IR 05000280/1992023

Insp Repts 50-280/92-23 & 50-281/92-23 on 921101-28. Violations Noted But Not Cited.Major Areas Inspected: Operations,Maint,Safety Assessment & Quality Verification. Emergency Exercise on 921118 Successfully Conducted

ML18153D211
Person / Time
Site:	Surry
Issue date:	12/18/1992
From:	Belisle G, Tingen S, York J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML18153D210	List: IR 05000280/1992023 ML18153D209
References
50-280-92-23, 50-281-92-23, NUDOCS 9301190049
Download: ML18153D211 (12)

Text

UNiTED STATES NUCLEAR REGULATORY COMMISSION

REGION II

101 MA~IETTA STREET, ATLANTA, GEORGIA 30323 Report Nos.: *50-280/92-23 and 50~281/92-23-Licensee: Virginia Electric and Power Company 5000 Dominion Boulevard

Glen All en, VA 23060 Docket Nos.: S0-280 and 50-281 License Nos~:

DPR-32 and DPR-37 Facility Name:

Surry l and 2

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Inspection Conducted:

November 1 through 28, 1992 Inspector_s:

Approved by:

Scope:

J. W. Yor Inspector

-~-

ting Senior Resident

.c::1,~~****

S.. G. Ting ~

esfde~ector _

• .. ~,.(Tv*

• Section Chi Projects SUMMARY

~~4/PL DaeS1gned.

( 'z_,. - 11/ (, z_

Date igned This routine resident inspection wai conducted on*site in the area of operations, maintenance, safety assessment and quality verification, licensee

~vent review, and action on pr~vious inspection items.. During the performance of this inspection,* the resident inspectors conducted* review of the 1 icens*ee' s backshifts, holiday or weekend operations on November 1, 17, 18, 22, and 27, 199.

Results:

In the operations c1rea~ the following items were noted:

The 1 i censee. conducted a succ~ssful emergency exercise (paragraph 3; a)~

Followup on Verification of Plant Records _(TI 2515/115) showed that records and logs for numerou~ station groups were verified as being accurate and complete (paragraph 3.b).

9301190049 921218

• PDR *. ADOCK 05000280 G

PDR

In the maintenance/stirveillance functional area, the maintenance on check valve l-CC-752 was accomplished in an efficient manner, and the involvement of the quality control inspector and maintenance engineer enhanced the quality of the wor Also, this is an example where the Check Vilve P~ogram, which was used previously to replace a sticky check valve, improved the operation of the plant (paragraph 4.a); *

In the engineering/technical support functional area, a non-cited violation was identified for the failure to test pumps in accordance with Sect4on XI of the American Society of Mechanical Engineers Boiler and Pressure Code, as required by Technical Specification 4.0.3 (paragraph 7.b).

In the safety assessment/quality verification area, the following item was noted:

During the previous inspection a problem was identified with maintenance personnel not performing independent verification when installing danger tag The corrective actions taken to prevent reoccurrence were adequ~te in-that independent verification for placement of danger tags was observed during the thi~ inspection period (paragraph 4.b).

The Quality Assurance assessment of the Vendor Information Program was effective in that potential program problems were identified {paragraph_

6)'.

• Persons Contacted*

Licensee Employees REPORT DETAILS R. Allen, Supervisor, Operations W. Benthall, Supervisor~ Licensing

• R. Bilyeu, Licensing Engineer

• H. Blake, Superintendent of Sit~ Services

• M. Bowling, Manager, Corporate Nuclear Licensing

• R. Blount, Sup*eri ntendent of Engineering

• D. Christian, Assistant Station Manager

• J. Downs, Superintendent of Outage and Plannin.

• D. Erickson, Superintendent of Radiation Protection

~R. Gwaltney, Su~erintendent of Maintenance

• M. Kansler, Station Manager

• A. Meekins, Supervisor, Administrative Servic_es

• J. McCarthy, Superintendent of Operations J. O'H~nlon, Vice President, Nuclear Operations

• A. Price, Assistant Station Manager RL Saunders, Assistant Vice President, Nuclear Operations

. *E. Smith, Site Quality AssOrance Manager

• B. Stanley, Supervisor, Station Procedures NRC Personnel

• S. Tingen, Resident Inspector J. York, Acting Senior Resident Inspector

• Attended Exit Interview Other licensee employees contacted included control room operators, shift technical advisors, shift supervi~ors and other plant personne Acronyms and initialisms used throughout thts report are listed in the last paragrap ~

Plant Status Unit 1 began the reporting period in power operatio The unit was at power at the end of the inspection period, day 83 of continuous operation Unit 2 began the reporting period in power operatio The unit was at power at the end of the inspection period, day 133 of continuous operatio Operational Safety Verification (71707, 42700)

The inspectors conducted frequent tours of the control room to verify proper staffing, operator attentiveness and adherence to approved procedur~ The inspectors attended plant status meetings and reviewed operator logs on a daily basis to verify operations safety and

• -

com~liance with TSs and to maintain awareness nf the overall operation o~ the facilit Instrumentation.and ECCS lineups were periodically reviewed from control room indication to assess operabilit Frequent plant tours were conducted to observe equipment status, fire protection programs, radiological _work-practices, plant.security programs and housekeepin Deviation reports were* reviewed to assure that potential safety concerns were properly addressed and *reporte Participation in Emergency Drill During the evening of November 18, the licensee conducted an*

emergency exercise. This exercise was evaluated by an NRC team composed of five people and included one of the resident inspector The other resident inspector participated in the drill. The participating inspector received notification by beeper-at home at 6:42 pm and immediately proceeded to the sit Arrival time at the site drill control room (simulator control room) was 7:12 p The inspector was briefed by an operations

.

manager concerning the -simulated NOUE for a containment integrity concern. A containment entry team had to exit through the equipment hatch escape trunk and could not fully close this hatc The exercise also had a simulated fire start on EOG #1 at 6:34 pm and it was necessary to get help from a local fire department.

This fire caused the site to declare an ALER After the briefing and control room observation, the inspector proceeded to the TSC and arrived there at 7:30 p Shortly after arriving, *the scenario also had a simulated main steam line break on the A steam generator inside containment and a tube rupture in the same S Because one the emergency buses is faulted and the containment spray pump on the other bus will not start, the pressure in containment rises above atmospheric and a release occurs through the partially open equipment hatch. A SITE EMERGENCY was then declared and a GENERAL EMERGENCY was declared a short time late The inspector kept a log of time various events took place~

Data was gathered to support the evaluation for classification of events, containment integrity, condition of vital shutdown equipment, vital electrical equipment status, impact of the units condition on the operation of the other unit, and the actions taken by the licensee to mitigate the consequence While in the TSC, the inspector observed the decisions and actions made by the"SEM concerning the simulated emergenc These decisions and actions *were considered to be satisfactory and conservativ In addition, briefings on plant conditions were*

frequently given to the inspector by the SEM or his staff. The

• inspector simulated several calls to-Region II such as would occur in an emergency situation and considers that the simulated emergency situations were handled by the.licensee in an efficient and professional manne * Followup on Verification of Plant Records The inspectors previously reviewed the licensee's verification of plant records and logs for the operations section (rR 280,281/92-18).

I_n addition, wherever it was possible, the licensee evaluated the accuracy of station records and logs based on security entrance record The inspectors reviewed some of these evaluations and had discu~sion~ with some of the personnel in order to clarify their respective respon~e to a station

'manager's memorandum on this subjec The following are short summaries on some of the responses:

Radiological protection department reviewed logs and records from both the radiological protection and chemistry

sections. This review showed all of the records that were required had been *take However, this could not be

.

correlated by a check of security entry records because very*

few of these areas require a key card entry.

Firewatch logs are reviewed by the labor supervisor each *

eight hour shif No discrepancies were identifie The licen$ee ~anagement also had discussed with each individual fire watch the importance of complete inspections and

accurate documentatio *

Security checked five days of their logs for completeness and found no problems. *

Emergency planning reviewed a sample of records, some requiring computer input, some requiring a second individual's involvement, and some requiring input by outside groups and identified no, problem A system engineering manager reviewed radiation control area entry records from July through September 1992, and concluded that the system engineers acquired their data from the fiel The engineers were informed that this back checking process would become a periodic method for meeting the concerns identified in NRC IN 92-3 *

The electrical maintenance group selected monthly periodic tests on a nu~ber of batteries and electrical penetrations to determine if logs and records could be verified for parts of August and September 199 Station security records showed that individuals signing for all 12 of the tests went into these areas and that a reasonable amount of time for performance of the test was spent in the are * *-*

The safety/loss prevention section performs station inspections for material that could cause fires and also -

inspects-fire extinguishing system~.

A review of 250

--

inspecti6ns that~required access through security monitor revealed no.discrepancies. These records were for.March, June, and August 199 *

No problems were identified in the Jicerisee's examination of records a~d_ log~.

• *

• *

Wtthin the areas inspected, no violation was identifie.

Maintenance Inspections- (62703) (42700)

During the reporting period, the inspectors reviewed maintenance activities to assure compliance with the appropriate procedures._* Check Valve Inspection (1-CC-752)

On November 4, the inspectors witnessed the maintenanc*e activities associated with the inspection_of-check'valve 1-CC-75 This maintenance was accomplished in accordance with WO 3800119106 and procedure O-MCM-0417-45, VOGT Piston.Check Valve, dated

September 23, 1992: The inspectors. also witnessed filling of tha system which was accomplished by using ~rocedure 1-MOP-8.44, Returning the Charging Pump Component Cooling Watef Pump B to Service, dated October 25, 199 *

The,nspectors noted that the maintenance progressed smoothly and*

on schedule and that procedures were utilized. A QC inspector was also present to monitor thi activity and a maintenance engineer performed the inspection of the check valv This chec:;k valve had a history of sticking open and was recently replace The check valve has not stuck open since being replace The purpose of inspection on this new check valve ~as to aid in the establishment. of an inspection frequency schedul This maintenance/inspection was accomplished in an ~fficient manner, and that the involvement.of the QC inspector and maintenance engineer enhanced the q~ality of the wor Also, this is an example where the Check Valve_ Program and subsequent valve replacement has improved the operation of the plan Repair of Trip Valve 2-SS-TV-201B During the performance of periodic test 2-PT-18.6B, trip valve 2-SS-TV-201B failed to open and its position indicator showed an intermediate positioM when the attempt to ~pen it faile This placed Unit 2 in an LCO, a six-hour clock to hot shutdown (TS -

3.0~1).

To exit the LCO, the licensee placed the second isolatiQn

• valve, 2~SS-TV-201A, in the cl-0sed positio The valve was

• '.

retained in this position by defeating its manual operating button in the control foo One of the elelctrical wires (leads) to the valve's control room pushbutton*was lifted and tagge The inspectors observed the electric1~n disconnect the lead and the placing of a red danger tag, 2-92-SS-015 Tag #1, on it to preverit cbntrol room operation and reconnection of the lea When an*

electrician places tags on a lead or piece of electrical equipment

. it must be independently verified by another electrician. During the last inspection period, an NCV was issued when the

. electricians di~ not work independently in a similar ~ituatib n this case, the ins~ectors observed that independent verification was-performed. This is one indtcation that the action taken to correct a previous problem for non-independent verification was effectiv *

In ~dditi~n to the abo~e observatibn.of work, the insp~cttiri v~rified that the maintenance documentation was correct. Th craft used WO 3800135246 and prdcedure EMP-C-SOV-163, Removal an Installation of Limit Switches and Solenoid Valves for Mechanica Department, dated September 12, 199 The valve was found closed and th~ limit switch and bracket were out of positio The position of the limit switch was*adjusted to conform to the position ~f the valve and the bracket was tightened. The-valve was.stroked, the stroke measured, and the position indica,ting lights were verified for the crirrect valve positio Post maintenance testing was performed using two PTs, PT 18.68, ~he valve exercise test (the test that originall.Y identified the problem), and PT *18.lOF, w~ic~ verifies* valve position i_ndicatio No discrepancies were identified.*

.

.

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Within the areas inspected, no violations were identifie.

Surveillance In~pections (61726, 42700)

_

During the reporting periods~ the inspectors reviewed surveillance activities to assure tompljance with the appropriate procedure and TS requirement *

The following surveillance activity was reviewedt

. Unit 2.Miscellaneous Containment Trip Valve Testing Un November 17, *the inspectors witnessed stroking and ti~ing of some of the mi*scellaneous trip valve~ fo~ Unit 2 cont~inmen Procedure 2-PT-18.68, Quarterly Testing of Miscellaneous Containment Trip Valves, dated December 12, 1989, was* use This test cycl~s trip-*valves to their required position for an accident and ensures that*clbsure time is acceptable. It'is also performed

• to meet the surveillance requirements of i nservi ce inspection and testing required by ASME Section X During the test, valve

. 2-SS-TV-2018 failed to open and according to step 6.2.1 of the procedure, the valve was *declared inoperable. A station deviation was submitted, and an urgent work order was prepare According to TS 3~0.1, this placed the unit in an LCO, a six-hour clock to

hot shutdown (the maintenance on this valve is discussed in paragraph 4.b).

From the control room, the inspectors observed stroking/testing of 14 additional valves which were from the sampling, safety r injection, main steam, and the component cooling water syste The stroking times for these valves varied from 0.6 of a second to 12.3 seconds. All of the 14 valves' time were less than the maximum stroke time allowed in the procedur The inspectors did not notice any discrep~ncies in the performance of the periodic tes Within the areas inspected; no ~iolations were identifie.

Safety Assessment and Quality Verification (40500)"

The inspector~ continued to meet with QA on a monthly basis to discuss retent QA findings at th~ statio QA oversight in station activities remains active. One of the items discussed during the meeting was the QA assessment of the Vendor Information Progra The licensee is in the process of updating vendor technical manuals via the Vendor Information Progra The program update is scheduled to be completed in March 1993. The inspectors reviewed the QA's assessment of this program, which was conducted during June-July 199 The audit identified progra~matic weaknesses existed, one of which:warranted~

management oversi~ht to ensure an adequate resolution. This one showed that certain vendor information was not being provided to the vendor information.coordinator and therefore not available to incorporated

. during the program updat QA's assessment concluded that the program was satisfactory over a 11.

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The inspectors concluded the Vendor Information Program was effective in identifying potential program problem Within the areas inspected, no violations were identifie.

(icensee Event Review (92700)

The inspectors reviewed the LERs listed below and evaluated the adequacy of corrective actio The inspector's review also included followup on the licensee's implementation of corrective actio (Closed) LER 280/92-006, Failure to Expand Scope of Mechanical Snubber Functional Testing. Due to Personnel Error.* This issue involved three Unit 1 snubbers which exceeded the drag force measured in the previous functional test by 50 percen The TS requires that for each snubber that does not meet these requirements that an additional 10 percent of that type of snubber be functionally teste Initially, the licensee had installed Pacific Scientific type snubbers and now have Anchor Darling type_

snubber The engineering group performed an evalua-tion and.found

• 7 the snubbers to be operab 1 e and ab 1 e to perform thefr i nt~-hded *

functio The vendor of.these sn~bbers provided a technical position that an increase of Sri percerit ~n the drag force* is not

• indicative of incipient failtire. Since the drag test results for

• Anchor Darling type snubbers are highly variable, and the TS

.criteria is not valid for these type snubbers. A one-time waiver of tompl1ance was requested and reciived for the Anchor Darling type snubbers from the 10 percent additional functional testing requirements of TS -4.17.C.6. Corrective. actions inclu_ded the engineering evaluation of the functional te.st results and the reminder to engineering personnel about the importance of adhering-to TS requirements.. In addition, the lfcensee submitted a change to the TS to provide the correct criteria for these snubbers~ (Closed) (ER 280/91-10, ASME Section iI Inservice Testing Progra Requiremerits Not Met Due to Persorinel Error~. This isiue was

identified by the licensee.and involved the failure to test pumps in acc6rdance with Section XI of the ASME Boiler and Pressure

Vessel Cod The following areas of noncompliance were identified:

Accuracies of certain flow instiuments exceeded 2%.

Full scale range of certai~ indicators was gre*ter that three times the reference value being measure Some pumps were being tested under dead head conditio11 Instrumentation inaccuracy and. improper sealing *c_ontributed to an improper test and was attributed ~o personnel not performing the*

proper review during the implementation of design changes that were ass_ociated with upgrading pump IST instrumentation. Short term corrective action involved obtaining NRC approval of an interium relief request from.the instrument accuracy requirements*

of Section XI and long term corrective action involved revising ca 1 i brat ion procedures and to insure that _.the ful 1 sea 1 e range of in~trumentation is within the confines of the requiremen Long term.corrective action also involved engineering performing an internal assessment iri the area of design change process. The -

inspectors reviewed the conclusions of this internal assessment which included the following corrective action to strengthen the design control process:

Revise design control pr6cedures to provide more detail for*

accomplishing design review 1 technical review, project engineer review, and*revision proces Place time limits for the review proces Develop design control performance indicator q'

,.*

. -.

Re;..review approved design changes when the original i_mplementation dates are delaye Procedures VPAP-0301, Design Change Process, Rev. 0, and STD-GN-0001, Instruction For DCP Preparat,ion, Rev. rn, both recent revisions, have been implemented to strengthen the design control proces Testing pumps at de~d head conditions was-also identified as personnel error. Corrective action involved revising procedures to eliminate dead head testing and ~ounseling personnel to ehsure components were tested in accordance with IST requirement *

.

'

TS 4.0~3 requites that.ASME Code Clais 1,2i and 3 co~ponents be t~sted in accordance with Section XI of the ASME Boiler and Pressure 'vessel Code, except where specific written relief has been granted by the NR The failure to test pumps in accordance with Section XI as required by TS 4.0.3 was identified as NCV 280,281/92-23-01. * This violation will not be subject to *

enforcement*action because the licensee's efforts in identifying and correcting-the violation meet the criteria specified in Section VII.b of the Enforcement Polic.

. (Closed) LER 281/91-001, Failure to Demonstrate PORV Block Valves Operable Due to Personnel Error. This issue involved the failure to perform a TS surveillance test due to personnel error. The licensee discovered-that PORV's 2-RC-MOV-2535 and-2536 had not

,been demonstrated operable at least once during a previous 92 day

• perio An additional missed surveillance for high energy ltne insp~ction was discovered four days after discovering the missed surveillance for the PORV block valves and resulted in the is~uance of NRC Vio _280,281/91-06-0 For corrective acti6ns,*the licensee has improved the program for scheduling PTs by formalizing communications between the group that schedules PTs and the group that performs thesi PT Additional correctiv~

actions involved appointing a point of contact in each of these_

• groups, developing a 111onthly and nine day-look ahead PT schedule, and enhancing the notification process when the scheduled PT has been performe The inspectors have noted that these corrective actions have be~n effective in preventing repetition of the missed

• surveillance pr6ble *

Within the areas inspected, -one non-cited vio,lation was identifie ~

Action on ~r~vious Inspection-Findings (9~701, 92702)

(Clcised) IFI 280/91-29~01, Acceptability of Manual Operator Action to Compensate-for Automatic Function. This issue involved evaluat~on of*

the licensee's criteria for determining when automatic functions can be replaced by manual action and how these extra operator actions are controlled such that they can be readily carried out when the minimum number of operators are available on shift. The inspectors reviewed

Virginia Power memorandum, Nuclear Policy on Defeating E_quipment or System Automatic Safety Functiotis,-dated June 8, *1992. This memorandum was from Vice President Nuclear Operations to both North Anna and Surry

• Station.Manager The memorandum stated Virginia Power's policy on defeating equipment or system automatic-safety functions and also

~ontained guidelines to be followed in the evaluations and decisions related to defeating equipment or system automatic safety functitin Station personnel hav*e been trained on this policy and the licensee is in the protess of proceduralizing the new polic The inspectors have al so monitored the station's day to day activities. associated with.

substituting manual operator action for automatic action and have concluded that adequate controls have been implemented~

Within t_he areas inspected, no violations were id~ntifie.

Exit Interview The results were summarized on November 30, with those individuals identified by an asterisk in Paragraph The following summary of inspection activity was discussed by the inspectors during.this exit:

.

.

Item Nuinber LER 280/92-006 NCV 280,281/92-23~01 LER 280/91-10 LER 281/91-001 IFI 280/91-29-01 Status Closed Closed Closed Closed

• Closed Description Failure to Expand Scope of M~chanical Snubber Functional Testing Due to Personnel Error

• (paragraph 7.a).

Failure To Test Pumps in Accordance with Section XI as Required by TS 4. (paragraph 7.b).

ASME Section XI Inservice Testing Program Requirements Not Met Due to Personnel Error (paragraph 7.b).

Failure to Demonstrate PORV Block Va-1 ves Operable Due to Personnel Error *(paragraph 7.c).

Acceptability of Manual Operator Action to Compensate for Automatic Function (paragraph 8).

• Proprietary informatio~ is not contained in this report. Dissenting comments were not.received from the* license...

1 *

Index of Acronyms and Initialisms *

ASME

-

ECCS -

IFI IR LCO LER NOUE NCV PORV PT NRC QA QC SEM SG

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TS TS VIO WO AMERICAN SOCIETY OF MECHANICAL ENGINEERS EMERGENCY CORE COOLING SYSTEM INSPECTOR FOLLOWUP ITEM INSPECTION REPORT LIMITING CONDITIONS FOR OPERATION LICENSEE EVENT REPORT NOTIFICATION OF UNUSUAL EVENT NONCITED VlOLATION POWER OPERATED RELIEF VALVE PERIODIC TEST NUCLEAR REGULATORY COMMISSION QUALITY ASSURANCE QUALITY CONTROL STATION EMERGENCY MANAGER/

STEAM GENERATOR TECHNICAL SPECIFICATION TECHNICAL SUPPORT CENTER VIOLATION WORK ORDER