ML18152A104
| ML18152A104 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 03/02/1990 |
| From: | Fredrickson P, Holland W, Larry Nicholson, York J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18152A105 | List: |
| References | |
| 50-280-90-01, 50-280-90-1, 50-281-90-01, 50-281-90-1, NUDOCS 9003200281 | |
| Download: ML18152A104 (21) | |
See also: IR 05000280/1990001
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UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, N.W.
ATLANTA, GEORGIA 30323
Report Nos.:
50-280/90-01 and 50-281/90-01
- Licensee:
Virginia Electric and Power Company
5000 Dominion Boulevard
Glen Allen, VA
23060
Docket Nos.:
50-280 and 50-281
Facility Name:
Surry 1 and 2
License Nos.:
DPR-32 and DPR~37
Inspection Conducte~:
- January 1 - February 3, 1990
Inspectors:
W. 6o~nioR.sTuent Inspect
.Approved by:
Scope:
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J. W~ ~'sicrent Inspector
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L. E.Nic~o~sident Inspector
--****>>// t/ _d~6L
P. E. Fredrickson. Section Chief
Division of Reactor Projects
SUMMARY
3)-Po
Date Signed
l-/-90'
Date Signed
3-/- ~t)
Date Signed
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Date Signed
. This routine resident inspection was conducted on site in the areas of. plant
operations. plant maintenance, plant surveillance, licensee event report
review, action on previous inspection findings. installation and testing of
modifications, and. evaluation of licensee self assessment capability.
Backshift and weekend tours were conducted ori January 6; 7. 15. 18. 21, *28 *. and
February 3.
Results:
During this inspettion period~ no violations or deviations we~e i~entified. A
strength was identified with regards to the licensee's propo?ed program and
schedule for conducting future safety assessments of major areas at the Surry
Power Station (paragraph 9).
- However, weaknesses were identified in several
functional
areas
including operations. maintenance/surveillance,
and
engineering/technical support. These weaknesses were~
The licensee's actions for ens~ring that operations has good capabilities
to determine RCS leak rates have not occurreq in* a timely manner
(paragraph 3.d).
'
9003200281 QOh~O~
ADOCK 6§666~80
PDC:
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2
A weakness was identified regarding inadequate maintenance practices
involved in repairing a main feed water pump bearing lubrication system
(paragraph 4.a)~
Deficiencies in planning and procurement activities were identified as
weaknesses in the maintenance/surveillance area (paragraph 4.c).
Another example was identified of a weakness previously documented in
Inspection Report 280, 281/89-34 concerning a lack of aggressive identifi-
cation and evaluation of anomalies that occur during surveillance testing
(paragraph 5.a).
An NCV concerning the resin facility project and modification of a
recirculation spray pump was identified as a failure to provide and/or
follow procedures for plant modifications (paragraph 8). These items are
considered to be an indication of a weakness in the control and testing
process of plant modifications.
During closeout of LER 280/89-41, an NCV was identified for failure to meet the
requirements of TS 3. 22 when taking a safety-related fan out of service
(paragraph 6).
During closeout of LER 281/89-12, an NCV was identified for failure to comply
with the requirements of TS 3.12.E (paragraph 6).
1.
Persons Contacted
Licensee Employees
REPORT DETAILS
- W. Benthall. Supervisor. Licensing
R. Bilyeu. Licensing Engineer
- D. Christian. Assistant Station Manager
D. Erickson. Superintendent of Health Physics
- E. Grecheck. Assistant Station Manager
- D. Hart. Supervisor. Quality. QA Department
- M. Kanslef. Station Manager
- A. Keagy. Supervisor of Station Materials
T. Kendzia. Supervisor. Safety Engineering.
- J. McCarthy. Superintendent of Operations
- J. Ogren. Superintendent of Maintenance
- S. Sarver. Superintendent of Planning
- T. Sowers. Superintendent of Engineering
- E. Smith. Site Quality Assurance Manager
- NRC Employees
- R. Mussei, Resident Inspector. RII
- S. Shaeffer. Project Engineer. RII
- Attended exit interview on Feb.ruary 6, 1990.
- Attended exit interview on February 9, 1990.
- Attended both exit interviews.
Other licensee employees contacted included control room operators. shift
technical advisors. shift supervisors and other plant personnel.
Ort January 11. 1990 a manageme~t meeting was held at the Surry Power
Station in order for Virginia Power to provide a progress update to NRC
regional and headquarters personnel on issues of mutual interest.* NRC
management in attendance at the meeting were:
S. Ebneter, Regional Administrator. RII
H. Berkow. Director. Project Directorate II-2. NRR
M. Sinkule. Branch Chief. DRP. RII
B. Buck1ey. Project Manager. NRR
The meeting focused on recent management and staffing changes; current
plant status; corporate support services updates; corporate engineering
and technical support updates; station radiological. operations. and
maintenance updates; and a quality assurance update.
Acronyms and initialisms used throughout this report are listed .in the
last paragraph.
2.
. 2
Plant Status
Unit 1 began the reporting period at power.
The unit operated at power
for the duration of the inspection period.
Unit 2 began the reporting period at power.
The unit operated at power*
for the duration of the inspection period~
3.
Operational Safety Verification
(71707 & 42700)
a.
Daily Inspectibns
The inspectors conducted daily inspections in the following areas:
control room staffing. access. and operator behavior;. operator
adherence to approved procedur~s. TS. and LCOs; examination of panels
containing instrumentation and other reactor protection system
elements to determine that required channels are operable; and review
of control room operator logs. operating orders. plant deviation
reports. tagout logs. jumper logs. and tags on components to verify
compliance with approved procedures.
The inspectors also routinely
accompanied station management on plant tours and observed the*
effectiveness of their influence on activities being performed by
plant personnel .
b.
Weekly Inspections
c.
The inspectors conducted weekly inspections in the followin~ areas:
verification of operability of se.lected ESF systems _by valve
- alignment. breaker posit ions. condition of equipment or component.
andoperability of instrumentation and support items essential to
system actuation or performance~
Plant tours were
conducted which
included observ_ation of general plant/equipment conditions. fire
protection* and preventative measures. control of activities in
progress. radiation protection controls. physical security controls.
plant housekeeping conditions/cleanliness. and missile hazards.
The
inspectors routinely monitored the temperature of the AFW- pump**
discharge *piping* t_o ensure increases in temperature were being
properly monitored and evaluated by the licensee.
Biweekly Inspections
The inspectors conducted biweekly inspections in the following areas:
verification review and walkdown of safety-related tagouts in effect;
review of sampling program (e.g .* primary and secondary coolant
sam~les, boric acid tank s~mples *. plant liquid _and gaseous samples);
observation of .control room shift turnover; review of implementation
of the plant problem identification system (deviation reports);
verification of selected portions of containment isolation lineups;
and verification that notices to workers are posted as required by 10 .
CFR 19.
.
,
,,:
3
. * d.
Other Inspection Activities
Inspections included areas in the Units 1 and 2 cable vaults. vital
battery rooms. steam safeguards areas, emergency switchgear rooms. *
diesel generator rooms. control room. auxiliary building. cable *
penetration areas. independent spent fue 1 s torag*e f ac i 1 ity. 1 ow 1 eve 1
intake structure. and the safeguards valve pit and pump pit areas.
RCS leak rates were reviewed to ensure that detected or suspected
leakage from the system was recorded. investigated. and evaluated;
a~d that appropriate actions were taken. if required.
The inspectors
routinely and independently calculated RCS leak rates using the NRC
Independent Measurements Leak Rate Program (RCSLK9).
on* a regulaf
basis. RWPs were reviewed* and specific work activities were mon,tored
to assure they were bei~g conducted per the RWPs.
Selected radiation
protection instruments were periodically checked, and equipment*
_operability and calibration frequency were verified.
During this. period* the inspectors specifically focused on the
licensee's surveillance procedure which is performed on a daily basis
to determine RCS leak rates.
This review was conducted based on
recent unexplainable variances in reported leak rates for Unit 1. It
should be noted that at no time were leakage rates identified which
were close to TS limits; however. if leakage had increased on the
unit during this period. it may have been difficult to insure that TS
r~quirements were being met.
The survei 11 ance procedure~ PT-10, "Reactor Cool ant Leakage" revision
dated October 17. 1989 was reviewed by the inspector. It
was noted that the procedure had one temporary change attached which
corrected an incorrect density conversion.
The inspector also noted
that the procedure required the operator: to perform numerous
calculations with a hand calculator to average RCS temperatures and
pressurizer levels from different channels.
In addition. curve books
had to be used to determine equivalent tank levels and. numerous
calculations were required to convert different variables for
temperature differences.
The inspector discussed the described conditions with operations
supervision and other station management and questione*d whether any
actions were warranted. *The operations superintendent discussed the
same concerns with corporate engineering in the presence of the
inspector and requested that additional review of the procedure be
conducted in order to provide a more* user friendly product.
The
inspectors. as noted above. have had .the capability to run
independent leak rate calculations on the NRC personnel computer for
several years.
The licensee has incorporated a computer leak rate
program on to the plant's computers.
However, during this review;
these computers were not being used by the operators to perform leak
rate determinations.
This was due in part to the computer programs
needing a revision to correctly provide for density compensation.
In
addition. the SNSOC had not authorized normal use of the pl ant
- .';.,:
....
computer for leak rate determination <;iue to the process not being
under the control of the QA program.
At the end of the inspection
period, the licensee corretted and authorized operations use of the
plant computers for calc.ulation of leak rates.
However. the
inspector noted that due to leakage into the PRT on Unit 1. the
computer was not providing_the required accuracy in leak rate. This
condition . required that the operators continue to use the hand
calculation method to determine leak rates. The inspector considers
that the licensee's actions for ensuring that tiperation~ has good
capabilities to determine RCS leak rates havenot occurred in a
timely manner.
e.
Physical Security Program Inspections
In the course of monthly activities. the inspectors included a review
of the 1 i censee I s phys i ca 1 security program.
The. performance of
various shifts of the security force was observed in the *conduct of
daily activities to .include: protected and vital areas access
contro 1 s; searching * of personne 1 * packages and veh i c 1 es; badge
issuance and retrieval;_escorting of visitors; and patrols and
compensatory posts.
Within the areas inspected~ no violations were identified.
4.
Maintenance Inspections (62703 & 42700)
During the reporting period, the inspectors reviewed maintenance
activities to assure compliance with the appropriate procedures.
Inspection ~reas included the following: *
a.
Main Feedwater Pump - Unit 2
On January 6. 1990, the inspector observed repairs being performed
on main feedwater pump 2-FW-P-lB.
Unit 2 had been ramped down to
less than 70% power in order to accomplish this activity.
The
maintenance activity was being conducted in order to determine why
excessive oil was leaking from oil lubricated bearings located
between the motors.
It should be noted that this component-had been
overhauled and reassembled during the refueling outage that had ended
in September 1989.
The current work was being performed under work
order number 3800090321 and to procedure number EMP-C-EPH-113.
Feedwater Pump Motors 1Bl and 1B2. 4160 Volts MFWP Motor Disassembly,
Repair. and Reassembly.
The cause of the leak was determined to be the result of a bolt that
was missing out of the inner seal on the inboard bearing of the
inboard motor.
The design of this bearing is such that the bolt
penetrates into the oil reservoir and; therefore. if the bolt is not
installed. a direct leakage path would occur.
Inspection of the
maintenance area by the craft determined that no bolt was present
which could have worked its way out of the bearing cap and dropped
5
beneath the motor during operation.
In a~ditfon. a second bolt w~s
found missing on the inner seal of the inboard bearing of the
outboard motor.
The inspector reviewed the work package and discussed this condition
with the maintenance craft supervision.
Based on this review. the
inspector concluded that the missing parts were a result of
inadequate maintenance practices and/or control Of work during the
refueling outage.
However, discussion with supervision indicated .
that the licensee did review this work with regards to insuring that
weak work practices were corrected.
The inspector considers that
this maintenance activity identified a weakness in the way some
balance of plant components were worked during the past refueling
outages.
b.
Main Feedwater Pump-Unit 1
. On January 7. 1990. the i,nspector observed a repair weld being.*
- performed on the suction vent line to pump casing on main feedwater
pump 1-FW-P-lA.
This pump had developed a pin hole leak during
operation at the.interface of the socket weld and base metal.
The weld procedure and certain stages of the welding were reviewed
during the repair process.
The work was performed under work order
number 3800089113.
No discrepancies were id~ntified.
-
c.
Review of Maintenance Activities which Affect Plant Operations
During this inspection period. the inspector focused on two
maintenance activiti~s which were having a dir~ct affect on Unit 1
operations.
The first item was related to operations personnel
having to take administrative control of a cross-connect valv~ in the
- 1 EOG room for the filling of one train of air bottles from the.
opposite trains air compress~r. This operator action was
required at least daily since late October 1989.
The inspector
reviewed the maintenance activity which was causing this action and
determined that work on* a discharge check valve which had been
removed for corrective maintenance on one of the two EOG air bank'~
air compressors was waiting on material for repair.
The check valve
(Ol-EG-42) had been tagged out.for maintenance on October 22, 1989.
Aft~r removal and inspection of the valve, engineering redesigned the
valve application.
This redesign required that material be procured
to complete the modification -of the valve.
The material. 2 1/2"
round stock. was ordered through the procurement system on a material
requisition on December 1. 1989.
The requisition was processed in a
normal manner with an expected date of delivery of February 14. 1990.
The inspector could not determine if any effort was made to expedite
the material; however. after identification. of this item as an area
of interest in the latter part of the inspection period. the
inspector noted that this material request was receiving additional
followup action by the licensee.
After talking to the operations
coordinator in the maintenance/planning area on January 31, 1990, the
6
inspector was informed that the requested material would be received
later that same day.
The inspector considers that the operations
coordinator wa~ supplying operations priorities to o~tstanding work
orders. however. the planning process did not allow for proper
c6nsideration of all outstariding work.
After talking to additional
management later that same day. the inspector learned that the
~aterial -ordered was not certified for its intended application and
would have to be reordered.
The correct material was reordered that
same day and was received within two days.
The inspector noted that
the subject check valve was repaired and reinstalled in the #1 EOG
air start system befor~ this inspection period ended.
.
.
.
.
.
.
- A second item. related to work associated with the correction of an
indicated ground condition on the Unit 1 B vital battery bus also
indicates a lack of prioritization and planning of maintenance
activities.
The _indicated ground was displayed in the control room
and identified by operations as a problem by work request 088416
dated November 29. 1989.
The inspector determined that the work to
troubleshoot this ground condition was authorized on December 12.
1989.
After identification of this item as an area of interest in
~he latter part of the inspection period, the inspector noted that
this item was receiving additional licensee attention. The inspector
was informed on January 22. 1990. that the ground had been traced to
one of the two vital battery chargers. Addi.tional procedures had to
be prepared to continue the troubleshooting of the ground.
When the
inspection period ended. the ground condition and its indication in
the control room still existed and maintenance was preparing to
continue troubleshooting after operations established required
conditions in accordance with the new procedure.
The inspector selected the two proceeding activities to follow up on
due to the concern that these activities either required operations
to take administrative actions in order to compensate for
out-of-service equipment or that operators did not have available
indicaticin in the control room.
The inspector considers that after
NRC involvement. the corrective action for each of these jobs
appeared to move towards resolution faster.
Several problems were
noted during review of each of the maintenance activities.
These
problems included lack of prioritization and good planning for the
maintenance activities and a lack of effective followup on procure-
ment of materials for safety-related work.
The inspectors
conclusions wer~ di~cussed with management and there was agreement
that the planning and procurement activities at the station needed
additional management attention. Planning and procurement activities
deficiencies
were
identified
as
weaknesses_ in
the
maintenance/surveillance area.
Within the areas inspected. no
vicilations were identified.
5.
Surveillance Inspecticins
(61726 & 42700)
During the reporting period. the inspectors reviewed various surveillance
- . **
7
activities to assure compliance with the appropriate procedures as
follows:
Test prerequisites were met~
Tests were peiformed in accordance with approved procedures;
Test procedures appeared to perform their intended function.
Adequate coordination existed among personnel involved in the test.
Test data was properly collected and recorded.
Inspection areas included the following:
a.
b.
Auxiliary Feedwater (AFW) Test.
On January 4. the inspectors witnessed a routine monthly test and a
special full flow test of the Unit 1 AFW system in accordance with
procedures 1-PT-15.lC and 1-ST~273.
The first test involved a normal
demonstration of operability of the turbine driven AFW pump l-FW-P-2.
The inspector independently verified that the pump performance was
within the specified acc~ptance criteria .
The second test (1-ST-273) was performed to ~btain trendtng data for
AFW full flow to each steam generator from the AFW pump 1-FW-P-2 with
and without the use of the AFW booster pumps 1-FW-P-4A & B.
Although
the booster pumps are not required by TS. they could provide an * *
alternate source of feed water from the emergency condensate make-up
tank.
This test successfully demonstrated that full flow to the
steam generators could be achieved with the booster pumps aligned to
the suction of the AFW pumps. * The 1 i censee is considering
performance of this test on*a quartefly basis.
The inspector witnessed the test and noticed that the turbine casing
relief valve was lifting during the test and blowing steam into the
space.
This discrepancy was not annotated on the applicable* test
critique form nor was a station work request submitted until
questioned* by the inspector.
This appears. to be an additional
- example of a weakness previously documented in Inspection Report 280.
281/89-34 regarding a lack of aggressive identification and evalua-
tion of anomalies that. occur during testing.
The licensee had
- internally tasked the operations superintendent to evaluate this
weakness by January 30. 1990.
This latest example further indicates
that action is warranted to enhance the surveillance program.
Charging Pump - Unit 2
On January 10. 1990, inspector witnessed the running of charging pump
2-CH-P-lB in accordance with periodic test 2-PT-18.7. Chargirig Pump
Operability and Performance Test, dated October. 19, 1989. - This
8
surveillance was being accomplished to demonstrate the operability of
the charging pump following maintenance.
The rotating*assembly for
this pump had been replaced thereby altering the pump performance.
The inspec*tors also reviewed EWR No.90-033,. Evaluate CH Pump
Reference Valves. which evaluated the new discharge and vibrational
dat~.
The testing demonstrated satisfactory operation with regards
to flow~ head. and other required parameters.
No deficiencies were
.noted.
Within the areas inspected. no violations_ were identified.
6.
Licensee Event Report Review
(92700) *
The inspecto~s reviewed the LER's listed below to ascertain whether NRC
reporting requirements were being met and to determine -appropriateness -of
the corrective actionsr The inspector's review also iricluded followup on
implementation of corrective action and review of licensee documentation
- that all required corrective actions were. complete.
LERs that identify violations of regulations and that meet the criteria of
10 CFR. Part 2. Appendix C.Section V are be identified as NCVs in the
following closeout para~raphs~
NCVs are considered first-time occurrence
violations which meet the NRC Enforcement Policy for exemption from
issuance of a Notice of Violation. These items are identified to allow
for proper evaluations of corrective actions in the event that similar
events occur in the future.
(Open) LER 280/89-37.
11A
11 S/G Header to Line SI Channel IV Declared
Inoperable Due to Malfunctioning Pressure Comparator. This issue involved
a failure of the subject comparator.
Corrective action for the failure
included replacement with a shop spare and testing after installation.
However. approximately 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after the instrument wa-s returned to
- service. the comparator failed again.
After the second replacement. the
instrument channel worked satisfactorily.
Part of the licensee's correc-
tive actions included a -commitment to review the repair and testing
methods associate_d with module refurbishment in the shop.
During* this
inspection period. a licensee QA audit of instrument maintenance
identified a finding with regards to traceability of electronic components
.. not being maintained.
Specific concerns in the finding related to
instructions not being provided for the repair of process modules.
traceability of the e 1 ectroni c components. and storage of the electronic
components.
The audit (S89-25) was is$ued on January 31. 1990.
The
inspector reviewed the audit finding and will review the licensee's
response and implementation of corrective actions prior to closeout of
this LER.
(Closed) LER 280/89-38. Unplanned Engineered Safety Features Component
Actuation. Auto Start of #3 EOG While Attempting to Shut Down Due to
Existing Hi Hi CLS Signal.
The issue involved an auto start of the #3 EDG
due to an existing CLS signal in the circuitry that had been initiated
9
earlier for special testing and never cleared.
The ilearing of the CLS
signal required tightening of a loose termin~l screw and resetting-of the
hi hi CLS signal.
The EOG was then returned to its automati~ mode of
operation.
This event and licensee corrective action was discussed in
Inspection Report 280. 281/89-28. This LER is closed.
(Close*d) LER 280/89-39.
11A
11 Steam Generator Header to Line Differential
Pressure Input to SI inoperable Due*to Malfunctioning Relay Contact.
The
issue involved a failure of the subject relay contact which was
contrary to the requirement of TS Tab1e 3.7-2. Corrective action included
connection of the leads affected to spare contacts on the relay and
satisfactorily testing of the modification.
In addition. the affected
drawings were revised to indicate the new lead contact locations.
The
inspector verified that corrective actions were ac~omplished.
(Closed) LER 280/89-40. Unplanned ESF Component Actuation~ TV-VG-109A
Failed Closed Due to Loose Connections in the Close Switch.
The issue
involved inadvertent closure of the subject valve due to a loss of
continuity in the electrical circuit to the trip valve
1s solenoid operated
air supply valve.
The valve had failed in its safety position.
Corrective action included tightening loose connections in the circuitry.
~nd satisfactorily testing of the valve.
The in~pector verified that the
corrective actions were accomplished. This LER is closed.
(Closed) LER 280/89~41. Auxiliary Vent Fan Taken.Out of Service Without
Implementing Technical Specification Action Statement Due to Personnel
Error.
The issue involved improper operator action with regards to
entering TS action statement 3.22 when taking a safety-related fan out of
service for maintenance.
The fan was determined to be out of service for*
approximately 30 minutes during the maintenance activity.
However. the
defi~iency was not discovered until after the fan had been ret~rned to
service.
Corrective actions to prevent recurrence which were implemented
by the operations superintendent included issuance of a memorandum to all
operations shift supervisors directing that safety-related equipment be
considered inoperable when their controls are pl~ced in the pull-to-lock
position.* The inspector revi~wed the corrective action arid discussed the
requirement with several SROs on shift.
The inspector considers -that
proper understanding of the requirement .is evident based on these discus-
sions.
This item is identified as an NCV (280/90-01-01) for failure to
meet the requirements of TS 3*.22 when taking a safety-related fan out of
service. This LER is closed.
(Closed) LER 280/89-42. Leakage Through Fault in Letdown System Drain Line
in Excess of Allowable Type
11C
11 Leakage.
The ;ssue involved identifica-
tion of RCS leakage through a crack in a fillet weld ori a socket tee
connecting a drain line to the letdown li.ne inside containment.
The
leakage point was between the inside containm-ent isolation valves and the
containment wall resulting in a containment integrity concern.
Immediate
corrective action included isolation of letdown to reestablish containment
integrity.
Additional corrective action included weld repair of the
10
1 eakage area and return to service of norma 1 1 etdown.
The inspector
verified that corrective actions were accomplished.
This LER is closed.
(Closed) LER 281/89-06, -Unplanned ESF Component Actuation, Closure of
Containment Isolation- Valve Due to Containment Particulate Radiation .
Monitor Alarm.
The issue involved the closure. of the containment
instrument air isolation valves due to the subject ala.rm.
This event was
discussed in inspection report 280. 28i/89-28.
The residents monitored
licensee evaluation and actions during that period *. This LER is closed.
(Closed) LER 281/89-08. Unplanned Engineered Safety Features Component
Actuation, Closure of TV-IA-201B Due to Loose Control Power Fuse.
The
issue involved identification of closure of th~ subject valve by operators
during control room board walkdowns.
Corrective action included identifi-. *
cation of a loose fuse in a fuse block which provided foi control power to
allow the valve to open.
The fuse block terminal clips had loosened
around the control power fuse~
A temporary modification was implemented
to correct the problem and a new fuse block was ordered.
Instrument air
was restored to the valve and the valve was returned to ~ervice after
te~ting.
The inspector reviewed the event and corrective actions.
This
- LER is c 1 osed.
(Closed) LER 281/89-09, Turbine Trip/Reactor Trip Due to 86 BU Trip Caused
by Spurious Actuation of KD-41 Relay.
The issue involved a reactor trip
from approximately 14% power due to a faulted relay in the turbine
generator electrical circuitry protection system.
After the trip all
safety systems performed as *designed.
This event was discussed in
Inspection Report 280. 281/89-28. This LER is closed.
(Closed) LER 281/89-10, Reactor Trip Due to Low Ste~m Generator Level
Following a Higher Than Expected Load Increase During Unit Startup.
The
i.ssue involved an automatic reactor trip from approximately 25% power due
to low low steam generator level which was caused by a rapid load increase
on the unit.
After the trip all safety systems performed as designed.
This event was discussed iri Inspection Report 280, 281/89-28 and
identified a weakness in operator control of the EHC system.
This LER is
closed~
(Closed) LER 281/89-11. Containment Integrity Violated Due to Containment
Penetration Being in an Unanalyzed Condition.
- The issue involved
identification of an improper ~ipe support for a Unit 2 containment piping
This event. including corrective actions. was fully
discussed in Inspection Report 280. 281/89-28. This LER is closed.
(Closed) LER 281/89-12. Individual Rod Position Indicators Out of
Specification For Greater Than 60 Minutes in a 24 Hour Period.
The issue
involved two !RPI in control bank A differing from the bank
1s step demand
position by more than 12 steps for greater than 60 minutes which is in
violation of TS 3.12.E. Corrective action included adjustment of the !RPI
to within limits in the next 15 minutes.
The cause of the violation was
attributed to improper control of logging of times the rods differ from
11
the requirement.
Additional corrective actions to prevent recurrence
included computer modification to alarm prior to exceeding 60 minutes and
modification of the logging procedure. This event is identified as an NCV
(281/90-01-02) for failure to comply with the requirement£ of TS 3.12.E.
This LER.is closed.
Withiri the areas inspected. no violations were identified.
1~
Action on Previous Inspection Findings
(92701. 92702)
a.
(Closed) IF! 280. 281/88-28-03. Review of Testing of CCW Heat
Exchanger Service Water System.
This issue stemmed from the concern*
that the component cooling heat exchangers (CCWHX) may not be able to
remove the necessary heat during certain worst case scenarios.
Inspection Report 280. 281/88-14 identified the initial concern over
. the use of vacuum priming to maintain service water flow. with
additional. inspection documented in Inspection Report 280. 281/88-51.
The inspector reviewed test data and calculations contained in the
- fol lowing documents:
Special Test 243. CC Heat Ex"changer Water Box Level Test.
Ca lcul a ti on ME-207. Opera bi 1 i ty Parameters of the Component
Cooling Heat. Exchangers.
Calculation ME-0222. Addendum 1. Component Cooli~g Water Heat
Transfer Operability Criteria.
Special Test 41A. 1-CC-E-lA Operability Check.
The inspector concluded* that adequate heat transfer capabi 1 i ty had
been demonstrated and is being maintained.
The original concern was
- mitigated somewhat by the raising of the minimal intake canal leve.l * .*
set~oint.
In_addition. the licensee is turrently replacing the heat.
exchangers and improving the instrumentation available to monitor
their performance. Thii !FI is considered closed.
- b.
(Closed) . !FI 280~ 281/89-06-04. Review of audits and weaknesses
concerning drawings and design change contra l .
The inspectors
identified a weakness regarding the licensee method for tracking and
completing *drawing. revisions that are identified- outside the formal
design change process.
For example. drawing discrepancies noted
during operator walkdown of the plant systems were annotated on a
drawing change request form with no unique number or formal tracking
method.
The licensee has since issued a revision to the applicable
- station administrative procedure* that requires a drawing .change
request nu~ber be assigned to each request as it is submitted.
A further concern was identified regarding the absence of any
prescribed time frame for correcting drawing discrepancies* that are*
identified as noted above.
The licensee has instituted a policy to
----
12
. correct drawing discrep~ncies on a similar time frame as required for
design changes. * This policy was being fully implemented in
procedures as the inspection period ended.
The inspector reviewed
a 11 1 i censee actions taken as a result of the above concerns and
consider them adequate.
A review of the completed Quality Assurance audit S89-16. Station
Records and Procedures. was performed for items pertaining to control
room drawings.
The findings. corrective actions. and current status
bf the audit items were discussed with the lead auditor in this area.
The inspector concluded that an adequate audit was conducted in this
area. This !FI is closed.
8.
Installation and Testing of Modifications (37828)
This inspection effort included a review of onsite activities and hardware
associated with the installation of plant modificatioris and .a verification
that related modifications activities are * in confc;>rmance with the
applicable licensing requirements.
This review inclu~ed a plant walkdown
to identify recent or temporary modifications. a review of the current
temporary modifications in place. and a review of several minor and major
modifications.
a.
Minor Modifications
The station currently has* two methods that modify systems and
components.
The design change .. program has his tori cal ly been used for
major plant modifications performed by*construction with an extensive
engineering review and approval process prior to turning a
modification over to the station.
Minor modifications have been
- handled using the EWR program that typically utilizes station
engineering and maintenance.
A programmatic review of the EWR
process was *dqcumented in Inspection Report 220.221/89_;39.
That
review cone 1 uded that previously fdentified weaknesses have been
aggressively pursued.
During this inspection period~ the inspector
questioned the philosophy of having two different programs for
modifications and was informed of a program under development that
encompasses both minor and major modifications.
Implementation of
this new program is currently scheduled to begin this Spring. with an
eventual elimination of the EWR process~
The inspector conducted numerous plant walkdowns during this
inspection period with an emphasis* on minor modifications and
concluded. in general. that adequate control was being maintained.
One example was identified. however. whe~e the licensee could not
- produce any documentation regarding the modification.
This example
involved a pressure gauge installed on the seal assembly vent
connection of the Unit 1 outside recirculati-On spray pump 1-RS-P-2A.
The gauge had no needle or glass face. and was not shown on any
approved station drawing nor carried as a temporary modification.
The recirculation spray p~mp is used in post-accident conditions to
13
draw water from the containment sump and supply if- back to the
containment spray rings.
A failure at this gauge~ coupled with the
gauge isolation valve being open, could compromise the seal integrity
of the pump.* After identification of the issue, the licensee had the
gauge removed.
Although the safety significance of this condition
is limited by the gauge being installed at a vent connection down-
~tream of a normally closed valve, this is identified as a violation
for failure to provide and/or follow procedures with regard to the
modification process.
The vi6lation is being classified as an NCV,
50-280,281/90-01-03; in that the criteria specified in Section v; of
NRC Enforcement Policy were satisfied.
The inspector also questioned the temporary lighting and sump pumps
that are installed in the safeguards valve pit on both units.
The
various power supplies and control devices which are located in the
safeguards valve pit, have no labels and are in a general state.of
disrepair. This i~stallation has been in place for several years yet
the condition is not annotated on any drawing nor GOntrolled as a
Permanently installed pumps, as depicted on
station drawings, have been inoperable for many years.
Although
flooding of the pit should not hinder the operability of the.
- components, it does create a problem with maintenance and introduces
the possibility of exterior pipe corrosion.
The inspector questioned
the threshold for determining a need for temporary modifications and
discussed the specifics of this situation with station management.
The licensee position was that although they believe that the
installation of sump pumps should be .allowed withoµt any formal
modification controls, they stated that a more detailed evaluation
regarding the use of sump pumps would be performed to ensure that
adequate controls are maintained.
The inspector concluded that the
licensee actions were adequate.
b.
Major Modifications
During this inspection period, a major plant modification associated
with the resin transfer facility was reviewed.
The selection of this
modification was due, in part, to *a break in. the instrument* air
system that occurred on January 5.
This break, located within the
modification area boundary, resulted in a transient in the plant
instrument air System.
The initial area of concern, as documented in
deviation report Sl-90~23, was that the broken air pip~ was not shown
on the appropriate control room drawing.
Further investigation
revealed the break location to be in a portion of the instrument air
system being installed for the new resin blend facility.
This
construction effort is being conducted in accordance with Design
Change 85-16 and had not been certified and turned over to plant
operations.
The inspector reviewed the above design change, procedures, and
supporting documentation a~sociated with the demolition and*
construction of a new resin waste disposal system.
Construction of
the new system was essentially complete in November 1988.
However,
14
final functional testing determined that major design flaws existed
- in the system.
Redesign and rework of the system was initiated in
early 1989 and functional testing has now been resumed.
The design
change that performed this work had.l39 field changes in effect at
the end of this inspection period.
The inspector also reviewed procedures and jumpers associated with
resin transfers pe~formed during 1989 and noted that portions of the
modified system had *been u~ed to transfer contaminated _resin prior to
completion of the design change.
The design ~hange program utilizes
a partial technical review process to place in service .smaller
segments of a larger modifications as :they are completed.
This
requirement *is specified in station administrative procedure
SUADM-ENG-03.
11Design Changes
11 * which also requires that SNSOC
approve the technical review prior to operability of equipment
affected by a design change.
This requirement was implemented during
the first half of 1989 in response to an NRC violation in this area.
The inspector reviewed the licensee*~ response to this violation ahd
concluded that corrective actio*ns had been* implemented in June 1989.
These corrective actions require t_hat a partial technical review
process should be initiated by t~e craft for turn ove~ of part of a
modified system prior to completion and testing of the entire modifi-
cation. * This partial closeout requires engineering concurrence for
~ork not completed. * Engineeiing is also responsible for completion
of the installation verificati6n that includes system walkdowns and
documentation that shows the portion of the system being turned over
for operation is complete.
In addition. this review identifies
drawing and procedure revisions that are required.
The completed
par ti a 1 techni ca 1 review package is then presented to SN SOC for
review and approval.
The inspector determined that there had not
been any partial technical reviews performed on Design Change 85-16
up to the time of this inspection.
Additional reviews determined that on at least two occasions after
June. 1989, equipment was used by operations that was installed or
modified by this design change yet the equipment had.not been through
the technical review process.
One of the events involved the - *
contamination of three employees that were attempting to operate a
portion of the system that was modified by the design change.
This
event was discussed in inspection report 89_-34 and resulted in a
violation .. The licensee initial evaluation of this eve~t concluded.
in part. that procedures and/or instructions were inadequate.
The inspector
1 s discussions with the design. engineers involved
indicate that although a formal engineering installation verification
was not performed, design did review the status of the system
~onstruction and testing and felt confident that the portion of the
system being considered for use would perform as required.
After
discussion between the inspector and the licen~ee. applicable control
room drawings were revised on January 30. 1990 *. to match the plant
,;
15
configuration. After these discussions~ the inspector concluded th~t
the licensee investigation into the contamination event up to this
.point had not identified problems which would have been ~ddressed by
the technical review process.
During the inspection. it was also concluded that the interface
between the post-modification test group (Advisory Operations) and*
normal plant operations department was weak.
This group uses generic
test procedures wit~ no formal instructions regarding isolation
and/or pl ant operations.
Their testing frequently energizes
- equipment or aligns untested/modif.ied equipment to plant systems
after only a verbal discuss.ion with the shift supervisor.
The
inspectors held a meeting on January 30 with senior managers to
better understand thts interface and the circumstances surrounding
this modification.
The licensee concluded that adequate controls
were not in place regarding the Advisory Operations process and
initiated action on February 1. 1990. to require a technical review
prior to Advisory Operations aligning the modification to the plant
for testing.
This change should ensure that the control room
drawings and procedures are updated to reflect the modifications
prior to clearing the plant isolatio~. * The ins~ectors concluded that
this action was adequate; however~ they expressed concern .over the
absence of a detailed post-modification test program for control of
plant configuration.
This *concern was di!:;cussed with station
management and they consider that present post-modification testing
control is adequate.
However. after additional discussion. the
Station Manager committed to conduct a review of post-modification
testing control.
The operating procedures and installation of jumpers used for resin
. transfer were found to be vague with numerous mi nor errors.
The
specific resin flowpath used was not apparent from the available
documentation. nor was the flowpath annotated.on an approved station
drawing that was available in the control room. In addition. design
~hange 85-16 was inadequate in that it did not isolate ,the instfument
air system while modifications were being performed. This condition
contributed to the plant instrument air transient that occurred on
January 5. 1990.
The inspectors discusse~ the above findings with station management
throughout the inspection period.
The licensee had suspended resin
movement following the station management briefing of the contamina-
tion event in September. pending the development of more detailed
operating procedures.
Contaminated resin has not been discharged
since that event.
It should also be noted that the licensee had
previously implemented a policy that required SNSOC approval to
transfer resin.
This review and approval process failed to identify
that portions of systems were being used witho~t the proper technical
review.
The inspectors consider that the coordination between
station disciplines were certainly aggravated by the problems and
delays associated with this modification.
16
The inspecto.rs concluded that the lack of compliance with prescribed
management programs, such as technical reviews and procedures, ~oupled
with the lack of adequate procedures regarding system isolation and the.
control of plant configuration during post-modification testing, indicate.
a significant deficiency with regards to the modification and operation of
the resin facility project.
The above examples of a failure to provide
and/of follow procedures pertaining to this project is identified as an
NCV (280,281/90-01-03).
The violation is not being cited because the
criteria specified in Section V. of the Enforcement Policy were satisfied.
In addition, the contamination event was previously identified as a
violation in NRC Inspection Report 280,281/89-34.
9.
Evaluation of Licensee Self-Assessment Capability (40500).
On January 26, 1990, thi: inspector visited the licensee
1 s corporate
offices to attend the corporate nuclear safety meeting and to discuss
current organization and pl ans with the corporate nuclear safety staff.
This monthly meeting is required by TS 6.1.C._2.d.
Included in the
discussion were current issues of interest
to both the NRC and the
industry, recent reactor trips and other events which occurred at each of
the nuclear stations, and a discussion of the -~pcoming EOP assessment
which will be conducted in February at the Surry Power Sta.ti on.
The.
inspector a*lso was provided a copy -of the proposed corporate nuclear
safety assessment schedule for 1990.
The inspector noted that assessments
are scheduled in the areas of operations_, mainte*nance, procedures, and
other programs being implemented.
Also noted on the schedule was a
condition where the licensee would be exchanging personnel with other
utilities during performance of the other utility
1 s assessments in similar
areas.
The inspector considers that the licensee
1s proposed assessment
program and schedule appears to be aggressively focused at past problem
areas and is a strength.
The implementation and effectiveness of the
licensee
1s assessment program will be monitored and inspected in future
inspections.
Within the area inspected, no violations were identified.
10.
Exit Interview
The inspection scope and findings were summarized on February 6, 1990,
with those individuals identified by an asterisk in paragraph 1.
An
_additional exit was held with the Station Manager on February 9, 1990 to
clarify some of the issues and to obtain the commitments discussed below.
During this inspection period,* no violations or- deviations were
identified.
A strength was identified with regards to the licensee
I s
proP-osed program and schedule for conducting future safety assessments of
major areas at the Surry Power Station (paragraph 9).
However, several
weaknesses were identified in several functional* areas including
operations, maintenance/surveillance, and en~ineering/ tethnical support .
17
These weaknesses were:
.
.
The 11 censee' s -actions for ensuring that operations has good
capabilities to determine RCS leak rates have not occurred in a
tim~ly manner (paragraph 3.g).
In the maintenance area. a weakness was identified in the way some
balance of plant components were worked during the past refueling
outages (paragraph 4.a).
Deficiencies in planning and procurement activities were .. identified _
as weaknesses in the.maintenance/surveillance area {paragraph 4.c).
Another exampJe was 1dentified of a weakness previously documented_ in
Inspection Report 280.281/89-34 concerning a lack of aggressive
identification and evaluation of anomalies that occur during
.*surveillance testing (paragraph 5.a).
Also. significant weakneises were identified in an inspection of the
plant modification process.
One example was identified with regards
to an unauthorized modification to a recirculation spray pump.
In
addition. work associated with the fnstallation of a new resin blend
facility was found deficient in that adequate modification boundary
isolation was not established which contributed to a plant instrument
air transient.
The inspectors concluded that licens~e investigation
into the contamination event up to date had not identified problems
which would have been addressed by the technical review process.
_ This inspection effort also identified programmatic weaknesses
associated with the procedural guidance and plant configuration
control during post-modification testing. This concern was discussed
with station management
and
they consider that present
post-modification testing control is adequate.
However.* after
additional discussion. the Station Manager committed to conduct a
revi~w
of post-modification testing crintrol.
An
(280.281/90-01-03) was identified for failure to provide and/or
fo1low procedures for the above problems.
(paragraph 8).
During closeout of LER 280/89-41. (paragraph 6) an NCV was identified for
failure to meet the requirements of TS 3.22 when taking a safety-related
fan out of service (280/90-01-01).
During closeout of LER 281/89~12. (paragraph 6). an NCV was identified for
failure to comply with the requirements of TS 3.12~E (281/90-01-02).
.
.
'
The licensee* acknowledged the inspection findings and generally agreed
with the inspection conclusions.
The lice1_1see did not identify as
proprietary any of the materials provided to or r.eviewed by the inspectors
during this inspection.*
.
11.
I_NDEX OF ACRONYMS AND INITIALISMS
~
.,
" '
ij:
18
ANSI
AMERICAN NATIONAL STANDARDS INSTITUTE
ABNORMAL OPERATING PROCEDURE
COMP.UTER AIDED DESIGN
CONFIRMATION OF ACTION LETTER
cc
COMPONENT COOLING
ccw
COMPONENT COOLING WATER
. CFR
CODE OF FEDERAL REGULATIONS
CLS
CONSEQUENCE. LIMITING SAFEGUARD
CRO
-
CONTROL ROOM OPERATOR
cw
CIRCULATING WATER
DPI
DELTA PRESSURE INDICATORS
DR
DEVIATION REPORT
EOG
EMP
ELECTRICAL MAINTENANCE PROCEDURE
EMERGENCY OPERATING PROCEDURE
ENGINEERED SAFETY FEATURE
EMERGENCY SERVICE WATER
ENGINEERING WORK REQUEST
GDC
GENERAL DESIGN CRITERIA
GPM
GALLONS PER MINUTE
HEALTH PHYSICS
HEAT EXCHANGER
HIGH PRESSURE SAFETY INJECTION
HSD
HOT SHUTDOWN
INSTRUMENT AIR
INSPECTION AND ENFORCEMENT
IFI
INSPECTOR FOLLOWUP ITEM
IRSP
INSIDE RECIRCULATION SPRAY PUMP
IOER
INDEPENDENT OFFSITE EVALUATION!REVIEW
!RPI
INDIVIDUAL ROD POSITION INDICATION
INSERVICE INSPECTION
LER
LICENSEE EVENT REPORT
LCO
LIMITING CONDITIONS OF OPERATION
LHSI
LOW HEAD SAFETY INJECTION
LOSS OF COOLANT ACCIDENT
.,.
MER3
MECHANICAL EQUIPMENT ROOM 3
MDV
MOTOR OPERATED VALVE
.
MCR -
MAIN CONTROL ROOM
NON-CITED VIOLATION
NORMAL OPERATING PRESSURE
NRC
NUCLEAR REGULATORY COMMISSION
NUCLEAR REACTOR REGULATION
OP
OPERATING PROCEDURE
ORS
. OUTSIDE RECIRCULATION SPRAY
PNEUMATIC CONTROL VALVE
PRESSURE INDICATOR
PM .
PREVENTATIVE MAINTENANCE
PRESSURIZER RELIEF TANK
I
I
.; .... *~ .
~ .
,.'
...... "'
. ,.
PSI-
QA.
RMT
RSS -
SCFM.
SNSOC
sov
- TAVG
TI
TS
vs
19
POUNDS PER SQUARE INCH
POUNDS PER SQUARE INCH GAUGE
PERIODIC TEST
QUALITY ASSURANCE
QUALITY CONTROL
RESIDENT ACTION ITEM
REGULATORY GUIDES
REACTOR OPERATOR
REACTOR PROTECTION SYSTEM*
RECIRCULATION MODE TRANSFER
RECIRCULATION SPRAY. HEAT EXCHANGER
RECIRCULATION SPRAY SYSTEM
RADIATION WORK PERMIT
REFUELING WATER STORAGE TANK
STANDARD CUBIC FEET PER MINUTE
SAFETY EVALUATION REPORT
.
SAFETY INJECTION
STATION NUCLEAR SAFETY AND OPERATING COMMITTEE
SOLENOID OPERATED VALVE
SAFETY PARAMETER.DISPLAY SYSTEM
. SENIOR REACTOR OPERATOR
AVERAGE TEMPERATURE,OF RCS
TEMPORARY INSTRUCTION
TECHNICAL SPECIFICATIONS
. UPDATED FINAL SAFETY ANAL YSlS REPORT
UNRESOLVED ITEM
UNDER VOLTAGE
VENTILATION SYSTEM