disc. The licensee calculated that it would take sixty-eight (68) minu_tes to achieve rupture pressure, during which time the reactor vessel would reach approximately 115 psi Assuming the above conditions with no operator actions, it would be possible to void the reactor vessel 7 inches into the active fuel regio The.operator would have indications
- that this was occurring, such as RCS level drop and vortexing of RHR, and therefore establish RCS makeup and forced cooling of the fue SNSOC reviewed the above scenario on May 1, 1989 and directe~ the following actions:
Require venting the accumulators to containment prior to reducing RCS level to a reduced inventory condition, or prior to disconnecting the seal table. -
Permit venting the accumulators to the process vent system only if the PRT is isolated, and only one accumulator is to be vented at a tim Report the findings via the INPO Network System for information. to _
other utilitie The inspector revie~ed the applicable reports pertaining to this event and discussed the corrective actions with station supervisio This item is close (Closed) IFI 280,281/88-51-02, Review of the Instrument Air System Status Prior to a Unit Restar The inspectors identified during the system walkdowns and documented in NRC Inspection Report 280,281/88-51 that the instrument air compressors were not being maintained in an operable and usable conditio The licensee committed to the restoration of the IA compressors and their fou~dations to an operable status as documented in-the Confirmation Of Action Letter, dated March 9, 198 *
The instrument air compressors are identified in the-UFSAR as being the primary (normal) supplier to the instrument air system and powered from an emergency bus to mitigate the consequences of a loss of offsite power even In reality, the service air compressors are used as the primar supply to the instrument air syste The inspectors witnessed portions of the effort to return the IA system to
compressors were removed and overhauled in accordance with work orders 072842 and 07842 The compressor foundations were refurbished in accordance with EWR 89-00 In addition, the inspectors reviewed the licensee implemintation of their response to Generic Letter 88-1 The inspectors concluded that the licensee actions regarding this IF! to be adequate pending completion of the overall work packag This.IFI is close.
Exit Interview The inspection scope and findings were summarized on *June 6, 1989, with those individuals ident_ified by an asterisk in paragraph 1 and also on May 18, 1989, with the Manager of Licensing, for violation 280,281/89-17-0 The following new items were identified by the inspectors during this exit:
One violation (paragraph 8) was identified for failure to provide for continuous review of all operational and safety aspects of the nuclear facility as specified in TS 6.1.C.2 (280, 281/89-17-01).
One non-cited violation (paragraph 7) was identified for failure to provide an adequate procedure for a safety-related maintenance activity (280/89-17-02).
The Manager of Licensing provided dissenting comments at the May 18, 1989 meeting, by stating that VEPCO met the letter of TS requirements for offsite review committee activitie The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspectio *
1 INDEX OF ACRONYMS AND INITIALISMS AP cc ccw CFR CW DR EOG EMP EDP ESF EWR GPM HELB HVAC HX HPSI IA IE I FI IDER IRS ISI LER LOCA MOV NCV NRC OP PM ABNORMAL OPERATING PROCEDURE COMPONENT COOLING COMPONENT COOLING WATER CODE OF FEDERAL REGULATIONS CIRCULATING WATER DEVIATION REPORT EMERGENCY DIESEL GENERATOR ELECTRICAL MAINTENANCE PROCEDURE EMERGENCY OPERATING PROCEDURE ENGINEERED SAFETY FEATURE ENGINEERING WORK REQUEST GALLONS PER MINUTE HIGH ENERGY LINE BREAK HEATING, VENTILATION, AND AIR CONDITIONING HEAT EXCHANGER HIGH PRESSURE SAFETY INJECTION INSTRUMENT AIR INSPECTION AND ENFORCEMENT INSPECTOR FOLLOWUP ITEM INDEPENDENT/OPERATIONAL EVENT REVIEW INSIDE RECIRCULATION SPRAY INSERVICE INSPECTION LICENSEE EVENT REPORT LOSS OF COOLANT ACCIDENT MOTOR OPERATED VALVE NON-CITED VIOLATION NUCLEAR REGULATORY COMMISSION OPERATING PROCEDURE PREVENTATIVE MAINTENANCE
~
~ -
...
..
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PPR PSI PSIG PT QA QC RCP RCS RHR RO RPS RSS RWP SER SI SNSOC sov SRO SW TS UFSAR
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POTENTIAL PROBLEM REPORTS POUNDS PER SQUARE INCH POUNDS PER SQUARE INCH GAUGE PERIODIC TEST QUALITY ASSURANCE QUAL ITV. CONTROL REACTOR COOLANT PUMP REACTOR COOLANT SYSTEM RESIDUAL HEAT REMOVAL REACTOR OPERATOR REACTOR PROTECTION SYSTEM RECIRCULATION SPRAY SYSTEM RADIATION WORK PERMIT SAFETY EVALUATION REPORT SAFETY INJECTION
.
STATION NUCLEAR SAFETY AND OPERATING COMMITTEE SOLENOID OPERATED VALVE SENIOR REACTOR OPERATOR SERVICE WATER TECHNICAL SPECIFICATIONS UPDATED FINAL SAFETY ANALYSIS REPORT