IR 05000338/1992023
| ML20127D592 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 12/11/1992 |
| From: | Fredrickson P, Lesser M, Taylor D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20127D561 | List: |
| References | |
| 50-338-92-23, 50-339-92-23, NUDOCS 9301150293 | |
| Download: ML20127D592 (18) | |
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.hg NUCLEAft REGULATORY COMMISSION 3 o HIGION il
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101 MARIETT A $1HE ET, ATL ANTA, G(oRGIA 30373 k ** ..+ /
Report tios.: 50-338/92-23 and 50 339/92-23 i Licensee: Virginia Electric & Power Company 5000 Dominion Boulevard Glen Allen, VA 23060 Docket Nos.: 50-338 and 50-339 License Nos.: HPF-4 and NPT-7 facility Name: North Anna 1 and 2 Inspection Conducted: October 18 - November 21, 1992 Inspectors: I .// D u/v//2 M.S. Less'e6/ Senior Resident inspector Date signed h fdf ?W D.R. laylopptesident inspector n/n/9 Date Signed Accompanying Inspector: A. B. Ruff Approved by: ]g P.L. Fredrickson, Sectiorf Chief Date Signed Division of Reactor Projects t
SUMMARY
- l Scope:
This routine inspection by the resident inspectors involved the following '
t areas: operations, minor modifications, maintenance, surveillances,-
engineered safety ft..ture walkdown, licensec event report followup, action on previous inspection findings and licensee evaluation of changes. Inspections
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j of licensee backshift activities were conducted on the following days:-
October 31, November 3 and 1 Results:
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In the area of Safety Assessment / Quality Verification, the'llcensee has not maintained a program to thoroughly evaluate changes to the environs for -
potential hazards. The licensee, however, is in the 3rocess of developing a *
program and will update Chapter 2 of the UFSAR when tie review is complete (para'10).
In'the area of operations, the licensee investigated and resolved an issue where the EDG governor load limits were found incorrectly adjusted. - The <
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licensee was able to prove that the EDG's remained operable and completed l -enhancements to preclude repetition (Para 3.c).
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In the area of engineering / technical support, the licensee demonstrated a high degree of commitment to resolve time response problems with the turbine drive AfW pumps. The governors were modified to change the ramp acceleration time from 30 seconds to 15 seconds (para 4.a).
In the area of maintenance, the licensee's overall planning and execution of the turbine trip valve repair was excellent. All aspects of plant and personnel safety were thoroughly considered to allow the work to be performed on-line (para 5.c).
In the area of surveillance, the licensee's ongoing surveillance review identified inadequate testing associated with the automatic AFW pump start circuitry. A temporary waiver of compliance was approved by the NRC to exempt testing on Unit I until the next shutdown (para 6.a).
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REPORT DETAILS Persons Contacted Licensee Employees L. Edmonds, Superintendent, Nuclear Training
- R. Enfinger, Assistant Station Manager, Operations and Maintenance J. Hayes, Superintendent of Operations D. Heacock, Superintendent, Station Engineering
- G. Kane, Station Manager
- P. Kemp, Supervisor, Licensing B. McBride, Station Coordinator Emergency Planning W. Matthews, Superintendent, Maintenance
- J. O'Hanlon, Vice President, Nuclear Operations D. Roberts, Supervisor, Station Nuclear Safety R. Saunders, Assistant Vice President,. Nuclear Operations D. Schappell, Superintendent, Site Services R. Shears, Superintendent, Outage and Planning
- J. Smith, Manager, Quality Assurance A. Stafford, Superintendent, Radiological Protection J. Stall, Assistant Station Manager, Nuclear Safety and Licensing Other licensee employees contacted included engineers, technicians, operators, mechanics, security force members, and office personne NRC Resident inspectors M. Lesser, Senior Resident inspector D._ Taylor, Resident Inspector
- Attended exit-interview Acronyms and initialisms used throughout this report are listed in the last paragraph, Plant Status
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Unit 1-is approaching end-of-core life-and continued to operate in-coastdown, ending the period-at 55% power. Unit 2 operated the duration of the inspection period at 100% powe . Operational Safety Verification (71707)
The inspectors conducted' frequent visits to the control room to _ verify proper staffing, operator attentiveness and adherence to approved procedures. The inspectors-attended plant status meetings and reviewed operator logs on a daily-basis to verify operational _ safety and compliance with TS and to maintain awareness.of the overall operation of
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the facilit Instrumentation and ECCS lineups were periodically reviewed from control room indications to assess operability. Frequent plant tours were conducted to observe equipment status, fire protection programs, radiological work practices, plant security programs and housekeeping. Deviation Reports were reviewed to assure that potential safety concerns were properly addressed and reported. Selected reports were followed to ensure that appropriate management attention and corrective action was applied, Missed Fire Hose Station Inspection During a plant tour on October 20, the inspectors identified that the fire hose inspection station, T-H-22E, in the Unit 2 Service _
Building walkway, had not been inspected for the months of September or October. Monthly inspections are indicated on a tag attached to the hose station. This was reported to the Shift Supervisor and OR N-92 1995 was written to resolve the concer The inspectors determined that associated procedure 2-FMP-2.2, which inspects service, turbine, and diesel building fire protection equipment, was completed on September 25. However, an existing PAR, which had previously changed the procedure, was not attached to the core procedure thus causi y the inspections to be misse The licensee immediately inspected 'he equipment and found no deficiencies. The inspectors verified tyt. tha eouin%.A in question was not listed in Table 16.2-3 of the UFSAR which establishes the minimum surveillances required by the fire protection program and, therefore, the error had minimal regulatory significance. The inspectors noted that the PAR was approximately 2 years old and had not been incorporated into a revised version of the procedure. The licensee has been successful in reducing the PAR. backlog in other departments, however, had not placed high priority on fire protection procedures and this appeared to contribute to the erro Following this incident, the licensee initiated action-to improve the fire protection procedure Protected Area Lighting-Survey On November 3, the inspectors conducted a backshift-inspection and observed a security officer perform a lighting survey of the protected area roof tops A calibrated meter was used t determine foot candles of light at various points. The officer noted several inoperable lights and appropriately took additional readings in affected areas. One particular area was noted to have-5 inoperable lights. The security officer took several readings in that area but did not initially recognize that they were below the minimum acceptance criteri Review by the supervisor identified the deficient condition and appropriate compensatory measures were ordere _ _ _ _ __ . _ _ _ _ _ . .
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The inspectors reviewed several surveys from previous weeks and determined that lighting in this particular area has been acceptabl c. EDG Load Limit Settings found Mispositioned On October 21, the licensee tested the IH ED During the test, lubrication oil, which had leaked onto the turbocharger inlet insulation, ignited and was immediately extinguished by operators running the engine. The operators described the flame as minor and there was no need for the fire brigade to respond. The licensee completed the test with no other problems. The licensee identified the leak to be from a ccver gasket on the front of the engine. Interim corrective action was to replace the oil-soaked insulation, install a covering on the insulation and retorque the front cover bolts. The licensee replaced the insulation on all EDG's. The long term repair will be to change the cover gasket during the next refueling outag On November 10, the licensee identified that the Unit 2H and J EDG governor load limit knobs were not at the " maximum fuel" settin The licensee conservatively declared both EDG's inoperable, entered the action statement of TS 3.8.1.1.e, and immediately re-positioned the knobs correctl The load limit acts as an internal governor mechanical stop to limit fuel rack movement. The licensee did not know at what specific setting fuel rack movement is inhibited, thus the conservative declaration of inoperabilit The inspectors reviewed the circumstances of the event. EDG room entry records were reviewed by both the licensee and the inspectors. It was concluded, most likely, that the EDG insulation workers inadvertently moved the knobs while conducting wor The load limit setting is verified by an operator once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The licensee was able to identify through record review and personnel interviews when it was last observed to be in the correct setting. The total time between the last verification anc identification of the incorrect setting was estimated to be 5-6 hours. The licensee did not consider the event to be reportable because it was within the TS time limits for having both EDG's inoperable. The inspectors questioned this because the plant had been in a condition outside the design basis. The licensee re-evaluated the reportability aspect and on November 12, reported the event to the NRC in accordance with 10 CFR 50.7 On November 13, the licensee performed a test to identify the specific load limit setting which actually renders the EDG's inoperable. With the 2H engine not running, the fuel rack was manually moved to the " maximum fuel" position. The load limit knob was then adjusted until the fuel rack started to move toward the " minimum fuel" position. The setting was observed to be more
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limiting than the November 10 settings, which proved that the 2H EDG was operable during the November 10 event. On November 16, the licensee withdrew the 10 CFR 50.72 notification. The licensee intends to perform a similar test on the 2J ED The inspectors verified that the licensee has adequate training in place to ensure that personnel are trained to reduce the ,
possibility of bumping or contacting. safety related component Following this incident, the licensee installed protective plexiglass covers over the face of the governor. With the exception of the initial determination of reportability, the inspectors considered the licensee's investigation and resolution of the issue to be goo Auxiliary Shutdown Panel Instr- -
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The inspectors reviewed DR ' cumented failure of LI-1477B, auxiliary shutdow n SG wide range level to meet acceptance criteria of 1-PT- .., Auxiliary Shutdown Panel Monitoring Instrumentation Check. The licensee appropriately-entered the 30 day action of TS 3.3.3.5 as a resul The surveillance checks the auxiliary shutdown panel monitoring channels for proper operation by comparing in';trument readings on the panel to other instrument readings measuring the same parameter. The wide range SG level on the auxiliary shutdown panel is compared to control room-narrow range level readings. To make the comparisons, calculations are performed to convert the narrow range to an equivalent wide range level. If the two values are within 5% of each other, the test is considered satisfactor For the test performed on November 14, the levels were just over the 5% tolerance. To correct the problem, the licensee-refined their calculations. Specifically, correction factors based on S pressure were revised to make the increment for pressures smaller therrbj alving a more accurate assessment of actual condition The irsrctors i discussed the old and revised. calculations with the-licesse. Following a change to the procedure on November 18, the PT was re-performed satisfactory and the action statement cleare No violations or deviations were identifie . Minor Modifications (37828) Turbine Driven AFW Pump Governor Modifications The inspectors reviewed DC 92-315 associated with governor modification-for the Unit 2--turbine driven AFW pump. The new *
governor was installed on October 19 after time response--testing
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of the existing governor failed its acceptance criteria to reach rated conditions within 57 seconds. :The licensee had recently- ~
!dentified time response problems with the existing governor and
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had been testing the pamp on an increased frequency to assure operability (IFI 50-339/92-18-01).
The existing Woodward Model PG-PL governor was supplied with a 30 second ramp rate bushing to control turbine acceleration. This feature n s added in 1990 to prevent turbine overspeeds and piping over pressurization which resulted from fast starts. The ramp rate bushing has a 0.031-0.034 inch orifice to control hydraulic oil flow, gradually bringing the turbine up to speed in 30 seconds. DC 92-315 modifies the ramp rate bushing to 15 seconds by changing the orifice size to 0.045-0.049 inc Post modification testing showed the turbine to start up on its first attempt in 27.7 second The licensee bench tested this governor at the vendor's facility the previout e . Test results and recent licensee experience show that N -m" starts result in quicker response times. The longer times for " cold" starts appears to be related to the effects of ambient temperature steam supply piping and the resultant pressure loss as steam condense The new governor has resulted in faster starting times. On October 26, a modified governor was installed on Unit 1 and successfully tested. " Cold" start tests were performed two weeks later on each unit to verify the adequacy of the modificatio The inspectors noted a high degree of management commitment to resolve the time response concern Service Water Restoration Project (DC-91-009-1)
Due to continuing problems with piping corrosion, the licensee is planning to perform extensive restoration and refurbishment activities on certain portions of the SW System during the Unit 1 refueling /SGRP outage commencing January 2, 199 The inspectors reviewed the DC, the safety evaluation and attended various meetings on the subject and will monitor and inspect licensee ;
project implementatio The initial scope of the project, (Phase I, Stage 1) involves refurbishment of approximately 800 linear feet of 24 inch concrete encased piping and replacement of approximately 160 linear feet of buried piping. Phase I of the project will continue through several refueling outages into 1995 and ultimately Nill involve 1500 feet of encased piping and 600 feet of replacement pipin During the upcoming outage, the licensee will accomplish the work as follows: Excavation of buried piping will begin approximately 1 month before the outage. The licensee has requested an exemption from the requirements of GOC-2 (Design basis protection against natural phenomena) in order to perform thi __ .___-_--,_.,,___m ___ _- - _ _ _ . __ __-__m
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l 6 The licensee will use the Action Statement of TS 3.7.4.1 to remece headers from service one at a time, in order to weld plugs in the lines to isolate Unit 2 loads from Unit The TS allows up to 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br /> of outage time for major repairs to the system. The action statement will be entered 6-times during the course of the refueling outage to install, relocate and remove plug . The licensee also requested exemption from 10 CFR 50.49, Environmental Qualification of Equipment, regarding the Unit 2 Control Room chillers. The chillers' qualification relies on the availability of backup chillers (Unit I control room chillers) which will not have a saurce of SW during the projec . The piping to be refurbished will initially be cleaned by abrasive blastin . A combination of visual, mechanical and UT inspections will be performed to assess the condition of the pipin . Pitted areas requiring base metal repair will be filled by weldin . l.ess significant pits will be filled with epoxy patch compoun . Two coats of 100% solids epoxy coating will be applied over the pipin . Piping to be replaced will be cut out a:.d new piping welded into place. The new piping will also be coated with protective epox The licensee's submittal includes several proposed contingency and compensatory measures to reduce the possibility of construction mishaps and minimize the consequences of postulated accident The licensee also included in their submittal, the results of a PRA to which determined the core damage frequency from loss of SW scenario . Maintenance Observation (62703)
Station maintenance activities were observed / reviewed to ascertain that the activities were conducted in accordance with approved procedures, regulatory guides and industry codes e standards, and in conformance with TS requirement EDG Fuel Injection Pump Replacement On October 28, the licensee removed the 2H EDG from service for various maintenance activities including engine coolant changeout
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in preparation for winter. Following completion of the work, the !
engine was run for a post-maintenance checkout. Fuel oil leaks- :
were_ observed by the. licensee around the number one cylinder fuel l injection pump. The inspectors witnessed subsequent fuel j injection pump replacement _under work order 5900154849 on October j 30 Initial plunger stroke measurements were out-of tolerance and l required the removal of a shim. Following this, the engine was tested satisfactoril LHSI Relief Valve Gag The inspectors reviewed licensee corrective actions following a LHSI pump test oc October 13 where discharge relief valve 2-SI-RV-28458 lirted and failed to fully resea The peak >
pressure during the test was 345 psig while the relief valve leaked about 1-2 gpm until the pump was secured and pressure dropped below 173 psig. The inspectors have documented chronic problems with LHSI system pressure surges as indicated in URI 50-338/91-22-0 Relief Valve 2-SI-RV-2845B is a valve common to both trains of LHSI; therefore, isolation and repairs could not be performed without rendering the-system inoperable. Since there is one additional relief valve on each train, the licensee impl_emented .
Temporary Modification N2-92-1027 to take credit for these and gag _
shut 2-SI-RV-2845B. This would eliminate the adverse-consequences of a radioactive release if 2-SI-RV-2845B failed to shut until repairs could be mad The inspectors reviewed JC0 92-06 and its associated safety-evaluation for adequacy. The three relief valves are installed to .
protect piping-from over pressurization-from the-reactor coolant system via check valve back leakage. The' licensee's JC0 requires-that an open path be maintained to either one of th).other two relief valves, 2-SI-RV-2845A or C via Cold leg Injection M0V's 2-SI-M0V-2864A or B. .These MOV's . are normally open and-would only be closed following an accident and a safety injection realignment
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to hot leg recirculatio Since the reactor-. coolant system would-be depressurized at that point, a relief _-valve would not_ be neede The inspectors considered the licensee's safety evaluation to.be acceptable, however, noted that this latest problem istyet another consequence'of continued challenges to the LHSI relief' valves due_- -
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to pressure spikes and inadequate venting. Previous problems-hav i included stuck open relief valves due to improper blowdown ring -
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settings-and a cracked vent line due to excessive-pipe. movement, Turbine Throttle Valve Repair During the last inspection period, report. 50-338,339/92-22,the licensee requested and was granted by.NRC, a one time-waiver to.
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exempt the testing requirements of TS surveillance 4.7.1.7.2. The waiver exempted testing throttle valves 1-MS-TV-1 and 1-MS-TV-3 due to 1-MS-TV-1 failing in the closed position. The waiver allowed the licensee to complete their planning effort in order to repair the valve. On October 27, after extensive planning, the~
licensee began the repairs. The inspectors attended the pre-job briefing and followed and observed the maintenance. Adequate precautions were taken which included the contingencies in case-of EHC isolation valves leaking. Leak by of the isolation valves had the potential to cause a loss of EHC to the other throttle valves and subsequently cause a turbine trip. The valve was removed by disconnecting the valve actuator and spring housing from the
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linkage support and moving the assembly to a suitable work area on -
the turbine deck. Upon valve disassembly, the licensee discovered that the upper knuckle was not torqued to the actuator shaft and a spacer located between the connecting rod and valve link did not fit into a rabbit-fit of the link as require The licensee indicated that this may have contributed to the valve's failur During reassembly, difficulty was experienced in fabricating a new spacer of correct size. The spacer size was critical because it effected both pin alignment and dashpot setting, These two attributes had tight tolerances and changing the spacer size to meet dashpot setting adversely affected pin alignment. However, the licensee had anticipated this problem and after several attempts a spacer sizing was fabricated which allcwed both tolerances to be me .
On October 31, after completing repairs, the valve was returned to service and TS surveillance- 4.7.1.7.2 was successfully ' completed for 1-MS-TV-1 and 1-MS-TV-3. The inspectors considered the overall planning-and execution of the maintenance to be excellen The procedure worked well and the coordinated effort of the disciplines involved with the maintenance _was good, Freeze Seal Isolation for 1-CC-458 On November 5, the inspectors observed the licensee apply a freeze seal to a 12 inch component cooling water pipe in _ order to isolate the system to repair seat leakage for manual valve 1-CC-45 Maintenance Engineering coordinated the effort using HMP-C-FS-2, Freeze Seal Isolation Using Freeze ' Seal Engineering. _This procedure uses the vendor, Freeze Seal Engineerirg, to establish e and maintain the seal. Liquid nitrogen was supplied from a large-
- tank which was towed to the site by truck. The capacity was L
adequate' to establish and maintain the seal for approximately two days.
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written contingency plan which included afequate steps to prevent flooding _ in the event of a failed . seal . The Woectors also verified that the freeze-seal chamber temperaLc e and nitrogen pressure were recorded at 15 ~ minute intervals.
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Upon valve disassembly, the disc of 1-CC-458 was observed to be gouged due to possible misalignment with the seat. An attempt to lap the disc was unsuccessful and a new disc was machined. The evolution was accomplished safely with good management involvement and oversigh Cold Weather Preparations The inspectors reviewed portions of the licensee's preparations for cold weather. The program is implemented in the form of PM's to check out the operation and adequacy of various equipment such as heat tracing, ventilation, space heating, pipe insulation and doors. EDG engine coolant is also changed to add an antifreeze solution. The inspectors verified that the PM's had been scheduled and complete The inspectors reviewed a QA assessment of the progra No significant problems were identifie No violations or deviations were identifie . Surveillance Observation (61726)
The inspectors observed / reviewed TS required testing and verified that testing was performed in accordance with adequate procedures, that test instrumentation was calibrated, that LC0's were met and that any deficiencies identified were properly reviewed and resolve AFW Pump Start Circuit Time Response Testing On October 21 at 12:45 pm, the licensee determined that time response surveillance testing on portions of the Unit 1 AFW Pump automatic starting circuit was not properly conducte Specifically, the automatic start relays associated with " station blackout" and " main feed pump trip" had not been time iesponse tested to function in s 60 seconds as required by 18 month TS surveillance 4.3.2.1.3. The licensee entered the 24 action statement of TS 4.0.3 and successfully completed testing of the
" station blackout" relays later in the da However, the licensee identified concerns with safely testing the
" main feed pump trip" relays while at power. In order to prevent a main turbine trip during the test, electrical leads would need to be lifted and subsequently landed, The licensee considered that an error or arc on the contacts during this evolution represented a potential for a turbine trip and resultant reactor tri The licensee, therefore, requested a one time temporary waiver of compliance to exempt the need to time response test these relays until the end of the Unit 1 operating cycle on January 2, 1993. The basis for the waiver included the following aspects: AFW start on " main feed pump trip" is anticipatory and not
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relied upon in the accident analysis. Steam generator low-low level will also cause an AFW star . The relays were functionally tested (although not timed) in March 1991 during the 18 month test. The inspectors reviewed 1-PT.71.4, AFW Pump Time Response and Logic Test, to verify thi . The unit currently is at 70% power in coastdown, significantly below its full power ratin . The HFA relays are historically reliable and are used throughout the plant. The licensee was abic to review the plant events records for an August 1991 safety injection and determined that at least one train of relays actuated well within the response time acceptance criteri The inspectors reviewed the licensee's actions. The licensee has been involved in an extensive and detailed review of surveillances for several months due to NRC concerns regarding surveillance test adequacy. This review to date has identified numerous examples of improper overlap or inadequate testing (URI 50-339/92-04-03).
Subsequent to identification of each example, the licensee appropriately tested the component and reported the event to the NR This particular concern with the AFW start relays was identified several months ago and the respective Unit 2 circuits were tested as the unit was in a refueling outage. The licensee recognized the lack of time response test data on Unit 1 at the time; however, inappropriately considered that the surveillance could be met. This was based upon the logic that it would be reasonable to assume that a test engineer would have identified a
"significant" time delay during functional testin However, the licensee subsequently questioned this as a weak argument following recent concerns with turbine driven AFW pump governor time response (para 4.a).
The NRC approved the licensee's waiver of compliance, however, required that an emergency TS change be processed. The licensee subsequently submitted the TS change on October 26, 199 Relay and Breaker Testing On October 28, the inspectors witnessed electrical testing for the Unit 2 A RHR pump. The licensee used 2-PT-84.10, Channel Calibration and Integrated System Functional Test of Protective Relays for Breaker 25H14, to perform the testing which satisfies in part TS surveillances 4.8.2.5.a.1 for containment penetration conductor overcurrent protection. The procedure tested the setpoints for overcurrent protective relays and functionally verified operation of the circuit breaker from the relays and from both the control room and the 10 CFR 50 Appendix R switch. The i
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procedure had recently been upgraded and thoroughly tested the equipmen , IJ EDG Fast Start On November 4, the inspectors observed the performance of 1-PT-82.2B, IJ Diesel Generator Test (Simulated Loss of Off-Site Power). The test demonstrates the availability of the IJ EDG to l
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reach TS required conditions of 900 rpm, 4160 1 420 volts, and 60 t 1.2 Hz within 10 seconds. Further, the EDG is loaded to 2500-2600 KW within 60 second No performance problems were identified with the test and operators and technicians exhibited good self check practices. However, prior to test performance, operators were required to PAR the procedure because a previous:
revision to the procedure had failed to adequately review changes that were made to insure the procedure would work as written. The inspectors considered the pre-evolution review by operators to be a good practice, but questioned how often PARS were required _ prior-to test performance. Based on conversations with operators and and because the inspectors have noted an improvement with procedure quality in general, no concerns resulted, Steam Dump functional Check On November 10, the inspectors observed the performance of 1-IPM-MS-T-408, Rev 1, Functional Check of Condenser Steam Dump-System. The test was developed in response to a September 20, 1991, reactor trip and safety injection and is performed on a six month basis. The procedure verifies that all of the. steam dump valves will cycle or trip-open when a simulated signal is provided-to the controlling circui Prior to the functional check, the steam dump isolation and bypass valves were shut to Isolate steam to the valves being tested. -The operators and: instrument technicians performing the test were cautious when performing = .,
iteps that had the potential' to.effect plant parameters and communications were good. No concerns were identifie . ESF System Walkdown (71710)-
The inspectors performed a wa_lkdown of the EDG fuel oil system.for both-units. The inspectors referred to drawings 11715-FB-035A and procedures 1(2)-0P-6.8A, Valve Checkout-Emergency Generator Fuel- System and 1-0P-53.lA, Valve ~ Checkoff-Fuel Oil Storage and Transfer.- The material-
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condition of the system was very good with very few outstanding work requests. The components were clearly labeled. Some minor-inaccuracies-such as improperly depicted valve positions were noted.on drawing These discrepancies were forwarded to the licensee-for resolutio _,
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The inspectors reviewed testing of the system and determined the following: The fuel oil transfer pumps are included in the IST program, however, are not flow tested due to a lack of instrumentation. In-its September 18, 1991 letter to the NRC, the licensee committed to installing flow instrumentation by March 31,-199 , Procedures are adequate to verify the fuel oil transfer pumps function in accordance with TS 4.8.1.1.2.a, ' The licensee is adequately sampling the fuel oil to verify that chemistry parameters are within specification in accordance with TS 4.8.1.1. . Procedures are adequate to verify fuel oil supply check valves are periodically verified to partially stroke open in accordance with -
the IST progra , The last 10 year cleaning of the underground fuel oil storage tanks was properly performed in accordance with TS 4.8.1.1.4 in 199 No violations or deviations were identifie . LER Followup (92700)
The following LERs were reviewed and closed. The inspector verified; that repo'rting requirements had been met,-that_causes had been identified, that corrective actions appeared appropriate and that generic' applicability had been considered. Additionally, the inspectors confirmed that no unreviewed safety questions were involved and that
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violations of regulations or TS conditions had been identifie (Closed) LER 50-339/92-15: Missed Surveillance on the H 2System Trouble -
I or High Hydrogen Annunciator Alarm Due to Incorrect Relay Configuration-Following performance of a channel- calibration, _ the licensee determined that the main -control room annunciator for containment analyzer, .
2-46-H2A-201-1,'was inoperable due to relay CR-1 beingLincorrectl wired. The wiring deficiency resulted in blocking the< actuation of the control room annunciator. This relay was determined to have been miswired during repl_acement of the relay in August of_1989.-- This item had-not been previously identified because-the calibration procedure was To correct the condition, the-licensee rewired the. relay,
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inadequat performed a channel calibration, revised the procedure and discussed the:
item with I&C personnel. The inspectors reviewed this item at the time-of--its occurrence and determined that a high hydrogen condition _would
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most likely have been identified by observing hydrogen. concentration gages. No safety concerns were identified.
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, Action on Previous Inspection items (92701, 92702) (Closed) IFI 50-339/92-18-01: Response Trending of Turbine Driven AFW Pump Partial followup of this item was documented in Report 50-338,339/92-22. The licensee determined that its time response testing of the turbine driven AFW pump was not an adequate as-found test because the steam admission piping was warm and not representative of the typically cold pipe temperatures. This caused initial steam flow on " cold" starts to condense and a much longer time for the turbine to accelerate to rated speed. The licensee modified the turbine governors as discussed in paragraph (Closed) URI 50-339/92-17-03: Valve 2-SI-3778 Weld Failure The concern involved repetitive weld failures on this particular i inch tubing and the licensee's threshold for performing a detailed evaluation of such failures. The licensee added a note to maintenance procedure 0-MCM-1801-01, Welding Safety Related and Seismic Related Equipment, to require a maintenance engineer to determine if a metallurgical examination on a failed weld is to be performed prior to repairs. The licensee also recently demonstrated heightened sensitivity by performing a cause failure analysis of a socket weld through-wall leak on a- 2 inch SW pipe to CH pump coolers. The leak was attributed to stress corrosion cracking resulting from a combination of excessive stress at a flanged joint, a susceptible material and a corrosive environment, (Closed) Violation 50-338,339/91-10 03: Failure to Meet Surveillance Requirements of-IST Program With Three Examples This violation involved failure to implement requirements of the IST program. To correct the three examples cited by the violation applicable procedures were changed and testing was completed. In-addition and as an enhancement to the IST program, a test procedure cross reference and an IST bases document was develope The cross reference data base pm ides a reference which matches a requirement for testing to a specific procedure which_ meets the requirement. The bases document was developed to facilitate proper identification and understanding of the IST program scop For each component which has the potential to fall into the program, an evaluation was' performed using_the crite.ia established in the bases-document and a determination was made as to whether the component requires testing under IS After the bases document was developed, the licensee compared the document with their current IST program document and identified-differences. The differences included initial and additional testing of components, and deletions to the program. The .
inspectors reviewed the components for which additional testing-
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was called for and questioned why these components were not tested as they were identified. Upon further discussion and review, the inspectors determined that the licensee had evaluated the additions, but had not prioritized implementation of each. The inspectors stressed the importance of timely review of each addition for compliance with ASME XI requirements. The licensee is working to implement a revision to the IST program which will-address these differences. An action plan for implementation is also being develope The inspectors concluded that the cross reference and bases documents are positive additions to the IST progra . Licensee Evaluations of Changes to the Environs Around Licensed Reactor Facilities (TI 2515/112)
When the management of a nuclear power plant facility made application for a license, the FSAR, the SERs based on the FSAR, and related technical information that was submitted to the NRC ware factors and commitments in support of that license application. Consistent with the State of Consideration accompanying the rulemaking of Section 50.71(e)
of Title 10 of the Code of Federal Regulations (10 CFR 50.71(e)),-
appropriate chapters of the FSAR, such as Chapters 2, 3, and 13, should be updated when.significant changes to the areas around the reactor site have occurred. Recent events such as discovery of new natural gas well at one facility or the proposed construction of an airport near another raise concerns that licensees may not be fulfilling existing requirements of 10 CFR 50.71(e) for evaluation of new hazards and updating the FSAR to accurately reflect the current site condition In accordance with the TI, the inspectors reviewed the issues discussed in Chapter 2 of the-North Anna UFSAR, such as'Section 2.1, Geography and Demography, which include exclusion area control, population areas within various radii of the site, transient population, and parks; and Section 2.2, Nearby Industrial, Transportation, Military Installatio As a result of this review the inspectors assessment is that the _
majority of the information in these sections are based on the licensing justification when the plant was licensed. Several of the discussions -
relating to population distributions discussed in these sections, are based on a 1970 Census, and projected transient population increase for the Lake Anna recreation area and a Disneyland style recreation and entertainment center (Kings Dominion) in Hanover Count The licensee's controlling procedure for updating the UFSAR is Nuclear--
Standard LINS-2802, Revision 1, dated April 17, 1992, Preparation and Control of UFSAR Updates. The review of this standard showed that th general requirements section states that UFSAR shall describe the current licensing basis and that changes to .the licensing basis'may-occur as. a result of NRC-issued. regulation, orders, amendments, or SER,.
or as a result of changes approved by SNSOC in accordance with 10 CFR
. 50.59 items. The general requirement section does not specifically address changes to the environs around the facility.
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15 4 Discussions with responsible licensing personnel indicated.that some of the information discussed in Chapter 2 of the UFSAR is current in their -
EP, which has been provided to the NRC. -As part of the-emergency 1 planning, the licensee contracted a reassessment of evacuation routes and this study reviewed and-included population data based on the 1990 population census and .the increase of transient population as a result >
of the Lake Anna recreation facility. -In part, as a result of the same NRC inspection at their Surry Plant (NRC Inspection Report 50 280,281/92-15 dated August 4,--1992), the licensee solidified their position to re-assess the Chapter 2 information and included it in phase 2 of their UFSAR quality review. The data in Chapter 2 will be evaluated as part of this review. It was anticipated that the necessary updating of information for this chapter would be implemented in 199 Pending this review by the licensee and further assessment by the NRC, this is identified as IFI 50-338,339/92-23-01, UFSAR Update Process for Non-Plant Type Modifications or Changes to the Environs on or Around the Facilit . Exit (30703)
The inspection scope and findings were summarized on November 25, 1992, with those persons indicated in paragraph-1. 'The inspectors described the areas inspected and discussed in detail the inspection results listed below. The licensee-did not identify as proprietary any of the material provided to or reviewed by the inspectors during this inspection. Dissenting comments were not received from the license Item Number Description and Reference IFI- 338,339/92-23-01 UFSAR Update Process- for- Non-Plant Type Modifications or Changes to the Environs on or Around the-Facility. (Paragraph'10)
1 Acronyms and Initialisms AFW Auxiliary Feedwater .
ASME- American Society of Mechanical Engineers CFR Code of Federal Regulations CH Charging DC Design Change DR Deviation Report ECCS Emergency Core Cooling System EDG_ Emergency Diesel Generator EHC Electro-Hydraulic Control EP Emergency Pla ESF Engineered Safety Features FSAR Final Safety Analysis Report GDC General Design Criteria
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-IFI Inspector Followup Item IST Inservice Testing JC0 Justification for Continued Operation KW Kilowatt LCO - Limiting Conditions for Operation LER Licensee Event-Report LINS Licensing Nuclear Standard LHSI Low Head Safety injection MOV Motor-0perated Valve NRC Nuclear Regulatory Commission PAR Procedure Action Request PM Preventive Maintenance PRA Probabilistic Risk Assessment ~
PSIG Pounds-Per Square Inch Gage-QA . Quality Assurance RHR Residual Heat Removal RPM Resolution Per Minute SER Safety Evaluation Report SG Steam Generator SGRP Steam Generator Replacement Program '
SNSOC Station Nuclear Safety and Operating Committee SW Service Water TI Temporary Instructions TS Technical Specification UFSAR Updated Final Safety Analysis Report URI Unresolved item UT Ultrasonic Test
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