ML18152A085
| ML18152A085 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 10/05/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18152A086 | List: |
| References | |
| 50-280-98-07, 50-280-98-7, 50-281-98-07, 50-281-98-7, NUDOCS 9810290251 | |
| Download: ML18152A085 (32) | |
See also: IR 05000280/1998007
Text
Docket Nos . :
License Nos. :
Report Nos . :
Licensee:
Facility:
Location:
Dates:
Inspectors:
Approved by: .
9810290251 981005
ADOCK 05000280
G
U.S. NUCLEAR REGULATORY .COMMISSION
REGION II
50-280. 50-281
50-280/98-07, 50-281/98-07
Virginia Electric and Power Company CVEPCO)
Surry Power Station. Units 1 & 2-
5850 Hog Island Road
Surry, VA
23883
July 26 - September 5. 1998
R. Musser. Senior Resident Inspector
K. Poertner. Resident In~pector
G. McCoy, Resident Inspector (In Training)
S. Freeman. Resident Inspector. Oconee (Sections M8.l
and M8.2)
P. Fillion and C. Smith. Reactor Inspectors (Sections
El.l. E3.l and E8.3 through E8.23)
R. Gibbs. Reactor Inspectof (Section E8.1)
D. Jones. Radiation Specialist (Sections Rl.2. Rl.3.
and Rl.4)
R. Haag. Chief. Reactor Projects Branch 5
Division of Reactor Projects
ENCLOSURE 2
EXECUTIVE SUMMARY
Surry Power Station. Units 1 & 2
NRC Integrated Inspection Report Nos. 50-280/98~07. 50-281/98-07
This integrated inspection included aspects of licensee operations.
engineering, maintenance. and plant support.
The report covers a six-week
period of resident inspection; in addition. it includes the results of
announced inspections by five Region II inspectors.
Operations
Licensee actions in preparation for the potential arrival of Hurricane
Bonnie were conservative and station operation was not i-mpacted by the
storm (Section 01.2).
The Unit 1 Auxiliary Feedwater system was properly aligned for standby
operation (Section 02.1).
The Unit 2 charging pump component cooling system was properly aligned
for normal operation.
The valve alignment procedure did not include the
surge tank sight glass isolation valves.
The licensee revised the
procedure to require that the valves be verified open (Section 02.2).
Maintenance
Unit 2 turbine inlet valve freedom testing was accomplished in
accordance with the procedure requirements and the test results were
acceptable (Section Ml.1).
Ventilation damper maintenance activities were properly documented and
procedures were present at the job site during work activities (Section
Ml. 2).
Engineering
A violation was identified for not correcting design problems.
.
conditions adverse to quality, in a timely manner.
In 1992 the licensee
identified that the setpoint for th~ overcurrent protection of the
inside recirculation spray pump motors could result in spurious tripping
upon motor starting, and that there ~as no analysis or test to
demonstrate that the components in the 125 VDC Station Battery
.Distribution System would receive rated voltage for all design basis
scenarios.
However. these conditions were not corrected as of August
1998 (Section El.1).
Violations of 10 CFR 50.71(e) for failure to update the UFSAR and 10 CFR
50.59 for the facility not being as described in UFSAR were identified.
However. the NRC is exercising discretion and refraining from issuing a
Notice of Violation in consideration of the licensee having a good UFSAR
review program in progress (Section El.1) .
2
There was a weakness. acknowledged by the licensee. in the area of
documenting how significant information such. as information notices is
disposed when that disposition involves closure without a detailed
review by an Operating Experience group reviewer (Section E3.l).
The Maintenance Rule periodic assessment met the requirements of
paragraph (a)(3) of the Maintenance Rule (Section E8.l).
An non-cited violation was identified for a condition outside the design
basis as described in Licensee Event Report 50-280. 281/98008-00.
The
cause was an inadequate test procedure (Section E8.23).
An unresolved item was identified related to not reporting the problem
described in Licensee Event Report 50-280. 281/98008-00 within 30 days
(Section E8.23).
Plant Support
Health physics practices were observed to be proper and high radiation
doors were found to be in good condition and locked (Section Rl.l).
The licensee was maintaining radioactive effluent monitoring
instrumentation in an operable condition and performing the required
surveillances to demonstrate their operability (Section Rl.2).
The onsite meteorological measurements* program was implemented in
accordance with the Updated Final Safety Analysis Report (Section Rl.3).
The licensee was maintaining the Control Room Emergency Ventilation
System in an operable condition and performing the required
surveillances to demonstrate operability of the systems (Section Rl.4).
Security and material condition of the protected area perimeter barrier
were acceptable (Section Sl).
Report Details
Summary of Plant Status
Unit 1 and Unit 2 operated at power the entire reporting period.
I. Operations
01
Conduct of Operations
01.1 General Comments (71707. 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 Hurricane Preparations
a.
Inspection Scope (71707)
The inspectors monitored licensee actions to prepare for the potential
arrival of hurricane Bonnie.
b.
Observations and. Findings
During the inspection period Hurricane Bonnie approached the North
Carolina coast.
The licensee monitored the storm track and implemented
severe weather preparations in accordance with Operations Checklist (OC)
-21. "Severe Weather." and AP-37.01. "Abnormal Environmental Condition."
The Virginia.Electric Power Company (VEPCO) Hurr.icane Response Plan is
triggered by the predtction of hurricane force winds on-site by the
Virginia Power Weather Center.
Hurricane force winds were not predicted
durjng the approach of Hurricane Bonnie: however. the licensee did
.
implement the plan as a precautionary measure.
The inspectors reviewed
the licensee's preparations. reviewed the status of important systems.
and monitored the storm's progress. Maintenance and surveillance
activities performed by the licensee were minimized during the time
frame that Hurricane Bonnie could impact the Surry station .
2
c.
Conclusions
Licensee actions in preparation for the potential arrival of Hurricane
Bonnie were conservative and station operation was not impacted by the
storm.
02
Operational Status of Facilities and Equipment
02.1 Unit 1 Auxiliary Feedwater System
a.
Inspection Scope (71707)
The inspectors performed a walkdown of the Unit 1 Auxiliary Feedwater
CAFW) system.
b.
Observations and findings
During the inspection period. the inspectors performed a walkdown of the
Unit 1 AFW system.
The inspectors reviewed the associated system
drawings. valve alignment procedure. and inspected accessible portions
of the system to verify proper valve alignment and material condition.
The system was properly aligned for standby operation.
The inspectors
identified one electrical breaker handle which required adjustment. This
problem was identified tti the licensee for resolution.
c.
Conclusions
The Unit 1 Auxiliary Feedwater system was properly aligned for standby
operation.
02.2 Unit 2 Charging Pump Component Cooling Water System
a.
Inspection Scope (71707)
The inspectors performed a walkdown of the Unit 2 Charging Pump
Component Cooling CCHCC) system.
b.
Observations and Findings
During the inspection period the inspectors performed a walkdown of the
Unit 2 CHCC system.
The inspectors reviewed the associated system
drawings. valve alignment procedure. and inspected accessible portions
of the system to verify proper valve alignment and material condition.
The system was properly aligned for normal operation.
During review of
procedure 2-0P-51.SA. "Charging Pump CC and SW Systems Valve Alignment."
the inspectors determined the CHCC surge tank sight glass isoration
valves were not verified open by the valve alignment procedure.* The
valves were verified open by the licensee and the procedure was revised
to require that the valves be verified open during performance of the
3
valve alignment procedure.
The inspectors verified that the Unit 1
procedure required that the surge tank isolation valves be verified
open.
c.
Conclusions
The Unit 2 charging pump component cooling system was properly aligned
for normal operation.
The valve alignment procedure did not include the
surge tank sight glass isolation valves.
The licensee revised the
procedure to.require that the valves be v~rified open.
08
Miscellaneous Operations Issues (92901)
08.1
(Closed) Inspection Followup Item (IFI) 50-280. 281/97002-01:
Long term
corrective actions to resolve potential TDAFW pump overspeed trips. The
licensee has initiated a modification package to provide a seal-in
circuit in the turbine driven auxiliary feedwater start circuitry to
prevent the pump from receiving an automatic stop signal based on steam
generator level after an automatic start signal is received.
The*
licensee plans to implement the modification during the next Unit 1 and
Unit 2 refueling outages.
08.2 (Closed) Violation (VIO) 50-280/97003-01:
Loss of containment
integrity.
The inspectors reviewed the licensee's corrective actions
associated with this event and found them acceptable.
The inspectors
verified during the subsequent Unit 2 refueling outage that the specific
deficiencies identified by the violation had been corrected prior to
establishing containment integrity.
I I. Mai ntena nee
Ml
Conduct of Maintenance
Ml.1 Turbine Inlet Valve Freedom Test
a.
Inspection Scope (61726)
b:
The inspectors observed portions of the Unit 2 turbine Inlet Valve
Freedom Test.
Observations and Findings
On September 2. 1998. the inspectors observed the performance of
procedure 2-0SP-TM-001. Revision 10. "Turbine Inlet Valve Freedom Test."
The inspectors observed activities locally at the turbine throttles. in
the emergency switchgear room and in the control room.
During the test.
the number 1 governor valve failed to shut in the maintenance mode and
the D intercept valve shut when the C reheat stop and intercept valves
were tested.
Neither of these problems invalidated the testing in
progress. and both were identified in DR S-98-2142 for further
investigation.
The number 1 governor valve was subsequently repaired.
4
The testing was performed in accordance with the procedural
requirements. and the test results were acceptable.
c.
Conclusions
Unit 2 turbine inlet valve freedom testing was accomplished in
accordance with the procedure requirements and the test results were
acceptable.
Ml.2 Ventilation Damper Maintenance
a.
Inspection Scope (62707)
The inspectors ob~erved portions of the work activity associated with
Work Order (WO) 00375779 and reviewed the completed work package.
b.
Observations and Findings
On September 3. 1998. the inspectors reviewed maintenance activities
associated with WO 00375779.
The WO was generated as a preventive
maintenance activity to lubricate the converter for the valve actuator
assbciated with ventilation damper 2-VS-MOD-200A.
The work activity was
performed in accordance with procedure O-MCM-0504-02. "Ventilation
Damper Actuator Overhaul ... Revision 2-P3.
The work activity consisted
of replacing the existing valve actuator with a new actuator.
The
licensee replaced the actuator to reduce the out of service time
associated with performing the maintenance activity. The licensee plans
to refurbish the actuator that was removed.
The inspectors noted that
the procedure was present at the job site during wotk activities
observed and that the component was properly isolated to allow the work *
activity to commence.
c.
Canel usi ans
Ventilation damper maintenance activities were properly documented and
procedures were present at the job site during work activities observed.
MS
Miscellaneous Maintenance Issues (92700, 92902)
M8.1
(Closed) Licensee Event Report (LER) 50-280/97001-00 and -01:
Shutdown
due to steam drain line weld leak. The events described in this LER
were previously discussed in Inspection Reports (IRs) 50-280. 281/96-13
and 50-280. 281/97-03.
The inspectors reviewed Revisions O and one of
the LER and proposed corrective action plan to prevent recurrence and
found them adequate.
The corrective actions included changing the
procedure for main turbine trip block assembly corrective maintenance to
add pull force testing of the trip solenoid coil. changing the turbine
trip signal functional test to include testing of the trip solenoid
prior to startup. and to replace the source range detectors every third
cycle.
The inspectors verified these actions had indeed been
implemented.
5
M8.2
(Closed) LER 50-280. 281/97002-00 and -01:
One train of auxiliary
ventilation system inoperable outside TS.
This LER and the events
leading to it were previously discussed in IR 50-280. 281/97-02.
Non-
cited Violation CNCV) 50-280. 281/97002-02 was identified for failure to
maintain two trains of Auxiliary Ventilation operable as required by TS.
The inspectors reviewed Revisions O and 1 of the LER and corrective
actions to prevent recurrence and found them adequate.
Revision 1 of
the LER stated that given the state of damper 1-VS-MOD-588. if an
automatic start signal occurred when fan 58A was operating, reverse
rotation of fan 588 could have been enough to cause fan 588 to fail to
start or continue to run.
The corrective actions for Revision 1
included revising the ventilation filter train test to address reverse
rotation considerations on fan operability. including checking for
reverse rotation with the opposite fan running.
The inspectors verified
these actions had indeed been implemented.
M8.3
(Closed) VIO 50-280/97003-02:
Failure to follow maintenance procedures.
M8.4
This violation involved the failure to properly install the cavity seal
ring in preparation for refueling. Corrective actions included the
modification of procedure O-MCM-1150-01. Reactor Disassembly and
Reassembly, to specify a sign-off step for the installation of RTV 3145
sealant along the inner J-seal.
The licensee also committed to form a
task team to review this violation and other maintenance procedural
compliance issues and implement management-approved recommendations.
Revision 6 of procedure O-MCM-1150-01 has been modified such that there
are individual sign-offs for each step of the cavity seal ring
procedure.
The step for sealant application now specifically requires
application along the entire circumference of the inner and outer J-
seals.
The accompanying figure. Figure 13 has also been modified to
clearly indicate where the sealant is to be applied.
A maintenance task team reviewed the maintenance procedural compliance
issues and identified four recommendations which were all accepted by
management.
These recommendations emphasized the role of first-line and
second-line management's monitoring of maintenance field work.
These
recommendations were tracked by the licensee's Commitment Tracking
System (CTS) (CTS Item 3844) and have been completed*.
(Closed) IFI 50-280. 281/97007-02: Alternate Alternating Current CAAC)
diesel coolant temperature concerns and long term actions to resolve the
issue. This item was opened for followup of inspectors* concerns about
the elevated operating temperature of the AAC diesel in certain specific
meteorological conditions.
When the AAC diesel is operated while wind
is from the northwest. the exhaust was blown back into the suction of
the rooftop radiators. resulting in elevated operating temperatures.
As a result of the temperature concerns. the licensee initiated Design
Change Package CDCP)92-052 and modified the diesel exhaust piping such
that the exhaust is released to the atmosphere vertically, at
approximately the same elevation as the exhaust of the radiators. This
will cause the hot exhaust gasses to be carried up and away from the
6
diesel building along with the radiator exhaust and reduce the
overheating problems previously noted.
Although the winds were not out
of the northwest, the AAC di ese_l has been subsequently opera ti ona lly
tested after the installation of the
modification.
M8.5
(Closed) VIO 50-280. 281/97002-03:
Procedures not appropriate to the
circumstances.
The inspectors reviewed the licensee's response to NRC
Inspection Report 50-280, 281/97-02, dated May 6, 1997. which describes
the corrective actions for the above listed violation. This violation
involved two instances where the licensee had failed to prescribe
adequate instructions for activities affecting quality.
Based on the
inspectors* review of the violation response letter and the related
corrective actions. it was concluded that the licensee had completed the
required actions for this violation.
III. Engineering
El
Conduct of Engineering
El.1 Followup to Surry Plant Design Inspection
a . Inspection Scope (37551. 92903)
In February and March 1998, the NRC, Office of Nuclear Reactor
Regulation CNRR), Events Assessments. Generic Communications and Special
Inspection Branch. performed a design inspection of the Safety Injection
and Recirculation Spray systems.
The results of this inspection were
recorded in the design inspection report (NRC Inspection Report Nos. 50-
280, 281/98-201) issued May 11. 1998.
The report transmittal letter and
Executive Summary communicate the following conclusions:
Discrepancies were identified regarding adherence of the systems
to their design and licensing basis.
The team found examples of inadequate corrective action for
potential problems identified by the 1992 Electrical Distribution
System Functional Assessment Can internal assessment).
The team identified a number of UFSAR discrepancies.
The.design inspection report transmittal letter states that any
. enforcement action resulting from that inspection will be handled by NRC
Region II via separate correspondence.
During the week of August 24 -
28, 1998. two Region II inspectors conducted an inspectiori at the VEPCO
corporate offic~ in Richmond. VA. to evaluate the findings of the design
inspection to determine whether they represent violations of NRC
requirements.
Each IFI and Unresolved Item (URI) are discussed in
Section ES, Miscellaneous Engineering Issues .
7
b.
Observations and Findings
Observations and findings regarding the issues of corrective action and
UFSAR discrepancies are discussed below.
Resolution of Design Problems Identified by the Licensee
In December 1992. the licensee completed a calculation which reviewed
and documented the overcurrent protection and coordination for the 480 V
safety-related load centers for Units 1 and 2 (refer to IFI 98201-06).
The number and title of that calculation are EE-0497. Safety-Related 480
V Load Center Coordination.
The Summary of Results section of EE-0497
discusses the Inside Recirculation Spray (IRS) pump motors. and states:
The nominal instantaneous setting is greater than 173
percent of the locked-rotor current. accounting for
the maximum possible DC offset.
Based on the
tolerance of the type OD trip device instantaneous
units (+/- 20%). 173 percent is not maintained.
This statement meant that theoretically the circuit breakers protecting
the IRS motors could trip on motor starting. The relevant design
criterion. as stated on sheet 40 of the calculation. was to have the
instantaneous trip device set above 173 percent of locked-rotor current
as a minimum. with 200 percent being preferred. Actually, the 173
percent setpoints was in terms of locked-rotor amperes at 460 V.
The
inspectors estimated what the voltage at the terminals of the motor
would be upon starting assuming 480 Vat the bus and 300 feet of cable.
The estimate was 446 V.
The setpoint in terms of locked-rotor current
at 446 V was nominal 181 percent. with an uncertainty band of 144 to 199 *
percent. Therefore. the inspectors agreed with the calculation
conclusion that theoretically the motor could trip upon starting. as the
transient starting current could be above the minimum trip point.
The
setpoints have not been re~ised as recommehded by the calculation.
No
DR was written for this problem at the time the calculation was issued.
In March 1997. the breaker for the Unit 1 lA IRS pump spuriously tripped
upon starting. and DR S-97-0943 was initiated. It was reasonable to
assume that there has not been repeated spurious tripping of the IRS
motor circuit breakers upon starting in the past. otherwise problem.
reports would have been written by the operators. This concept was used
by the inspectors to conclude that there was no immediate operability
concern.
Nevertheless. the inspector's position was that the setpoiht
should be brought within the design criteria at the earliest
opportunity. *
In about June 1992. the licensee performed an Electrical Distribution
System Functional Assessment CEDSFA) on Surry. That assessment
.
identified th~t there was no analysis or test to demonstrate that the
components on the 125 VDC Station Battery Distribution System would
receive rated voltage for all de~ign basis scenarios.
Rated voltage is
given as a range. i.e .. minimum and maximum.
EDSFA Item A-105 addressed
the issue of low voltage and Item A-185 addressed the issue of high
8
voltage.
The inspectors were not able to ascertain the official status
of these items.
However. it was clear from discussions with the
cognizant engineers that nothing had been done on these items.
During the period of the design inspection. the licensee performed some
voltage analysis on components selected by the design inspection team
(inspection questions S-98-130 and 131).
These questions were reviewed
by the inspectors during the current inspection. and the inspectors
agreed that the question responses gave some measure of confidence that
there was no immediate operability concern with low voltage.
Both the breaker setpoint issue and the DC voltage analysis issue
represent condition adverse to quality identified by the licensee in the
past for which no DR was written and no corrective action was taken
until intervention by the design inspection team.
These circumstances
represent a violation of 10 CFR 50. Appendix B. Criterion XVI.
"Corrective Action." which requires that conditions adverse to quality
be corrected in a timely manner.
Subsequent to the design inspection.
the licensee has committed to implement corrective actions for these
problems.
In the inspection report response letter. dated July 9. 1998.
on Attachment 1. pages 34 and 35. the licensee states: "The development
of a new DC System transient model and calculation encompassing end
components will be completed by December 16. 1999." The inspectors
examined Commitment Tracking System (CTS) Item No. 4211. and observed
that the action plan included an item to develop a new DC System *
transient model and calculation encompassing end components by December
1. 1999.
The inspection response letter Attachment 1. page 21. states:
"Virginia Power will provide additional tripping margins. as required.
between the individual motor feeders [breaker setpoint] and the locked
rotor curr~nt." Furthermore. it states on page 21 that this will be
accomplished by revising calculation EE-0497 and preparing a DCP to
implement the setpoint changes.
During the inspection the licensee
indicated that the IRS breaker setpoint change will be implemented in a
timely manner.
The inspectors examined CTS Item Nos. 4210 and 4290. and
observed that they were tracking the resolution of problems with
Calculation EE-0497 and specifically the IRS pump breaker problem.
In
addition. the inspection response letter Attachment 2. pages 1 and 2.
discusses the corrective action problem identified by the design
inspection team (and discussed in this section). Attachment 2 proposes
to p~rform a root cause analysis on the poor disposition of the EDSFA
findings and to take programmatic type corrective actions if needed.
The *circumstances described above. i.e .. failure to take corrective
action for identified design type problems. constitute a violation of 10
- CFR 50. Appendix B. Criterion XVId and will be identified as Violation
50-280. 281/98007-01. Failure to Take Corrective Action for Identified
Design Problems.
UFSAR Discrepancies
The design inspection report identified eighteen UFSAR discrepancies..
inaccuracies. inconsistencies etc. These are listed in Section El.4.2
C.
9
of the report. along with some Design Basis Document COBO)
discrepancies.
During the current inspection. the inspectors evaluated
each of the UFSAR items for significance.
Each of the items fell into
one of three categories:
A.
A clarification of original or old wording would enhance the
document
B.
50.71(e) issue
C.
50.59 issue
Based on these evaluations. the inspectors concluded that items in A
above were not violations of NRC requirements.
Items in Band C above
were violations of 10 CFR 50.71(e) for failure to update the UFSAR and
violations of 10 CFR 50.59 for the facility not being as described in
UFSAR. respectively.
However. according to NUREG 1600. "General
Statement of Policy and Procedures for NRC Enforcement Actions." (the
Enforcement Policy) as revised on May 13. 1998. the NRC may refrain from
issuing a Notice of Violation when certain criteria are met for issues
considered old design issues. Discretion may be considered if. in the
Staff's view. the licensee would have identified the violation in light
of the defined scope. thoroughness. and schedule of the licensee's
initiative CUFSAR review program).
The scope of the licensee's UFSAR
review program is defined in a letter from VEPCO to the NRC dated May
23. 1997. on the*subject of an integrated configuration management
program.
The inspectors saw documentation that nine of the eighteen items in the
report were already resolved by the licensee in that the necessary
evaluations had been performed and the revised wording had been
prepared.
The inspectors examined a sample of these changes. and found
that the evaluations and revised wording were correct.
The inspectors
also examined the methodology and data bases utilized in the UFSAR
review program. and found that documentation was detailed and extensive.
The inspectors concluded the licensee had a good UFSAR review program.
The inspectors *also noted that the UFSAR review program had not.*
completed any system at the time of the design inspection.
In summary. the UFSAR discrepancies identified by the design inspection
team did represent a violation of the requirement to update the UFSAR. *
However. the NRC is exercising discretion in accordance Section VII.B.3
of the Enforcement Policy and refraining from issuing a citation for
this Severity Level IV violation.
Conclusions
A violation was identified for not correcting design problems.
conditions adverse to quality. in a timely manner.
In 1992 the licensee
identified that the setpoint for the overcurrent protection of the
inside recirculation spray pump motors could result in spurious tripping
upon motor starting. and that there was no analysis or test to
10
demonstrate that the components in the 125 VDC Station Battery
Distribution System would re~eive rated voltage for all design basis
scenarios.
However. these conditions were not corrected as of August
1998.
.
Violations of 10 CFR 50.71(e) for failure to update the UFSAR and 10 CFR
50.59 for the facility not being as described in UFSAR were identified.
However. the NRC is exercising discretion and refraining from issuing a
Notice of Violation in consideration of the licensee having a good UFSAR
review program in progress.
E3
Engineering Procedures and Documentation ..
E3.1 Conduct of Operating Experience Review Program
a.
Inspection Scope (92903)
The inspectors reviewed the licensee's evaluation for NRC Information
Notice IN 98-22. Deficiencies Identified During NRC Design Inspections.
b.
Observations and Findings
C .
The Significant Information Focus Team. which is the second level of
screening for INs. disposed IN 98-22 as follows: "Close to the North
Anna architect/engineer inspection preparation team review.
Information
copies sent to Configuration Management. Nuclear Training and two
supervisors at the Surry plant." North Anna did not receive an
architect/engineer inspection and the preparation team was dissolved
before it reviewed the subject IN.
The Corporate Operating Experience Coordinator. who chairs the
Significant Information Focus Team meetings, stated that. even though
not documented. the IN was not recommended for detailed review by the
Operating Experience group because each of the items had already been
received via separate communication.
He also stated that the IN was
included in technical staff training.
The inspectors did not
independently confirm these statements.
Apparently as a result of NRC inquiry into the handling of IN 98-22. the
IN has been reopened. and will receive a detailed review by an Operating
Experience reviewer.
The inspectors commented that there appeared to be a weakness in
documenting the reason for closeout of the IN.
The Corporate Operating
Experience Coordinator agreed with that comment.
He indicated that they
were in the process of improving the documentation of reasons for items
closed without detail evaluation by an Operating Experience reviewer~
Conclusions
There was a weakness. acknowledged *by the licensee. in the area of
documenting how significant information such as INs are disposed when
11
- that disposition involves closure without a detailed review by an
Operating Experience group reviewer.
EB
Miscellaneous Engineering Issues
E8.l Maintenance Rule Periodic Assessment
a.
Inspection Scope (37551. 62706. and 92902)
Paragraph (a)(3) of the Maintenance Rule requires that performance and
condition monitoring activities and associated goals and preventive
maintenance activities be evaluated taking into account. where
practical. industry-wide operating experience. This assessment is
required to be performed at least one time during each refueling cycle.
not to exceed 24 months between evaluations.
The inspectors discussed
the requirements .with the corporate Maintenance Rule coordinator who is
responsible for this activity. The inspectors also reviewed the
completed assessment which was issued in March 1998.
b.
Observations and Findings
The inspectors verified that the completed assessment was in accordance
with the guidance contained in NUMARC 93-01. "Nuclear Energy Institute
Industry Guidelines for Monitoring the Effectiveness of Maintenance at
Nuclear Power Plants." Revision 2. which included review of: goals and
monitoring, performance criteria. effectiveness of corrective actions.
balancing of availability and reliability, the use of industry operating
experience. and effectiveness of a preventive maintenance program.
C.
Conclusions
The Maintenance Rule periodic assessment met the requirements of
paragraph (a)(3) of the Maintenance Rule.
E8.2 (Closed) VIO 50-280. 281/97002-04:
Failure to meet the requirements of
10 CFR 50.9(a) for LER 50-280/97002-00. and
(Closed) VIO 50-280/97003-03:
Failure to meet the requi~ements of 10
CFR 50.9(a) for LER 50-280/97001-00.
- The inspectors reviewed the licensee's response to NRC Inspection Report
50-280. 281/97-02. dated May 6. 1997. which describes corrective actions
for the violations listed above.
These violations involved reporting
inaccurate information to the NRC in Licensee Event Reports.
Based on
the inspector's review of the violation response letter and the related
corrective actions. it was concluded that the licensee.had completed the
required actions for these violations.
E8.3
(Open) IFI 50-280. 281/98201-01:
Low Head Safety Injection (LHSI) pump
Net Positive Suction Head (NPSH).
This item involves the method of
calculation of the available NPSH for the LHSI. Inside Recirculation
Spray (IRS) and Outside Recirculation Spray (ORS) pumps.
The issue is
12 -
the same as the issue of Generic Letter 97-04. "Assurance of Sufficient
Net Positive Suction Head for Emergency Core Cooling and Containment
Heat Removal ... issued October 7. 1997.
The NRC is reviewing information
on this issue supplied by the licensee in response to the design
inspection report. in response to the generic letter and in response to
a request for additional information.
The IFI remains open pending
review by the NRC.
E8.4 (Closed) IFI 50-280. 281/98201-02:
Error in Calculatjon SM-104. Reactor
Cavity Water Holdup.
The IFI was opened because calculation SM-104.
Revision 1. failed to account for some of the water volume lost over a
period of time from the containment floor.
The calculation was revised
by the licensee to address this concern.
The inspectors reviewed
revision 2 of the calculation which determined the available Net
Positive Suction Head (NPSH) for safeguard pumps following a design
basis Loss of Coolant Accident (LOCA) based on the effects of the
following:
Holdup of spray water in the reactor cavity
Recirculation spray piping fill volume
Draining condensate films on passive heat sinks in containment
Suspended spray droplets in the containment atmosphere.
Based on the results of the above analysis the following penalties were
applied to currently reported available NPSH values in order to reflect
the integrated effects of these uncertainties:
Outside recirculation spray pumps; -0.15 foot
Inside recirculation spray pumps~ -0.16 foot
Low head safety injection pumps; -0.17 foot.
The licensee prepared UFSAR change request number FS-98-021 to revise
UFSAR sections 6.2 and 6.3.
The basis for this change was Westinghouse
Nuclear Safety Advisory Letter (NSAL)97-009. Containment Sump Issues.
The licensee's review of the issues listed in NSAL 97-009 led to the
conclusion that the penalties documented in calculation SM-104. Revision
2. should be subtracted from ~urrently reported NPSH for the spray
.
pumps.
The inspectors reviewed the 50.59 evaluation. performed for the
UFSAR change, and verified that the UFSAR change request was in the
licensee's commitment tracking system with a schedule completion date of
August 31. 1998.
This item was being tracked by Task Item No. 682.
Based on objective evidence reviewed this item is closed.
EB.5
(Open) URI 50-281/98201-03: -Unit 2 LHSI pump minimum flow.
The design
inspection team identified that one of the Unit 2 Low Head Safety
Injection (LHSI) pumps could be subjected to less than rated minimum
13
flow for certain design basis scenarios. The susceptibility of the LHSI
pumps to interact during recirculation at close to shut off head
conditions was documented by the licensee on DR S-98-0660.
Additionally. in response to DR S-98-0660 the licensee prepared
calculation number ME-0558 in order to evaluate a proposed plant
modification to the Unit 2 LHSI pump recirculation piping.
The
inspectors reviewed calculation ME-0558 and determined the scope of the
plant modification to include relocating each LHSI pump recirculation
line from downstream of the pump discharge check valve to upstream of
the discharge check valve.
The calculation* concluded that with
implementation of the plant modification the LHSI pumps discharge flow
rates during parallel operation will result in flows of* approximately
132 gpm for pump 2-SI-P-lA and 185 gpm for pump 2-SI-P-lB.
As discussed
in NRC Inspection Report Nos. 50-280. 281/201. paragraph E.1.2.1.2(g).
the Unit 2 LHSI pumps .were considered operable based on 18 gpm
recirculation flow and operator action within 30 minutes to secure one
LHSI pump.
Consequently, the post modification flow rate of 132 gpm and
185 gpm were considered adequate to maintain the Unit 2 LHSI pumps
The licensee in their response letter to the design inspection. dated
July 9. 1998. committed to implement a plant modification during the
1999 Refueling Outage (RFO) for Unit 2 and the 2000 RFO for Unit 1 in
order to resolve this issue. The licensee also committed to review
their response to NRC IEB 88-04 to ensure that there are no other
invalid assumptions regarding pumps that are susceptible to potentially
harmful interactions. * The review will be completed by October 1. 1998.
and a revised response submitted if necessary.
The URI remains open pending evaluation of other potential design basis
issues.
E8.6
(Open) IFI 50-280/98201-04:
Motor thermal overload for 1-SI-P-lB.
In
the licensee's response to the design inspection report. dated July 9.
1998. the licensee committed to provide overcurrent protection for the
1-SI-P-lB motor by adjusting the setpoint of the trip devi.ce or
replacing the trip device if necessary.
The inspectors observed that
this item was tracked by CTS No. 4288.
Also. the licensee has been
requested to furnished additional details of the equipment in a
telephone conversation on July 28. 1998.
The IFI remains open pending
review by the NRC.
E8.7
(Open) IFI 50-280. 281/98201-05:
Adequacy of 4160 VAC electrical cables
to withstand fault current.
Reference to IEEE standards indicates that.
given the available short-circuit current magnitude. the breaker
operating time and the type of cable (aluminum conductor), a minimum
size of 250 KCM would be required to ensure that the 250 °C momentary
temperature rating is not exceeded.
The problem is that several
circuits have smaller conductors. for example the charging pump motors
are fed with No 1 AWG size cable.
The fact that some cables are
undersized from a short-circuit viewpoint means that. if a short-circuit
were to occur on one of those cables. the protecting circuit breaker
14
could not possibly operate fast enough to prevent severe damage along
the whole length of the cable. This situation raises questions about
whether the installation meets Appendix R requirements.
One specific
question is whether a fire induced short-circuit on a circuit not
required for safe shutdown could result in significant damage to a safe
shutdown required circuit given the fact that the two circuits could be
in close proximity in a cable tray.
As stated in the licensee's response to the design inspection report.
dated July 9. 1998. and as confirmed during the inspection. the
licensee's approach to resolving this issue is to attempt to obtain test
reports that will show that a cable damaged by short-circuit could *not
result in damaging an adjacent cable to the extent that it could not
perform its intended functi.on.
The licensee stated they had knowledge
that tests had already been conducted for use at another plant that
would apply to the Surry situation.
The inspectors* position was that the licensee's approach was
reasonable. and they should be given a* reasonable period of time to
pursue that approach.
Should the licensee use a test report to show
that the existing installation is acceptable. the NRC would want to
review that report.
In addition. the NRC would want to verify by on-
site inspection that configurations assumed in the report are consistent
with the actual installation. If the test report cannot be obtained or
cannot be used to show acceptability of the existing installation. then
compliance with Appendix R would be in question. and the NRC would
monitor that situation.
For the reasons stated herein. the IFI remains
open.
E8.8
(Closed) IFI 50-280. 281/98201-06:
Breaker-to-breaker and breaker-to-
fuse analysis. This issue involves problems discussed in the Summary of
Results and Conclusions sections of -Calculation EE-0497.
This
calculation was Completed in December 1992. and its purpose was to
determine the setpoints of the overcurrent trip devices at the safety-
related 480 V load centers of both units.
It was a re-constitution type
calculation generated because the basis for the original setpoints was
lost. The IFI does not involve breaker to fuse coordination as that is
not covered by Calculation EE-0497.
The Summary of Results section states that several problems (with the
existing setpoints) were identified in the calculation. but that none of
thes~ were safety significant. The inspectors reviewed each problem
discussed in the Conclusions section of the calculation.
The inspectors
agreed that the problems were not safety significant. except for* one
case. That case is the setpoint for the IRS pump motors. which is
discussed in Section El.1 of this report under the heading: Resolution
of Design Problems Identified by the Licensee.
In the response letter
to the design inspection report. dated July 9. 1998. the licensee
committed to resolve all issues discussed in the EE-0497 calculation by
making setpoint changes if necessary.
The inspectors noted that CTS
Items 4210 and 4290 were tracking this item.
The IFI was closed.
15 *
E8.9
(Closed) IFI 50-280. 281/98201-07:
Breaker replacement.
In their
response to the design inspection report. the licensee committed to
replace circuit breakers as necessary at the next refueling outages to
make the enhancements recommended. or implied by, the analysis of
penetration protection.
The analysis is contained in Technical Report
EE-0094. Containment Electrical Protections - Electrical Protection
Devices - Power Circuits Surry Unit 1. and EE-0095 for Unit 2.
The
inspectors reviewed these technical reports. and agreed with the
licensee's position that the technical report conclusions did not
represent any operability concerns.
The inspectors observed that CTS
Item No. 4291 was tracking this work scope.
E8.10 (Open) URI 50-280, 281/98201-08:
Emergency Diesel Generator (EOG)
battery transfer switch.
The design inspection team identified that
there was no analysis to demonstrate the capacity of number 3 EOG
battery to supply two sets of EOG loads.
The lack of analysis raised
questions about a possible common mode failure. because the breaker
which could connect the second set of loads did not have sufficient
administrative controls.
In response to the NRC's concern the licensee prepared Potential Problem
Report (PPR) No.98-021. dated March 2. 1998, which described the desigh
adequacy of the transfer switches used to allow 125 VDC control power
for the number 1 and/or 2 EDGs to be supplied from number 3 EOG battery .
This PPR documented an evaluation of the applicable design criteria for
the original plant design and the licensing basis for the use of these
switches.
The PPR stated that because use of the throw over switches
were permitted by procedure and no analysis of their use was found. it
was recommended that a station DR be written in order to initiate
corrective action.
The PPR also recommended that (1) operation of the
switches be prevented by pulling their respective fuses and locking them
in the position where each battery is powering its associated EOG 125
voe load; and (2) revising plant procedures O-AP-17.04 and O-FCA-12.00
to remove the requirement for use of the switches.
In the response to the design inspectioh report. dated July 9. 1998. the
licensee stated the switch has been disabled by locking them in the
"open" position. -The inspectors reviewed station DR S-98-0605 and
verified that the recommendations of PPR-98-021 had been incorporated
for disabling the transfer switches and revising the procedures to
delete the steps detailing operation of the switches. This item has
been incorporated in the licensee's commitment tracking system and
assigned CTS No. 4202 to ensure completion of this commitment by June
30. 1999. Additionally, a Request for Engineering Assistance (REA) has
been submitted for preparation of a design change package to either
physically remove or physically secure the throw over switches to
prevent their use in the future.
Although these corrective actions were
adequate to address the issue. the URI will remain open pending review
by the NRC to determine whether an unreviewed safety question was
involved during past operation.
16
E8.11 (Open) URI 50-280. 281/98201-09:
DC tie breaker. This item was
identified in connection with a concern of whether closing the DC tie
breaker with both batteries connected to the DC busses constituted an
Unreviewed Safety Question (USQ).
The licensee wrote station DR S-98-
0719 to document that the interim configuration of two batteries and
four chargers was not covered by a calculation of record and would
likely exceed the fault interrupting current of the bus.
The inspectors
reviewed DR S-98-0719 and determined that the licensee's developed
corrective actions for this item included the following:
Station engineering to provide guidance for revising procedures on
how to perform removal and return to service of the station
batteries by July 31. 1998.
Procedures department to revise procedures 1/2-MOP-EP-30 and 31;
and l/2-MOP-EP-204 thru 207 by September 15. 1998.
The above corrective actions have been incorporated in the licensee's ,
commitment tracking system. Additionally, CTS No. 4292 has been
assigned to monitor completion of the corrective actions which has been
scheduled for October 1. 1998. in the commitment tracking system. This
i tern. remains open pending review by the NRC to determine whether an
unreviewed safety question exists or existed in the past.
Also. the design inspection team identified a issue as to whether the
molded case switch used to cross connect the station batteries met
applicable regulatory requirements (IFI 50-280. 281/98201-10).
Station
DR S-98-0661 was written to document this plant condition and to
initiate corrective action. The inspectors reviewed DR S-98-0661 a~d
verified that corrective actions had been developed for resolution and
recurrence control of this item. *The corrective action plan involved
preparation of a Type 1 report. "Evaluation of DC Cross-Tie Surry
Station." dated July 31. 1998. This report concluded that the existing
molded-case switch which serves as the DC cross-tie does not meet Safety
Guide 6 requirements of having at least one interlock to prevent
operator error that could parallel their standby sources.
It also
recommended that the existing DC system be modified by supplementing the
existing molded-case switch or replacing the single molded-case switch
with two devices. A Request for Engineering Assistance (REA) was
prepared for development of the plant modification in support of
implementation by the end of Unit 2 year 2000 RFO and by the end of Unit
1 year 2001 RFO.
In the response to the design inspection report. dated July 9. 1998.
licensee committed to perform an evaluation to determine whether
modifications were required to comply with Safety Guide 6.
The licensee
also committed to develop design change packages to support
implementation by the end of Unit 2 2000 RFO and by the end of Unit 1
2001 RFO.
The inspectors verified that this item had been incorporated
in the licensee's commitment tracking system and CTS No. 4262 had been
assigned for monitoring closure of all corrective actions.
However.
final disposition of this manner is pending evaluation cif the USQ.
17
E8.12 (Closed) IFI 50-280. 281/98201-10:
DC bus tie interlock. This issue*
has been combined with URI 50-280. 281/98201-09.
Thus. the IFI is
considered closed.
E8.13 (Closed) IFI 50-280. 281/98201-11:
Battery calculation discrepancies.
The inspectors reviewed Calculation No. EE-0046. "125 VDC Loading
Analysis-Unit 1 Batteries: Analysis of New Annunciator Loading,"
Revision 1. Addendum OlB which was prepared by the licensee to address
concerns identified by the NRC.
The calculation evaluated station batteries lA and lB new loading for
the replacement annunciators and incorporated changes to battery lA and
1B load model based on the February 1998 Surry A/E inspection.
The
revision addressed the two-hour accident duty cycle for battery lA and
lB and the four-hour Station Blackout (SBO) duty cycle for battery lA.
Based on the above review the inspectors verified that the changes in
the load model in response to the findings of the A/E inspection
included:
Inverter load based on the accident loading of the vital busses in
lieu of inverter full load rating.
Switchgear manufacturer recommendation for using switchgear spring
charging motor current of 6.5 times rated current of 10 Amps.
Inclusion of an additional breaker operation in the first minute
of the duty cycle for additional conservatism.
Inclusion of a random load for an additional breaker operation
during the duty cycle for additional conservatism.
The licensee in their- response to the design inspection report. *dated
July 9. 1998. committed to revise calculation EE-0046 by March 30. 1999.
to incorporate all A/E inspection findings.
The inspectors verified
that CTS No. 4211 had been assigned to Corporate Engineering for
completion of this item.
Based on objective evidence reviewed this item
is closed.
E8.14 (Closed) IFI 50-280. 281/98201-12:
Battery design margin.
The design
inspection report identified the following concerns with calculation
14937.28. Verification of Lead Storage Battery Size for Emergency Diesel
Generator. Revision 2:
Calculation should provide worst case battery loading by assuming
at least two unsuccessful starts in the first minute.
The starting currents for some DC motors in the EOG starting
circuit may be partially concurrent with the current drawn by the
EOG field flashing circuitry.
18
The second start attempt in the first minute invokes two redundant
starting circuits thereby almost doubling the load demand.
In response to the above concerns the licensee wrote station DR S-98-
0677 to document deficiencies and initiate corrective actions.
Additionally, the licensee in their response to the design inspection
report. dated July 9, 1998. stated that an operability review had been
performed for the issues listed on station DR S-98-0677 and concluded
that the Emergency Diesel Generator (EOG) battery had adequate margin
such that the documented deficiencies do not present an operability
concern.
The license also committed to revise calculation 14937.28 for
the EOG battery two hour load profile to incorporate the concerns listed
above.
Calculation 14937.75. Verification of Lead Storage Battery Size
for Emergency Diesel Generator Under Station Blackout Conditions.
Revision 1. will also be reviewed and revised if similar discrepancies*
are identified.
The inspectors reviewed calculation 14937.28 Revision 2. and verified
that there was a battery margin of 88.8% with its present duty cycle.
The inspectors concurred with the licensee's conclusion that adequate
margins exist and there is not an operability concern for the EOG
battery. Corrective actions documented on station DR S-98-0677 were
reviewed to verify agreement with the licensee's commitment in their
response to the design inspection report. dated July 9, 1998.
The
inspectors verified that these corrective actions had been incorporated
in the licensee's commitment tracking system and CTS No. 4223 had been
assigned to monitor closure of this item scheduled for December 16.
1998.
This item is closed based on objective evidence reviewed.
E8.15 (Closed) IFI 50-280. 281/98201-13:
DC fault contribution.
The design
inspection report documented a concern where a calculation for
determining the EOG batteries short-circuit current had not been
prepared.
The inspectors were informed by the licensee that a station
DR had not been prepared for this item because a condition was never
identifted in which available fault currents exceeded component design ..
The licensee in their response to the design inspection report. dated
July 9. 1998. committed to prepare a EOG battery _short-circuit
calculation by December 1. 1998.
The inspectors verified that CTS No.
4298 had been assigned to this item and responsibility for closure had
been assigned to the Corporate Engineering Group.
This item is closed
based on objective evidence reviewed.
E8.16 (Closed) IFI 50-280. 281/98201-14:
DC load flow/voltage drop.
This
issue is discussed in Section El.l of this report under the heading:
Resolution of Design Problems Identified by the Licensee.
The issue
represents an example of a violation of NRC requirements in the area of
corrective action.
The IFI is closed because satisfactory corrective
actions have been put in place.
19
E8.17 (Closed) IFI 50-280. 281/98201-15: Adequate DC component voltage. This
issue is essentially the same as the issue of IFI 98201-14 except that
IFI 98201-14 dealt with the Station Battery Distribution System and
98201-15 dealt with the Diesel Generator Batteries Distribution Systems.
The issue is that the licensee did not have a calculation demonstrating
that the components would receive rated voltage for all design basis
scenarios.
The inspectors found that the situation with the diesel
generator batteries was not as significant as the situation with the
station batteries for two reasons. First, the loss-of-offsite-power
test conducted each outage very nearly duplicated the design basis
scenario for the diesel generator batteries. Therefore the test went a
long way in demonstrating the system could perform its design basis
function.
Second. the inspectors observed that the diesel generator
battery (Exide EI-5) is capable of supplying 210 Amperes for one minute
and 97 Amperes for one hour.
The calculated load for the first minute
was 83 Amperes.
Therefore. there was a good deal of design margin to
cover any design basis loads that may not appear in the loss-of-offsite-
power_test.
In their response letter to the design inspection. the
licensee committed to develop a new analysis for voltage drop for diesel
generator battery loads.
The inspectors observed that CTS Item No. 4299
was tracking this scope of work.
E8.18 (Closed) IFI 50-280. 281/98201-16:
DC load control.
In thei~ response
to the design inspection report. the licensee committed to revise the
relevant procedures to strengthen the control over adding of loads to
the DC busses.
The specific procedures to be revised were mentioned in
the response.
In addition. the licensee committed to provide training
on the revised procedures.
The inspectors observed that CTS Items 4179
and 4297 are tracking these commitments.
E8.19 (Closed) IFI 50-280. 281/98201-17: Battery surveillance test.
In their
response to the design inspection report. the licensee committed to
revise the procedure for the battery performance test to make the test
consistent with the test described in industry standards (IEEE 450).
The change would continue a performance test until final design end .
voltage was reached thereby determining the true battery capacity.
Previously the test was terminated at the duty cycle time which had
been showing a capacity less than the true capacity.
The inspectors
confirmed that the procedure for emergency diesel No 1 battery was
revised as described above and made effective May 21. 1998.
The
inspectors observed that CTS Item No. 4355 was tracking this commitment.
E8.20 (Closed) IFI 50-280. 281/98201-18:
Fuse control.
In their response to
the design inspection report. the licensee clarified certain statements
in the design inspection report.
The licensee stated that their item
equivalency evaluation procedure was adequate as written.
They
determined that certain individuals were not always using the procedure
when making substitutions of non-safety-related fuses.
Therefore. the
corrective action will be to review the maintenance work management
process to determine whether enhancements are required.
As a minimum.
training will be provided as to how fuse substitutions shall be
20
controlled.
The inspectors observed that CTS Item Nos 4300 and 4301
were tracking these commitments.
E8.21 (Open) IFI 50-280. 281/98201-19:
RS System flow.
The inspectors
reviewed the licensee's corrective actions for resolution of the
deficiencies identified with calculation ME-405 which did not account
for flow diversions from Units 1 and 2 inside recirculation spray (IRS)
and outside recirculation spray (ORS) pumps.
The licensee in response
to the NRC concerns prepared station DR S-98-0673 to initiate corrective
actions including alternatives to minimize flow through the unidentified
flow paths.
The corrective actions developed as*a result of DR S-98-
0673 were tracked under CTS No. 4129 and resulted in initiation of a
Recirculation Spray System Margin Improvement Project.
This project was intended to address the short term and long term
corrective actions identified in the response to station DR S-98-0673
for improving the flow paths from the IRS and ORS systems.
Mechanical
Engineering Technical Report ME-0116. Revision 0. Recommendations for
Recovery of RS System Delivered Spray Flow Losses. described the long
term and short term corrective actions developed by this project. The
short term corrective actions were identified as elimination of the
recirculation flow paths that do not directly contribute to the spray
flows or to the net positive suction head (NPSH) improvements of the
recirculation spray pumps.
The long term corrective actions recommended
remodeling the IRS system and ORS system to include the effects of EOG
frequency variations: voltage variations: and instrument uncertainties.
The long term corrective actions also recommended evaluating the size of
the ORS pump discharge flow restricting orifice and the IRS bleed flow
orifice.
The licensee in their response to the design inspection report. dated
July 9, 1998. committed to implement design changes to eliminate non-
needed -flow paths.for the recirculation spray system by the end of 1998
refueling outage (RFD) for Unit 1 and 1999 RFD for Unit 2.
System flow
calculations were also required to be updated at the time the design
change packages were implemented in order to include those flow paths
that could not *be eliminated.
At the time of the inspection the.
licensee was in the process of developing Design Change Number (DCN) 98-
040. Recovery of RS System Delivered Spray Flow/Surry Unit 1.
The
purpose of this plant modification was to implement the short term*
corrective actions to recover the shortfalls in recirculation flows
doc~mented in CME-98-0013 by closing the valves identified within the
scope of DCN 98-040.
The inspectors observed that table 4 of this
document listed spray flow margins that would be achieved after
implementation of the plant modification. Section 4. "References" of
the DCN. however. did not identify the calculation of record which
supported the values of spray flow margins documented in table 4.
The
inspectors were inform~d by the licensee that a formal calculation had
not yet been prepared to demonstrate the margins that would be available
after implementation of the plant modification. Station DR S-98-0673
identified CTS No. 4129 as the tracking mechanism for ensuring that
required corrective actions are completed by the end of the next RFD for
21
each unit. This item is left open until plant modification DCN 98-040
and the associated system flow calculations have been approved and
issued for use.
E8.22 (Closed) IFI 50-280. 281/98201-20:
Unqualified coatings.
In their
response to the design inspection report, the licensee outlined their
program for resolving the issue of whether debris from unqualified
coatings and other debris could clog the containment sump screens .. The
inspectors discussed the program with the cognizant engineers.
They
presented a detailed program flow chart which depicted 22 specific
activities arranged in three*phases.
They also presented the purchase
order with specification showing that Phase 1 work had been awarded to
an outside engineering firm.
The inspectors concluded that
implementation of the coatings/debris program should resolve this issue:
E8.23 (Closed) LER 50-280. 281/98008-00: Auxiliary ventilation fans in a
condition outside design basis for certain accidents. Auxiliary
ventilation fans l-VS-F-58A and -58B are components in the Emergency
Ventilation Filtration System which provides a method for control of
airborne isotopes and provides cooling for the charging pumps.
The fans
are safety-related and they are shared between the two units.
Normally,
the 58A fan is aligned to the lH bus and the 58B fan is aligned to the
2H bus.
The design provided for the capability to align the 58A fan to
the 2J bus by physically disconnecting and reconnecting power cables in
splice boxes.
Similarly, the 58B fan could be aligned to the lJ bus.
The auxiliary ventilation fans receive safety injection start signals
and loss-of-power load shed signals. Surveillance test OPT-ZZ-001 which
is basically a logic test of safety injection and load shed signals
included these fans in the test.
One of the power supply .realignments
described above (depending on which unit was in the refueling outage)
was made during the test. because it was thought necessary to actually
make the realignment to test all the logic. Specifically, it was
thought that realignment was necessary to verify load shedding upon a
loss of voltage .. When in the test alignment. the Emergency Ventilation
Filtration System was outside the design basis.
For example. a test
condition could be Unit 1 on-line and Unit 2 in an outage.
A typical
surveillance test alignment was the 58A fan aligned to the 2J bus and
the 58B fan aligned to the 2H bus.
Then. if a Unit 1 LOCA were to occur
coincident with loss-of-offsite-power (this means on both units). and
the No. 2 emergency diesel generator failed to start. power would be
lost to both .the fans.
The 58B fan would loose power due to failure* of
the No.2 emergency diesel generator. and the 58A fan would loose power
due to the loss-of-offsite-power. Apparently, the licensee did not *
recognize in the past that the design basis was not met while in the
test configuration.
The licensee identified this problem while they
were discussing the concept of whether the design bqsis is a loss-of~
offsite power *on one unit or on both units.
Review of outage history
data from 1994 by the licensee showed that the test alignment was
maintained for extended periods of time following completion of the OPT-
ZZ-001 test. The three longest durations in the test alignment were 142 *
days, 42 days and 25 days.
22
The cause of this problem was that the test procedure OPT-ZZ-001 did not
adequately control the test in that it did not specify restoring the
normal alignment immediately following the test. nor did it initiate an
Limiting Condition for Operation (LCD) clock when the test alignment was
entered. These circumstances represent a violation of 10 CFR 50.
Appendix B. Criterion XI. "Test Control." which requires that testing be
performed in accordance with written test procedures which incorporate
. the requirements and acceptance limits contained in applicable design
- documents .
The licensee's corrective action to preclude recurrence of this problem
has already been developed and initiated. The basic resolution is to
leave the 58A and 58B fans in their normal alignment during the logic
testing. This solution became apparent once it was realized that the
load shed function could be tested while in the normal configuration.
The inspectors reviewed the concept of this change to the test
procedure. along with the safety evaluation for the change. and
concluded that it was a valid resolution to the problem.
Since the violation was non-repetitive. licensee identified and the
corrective action was developed and close to implementation. it will be
treated as a Non-Cited Violation. consistent with Section VII.B.l of the
NRC Enforcement Policy. It is identified as Non-Cited Violation 50-280.
281/98007-02. Emergency Ventilation Filtration System Outside Design
Basis for Certain Scenarios for Certain Periods of Time.
While reviewing LER 98-08 the inspectors observed that the LER was not
submitted within 30 days of discovery of the event.
The inspectors
considered. the discovery date to be the initiation date of the
underlying DR.
Deviation Report S-98-0503 describes the deviation as
follows:
The alternate power supplies for l-VS-F-58A and l-VS-
F-58B are the 2J and lJ power supplies respectively.
Due to the #3 EOG being.the swing diesel generator.
when the'58 fans are powered by the alternate power.
source. a loss of offsite power would result in the
loss of power to the fan if the #3 EOG transferred to
the other unit.
- The DR indicates the date of discovery was February 20. 1998.
The LER
report date was May 22. 1998. which was 91 days after the date of
discovery.
The licensee stated the interpretation that 10 CFR
50.73(a)(l) which requires that LERs be submitted within 30 days after
discovery of the event allows for evaluation time in the case of design
basis issues. Their practice has been to start the 30 day clock upon
final determination that the condition is in fact reportable.
The NRC
will review this interpretation further before making a final
determination as to whether this practice violates NRC requirements .
The matter is identified as URI 50-280. 281/98007-03. Failure to Submit
LER Withtn 30 Days.
23
IV. Plant Support
Rl
Radiological Protection and Chemistry Controls
Rl.l General Comments (71750)
On numerous occasions during the inspection period, the inspectors
reviewed Radiation Protection (RP) practices including radiation control
area entry and exit, survey results. and radiological area material
conditions.
In addition. the inspectors reviewed the status of numerous
locked high radiation doors and found them to be.in good condition and
locked. Overall, no discrepancies were noted. and the inspectors
determined that RP practices were proper.
Rl.2 Radioactive Effluent Monitoring Instrumentation
a.
Inspection Scope (84750)
The inspectors reviewed procedures and records pertaining to
surveillances and alarm setpoints for selected radioactive effluent
monitors.
The surveillance procedures and established alarm setpoints
were evaluated for consistency with the operational and surveillance
requirements for demonstrating the operability of the monitors.
Those
requirements were specified in sections 6.2.2 and 6.3.2 and Attachments
3 and 12 of VPAP-2103, "Offsite Dose Calculation Manual (ODCM)."
b.
Observations and Findings
The inspectors toured the Control Room and relevant areas of the plant
with a licensee representative to determine the operational status for
the following effluent monitors.
RM-RRM-131 .
l-SW-RM-120
l-GW-RM-130-1
l-VG-RM-104
Radwaste Facility Liquid Effluent Line
Circulating Water Discharge Line
Process Vent Noble Gas Activity Monitor
- Ventilation Vent Noble Gas Activity Monitor
The above monitors were .found to be well maintained and operable at the
time of the tours.
The irispectors reviewed 14 procedures related to channel checks. source
checks. channel calibrations. channel functional tests. and alarm
setpoints for the above listed monitors.
The inspectors determined that
the procedures included provisions for performing the required
surveillances in accordance with the relevant sections of the ODCM and
at the specified frequencies.
The inspectors also reviewed recently
completed surveillances for the above listed monitors.
Those records
indicated that the surveillances were being kept current and *performed
in accordance with their applicable procedures.
The inspectors also
verified that the current alarm setpoints for three of the above listed
monitors were determined in accordance with the licensee's .procedure for
24
establishing effluent setpoints and were more conservative than required
by the ODCM.
The licensee indicated that effluent monitor percent availability was
not routinely tabulated. therefore. the inspectors reviewed the
licensee's records of DRs pertaining to the four selected monitors.
During the period January 1997 through July 1998 no DRs were issued for
monitors RR-RRM-131 and 1-SW-RM 120. five were issued for monitor 1-GW-
RM-130-1. and eighteen were issued for monitor 1-VG-RM-104.
Most of the
DRs issued for monitor 1-GW-RM-130-1 were initiated when it was found.
during periodic testing, that the setpoints had reverted to more
conservative default values. apparently due to sporadic electrical
spikes.
The licensee has addressed reliability problems of monitor 1-
VG-RM-104 as evidenced by a decreasing trend in the number of DRs. i.e ..
most of the DRs issued for monitor 1-VG-RM~104 occurred in early 1997
with only three in 1998.
From the items reviewed and discussions with
the cognizant system engineer. the inspectors determined that the
selected monitors were seldom out of service for extended periods except
for scheduled preventive maintenance and surveillance testing.
c.
Cone l us i ans
The licensee was maintaining radioactive effluent monitoring
instrumentation in an operable condition and performing the requited
surveillances to demonstrate their operability.
Rl.3 Meteorological Monitoring Program
a.
Inspection Scope (84750)
b.
The inspectors evaluated implementation of the licensee*~ onsite
meteorological measurements program for consistency with the program
description contained in Section 2.2.1.2 of the Updated Final Safety
Analysis Report CUFSAR).
Observations and Findings
The inspectors reviewed meteorological surveillance procedures and
determined that they included provisions for performing daily channel
checks and semiannual channel calibrations. The inspectors also
reviewed the licensee's records for calibration of the instrumentation
used to monitor wind speed. wind direction. and air temperature. Those
records indicated that the most recent instrument calibrations. which
had been performed during May 1998. were current and had been performed
in accordance with the applicable procedures.
The inspectors reviewed
recently completed Control Room Logs and Operating Records and
determined that channel checks of the meteorological monitoring
instruments had been performed on a daily basis.
During a tour of the
Control Room the inspectors noted that the meteorological monitoring
instrumentation was operable.
- \\
25
The UFSAR indicated that a microprocessor-based data acquisition system
was used for collection of meteorological monitoring data and that the
data were edited for validity each month before being transferred to the
historical database.
The inspectors reviewed licensee records for the
valid data capture rate from the various monitoring instruments.
Those
data indicated that the year-to-date valid data capture rate for the
first six months of 1998 was greater than 99 percent which was
consistent with industry guidelines.
The inspectors determined that the meteorological monitoring
surveillance requirements were met and the instruments were maintained
c.
Conclusions
The inspectors concluded that the onsite meteorological measurements
program was implemented in accordance with the UFSAR.
Rl.4 Control Room Emergency Ventilation System
a.
b.
Inspection Scope (84750)
The inspectors reviewed the licensee's procedures and records for the
surveillances required to demonstrate operability of the Control Room
Emergency Ventilation System (CREVS).
Those procedures and records were
evaluated for consistency with the operational and surveillance
requirements delineated in TS 3.19. 3.23. 4.1 and 4.20.
Observations and Findings
The inspectors toured the Turbine Building. Control Room. Emergency
Switchgear and Relay Room~ and Mechanical Equipment Rooms in which the
Control Room ventilation systems were located. The licensee's cognizant
system engineer accompanied the inspectors on the tours. during which
the major components of the systems were located-and identified. The
emergency ventilation systems included redundant bottled air supply
systems for pressurizing the Control Room for one hour under accident
conditions and four independent air filtration units consisting of fans.
dampers. pre-filters. High Efficiency Particulate Air (HEPA) filters.
and charcoal adsorber filter beds.
The inspectors verified that the air
- flow paths and arrangement of the system components within those *paths
were consistent with the system diagram (Figure 9.13-3) referenced in
Section 9.13.2 of the UFSAR .. The inspectors observed that the
components and associated ductwork were well maintained structurally and
that there was no physical deterioration of the equipment or ductwork
sealants.
The inspectors reviewed selected ventilation system surveillance
procedures and determined the they included provisions for performing
functional tests. filter leak tests. air flow measurements. differential
pressure measurements. and charcoal adsorption efficiency testing .. The
surveillance frequency and acceptance criteria for the test results
26 .
specified in those procedures were consistent with the TS requirements.
Review of selected records of those tests. generally the most recently
completed. indicated that they had been performed in accordance with the
testing procedures and that the acceptance criteria had been met.
The
inspectors noted that the filter leak tests were most recently performed
during January 1997. which exceeded the 18 month surveillance frequency
required by TS 4.20 but did not exceed the plus or minus 25 percent
adjustment to surveillance time intervals allowed by TS 4.0.2.
c . * Cone l us i ons
The inspectors concluded that the licensee was maintaining the CREVS in
an operable condition and performing the required surveillances to
demonstrate operability of the systems.
Sl
Conduct of Security and Safeguards Activities
On numerous occasions during the inspection period. the inspectors
performed walkdowns of the protected area perimeter to assess security
and general barrier conditions.
No deficiencies were noted and the
inspectors concluded that security posts were prop~rly manned and that
the perimeter barrier's material condition was properly maintained.
V. Management Meetings
Xl
Exit Meeting Summarj
The inspectors presented the inspection results to members of licensee
management at the conclusion of the inspection on September 18. 1998.
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.
27
PARTIAL LIST OF PERSONS CONTACTED
M. Adams. Superintendent. Engineering
R. Allen. Superintendent. Maintenance
R. Blount. Manager. Nuclear Safety & Licensing
M. Crist. Superintendent. Operations
E. Collins. Director. Nuclear Oversight
E. Grecheck. Site Vice President
L. Hartz. V. P. Nuclear Engineering
J. Martin. Corporate Maintenance Rule Coordinator*
B. Shriver. Manager. Operations & Maintenance
T. Sowers. Superintendent. Training
B.*stanley, Supervisor. Licensing
W. Thornton. Superintendent. Radiological Protection
IP 37551:
IP 40500:
IP 61726:
IP 62706:
IP 62707:
IP 71707:
IP 71750:
IP 84750:
IP 92901:
IP 92902:
IP 92903:
Opened
INSPECTION PROCEDURES USED
Onsite Engineering
Effectiveness of Licensee Controls in Identifying, Resolving, and
Preventing Problems
Surveillance Observation
Maintenance Rule
Maintenance Observation
Plant Operations
Plant Support Activities
Radioactive Waste Treatment. and Effluent and Environmental
Monitoring
Followup - Plant Operations
Followup - Maintenance
Followup - Engineering
ITEMS OPENED, CLOSED, AND DISCUSSED
50-280. 281/98007-01
Failure to take corrective action for
identified design problems (Section El.1).
No response required for violation.
50-280. 281/98007-02
50-280. 281/98007-03
Emergency Ventilation Filtration System
outside design basis for certain scenarios
for certain periods of time (Section
E8. 23).
Failure to submit LER within 30 days
C Sect i on E8 . 23) .
'1
28
Closed
50-280. 281/97002-01
IFI
Long term corrective actions to
resolve potential TDAFW pump
overspeed trips (Section 08.1).
50-280/97003-01
Loss of containment integrity
(Section 08.2).
50-280/97001-00. -01
LER
Shutdown due to steam drain line
weld leak (Section M8.1).
50-280. 281/97002-00, -01
LER
One train of auxiliary ventilation
system inoperable outside T.S.
(Section M8.2).
50-280/97003~02
Failure to follow maintenance
procedures (Section M8.3).
50-280. 281/97007-02
IFI
Alternate alternating current CAAC)
diesel coolant temperature concerns
and long term actions to resolve the
issue (Section M8.4).
50-280. 281/97002-03
Procedures not appropriate to the
circumstances (Section M8.5).
50-280, 281/97002-04
Failure to meet the requirements of
10 CFR 50.9(a) for LER 50~280/97002-
00 (Section E8.2).
50-280/97003-03
Failure to meet the requirements of
10 CFR 50.9(a) for LER 50-280/97001-
00 (Section E8.2).
50-280. 281/98201-02
IFI
Error in Calculation SM-1047.
"Reactor Cavity Water Holdup"
(Section EB A).
50-280. 281/98201-06
IFI
Breaker-to-breaker and fuse-to-fuse
analysis (Section E8.8).
50-280. 281/98201-07
IFI
Breaker replacement (Section E8.9).
50-280. 281/98201-10
IFI
DC bus tie interlock (Section
EB.12).
50-280. 281/98201-11
IFI
Battery calculation discrepancies
(Section EB.13).
50-280, 281/98201-12
IFI
Battery design margin (Section
EB.14).
!jlal
"
I_
29
50-280. 281/98201-13
IFI
DC fault contribution (Section
E8 .15).
50-280. 281/98201-14
IFI
DC load flow/voltage drop (Section
EB.16).
50-280. 281/98201-15
IFI
Adequate DC component voltage*
(Section EB.17).
50-280. 281/98201-16
IFI
DC load control (Section E8.18).
50-280, 281/98201-17
IFI
Battery surveillance test (Section
EB.19).
50-280. 281/98201-18
IFI
Fuse control (Section E8.20).
50-280, 281/98201-20
IFI
Unqualified coatings (Section
E8. 22).
50-280. 281/98008-00
LER
Auxiliary ventilation fans in a
condition outside design basis for
certain accidents (Section E8.23).
50-280, 281/98007-03
Emergency Ventilation Filtration
System outside design basis for
certain scenarios for certain
periods of time (Section EB.23).
Discussed
50-280. 281/98201-01
IFI
LHSI pump NPSH (Section E8. 3).
50-281/98201-03
Uni-t 2 LHSI pump minimum flow
C Sect i on EB . 5) .
50-280/98201-04
IFI
Motor thermal overload for 1-SI-P-lB
(Section EB. 6).
50-280. 281/98201-05
IFI
Adequacy of 4160 VAC electrical
cables to withstand fault current
(Section EB. 7).
50-280. 281/98201-08
EOG battery transfer switch (Sect1on
EB.10).
50-280, 281/98201-09
DC tie breaker (Section EB .11).
50-280, 281/98201-19
IFI
RS System fl ow C Section EB. 21) .