IR 05000280/1991006

Insp Repts 50-280/91-06 & 50-281/91-06 on 910224-0330. Violations Noted.Major Areas Inspected:Plant Operations, Maint,Surveillance,Procedures,Esf Sys Walkdown & Review of Licensee Self Assessment Capabilities

ML20128Q588
Person / Time
Site:	Surry
Issue date:	04/12/1991
From:	Fredrickson P, Holland W, Tingen S, York J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20128Q515	List: IR 05000280/1991006 ML20128Q510 ML20128Q542
References
50-280-91-06, 50-280-91-6, 50-281-91-06, 50-281-91-6, NUDOCS 9610210101
Download: ML20128Q588 (15)

Text

. - - - __ . -- ._ . . - . . _ .

. .

UNITED STATES

[gs,a E84 o

• , NUCLEAR REGULATORY COMMISSION

.l' -

$ REGION li j

'"

[ 101 MARIETTA STREET, N h

, ATLANT A, GEORGI A 30323 f l 4..v ...

j Report Nos.: 50-280/91-06 and 50-281/91-06 Licensee: Virginia Electric and Power Company l 5000 Dominion Boulevard Glen Allen, VA 23060 Docket Nos.: 50-280 and 50-281 License _Nos.: DPR-52 and DPR-37 Facility Name: Surry 1 and 2 ~

Inspection Conducted: February 24 through March 30, 1991 Inspectors: M,[g/ jf v [ M9, W. E".gallena, Sehior Resident Inspector Pate Signed

$$d/ W* Y 9s J. W. Tefpsident Inspector Date Signed h W/ &s/ Y /Cr /

5. G. Tintfepsident Inspector Itate Tigned Approved by: e _

4 // ') /9 /

P. E. Fredrickson, Section Chief Date Sitned Division of Reactor Projects SUMMARY Scope:

This routine resident inspection was conducted on site in the areas of plant operations, plant maintenance, plant surveillance, plant procedures, ESF system walkdown, and review of licensee self-assessment capabilities. During the perfonnance of this inspection, the resident inspectors conducted review of the licensee's backshift or weekend operations on February 24, 26, March 1, 3, 6, 15, 19, 21, 22, 24, and 3 Results:

In the safety assessment / quality verification functional area, a violation was identified for failure to take adequate corrective action for untimely performances of periodic tests (paragraph 5).

A review of the. status of the Procedure Upgrade Program for Administrative Procedures indicated that the program inplementation appears to be progressing in accordance with the current schedule and is providing for a better understanding of administrative requirements. However, the licensee's Quality Assurance organization determined that new procedures were being implemented at a pace which did not allow for adequate training prior to implementation. The 9610210101 910412

~

PDR ADOCK 05000280 G PDR

--. - --

.

licensee was addressing these issues with additional training during this perio A review of the status of implementation of the Technical Procedures Upgrade Program indicated that the program would provide for better technical procedures with accurate, verifiable result The implementation schedule was progressing satisfactorily in all departments with the exception of the maintenance instrumentation and control activity. The inspectors consider that implementation of this program in the instrumentation and control area needs continuing management and supervisory attention and involvement. Also, additional review of the current procedures in the instrument and control area is warranted (paragraph 7).

In the safety assessment / quality verification functional area, the failure to update the Updated Final Safety Analysis Report was identified as NCV 50-280, 281/91-06-02 (paragraph 8).

In the safety assessment / quality verification functional area, the use of the Local Performance Annumciator Panels for self-assessment was identified as a strength (paragraph 8).

. ,

_

REPORT DETAILS Persons Contacted Licensee Employees l R. Allen, Supervisor, Shift Operations

• W. Benthall, Supervisor, Licensing R. Bilyeu, Licensing Engineer

.

!

• D. Christian, Assistant Station Manager, Operations and Maintenance

• J. Downs, Superintendent, Outage and Planning D. Erickson, Superintendent, Radiological Protection

• R. Gwaltney, Superintendent, Maintenance

.

M. Kansler, Station Manager T. Kendzia, Supervisor, Safety Engineering

• J. McCarthy, Superintendent, Operations

• A. Price, Assistant Station Manager, Nuclear Safety and Licensing l

• E. Smith, Site Quality Assurance Manager

• T. Sowers, Superintendent, Station Engineering NRC Personnel W. Holland, Senior Resident Inspector

• S. Tingen, Resident Inspector

• J. York, Resident Inspector

• Attended exit intervie Other licensee employees contacted included control room operators, shift technical advisors, shift supervisors and other plant personne Acronyms and initialisms used throughout this report are listed in the last paragrap . Plant Status Unit 1 began the reporting period in power operatio The unit operated at power for the duration of the inspection perio Unit 2 began the reporting period in power operation. The unit operated at 90% power until March 3, when the unit began a normal coastdown in power. The unit commenced a normal shutdown from 73% power on March 29 to conduct a scheduled refueling / maintenance outage. The unit was at an intermediate shutdown condition when the inspection period ende . Operational Safety Verification (71707 & 42700) Daily Inspections I l

i j

_.

, ,

~ . _

The inspectors conducted daily inspections in the following areas:

control room staffing, access, and operator behavior; operator adherence to approved procedures, TS, and LCOs; examination of panels containing instrumentation and other reactor protection system elements to determine that required channels are operable; and review of control room operator logs, operating orders, plant deviation reports, tagout logs, temporary modification logs, and tags on components to verify compliance with approved procedures. The inspectors also routinely accompanied station management on plant tours performed being and observed the personne by plant effectiveness of their influence on activities Weekly Inspections The inspectors conducted weekly inspections in the following areas:

operability verification of selected ESF systems by valve alignment, breaker positions, condition of equipment or component, and actuation orof operability instrumentation and support items essential to system performanc Plant tours were conducted which included observation and of general plant / equipment conditions, fire protection preventative measures, control of activities in progress, radiation protection controls, physical security controls, missile hazards, and plant housekeeping conditions / cleanlines The inspectors routinely noted piping to ensure increases in the temperature of the AFW pump discharge monitored and evaluated by the lia nsee. temperature were being properly Biweekly inspections The inspectors conducted biweekly inspections in the following areas:

verification review and walkdown of safety-related tagouts in effect; review of sampling program (e.g. , primary and secondary coolant samples, boric acid tank samples, plant liquid and gaseous samples);

observation of control room shift turnover; review of implementation of the plant problem identification system; verification of selected portions of containment isolation lineups; and verification that notices to workers are posted as required by 10CFR1 Other Inspection Activities inspections battery roomsincluded areas in the Units 1 and 2 cable vaults, vital diesel genera, tor rooms, steam safeguards areas, emergency switchgear rooms control room, auxiliary building, cable penetration areas, independent spent fuel storage facility, low level intake structure, and the safeguards valve pit and pump pit area RCS leak rates were reviewed to ensure that detected or suspected leakage from the system was recorded, investigated, and evaluated; and that appropriate actions were taken, if required. The inspectors routinely independently calculated RCS leak rates using the NRC Independent Measurements Leak Rate Program (RCSLK9). On a regular basis, RWPs were reviewed, and specific work activities were

_ _ _ ___ _ ..__ _ __ _ _ __ _ -- . . _ . _ _ . . _ _ _ _ _ .

. ,

l i

,

-

e i

monitored to assure they were being conducted per the RWP Selected

radiation protection instruments were periodically checked, and equipment operability and calibration frequency were verified.

, During this inspection period, a problem was identified involving improper system foroperation Unit 1. of a pressure switch in the containment spray This pressure switch provided a close signal to one of two parallel caustic (Na0H) supply valves from the chemical addition tank to the suction of the B CS pump. The close signal i would be generated in the event the CS pump failed to develop

. adequate discharge pressure during accident condition Testing i results determined that the pressure switch affecting the parallel

,

valve for the B train was also inoperable. Unit 1 B train CS system

'

was declared inoperable and a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> LCO was entered. An engineering evaluation of this condition was conducted and it was concluded during accidentthat closure condition of the caustic supply valves was not required

A JC0 was prepared with an attached safety evaluation to allow for verifying open the associated CS

'

valves and removing power from the sam These actions were  !

accomplished LC0 was exite within the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> action a statement timeframe and the 1 Further testing determined that the Unit 1 A train and the Unit 2 A and B train pressure switches were operabl "

The inspectors were advised of the above condition after licensee identification report of the problem during SNSOC review of a deviation for closecu The deviation report, which was written in

-

November 1990, was reviewed prior to Unit I restart from refueling and was determined not to be a startup issue at that time. The inspectors monitored licensee actions after identification of the 4 problem including licensee discussions with NRC management on

immediate actions, entry _ and exit into the LCO condition, safety actions in review committee of the JC0 and safety evaluation, and operator implementation of JC0 requirements. The licensee conducted a root cause evaluation as to why this issue was not 2 identified as reoutring resolution prior to startup. The inspectors

-

reviewed the preliminary conclusions of the evaluation with the

licensee and noted the following:

'

_ -

Switch calibrations were performed during refueling outages;

however, preventative maintenance actions were not adequately addressed in a progra The deviation report was not included in the startup assessment

'

review sam list due to the identification of a work order on the however,The work order was discussed during startup assessment;

the work order was identified as a preventative maintenance work order and did not receive proper attention due to this statu CS train A remained operable during the timeframe from unit restart until identification and correction of the deficiency.

. - . .- . . - - - - - . . . .. . ..

,,

, ,

i

Based on the above information, the inspector concluded that the licensee was focusing on event causes in a proper manner and after completion management, of the evaluation and presentation of findings to appropriate corrective actions should be implemente i The licensee pressure switc will issue a LER on the failure o' the CS pump discharge l

inspector closeout Corrective of this LER.actions will be durther evaluated upon Physical Security Program Inspections In the course of monthly activities, the inspectors included a review of the licensee's physical security program. The performance of various daily shifts of to activities theinclude:

security force was observed in the conduct of protected and vital areas access controls; issuance and searching of personnel, packages and vehicles; badge compensatory post retrieval; escorting of visitors; and patrols and No discrepancies were note Within the areas inspected, no violations were identifie .

Maintenance Inspections (62703 & 42700)

During the reporting period, the inspectors reviewed maintenance activities to assure compliance with the appropriate procedure )

The following maintenance activity was reviewed: Motor Driven AFW Pump 1-FW-P-38 1 On March 4 the inspectors witnessed the performance of periodic test 1-PT-15.1 February 14, Motor 1991. Driven Auxiliary Feedwater Pump 1-FW-P-3B, dated During this test, the flow showed an increase on the recirculation valve position flow instrumentation without any adjustmer.t of the revealed flang a leak at the interface between a thread 3800108756The periodic was issue test was discontinued and work request n test was performed again on March 6.The craft tightened the fitting and period pump, the flow Again after a short run on the adjustmen indication began to increase without any valve interfac Once again leakage was detected at the same fitting An analysis of the fitting showed a circumferential crack and distortion of the threads, probably caused by overtightening. The system engineer stated that the fitting was a schedule 40 and in the future would be replaced with a thicker schedule 80 fitting. This flow for testing instrumentation purposes. On is March on the7recirculation line and is only used performed. No discrepancies were, identified.the periodic test was successfully

__ _ _ _ _ __ _ -_ _ _ _ . _ _ . . - _ . . _ _ _ _ .

.

5 Pressure Switch 1-CS-PS-103A Calibration On March 6, the inspectors witnessed the calibration of pressure switch 1-CS-PS-103A. The purpose of this pressure switch is to detect the discharge pressure of containment spray pump 1-CS-P-18, and on low pressure provide an automatic closure signal to the containment spray system CAT suction valve 1-CS-MOV-103 The operation of the pressure switch, suction valve, and spray pump is discussed in more detail in paragraph 3.d. EWO 3800108879 and procedure IMP-C-G-35, Pressure Switch Checkout, dated November 27, 1988, were used to accomplish this maintenance. The inspectors attended the prejob brief, walked down the job with the technicians, observed portions of the pressure switch calibration, reviewed the procedure at the job site, reviewed the completed work package, and reviewed the applicable portions of procedure 1-DRP-005, Instrument Setpoints, dated July 24, 1990. While attempting to obtain the as-found setpoint, the pressure switch did net actuate. After the technician agitated the pressure switch, it properly actuated at the correct setpoin operate, it was determined Because the pressure switch did not initially to be inoperable. The resulting corrective action is discussed in paragraph 3.d. With the exception of the pressure switch setpoints contained in 1-DRP-005, no deficiencies were note Procedure IMP-C-G-35 is a generic procedure that provides instructions to calibrate pressure switches throughout the plan The procedure does not provide pressure switch setpoint The technicians are required to obtain pressure switch setpoints preferably from the setpoint document, or if not in the setpoint document, Review of obtain the setpoints from the instrument's history folde the setpoint documents,1-DRP-005 amd 2-DRP-005, and instrument history folders for the Units 1 and 2 containment spray pumps' pressure switches, revealed that conflicting isformation was provide The Unit 1 setpoint document specified a 60 psig setpoint while the Unit 2 setpoint document specified a 70 psig setpoint. The instruments' history folders specified both 60 and 70 psig setpoint The Unit 2 setpoint document provided a pressure switch span while tne Unit 1 setpoint document did not provide a span. The pressure switch's toleranc span is required in order to calculate the setpoint Since the function of the containment spray pump discharge pressure switches was eliminated as discussed in paragraph 3.d. the conflicting information specified in the setpoint documents and instrument history folders are not a safety concern. However, the inspectors are concerned that the setpoint documents and instrument history folders may contain other discrepancies. This issue will be further reviewed during subsequent inspection periods, Overview of the Maintenance Trending and CFE Programs Implementation

.

_ _ _ _ _ _ _ _ . __ .

.

i

,

In January 1990, the licensee implemented maintenance trending and CFE programs in order to enhance maintenance effectivenes j VPAP-1501, Station Deviation Reports, and VPAP-1601, Corrective

Corrective Action, establish the requirements for the program The inspectors reviewed VPAP-1501, VPAP-1601, results of QA audits S90-07, dated April 27, 1990, and S90-14, dated November 7,1990, Station Deviation Trend Report For October - December, 1990, and 1 discussed the programs with the cognizant licensing and maintenance supervisor i The inspectors concluded that the programs have been adequately I implemented, however new program type problems have been experience The QA audits identified that issuance of trending reports was not timely and that there was a large backlog of CDEs. Discussion with

.

l l the cognizant maintenance supervisor indicated that there was also a i'

large backlog of CFEs. The inspectors concluded that the licensee )

was aggressively pursuing these new program problems. VPAP-1501 and

- VPAP-1601 have been revised to streamline program processes, CDE backlog numbers have been reduced, and maintenance engineering is in theCFE of process of adding two more engineers to help reduce the backlog Within the areas inspected, no violations were identifie . Surveillance Inspections (61726 & 42700)

During the reporting period, the inspectors reviewed various surveillance activities follows: to assure compliance with the appropriate procedures as

-

Test prerequisites were me l Tests'were performed in accordance with approved procedure Test procedures appeared to perform their intended functio Adequate coordination existed among personnel involved in the tes Test data was properly collected and recorde !

The following surveillances were either reviewed or observed: Motor Driven Auxiliary Feedwater Pump Testing On March 4 and 6, the inspectors witnessed the performance of periodic -test 1-PT-15.1B, Motor Driven Auxiliary Feedwater Pump 1-FW-P-3B, dated February 14, 199 The purpose of this test is to demonstrate operability of 1-FW-P-3B. Both of the tests were discontinued because a leak caused an inaccurate flow indication (see

, .

_

i par. 4.a).

The inspectors noted that when a periodic test is discontinued, the permanent the partially completed documentation is made a part of record On March 7, af ter repair of the leak, the periodic test was successfully complete The results of the test were reviewed by the inspectors and no discrepancies were note b.

>

Review of Surveillance Testing i

During the inspection period, the licensee identified two instances where On Marchpts7,were not perfonned within the TS required time interval DR S-91-0280 2-PT-18.61, was issued as a result of not performing Pressurizer Block Valve Stroke Test, within the TS quarterly time interval. On March 11, DR S-91-0286 was issued as a result the TSofweekly not performing PT 53.3, High Energy Line Inspection, within time interva The inspectors reviewed the 1990 and 1991 DRs that have been issued against intervals.pts which were not performed within their scheduled time Including the DRs discussed in the previous paragraph, there were nine DRs issued as a result of not performing pts within ,

their scheduled time intervals. Three of the nine DRs identified the l i

failure to perform surveillance testing within TS specified time interval The licensee's action be assignedadministrative to DR procedures require that corrective '

The inspectors reviewed the corrective j

actions assigned to the 1990 and 1991 DRs issued prior to March 1991, -

documenting pts that were not performed within their scheduled date DR 2-90-0219, dated March 28, 1990, identified that a .new procedure, 2-PT-18.8A, Charging Pump Component Cooling Performance, was issued but not performed during the scheduled time interval. Corrective action for this DR involved revising administrative procedures to require that the Test Group, which is the group responsible for identifying when pts are required to be performed, be notified when new pts were issued and schedule the PT accordingl DR 1-90-0875, dated June 28, 1990, Operability, was not performed within its scheduled date NCV identifie 280/90-26-01 P was issued as a result of the failure to perform this Also, the licensee reported this problem in LER 280/90-0 Corrective action involved issuance of PT tracking schedules that would identify when quarterly or longer surveillances approached the end of tneir grace period. Also, enhancement of adminstrative procedures identificationwas accomplished of overdue pts. to highlight the process for timely Corrective actions for the remaining i

'

1990 and 1991 DRs focused on the particular PT that was not performed during for thatthe PT.scheduled dates and on how to prevent it from reoccurring The inspectors discussed the TS surveillances that were missed in March 1991, with licensee personnel. The inspectors concluded that 2-PT-18.61 was not accomplished when required for two reason . . _ - -- - - - - _ _ _ _ .

.

%.

Corrective action taken in March 1990, to ensure that new pts are

properly scheduled for performance was not adequate because one year later 2-PT-18.61, a new PT, was issued without being properly

,

' '

scheduled for performanc The second reason this PT was not performed is the tracking process for pts that are approaching the end of their grace period is ineffective. After the performance of a

1 PT, it takes approximately two to three weeks for the Test Group to

! receive the completed PT and update records that the PT was completed. During this two to three week period, pts are listed on PT tracking lists as not completed. As a result, the PT tracking lists are lengthy and personnel do not adea'Jately review this list because user perception is that many of the pts listed were performed .

within the required timeframe; however, records were not updated in a l timely manner by the Test Group. The inspectors concluded that corrective action taken in June 1990, to provide identification that

a PT was approaching its grace period end date was not effectively implemented.

- The inspectors also concluded that PT-53.3 was not

performed when required because corrective actions for previously missed pts did not provide adequate checks and balances to assure

.

performance of all pts.

The inspectors consider that the licensee's corrective actions taken in response to past problems associated with untimeiy performance of pts to be inadequate. Corrective actions involving identification of new pts, notification that pts were approaching the end of their grace two ptsperiod, in March and highlighting overdue pts did not prevent missing 199 l

10CFR50, Appendix B, Criterion XVI states, in I part, that measures shall be established to assure that conditions

,

adverse to quality, such as deficiencies, deviations, and nonconformances be promptly identified and corrected. Failure to take adequate corrective action for missed pts is identified as Violation 280,281/91-06-0 Within the areas inspected, one violation was identifie . Plant Procedures (42700)

During this inspection period, the inspectors continued with a review of the licensee's Procedure Upgrade Program. Discussions were held with corporate progra and stction management and supervision responsible for the Addi t'. .,nal discussions and reviews were conducted with supervision and personnel responsible for implementation of the progra The following conclusions were determined during these discussion The Procedure Upgrade Program for Administrative Procedures at the Surry Power inspection Station was approximately 60% completed when reviewed during this perio December, 199 The project completion date for this program is During the last 6 months, the licensee's QA organization determined that new procedures were being implemented at a pace which did not allow for adequate training prior to implementatio The implementation schedule was reviewed and adjusted to address this concer _

. . l

~

l

,

The program implementation appears to be progressing in accordance with the current schedule and administrative requirements.is providing for a better understanding of which provided an overall ev6The inspectors reviewed a licensee techn 1uation of Surry's Technical Procedures upgrade Program and noted that the I&C area of the maintenance department had completed the fewest upgrade reviews during 1990. Based on this progress, procedurethe inspectors writers reviewed group I&C the method of procedure upgrade with the section.

. noted the following: During this review, the inspectors

-

.

The procedure technical upgrade program will provide better, more uniform procedures.

!

the full verification and validation process.However, very The inspector few proced was informed that some procedures had been provided to the I&C shop for verification; however, shop progress in this area was minima The process for procedure upgrade requires that setpoint data be identified and verified as being accurate.

4 in many cases did not provide assurance of validity.Information This condition in the sho

~-

required detailed records searches to assure that data was accurat This effort was being accomplished by the procedure writers who requested eagineering support when necessar The inspectors noted

that current procedures which were being used for loop calibration or other functional checks contained several PARS and that setpoint data

-

information was based in many cases on the shop instrument history file The inspectors also questioned procedure writers about available information to upgrade procedures and concluded that some information needed additional clarification or revisio Setpoint document discrepancies are also discussed in paragraph Based on these discussions and reviews, the inspectors concluded that

!

implementation with of the TPUP accurate, verifiable would provide for better technical procedures result The implementation schedule was

-

progressingI&C maintenance satisfactorily sho in all departments with the exception of the

The inspectors consider that implementation of this attention and involvement. program in the I&C area needs additional managem of the current procedures in the I&C area is warranted.They further conclu i

This effort will continue during the next inspection period in conjunction with the I&C maintenance document isste identified in paragraph Within the areas inspected, no violations or deviations were identifie . ESF System Walkdown (71710)

t i

. .

During this inspection period, the inspectors performed a detailed walkdown of the accessible portions of the ESF systems listed below. The inspection included, but was not limited to verification that housekeeping was adequate, valves did not exhibit gross packing leakage or improper labeling, the plant and valves appeared to be in correct positions as required by condition Unit 1 - Low Head Safety injection System The inspectors specifically walked down the accessible major flowpaths for the low head SI system and noted all components which had outstanding work requests identifie The inspectors then reviewed the status of each identified wor work request and associated work order to determine status of The only discrepancy noted was a lack of attention on the part of the craft in removing the local work request tag when work was complete No operational concerns were identifie Safety-Related HVAC System The inspectors walked down certain portionc of the flowpath for the safety-related HVAC with the systems e?gineer. Also, four individual sup; orts / restraints were inspected tr the drawing requirements for configuration, welding, bolting, and dimensions. No operational concerns were identified. The inspectors reviewed Inspection Report 50-280, 281/91-03, which was a followup on the maintenance team inspection, and noted that this report indicated that there were 450 open work orders on the HVAC system at the time of the inspection. The inspectors will continue to follow the licensee's efforts to reduce this large backlog on the HVAC syste Within the areas inspected, no violations were identifie .

Evaluation of Licensee Self-assessment Capability (40500)

Self-Assessment Annunciator Panels The licensee has initiated a self-assessment system that uses annunciator windows (panels) which display various colors to indicate the self-assessment performance) evaluation of various area This performance annun(ciator panel is divided into three performan personnel performance, equipment performance, and program performanc Each performance area is represented by panels, e.g. personnel performance has operation, maintenance, radiological protection, engineering et The panels for the equipment performance area has plant equipment availability, thermal performance, ESF actuations, reactor trips et Each of these panels (windows) has a number of sub-windows or panels that are evaluated on the station level in order to determine the overall evaluation of the pane _

_ - _ . _

_ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ . _ _ - _ _ __ ___________. _ _ . _

1 . .

I

!

,

'

A committee composed of an Assistant Station Manager, Station Quality Manager, Manager of the Corporate Nuclear Safety Group, and Manager of

,

the Industry Operating Events Reporting Group meet quarterly to evaluate

the individual windows and select the appropriate color. Numerical values

and judgemental evaluations are used for making these selections.

i This self-assessment tool is used to evaluate the performance in individual areas and to identify an area that'needs additional management attention.

(potential For example, when the indicators show either a yellow reduction in the margin of n fety or significant

-

operations / maintenance impact) or a red (significant actual reduction in the margin of safety) window or panel, the station superintendent responsib%

course for this area is called before the committee to explain the

condit action that will be taken to correct or change the degrading ,

l i l

The Quality Assurance Department Trending Program also uses the

'

annunciator windows method to represent the results of the activities performed by the QA departments at Surry, North Anna, and Corporat The

functional areas that are evaluated are

engineering, operations, maintenance, TS, licensing / programs, records administration, radiological protection, security, procurement / material control, emergency prepardness, fire protection, chemistry, inservice inspection, special processes, nuclear ' site services, configuration management, fitness for duty, procedures, and nuclear training. These areas are evaluated on a quarterly basis with red, yellow, white, and green used to indicate the status of the quality program and to indicate areas that need more attention from the quality organization. Input to the individual functional windows include audit findings, deviation reports, surveillance ,

findings, NRC findings, and INPO item l tools by the licensee is considered a strengt The use of these self-assessment '

Safety Committee Meetings i

The inspectors attended the on-site safety committee, SNSOC, meeting on March 26 and 28 in order to evaluate the licensee's onsite program for continuing review of the operational and safety aspects of the nuclear facility as required by TS 6.1.C. The inspectors observed the committee ,

reviewing several new procedures, an engineeria work request for the replacement and modification of the containment sump in Unit 2, the temporary modification logs for both units, and the root cause evaluation for switche a problem encountered with the containment spray discharge pressure l

'

The licensee mont has established SNSOC ad hoc subcommittees within the las The'se subcommittees can approve nonintent procedure changes and

revisions, change and routine changes to engineering work requests and design The inspectors noted that the SNSOC continues to function well and in a coordinated manner,

.J

. .

e

Updating UFSAR

,

The inspectors discussed Deviation Report No. S-91-0269, dated February 26, 1991, with the license This deviation identified the fact that a backlog greater than six months old exists for the submittal of UFSAR changes. The requirements of 10 CFR 50.71.e.4 are that revisions to the

UFSAR shall be filed no less frequently than annually and shall reflect all changes up to a maximum of six months prior to the date of filin For Surry there were 15 changes to be filed for updating the UFSAR that were greater than 18 months old, 16 changes less than 18 months but greater than 12 months old, and 39 changes greater than 6 months but less than 12 months old. An accurate UFSAR has particular importance for input to safety evaluations required by 10 CFR 50.59 and for some of the inputs I to the TS. This condition was also identified for North Anna (re Inspection Report 50-338,339/91-02).

In a memorandum to M. Bowling dated February 19, 1991, some of the ,

following reasons for the backlog were identified: failure to clearly !

identify an administrative control, inefficient processing of change l packages, lack of management attention, etc. This same memorandum i

contained recommendations for reduction of the backlog.

, This licensee identified condition is identified as NCV .

50-280,281/91-06-03, Failure to maintain UFSAR updated. This licensee !

i identified violation is not being cited because the criteria specified in Section V.G.1 of the NRC Enforcement Policy were satisfie Within the areas inspected, one NCV was identified.

9. Exit Interview The inspection scope and results were summarized on April 1,1991 with those individuals identified by an asterisk in paragraph 1. The following summary of inspection activity was discussed by the inspectors during this exit.

,

Item Number Description and Reference VIO 50-280,281/91-06-01 Failure to take adequate corrective

,

action for missed pt i NCV 50-280,281/91-06-02 Failure to update the UFSA The licensee acknowledged the inspection conclusions with no dissenting comment The licensee did not identify as proprietary any of the nie terials provided to or reviewed by the inspectors during this insp'ctio _ . _ .

....

-=,

f

!

l l

1 Index of Acronyms amd Initialisms l

' AFW -

AUXILIARY FEEDWATER CAT -

CHEMICAL ADDITION TANK CFR -

CODE OF FEDERAL REGULATIONS CDE -

CAUSE DETERMINATION EVALUATION

! CFE -

COMPCHENT FAILURE EVALUATION CS -

COOLANT SYSTEM DR -

DEVIATION REPORT l ESF -

ENGINEERED SAFETY FEATURE EWO -

ENGINEERING WORK ORDER GPM -

GALLONS PER MINUTE HVAC -

HEATING, VENTILATION, AIR CONDITIONING I&C -

INSTRUMENTATION AND CONTROL ISI -

INSERVICE INSPECTION JC0 -

JUSTIFICATION FOR CONTINUED OPERATION LER -

LICENSEE EVENT REPORT LC0 -

LIMITING CONDITIONS OF OPERATION NCV -

NON-CITED VIOLATION NRC -

NUCLEAR REGULATORY COMMISSION PT -

PERIODIC TEST RCS -

REACTOR COOLANT SYSTEM RWP -

RADIATION WORK PERMIT SI -

SAFETY INJECTION SNSOC -

STATION NUCLEAR SAFETY AND OPERATING COMMITTEE TS -

TECHNICAL SPECIFICATIONS URI -

UNRESOLVED ITEM UFSAR -

UPDATED FINAL SAFETY ANALYSIS REPORT VIO -

VIOLATION VPAP -

VIRGINIA POWER ADMINISTRATIVE PROCEDURES

,

i

!

l