IR 05000280/1989036
| ML18153C084 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 01/11/1990 |
| From: | Kellogg P, Mellen L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18153C083 | List: |
| References | |
| 50-280-89-36, 50-281-89-36, NUDOCS 9001300468 | |
| Download: ML18153C084 (11) | |
Text
Report Nos.:
UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, ATLANTA, GEORGIA 30323 50-280/89-36, 50-281/89-36 Licensee:
Virginia Electric and Power Company Docket Nos.:
50-280 and 50-281 Facility Name:
Surry Units 1 and 2 License Nos.: DPR-32 and DPR-37 Approved by:
Der~ Sig!')ed
//~/re bate Signed SUMMARY Scope:
Thi5 special announced inspection was conducted to review the results of corrective actions taken to correct deficiencies identified during the Safety System Functional Inspection on the Emergency Service Water Syste This inspection also reviewed the Procedure Upgrade Progra Results:
The majority of the corrective actions for the SSFI identified violations are either complete or in progres The corrective action effort appears adequate with the completed corrective actions showing significant improvement over the conditions that existed at the time of the Safety System Functional Inspectio The Procedure Upgrade Program has not been in effect for sufficient time t determi.ne the adequacy of the progra The limited commitment tracking system and the optimistic schedule were the only areas of weakness that were identified.
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REPORT DETAILS Persons Contacted Licensee Employees
- B. Benthall - Licensing
- B. Bileyu - Licensing
- E. Grecheck - Assistant Station Manager, Nuclear Safety and Licensing E. May - Project Engineer *
R. Rasnic - Supervising Mechanical Engineer S. Wiser - Mechanical Design Engineer Other licensee employees contacted included engineers, operators, :
technicians~ maintenance personnel, and office personne NRC Resident Inspectors
- W. Holland, Senior Resident Inspector L. Nicholson, Resident Inspector
- Attended Exit Interview Acrcnyms used throughout this report are listed in the last paragrap Procedure Upgrade Program
- Maintenance and Operating Procedure Upgrade Program The inspector attended a presentation by the licensee that described the Maintenance and Operations Procedure Upgrade Program {MOPUP).
There are approximately 6500 Surry procedures that will be upgraded in this effort. This includes:
3425 Operation Procedures 2345 Maintenance Procedures 290 Miscellaneous Test Procedures 179 Health Physics Procedures 163 Chemistry Procedures
Engineering Procedures
Emergency Planning Procedures
Security procedures The inspector reviewed a selected sample of the approximately three hundred procedures which have been completed to dat While the technical content has not changed considerably, the human factor aspects appear to have improve These procedures will require a supplementary revision to bring them into conformance with the writers guide for this projec The writers guide is presently scheduled to be issued in February 199 ~*
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The licensee 1s schedule indicates that approximately 80-85 procedures will be revised monthly for' five year The planned staffing level for this project is 45 which includes 12 procedure writer The inspector noted that a weakness of the program appears to be the lack of an organized compilation of regulatory. conunitments at the onset of the tas The inspector discussed this concern with the licensee. The progress of this project will be reviewed during futurE:
inspection Administrative Controls Upgrade Program The Administrative Controls Upgrade Program (ACUP) inanages the Administrative Procedure upgrad Similar station administrative controls will be combined into procedures that are conunon to both Surry and North Ann There are approximately 320, procedures that will be upgraded using this process. This includes:
110 Station Department AdiT1inistrative Procedures 75 Station Administrative-Procedures 76 Administrative Standards 50 Corporate Administrative Procedures At the time of this inspection the inspector w~s informed that 36 procedures had been implemented using this proces The inspector checked with station records and determined that approximately 19 procedures had been received and distribute The licensee is reviewing their tracking system to determine where the balance of the procedures are in the syste No violations or deviations were identifie.
Action on Previously Identified Findings (92701, 92702} (Closed) Violation 280,281/88-32-01: Failure to establish a design control program that meets ANSI N 45.2-11 requirement The inspector reviewed Design Calculation ME-166, Intake Canal Inventory, Revision 2, dated July 11, 1989, which is a combination of a 11 previously issued design ca lcul at ions that addressed the upper intake canal inventory concern The calculation results were validated by simulator runs and field verificatio The conclusions of the calculation indicate that with a canal level of 23 feet, with appropriate manual and automatic actions, there is sufficient canal inventory to support post accident_recirculation spray heat exchanger operatio The inspector discussed the calculation, including all assumptions, with the originato The inspector then reviewed the assumptions with the plant operations staf The inspector also reviewed a selected sample of the modified procedures and determined that appropriate changes were included in the procedur '" **
Other revised calculations relating to additional open report items were also reviewed during this inspectio In general the procedures have improved and the specific examples cited in Inspection Report No. 88-32 were correcte (Closed) Violation 280,281/88-32-02: Failure to exercise service water valves to the position required {closed to open).
The inspector reviewed Performance Test PT-25.1, Quarterly Testing of Circulating Water and Service Water System Valves, dated-July 19, 1989, and PT-25.2, Testing of Service Water Valves to and from Recirculation Spray Heat Exchangers, dated September 29, 1988, which were revi5ed to reflect the required test directio (Closed) Violation 280,281/88-32-03: Failure to include appropriate qualitative or quantitative acceptance criteria into site procedure The inspector reviewea the specific examples of either missing or inappropriate acceptance criteria cited in NRC Inspection Report Nos. 50-280,281/88-3 The 1 i censee revised MMP-C-G-228, 30 Inch Jamesbury IM0-302 Valves, dated October 25,1989; PT-25.3A, Emergency Service Water Pump, dated October 10, 1989; PT-25.3B, Emergency Service Water Pump, dated October 10, 1989; PT-25.3C, Emergency Service Water Pump, dated October 10, 1989; PT-23.)D, Emergency*
Service Water Pumps Batteries Weekly Check, dated May 14, 1989; PT-23.9D, Emergency Service Water Pumps Batteries Quarterly Check, dated May 14, 1989; and Emergency Diesel-Service Water Pumps Battery Replacement, June 21, 198 The inspector reviewed these procedures and determined that the appropriate acceptance criteria were include (Closed) Violation 280,281/88-32-04: Failure to establish adequate procedures for torquing fastener The inspector reviewed Standing Order 89-1, dated May 22, 1989, that was issued to ensure the correct values are used when torquing fastener This required in part that all torque values listed in procedures wi 11 be verified by Maintenance Engineering prior to torquin Maintenance Engineering will note verification by initialing the value in the procedur The. inspector also reviewed SUADM-M-45, Torque Manual, dated October 10, 1989, which provides guidelines and techniques for prestressing bolts, studs, and other fasteners. Collectively, these programmatic changes provide the technical basis for a reliable torquing progra (Open) Violation 280,281/88-32-05: Failure to establish adequate measures to maintain material traceabilit *
The inspector reviewed the licensee 1s proposed corrective actions and discussed them with the Supervisor of Purchasing Departmen The program has not been completely implemented and those portions that have been implemented have not been in place lon~ enough to judge their effectivenes This item will remain open until the program has been completely implemente (Closed) Violation 280,281/88-32-06: Failure to perform testing to demonstrate operabilit The inspector reviewed the proposed operability test program and discussed the program with program managemen The program incor~orates appropriate testing criteria; however, it has not bee implemente Administrative Procedure SUADM-M-47, Post-maintenance Test/Verification Program, Revision 0, that governs this process received SNSOC approval on December 13, 198 The first work orders generated from this new procedure appeared adequat (Closed) Violation 280,281/88-32-07: Fa.ilure to correct conditions adverse to qualit *
The inspector reviewed QADIN 18, Revision 6, which established the requirements for the administrative control and processing of Quality Assurance Audit Program documents within the Quality Assurance Departmen The procedure clearly defines responsibil'ity for the correction of conditions adverse to qualit The specific items addressed in NRC Inspection Report Nos. 50-280,281/88-32 have been correcte (Closed) Violation 280,281/88-32-08: Failure to document corrective action for identified deficiencie The inspector reviewed SUADM-LR-13, Station Deviations, draft, that included an augmented methodology for assuring that Station Deviations are investigated and processed in an expeditious manne Additionally the inspector reviewed Quality Assurance Organization Conformance Standard QAOS-2.1, Revision 0, that defines the responsibilities and scope of the activity reporting process within the Quality Assurance Organizatio These documents clearly define the process to be taken when Quality Control identifies deviations or nonconformance The procedural improvements appear adequat (Closed) Deviation 280,281/88-32-09: Failure to meet commitments to the NRC Generic Letter 83-28 for including vendor manual requirements into site procedures *
The inspector reviewed Mechanical Preventive Maintenance Procedure SW-P-M/SA2, Emergency Service Water Pump Coupling, Clutch, Right-Angle G~ar Drive and Pum~ Lubric~tion, Strainer and Vent Trap Inspection; Calibration Procedure 2-CAL-466, Recirculation Spray Heat Exchanger Inlet Header F-SW-205B; Operating Procedure OP-49.2, Diesel Emergency Service Water Pump Operation, Revision 1; Mechanical Preventative Maintenance Procedure SW-P-M/A3, Emergency Service Water Pump Diesel Engine Service and Inspection; Preventive Mechanical Maintenance Procedure ZZ-MOV-M/Cl, Limitorque Motor Operated Valves Inspection and Lubrication; and Preventive Electrical Maintenance Procedure ZZ-MOV-E/Cl, Limitorque Motor
- Operated Valve Service and Inspectio These procedures were modified to include the appropriate vendor manual requirement (Closed) Unresolved Item 280,281/88-32-11: NRR to determine if Surry can meet GOC-2 requirement The licensee has prepared an Action Plan GOV 02-54C, GDC-2 Hurricane Shutdown Reanalysis Surry Power Station. Additionally, the licensee has pre pa red Abnormal Procedure AP-37. 0 I, Abnormal Environmental Conditions, Revision 00.0 Both of these documents have been submitted to NRR for resolutio (Closed) Unresolved Item 280,281/88-32-12: Evaluate the lack of voltage drop or voltage profile analysis for station 125 volt direct current batterie The inspector reviewed Engineering Calculation EE-46, Surry 125Vdc Loading Analysis, Revision 0, which verified the I25Vdc system, confirmed battery sizing, and determined vo 1 tage 1 eve ls at the distribution panel The results of this calculation were that the 125Vdc system was satisfactory as currently configure The inspector spot checked portions of the Engineering Calculation and discrepancies were not identifie.
(Closed) Unresolved Item 280,281/88-32-13: Evaluate the potential loss of combustion air to the Emergency Service Water Diesels due to ceiling damper failur The licensee's current operating procedures contain instructions to block open any ventilation damper that fails to open on a diesel star A ladder and pliers must be available and administratively contra 11 ed in the Emergency Service Water Pumphouse to enable the operator to implement these instruction The inspector verified that these are administratively controlled and available for use by the operator. A permanent solution is being develope (Closed) Inspector Followup Item 280,281/88-32-15:
Resolution of deficiencies from walkdowns of the Service Water System and Pumphous... **
The majority of the identified deficiencies have been correcte Those that have not been corrected have been schedule The inspector reviewed a selected portion of the corrective actions and additional discrepancies were not identifie (Closed) Inspector Followup Item 280,281/88-32-16: Evaluate testing the batteries during Emergency Service Water Pump Diesel surveillance without a battery charger connecte The inspector reviewed Engineering Work Request 89-526, Evaluate Service Water Pumps Ammeters 91-SW-PENG-lA, lB, IC, which provides the direction for changes to Performance Test PT-2 The revision to* this procedure deiineates the testing methodology for the charging circui (Closed) Inspector Followup Item 280,281/88-32-17: Update electrical drawing 11448-FE-lG to accurately reflect as built conditions.* One-line diagram 11448-FE-lG, Revision 13, showed a feed to the Air Side Seal Oil Backup Pump from Bus 18 that was not installed in-the fiel The licensee investigated this discrepancy and determined that it resulted from incorrectly updated drawings that did not reflect a 11 the work performed.under design change 85-1 The inspector reviewed drawing revisions 14 and 15 and confirmed that the discrepancy has been correcte (Open)
Inspector Followup Item 280,281/88-32-18:
Wirina discrepancies between drawings and as built conditions in the main control boar This item has been assigned to the corporate electrical engineering design office and is scheduled for licensee followup on February 28, 199 (Closed) Inspector Followup Item 280,281/88-32-19: Evaluate the use of Butterfly valves for throttlin The licensee has turned thfs problem over to the corporate engineering staf The inspector reviewed the Architect-Engineers draft evaluation, issued on December 5, 1989, on the use of Butterfly valves for throttlin The licensee is reviewing this evaluation for incorporation into plant procedure (Closed)
Inspector Followup Item 280,281/88-32-20: Correctly maintain operator logs to accurately reflect personnel availabl The Uni.t 2 Senior Reactor Operator's log has been changed to specify Technical Specification Positions that are manned by operation The inspector reviewed a random sample of Senior Reactor Operator's log entrie In the sample reviewed, all the required mtidified log entries were accurat (Closed) Inspector Followup Item 280~281/88-32-21: Update plant procedures and UFSAR to _accurately reflect updated Service Water ca lculati an The inspector reviewed Licensed Operator Requalification Program, RQ-89.S3-LP-1, Outage Modifications, which identified procedures and equipment that were modified during the previous outag The inspector reviewed a selected sample of this information, and it appeared adequat (Closed) Inspector Foll owup Item 280,281/88-32-22: Verify Service Water valve testing and method to keep Recirculation Spray Heat Exchanger dr *
PT-25.2, Testing of service water valves to and from recirculation spray heat exchanger and PT-25.1, Quarterly Testing of Circulating Water and Service Water Sys.tern Valves were modified to preclude the possibility of service water intrusion during stroke time testing of circulating water and service water motor operated valve Additionally, the licensee revised the Maintenance Operating Procedures that address removal and return to ser~ice of the main condenser waterboxes (MOP-48 seri~s).
The inspector reviewed these changes and found them to be acceptabl (Closed) Inspector Followup Item 280,281/88-32-23: Evaluate the installation of a commercial grade gauge in a safety-related application and maintain calibration records for this gaug Differential Pressure Indicator 1-SW-DPI-28 was the specific instrument that was addressed in this inspector followup item. This instrument was evaluated against the criteria established in the licensee's Technical Report EE-0012, Clarification of Safety and Non-safety Related Pressure Boundaries as They Relate to Iristrumentation, Revision The licensee determined that it was not required to be purchased as a safety-related componen Periodic Test Procedure, PT-62.19, Tracking Procedure for Secondary Instrumentation was revised on September 26, 1989, to include 1-SW-DPI-28 in the routine annual calibration progra (Open) Inspector Followup Item 280,281/88-32-25: Revise UFSAR to accurately reflect correct test frequency for ESW pump An appropriate UFSAR Change Request has been prepared and is in the review/approval proces The licensee was unable to locate the UFSAR change request. This item remains ope... **
8 (Closed) Inspector Followup Item 280,281/88-32-26:
Provide training for personnel on use of PT25.3.C data takin The inspector reviewed the classroom instruction package for Mechanics Course, ND-5-LP-7, Test Equipmen The course material had been modified to include appropriate instructions on the use of Strobotac Speed Indicato Aclditionally, the.inspector reviewed Nuclear Control Room Operator Development Program Job Performance Measure 1.09.05, which requires that prior to solo use of Strobotac equipment, a trainee must successfully demonstrate the ability to use the equipmen The corrective actions appear adequat (Closed)
Inspector Followup Item 280,281/88-32-27:
Include tolerances for ESW pump flow in appropriate procedure The inspector reviewed OP 49.2, Diesel Driven Emergency Service Water Pump Operations, June 20, 1989, which contained the appropriate ranges for cooling water temperature, lube oil pressure, and pump discharge pressur Additionally, the inspector reviewed 1-PT-25. 3A, Emergency Service Water Pump ( 1-SW-P-lA); 1-PT-25.38, Emergency Service Water Pump (l-SW-P-18); and 1-PT-25.3C, Emergency Service Water Pump (1-SW-P-lC)
which were issued on June 20, 198 These procedures contain appropriate ASME Section IX and ISi acceptance criteri (Closed) Inspector Followup Item 280,281/88-32-28: Revise procedures to assure operability of control room chiller pump PT 32.16, Control Room Envelope Air Conditioning System, was revised August 22, 198~.
This revision addresses control room chiller operabilit The inspector reviewed the data from the two most*
recent completions of PT 32.16, however, these were not accomplished using the current revisio The revised Performance Test will not be run with the changes until January 199 Nevertheless, these procedure changes appeared to be adequat (Closed)
Inspector Followup Item 280,281/88-32-29:
Perfor corrective action to close DR 1-88-099 Station Deviation Sl-88-0998 addressed the lack of qualification of the diesel start batteries and inadequate test procedure Special test ST-231, Emergency Service Water Pumps Performance Run, dated January 21, 1989, was performed to obtain the data necessary to improve existing surveillance procedure The data from these tests were used to verify and modify assumptions made in design calculations and to update procedures *
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Calculations CE-0602, Seismic Qualification of Emergency Service Water Diesel Starting Battery Exide COM-8D-P and Battery Rack, Revision O; CE-0593, Seismic Qualification of Emergency Service Water Starting System Batteries, Revision O; and SE0-1195, Seismic Supports for Single/Double Heater Arrangement for the Emergency Service Water Pump House, Revision O; were prepared to seismically qualify the ESW Pump diesel batteries. The inspector reviewed these calculations along with EE-0044, Electrical Equipment Qualification Emergency Service Water System (Safety System Functional Inspection Concerns), Revision The inspector discussed the calculations with the appropriate author.' These calculations appeared adequat.
Exit Interview The inspection scope and findings were summarized on December 14, 1989, with those persons indicated in Paragraph The inspectors described the areas inspected and described th~ inspection results listed belo No dissenting comments were receive Licensee management was informed that eight previous violations, one previous deviation, three previous unresolved items and 12 IFI 1s discussed in paragraph 3 were closed during this inspectio.
Acronyms AE-ANSI-ASME-AOP-BC-CC-CCW-CFR-CW-DR-.
EMP-ESF-ESW-EWR-F-
FT-GDC-HX-I&C-IFI-MOV-NRC-NRR-Architect Engineer American National Standards Institute American Society of Mechanical Engineers Abnormal Operating Procedure Bearing Cooler Component Cooling Component Cooling Water Code of Federal Regulation Circulating Water Deviation Report Electrical Maintenance Procedure Engineered Safety Features Emergency Service Water Engineering Work Request Fahrenheit Flow Transmitter General Design Criteria
. Heat Exchanger Instrument and. Control Inspector Followup Item Motor Operated Valve Nuclear Regulatory Commission Nuclear Reactor Regulation
".
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OP-Operating Procedure P-Pump PM-Preventive M~intenance PO-Plant Operator RHR-Residual Heat Removal RO-Reactor Operator RS-Recirculation SpraY
RSHX-Recirculation Spray Heat Exchanger SNSOC-Station Nuclear *Safety and Operating Corranittee SRO-Senior Reactor Operator
_
SSFI-Safety System Functional Inspection SW-Service Water
TS-Technical Specifi£ation UFSAR-Updated Final Safety Analysis Report URI-Unresolved Item