IR 05000280/1990038
| ML18153C500 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 01/04/1991 |
| From: | Jape F, Moore R, Matt Thomas NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18153C499 | List: |
| References | |
| 50-280-90-38, 50-281-90-38, NUDOCS 9101230054 | |
| Download: ML18153C500 (9) | |
Text
Report Nos.:
UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, ATLANTA, GEORGIA 30323 50-280/90-38 and 50-281/90-38 Licensee:
Virginia Electric and Power Company Glen Allen, VA 23060 Docket Nos.:
50-280 and 50-281 Facility Name:
Surry 1 and 2 License Nos.: DPR-32 and DPR-37 Inspection Conducted:
December 10-14, 1990 Inspectors~K m a:u:z-.:L-.
. Moore
.Thomas
pproved by:~~ 4 ~*
F. Jape, Chief Engineering Assessment S~
Engineering Branch Division of Reactor Safety SUMMARY Scope:
Dat~ Signed 1-..3-e,1 Date Signed I /Lt/ 7/
Date Signed This routine, unannounced inspection was conducted in the areas of design change and modifications, engineering technical support, and follow-up on previous inspection finding Results:
In the* areas inspected, violations or deviations were not identifie The DCPs reviewed by the inspectors appeared to be adequately implemente Licensee efforts to enhance the overall DCP process are positive indications of management's involvement in the DCP proces Efforts to reduce the EWR backlog have proven to be effectiv Restructuring of engineering resources and programs, began in 1989 ~ was generally complet Adequate product was available demonstrating the improved effectiveness of engineering technical support at Surr The system engineering and root cause analysis programs were well structured and implemente The high level of technical staff involvement in the deficiency reporting program was a strengt PDR ADOCK 05000280 G
..
- Persons Contacted Licensee Employees REPORT DETAILS
- R. Bilyeau, Licensing Engineer R. Boles, SE
- M. Bowling, Manager, Licensing and Programs W. Corbin, Supervisor, Project Engineering (Surry), Nuclear Engineering Services A. Fletcher, Assistant Superintendent, Site Engineering A. Hall, SE
- D. Hart, QA Supervisor
- M. Kansler, Plant Manager T. Kendzi a, Supervisor, SNS J. Laflam, SE
- T. Sowers, Superintendent, Site Engineering S. Semmes, SE Other 1 i censee emp 1 oyees contacted during thi-s inspection inc 1 uded craftsmen, engineers, technicians, and administrative personnel.
NRC Resident Inspectors
- W. Holland
- Attended exit interview Design, Design Changes and Modifications (37700)
Modifications The inspectors reviewed the modification packages 1 i sted be 1 ow to verify the adequacy of the 10 _CFR 50. 59 evaluations, verify that the design changes were prepared and being i nsta 11 ed in accordance with 1 i censee administrative procedures and applicable industry codes and standards, field changes were reviewed and approved in accordance with administrative controls, and post modification test requirements were specifie The following modifications were reviewe DCP 87-28, Component Cooling Heat Exchanger Replacement This DCP replaced CC heat exchangers 1-CC-E-lA and l-CC-E-1 The heat exchangers were replaced because of the high corrosion and erosion rate of the HX copper nickel tube The corrosion was caused by high levels of sulfate reducing bacteria which resulted in a
- pitting attack on the copper nickel base alloy To provide for better protection against erosion and corrosion, the new HXs have
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titanium tubes and titanium clad carbon steel tube sheet The o 1 d HXs were bui 1 t in accordance *with the requirements of ASME Section III, 1968 editio The new HXs were built in accordance with the requirements of ASME Section VIII, 1986 editio By letter to the NRC dated July 23, 1987, the 1 i censee requested re 1 i ef from certain ASME Code requirement The NRC granted the licensee's relief request in a letter dated February 25, 198 DCP 90-26, HX Service Water Piping Cleaning and Recoating, Surry Unit 1 This modification involved cleaning the affected SW piping of its existing coating; inspecting and repairing any piping corrosion
- pitting; and recoating the piping with a material that will improve system operating characteristic The old coating was a coal tar epox The new coating was a 100 percent solids epox The pipe cleaning involved a four-step process:
(1) Hydrolazing to remove gross buildup; (2) Detailed inspection of the cleaned piping to determine the location of local corrosion pitting; (3) Repair of the piping via a weld repair at the perforation or pit where excessive corrosion of the pipe wall was found; (4) Abrasively blast cleaning the system to remove all remaining corrosion products and coal tar epox The pipe coating process involved repairing corrosion pits that were determined not to require weld repairs by using the epoxy repair putty; and applying the coatin The other purpose of this DCP was to install pressure taps upstream of valves SW-MOV-104B,-104C,-105B,-105 These pressure taps are used to perform flow testing of the B and C RSHX The piping inspection, cleaning, and installation of the pressure taps for flow testing were done in response to NRC Generic Letter 89-13, Service Water System Problems Affecting Safety-Related Equipmen The GL recommended establishment of an SW piping surveillance progra EWR 90-330, Recirculation Spray Heat Exchanger Piping Inspection and Cleaning, Surry Unit 2 This modification involved inspecting and cleaning the Unit 2 RSHX supply pipin This inspection was determined to be necessary based on the results found during implementation of DCP 90-2 The purpose of the hydrolazing and mechanical cleaning was to rid the piping system of biofouling, remove any loose coal tar epoxy coating that was still attached to the piping, and remove any loose corrosion deposits from the piping wall *,;>
Unit 2 was operating at power when it was determined that the RSHX supply piping needed to be inspecte Unit 2 was shut down in order for this EWR to be implemente This issue is discussed in greater details in NRC Inspection Report 50-280, 281/90-36, and LER 90-14 dated November 21, 199 In the areas inspected, violations or deviations were not identifie Engineering Work Requests The inspectors reviewed EWR performance data and the licensee's efforts to reduce the backlog of unanswered EWR Licensee personnel stated that there was a backlog of approximately 600 unanswered EWRs approximately two years ag The backlog" of unanswered EWRs as of November 30, 1990, was 12 Licensee personnel stated that there were several factors which contributed to the reduction in the number of unanswered EWRs over the last two year First, both units were shut down and additional engineering support was provided during 1989 to reduce the backlo Other efforts included measures for prioritizing, screening, and using other systems available such as procurement reviews and the station management review tea All EWRs are reviewed by engineerin A number of the EWRs were procurement related issues which were handled through procurement document reviews by the station procurement engineering grou The management review team meets weekly to review EWRs which involve minor modifications and prioritizes the EWR Licensee personnel stated that their target is to reduce the number of backlog EWRs to an average of approximately 5 *
The inspectors reviewed performance data which showed that the number of unanswered EWRs has steadily declined over the last 12 months from 297 to the current number of 12 The inspectors consider the licensee's efforts to reduce the EWR backlog has been effective and is a positive example of management's involvement in providing quality and timely engineering support to the plan In the areas inspected, violations or deviations were not identifie FCRs and Design Change Process In addition to reviewing the DCPs the inspectors also held discussions with engineering personnel concerning the number of field changes in DCP Licensee personnel stated that they are evaluating causes for FCRs in an effort to develop corrective actions to-reduce the number of FCRs in DCP One of the efforts inc 1 udes imp 1 ement i ng a pi 1 ot program during the upcoming Unit 2 refue 1 i ng outage where the DCP imp 1 ement i ng procedures will be developed by the Nuclear Site Services/Construction department, which has responsibility for implementing DCP Currently, the DCP implementing procedures are written by engineerin *
Other efforts to improve the design change process include a DCP post implementation revie This review involves reviewing selected DCPs implemented during the current Unit 1 refueHng outage, focusing on engineering, procurement, construction, and six months of operations i appropriat *
Additionally, Nuclear Engineering Services has set a target for completing engineering work on DCPs and providing the DCPs to the station for SNSOC review at least 90 days prior to a scheduled refueling outage. This will help station personnel in outage planning and schedulin During review of the Unit 1 DCPs implemented during the current refueling outage, the inspectors noted that, a 1 though the target date was not met in a 11 instances, the li~ensee 1s efforts to improve in this area are considered positiv In the areas inspected, violations or deviations were not identifie.
Engineering Technical Support Overall, the Surry engineering and technical support capability has continued to mature since February 199 Restructuring of engineering resources and programs, began in 1989, was generally complet Adequate product was available demonstrating the improved effectiveness of engineering technical support at Surr The SE program was well structured and SEs were effectively accomplishing their support responsibilitie A comprehensive root cause analysis program was developed and implemented early in 199 The varying levels of root cause analysis accomplished in 1990 demonstrate the program was effectively implemented, and substantially improved performance was evident in this area since 198 The engineering organization has developed and recently implemented se 1 f assessment activities to monitor overall engineering performanc Onsite engineering services provided by the System Engineering and Station Nuclear Safety organizations were reviewe The SE organization provided direct technical support to the plant via interfaces in maintenance, operations, testing, and design change activities. The SNS group provided admi ni strati ve contra 1 for the p 1 ant pef ici ency reporting program (Deviation Reports) and performed the root cause analysis for those deficiencies and events requiring cause evaluation SE performance review encompassed interviews and review of documentation which demonstrated SE involvement in plant activitie The current SE program was out 1 i ned in SSES 3. 01, Contro 11 i ng Procedure for System Engineering, dated August 6, 199 This procedure replaced the SE program procedure which was in use when the NRC reviewed the program in February 1990 (NRC - Report No. 50-280, 281/90-20).
The current procedure was incorporated to parallel the North Anna SE program.*
SSES 3.01 outlined an improved SE program with respect to guidance on system trending and
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tracking and how this information was to be documented and communicated to managemen The specific structured requirements for system trending, tracking, and documentation were applied to Priority 1 system The trending, tracking, and documentation applied to Priority 2 and 3 systems was left to the discretion of the responsible S Engineering management categorized pl ant system_s as Priority 1 based on the fo 11 owing criteria:
Systems which have had significant problems that affect or could have affected reliable generation; Systems with poor maintenance histories which have been costly to maintain; Systems which have either essential safety or power generation functions; Systems which industry experience has determined to be unreliable or have had significant problems; Systems which cause significant chronic operational problem Surry implementation of SSES 3.01 was in the process of being scaled down to those aspects which management felt appropriate to the Surry statio Primarily, documentation of SE activities was to be reduced from that specified in the procedur Engineering management stated the SE manhours would be more effective in field work and real time technical support than
- documentation function The indicated program adjustment did not represent a reduction in SE plant support but a reduction in direct objective evidence demonstrating SE real time and proactive activitie There were 23 SEs with two supervisor Approximately 90 systems were assigned; 16 of these were categorized as Priority The documentation available demonstrated considerable proactive and real time involvement on Priority 1 system Discussions with four SEs demonstrated they were knowledgeable of system status on Priority 2 systems although trending functions were less develope The biweekly STAT procedure provided a mechanism for routine review activities to evaluate system status. This checklist was applied to Priority 1 systems and included review of work orders, pl ant logs, ongoing projects, survei 11 ance tests, DRS, CFEs, available trend information and performance of system walkdown The STAT procedures were begun in November 1990 and were performed for ~ 11 16 Priority 1 systems and three Priority 2 system The System Engineering *
Quarterly Report, Third Quarter 1990, provided a good overview of system activities and status for the Priority 1 system The STAT procedures and Quarterly Report provided a well structured methodology for monitoring and reporting system 11health.
In conclusion, program application to the Priority 1 systems was goo Program app 1 i cat ion to Priority 2 and 3 systems was 1 ess structured and defined; however, the SEs interviewed appeared knowledgeable of system status on these systems.
- System Engineering involvement in plant activities was eviden In January 1990, SEs coordinated with the *planning organization to identify work to be accomplished in the Unit 1 and 2 refueling outage An inplant memorandum dated June 1, 1990, from the Maintenance Engineering Supervisor to the site Engineering Manager, highlighted the effective interaction of SE and maintenance engineering in accomplishing component failure evaluation Other memoranda from SE demonstrated proactive SE activities, e.g., status of outstanding work request cards hanging in the EOG rooms, T.S. required heat trace circuits near failing criteri Review of a sample of DRs for the previous four-month period demonstrated plant deficiencies identified by SE The Design Base Document review process involved S Several draft DBDs were being reviewed by S Nine DBDs were scheduled to be issued in March 199 The SNS group was responsible for administration of the DR program and implementation of the root cause analysis program at Surr The staff of approximately 15 included STAs and technical personnel accomplishing external plant operating experience reviews and root cause analysi Deviation Reports received root cause evaluations of varying depth in accordance with safety significance of the identified issues. A review of routine DRs demonstrated the lower. level of cause analysis.. The level of evaluation for the routine DRs reviewed was appropriat DRs with identified or potential safety significance received a more involved Cause Determination Evaluatio _The following CDEs were reviewed:
Sl-90-637 Sl-90-856 Sl-90-740 Sl-90-014 S2-90-0079 Sl-90-0138 Sl-90-1405 Sl-90-1100 The cause evaluations accomplished for these CDEs were appropriate for the significance of the issue identifie Root Cause Evaluations were performed for those events or id~ntified issues with significant impact on plant operations, i.e., reactor trips, major component failur These evaluations were accomplished by a team of technical and discipline speci a 1 i sts and encompassed a comprehehs i ve information gathering and analysis proces Approximately seven RCEs were initiated in 199 The RCEs reviewed were generally adequate and appropriate to the significance of the identified issu RCE 90-001 which evaluated the installation of an inappropriate Steam Generator level transmitter was comprehensive and the recommendations appropriately addressed the identified cause RCE 90-008 addressed a failed Unit 2 MFR The conclusion that dirt and foreign material in the positioner air resulted in failure was reasonable; however, the corrective action to periodically replace the inlet filter orifice appeared minima The determined cause included unclean or wet instrument air but corrective action did not include evaluation or monitoring of instrument air quality in relation to the manufacturer's recommendation for these valve The majority of the RCEs were awaiting a management review and approva Corrective actions initiated from RCEs were entered into a commitment tracking syste *
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. 7 Overall the administrative control and trending of DRs was adequat Approximately 2,400 DRs were initiated* in 1990 with approximately 57 percent close Due to the upfront operability and reportability reviews performed, there was no apparent safety significance associated with the backlog of DR In addition to administrative control, approximately 35 percent of DRs were assigned to eDgineering for resolutio The high level of involvement in the DR process by the technical staff is a
- strength. Licensee QA Audit.S90-14 of the DR program identified DRs which did not receive required CD£ SNS responsiveness and corrective action for this finding was timely and effectiv DRs were trended quarterl The Station Deviation Trend Report, May-October 1990, provided an overview of DR-related trends and individual cause trend A trend report was generated for the Unit 1 refueling outage which listed outage testing failures and associated corrective actions initiate Engineering self-assessment activity included periodic self-assessment of Engineering functions and programs, and a 11customer 11 surve Procedure SSES 1.09, Engineering Self-assessment Program, October 1, 1990, implemented the goals of the Engineer Quality Plan to initiate critical self-assessment activitie The program established specific performance indicators reflective of engineering functions, i.e., EWR backlog, DR response, QA findings, test deficiencies, etc *. The November 1990 monthly*
engineering assessment demonstrated trends related to these indicator Although the report contains tables and graphs representing these indicators there was no interpretation which translated the data into a meaningful assessment statement regarding engineering performance for the mont It was notable that the indicators were defined by a specific range of acceptance in conjunction with a Performance Annunicator Panel methodology being developed at Surry as part of a plant-wide self-assessment progra An opinion survey was distributed to the plant to evaluate site engineering performance in the areas of professionalism, performance, and communicatio The survey was initiated in October 199 On a scale of 1 (poor) to 10 (good), the survey demonstrated an overall opinion of approximately 7 in each are The survey results reflected a general respect and reliability for SE and other site engineering service The self-assessment program of SSES 1. 09 and the survey demonstrated engineering actions to monitor and improve engineering technical suppor.
Action on Previous Inspection Findings (92701, 92702) (Closed) Inspector Follow-up Item 280, 281/88-32-18:
Wiring Discrepancies Between Drawings and As-built Conditions in the Main Control Boar In response to this deficiency, the licensee performed walkdowns of the main control board Discrepancies identified resulted in the initiation of 83 Drawing Change Requests which were complete Additional tagging and wiring discrepancies were identified on EWR 89-35 EWR 89-356 has not been completed; it has been entered into the scheduling process and continues to be tracked on the
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1 i censee I s commitment tracking progra Licensee action on this issue was adequate for closur (Closed) Inspector Follow-up Item 280, 281/90-08-0l, Setpoint Progra I neons i stenci e This item addressed inconsistencies between upper tier and lower tier program document Primarily, corporate Electrical Engineering Standard, EEN-0211, specified a structure and scope for the Setpoint Cont ro 1 Program that was not imp 1 emented by the Surry stat ion progra Discussion with engineering personnel demonstrated aspects of EEN-0211 were not applicable to the Surry statio Corrective action was to delete EEN-0211 from the upper tier references for the setpoint progra This corrective action was complete.
Exit Interview The inspection scope and results were summarized on December 14, 1990, with those persons indicated in paragraph The inspectors described the areas inspected and discussed in detail the inspection result Proprietary information is not contained in this repor Dissenting comments were not received from the license.
Acronyms and Initialisms ASME cc COE
. CF DCP DR EOG EWR FCR HX LER MFRV MOV RSHX QA SE SNSOC STA STAT SW TS American Society of Mechanical Engineers Component Cooling (System)
Cause Determination Evaluation Component Failure Evaluation Design Change Package Deviation Report (deficiency reporting program)
Emergency Diesel Generator Engineering Work Request Field Change Request Heat Exchanger Licensee Event-Report Main Feedwater Regulating Valve Motor Operated Valve Recirculation Spray Heat Exchanger Quality Assurance System Engineer (System Engineering)
Station Nuclear Safety and Operating Committee Shift Technical Advisor System Trending and Tracking (Procedure)
Service Water Technical Specification