IR 05000280/1992012
| ML18153D028 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 05/22/1992 |
| From: | Branch M, Fredrickson P, Tingen S, York J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18153D027 | List: |
| References | |
| 50-280-92-12, 50-281-92-12, NUDOCS 9206120119 | |
| Download: ML18153D028 (8) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, ATLANTA, GEORGIA 30323 Report Nos.:
50-280/92-12 and 50-281/92-12 Licensee:
Vi rgfoi a Electric. and Power Company 5000 Dominion Boulevard Glen.Allen, VA 23060 Dockef Nos.:
50-280 a.nd 50-281 License Nos.:
- .Facility Name:
Surry 1 and 2
- Inspection Conducted:
May m through 18, 1992 * Approved by:
SUMMARY Scope:
This special inspection was conducted on site to review the reported inoperability of the A CH/HHS! pump under certain pump configurations, and to evaluate the effectiveness of corrective actions that were implemented as a result of a similar event that occurred in Augu~t, 1991 which resulted in escalated enforcemen *
Results:
One apparent violation was identified for ineffective corrective actions
. (failure to comply. with 10 CFR 50, Appendix B Criterion XVI) that resulted in exceeding Technical Specification 3.3.B.2 time constraints *
9206120119 920522 PDR ADOCK 05000280 G
PDR Persons Contacted Licensee Employees REPORT DETAILS
- W. Benthall, Supervisor, Licensing
- R. Bilyeu, Licensing Engineer H. Blake, Superintendent of Site Services
- R. Blount, Superintendent of Engineering
- M. Bowling, Manager, Nuclear Licensing - Cotporate
- D. Christian, Assistant Station ~anager J. Downs, Superintendent of Outage and Planning A. Fletcher, Assistant Superintendent of Engineering
- G. Flowers, Manager, Nuclear El~ctrical Engineering R. Gwaltney, Superintendent of Maintenance
- L. Hartz, Manager, Nuclear Quality Assurance - Corporate
- M. Kansler, Station Manager
- J. Long, System Engineer
- J. McCarthy, Acting.Assistant Plant Manager
- G. Miller, Senior Staff Engineer, Nuclear Licensing
- D. Modlin, Supervisor, Shift Operations - Acting
- J. O'Hanlon, Vice President, Nucleat - Corporate
- R. Shore, Station Nuclear Safety
- E. Smith, Site Quality Assurance Manager NRC Personnel
- M. Branch, 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 ~up~rvi~ors and other plant personne Acronyms and initialisms used throughout this report are listed in the last paragrap.
Review of Charging Pump Operability Background Information On May 11, the licensee made a 10 CFR 50.72 report regarding operation of Unit 1 without complying with the requirements of TS 3.3.B.2. (Safety Injection System) for alignment of the CH/HHSI pumps.* This condition existed since the startup on May The
control switches for the CH/HHS! pumps 'were aligned such that the A*
CH/HHS! pump would trip on an undervoltage condition. This CH/HHS!
pump configuration was identical to the condit,on that resulted in es_calated enforcement action in September 199L A review of the 1991 event as well as the details. of the May, 1992, event are discussed in the following paragraph *
In.August 199lj the CH/HHS! pumps' control switch configuration was questioned by the NR After a detailed review of the confi gura-tion by the licensee, it was determined that since 1980, the typical alignment of.having the C CH/HHS! pump in PTL violated TS 3.3.B.2. Inspection Report 50-280,281/91-24 documented the NRC review of this issue which resulted in escalated enforcement. This report also described the prior 1980 design and the licensee immediate corrective actions to comply with TS requirement There are three CH/HHS! pumps in each unit. The A pump is.powered from the H emergency bus, the B pump is powered from the J emergency bus, and the C pump is a swing*pump that can be powered from.the Hor J bus. TSs require that two CH/HHS! pumps be available for a unit when critical, one pump powered from the H bus and the other pump powered from the J bu In the alignment.where*
the A and B pumps' control switches are in the r~n or automatic start positions, the C pump control switch is in PTL, and the C pump's J bus supply*breaker is racked-out, on initiation of an ECCS
- signal, coincident with an H bus undervoltage condition, the A pump would.have locked out and not started automatically. Operator action would be required to manually, start the A pum Upon discovery of the inadequate CH/HHS! pump configuration on
- May 11, operations initiated the following immediate actions. The
.A pump was declared inoperable and the TS action requirement to be in hot shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> was entered. The pumps were realigned such that the A control switch was in the.PTL position, B pump control switch in run, and C pump c.ontrol switch in the
automatic start position. The TS shutdown action statement was then exited. The Unit 2 CH/HHS! pump control switches were verified to be correctly aligned. Previous Unit 1 CH/HHSI pump configurations since unit startup were reviewed and Deviation Report S-92-0866 wa~ issued. The deviation report stated that during a design/basis accident which includes a undervoltage on the H bus, the inadequate CH/HHSI pump configuration concurrent with a single failure.. of the B pump would result in the unit not having a CH/HHSI pump available for automatic start. At approximately 2: p.m. the licensee made a one-hour nonemergency report in accordance with 10 CFR 50.72. Since automatic CH/HHS! initiation assumed in the design basis accident in coincidence with a single active_
failure, the units would be outside the design base$ in certain pump configurations if credit for manual operator could not be take *
The licensee's CNS event review team was established an9 on May 12 review of the event was initiated. Additionally, operations reissued a standing order describing the requirement for lifting the* UV interlock lead if the A pump was incl~ded as one of the two required operable pumps for unit operation. The MEL was also modified to provide more detailed information on pump.operability requirements for unit operatio Evaluation of Causes During the spring 1992 Unit 1 refueling outage, the licensee performed the necessary.engineering reviews to allow reestablishment of the pre-1980 configuration alignment of the CH/HHS! pump Upon receipt of an ECCS signal without an undervoltage on the H bus, all three CH/HHS! pumps would automatically star DC 91-021, Charging Pump Auto Start Evaluation/Surry/1&2, dated November 1, 1991, required that a*ll three CH/HHS I pumps be norma*l ly aligned to automatically start upon receipt of an ECCS initiation signal. If an undervoltage conditiori developed on the H bus, the A pump would lockout and the Band C pumps would continue to operat As previously discussed, the licensee initially planned to operate Unit 1 following the RFO with two CH/HHS! pumps aligned for automatic start and the third charging pump operating. Step 5.3.6 of 1-GOP-1.3 originally required that tbe CH/HHS! pumps be placed in this configuration when RCS temperature passed through 350 degrees During the Unit 1 startup assessment, the licensee reevaluated this configuration and changed CH/HHS! pump configuration to one pump operating, one pump aligned for auto start and the third pump in PT Because o the change in CH/HHS! pump configuration, Step 5.3.6 of l-GOP-1.3, was changed by PAR 92-557 to align the CH/HHS! pumps as directed by the shift supervisor. This procedure change was approved.by SNSOC.'
When operators subsequently performed this step they incorrectly a.ligned the A CH/HHS! pump for auto start~ the B pump in operation, and the C pump in PT With the C pump in PTL a temporary
_modification to lift the lead for the A pump UV interlock that was
- necessary to keep the A pump operable (i.e. able to automati_cally start on SI and remain running under an under voltage condition)
was not performe *
The inspectors reviewed procedures 1-0P-CH-002~ Charging Pump A Operations, dated January 14, 1992, and l-OP-004, Chargjng Pump C Operations, dated March 26, 1992 and concluded that these procedures contained adequate instructions, to ensure that CH/HHS!
pumps are properly configured. These procedures are routinely performed during normal plant operation but do not establish required conditions prior to changing modes of plant operation. The inspectors identified one opportunity where op~rators could have identified that the CH/HHSI pumps were improperly aligned during the perfonnance of one of these routine procedure On May 9, C CH/HHS I pump was. sta rt~d-.in accordance with 1-0P-CH-004 to perform
- PT 1-PT-18.7, Charging Pump Operability And Performance Tes The inspectors reviewed the PT test results 4nd concluded that operators could have identified_ the incorrect CH/HHSl pump align'."
ment during the performance of step 5.2.6 of l-OP-CH-004. * This. step required that operators verify the status of the A CH/HHSI pump UV interlock prior to starting the C CH/HHSI pum During the performance of this step, operators acknowledged that the A CH/HHSI pump UV interlock was enable However, operators failed to
_realize that the CH/HHSI pumps were in an alignment not allowed when the A CH/HHSI pump UV interlock was enable When l-PT-1 stopped the operating C pump the procedure only stated to stop the pump and did not contain precautions associated with the A CH/HHSI pump UV interloc Previous Corrective A~tions *. The licensee's November 20 and December 20, 1991, responses to th previous enforcement action and also LER 91-020 committed to the following corrective actions:
Complete a review to.determine if other critical plant components require manual operator action which was*
.inconsistent with design basis operatio Develop a consistent policy for acceptable operator manual intervention consistent with Technical Specification definition for operabilit *
Train station operating and engineering personnel on the policy for use of manual operator action Perform engineering evaluation to determine if changes in the*
operating methods of the CH/HHSI pumps can be made to eliminate concerns associated with th~ A pump UV lockou Make procedure changes as necessary to ensure the CH/HHSI pumps are aligned in a configuration where automatic capability is maintain~ *
The inspectors reviewed the licensee corrective actions described above and the results of that review are discussed in the conclusion section belo Conclusions The procedures that were modified by the licensee as part of the corrective actions for the August 1991 event were not inclusive in that they did not address all cases where pump realignment is specifie When the CH/HHSI pumps were aligned per 1-GOP-1.3 or stopped in accordance with l-PT-18.7 there were no references to
- cautions associated with the A pump interlocks. This lack of administrative control in 1-GOP-1.3 was a major contributor to the improper CH/HHSI *pump control switch alignmen Procedure l-GOP-1.3 revision 2, which implemented the requirements of DC-91-21 would have resulted in an acceptable alignment since it originally required all three CH/HHSI pumps be operable for the 350 degree F mode chang However, the procedure as originally written did not address situations when only two pumps would be available (as allowed by TS) and would eventually have needed to be modified in the event of testing or maintenance of one CH/HHSI pum One of the conmitments discussed above involved an engineering evaluation to determi.ne if changes in the operating methods for the CH/HHSI pumps could be made to eliminate the concern associated with the A pu~p UV interloc Item CTS#1552, from the licensee's-conunitment tracking system, was assigned for this engineering evaluation and indicated that it had been accomplished by implementation of DC 91-02 The inspector's review of DC jl-021 determined that the removal of the UV lockout interlock was not addressed as part of the design chang DC 91-021 only addressed the reevaluation of the pre-1980 design and a return to the automatic three-pump-start configuratio The inspectors also reviewed previous opportunities to correct the desig The inspectors noted that as part of the enforcement conference for Inspection Report 91-24 the licensee had identified two engineering reviews that could have corrected the condition, however the
.licensee appeared to focus on the acceptability of operator actions and procedures versus correcting the hardwar Had the licensee modified the hardware after the 1991 violation the May 11 event would not have occurre *
Prior to the Unit 1 startup following the RFO, operators were trained on the proposed new method of CH/HHSI pump operation described in DC 91-2 This training was documented in Training Synopsis, RQ-92.3-TS-5, Charging Pump Operation, dated April 6, 199 The inspectors reviewed the training synopsis and concluded that operators were instructed that procedural controls were in place to defeat the UY interlock on the A CH/HHSI pump if the C pump was taken out of service.. The inspectors also concluded that this training contributed to the occurrence of the event in that it misled operators into believing that procedural controls would control CH/HHSI pump configuratio However, operators had opportunities to identify that the CH/HHSI pumps were improperly aligned and failed to do s During review of the,temporary modification log, and also during performance of 1-0P-CH-004 as previously discussed, operators could have identified that the A
. CH/HHSI pump UV interlock was not defeate TS 3.3.B.2 states that two of the three CH/HHSI pumps in a unit may be out of service, provided immediate attention is directed to making repairs and one of the inoperable pumps be restored to an
,
operable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. If one of the inoperable pumps is not restored to an operable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, then the -
reactor shall be placed in the shutdown condition. If one of the inoperable pumps is not restored within an additional 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, the reactor shall be placed in a cold shutdown condition. The failure to configure Unit l's CH/HHS! pump prior to plant startup on May 1 such that the A pump would automatically operate during a design basis accident resulted in a condition not allowed by TS 3.3. Unit 1 operated at power in an improper CH/HHS! pump configuration for the periods of May 1 through May 7 at 10:06 am, from 5:55 on May 7 through-9:22 p.m. on May 9, and from 10:29 p.m. on May 9 to discovery and correction at 9:30 am on May 1 CFR 50, Appendix B, Criterion XVI, as implemented by Oper_ational Quality Assurance Program Topical Report (VEP 1-5A, Section
17.2.16), requires, in part, that measures be established to assure that conditions adverse to quality be promptly identified and coirected and in the case.of significant conditions adverse to quality, the measures shall assure that the cause of the condition ts determined and corrective action taken to preclude repetitio The failure to preclude repetition of the August 1991 event b,ecause of ineffective corrective actions was identified as Apparent Violation 50~280/92-12-01, Ineffective Corrective Actions Associated With CH/HHS! Pump Switch Configuratio Within the areas inspected, one apparent violation was identifie.
- Exit Interview
. The inspection scope and results were summarized on May 18, 1992, with those individuals identified in paragraph 1. The following sul!l1lary of inspection activity was discussed by the inspectors during this exi Item Number Description and Reference Apparent VIO 50-280/92-12-01 Ineffective Corrective Actions Associated*
With CH/HHS! Pump Switch Configuration The licensee acknowledged the inspection conclusions with no.dissenting comment The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspectio * Index of Acronyms and Initialisms CFR CH/HHSI-CNS ECCS EOP CODE OF FEDERAL REGULATIONS CHARGING/HIGH HEAD SAFETY INJECTION CORPORATE NUCLEAR SAFETY EMERGENCY CORE COOLING SYSTEM EMERGENCY OPERATING PROCEDURE
.......-,-------------~-~---**. *-=***=***-~----~---~
TS UV
HOT S~UTDOW MINIMUM EQUIPMENT LIST NET POSITIVE SUCTION'HEAD NUCLEAR REGULATORY COMMISSION PULL TO LOCK REACTOR COOLANT SYSTEM REFUELING OUTAGE STATION NUCLEAR SAFETY AND OPERATING COMMITTEE TECHNICAL SPECIFICATION UNDER VOLTAGE *