IR 05000280/1990004

Insp Repts 50-280/90-04 & 50-281/90-04 on 900212-16 & 20-23.No Violations or Deviations Noted.Major Areas Inspected:Inservice Testing,Complex Surveillance,Local Leak Rate Testing & Concerns Re Reactor Coolant Pump Barriers

ML18153C175
Person / Time
Site:	Surry
Issue date:	03/21/1990
From:	Belisle A, Scott Sparks NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML18153C174	List: IR 05000280/1990004 ML18153C173
References
50-280-90-04, 50-280-90-4, 50-281-90-04, 50-281-90-4, NUDOCS 9004110095
Download: ML18153C175 (24)

Text

Report Nos.:

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION 11 101 MARIETTA STREET, AT.LANT A, GEORGIA 30323 50-280/90-04 ano 50-281/90-04 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:

February 12-16 and 20-23, 1990 Inspector:

S. sh~

S. Sparks,Team Leader Team Members:

S. Tingen J. Zeiler Accompanying Personnel:

A. Belisle, February 20-23, 1990

;)

..

I j'

I -

Approved by:

( ( JY:...~l (/12'-'

A. Belisle, Chfef]

Scope:

Test Programs Section Engineering Branch Division of Reactor Safety SUMMARY Date Signed rlatelSigned This routine, announced inspection was conducted in the areas of inservice testing, complex surveillance, local leak rate testing, containment integrity,

.MDV and SRV program review, concerns related.to the recirculation spray heat exchangers, concerns related to the reactor coolant pump thermal barriers, and inspection followup on previous inspect~on finding *

Results:

In the areas inspected, violations or deviations were not identifie \\ *.

Weaknesses were identified in the areas of IST of pumps and check valves, paragraph Weaknesses were identified concerning MDV training, paragraph Strengths were identified in that the licensee was aggressively pursuing MDV failures,Bulletin 89-10 requirements; and monthly MOV reporting, paragraphs 6.a and l Oc,90::- *

F'DFi*

/\\ * * * *-*.9(10:-:.-:,,*1

-

i

,.,r,o,-*,***. c:-. -**-*

w

--, u~ooojeo F'DC

A weakness was identified concerning Event V pressure isolation valves, which involved the method for maintaining the procedure and local leak rate testing acceptance criteria, paragraph _...,.;,,,,,-' Persons Contacted Licensee Employees REPORT DETAILS

• W. Benthall, Licensing Supervisor C. Duang~ IST Engineer

• E. Grecheck, Assistant Station Manager

• D. Hart, Quality Supervisor

• M. Kansler, Station Manager

• J. Kin, Corporate IST

• R. MacManus~ IST Superviscir

• D. Roger, ISI/NDE Programs

• 8. Sca~lan, Licensing Engineer B~ Sloan, System Engineer K. Sloane, Operations Support Supervisor

• J. Stouffer, MDV Coordinator D. Valdivieso, Senior Engineering Technician Other licensee employees contacted during this craftsmen, engineers, operators,

• mechanics, administrative personne NRC Resideni Inspectors

• W. Holland, Senior Resident Inspector L. Nicholson, Resident Inspector

• J. York, Resident Inspector

• Attended exit interview inspection technicians, included and Acronyms and initialisms used throughoLlt this report are listed in the last paragrap. *

Inservice Testing (73756)

10 CFR 50.55a(g) and TS Surveillance Requirement 4.0.3 require th~t ASME..

Code Class 1, 2, and 3 pumps and valves be inservice tested in acco~dance?

with Section XI of the ASME Boiler and Press~re Vessel Cod Secti~n XI specifies ~equirements for IST to assess operational readiness of ceftain Class 1, 2, and 3 pumps and valve The licensee is committed to the requirements of ASME Code)Section XI, 1980 Edition through the Winte Addenda for pump and valve testin During this inspection, the inspectors reviewed the licensee's IST Program, implementing procedures, ii and test results that accomplish Section XI pump and valve IST for components in the AFW syste *

2 Check Valve Testing The inspectors reviewed procedures and results for check valves located in the AFW syste Requirements for full stroke and reverse flow exercising check valves are contained in Section XI, Subsection IWV-3520 of the Cod The inspectors noted that some check va 1 ves were not ful 1 stroked in accordance with the guidance contained in GL 89-04, Guidance on Developing Acceptable Inservice Testing Program GL 89-04 states that an acceptable method to full stroke check valves is to pass design accident flow through the valve.- Specifically, the following check valves were noted in this category:

Valve 2-FW-305 2-FW-306 2-FW-131 2-FW-133 2-FW-136 2-FW-138 2-FW-027 2-FW-058 2-FW-089 2-FW-142 2-FW-157 2-FW-172 Actual Flow 100 GPM 100 GPM 100 GPM 100 GPM 100 GPM 100 GPM 100 GPM 175 GPM 175 GPM 100 GPM 175 GPM 175 GPM Design Flow 175 GPM 175 GPM 350 GPM 350 GPM 350 GPM 350 GPM 350 GPM 350 GPM 350 GPM 350 GPM 350 GPM 350 GPM Similar conditions exist for the Unit 1 check valve The licensee's current IST program, (Revision 4 for Unit 1, and Revision 2 for Unit 2) recognizes the NRC position on full-stroKe testing of check valves, and their IST program has committed to revising CSD and RFD procedures by the next RFO for each uni Check valves which are.

burdensome to full stroke test will be identified by the licensee, and an acceptable alternative, such as disassembly, will be considere The inspectors discussed planned revisions to these procedures with the licensee. Procedural revisions should address the NRC position on check valve testin However, until such testing is implemented and performed, the inspectors consider the lack of current check valve full stroke testing to be a weakness in the licensee's IST progra The inspector's review of current testing procedures for check valves located in the AFW system indicated that partial stroke testing was performed at the required frequenc The inspectors also reviewed reverse flow testing of check valve The inspectors were speci fi cal ly interested in reverse fl ow testing check valves FW-27, FW-58, and FW-89 (both Units), due to their importance.i.R- -

minimizing a common cause failure as identified in the Surry PRA analysi These check valves are located in the AFW piping where the*AFW system is

tied to the main feedwater pipin Th.e PRA analysis indicated that failure of these check valves to prevent reverse flow could steam bind the AFW pumps, and could subject upstream piping to abnormally * high temperature The inspectors noted that these check va l.ves were not being reverse-fl ow teste However, the pump discharge check va 1 ves (FW-142,157,172) were reverse flow tested per !ST,- and two additional check valves at the containment penetration for each train are reverse flow tested (FW-131,133,l3b and 138, although these were not in the !ST program for reverse-flow testing).

The licensee also monitors piping temperature at each containment penetration (both trains)* during each shift to detect leakage past the three check valves (i.e., FW-27, FW-131, and FW-133).

Based on the current testing and temperature monitoring, the inspectors concluded that the licensee is taking adequate measures to preclude steam binding the AFW pump Pump Testing The inspectors reviewed !ST of the MDAFWPs (2 per Unit), and the TDAFWPs (1 per Unit), to detefmine if testing was performed in accordance with Section XI, Subsection !WP, requirement The following AFW

!ST implementing procedures were reviewed:

1-PT-15.lA 1-PT-15.JB 1-PT-:15. lC 1-ST-263 1-ST-267 Motor Driven Auxiliary Feedwater Pump (1-FW-P-3A)

Motor Driven Auxiliary Feedwater Pump (1-FW-P-3B)

Turbine Driven Auxiliary Feedwater Pump (1-FW-P-3C)

Auxiliary Feedwater Full Flow Trending Data Turbine Ori ven Auxiliary Feedwater Full Fl ow Trending Data Technical Manual, Ingersall-Rand Instructions for HMTA and HMTB Hori-zontally Split, Multistage Sleeve Type Bearings, dated March 1965 Similar procedures were reviewed for Unit Relief Request P-6 provides the licensee's current testing requirements for the AFW pump Due to a lack of instrumentation on the recirculation lines, flow cannot be measure The licensee's !ST program indicates that a design change has been initiated to install larger recirculation lines with flow and pressure instrumentation. Installation is scheduled for the upcoming RF The licensee's current testing may not indicate hydraulic degradation due to a lack of flow meisurement, and thus the insptctors -~

consider the current testing t6 be a weakness in the*IST progra ~

, (

.

'

.,\\'.

Due to the 1 i censee I s current AFW pump testing, recent full-flow testing during the last CS ST-273 were reviewed, and indicated that all approximately on the vendor's head curve *

• ,.

'

.

the inspectors reviewed Procedures ST-263 and pumps were operating The inspectors also reviewed and witnessed the performance of 1-PT-15.lB (Unit 1 38 MDAFWP) and 2-PT-15.lC (Unit 2 TDAFWP).

During the pre-test briefing, precautions and limitations, procedural steps, and acceptance

• criteria were discusse Based on a review of the completed test data,.

the licensee correctly categorized the MDAFWP 38 *test as entering the alert statu The inspectors also noted that while the 38 pump was running, no patking leak was evident. Review of the pump technical manual indicated that leakage is rieeded for packing lubrication and cooling. The licensee stated that this condition had been discussed with the pump vendor, who stated that this condition was more of a maintenance problem and not an operational. concer In addition,. due to the physical arrangement of the packing, lubrication to the seals when the pump was running may be difficult to detect visually. The licensee also monitored*

temperature in the sea 1 area during the 1-PT-15.18 test of the MDAFW 38 pump in which the temperature stabilized at approximately 120° Power Operated Valve IST The inspectors_reviewed IST for th~ following MOVs and AOVs located in the AFW system:

1-FW-MOV-151A 1-FW-MOV-1510 1-FW-MOV-260A 1-MS-SOV-102B 1-FW-MOV-151B 1-FW-MOV-151E 1-FW-MOV-260B 1-FW-MOV-151C 1-FW-MOV-151F 1-Ms..:sov-102A Similar valves were reviewed for Unit 2.*

• Licensee personnel wer~ interviewed regardi~g the general methods used t6 stroke-time power-operated valve The inspectors also reviewed appropriate relief requests, and implementing procedures which accomplish IS Criteria for IST power operated valves are contained in Subsection IWV 3400 of the Code, which specifies stroke timing, fail-safe testing, and corrective *action requirement Subsection IWV-3300 addresses valve position indicator verification and requires checking remote position indicators once every. two years to verify that valve operation is accurately indicate *

The inspectors verified that the testing frequency and post-maintenance testing as a result of corrective actions was performed sa*tisfactoril Within the areas inspected, no viol~tions or deviations were identifie.. Contain~ent Local Leak Rate Testing (61720)

The purpose of the inspettion activities in this.area was to determine if the 1 i censee I s LLRT program was being conducted in compliance with*

NRC requirements and applicable industry standard The following LLRT engineering and* Unit 2 specific periodic test procedures were examined:

-~-*-

ENG-7 PT-1 PT-16.2 PT-16.28

• 2-PT-1 PT-1 PT-1 PT-1 PT-16.11

Type Band C Leakage Tracking, dated 08/22/89 Electrical Penetration Local Leakage, dated 10/27/89 Conax Electrical Penetration Leakage Test, dated 07/19/89 Westinghouse Electrical Penetration Leakage, dated 07/19/89 Containment Isolation Valve Local Leakage Rate Testing (Type 11C 11 ), dated 04/19/89 Containment Personnel Air Lock Test~ dated 05/30/89 Equipment Hatch and Emergency Personnel Escape Hatch Leak Test, dated 05/30/89 Personnel Airlock Leakage Test, dated 07/19/89 Containment Purge Leakage Test, dated 09/06/88 The inspectors verified that the following attributes were included in these procedures to ensure that adequate leak rate tests were conducted:

(1) A 11 re qui red containment pen et ration boundaries and CI Vs were included in the LLRT progra (2)

LLRTs were performed at CILRT peak design pressur (3)

The LLRT program utilized approved methods for testing contain-ment penetration boundaries and CIV (4)

Penetration leakage rates were determined using the maximum pathway leakag (5) * The criteria and response for LLRTs and combined leakage rate failure were incorporated in the test program procedure One procedural weakness was i dent ifi ed and discussed with the 1 i censee concerning Type C test procedure PT-1 Each penetration tested is provided with a system diagram which identifies the initial valve lineup required before testin After testing is complete, the valves are returned to their ori~inal position: However, one sign-off step controls the verification that the system is in the correct lineup for testing and one sign-off controls valve restoratio For more complex systems~ this requires the verification of a large number of valves. This activity can be further complicated by the use of more than one person manipula~ing th~

valve A more positive means of control for this activity would b~ t(,'

individual sign-offs for each valve in the system tested. It was l~arned from discussions with the LLRT coordinator that the licensee had al~eady planned to revise procedure PT-16.4 to include individual valve sign-offs for the initial configuration, the test position, and the resiored valve position for each penetration. The procedures were to be revised before the next Unit 1 RFD scheduled in October 199 *~

Using procedure* PT-16.4, a detailed review was performed for Type C classified CIVs* in the following penetrations:

• Penetration 15

• Penetration 23 Penetration 24 Penetration 33 Penetration 38 Penetration 51 Penetration 53 Penetration 70 Penetration 89

CVCS - charging to regenerative heat exchanger HHS! - normal charging to hot legs RHR to RWST Gaseous drains and vent system - drain tank pump discharge Aerated drain system - sump pump discharge Recirculation spray - service water drains Primary plant gas system - nitrogen to PRT Recirculation spray - pump discharge Air ejector discharge to containment The inspector verified that adequate alignments for venting and draining existed, and that adequate valve boundary alignments were provided for each valve teste The inspectors verified that the penetration valve configurations described in the procedure agreed with current plant drawing In addition, the inspectors verified that the penetrations conformed to the General Design Criteria 55, 56, and 57 of Appendix A to 10 CFR 5 From the penetration review, a minor discrepancy between,the valve diagram provided in the procedure and the official plant drawing was identified and discussed with the licensee. A valve used as a vent path for testing penetration 38 was not found on the official plant drawin The licensee investigated this problem and discovered that the valve had been deleted by mistake after a routine system walkdown was conducted by the responsible system enginee The valve was located in an obscure location and was overlooked during the walkdow Since the valve was not visually found, the system engineer requested the plant drawing to be revised to delete the valve. The licensee stated that the plant drawing would be correcte The inspectors considered this matter an isolated even The inspectors reviewed a sample of completed as~found and as-left Type 8 and C LLRT results since the beginning of the last outage for Unit Particular attention was devoted to verify that corrective maintenance work was performed for valve test failures and that retests were performed as require Unacceptable conditions were not identifie The inspectors discussed th~ training of operations personnel performing LLRTs and interviews conducted with test personnel to determine their knowledge of test practice No formal training is provided for test personne However, test. personnel interviewed were knowledgeable of their responsibilities, the use of test equipment, and the technical aspects of leak rate testin The licensee plans to provide formal training to test personnel before the next refueling outag Within the areas inspected, no violations or deviations were identifie ~--~---

• 7 Verification of Containment Integrity (61715)

The purpose of inspection activities in this area was to verify the adequacy and implementation of procedures and controls designed to maintain containment integrity and to mitigate contamination releases in the event containment integrity is lost following a LOC Primary Containment Integrity Controls The inspectors reviewed Unit 2 operation procedures OP-1.1, Unit Startup Operation - Ambient Temperature to 195 Degrees F, and OP-lE, Containment Integrity Checklist, which.together ensure all necessary plant conditions are established and prerequisites are met for reactor startu The inspectors verified that the procedures included provisions as specified in TS Section 1.H for ensuring primary containment integrity exists before the plant enters operational modes which require containment integrit The inspectors also reviewed Unit 2 procedure PT-16;13, Containment Integrity -

LMC Valve Verific*ation, which provides assurance of primary containment isolation by verifying that all outside and inside vent and drain valves located between the CIVs are closed and capped as require For the penetrations reviewed in detail in paragraph 3, the inspectors verified that the procedure included all required valve In addition, a walkdown was conducted of 25 penetrations on both units to ensure that the vent and drain valves were in their required positio Containment Spray and Spray Additive System Review The Unit 2 containment spray and spray additive systems were selected for review to verify their integrity and operabilit The following TS required surveillances, which demonstrate the operability of pumps, valves, and flow requirements of the systems, were reviewed:

2-PT-1 PT-1 PT-1 PT-1 ~PT-17.4A Containment Spray System, dated 10/19/89 Containment Inside Recirculation Spray Pump Test, dated 10/25/89

.

.

Containment Outside Recirculation Spray Pumps, dated 10/25/89

,.

Containment Spray and Recirculation Spray Ch~ck r:

Valves, dated 10/22/86

\\

Containment Spray 1-CS-105 and 105 Check Valv~'

Test, dated 10/22/86 The inspectors verified that the procedures complied with applicable plant TS requirements, that adequate information and instruction were

~

provided, and that adequate acceptance criteria and 1 imi ts were specified.

Completed surveillance records since January 1988 for the above procedures were reviewed to verify that the survei 11 ances were performed at the required frequenc~es, test results met* acceptance criteria or limits, and appropriate sign-offs, test reviews, and test concurrences were performe The inspectors reviewed all work requests since January 1988 for the Unit 2 containment spray system pumps and motor operated valves. The inspectors verified that appropriate action was taken* to restore operability to these components following maintenanc A walkdown of portions of the containment spray and spray additive systems located outside containment was also conducte All valves were verified to be in their required position for proper system operatio Both trains were operationa In addition, all areas inspected were generally clean and free from debri No unacceptable conditions were identifie Within the areas inspected, no violations or deviations were identifie.

Complex Surveillance Testing (61701)

TS 3.l.c.7a and TS Table 4.1-2A, item 18 specifies test frequency and leak rate limits for Event V pressure isolation valves SI-79, SI-241, SI-82, SI-242, SI-85, and SI-243; The inspectors reviewed PT-18.11, SI Check Valve Leakage - Primary Coolant System Pressure Isolation Valves, whose purpose is to leak test check valves SI-79, SI-241, SI-82, SI-242, SI-85 and SI-243. The inspectors also reviewed performance records of PT 18.11 dating back to 1985 and work histories associated with the check valve Results of the review indicated that the following objectives were satisfactorily met:

Test Methods were acceptabl Individual in lieu of combined leakage rates were obtaine Leakage rates obtained at lower than normal operating pressure were normalized using correct conversion factor Acceptance criteria were in accordance with T Test frequencies were in accordance with T Check valves were leak tested following maintenanc The PT 18.11 review indicated several weaknesses in the licensee's method of maintaining the procedur The procedure was routinely deviated in lieu of permanently changed in order to install test equipment or se.t-----****

plint conditions, which the inspectors consider to be a weaknes The.*

licensee has recently implemented a new program that will require permanent procedure changes in lieu of routine deviations which should correct this weaknes *

The inspectors also identified a weakness in the Unit 2 procedure acceptance criter~a. The Unit 2 procedure allowed an option to leak test check valves at a test pressure of 150 psi or 300 ps However, the acceptance criteria for both test pressures were i dent i ca 1, wlii ch is incorrect, in that they should be separately normalized to the proper system pressur It appeared that the licensee initiated a procedural change to correct this; however, the Unit 1 procedure was mi stak.en ly changed to recognize the 150 psi test pressure option in 1 i eu of the Unit 2 proc~dur Review of the Unit 2 procedure indicated that the licensee did not utilize*

the 150 psi option; therefore, all ieak tests performed at 300 psi were vali The licensee initiated action to correct th~ Unit 2 procedur Within the areas inspected, no violations or deviations were identifie.

MDV and Relief Valve Program Review (92701) MOV Program Review On September 1, 1989, the licensee* implemented a new program to maintain MOV Station Administration Procedure, VPAP-0805, Motor Operated Valve Program, provided the requirements for the new progra The inspectors reviewed Revision 1 to VPAP-0805 and inspected the following areas in order to evalua.te the licensee's implementation of the new MDV program:

MDV failures, MDV failure reports, MDV coordinator, MDV engineer, Quality Assurance Department Audits, MDV team, MDV team training, Monthly MDV reports, MDV trending, and MDV diagnostic testin In the majority of these areas the inspectors concluded that the new MDV program was implemented and adhered to by station personn~ Th~

MDV program deve 1 oped by the 1 i cen see was comprehensiv \\A,s a *1(

result, all MDV failures were being aggressively pursued which was identified as a strength, as discussed in paragraph Another strength was the quality of the review that thoroughly explained all MDV failures, MDV failure rates, and associated problems and solution Several areas were identified where the new MDV program had not been fully implemente These areas are listed below and were not identified as weaknesses because th~ program is relatively new and will take time to complete the f~ll. im~lementation:

• VPAP-0805 requires that the MOV coordinator maintain a list of all qualified MOV team member The MOV coordinator was not maintaining this lis It took several days for the MOV coordinator to develop this list after the inspectors requested i VPAP-0805 requires that all MOV team member electricians be qualified to u~e 'MOV diagnostic test equipmen Of the twenty-three MDV team member electricians, two were qualified to use MDV diagnostic test equipment and four additional electricians were in trainin VPAP-0805 specifies that: (1) MDV team concept wi 11 a 11 ow a designated group of well trained electricians, mechanics, and engineers to assume ownership of MOVs, (2) personnel experience will develop from specific operating histories, and (3) by working and maintaining MOVs throughout the year, a level of experience based on expertise wi 11 develo After reviewing VPAP-0805, the inspectors had the impression that a select group of mechanics and electricians would be responsible for performing major MDV maintenanc The select group amounted to 46 mechan,cs and electrician The inspectors questioned how such a large group co.uld develop and maintain experience, since during outages the licensee planned to use contractors to work MOV This area was also identified-in a licensee Quality Assurance Audit recently performe Weaknesses were identified in the implementation of the MDV. program in the area of trainin The mechanics and electricians received special MDV training conducted by the licensee's training department, and they received additional MOV training from a private contracto VPAP-0805 states that in order to qualify as a MDV team member, the person must be tested and, to pass, have a grade of 70 or highe The inspectors reviewed the records of five MOV team member electricians and mechanic All five passed the licensee's MDV training course; however, two of the five scored below 70 on the contractor's MOV course. Additional review by the licensee revealed that 4 additional people failed the contractor 1 s course for a total of 6 of 46 MDV team member electricians and mechanics failing the contractor's MDV cours The li~ensee explained that the contractor's MDV course was a training enhancement and not a requirement for MDV team members to pass to be qualifie It appeared that no evaluation was performed in order to determine why the six people failed the contractor's MOV cours In addition there appeared to be confusion in what MOV team member training was require Originally the inspectors were informed that electricians and mechanics who did not attend the contractors MDV course were not considered MOV team members; however, only after discovering that _s;i.,x-people failed the contractors MDV course did the licensee state that this was only a training enhancement and was not require *

11. Safety and Relief Valve Program Review The licensee was in the process of developing an improved safety and relief valve program which was scheduled to be implemented by July 199 Station Administrative Procedure, VPAP-0804, Safety and Relief Valve Program, was recently approve The purpose of VPAP-0804 was to establish the requirements and guidelines for developing, implementing, and maintaining the safety and relief. valve progra The inspectors reviewed VPAP-0804 and recommended the following improvements:

Incorporation of ANSI/ASME OM-1-1981, Requirements For Inservice Performance Testing of Nuclear Power Pl ant Pressure Devices, into VPAP-0804 would be a significant program enhancemen OM-1-1981 contains the most recent and comprehensive set of requirements for testing safety and relief valves..

VPAP-0804 addressed test frequency intervals but did not specifically address IST requirements for test frequency intervals when failures occur. * These requirements were addressed by other licensee procedure However, because IST valves are required for safe shutdown and to. mitigate**

consequence of accidents, they are much more important than other valves and as such should be reflected by VPAP-080 VPAP-0804 re qui red that correlating data was re qui red when setpoint testing valves on a medium other than the normal system medium, but it did not provide guidelines for correlating this dat The l icerisee stated that invoking procedures would specify how to correlate dat Correlation of data can have a major effect on setpoint and, presently, there are no industry standards for correlation of dat It would be prudent to include correlation of data in VPAP-0804 in order to ensure a higher level of revie Within the areas inspected, no violations or deviations were identifie.

Inspector Followup (92701) Concerns Relating to Reactor Coolant Pump Thermal Barrier Lea~age to~

the Component Cooling Water System

t, f

\\:.,

Readings. on the CC radiation monitors (l-CC-RM-105, 106) are 'very high; consequently, the start of a significant primary to CC leak couid begin without the ability to identify the event until the alarm condition is reache *

On February 21, 1990, l-CC-RM-105, 106 were reading approximately lE+ This reading increased from SE+4 since December 11, 1989.

• On February 22, 1990, the inspector attended a meeting conducted by licensee personnel where methods were being considered for cleaning the CC system piping to reduce the background leve This cleaning was being proposed for the next scheduled outag The method being proposed evaluated modifying existing piping such that temporary ion exchangers could be adde The inspector a 1 so reviewed Type 1 Fina 1 Report, Changing RM-CC-015/106 to Off-Line Mani tors, dated March 10, 198 This report states, simply, that because of the detector 1s location and upon actuation of the check source, no positive upscale response is observed because the background activity is higher then the check sourc This results in unacceptably low radiation monitor sensitivit Several options are discussed in the report. One recommendations was to change the existing monitors to off-line monitors sine~.this would provide better immunity to ambient background radiatio An off~line monitor would be more flexible as to where it could be located, provides a higher level of sensitivity, and can be easily decontaminated without affecting reactor operatio As of the date of this inspection, however, no action has been taken on this repor The licensee suspects that a small RCP to CC leak exist The inspector reviewed a chart of CC total activity and boron concentra-tion from June 1989 to presen From June until the first week.in August 1989, the total activity level in the CC system was approximately SE-From the first week in August until the first week in September 1989, the total activity level increased to approximately lE-It has remained at this level sinc The inspector reviewed a chart of Unit 1 RCS verses CC CS-134 Activity from December 30, 1989, until February 8, 199 This chart delineates the CC CS-134 activity and also delineates a hypothesized 0.0236 gpm leak from the RCS to the CC syste The activity levels increased correspondingl With additional specialized sampling (AR-41 and CS-137), the licensee has hypothesized that there is a RCP thermal barrier leak into the CC system. Additional testing is being performed to verify which RCP thermal barrier is lealdn This testing involves making a containment entry and sampling each RCP thermal barrier CC discharge lin On December 21, 1989, the SEN issued a Station Deviation Trends for November 1989 Report to the SNSO This report summarized major trend items for the previous six month Additionally, the report evaluated radiation monitor failures for 198 The report also lists the following generic problems with radiation monitors:

'

Filter faults, flow faults, filter tears, Unconservative setpoints, Monitor will not source check, Alarm Setpoint problems, and Unavailability of monitors..

During a January 12, 1990, meeting, the SNSOC established a

. subcommittee to review issues associated with repetitive radiation monitoring system problem The following are the indicators that led to formation of this subcommittee:

Deviation Reports (SEN Report dated 12/21/89),

Repetitive failures, Check source problems, Long term compensatory actions for CC SW monitors, and High background levels on several monitors The subcommittee has been directed by SNSOC to review all available data sources, and issues are to include, but.not be limited to, the following:

Original design and analyses assumpti6ns, Actual operating practices, Individual monitor reliability history, and Compensatory actions now in place, or necessary recommendations..

The subcommittee's report to the SNSOC is due on February 27, 199 A memorandum dated February 13, 1990, from the Radiation Monitor System Engineer lists problems and recommended solutions associated with various radiation monitor The CC system radiation monitors (RM-CC-195, 106) are stated to have a high background (rising)

problem. Additionally, the problem states that they must be manually source checked.. The solutions/current work states that a task team is studying cleaning up the CC syste The inspector also investigated the lack of an a~to-isolation feature compounding the severity of a primary-to-CC lea The inspector reviewed drawing 11448-FM-072A, Flow/Valve Operating Numbers Diagram Component Cooling Water System, for Unit 1. This drawing delineates the CC system piping diagram to RCP 1-RC-P-lA but is typical for all RCPs for both unit Valve 1-CC-TV~120A auto-isolates the.CC piping after a 10 second delay when an increase in flow is sensed by flow transmitter l-CC-FT-107 This valve also fails open on loss of electrical power or on loss of containment instrument ai The inspector reviewed draft proposals to modify the CC system during the next outag These proposals include:

• .,

'..

Adding two safety-related, air operated, fail-closed valves downstream of each thermal barrier coole '

Adding redundant safety-related flow instrumentation to each cooling water loop downstream of the thermal barrier The instrumentation included adding high and low flow alarms, control switches,* and. indicator lights to the main control board Adding conduit, conduit supports, and cable to support the upgraded safety-related desig Adding pipe supports to ensure qualification of the p1p1ng from the thermal barrier cooler, up to and including the first support downstream of the flow instrumentatio The possibility of producing a primary-to-CC leak of sufficient pressure to rupture the CC piping, which would create an uncontrollable leak, was also reviewe The piping upstream of v*alve 1-CC-24 to downstream of valve l-CC-28, based on reviewing drawing 11448-FF1-072A (Sheet 2 of 7) is Schedule 160, ASTM GR 10 This piping 1 s rating is well in excess of primary system pressure. This piping was installed as part of the original desig The licensee could not determine if the piping was GR A or. B; however, the GR A pressure rating is 3466 psig and the GR B pressure rating i psi *

Changes to the CC system were previously inspected and are discussed in NRC Inspection Report Nos. 50-280/89-18 and 50-281/89-18, and 50-280/89-19 and 50~281/89-1 Concerns Related to RSHX Flow Conditions This concern deals with assuring that the RSHX flow would be sufficient to remove decay heat after an accident since the RSHX have not-been flow teste The RSHX were not flow tested. after installatio The inspector reviewed the following documents:

ME-0187 ME-2082 ME-166 Pressure Drop Due to Mar{ne Growth In The RSHX Inlet SW Piping Upstream of Valves SW-MOV-203 A, B, C, and D, R2, 4/26/89 Specification For Containment Recirulation Spray Coolers, Surry Power Station, Units 1 and 2, R2, 7/27/89 Intake Canal Inventory, R2, 5/2/89

14937.43 12846.11

Changes In Intake Canal Level Due To Installation Of New RSHXs, M-7, 7/27/88 Service Water Flow Rate To Recirculation Spray Coolers, 12/14/77 The documents delineate the design flows and specifications for the newly installed RSH The manufacturer's specifications for the RSHX state the rated flow to be 6140 gpm (for each RSHX) for a calculated pressure drop of 1.2 ps This rated flow is also used in calcula-

_tions for the canal inventor The UFSAR, Table 9.9-2, states that the re qui red fl ow to the RSHXs is 24,400 gpm ( 6100 gpm per heat exchanger).

Calculation 14937.43 states that the flow rates through the RSHXs is a function of the intake canal level and the discharge canal leve The flowrate Q is given as a constant multiplied by the square root of the height (H) of wate This is for two RSHX Based on the current minimum expected level in the intake canal during a design basis accident (17.2 feet), the following are the calculated flows through the RSHXs:

17,455 gpm (2 heat exchangers, with vacuum priming)

12,766 gpm (2 heat exchangers, without vacuum priming)

The calculated flow rates exceed the UFSAR requirement (12,200 gpm)

for two heat exchanger Discussions are currently in progress between the licensee and Regional Management regarding when confirmatory testing wi 11 occur or the basis for granting re 1 i ef from the testing IE Bulletin 85-03 Followup (92701)

(Closed) 50-280, 281/85-BU-03, TI 2515/73, Motor Operated Valve Common Mode Failure During Plant Transients Due to Improper Switch Setting The purpose of the bull et in was to require 1 i censees to deve 1 op and implement a program to ensure that switch settings for high pressure coolant injection and emergency feedwater systems* motor operated valves, subject to testing for operational readiness in accordance with 10 CFR 50.55 a (g), are properly set, selected, and maintaine The 1 i censee I s IE Bull et in 85-03 program was previously inspected as is discussed in NRC Inspection Report Nos. 50-280, 281/89-03, 89-10, * and 89-1 ** The inspectors reviewed the results of MOV differential pressure testing performed by the -license The licensee expanded the scope of IE Bulletin 85-03 to all safety-related valves; therefore, numerous differential pressure tests were performe In order to accomplish MOV differential pressure testing, all rising stem valves that were of the same manufacturer, size, type (gate or globe), and function were placed in a single grou The MDV in the group with the highest running load~

,,,

as determined by diagnostic testing, were differential pressure teste Diagnostic test equipment was utilized by the licensee to measure MDV parameters while performing differential pressure testin After accomplishing differential pressure testing, the licensee calculated the actual valve factor from the diagnostic test results. In many cases, the actual valve factor was higher than the valve factor used in the standard equation for calculating valve thrus The following are examples of where actual valve. factors were higher than the standard equation valve factors:

Valve Valve Valve Valve Equation Actual Valve N Manufacturer Size Ty~e Valve Factor Factor CH-2269B Aloyco 411 Gate

.3

.59 CH-1269A Aloyco 411 Gate

.3

.64 CH-1269B Aloyco 411 Gate

. 3

.41 SI-2862A Aloyco

. 811 Gate

.3

.56 SI-1863A Aloyco 811 Gate

.3

.48 SI-1863B Aloyco 811 Gate

.3

.53 CH-22898 Anchor Darling 211 Gate

.2

.36 SI-2867C-Anchor Darling 311 Gate

.2

.26 CH-1289B Anchor Darling 311 Gate

.2

.29 CH-1373 Anchor Darling 311 Gate

.2

.-31 SI-2842 Anchor Darling 411 Gate

.2

.30 SI-1842 Westinghouse 411 Gate

.3

.44 CH-1275C Velan 211 Globe.32 FW-251A Velan 311 Globe. 21 On July 20, 1989, MDV* SI-2885C failed to close against differentia pressur In order for the valve to operate against a differential pressure, the torque-switch setting was increased. SI-2885C is a two-inch globe valve manufactured by Vela Subsequent investigation by the licensee into why the torque-switch setting had to be increased revealed that the valves grouped with SI-2885C were all Velan two-inch globe valves, but the valves were also different model number Licensee correspondence with Velan revealed that Velan valves that had the same models, as SI-2885C, require much more thrust than the licensee 1 s standard equation provide As a ~esult of the SI-2885C failing to operate, the licensee will modify their differential pressure testing criteria to ensure valves are also grouped per model numbers..

The licensee 1 s effort in investigating valve SI-2885C failure to operate is an example of how MDV failures are being aggressively pursued and thoroughly analyzed. This was identified as a strength in the licensee 1s MDV progra Another strength that was identified involving the licensee 1 s MDV program was that the IE Bulletin 85-03 scope was expanded to include*

all safety-related MOV Balance of plant MOVs are also being incorporate As* a result of expanding the MDV program scope, the.

licensee has an opportunity to complete Generic Letter 89-10, Safety-Related Motor-Operated Valve Testing and Surveillance, action items ahead of the GL schedul f

Within the areas inspected no violations or deviations were identifie.

Action on Previous Inspection Findings (92701, 92702) (Closed) Temporary Instruction 50-280, 281/TI 2515/84, Verification of Compliance With Order For Modification of License:

Primary Coolant System Pressure Isolation (Event V) Valve The objectives of this Temporary Instruction are fully discussed in paragraph 5 of this Inspection Repor (Closed) Violation (50-280, 281/88-29-02):

Errors in Pressurizer Level and RCS Average Temperature Constants in RCS Leakage Test Procedures The licensee's response dated September 23, 1988, was considered acceptable by Region I The inspectors reviewed procedures 1/2-PT-10, which were revised March 30, 1989, and verified that they incorporated the appropriate temperature correction factor During review of periodic test 1/2-PT-10, Reactor Coolant Leakage, the inspector.identified the use of an incorrect constant for correcting changes in average RCS temperature and the licensee failed to correct for density differences between the pressurizer and volume control tank during RCS leakage measurement These errors were correcte (Closed) Violation (50-280, 281/88-30-01):

Failure to Perform Inservice Test as Required by ASME Code,Section XI, IWV-3511 This violation was issued for failure to test relief valve 2-RV-2209 at the required frequenc The inspectors reviewed the licensee's corrective action in response to this violation and considers it acceptabl (Closed) Violation (50-280, 281/89-10-01):

Failure to Promptly Correct MOV Deficiencies The licensee's response dated June 7, 1989, was considered accepted by Region IL Licensee MDV corrective actions as discussed in paragraphs 6.a and 8 of this Inspection Report were considered adequat (Closed) URI (50~280, 281/88-19-01):

Leakage Correction to Secondary System Prior to Type A Test without Quantifying Correction for Determination of the As Found Leak Rate

~,.

A previous inspection identified that Surry performs an air pressure test on the secondary side of the steam generators to identify and repair leak paths. This test is performed only as a prerequisite to the CILR Leakage that is repaired as a result of this test is not quantified for the pur~ose of adjusting the CILRT.results to *obtai the 11As-Found 11 condition of the containment. The licensee's accident analysis shows that 60 minutes following the design basis accident, the containment would return to its subatmospheric pressure conditio Additionally, the licensee assumes that the steam generators would remain at a higher pressure than containment during the first 60 minutes following the accident and before subatmospheric conditions are returne Therefore, any leakage following the accident would be from the secondary system into *the containmen The licensee plans to submit to the NRC, for review, their position that secondary systems are pressure sealed post accident for a sufficient time to allow the containment pressure to become subatmospheric. * This item is closed based on the licensee's tracking of this actio (Closed)

URI (50-280, 281/88-27-01):

• 10 CFR so.5g Review for RSHX R~placement Potential Inadequate This item was identified during an inspection conducted in July 1988 and documented in NRC Inspection' Report Nos. 50-280/88-27 and 50-281/88-27, which was issued August 17, 198 In September and November 1988, an SSFI was conducted on the service water and core spray system The inspection. results are documented in NRC Inspection Report Nos. 50-280/88-32 and 50-281/88-3 This inspec-tion identified problems ~ith the service water syste Aspects of this unresolved item were also reidentifie In order to resolve these problems, the licensee instituted a design basics documentation program which is reverifying the design basis documents for numerous safety-related system Design calculations were performed for the service water system and appropriate UFSAR and TS parameters were modified based on these calculation The corrective actions were verified during an inspection conducted in December 1989 and documented in NRC Inspection Report Nos. 50-280/89-3 and 50-281/89-3 (Closed) IFI (50-280, 281/87-30-04): Specification of Maximum Li~iting Valve Stroke Time The inspectors reviewed EWR 89-628 and 628A to verify that maximum limiting stroke times were not based on system requirements, but were based on actual valve data from the licensee's !ST trending pro~ra This method is also recognized in GL 89-0 The licensee's actions for this item were satisfactory.

• 19 (Closed) IFI (50-280,281/87-30-06):

Verification of Check Valve Exercising to the Open Positio The licensee's response to this item is consistent with GL 89-04~ i which full design accident flow is used to full stroke open check valve As documented in the licensee's 1ST program, CSD and RFD procedures will be revised during the upcoming RF Check valves which cannot be full stroke tested due to impracticability will be identified by the licensee and alternate testing such as disassembly will be considere The licensee's response to this item is satisfactor (Closed) I FI ( 50-280, 281/87-30-07)*:

Specification -of Containment Isolation Valve Leakage Rates A previous NRC inspection ~f the licensee's IST program identified that the licensee was not meeting the analysis of leak rates and corrective action requirements for 1 eak rate testing CI Vs in accordance with the 1980 ASME Code, paragraphs IWV-3426 and IWV-342 The licensee committed to revise their IST program to meet these requirement The inspectors reviewed the 1 i censee I s current IST program and periodic test PT-1 PT-16.4 controls the leak rate testing of CIV From this review, it was verified that the requirements of paragraphs IWV-3426 and IWV-3427 were being met: (Closed) IFI (50-280, 281/88-29-01):

Determine if Changes to the Startup Program Described in VEP-FRD-36A were Evaluated and Reported *During inspection of the physics testing for Surry Unit 1 Cycle 10 startup, an NRC inspector reviewed the licensee's Topical Report VEP-FRD-36A,

"Control Rod Reactivity Worth Determination by the Rod-Swap Technique," dated December-198 The inspector noted in this review that the startup test program did not contain all of the e 1 em.en ts described in the repor Specifically, there was no measurement of the isothermal_ temperature coefficient with the reference bank inserted and the licensee did not construct a flux map at hot zero power for the rodded condition. Although these changes did not have a significant affect*on the startup test program, the modifications should have been formally evaluated and documented..

The licensee submitted a supplement to the topical report by letter dated December 8, 198 In this letter, the licensee described the modifications from their original commitments and evaluated the impact the changes had on the startup test progra The inspectors agreed with the licensee that the modifications had no significant impact on the adequacy of the startup physics test program.

(Closed) !FI (50-280, 281/89-01-01):

Evaluate Corrective Action to Prevent Reoccurrence, Administrative Test Controls

'..

• --*~:_ __.

• 0, A

The inspectors reviewed the latest revision to Administrative Procedure SUADM-ENG-09, Test Control, dated 1/16/9 The procedure was revised to provide specific requirements which must be followed when writing and performing special test The controls listed in SUADM-ENG-09 provide adequate guidance -which, if adhered to, should preclude a loss of test contro The licensee's actions for this item were considered satisfactor.

(Closed)

!FI (50-280, 281/89-01-02):

Evaluate Agastat Relay Repeatibility The inspectors reviewed procedure ECM-1803-01, Time Delay Relay Disconnection, Replacement, and Connection, in which the licensee had added acceptance criteria for repeat accuracy and average delay tim Repeat accuracy acceptance criteria were unique to each Agastat series rela The licensee's actions for this item were satis-factor (Closed) Pa.rt 21 (50-280, 281/P21-89-18):

Limitorque Corporation Notification of Temperature on DC Motors and Failure of Melamine Torque switches due to Post Mold Shrinkag The licer:see did not have any Limtorque MOVs with DC motors; therefore, this portion of the Part 21 notification did not appl The licehsee has completed inspections of all safety-related MOVs and has replaced all melamine torque switches identifie.

Exit Interview The inspection scope and results were summarized on February 23, 1990, with those persons indicated in paragraph 1. The inspectors described the areas :inspected and discussed in detail the inspection results listed abov Proprietary information is not contained in this repor No dissenting comments were received from the license Licensee management was informed that the following items were closed:

TI 280,281/2515/73, paragiaph TI 280,281/2515/84, paragraph !EB 85-BU-03, paragraph VIO 280,281/88-29-02, paragraph VIO 280,281/88-30-0l, paragraph VIO 280,281/89-10-0l, paragraph URI 280,281/88-19-0l, paragraph URI 280,281/88-27-01, paragraph IF! 280,281/87-30-04, paragraph !FI 280,281/87-30-06, paragraph IF! 280,281/87-30-07, paragraph !FI 280,281/88-29-01, paragraph 9.

... **

IFI 280, 281/89-01-01, paragraph IFI 280, 281/89-01-02, paragraph Part 21, 280,281/P21 89-18, paragraph Per tel econ with B. Scanlan on 3/1/90, licensee management was informed that due to corrective actions taken during the inspection, a non-citable violation would not be identified regarding procedural deficiencies for Event V pressure isolation valve acceptance criteri.

Acronyms and Abbreviations AFW ADV Ar ASME cc CILRT CIV Cs CSD eves GPM HHSI I FI ISI IST LCD LLRT LMC LOCA MDV NRC PORV PRA PRT PSIG PSV PT QA RCP RCS Re RFD RHR RSHX RWST SEN SI SNSOC Auxiliary Feedwater Air Operated Valve Argon American Society of Mechanical Engineers Component Cooling Water Containment Integrated Leak Rate Test Containment Isolation Valve Cesium Cold Shutdown Chemical and Volume Control System Gallons Per Minute High Head Safety Injection Inspector Followup Item Inservice Inspection Inservice Testing Limiting Condition for Operation Local Leak Rate Test Leakage Monitoring Connections Losi of Coolant Accident Motor Operated Valve Nuclear Regulatory Commission Power Operated Relief Valve Probabilistic Risk Assessment Pressurizer Relief Tank Pounds per Square Inch, Gage Pressurizer Safety Valve Periodic Test Quality Assurance Reactor Coolant Pump Reactor Coolant System Revision Refueling Outage Residual Heat Removal Recirculation Spray Heat Exchangerer Refueling Water Storage Tank Safety Engineering Nuclear Safety Injection Surry Nuclear Station Operations Committee

..... **

SRV SSFI SW TS UFSAR URI

Safety Relief Valve Safety System Functional Inspection Service Water Technical Specifications Updated Fi~al Safety Analysis Report*

Unresolved Item

'- -*

--..