ML18152A066
| ML18152A066 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 10/28/1996 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18152A067 | List: |
| References | |
| 50-280-96-10, 50-281-96-10, NUDOCS 9611040199 | |
| Download: ML18152A066 (34) | |
See also: IR 05000280/1996010
Text
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I I
Docket Nos:
License Nos:
Report No:
Licensee:
Facility:
Location:
Dates:
Inspectors:
Approved by:
9611040199 961028
ADOCK 05000280
G
50-280. 50-281
50-280/96-10. 50-281/96-10
Virginia Electric and Power Company (VEPCO)
Surry Power Station. Units 1 & 2
5850 Hog Island Road
Surry. VA 23883
September 8 - 28. 1996
R. Musser. Senior Resident Inspector
D. Kern. Resident Inspector
W. Poertner. Resident Inspector
P. Kellogg, Reactor Inspector (Sections 08.1.
08.2. Ml.3. MB.4. and M8.5)
W. Miller. Reactor Inspector (Sections Fl.1.
Fl.2. F2.1. F2.2. F3. F5. F6. F7. F8.1. and
FB.2)
N. Salgado. Resident Inspector. Oconee (Section
E4.1)
E. Testa. Senior Radiation Specialist (Sections
Rl.1. R2.1. R2.2. R7. and R8.1)
G. Belisle. Chief. Projects Branch 5
Division of Reactor Projects
Enclosure 2
EXECUTIVE SUMMARY
Surry Power Station. Units 1 and 2
NRC Inspection Report 50-280/96-10 and 50-281/96-10
This integrated inspection included aspects of licensee operations. engineer-
ing. maintenance. and plant support.
The report covers a three-week period of
resident inspection: in addition. it includes the results of announced inspec-
tions by three regional inspectors.
DRerations
The licensee's actions to repair a Unit 2 letdown line leak were appropriate
and accomplished in a methodical manner.
The management decision to
reengineer the configuration of the Unit 2 letdown line and remove the unit
from service to implement the modifications prior to the next scheduled
refueling outage seems appropriate based on the number of recent weld failures
that have occurred on the Unit 2 letdown line piping (Section 01.2).
The decision to test all four Component Cooling Heat Exchangers (CCHXs)
following a failed test on the C CCHX demonstrated an appropriate safety
perspective and sensitivity to potential common mode failure.
Increasing the
testing frequency was successful in preventing entry into a Technical
Specification (TS) Limiting Condition for Operation (LCD) during the remainder
of the inspection period (Section 01.3).
The licensee's actions to investigate and repair the A Unit 1 charging pump
motor failure were appropriate and accomplished in an expedious manner
(Section 01.4).
Issues identified during the service water self-assessment had been thoroughly
investigated and dispositioned by the licensee (Section 08.1).
Maintenance
The Unit 2 blender maintenance activity was accomplished in accordance with
the Work Order (WO) package requirements and approved procedures.
The system
was adequately isolated prior to commencing maintenance (Section Ml.1)
Engineering
Safety Evaluation 96-122 adequately justified the use of alternate boration
and dilution flowpaths and the Station Nuclear Safety Operating Committee
(SNSOC) meeting was professional and resulted in an indepth review of the
subject safety evaluation (Section El.1).
Review of standing DCP scope additions determined that they contained the
appropriate specifications. drawings. system descriptions. and safety
evaluations (Section E4.1).
Plant SURROrt
The licensee effectively implemented comprehensive training programs for the
operation of the Surry Radwaste Facility (SRF) and shipping radioactive
' *
2
materials. The inspectors determined that the revised radwaste shipping
approach. in the May 6. 1996 letter was acceptable (Section Rl.l).
No concerns with the licensee's SRF radiation monitor or calibration and
alarm. set points. equipment or High Integrity Container CHIC) lifting
attachments analysis were identified during the inspection (Section R2.1).
The Independent Spent Fuel Storage Installation (ISFSI) was properly posted
and entrance to the location appropriately controlled by Radiation Work
Permits (RWPs).
Environmental Thermo Luminescent Dosimeters (TLDs) were
verified to be in place. Adequate dose assignment as a result of neutron dose
assessment was taking place.
Surveys were taken as required and results were
selectively spot checked and found comparable.
Smear surveys were counted and
found clean.
Housekeeping was excellent at the ISFSI and low level waste
storage warehouse (Section R2.2).
The licensee was performing self assessments and taking timely and
comprehensive corrective actions.
One Unresolved Item was identified for
improper actions associated with a containment entry. A Noncited Violation
was also identified for respirators issued to nonqualified personnel (Section
R7).
The licensee was aggressively sampling and monitoring the primary and
secondary water chemistry parameters.
Parameters were maintained at a few
percent of TS limits.
The continuing training program appeared comprehensive
and provided adequate training to improve and maintain technician knowledge
and analytical skills (Section RS.l).
Corrective actions to improve RWP comprehension. Radiation Protection (RP)
coverage within containment. and stay time assessment were effectively
implemented (Section RS.2).
The licensee has been pro-active in the resolution of the Thermo-Lag issue.
Completion of the NRC review for the use of Thermo-Lag as radiant energy heat
shields in the containment is the only outstanding Thermo-Lag related issue at
Surry (Section Fl.l).
One fire protection related violation involving the failure to provide
appropriate preventive maintenance for safety related motors was identified
(Section Fl.2).
The spare equipment required for repairs following an Appendix R fire was
properly stored.
However. an Inspection Followup Item was identified for
preventive maintenance requirements on spare safety-related equipment (Section
Fl. 2).
The maintenance records. equipment trending data and inspection of the fire
protection components. indicated that there was no maintenance backlog on the
fire protection systems and. with the exception of the out-of-service fire
suppression systems for the SRF. the maintenance. operability and performance
of these systems were adequate.
The lack ~fa site procedure to establish
3
appropriate compensatory measures for degraded fire protection systems and
features not included in the TSs was identified as a weakness (Section F2.1).
Appropriate surveillances and tests were being performed on the fire
protection features and systems (Section F2.2).
The fire protection program implementing procedure met the commitments to the
NRC.
However. the procedure does not require each fir*e brigade member to
participate in at least two drills per year (Section F3).
The fire brigade organization and training met the commitments to the NRC.
Not stipulating a minimum participation of at least two drills per year for
each member of the fire brigade was identified as a weakness (Section F5).
- The coordination and oversight of the facility's fire protection program met
the licensee's commitments to the NRC (Section F6).
The audits and assessments of the facility's fire protection program were
through and appropriate corrective actions were taken to resolve the
identified issues (Section F7) .
1
Report Details
Summary of Plant Status
Unit 1 and Unit 2 operated at power the entire reporting period.
I. Operations
01
Conduct of Operations (71707)
01.1 General Comments (40500)
The inspectors conducted frequent control room tours to verify proper
staffing. operator attentiveness. and adherence to approved procedures.
The inspectors attended daily plant status meetings to maintain
awareness of overall facility operations and reviewed operator logs to
verify operational safety and compliance with Technical Specifications
(TSs).
Instrumentation and safety system lineups were periodically
reviewed from control room indications to assess operability. Frequent
plant tours were conducted to observe equipment status and housekeeping.
Deviation Reports (DRs) were reviewed to assure that potential safety
concerns were properly reported and resolved.
The inspectors found that
daily operations were generally conducted in accordance with regulatory
requirements and plant procedures.
01.2 Unit 2 Letdown Line Leak
a.
Inspection Scope (71707. 40500)
The inspectors reviewed the licensee's actions to repair a leak on the
Unit 2 letdown line inside containment.
b.
Observations and Findings
On September 11. at 2:19 a.m .. Reactor Coolant System (RCS) total
leakage increased to 0.941 gallons per minute (gpm) and unidentified
leakage increased to 0.849 gpm.
Previous total leakage and unidentified
leakage values were 0.139 gpm and 0.033 gpm respectively.
Based on the
increased leakage rate. containment air samples were requested and a
backup leakage calculation was initiated. The backup calculation was
consistent with the previous calculation. A containment entry was made
to try to identify the source of the increased RCS leakage.
The
containment entry identified that a leak existed on the normal letdown
line at a welded coupling downstream of valve 2-CH-HCV-2200B.
Excess
letdown was placed in service and normal letdown was removed from
service to isolate the leaking weld joint. Following isolation of
normal letdown total. leakage decreased to 0.297 gpm and unidentified
leakage decreased to 0.167 gpm.
At no time did the leakage values
exceed the TS allowed values.
C.
2
Station management conducted numerous meetings on this matter to
determine a course of action to repair the leak.
The licensee decided
to repair the leaking weld joint with the unit at power and to cut out
the failed weld so that a failure analysis could be performed.
The
licensee also decided that the unit would be shutdown and the letdown
line would be modified at the earliest opportunity once the root cause
of the weld failure was determined and a corrective action plan
developed.
The decision to shutdown the unit in the future to modify
the letdown line was based on the fact 4 weld leaks had developed in the
letdown line piping within the last 12 months.
The three previous leaks
developed on the piping tee connection immediately downstream of the
leaking coupling.
The failed coupling weld was a shop welded joint
associated with repair activities for a March 1996 letdown line weld
failure.
The licensee removed the failed weld for failure analysis and replaced
the coupling and associated piping.
Normal letdown was returned to
service on September 13 following coupling and pipe replacement
activities. The failure analysis performed on the failed weld
determined that the weld failed as the result of a fatigue crack which
initiated at a lack of fusion discontinuity in the fillet weld between
the 2 inch coupling and schedule 40 pipe.
The failure analysis
determined that the fatigue crack possibly initiated as a relatively low
cycle/high stress process but was predominately propagated as a high
cycle/low stress process.
The licensee was still formulating a
corrective action plan to modify the letdown line piping at the end of
the inspection period.
Conclusions
The licensee's actions to repair the letdown line were appropriate and
accomplished in a methodical manner.
The management decision to
reengineer the configuration of the Unit 2 letdown line and remove the
unit from service to implement the modifications prior to the next
scheduled refueling outage seems appropriate based on the number of
recent weld failures that have occurred on the Unit 2 letdown line
piping downstream of the letdown orifices.
01.3 Component Cooling Heat Exchanger Fouling
a.
Inspection Scope (71707. 40500)
The inspectors reviewed the licensee actions with regard to inoperable
Component Cooling Heat Exchangers (CCHXs).
b.
Observations and Findings
On September 18. at 8:35 p.m .. the C CCHX failed to meet the acceptance
criteria of procedure l-OSP-SW-004. Measurement of Macrofouling Blockage
of Component Cooling Heat Exchanger 1-CC-E-lC. revision 5. due to low
flow.
The C CCHX was declared inoperable.
Based on the low flow
condition operations tested the D CCHX due to concerns with potential
3
common mode failure mechanisms.
The D CCHX also did not meet the
procedure acceptance criteria and was declared inoperable at 9:30 p.m.
With two out of four CCHXs inoperable both units entered a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />
action statement to return 3 CCHXs to service.
The A and B CCHXs were
tested and met the operability acceptance criteria. The testing of the
A and B CCHXs was completed at 2:30 a.m. on September 19.
The C CCHX was cleaned and returned to service at 1:51 a.m. and the D
CCHX was cleaned and returned to service at 5:58 a.m.
The licensee
increased the CCHX macro fouling testing frequency from once a week to
twice a week based on the increased fouling rate observed.
The
inspectors verified that increased testing was implemented and noted
that as of the end of the inspection period. the increased testing
frequency was successful in preventing entry into a TS Limiting
Condition of Operation (LCD).
c.
Conclusions
The decision to test all four CCHXs demonstrated an appropriate safety
perspective and sensitivity to potential common mode failure.
The
increased testing frequency was successful in preventing entry into a TS
LCD during the remainder of the inspection period.
01.4 Unit 1 Charging Pump Failure
a.
Inspection Scope (71707)
The inspectors reviewed the circumstances surrounding the failure of the
Unit 1 A charging pump.
b.
Observations and Findings
On September 19. at 8:49 p.m .. the Unit 1 A charging pump was started
from the control room to allow the C charging pump to be secured.
When
the pump was started. pump current (amps) pegged high and then returned
to zero.
The operator in the auxiliary building reported a flash of
light. a puff of smoke and a loud noise from the pump cubicle.
The
control room operator immediately secured the pump and placed the
control switch in pull-to-lock to prevent further operation of the pump.
Further investigation by operations found discoloration in the area of
the motor junction box and an instantaneous overcurrent drop on the C
phase at the breaker cubicle.
At the time of the event. the B charging pump was inoperable due to
maintenance activities. The maintenance activities had been completed.
however. post maintenance testing was required to declare the pump
operable and breaker interlocks prevented starting the B pump with the C
charging pump powered from the same electrical bus.
With the A charging
pump inoperable. a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> LCD was entered due to only one charging pump
being operable and capable of receiving an automatic start signal on an
accident signal.
4
The A charging pump breaker was tagged out at 9:40 p.m .. to allow
electrical maintenance personnel to troubleshoot the problem.
The
troubleshooting determined that the B phase of the motor was
electrically open and that the B phase motor lead had burned through at
the lug connection in the motor junction box.
The pump motor was
meggered with satisfactorily results.
Based on the troubleshooting
activities the licensee decided to replace all the electrical
connections in the motor junction box and test the breaker trip
circuits. The licensee determined that the C phase overcurrent
indication resulted from mechanical agitation when the breaker tripped
open and that a real instantaneous overcurrent condition did not occur
on the C phase.
The electrical connections were replaced and the breaker trip functions
were tested.
No problems were identified during the testing. The
licensee replaced the C phase overcurrent device based on the indication
problem following breaker operation.
The failed connection was saved
and sent offsite for analysis in an attempt to determine the cause of
the failure.
The A charging pump was tested and returned to service at
9:21 p.m. on September 20.
Subsequent to returning the A charging pump
to service. the B charging pump was tested and the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> LCO was
exited at 11:31 p.m. on September 20.
The inspectors inspected the failed motor lead connection. monitored
licensee corrective actions. and reviewed the event with maintenance
engineering personnel to ensure that the pump breaker protection devices
operated as designed.
c.
Conclusions
The licensee's actions to investigate and repair the A charging pump
motor failure were appropriate and accomplished in an expedious manner.
08
Miscellaneous Operations Issues (92901)
08.1
(Closed) Inspection Followup Item (IFI) 50-280. 50-281/94009-01: follow-
up on Service Water System Operational Performance Assessment (SWSOPA)
corrective actions.
During the Service Water System Operational
Performance Inspection (SWSOPI). several items had been identified that
required additional corrective action or evaluation by the licensee.
These items were as follows:
The assessment identified that Service Water System (SWS) lines of
8 inches or less were not being flow tested. the heat exchanger
performance monitoring did not meet the intent of GL 89-13. and
that the Emergency Service Water (ESW) pump right angle gear
coolers did not receive adequate maintenance.
The inspector
reviewed the licensee's closeout of these assessment items.
The
SWS lines of 8 inches or less are being inspected during component
maintenance activities and during outages.
Heat exchanger
performance had been enhanced by the installation of additional
flow indications.
The right angle gear coolers have flow
5
instrumentation installed which indicates when cleaning of the
coolers is necessary.
Charging pump lube oil cooler temperature control valves had been
down graded inappropriately to non-safety related.
New valves had
been procured as non-safety related.
However. these new valves
had not been installed at the time of the assessment.
The
original disposition of this items was to change the failure mode
of these valves and leave them as non-safety related.
Upon
further review the licensee determined that the valves should be
classified as safety related.
The inspector reviewed the change
documentation to upgrade the valves back to safety related.
The
new valves will be upgraded or safety related valves will be
procured prior to their installation.
The SWS pumps were diesel powered and fuel for their engines was
supplied from a common tank.
The SWSOPA identified that the four
sampling procedures applicable to this tank had inconsistent fuel
oil sampling acceptance criteria. The inspector reviewed the
change to C-93.212. "Diesel Fuel Tank Number 2 [underground
storage tank]: Sampling and Analysis After Fuel Addition." dated
6/28/94. and concluded that the acceptance criteria had been
changed to agree with the other three procedures.
The Updated Final Safety Analysis Report (UFSAR) contained an
incorrect statement. in one section. that indicated that the
containment would return to a subatmospheric condition in less
than 30 minutes.
The correct value is 60 minutes.
The inspector
reviewed the applicable portions of the UFSAR and determined that
the 30 minute error was revised to 60 minutes in revision 23
issued in December 1994.
The licensee's intake canal level probes which are required to
operate to isolate non-safety related loads on the SWS system had
been failing due to macrofouling of the probe tip. Replacement
tips had been response time bench tested and failed the 66 second
response time required for the isolation actuation.
The inspector
reviewed the Performance Test (PT) test. PT-2.21 B. C. Canal
Level. dated 2-24-94. which tests the installed probes.
The PT
had been revised to reduce the setpoint from 300mv to 250mv.
This
reduced the response time of the probes by 10 -15 seconds.
The
response time of the probes was demonstrated to be< 66 seconds on
the last performance of the PTs.
Recirculation Spray Heat Exchanger (RSHX) flow was being monitored
by valve position vice flow indication.
Flow indication existed
but had not been included in the Emergency Operating Procedures
(EOPs) as an indication available to the operators.
The inspector
reviewed the applicable EOPs (1/2-E-O. revision 16. and determined
that the RSHX flow instrumentation had been added to the
procedures in addition to the valve position.
6
The SWSOPA identified discrepancies in operator training modules
NCRODP 12-S and 13 Intake Canal Level and Setpoints. concerning
the low level setpoint of the i~take canal for various functions
and system operating requirements.
The inspector reviewed the
training modules.
The modules had been revised to show the
correct setpoint of 23 feet.
The RSHXs are normally isolated and drained during normal
operation.
The SWSOPA had determined that water had entered one
of the heat exchangers when throttling Circulating Water (CW)
system during cold weather. Administrative procedures were to be
revised to ensure that the RSHXs remained dry.
The inspector
reviewed the operations monthly check for dryness.
The test
procedures had also been revised to note that the isolation valves
are leak tight and to minimize the length of time that water is
against the valves.
The SWSOPA identified that the radiation monitoring equipment on
the SWS discharge piping from the RSHXs may not be operable due to
inadequately sized suction piping.
The suction piping had been
changed from 3/4 inch to 2 inch.
The inspector reviewed the
performance test. 1/2 OPT-RS-066 Radiation Monitor Functional
Test. Dated 8/20/96. This test determines that water pumps
through the detector well. check that static and dynamic pressures
available and that the annunciator circuits function properly.
The test results were satisfactory.
08.2 (Closed) Licensee Event Report (LER) 50-281/96001-00 and Violation (VIO)
50-280. 50-281/96002-02:
loss of containment integrity due to through
wall leak in the Residual Heat Removal (RHR) reactor cavity drain line.
A through wall leak developed due to intergranular corrosion at the
intersection of the pipe seam and an overlapping saddle support weld.
The Unit was brought to cold shutdown and the piping was replaced.
Ultrasonic Testing (UT) of additional piping on Unit 2 did not identify
any additional defects that were beyond code allowable.
The resident inspectors in responding to this event determined that. on
January 16. 1996. written procedures were not followed for corrective
maintenance operations.
The leak on a containment penetration weld
inside the Radiological Control Area (RCA) was not reported to the Shift
Supervisor. and this weld leak was not documented on a Work Request
(WR).
The weld leak was identified on a maintenance Deficiency Card.
Also. this deviation was not reported on a DR.
These failures allowed
Unit 2 to operate at power for approximately five weeks with a degraded
containment penetration. This was identified to the licensee as a
violation in NRC Inspection Report (IR) 50-280. 281/96-06.
As part of followup to the LER the inspector also verified the
licensee's corrective actions for the violation. These corrective
actions included revising procedures VPAP- 1501 and 2002 Deficiency
Reporting revision 5 and 6. to include the necessity of identifying any
7
though wall leak inside the RCA on a WR. and revising the screening
process for Deficiency Cards.
Additionally. the station manager issued
a memorandum to all station personnel discussing the correct programs
for the identification of deficiencies.
The inspectors concluded that
these actions were adequate to preclude recurrence.
II. Maintenance
Ml
Conduct of Maintenance
Ml.1 Unit 2 Blender Repair
a.
Inspection Scope (62703)
The inspectors observed corrective maintenance activities associated
with Work Order (WO) 00351738. Investigate/Repair Valve FCV 1114A.
b.
Observations and Findings
On September 25. the inspectors reviewed the WO package. verified that
the system isolation was adequate to perform the maintenance activity.
and observed portions of the maintenance activity in progress.
The
maintenance activity was initiated due to the inability to achieve
primary grade (PG) water flow to the Unit 2 blender.
The activity
consisted of removing the valve actuator and bonnet to allow inspection
of the valve internals to determine if the valve disc had separated from
the valve stem.
Inspection of the valve internals did not identify any
discrepancies. Subsequent inspection of the piping downstream of the *
valve utilizing a boroscope determined that a spring loaded check valve
was not moving freely.
The check valve was mechanically cycled
internally and proper operation was verified.
The system was returned
to service and proper PG flow was obtained.
c.
Conclusions
The maintenance activity was accomplished in accordance with the WO
package requirements and approved procedures.
The system was adequately
isolated prior to commencing maintenance.
Ml.2 Reactor Protection System Logic Testing
a.
Inspection Scope (61726)
The inspectors witnessed portions of the Unit 2 Reactor Protection
System (RPS) logic testing conducted on September 27.
b.
Observations and Findings
The inspectors witnessed the portion of Unit 2 procedure PT 8.1. Reactor
Protection Logic (for Normal Operations). revision 8. performed on the B
train of the RPS.
The technicians performing the surveillance were
knowledgeable of the procedure requirements and precautions.
The
. *
8
periodic test was accomplished in accordance with the procedure and all
acceptance criteria were met.
c.
Conclusions
The portion of the RPS logic testing witnessed by the inspectors was
accomplished in accordance with the procedure's requirements and all
acceptance criteria were met.
The technicians performing the
surveillance were knowledgeable of the procedure's requirements and
precautions.
Ml.3
a . Inspection Scope
b.
C.
The inspector observed the release nut clearance on both units* main
steam safety valves on September 25. 1996.
Observations and Findings
In May 1996. an event occurred at another reactor where the release nut
cotter pin became disengaged. This allowed the release nut to vibrate
down the valve stem and caused the valve to stick open.
The root cause
of this occurrence appeared to be inadequate maintenance procedures in
that the cotter pin. which was to hold the release nut 1/8 to 1/16
inches above the top lever. was incorrectly installed. The Dresser
model 3700 safety valves are similar in construction to the other
plants. The inspector observed the safety valves in Unit 1 and 2.
Observations confirmed that clearance between the release nut and the
top lever did exist and was greater than 1/8 inch.
The cotter pins
could not be observed.
The cap of the valve covers the top of the
release nut and obscures the area where the cotter pins are installed.
The licensee's system engineer was familiar with the event and had
initiated a change to maintenance procedures MPT-0427-02. Main Steam
Safety Setpoint Verification for both unit3. Additional~y. the system
engineer had initiated a technical manual change to clarify the
installation of the cotter pins.
The system engineer indicated that
only vender personnel had worked on the safety valves and that no
previous problems had been identified in this area.
Conclusions
The licensee was aware of the problem with the main steam safety valve
release nuts and had taken appropriate action by initiating changes to
maintenance procedures to ensure that a similar problem would not occur
at this facility.
MB
Miscellaneous Maintenance Issues (92700. 92902)
M8.l
(Closed) Violation 50-280. 281/95022-01:
missed technical specification
surveillance. This violation was issued Nhen maintenance personnel
failed to perform station battery and smoKe detector surveillances
9
within required periodicities. Root cause evaluation (RCE) 95-09.
Missed Battery Surveillance. revision 1. determined that electrical
supervisors failed to adequately perform technical reviews of completed
surveillances. The licensee attributed the errors to programmatic
issues and weaknesses in personal accountability and supervisory
oversight.
Initial corrective actions were previously documented in NRC
IR 50-280. 281/95-22.
Corrective actions to preclude recurrence included counseling electrical
supervisors regarding their surveillance reviews. procedure revisions to
clarify supervisory review responsibilities and partial surveillance
completion documentation. and one additional person was assigned to the
electrical department to assist in periodic test (PT) scheduling and
tracking.
To further strengthen PT accountability. VPAP 1102. Periodic
Testing. revision 1-PSl. was revised to require administrative and
technical PT reviews to be completed within the PT test interval. The
inspectors reviewed the procedure revisions. interviewed personnel. and
verified that the corrective actions were complete.
No TS surveillances
have been missed since April 1995.
The inspectors concluded that
corrective actions were effectively implemented to address this
violation.
M8.2
(Closed) LER 50-281/95004-00: installation of damaged circuit card
resulted in Unit 2 manual reactor trip.
On May 11. 1995. installation
of a damaged control rod drive (CRD) circuit card caused four control
rods to fully drop into the core with the reactor at 100 percent power.
The event and initial corrective actions were documented in NRC IR 50-
280. 281/95-08. A cracked resistor on the replacement circuit card was
not evident to technicians prior to installation. Corrective actions to
preclude recurrence included several revisions to warehouse receipt.
inspection. and storage practices.
These actions were effectively
implemented promptly after the event.
In addition. the licensee
developed additional preinstallation card testing capabilities. The
inspectors observed the revised circuit card receipt practices and
preinstallation testing.
NRC IR 50-280. 281/95-17 documents some of the
circuit card testing observations.
The inspectors concluded that
corrective actions were properly implemented to preclude the
installation of damaged CRD circuit cards.
M8.3
(Closed) LER 50-281/95005-00: manual trip due to control rods dropping
into reactor core.
On May 21. 1995. four control rods dropped into the
core due to a degraded CRD circuit card.
The event and initial
corrective actions were documented in NRC IR 50-280. 281/95-08.
The
licensee determined that the root cause was an adverse operating
environment (excessive heat and dust) in the vicinity of the CRD
cabinets.
The root cause assessment considered a broad range of causal
factors.
NRC IRs 50-280. 281/95-17. 96-02. and 96-07 document inspector
observations regarding corrective action implementation.
The two most
significant corrective actions were enhanced CRD inspection and testing
practices and an air conditioning upgrade for the normal switchgear
rooms which house the CRD cabinets. The air conditioning upgrade was
completed in May 1996.
This upgrade was an effective long term
10
corrective action to establish adequate environmental conditions for CRD
cabinet circuitry. The inspectors determined that corrective actions to
address the CRD circuit card failures were effectively implemented.
M8.4 (Closed) LER 50-280/95006-00:
emergency service water pumps 1-SW-P-lA
and lC declared inoperable due to low flow and speed indications.
During a performance test on August 22. 1995. the 1-SW-P-lC emergency
service water pump was declared inoperable due to indications of low
flow and low speed.
On August 23. 1995. marine growth was removed from
the suction bell and impeller surfaces by a diver and the pump was
successfully tested.
The 1-SW-P-lA emergency service water pump was
tested on August 23. 1995. and it also was declared inoperable due to
low flow and speed indications.
Marine growth was removed form the
suction bell and impeller.
The pump was returned to service following a
successful test on August 24. 1995.
The licensee had previously experienced fouling of the pump suction
bells and impellers by marine growth.
This had occurred twelve times in
the previous two years. A routine cleaning by divers had been
incorporated into a preventive maintenance item for the SWS pumps.
The
warm weather had accelerated the marine growth and caused the
inoperabilities on this occasion.
The inspectors reviewed the
corrective actions for these occurrences which included more frequent
cleaning during the warm weather months and the coating of the suction
bells and impellers with an anti-marine growth coating.
The inspectors
determined that the licensee was continuing investigations into methods
,)
to prevent further recurrence.
M8.5
(Closed) LER 50-280/96005-00: both trains of Unit 1 and 2 charging pump
service water pumps became air bound.
On May 6. 1996. both trains of
the Unit 1 and 2 charging pump service water pumps became air bound
rendering the charging pumps inoperable. Service water was restored to
one Unit 1 pump within one minute.
The remainder of the pumps were
vented and flow was re-established within one hour.
Underwater diving activities on the Unit 2 circulating and service water
piping was identified as the source of the air in the system.
Air from
the divers entered the service water supply lines when valve 2-SW-MOV-
201B was opened in preparation for a safety injection logic test.
The inspector reviewed the licensee's corrective actions which included
revising procedures used to perform maintenance on the circulating and
service water systems.
The procedures had been revised to note the
possible air binding of the lines due to the use of divers in the
systems and the necessary steps to vent the line to remove the air
exhaled by the divers.
11
III. Engineering
El
Conduct of Engineering
El.1 Safety Evaluation to Support Unit 2 Blender Operations
a.
Inspection Scope (37551)
The inspectors reviewed Safety Evaluation 96-122. Makeup. Boration and
Dilution with the Normal Blender Flowpath Unavailable.
b.
Observations and Findings
The inspectors reviewed the safety evaluation and attended the Station
Nuclear Safety Operating Committee (SNSOC) meeting that approved the
safety evaluation for implementation.
The safety evaluation was
initiated to support a procedure change to procedure 2-0P-CH-007.
Blender Operations. revision 1. to allow an alternate method of boration
and dilution with the Unit 2 blender inoperable.
The alternate
flowpaths bypassed the blender and required manual control of valves
located in the auxiliary building.
The safety evaluation required
continuous communications between the control room and the remote valve
locations. placed limits on the amount of boron that could be added by
makeup and specified the dilution flowrate following boron addition.
The safety evaluation was thorough and adequately justified the
procedure revision.
The SNSOC meeting was conducted in a professional
manner and resulted in an indepth review of the subject safety
evaluation.
c.
Conclusions
Safety Evaluation 96-122 adequately justified the use of alternate
boration and dilution flowpaths and the SNSOC meeting was professional
and resulted in an indepth review of the subject safety evaluation.
E4
Engineering Procedures and Documentation
E4.1
Review of Standing Design Change Packages
a.
Inspection Scope
The inspectors reviewed the licensee's standing design change process as
controlled by Surry Station Engineering Services (SSES) Implementing
Procedure. SSES-2.11. Controlling Procedure For Standing Design Change
Package (DCP) Guidelines. revision 1.
The inspector randomly selected
several standing DCPs to review the work scope additions. safety
evaluations. drawings, and/or applicable specifications .
12
b.
Observations and Findings
Procedure SSES-2.11. revision 15. establishes the guidelines to be
utilized by Engineering personnel when preparing a standing DCP.
The
inspector also reviewed the following procedures which were used to
prepare DCPs:
Nuclear Design Control Program General Nuclear Standard
STD-GN-001. Instruction for DCP Preparation. revision 15. and Station
Administrative Procedure VPAP-0301. Design Change Process. revision 6.
A standing DCP is a design change written for the installation of
equipment or components that has a defined design. but an undefined work
scope.
Examples of standing DCPs are:
piping replacement. motor termination inspections. concrete repairs. and
solenoid valve replacement.
The design scope describes the modification
to be performed.
The work scope addition is the supplemental scope of
work that is added to the standing DCP.
A work scope addition may not
change the original design scope of the DCP.
The inspector reviewed several work scope additions on the following
standing DCPs:
DCP 92-074:
Misc. Transmitter Replacement
DCP 95-001: Standing DCP MI Setpoint/Scaling Changes/Surry/Units
1&2
DCP 92-083:
Misc. Limitorque Motor Operator Modification
The inspector noted that work scope addition number twenty on DCP 95-001
involved changing the existing "High" temperature alarm setpoint of
140 °F to a new lower temperature of 115 °F.
The field change lowered
the alarm temperature setpoint to provide additional response time to an
increase in Spent Fuel Pool (SFP) temperature.
The licensee initiated
this change in response to recent concerns over SFP cooling issues.
The
inspectors considered that the licensee's work scope addition number
twenty on DCP 95-001 was performed in accordance with applicable
procedures. and was conservative. All the other scope additions that
were reviewed by the inspector contained appropriate specifications.
drawings. system descriptions. and adequate safety evaluations when
required.
c.
Conclusion
The inspectors concluded that all the standing DCP scope additions
reviewed contained appropriate specifications. drawings. system
descriptions. and safety evaluations.
13
IV. Plant Support
Rl
Radiological Protection and Chemistry (RP&C) Controls
Rl.l Transportation of Radioactive Material
a.
Inspection Scope (86750. TI 2515/133)
The inspectors evaluated the licensee's transportation and radioactive
materials programs. including worker training and facility operation
training.
Implementation of revised Department of Transportation (DOT)
and NRC transportation regulations for shipment of radioactive materials
as required by Title 10 Code of Federal Regulations (CFR) Part 71.5 and
49 CFR Parts 170 through 189 were also inspected.
In addition. the
licensee's May 6. 1996. Revised Response to IE Bulletin and Notice of
Violation Radioactive Waste Packaging and Shipment were reviewed and
evaluated.
b.
Observations and Findings
The inspectors reviewed training associated with the revised Department
of Transportation and NRC transportation regulations and found the
training to be comprehensive.
The inspectors reviewed training for
working in the Surry Radwaste Facility (SRF).
The review included
lesson plans. self study instructional material for system's operation
and design information and technical handout material. prints. exam
questions and exam results. The inspectors toured the SRF and
determined that the shipping containers were appropriately labeled and
properly stored.
At the time of the inspection the licensee had
temporarily halted shipments of evaporator bottoms and were evaluating
the options to determine the direction they were going to pursue when
they resumed shipping.
The inspectors reviewed the original response to IE 79-19. Bulletin
Packaging of Low Level Radioactive Waste for Transport and Burial. dated
September 27. 1979 (Serial No. 670).
NRC Inspection Report 50-280/80-16
and 50-281/80-17 and EA 80-28 identified a violation for not adequately
identifying radiation levels on radioactive waste shipped offsite. The
response dated June 20. 1980 (Serial No.544). indicated that procedures
had been revised for the packaging and shipment of solid radioactive
waste to require a minimum of six documented contact readings and to
conspicuously mark the highest contact reading on the package surface.
A commitment was also made to have a Quality Control (QC) inspector
witness radioactive waste loading and shipment operations. A Health
Physics Position Paper. prepared by the Supervisor. Health Physics
Technical Services. dated July 10. 1996. evaluated the aspects of QC
Inspection and Review of Radwaste Shipping Papers. Since the time of
the commitment. significant organizational changes have occurred and a
long successful record had been established showing no repeat of the
earlier violation.
14
The inspectors reviewed the revised commitments that state that the RP
procedures now require that only the highest contact radiation reading
for each package be recorded. and no longer require that each
radioactive waste package be marked with the highest contact reading.
The licensee's response also stated that verification of proper
radioactive waste loading and shipping would be performed by qualified
personnel and periodic audits of the radioactive waste program would be
performed by the Nuclear Oversight Department.
c.
Conclusions
The licensee effectively implemented comprehensive training programs for
the operation of the SRF and shipping radioactive materials. The
inspectors determined that the revised radwaste shipping approach. in
the May 6. 1996 letter was acceptable.
R2 Status of Radiation Protection Facilities and Equipment
R2.1 Radiation Monitor and Calculation Review
a.
Inspection Scope (84750. 86750)
The inspectors reviewed selected SRF radiation monitors for calibration
and alarm set points.
The inspectors also reviewed the analysis and
calculations associated with the Model Ll4-195 High Integrity Container
(HIC) lifting attachments.
b.
Observations and Findings
C.
The inspectors reviewed selected alarm set points in the SRF and
calibration data and determined that monitors were within their
calibration interval and alarm set points were correctly set.
The inspectors reviewed the acceptability of using the Ll4-195 HICs for
multiple shipments and for the handling required to make the shipments.
The inspectors reviewed the calculations performed on the lifting
attachments to demonstrate their multiple use acceptability.
The
analysis showed that the devices were acceptable for at least ten
handling cycles: however. the licensee has restricted their use to three
handling cycles.
The inspectors verified that HIC lifting attachments
were changed out after three cycles. There have been 20 shipments of
evaporator bottoms using the HIC containers this year.
The last HIC
shipment was made on August 20. 1996. The inspector verified the change-
out of the lifting attachments.
Shipments have been temporarily put on
hold pending an evaluation of shipping large quantities of evaporator
bottoms.
This evaluation has a management due date of November 1. 1996.
Conclusions
No concerns with the licensee's SRF facility radiation monitor or
calibration and alarm. set points. equipment. or HIC lifting attachments
analysis were identified during the inspection.
-*
15
R2.2 Tours of Licensee Radiological Control Areas (RCAs)
a.
Inspection Scope (83750. 60855. 71750)
During tours of the licensee facilities. the inspectors selectively
verified that radiological postings and labels were appropriate for the
radiological hazard.
The licensee's Independent Spent Fuel Storage
Installation Radiation Protection Activities were selectively reviewed.
b.
Observations and Findings
The inspectors observed the control of contaminated and radioactive
material and housekeeping within the licensee's Independent Spent Fuel
Storage Installation (ISFSI). low level radioactive waste warehouse and
scrap storage areas.
The inspectors also verified that recent survey
information for the ISFSI was readily available for briefings for
workers needing access to the ISFSI area.
The inspectors independently
verified selected survey points and took independent smear survey
samples from storage containers.
The neutron dose assessment
calculations were reviewed for the inspector's entry. Additionally. the
records for selected individuals who had entered the area under separate
RWPs were reviewed to insure that neutron dose assessments had been
performed and that proper neutron doses had been recorded and assigned.
Postings at the ISFS I. low level waste storage warehouse and scrap
storage areas inside the SRF were found to be properly located.
Additionally. environmental Thermo Luminescent Dosimeters (TLDs) at the
ISFSI were verified to be at their designated locations.
c.
Conclusions
The ISFSI was properly posted and entrance to the location was
appropriately controlled by RWPs.
Environmental TLDs were verified to
be in place.
Adequate dose assignment as a result of neutron dose
assessment was taking place. Surveys were taken as required and results
were selectively spot checked and found comparable.
Smear surveys were
counted and found clean.
Housekeeping was excellent at the ISFSI and
low level waste storage warehouse.
R7 Quality Assurance in RP&C Activities
a.
Inspection Scope (83750)
The inspectors reviewed the licensee's program for identifying and
correcting deficiencies or weaknesses related to the control of
radiation or radioactive material.
b.
Observations and Findings
The inspectors selectively reviewed the DRs related to the control of
radiation or radioactive material.
During discussions with licensee
representatives and reviews of DRs. the inspectors reviewed the details
of DR No. S-96-1771 involving activities associated with a containment
16
entry made on August 17. 1996. to investigate an oil level alarm on
reactor coolant pump 2-RC-P-lB motor.
A root cause investigation was
conducted by the licensee and involved personnel exceeding Digital
Alarming Dosimeter (DAD) limits. The root cause revealed a failure of
the Health Physicist Shift Supervisor (HPSS) to be fully knowledgeable
of and comply with RWP requirements.
The HPSS. in an attempt to conceal
the procedural violations. allegedly falsified records associated with
RWP Briefing Attendance Roster dose set-points for DADs.
The workers received a dose of 186 and 205 mrem.
These doses did not
exceed any regulatory limits.
The HPSS admitted that he missed the RWP
requirement to use a Special RWP and forgot to change the DAD dose alarm
set-points.
He knew the workers exceeded their alarm set-points. knew
the RWP requirements to exit the containment. but made a decision to
allow them to finish the job. knowing that he was violating the RWP.
The licensee took disciplinary action as a result of their
investigation.
Procedural violations for this event were:
(1) Failure
to exit area when workers exceeded their DAD alarm set-point in dose
mode. (2) Failure to write a Special RWP for expected doses in excess of
100 mrem. and (3)
Failure to* maintain complete and accurate
information.
The licensee was informed that this would be tracked as an Unresolved
Item (URI) pending Regional and Headquarters review: URI 50-280 .
281/96010-01: improper actions associated with a containment entry.
The inspectors reviewed DR S-96-1981. dated September 11. 1996,
involving the issuance of a respirator to a worker who was not qualified
by virtue of having an expired respiratory fit test. The respirator was
issued to the same individual on two separate dates (August 15. 1996 and
August 16. 1996) for containment entries.
The worker's fit test
qualification expired on March 31. 1996.
The licensee discovered the
problem while reviewing personnel qualifications for containment entries
in support of steam generator letdown line maintenance.
The individual
was requalified on September 11, 1996.
As part of the investigation.
the licensee was evaluating the need to perform a Whole Body Count.
The
following procedures were identified by the licensee to be violated by
the individual. VPAP-2101. Radiological Protection. revision 11. dated
August 1. 1996. Section 6.4.9 a and c. VPAP-0106. Subatmospheric
Containment Entry, Revision O-PS2. Section 6.2.2. and HP-1042.150.
Respirator Issue revision 1. dated December 12. 1995. Section 4.2.
At
the conclusion of the inspection. the licensee was aggressively
reviewing the following: the software program Personnel Radiation
Exposure Management System (PREMS) that can be used to determine the
worker's qualifications. the records and data available at the
respirator issue point and the training and procedures associated with
respirator issue.
The licensee identified and corrected violation is
being treated as a Noncited Violation: NCV 50-280. 281/96010-02:
Respirators issued to nonqualified persunnel. consistent with Section
VII.B.l of the NRC Enforcement Policy .
17
c.
Conclusions
The licensee was performing self assessments and taking timely and
comprehensive corrective actions.
One URI and one NCV were identified.
RB Miscellaneous Radiation Protection and Chemistry Issues
R8.l Primary and Secondary Chemistry
a.
InsQection ScoQe (86750. TI 2515/133)
The inspectors reviewed and discussed the results of the licensee's
primary and secondary chemistry program.* The inspectors also reviewed
the Nuclear Chemistry Technician Continuing Training Program - 1996.
b.
Observations and Findings
The inspectors reviewed the chemistry results for the TS data associated
with the Primary and Secondary Water Chemistry parameters for the period
from January 1. 1996 through September 11. 1996. and determined that all
required TS chemistry results were maintained at small percentages of
the limits.
The Nuclear Chemistry Technician Continuing Training Program - 1996
includes the following training elements: classroom training. laboratory
training and in plant training.
The inspectors determined that the
areas covered provided adequate continuing training to maintain the
skills necessary to perform the chemistry program.
The training also
included recent industry event updates.
c.
Conclusions
The licensee was aggressively sampling and monitoring the primary and
secondary water chemistry parameters.
Parameters were maintained at a
few percent of TS limits.
The continuing training program appeared
comprehensive and provided adequate training to improve and maintain
technician knowledge and analytical skills.
R8.2
(Closed) Violation 50-281/95023-01: multiple personnel violations of RWP
requirements.
On December 14. 1995. mechanics violated several aspects
of the radiological work permit (RWP) while performing a weld repair to
the Unit 2 letdown system inside containment.
Immediate corrective
actions were documented in NRC IR 50-280. 281/95-23. Additional actions
to preclude recurrence included event discussion during a station human
performance stand down day. revisions to contractor training emphasizing
individual accountability. enhanced maintenance department supervision
over RWP practices during the Spring 1996 refueling outage. and
increased on the job radiological protection (RP) assessment.
The
inspectors subsequently observed RP practices during the Unit 1 incore
detector D repairs and during the Unit 2 reactor coolant pump oil leak
investigation.* These observations were documented in NRC IR 50-280.
18
281/96-01 and 96-02.
Work activities were well planned with appropriate
considerations to minimize radiation exposure.
Subsequent field
observations indicate that workers have improved their understanding of
RWP requirements and individual responsibilities.
The inspectors
concluded that corrective actions to improve RWP comprehension. RP
coverage within containment. and stay time assessment were effectively
implemented.
Fl
Control of Fire Protection Activities
Fl.l Resolution of Thermo-Lag Fire Barrier Issue (64704)
a.
Inspection Scope
The inspector reviewed the action taken to resolve the degraded Thermo-
Lag fire barriers to determine if this action was consistent with the
NRC requirements.
b.
Observations and Findings
In 1991. the NRC found that Thermo-Lag fire barrier material did not
perform to the manufacturer's specifications. Specifically, the
installed Thermo-Lag barriers would actually provide approximately one
half of the specified rating, i.e .. a 1-hour fire rated barrier would
provide approximately 20 to 30 minutes of protection.
The NRC issued
NRC Bulletin 92-01. Failure or Thermo-Lag 330 Fire Barrier System. and
requested licensees with Thermo-Lag fire barriers to take the
appropriate compensatory measures for the areas where the Thermo-Lag
materials were installed. Virginia Electric and Power Company responded
to this bulletin by letters dated July 29. 1992: April 12. 1993: and
December 15. 1995.
The following actions had been taken on this issue
at Surry:
Containment:
The December 15. 1995. letter submitted to the NRC provided a
justification and requested an exemption for the continued use of
Thermo-Lag as a radiant energy shield in the containment.
This item is
presently under review by the NRC.
Communication System Cables in Unit 1 Cable Vault and Emergency
Switchgear Room:
Plant modification DCN 91-10 installed a new radio communication system
with redundant power supplies in separate fire areas as indicated by
drawing 11448-FE-90KA.
The inspector reviewed this drawing and walked
down the new installation.
The new system met the separation
requirements of 10 CFR 50 Appendix Rand the electrical cables for the
old system are no longer in use.
This issue is resolved.
19
HVAC Ducts in Turbine Building Between Fire Dampers and Control Room and
Emergency Switchgear Rooms:
The licensee performed an engineering evaluation and determined that the
installation of the degraded Thermo-Lag installed on the HVAC ducts in
the Turbine Building between the fire dampers and the control room and
emergency switchgear rooms provided protection equivalent to the
required 3-hour fire rating. This evaluation was included in the Surry
Appendix R Report and was based on the 2-hour fire rating of the HVAC
ducts. approximately 1-hour rating of the Thermo-Lag material on the
duct and on the fire suppression system provided in the Turbine
Building.
The inspector reviewed this evaluation and had no questions.
Charging Pump Service Water Pump Supply Piping:
A Thermo-Lag 3-hour fire barrier was initially installed in Mechanical
Equipment Room 3 to provide a fire barrier for the protection of the
fiberglass service water piping to the charging pumps.
This Thermo-Lag
material had been removed and replaced by a cememtitious fire barrier
material. Pyrocrete 241. which was listed by Underwriters* Laboratories.
Inc .. as having a 3-hour fire resistance rating.
The inspectors
reviewed work request 262077-02 (Tracking No. 93-013-001). performed a
walkdown inspection of the installation and verified that this
replacement fire barrier system had been installed. This issue is
resolved.
c.
Conclusions
Based on this review. the licensee has been proactive in the resolution
of the Thermo-Lag issue.
Fl.2 Storage and Preventive Maintenance of Appendix R Repair Equipment
(64704)
a.
Inspection Scope
b.
The inspector reviewed the storage and maintenance of the spare
equipment designated as repair components required to meet the
requirements of 10 CFR 50 Appendix R.
Observations and Findings
During the Appendix Revaluation of Surry. a number of components-were
identified which may be required to be repaired in the event of an
Appendix R fire. These repair items were identified by Procedure
O-EPM-2303-01. RHR/CC Appendix R Equipment Inspection. revision 2. and
were stored in the site warehouse.
The inspectors toured the warehouse
and reviewed the storage of these items.
The small equipment items.
tools. and miscellaneous parts were stored in four locked gang boxes .
The inspectors did not reinventory these items since they had recently
been inspected by the licensee and the gang boxes were locked.
The
20
warehouse also contained two large motors. two pumps (one Residual Heat
Removal (RHR) and one Component Cooling Water (CC)). four electric motor
driven exhaust fans. four large cable reels and miscellaneous equipment.
This equipment was satisfactorily stored.
The inspector reviewed the preventive maintenance required to be
performed on the two large electric motors [Spare Motors 108 and 109] by
Procedure O-EPM-2302-01. Quarterly Inspection of Stored Motors.
revision 1.
This procedure required the electric motor shafts to be
rotated at least two turns at each quarterly inspection.
The most
recent quarterly inspection was performed on September 3. 1996. but the
shafts to these motors were not rotated.
The motor data sheets attached
to these motors identified each quarterly inspection since September
1991.
These data sheets indicated that the motor shafts had not been
rotated since September 1991.
Attachment 1 to Procedure O-EPM-2302-01
identified the spare motors in storage at Surry.
The September 1996
inspection indicated that several additional motors had also not been
properly rotated. This failure to follow a maintenance inspection
procedure is identified as Violation 50-280. 281/96010-03. Inadequate
Preventive Maintenance Performed on Spare Electric Motors.
After conducting the motor prevention maintenance review. the inspector
requested information from the licensee as to the preventive maintenance
being performed on the spare safety-related RHR and CC pumps.
The
licensee indicated that no preventive maintenance was required or was
being performed on these pumps.
Pending further review of the
licensee's position. this item is identified as Inspection Follow-up
Item 50-280. 281/96010-04. Preventive Maintenance Requirements for Spare
RHR and Component Cooling Water Pumps.
c.
Conclusion
The spare equipment required for repairs following an Appendix R fire
were properly stored.
However. a violation was identified for
inadequate preventive maintenance being performed on the spare safety
related electric motors required for installation following an Appendix
R fire.
In addition. an inspection followup item was identified for
reviewing preventive maintenance practices on safety-related RHR and CC
pumps.
F2
Status of Fire Protection Facilities and Equipment
F2.l Operability of Fire Protection Facilities and Equipment (64704)
a.
Inspection Scope
The inspector reviewed the open maintenance work orders on the fire
protection systems. the system engineer's quarterly report data.
maintenance history and the fire protection systems to determine the
performance trends and the material conditions of the plant's fire
protection systems. equipment and features.
-*
b.
21
Observations and Findings
As of September 20. 1996. there were a total of 22 open work requests
related to the fire protection systems and features.
Most of these were
either routine preventive maintenance items or involved minor corrective
maintenance work.
However. one work item involved the removal and
replacement of a post indication valve which controlled the water supply
to all of the fire protection systems in the SRF.
This valve was
leaking and had been closed.
Replacing this valve was not considered a
major work activity, but the valve had been closed and the fire
suppression systems for the facility had been out of service since
August 12. 1996.
The fire protection systems for the SRF are not
included in the Technical Specifications (TS): therefore. the licensee
had not incorporated any compensatory action due to the lack of fire
protection suppression systems for the facility.
Not implementing
compensatory measures for fire protection features not covered by the TS
was identified as a weakness.
As of the close of this inspection. the
licensee had not established a date for the restoration of this system
to service.
The licensee informed the inspector in the event of a fire.
the closed valve could be manually reopened.
The Surry System Engineering Quarterly Report. Second Quarter 1996 was
reviewed.
The rating of the fire protection systems was satisfactory.
The report also identified problems with the maintenance of the 8-hour
Appendix R emergency lighting units.
The inspector interviewed the fire
protection system engineer and found that the principle problem with
these lighting units was a high battery burn out rate due to the loss of
electrolyte in the batteries which was apparently caused by excessive
heat.
An engineering evaluation was in process.
The resolution of this
problem was scheduled to be completed by late 1997.
The system engineer
informed the inspector of a number of problems being experienced with
the facility's fire alarm system. Although functional. this system is
old. obsolete and no longer manufactured.
Replacement parts have been
difficult to obtain.
The need for the replacement of this system was
identified in QA audit 96-02 of the fire protection program.
The inspector toured the plant and noted that. with the exception of the
out of service fire suppression systems installed in the Radwaste
Facility. all of the systems inspected were operational and well
maintained.
c.
Conclusions
The maintenance records. equipment trending data and inspection of the
fire protection components. indicated that there were no maintenance
backlog on the fire protection systems and. with the exception of the
out-of-service fire suppression systems for the SRF. the maintenance.
operability and performance of these systems were good.
The lack of a
site procedure to establish appropriate compensatory measures for
degraded fire protection systems and features not included in the TS was
identified as a weakness.
22
F2.2 Surveillance of Fire Protection Features and Equipment
a . Inspection Scope
The inspectors reviewed the following completed surveillance and test
procedures:
O-LPR-FP-001. Fire Barriers (18 Months)
O-LPT-FP-005. Inspection of Hose Stations and Fire Extinguishers
(Monthly)
O-LPT-FP-022. Operability Test of Fuel Oil Pump House High
Pressure CO2 System
O-LPT-FP-027. Operability Test of Emergency Service Water Fuel Oil
Tank Room High Pressure CO2 System
1-EMT-0902-02. Fire Protection Low Pressure CO2 System Equipment
Test
O-OPT-FP-006. Flow Tests of Fire Protection System (3 Years)
O-OPT-FP-008. Fire Pump Flow Rate Test (Annual)
b.
Observations and Findings
The completed surveillance tests of the fire protection systems reviewed
by the inspectors were appropriately completed and met the acceptance
criteria. However. the inspectors noted that the fire protection system
engineer had not reviewed all of the completed surveillances and tests.
The licensee informed the inspector that the site policy did not require
system engineering to review all completed test procedures.
Each system
engineer was required to review the results of only approximately 10
percent of the completed surveillance tests.
However. the inspector noted that several completed tests on the
principle fire suppression systems were not reviewed by the system
engineer and trending of the performance of the fire protection systems
to analyze the system's performance characteristics was not being
conducted.
The licensee stated that they planned to evaluate trending
in this area.
The station safety and loss prevention supervisor (fire protection
supervisor) monitored the overall fire protection program and reviewed
the completed tests and surveillances performed by his staff.
He also
reviewed the surveillance findings and test results performed on the
fire protection systems by other groups which were unsatisfactory or did
not meet the acceptance criteria .
-*
C.
23
Conclusions
Appropriate surveillances and tests were being performed on the fire
protection features and systems.
F3
Fire Protection Procedures and Documentation
a.
Inspection Scope (64704)
Procedure VPAP-2401. Fire Protection Program. revision 4. was reviewed
for compliance with the NRC requirements and guidelines.
Plant tours
were performed to determine procedure compliance.
b.
Observations and Findings
Procedure VPAP-2401 establishes the administrative guidance used to
implement the fire protection program at Surry and includes the
requirements for the control of combustibles and ignition sources. and
fire brigade organization and training.
The procedure was satisfactory
and met the NRC requirements and guidelines. except for fire brigade
drills. Fire brigade drills are required by VPAP-2401. Section 6.6.12.
to be conducted quarterly. Drills are performed quarterly for each
operations shift. However. drills are not scheduled to assure that each
brigade member participates in at least two drills per year as
delineated in by 10 CFR 50 Appendix R Item L.3.
This specific portion
of Appendix R is not required at Surry.
The issue is further addressed
in Section F5.
c.
Conclusions
The fire protection program implementing procedure met the commitments
to the NRC.
However. the procedure does not require each fire brigade
member to participate in at least two drills per year.
F5
Fire Protection Staff Training and Qualification
a.
Inspection Scope (64704)
b.
The inspector reviewed the fire brigade organization and training for
compliance with the facility's fire protection program and the NRC
guidelines and requirements.
Observations and Findings
The organization and training requirements for the Surry plant fire
brigade are established by VPAP-2401. Section 6.6.
The fire brigade for
each shift was composed of a fire brigade leader and two brigade members
from operations and two brigade members from security.
The operations
fire brigade leader and members are normally auxiliary (non-licensed)
unit operators.
Each fire brigade member is required to receive
initial. quarterly and annual fire fighting related training and
. ,,
24
satisfactory completion of an annual medical evaluation which provides
certification that the fire brigade member can participate in the fire
brigade.
There were a total of 44 operations personnel and 20 security
personnel on the plant's fire brigade.
Although the normal industry practice is to utilize licensed personnel
as the fire brigade leader. the licensee considered the non-licensed
operators as having sufficient training and knowledge of plant
safety-related systems to understand the effect of fire on safe shutdown
capability to meet the commitments to the NRC.
In addition. licensee
personnel were available for consultation. if required. in the event of
a fire.
The inspector reviewed the training and medical records for five
security and five operations personnel and verified that the training
and medical certification for these employees were up to date.
The drill records for 1995 and the first three quarters of 1996 were
reviewed.
These records indicated that at least one drill per quarter
had been performed for each of the five operational shifts. However.
since security has only four shifts. all four security shifts did not
routinely participate in some of the quarterly fire brigade drills.
In
addition. since normally only approximately five personnel respond to
fire brigade drills. several of the fire brigade members may not
routinely participate in a fire brigade drill.
NRC policy is for each
fire brigade member to participate in at least two drills per year.
This is not required at Surry and is considered a weakness.
The inspector reviewed the list of areas in which fire drills had been
held since 1993 and noted that the drills were performed in a number of
different plant areas to assure that the brigade was familiar with the
fire protection and operational features and fire hazards in these
areas.
c.
Conclusions
The fire brigade organization and training met the commitments to the
NRC.
However. not stipulating a minimum participation of at least two
drills per year for each member of the fire brigade was identified as a
weakness.
F6
Fire Protection Organization and Administration
a.
Inspection Scope
The licensee's management and administration of the facility's fire
protection program was reviewed for compliance with the commitments to
the NRC and to current NRC guidelines.
F7
25
b.
Observations and Findings
The designated onsite manager responsible for the administration and
implementation of the fire protection program was the Station Manager.
This responsibility had been delegated to the Supervisor. Administrative
Service.
The Supervisor. Station Safety and Loss Prevention reports to
the Supervisor. Administrative Services and was responsible for the
station fire protection program and ensuring that the appropriate fire
prevention procedures and surveillance tests of the fire protection
features were implemented.
Completed tests and surveillances performed
by the Safety and Loss Prevention staff were reviewed for accuracy.
Tests and surveillances which did not meet the acceptance requirements
were also reviewed and notification reports were prepared for the
appropriate authorization. Coordination of the station's Appendix R
requirements was provided by a fire protection system engineer in the
Nuclear Engineering group.
Engineering support for the design of the
fire protection features was provided by the offsite Design Engineering
and Support organization.
c.
Conclusions
The coordination and oversight of the facility's fire protection program
met the licensee's commitments to the NRC .
Quality Assurance in Fire Protection Activities
a.
Inspection Scope
The following audits and self assessment report were reviewed:
QA Audit 92-15
Fire Protection and Loss Prevention Audit
(Annual and Triennial)
QA Audit S95-02
Fire Protection and Loss Prevention
QA Audit 96-02
Fire Protection Implementation Program
Self Assessment
Safety and Loss Prevention Fire Protection
Program Self Assessment of July 24. 1996
b.
Observations and Findings
These audits and the self assessments were comprehensive and identified
a number of findings. observations and issues for resolution to enhance
the facility's fire protection program.
The inspectors reviewed the
audit findings from each QA report and verified that the items had been
resolved. except for two items in QA Audit Report 96-02 which were
scheduled to be completed by November 1996 .
- ~
,, I
26
c.
Conclusions
The audits and assessment of the facility's fire protection program were
thorough and appropriate corrective actions were taken to resolve the
identified issues.
Miscellaneous Fire Protection issues
F8.l Fire Protection Related NRC Information Notices
F8.2
The inspectors reviewed the licensee's evaluation for the following NRC
Information Notices (IN) and concluded that these INs had received an
appropriate evaluation and that the required corrective actions had been
completed:
IN 92-18. Potential Loss of Shutdown Capacity During a Control
Room Fire
IN 92-28. Inadequate Fire Suppression System Testing
IN 94-28. Potential Problems with Fire Barrier Penetration Seals
a
IN 94-31. Potential Failure of WILCO. LEXAN-Type HN-4-L. Fire Hose
Nozzles
IN 94-58. Reactor Coolant Pump Lube Oil Fire
(Closed) Inspection Follow-up Item 50-280. 281/95023-02: modification of
MER-5 power supply cable fire barrier to eliminate need for fire watch.
This item was first documented by NRC IR 50-280. 281/93-30. Paragraph 6
and involved the installation of a 1-hour fire rated barrier for the
power cables located in the Unit 2 emergency switchgear room.
This room
provides the power for the control room and emergency switchgear room
chillers. MER-5.
To meet the requirements of 10 CRF 50 Appendix R.
these power cables in the Unit 2 switchgear room were required to be
installed within a 3-hour fire rated barrier. since an automatic fire
suppression system was not installed in this room.
To resolve this
issue. the licensee will retain the 1-hour fire barrier for these power
cables in the switchgear room and will provide an alternate power supply
to the MER-5 chillers from the non-safety related emergency diesel
generator which was recently i nsta 11 ed to meet the "station blackout"
requirements.
Installation of this alternate power supply will be
accomplished by a plant modification which was scheduled to be competed
in late 1997.
Until this modification is completed. the licensee will
maintain the hourly fire watch currently provided for this area.
The inspector reviewed the fire watch patrol records for the Unit 2
emergency switchgear room and ve:ified that an hourly fire watch patrol
was being performed for this area.
i.'
J I
27
V. Management Meetings
Xl
Exit Meeting Summary
The inspectors presented the inspection results to members of licensee
management at the conclusion of the inspection on October 3. 1996.
The
licensee acknowledged the findings presented.
The inspectors asked the licensee whether any materials examined during the
inspection should be considered proprietary.
No proprietary information was
identified .
-'
a I
28
PARTIAL LIST OF PERSONS CONTACTED
Licensee
R. Blount. Maintenance Superintendent
D. Christian. Station Manager
M. Crist. Operations Superintendent
J. McCarthy. Assistant Station Manager. Operations & Maintenance
R. Saunders. Vice President. Nuclear Operations
B. Shriver. Assistant Station Manager. Licensing and Compliance
T. Sowers. Engineering Superintendent
B. Stanley, Director Nuclear Oversight
J. Swientoniewski. Supervisor Station Nuclear Safety
W. Thorton. Superintendent. Radiological Protection
IP 37551:
IP 40500:
IP 60855:
IP 61726:
IP 62703:
IP 64704:
IP 71707:
29
INSPECTION PROCEDURES USED
Onsite Engineering
Effectiveness of Licensee Controls in Identifying, Resolving, and
Preventing Problems
Operation of an ISFSI
Surveillance Observation
Maintenance Observation
Plant Operations
IP 71750:
Plant Supprot Activities
IP 84750:
Radioactive Waste Treatment. And Effluent And Environmental
Monitoring
IP 86750:
Solid Radioactive Waste Management And Transportation Of
Radioactive Materials
IP 92700:
Onsite Followup of Written Reports of Nonroutine Events at Power
Reactor Facilities
IP 92901:
Followup - Operations
IP 92902:
Fo 11 owup - Maintenance
TI 2515/133:Implementation of Revised 49 CFR Parts 100-179 AND 10 CFR Part 71
Opened
50-280. 281/96010-01
50-280. 281/96010-02
50-280. 281/96010-03
50-280. 281/96010-04
Closed
50-280, 281/94009-01
50-281/96001-00
50-280. 281/96002-02
ITEMS OPENED, CLOSED, AND DISCUSSED
Improper actions associated with a containment
entry. This item is under review by regional
management (Section R7).
Respirators issued to nonqualified personnel
(Section R7).
Inadequate preventive maintenance performed on
spare electric motors (Section Fl.2).
IFI
Preventive maintenance requirements for spare
RHR and component cooling water pumps (Section
Fl .2)
IFI
SWSOPI corrective actions (Section 08.1).
LER
Through wall leak in RHR piping (Section 08.2).
Failure to follow procedures for Deficiency Card
initiation (Section 08.2).
30
50-280. 281/95022-01
Missed technical specification surveillance
(Section M8.1).
50-281/95004-00
LER
Installation of damaged circuit card resulted in
Unit 2 manual reactor trip (Section M8.2).
50-281/95005-00
LER
Manual trip due to control rods dropping into
reactor core (Section M8.3).
50-280/95006-00
LER
Loss of SWS pumps due to marine growth (Section
M8.4)
50-280/96005-00
LER
Air binding of SWS pumps (Section M8.5).
50-281/95023-01
vro
Multiple personnel violations of RWP
requirements (Section R8.2).
50-280. 281/95023-02
IFI
Modification of MER-5 power supply cable fire
barrier to eliminate need for fire watch
(Section F8. 2).
50-280.281/96010-02
Respirators issued to nonqualified personnel
Discussed
None
(Section R7) .