IR 05000280/1994006
| ML18153A910 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 04/01/1994 |
| From: | Belisle G, Branch M, Tingen S, York J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18153A909 | List: |
| References | |
| 50-280-94-06, 50-280-94-6, 50-281-94-06, 50-281-94-6, NUDOCS 9404120155 | |
| Download: ML18153A910 (12) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, N.W., SUITE 2900 ATLANTA, GEORGIA 30323-0199 50-280/94-06 and 50-281/94-06 Licensee: Virginia Electric and Power Company 5000 Dominion Boulevard Glen Allen, VA 23060 Docket Nos.:
50-280 and 50-281 License Nos.:
DPR-32 and DPR-37 Facility Name:
Surry 1 and 2 Inspection Conducted:
February 6 through March 5, 1994 Inspectors:
Approved by:
b~~
S. G. ~n~ent Inspector G.~Beis,Seili on Chief Division of Reactor Projects SUMMARY Scope:
3-<3( -ii Date Signe 3-.3/-?~
Date Signe 3-31-9'~
Date Signe This routine resident inspection was conducted on site in the areas of plant status, operational safety verification, maintenance inspections, surveillance inspections, review of plant modifications, and refueling activitie Inspections of backshift and weekend activities were conducted on February 6, 7, 9, 13, 16, 23, 24, 28 and March 1 and 2, 199 Results:
Operations functional area Personnel involved with the reactor head lift evolution were familiar with their job assignments and they performed in an efficient manne There was one difficulty observed associated with threading the lifting pin bolt into the shackl Based on discussions with personnel involved, this appeared to be a recurring problem {paragraph 7).
9404120155 940401 PDR ADOCK 05000280 Q
Maintenance functional area Maintenance personnel performing accumulator check valve maintenance were knowledgeable and skilled. Also the support provided by radiation protection personnel during this maintenance was goo However, maintenance personnel had to overcome numerous obstacles in order to perform the maintenance (paragraph 4.b).
System engineering and operations personnel were thoroughly prepared to perform Unit 1 low head safety injection pump testing. The actual testing was accomplished utilizing good command and control (paragraph 5.a).
Extensive repairs to the Unit 1 main generator voltage regulator were performed to improve the regulator's reliability (paragraph 4.c).
Engineering functional area Not performing a safety evaluation for operating the low pressure carbon dioxide fire suppression system in a manner other than as described in the Updated Final Safety Analysis Report was identified as an Unresolved item 50-280, 281/94-06-01 (paragraph 3).
The engineering examinations and evaluations performed on the inside of the service water discharge piping for the Unit 1 recirculation spray heat exchangers were thorough and were identified as a strength (paragraph 4.a).
The Unit 1 design change package associated with installing the pressurizer safety valve drain lines was completed with minimum revisions or installation problem The engineering support for the modification was identified as a strength (paragraph 6).
Plant Support functional area During the Unit 1 refueling activities, ALARA was evident during all portions of the operation. Radiological briefings were thorough and identified as a strength (paragraph 7).
-~==--==~=~------------------------~-~---- Persons Contacted Licensee Employees REPORT DETAILS
- W. Benthall, Supervisor, Licensing
- R. Bilyeu, Licensing Engineer H. Blake, Jr., Superintendent of Nuclear Site Services
- R. Blount, Superintendent of Maintenance
- D. Christian, Assistant Station Manager J. Costello, Station Coordinator, Emergency Preparedness
- J. Downs, Superintendent of Outage and Planning
- D. Erickson, Superintendent of Radiation Protection A. Friedman, Superintendent of Nuclear Training B. Hayes, Supervisor, Quality Assurance
- M. Kansler, Station Manager C. Luffman, Superintendent, Security. *
- J. McCarthy, Superintendent -~f Operations
- D. Hayes, Supervisor of Administrati*ve Services
- A. Price, Assistant Station Manager R. Saunders, Assistant Vice President, Nuclear Operations
- E. Smith, Site Quality Assurance Manager
- T. Sowers, Superintendent of Engineering
- J. Swientoniewski, Supervisor, Station Nuclear Safety Other licensee employees contacted included plant managers and supervisors, operators, engineers, technicians, mechanics, security*
force members, and office personne NRC Personnel
- M. Branch, Senior Resident Inspector
- S. Tingen, Resident Inspector J. York, Resident Jns~ector
- Attended Exit Interview on March 8, 1994
- Attended Exit Interview on March 31, 1994
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Acronyms and initialisms used throughout this report are listed in the last paragrap.
Plant Status Unit 1 was shutdown for a planned refueling outage for the entire perio Unit 2 began the reporting period at 100% powe On February 14, power was reduced to 98% due to excessive level oscillations in the C S The level oscillations were attributed to scale buildup which partially blocked the quatrefoil assemblies in the SG upper tube support plate *
The licensee predicted that a 0.7% power reduction per month would occur due to increased blockage in the quatrefoil assemblies. A 22-day outage has been scheduled to begin on June 14, 1994, to remove the blockag The unit operated at 98% power for the remainder of the perio.
Operational Safety Verification (71707)
The inspectors conducted frequent tours of the control room to verify proper staffing, operator attentiveness and adherence to approved procedure The inspectors attended plant status meetings and reviewed operator logs on a daily basis to verify operational safety and compliance with TSs and to maintain overall facility operational awa'renes Instrumentation and ECCS lineups _were periodically reviewed from control room indication to assess operability. 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 On February 15, 1994, the low pressure carbon dioxide tank manual isolation valve (l-FP-1052), which is normally locked open, was observed by the inspectors to be closed. A small leak had been identified and l-FP-1052 was closed to conserve inventory. While the valve was closed, the low pressure carbon dioxide fire suppression system was considered operable by the licensee. Administrative controls were established to open l-FP-1052 in accordance with procedure l-EPT-0902-01, Fire Protection Low Pressure Carbon Dioxide System Puff T~st. Administrative controls required that an operator be stationed at l-FP-1052 to open the valve when instructed by the control roo Section 9.10.2.2.7 of the UFSAR describes an automatic CO2 fire suppression system with design features which include heat detectors, remote manual pull stations, and lockout controls for personnel protectio Procedure l-EPT-0902-01 was an upgraded procedure that was issued on September 15, 199 The purpose of this procedure was to perform low pressure carbon dioxide fire suppression system puff testin Attachment 1 to this procedure provided instructions for establishing administrative controls when l-FP-1052 was shut to perform testin Attachment. 1 to 1-EPT-0902-01 was being utilized on February 15, 1994, to maintain the system operable while 1-FP-1052 was closed to perform maintenanc The inspectors reviewed the 10 CFR 50.59 screening for procedure l-EPT-0902-0 The screening concluded that a SE was not required. The inspectors considered that the licensee was operating the low pressure carbon dioxide fire suppression system differently than described in the UFSAR and that a SE pursuant to 10 CFR 50.59(b)(l) was require The inspectors concluded that although this evolution was allowed by the procedure there was no type of evaluation performed to assess
substituting manual action for an automatic action. The licensee disagreed with the NRC's interpretation of 10 CFR 50.59(b)(l) for this example, in that, the NRC interpretation of 10 CFR 50.59(b)(l) was too strict and that a SE was not required. This issue was identified as URI 50-280, 281/94-06-01, Not Performing a SE For Administrative Control of l-FP-105 In correspondence dated July 31, 1992, the licensee stated that the UFSAR description may include certain operating procedural details. The licensee further stated that to fully define operational configurations these system descriptions and the system layout drawings must be evaluated in concert with associated operating and maintenance procedure This interpretation was different than that being applied by the NR This interpretational difference was discussed at a subsequent NRC - VEPCO counterparts meeting conducted in September 1992 but was not resolve Although the licensee determined that a SE was not required, a SE was subsequently prepare The inspectors reviewed SE No.94-045 for administrative control of valve 1-FP-105 The SE concluded that it was acceptable to shut l-FP-1052 provided that an operator could open the valve within 30 seconds upon notification from the control roo Procedure l-EPT-0902-01 was revised to indicate that l-FP-1052 was required to be opened within 30 second The inspectors concluded that SE 94-045 met 10 CFR 50.59 requirements and included the appropriate Appendix R revie Within the areas inspected, one unresolved item was identifie.
Maintenance Inspections (62703)
During the reporting period, the inspectors reviewed the following maintenance activities to assure compliance with the appropriate procedure Visual Inspection of Unit l RSHX SW Piping While performing procedure, l-OPT-RS-003, SW Flow Test Through Two RSHXs, leakage was detected coming from the 24-inch diameter carbon steel discharge pipe at the elbow on the B RSH The through wall leak in the elbow was located approximately 90 degrees from top dead center and was a result of general corrosion caused by a failure of the original coal tar coating. This piping system is normally maintained dr On February 17, the inspectors accompanied the licensee's material engineer while visually inspecting the inside of the B RSHX discharge elbow and the straight run of pipe. This and the preceding engineering inspection revealed sporadic coating blisters with some exfoliation corrosion of the carbon stee Also, coating failures were evident approximately 10 inches
upstream and downstream of the expansion joints in the discharge line. The A, Band C RSHX discharge lines were examined with similar results. The licensee ground the corroded areas and performed ultrasonic wall thickness measurement Only an outside ultrasonic thickness measurement was performed on the D RSHX because the vessel was filled with water for hydrostatic testin The inspectors determined this to be an adequate method for determining minimum wall thickness. All areas measured, with the exception of the B RSHX discharge pipe elbow, exceeded the minimum ASME Code wall thickness requirements. Since this system is maintained in the dry condition no further wall reduction should occur due to general corrosio The elbow that was leaking (B RSHX 1) was missing approximately 50 percent of its original coal tar coating and was evaluated as below the ASME Code allowable minimum wal The nominal thickness of the piping is 0.5 inches with 0.375 inches required in the elbow area and 0.15 inches required in the straight run of pipin The area that was below minimum wall extended approximately 75%
around the circumference and encompassed the through wall leaking are The licensee replaced the elbow. This piping was considered a membrane barrier; however, no leakage path to the outside atmosphere existed because the SW intake and discharge valves are closed during normal power operation In addition, if the hole in the pipe existed during an actual emergency condition, the radiation monitor in the discharge line would have detected the leak and that discharge line could have been isolated by closing the discharge valve (all four of the discharge lines have radiation monitors).
- The inspectors considered that the examinations of the inside of these SW lines by the licensee's engineering personnel to be thorough and is identified as a strengt Unit 1 Accumulator Discharge Check Valves The inspectors monitored the maintenance associated with the Unit 1 Band C accumulator discharge check valves l-SI-128, 130, 145 and 147. This maintenance was required because back leakage through the check valves into the accumulators created problems while the plant was operating. Previous operational problems associated with in-leakage into the Unit 1 B accumulator were discussed in NRC Inspection Report Nos. 50-280, 281/93-2 The check valves were disassembled, inspected, manually exercised, seating surfaces blue checked, repaired as required and reassemble The valve vendor assisted station personnel in performing repair The maintenance on l-SI-128 was accomplished in accordance with WO 274647 and procedure O-MCM-417-25, Darling Swing Check Valve Inspection and Overhaul Model S 350W SC, dated December 10, 199 No significant deficiencies with the check valve were identified
during'the inspection. However, the as-found blue check was unacceptabl The seating surfaces were lapped and a satisfactory blue check was obtaine The maintenance on l-Sl-130 was accomplished in accordance with WO 272385 and procedure O-MCM-417-2 Inspection of the check valve identified that the internals were wor The internals were replaced and the valve was reassemble Maintenance on l-SI-145 was accomplished in accordance with WO 267802 and procedure O-MCM-417-2 During a previous RFO, this check valve was inspected and the seat ring was identified to be cracke The maintenance to repair the valve was deferred to the present RF During this RFO the seat ring was replaced and the seating surfaces lappe Maintenance on l-Sl-147 was accomplished in accordance with WO 267804 and procedure O-MCM-417-2 No significant deficiencies were identified during the inspection. The seating surfaces were polished and the valve was reassemble The inspectors reviewed the PMT requirements which required that each check valve be partially stroke exercised following reassembly, verification that each valve closes (this was to be accomplished by performing a seat leak test) and each valve body to body joint was to be inspected for external leakage when the plant was pressurize By a thorough review of the completed work packages or by observing the maintenance, the inspectors noted that the mechanics had to overcome numerous obstacles in order to perform the maintenance on the check valve Many of the following obstacles occurred during the backshift and resulted in delays:
The scope of the maintenance on l-SI-147 was to inspect the valve internals. The original WO for this maintenance stated that the valve could be opened but not disassemble In order to inspect the internals the valve had to be disassemble Mechanics had to resubmit the WO to planning for revision in order to continue the maintenance after the valve was opene Mechanics had to obtain a written transmittal from maintenance engineering specifying the required body to bonnet torque value Torque values were typically not specified in procedure The label on the blueing compound stated that the compound was not allowed for use inside the RC The maintenance foreman had to contact procurement engineering in order to get permission to use the blueing compound inside the RC The inspectors accompanied a lead mechanic preparing to work l-Sl-147. The lead mechanic had spent approximately four hours preparing for the job. During a RP briefing it was identified
that the mechanics would have to wear special dosimetry and that the lead mechanic could not obtain special dosimetry because his NRC Form 4 was not signed. Since it was the backshift, the lead mechanic's NRC Form 4 was not available for signature and another mechanic had to be obtained and briefed in order to assume responsibilities as lead mechani The PMT sheets contained VT inspection requirements that were not specified in procedure O-MCM-417-2 Special qualifications were required to perform VT inspections. The mechanics reviewed procedure O-MCM-417-25 and did not identify the need for VT requirement Later it was identified that the PMT specified VT inspections and special arrangements had to be made to ensure that qualified VT personnel were available when neede Although it was acceptable to specify VT inspection requirements on the PMT sheets, it made job planning more difficult since different documents needed to be reviewed to determine job scop Maintenance personnel performing accumulator check valve maintenance were knowledgeable and skilled. Also, the support provided by RP personnel during this maintenance was goo However, maintenance personnel had to overcome numerous obstacles in order to perform the check valve maintenanc These observations were provided to managemen Unit 1 Voltage Regulator Repairs During the previous operating cycle both units experienced problems with the main generator voltage regulato One of these voltage regulator problems resulted in a unit trip. During this Unit 1 RFO, the licensee initiated repairs to the system to improve reliability and reduce the probability of a unit tri During the shutdown special testing was conducted to identify desired repair The repair work was performed using WO 272585-0 The inspectors reviewed the repair activities and held discussions with the Electrical Maintenance Supervisor. The repairs consisted of 1)
removing and refurbishing 12 electrical modules, 2) replacing and calibrating the M300 isolation transducers, 3) replacing selected power supplies because of overheating, 4) replacing selected relays, and 5) installing test jacks on the panel fronts to facilitate on-line equipment performance monitoring. The repairs listed above should improve equipment performance and reliabilit Aluminum Bronze Valve Replacements On October 12, 1993, the licensee documented a condition where SW was seeping through several cast aluminum bronze valves. This issue was documented in NRC Inspection Reports Nos. 50-280, 281/93-24 and 93-26. Twenty valves per unit were replaced with spool pieces or cast stainless steel valve With the Unit 1
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valve replacement completed this inspection period, all the effected valves have been replaced on both units. The inspectors performed a walkdown of the Unit 1 and 2 SW to charging pump systems and verified that all of the valves were replaced with either spool pieces or cast stainless steel alloy CFS valves (316 stainless steel}. Twenty-two valves total for both units were replaced with spool pieces (90-10 copper-nickel} and 18 were replaced with stainless steel valve When this condition was discovered, justification for continued operation documents were written for both units. The inspectors reviewed the closeout for JCO C-93-004, Continued Operation with Through Wall Leakage of Charging SW System Valves, revision No discrepancies were identifie Within the areas inspected, no violations or deviations were identifie.
Surveillance Inspections (61726)
During the reporting period, the inspectors reviewed surveillance activities to assure compliance with the appropriate procedure and TS requirement Unit 1 LHSI System Testing On February 6, the inspectors witnessed the licensee performing l-OPT-SI-002, Refueling Test of The LHSI Check Valves to The Cold Leg This test inspects for external SI system leakage when the system is pressurized, verifies that SI cold leg and LHSI pump suction check valves travel to their full open position, and flow tests the LHSI pump SI MOV differential pressure testing was also performed during the test. The inspectors attended the pre-job brief and observed test performance from the control roo The inspectors noted that system engineering and operators shared responsibilities in directing this test. It was evident that personnel were prepared to perform the test and that the actual testing was accomplished utilizing good command and contro Attachment 2 to the procedure provided acceptance criteria in the form of a graph of RWST level versus LHSI flow rate. During the test, both LHSI pumps flow rates were below the minimum specified in the procedure's acceptance criteria. The flow rate for 1-SI-P-lA was 3171 gpm versus a required flow rate of 3290 gpm and the flow rate for 1-SI-P-lB was 3186 gpm versus a required flow rate of 3285 gp DR S-94-311 was submitted as a result of the lower than acceptable flow rate The inspectors reviewed the licensee's evaluation of DR S-94-31 The evaluation stated that the minimum acceptable LHSI pump flow rate was 3060 gpm when obtaining flow rates from the ERF compute A flow rate of 2970 gpm at 100% level in the RWST and O RCS pressure was required to meet calculated PCT requirements and an
additional 90 gpm was required to account for accuracy of flow data obtained from the ERF compute The evaluation also concluded that LHSI pump performance was not degrading and that the lower than expected flow rates during the test was attributed to the cavitating venturies restricting flo Discussion with the system engineer stated that the acceptance criteria in l-OPT-SI-002 would be revised to more accurately indicate the required flow requirement The inspectors reviewed the licensee's April 19, 1993, letter to the NRC which provided a revised PCT based on minimum LHSI flow rates of 2970 gp The inspectors concluded that the Unit 1 LHSI test results exceeded the minimum 2970 gpm requirement after factoring in instrument inaccuracies and were therefore acceptabl The inspectors also reviewed the Unit 2 LHSI pump flow test results obtained during the 1993 spring RFO and concluded that the flow rates were acceptabl Testing the Unit 1 A IRS Pump_
On February 14, the in~pectors observed the licensee testing the A IRS pump in accordance with procedure l-OPT-RS-003, Flow Test of Inside Recirculation Spray Pumps 1-RS-P-IA and l-RS-P-18, revision 3-Pl. The test provides full flow testing and verifies pump operabilit The inspectors reviewed the procedure and observed the pretest briefing. A special dike was erected to provide water to the IRS pumps and a special piping spool piece was placed in the flow*path so that the pump would full flow test. The inspectors observed part of the test from the control roo The total pump head and the pump vibrations met acceptance criteri No discrepancies were identifie Within the areas inspected, no violations or deviations were identifie.
Review of Plant Modifications (37828}
The inspectors monitored the licensee performing DCP ~2-043, Pressurizer Safety Valve and Loop Seal Modification - Surry Unit I. This modification installed drain lines o~ each PSV loop seal and on the common PORV loop seal, installed new PSVs, and replaced the loop seal ovens with removable reflective insulation pad The modification changed fluid conditions from water to steam in the piping upstream of the PSVs and PORV One objective of this modification was to reduce leakage past the seats of the PORVs and PSV Leakage past the PORV and PSV seats has previously created operational problems in both unit This same modification is scheduled to be accomplished in Unit 2 during the upcoming fall RF The inspectors walked down this design change after completion and verified that the loop seal drain lines were installed in accordance
- with the installation drawing The inspectors also reviewed SE 93-176 for the design change; reviewed the new PSV setpoint test results contained in Crosby test procedure T-16679, revision 3; verified that the control room drawing 11448-FM-0868 was updated; observed portions of the installation of loop seal drain lines and PSVs; verified post modification test requirements were adequate; and verified that operator v training on the modification prior to startup of the unit was schedule No discrepancies were identified. The inspectors noted that this design change was completed with minimum revisions or installation problems, and concluded that the engineering support for the modification was a strengt.
Refueling Activities (60710)
The inspectors witnessed the reactor head lift and reactor cavity floodu The personnel involved with the evolution were familiar with their job assignments and performed in an efficient manne There was one difficulty observed associated with threading the lifting pin bolt into the shackl Based on discussions with personnel involved this appeared to be a recurring proble The remainder of the evolution went smoothly with the worker on the head receiving less radiation exposure than expected primarily due to the pre-evolution briefing and his experienc Prior to the head lift, the inspectors verified that containment integrity was established. This was accomplished by reviewing procedure l-OPT-CT-210, Containment Integrity, and the associated tagout, and a walkdown of seletted containment penetration On February 28, the inspectors reviewed the containment integrity procedure and tagout prior to commencement of the core on-loa Walkdowns of selected penetrations were also performed with no discrepancy note Core on-load commenced on February 2 On March I and 2, the inspectors observed the licensee loading fuel elements into the following core locations: G-7, H-7, H-8, J-7, J-8, J-9, H-7, H-8, K-11, K-12, K-13 and K-1 The core on-load was controlled by procedure l-OP-FH-001, Refueling Operations, revision This operating procedure was supplemented by the cycle 13 core on-load instructions Sl-OP-94-17 which specified the elements' core location The inspectors verified that after eight elements were loaded into the core, source range instruments were being monitored in the control room as required by TS 3.10.A.3. Additionally, the inspectors reviewed the 1/M reactivity plot that was being performed in the control room as required by step 5.22.3 of procedure l-OP-FH-00 No discrepancies were identified. The inspectors noted that the refueling crew's performance was good with everyone working together as a tea Within the areas inspected, no violations or deviations were identifie ~
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- Exit Interview The inspection scope and findings were summarized on March 8 and 31, 1994, with those persons indicated in paragraph The inspectors described the areas inspected and discussed in detail the inspection results addressed in the Summary section and the item listed belo Item Number URI 50-280, 281/94-06-01 Status Open Description/(Paraqraph No.)
Not Performing a SE For Administrative Control of l-FP-1052 (Paragraph 3)
Proprietary information is not contained in this report. Dissenting comments associated with the URI were received from the licensee and are described in paragraph.
Index of Acronyms and Initialisms ALARA -
ASME -
ECG ERF GPM IRS JCO LHSI -
RWST -
UFSAR -
URI VT WO AS LOW AS REASONABLY ACHIEVABLE AMERICAN SOCIETY OF MECHANICAL ENGINEERS CODE OF FEDERAL REGULATIONS DESIGN CHANGE PACKAGE DEVIATION REPORT EMERGENCY CORE COOLING SYSTEM EMERGENCY DIESEL GENERATOR EMERGENCY RESPONSE FACILITY GALLONS PER MINUTE INSIDE RECIRCULATION SPRAY JUSTIFICATION FOR CONTINUED OPERATION LOW HEAD SAFETY INJECTION MOTOR OPERATED VALVE NUCLEAR REGULATORY.COMMISSION PEAK CLAD TEMPERATURE POST MAINTENANCE TEST POWER OPERATED RELIEF VALVE PRESSURIZER SAFETY VALVE RADIOLOGICAL CONTROL AREA REACTOR COOLANT SYSTEM REFUELING OUTAGE RADIOLOGICAL PROTECTION RECIRCULATION SPRAY HEAT EXCHANGER REFUELING WATER STORAGE TANK SAFETY EVALUATION STEAM GENERATOR SAFETY INJECTION SERVICE WATER TECHNICAL SPECIFICATION TECHNICAL PROCEDURES UPGRADE PROGRAM UPDATED FINAL SAFETY ANALYSIS REPORT UNRESOLVED ITEM VISUAL TEST WORK ORDER