ML18151A126
| ML18151A126 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 10/08/1987 |
| From: | Cantrell F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18151A125 | List: |
| References | |
| 50-280-87-21-EC, 50-281-87-21, NUDOCS 8710260417 | |
| Download: ML18151A126 (22) | |
See also: IR 05000280/1987021
Text
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UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, N.W.
ATLANTA, GEORGIA 39323
ENCLOSURE 1
Enforcement Conference Summary
Licensee:
Virginia Electric and Power Company
Docket Nos.:
50-280 and 50-281
License Nos.:
Facility Name: Surry 1 and 2
Approved By: ~~hief
SUMMARY
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DateSigned
Scope:
An Enforcement Conference was held in Region II on September 24, 1987.
Mr. M. L. Ernst opened the meeting by expressing concern with inadequate
surveillance testing of the emergency diesel generators and elimination of
turbine valve freedom testing described in the Surry FSAR without a 10 CFR
50.59 evaluation or NRR review.
Virginia Electric and Power Company then made
a presentation covering these two items including root cause, corrective
actions, and conclusions.
Enclosure 3 contains information from the
presentation.
Results:
The results of the NRC findings in this area will be forwarded under
separate cover.
--
REPORT DETAILS
1.
Attendees - see Enclosure 2
2.
Enforcement Conference
Mr. M. L. Ernst opened the meeting by expressing concern with elimination
of turbine valve freedom testing described in the Surry Final Safety
Analysis Report without a 10 CFR 50.59 safety evaluation or NRR review and
failure to perform a Technical Specific~tion required diesel generator
degraded/undervoltage survei 11 ance test.
Both issues are discussed in
Inspection Report 50-280,28l/87-21.
Mr. W. L. Stewart, Vice President,
Nuclear Operations, Virginia Electric and Power Company, gave a brief
description of the events.
Mr. E. S. Grecheck, Assistant Station. Manager,*
Surry, then presented a time line, justification for continued operation,
root cause, corrective action, and conclusion on the turbine valve freedom
issue.
Mr. E. S. Grecheck
then presented a description of the circuit,
time line, safety impact, root cause, corrective action, and future policy
associated with the failure to perform the diesel generator
degraded/undervoltage surveillance test.
The first issue discussed was the deleting of the turbine valve freedom
test approximately ten years ago.
The test is committed to in the Updated
Final Safety Analysis Report (UFSAR) and was deleted without a safety
evaluation as required by 10 CFR 50.59.
Deleti"ng this test increases the
risk of a turbine missile which is a postulated event.
This constitutes
an unreviewed safety question as defined in 10 CFR 50.59, therefore prior
Commission approval should have been sought prior to deleting the test.
This deviation from the UFSAR was discovered by the licensee during a
review in June 1987, and a justification for* continued. operation was
approved by the Station Safety Committee on September 4, 1987, but no
10 CFR 50.59 safety evaluation was performed.
The root cause was stated
to be that UFSAR statements were not recognized as commitments in 1976.
Corrective actions include testing the valves during the next outages,
resuming monthly testing following startup, and improving the 10 CFR 50.59
process at Surry.
This was one of the several examples of a failure to
perform 10 CFR 50.59 reviews described in Inspection Report 280,281/87-21.
The other issue discussed involved a failure to perform a diesel generator
degraded/undervoltage surveillance test required by the Technical
Specifications.
This surveillance was incorporated into the Technical
Specifications in 1982 but the requirement was not implemented by any
procedures.
In 1984, a licensee-initiated surveillance requirement study
identified the failure to perform this test, but no actions were taken to
correct the deficiency.
In June 1987, the resident inspector discovered
the failure to perform this test during a review of a procedure (PT 18.2).
A formal justification for continued operation was approved by the Station
Safety Committee on September 4, 1987.
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2
The licensee stated that the impact on safety was minimal in that no
single failure could cause a loss of the safety function.
However, a
failure of the untested circuit to reinstate on all four devices could
result in a failure of the diesel generator to supply power on
degra.ded/undervoltage. This is unlikely since the undervoltage feature is
tested monthly in accordance with a separate requirement.
The licensee
stated that the root causes were inadequate review of surveillance
requirements imposed by Amendments 80/81 to the Technical Specifications.
and inadequate follow-up of the discrepancy noted in 1984. Corrective
actions included functional testing of the required components, revising
the refueling periodic test, and detailed review of similar tests.
Once the missed survei 11 ance become known to VEPCO management,. the
associated components were not declared inoperable and the appropriate
limiting condition for operation was not entered.
The licensee stated
that based on their Technical Specification definition of operability they
did not consider the equipment inoperable.
Technical Specification I.D.
defines operable as follows:
.
11A system, subsystem, train, component or device shall be operable or
have operability when it is capable of performing its specified
function(s).
Implicit in thi~ definition shall be the assumption
that all necessary attendent instrumentation, controls, normal and
emergency electrical power sources, cooling or seal water,
lubrication or other auxiliary equipment that are required for the
system, subsystem, train, component or device to perform its
function(s) are also capable of performing their related support
functions ( s).
The system or component sha 11 be considered to have
this capability.when:
(1) it satisfies the limiting conditions for
operation defined in Section 3, and (2) it has been tested
periodically in accordance with Section 4 and meets its performance
requirements.
11
When questioned as to why the component had not been declared inoperable
based item (2) of the definition, the licensee stated that current
practice at Surry was to consider the component as not meeting the
operable definition but not technically
11 inoperable.
11
This position does
not appear to be consistent with the definiti6n in the Technical
Specification.
The licensee has conimi tted to consider a component
inoperable, enter the associated limiting* condition of operation, and
consult with the NRC as necessary when a surveillance is missed.
3.
Conclusions
The testing of the turbine valves was deleted from unknown reasons
approximately ten years ago without performing a 10 CFR 50.59 review and
VEPCO plans to reinstate the practice* of performing these tests monthly
while operating.
The probability of a turbine missile event is increased
by deleting the test thereby constituting an unreviewed safety question.
The probability of this event is
11small
11 as stated by the licensee.
Actions are being taken to improve the Surry 10 CFR 50.59 review process.
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3
Fai 1 ure to perform the diesel degraded/undervoltage survei 11 ance as
required by Technical Specifications was caused by a failure to
incorporate the requirements of the Technical Specification amendments as
stated by the licensee.
Testing will be performed in the future and
similar occurrances will result in dec_laring the component inoperable.
The diesels should have been declared inoperable when it was discovered
that the surveillance was missed.
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ENCLOSURE 2
Enforcement Conference Attendees
Virginia Electric and Power Company
W. L. Stewart, Vice President
E. W. Harrell, Station Manager, North Anna
M. L. Bowling, Assistant Station Manager, North Anna
E. S. Grechek, Assistant Station Manager, Surry
A. H. Stafford, Health Physics Superintendent, North Anna
S. P. Sarver, Health Physics Superintendent, Surry
N. E. Hardwick, Manager, Nuclear Power and Licensing, Corporate
G. L. Pannell, Director, SEC
Nuclear Regulatory Commission
M. L. Ernst, Deputy Regional Administrator
G. R. Jenkins, Director, Enforcement and. Investigations Coordination Staff
V. L. Brownlee, Branch Chief, Division of Reactor Projects (DRP)
R. Goddard, Regional Counsel
F. S. Cantrell, Section Chief, DRP
F. J. Congel, Office of Nuclear Reactor Regulation (NRR)
L. J. Cunningham, NRR
F. Jape, Section Chief, Test Programs, Division of Reactor Safety (DRS)
C. Patel, Project Manager, Surry, NRR
R. P. Croteau, Project Engineer, DRP
L. E. Nicholson, Resident Inspector, Surry
L. Trocine, Enforcement Specialist
C. H. Bassett, Radiation Specia1ist, DRSS
W. E. Holland, Senior Resident Inspector, Surry
J. L. Caldwell, Senior Resident Inspector, North Anna
P. J. Fillion, Reactor Inspector, DRS
G. R. Wiseman, Fire Protection Engineer, DRS
ENCLOSURE 3
AGENDA
SURRY POWER STATION.
e Turbine Valve Freedom Testing
Time Line
Justification for Continued *
Operation
Root Cause
Corrective Actions
- Conclusions
e Degraded/Undervoltage Surveillance Test
Description of circuit
Time Line
Safety Impact
Root Causes
Corrective Actions
Future Policy
TURBINE VALVE FREEDOM TESTING
TIME LINE
5/71
Supplemental question to FSAR 1().5 committed to monthly
testing. Station implemented weekly PT 29. 1
2/76
PT 29. 1 frequency changed to every two weeks
8/76
Last performance of PT 29. 1 on Unit 2
6/77
Last performance of PT 29. 1 on Unit 1
7/82
UFSAR submitted
-Chapter 10 stated prior to each start up
-Chapter 14 stated -periodic basis during unit operation
.,
6/87
Station deviation submitted as a. result of corporate (SEC)
reviews
SNSOC reviewed the deviation and an action plan
developed
9/4/87 Formal JCO approved by SNSOC
JUST/FICA TION FOR
CONTINUED OPERATION
e UFSAR indicates probability of turbine missile practically zero
9
-Turbine very rugge.d
.
-Adequate protection of safety-related equipment
e Periodic valve stroking
further reduces the possibility of valve stem sticking
e Valves have. been reliable during past operation
. e A VT chemistry now used
e Valves exercised during last outage
8/8/87 - Unit 1
4/5/87 *- Unit 2
e MSTV's are safety-related back up,.
e MSTV's are closed by procedure if turbine fails
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ROOT CAUSE
FSAR statements were not
recognized as commitments in 1976
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CORRECTIVE ACTIONS
Short Term
- Testing to be performed during next scheduled outage
-Unit 1 testing to be performed during current
maintenance outage
-Unit 2 outage scheduled for October, 1987
- Monthly testing to resume following start up
Long*Term
- Need for improvements in the 10CFR 50.59 process
previously identified
50.59 EVALUATION ENHANCEMENTS
e Employee Task Team Formed
-Improve content of evaluations
e Augmented Training of SNSOC ~embers
-Training module
-Included review of recent NRC findings at
other plants
-Emphasis on FSAR and procedural changes.
- -Presentation on 8/11/87; make up 9/11187
- all SNSOC members attended training
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EVALUATION ENHANCEMENTS
(Continued)
e Augmented Training for Engineers and ST As
e Program Review
-Weaknesses in screening and rep.orting
identified
~station deviation submitted on 8/28/87
-Improved screening criteria developed
-Implementation reviewed by SNSOC
-Procedure changes by 10/30/87 - Interim
corrective actions already implemented
CONCLUSIONS
e Initial decision to suspend testing 1976
e Identified by internal. review process
e Prompt corrective action is being
implemented
e Programmatic enhancements to 50.59
e~aluation process previously initiated
and ongoing
DEGRADED/UNDERVOLTAGE
SURVEILLANCE TEST
e Overall protection scheme
e Block feature when EDG is sole
power supply
TRANSFER
BREAKER
10
SEC
D/G
BKR
50
SEC
DEGRADED PROTECTION
60
SEC
7
SEC
- 2/3 UV
PROTECTION
LOGIC
ENABLE/DISABLE
UV PROTECTION
ACTUATION
RELAYS
UNDERVOL TAGE PROTECTION
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B
C
C
X-FER
D/G
BKR
BKR
-
2 SEC
ACTIONS ON SENSED UNDERVOLTAGE
e Opens
-Breaker from transfer bus
-Stub bus breaker
-RHR pump breaker
-CC pump breaker
-A charging pump
(H BUS only)
(only if C pump is nof racked into J-bus)
e Starts .
-Emergency diesel- generator
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-C charging pump (H-bus only)
e Closes
.
-Emergency diesel generator breaker
1982
UV/degraded voltage protection installed
-Initial testing included interlock :checks
8/82
Technical Specification change submitted
TIME LINE
10/82
Technical Specification amendment 80/81 issued
Surveillance test modified
10/84
Surveillance requirement review study
This item identified
Corrective action not implemented
6/29/87 NRC Resident Inspector requests evaluation of
procedure discrepancies (PT .18. 2)
7/24/87 Station Review determines surveillance not implemented
Station Deviation written
Technical reviews performed, minimal safety impact .
identified
.
9/4/87
Formal JCO approved by SNSOC
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IMPACT ON SAFETY
Failure to Block
e No second start attempt on diesel
e Breakers already in position
e RHR and CC not required for DBA
e No single failure could cause loss of
safety function
Reinstate
e Indirectly confirmed each refueling
e Verified functional
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ROOT CAUSES
. e Inadequate review of surveillance
requirements imposed by amendments
80/81
. e Inadequate follow-up of discrepancy
noted in 1984
CORRECTIVE ACTIONS
e Functional Testing of enable/disable interfock
-Unit 1 J Bus testing completed
- *
Unit 1 H Bus testing prior to startup
-Unit 2 testing completed
e Discrepancies from 1984 technical specification
report reviewed. Resolution to be formally documented
and tracked.
e Refueling PT's will be revised to include testing
e Detailed review of SI and CLS functional tests will be
performed
e Detailed SNSOC review of off-normal events already
implemented
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FUTURE POLICY
e Failure to perform surveillance
will be considered to render
component inoperable per LCO *
e Consult with NRC as necessary
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