ML18152A128

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Insp Repts 50-280/97-03 & 50-281/97-03 on 970309-0419. Violations Noted.Major Areas Inspected:Licensee Operations, Engineering,Maint & Plant Support
ML18152A128
Person / Time
Site: Surry  
Issue date: 05/19/1997
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML18152A129 List:
References
50-280-97-03, 50-280-97-3, 50-281-97-03, 50-281-97-3, NUDOCS 9705290349
Download: ML18152A128 (24)


See also: IR 05000280/1997003

Text

..

Docket Nos:

License Nos:

Report No:

Licensee:

Facility:

Location:

Dates:

Inspectors:

Approved by:

9705290349 970519

PDR

ADOCK 05000280

G

PDR

U.S. NUCLEAR REGULATORY COMMISSION

REGION II

50-280, 50-281

DPR-32, DPR-37

50-280/97-03, 50-281/97-03

Virginia Electric and Power Company (VEPCO)

  • Surry Power Station, Units 1 & 2

5850 Hog Island Road

Surry, VA 23883

March 9 - April 19, 1997

R. Musser. Senior Resident* Inspect,- ....

K*. Poertner, Resident Inspector

P. Byron, Resident Inspector

J. Coley, Jr., Reactor Inspector (Section M2.l, M2.2,

and M2.3)

B. Crowley, Reactor,. Inspector (Assisted J. Coley with

inoffice review, Section M2.3)

D. Jones, Sr. Radiation Specialist (Section Rl.l,

Rl.2, Rl.3, and Rl.4)

G. Belisle. Chief, Reactor Projects Branch 5

Division of Reactor Projects

Enclosure 2

..

- - - - - - - - - -

EXECUTIVE SUMMARY

Surry Power Station, Units 1 & 2

NRC Inspection Report Nos. 50-280/97-03, 50-281/97-03

This integrated inspection included aspects of licensee operations.

engineering, maintenance. and plant support.

The report covers a 6-week

period of resident inspection; in addition, it includes the results of

announced inspections by a regional radiation specialist and regional projects

inspectors.

Operations

  • .

During the Unit 1 Refueling Outage (RFO), the licensee failed to

properly maintain refueling containment integrity which constituted a

violation of Technical Specification (TS) 3.10.A.1 (Section 01.2).

The inspectors concluded that the licensee could have exhibited a more

conservative approach by providing an additional method to monitor spent

fuel pit temperature during the period of high pit heat load (Section

01.3).

Maintenance

Maintenance personnel failed to follow the reactor disassembly procedure.

in that they did.not place RTV along the entire circumference of the

inner J-Seal resulting in the cavity seal leak during post installation

testing. This is a. Violation of TS 6.4.D. The inspectors consider that

work practice is the only causal factor described in Deviation Report

(DR) 97-0795 to be valid. The procedure is clear and explicit. The

inspectors concluded that the response to DR 97-0795 should have been

more explicit in that it did not detail the work practice/failure to

follow procedure issue. The proposed corrective actions involving

revising the-procedure are enhancements and will likely not prevent

recurrence. The inspectors discussed this with plant management and

plant manageme.nt stated that they would review the issue (Section Ml.1).

The work performed to install 1-SW-MOV-105B was performed properly and

in accordance with the specified work instructions. Providing more

detailed instructions in the design change and work order was discussed

with plant management as a potential enhancement for future tasks of

this type (Section Ml.2).

The inspectors determined that the licensee performed the appropriate

actions to correct a number of longstanding equipment problems.

The

effectiveness of these activities will be determined during the next

operating cycle (Section Ml.3).

The Inservice Inspection (ISI) period plan, personnel certifications,

weld examination, and the ultrasonic examination procedure were in

accordance with Code Requirements (Section M2.l) .

The drawing for the upstream elbow weld on Pressurizer Line No. 4"-RC-

34-1502 (weld adjacent to Weld No. 3-02) was not depicted on ISI reactor

2

coolant isometric sketch No. 11448-WKS-0124Al-1.

The licensee took

actions to have the !SI drawing revised (Section M2.l).

The review of procedures, personnel certifications and the evaluation of

recorded eddy current data for tubes in the A steam generator revealed

that Westinghouse personnel were very knowledgeable of the eddy current

examination and data analysis process (Section M2.2).

Virginia Power Company has approximately 5000 components in the Unit 1

flow accelerated corrosion program. Approximately 110 to 121 of these

components are scheduled each outage to be examined. A concern was

expressed when high component replacement rates were experienced from

the small sample of components examined.

The licensee issued DR .

S-97-0895 to address flow accelerated corrosion concerns.

Licensee

actions planned in response to this deviation were considered good

(Section M2.3).

Engineering

The modification activities revi~wed by the inspectors during the RFO

should correct two longstanding equipment deficiencies (Section El.I).

Based on the deterioration seen in the Unit 1 letdown orifices. the

licensee prudently replaced these orifices and associated downstream

piping during the 1997 Unit 1 RFO (Section El.2) .'

The inspectors identified a violation .involving an inaccurate Licensee

Event Report (LER) submittal. The licensee addressed this matter and

the associated corrective actions in their response to Violation

50-280, 281/97002-04 (Section EB.I).

Plant Support

During the Unit 1 RFO, the licensee was properly monitoring and

controlling personnel radiation exposure and posting area radiological

conditions in accordance with 10 CFR Part 20 (Section Rl.1).

The licensee was maintaining radioactive effluent monitoring

instrumentation in an operable condition and performing the required

surveillances to demonstrate their operability. The Radiation

Monitoring Upgrade Program was considered to be a significant program

improvement (Section Rl.2).

The onsite meteorological measurements program was implemented in

accordance with the Updated Final Safety Analysis Report (UFSAR)

(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 system (Section Rl.4) .

I,

Report Details

Summary of Plant Status

Unit 1 was in a RFO the entire reporting period.

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 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. 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 Loss of Refueling Containment Integrity

a.

Inspection Scope (71707)

The inspectors reviewed instances which resulted in a loss of refueling

containment integrity during the Unit 1 RFO.

b. Observations and Findings

On March 20, with Unit 1 in refueling shutdown and fuel movement

underway, a *1 i censee manager performing a wa l kdown of refueling

containment integrity penetrations discovered that the blanks on the

main steam safety valve flanges were not properly secured.

Fuel

movement was stopped. A subsequent investigation revealed that the

blank installed in the position of main steam safety valve l*MS-SV-103C

had a gap of approximately one-eighth inch between the .sealing surfaces.

The licensee developed and implemented a containment integrity

verification plan which involved checking other penetrations and

properly securing the blanks on the main steam safety valve flanges.

No

additional problems were identified. Fuel movement resumed

approximately three and one-half hours after being stopped.

The fo 11 owing day at approximately 10: 54 a. m. . during a tour of the Unit

1 containment, a member of the licensee's Nuclear Oversight Department

discovered that the containment equipment hatch blank flange was not .

properly closed. Light from outside containment could be seen through

the flange seating surface.

Fuel movement was again stopped. A more

2

detailed and effective containment integrity verification plan was

implemented. Operations performed a detailed walkdown of all

containment penetrations.and identified another leakage path.

Main

Steam Trip Valve, 1-MS-TV-lOlC, had drifted from the full closed

position and was no longer serving as a containment barrier as required.

Instrument air had leaked past an isolation*valve to the trip valve's

actuator causing the valve to partially open.

These* matters were

corrected prior to the resumption of fuel movement.

This matter was reported to the NRC in accordance with 10 CFR 50.73 (LER

50-280/97006-00).

In this report, the licensee stated that the

requirements of 10 CFR 100 would not have been exceeded in regards to

this matter if a postulated fuel handling accident had occurred with the

containment conditions as stated. The inspectors reviewed the

licensee's evaluation and concurred with the licensee's conclusion.

The failure to maintain all penetrations which provide a direct path

from containment atmosphere to the outside atmosphere closed is a

violation of TS 3.10.A.l. Th~ failure to maintain refueling containment

  • integrity during fuel movement will be tracked as Violation

50-280/97003-01.

c. Conclusions

Duri.ng the Unit 1 RFO, the licensee failed to properly maintain

refueling containment integrity during fuel movement which constituted a

violation of TS 3.10.A.1.

01.3 Spent Fuel Pit Temperature Monitoring (71707)

On March 23, the day folJowing the completion of the Unit 1 full core

offload, the inspectors reviewed the licensee's methods of monitoring

spent fuel. pit temperature.

Normally, a temperature indicator on both

the Unit 1 and 2 control panels displays the spent fuel pit temperature.

Additionally, two alarms for spent fuel pit high temperature (high and

high-high temperature) are normally available through the control room

annunciator system.

On the date of this review and for the previous

five days, only the temperature indicator on the Unit 2 panel remained

operable. The remainder of the equipment was out of service due to an

ongoing modification involving a portion of the non-safety related

instrument racks.

To compensate for this condition, operations

.

personnel were logging spent fuel pit temperature on an hourly basis and

were well aware of the equipment status. The inspectors concluded that

the licensee could have exhibited a more conservative approach by

providing an additional method to monitor the spent fuel pit temperature

during this period of high spent fuel pit heat load.

08

Miscellaneous Operations Issues (92901)

08.1 (Closed) LER 50-281/95001-00:

pressurizer heatup exceeded TS limit due

to lack of procedural control.

On February 4, 1995, the Unit 2

operators noted that the pressurizer cooldown rate was close to the

3

200° Fahrenheit per hour (F/hr) cooldown allowed by TS 3.1.B.3. The

operators slowed the cooldown rate and submi.tted DR 95-0206. A review

of the data taken during the performance of General Operating Procedure

2-GOP-2.6, "Unit Cooldown, Less Than 205° F to Ambient," revealed that

the TS specified cooldown rate had not been exceeded.

However, the data

indicated that the pressurizer temperature increased from 254° F to

400° Fin a one hour period which exceeds the TS specified limit of

100° F/hr.

DR 95-0218 was issued to describe this event. This event is

described in detail in Inspection Reports (!Rs) 50-280, 281/95003 and

50-280, 281/95006.

The licensee attributed the event to inadequate procedural c9ntrols for

pressurizer in-surges and out-surges during the Reactor Coolant System

(RCS) cooldown which was due to lack of operating experience.

In

addition the operators did not anticipate a heatup during RCS cooldown

evolutions. The licensee initiated training on the event and revised

Procedure 1/2-GOP-2.6. Westinghouse performed an analysis of the

effects of the transient on the pressurizer. The analysis revealed that

the transient had no detrimental structural effects on the pressurizer.

The Westinghouse Owners Group (WOG) created a task team on pressurizer

in-surge and out-surge transients. The team collected data on

. pressurizer heatup and cooldown rates. The WOG completed their review

and on February 3, 1997, issued a set of guidelines to mitigate these

events. The results of the review were documented in WCAP-13588,

"Operating Strategies for Mitigating Pressurizer Insurge and Outsurge

Transients," dated March 1993 and WCAP-14717, "WOG Evaluation of the

Effect of Insurge/Outsurge Out of Limit Transients on the Integrity of

the Pressurizer (Program MUHP-5063 Summary Report)," dated August 1996.

The licensee plans to evaluate the results and recommendations of the

task team.

The following procedures were revised as a result of the

guidelines:

OSP-RC-001. "RCS and Przr Heatup/Cooldown Verification,"

Revision 1

GOP-1.1. "Unit Startup, RCS Heatup From Ambient to 195° F,"

Revision 9

GOP-1.2, "Unit Startup, RCS Heatup From 195° F to 345° F,"

Revision 9

GOP-2.4, "Unit Cooldown; Hot Shutdown to 351° F." Revision 9

GOP-2.5, "Unit Cooldown, 351° F to 201° F," Revision 7

GOP-2.6, "Unit Cooldown, 201° F to Ambient," Revision 7

The inspectors verified that the changes had been made to the

procedures.

The inspectors reviewed the heatup and cooldown data of February 4,

1995, contained in GOP-2.6: Westinghouse evaluation RM06-1566, dated

February 13, 1995; and the training lesson plans. Tr*aining records were

reviewed and the inspectors verified that training had been given. The

licensee has completed their planned corrective actions.

4

08.2 (Closed) Violation 50-281/95006-02: pressurizer heatup rate exceeded TS

limits of 100° F/hour. This violation was written against the event

described in Section 08.1 CLER 50-281/95001-00).

The inspectors

reviewed the licensee's*response dated June 15, 1995, and determined

that it was acceptable. The closure of the LER 50-281/95001-00 also

closes this item.

08.3 (Closed) LER 50-280/97006-00: loss of refueling integrity due to an

inadequate containment closure process.

The corrective actions related

to this LER will be tracked by Violation 50-280/97003-01.

IL Maintenance

Ml

Conduct of Maintenance

Ml.1 Reactor Cavity Seal Ring

a.

Inspection Scope (62707)

On March 16, 1997, following installation of the cavity seal ring, the

licensee performed the cavity level air drop test. The test failed

because of excessive leakage. The inspectors reviewed the DRs and

verified the licensee's corrective actions .

b. Observations and Findings

The licensee installed the cavity seal ring in accordance with O-MCM-

1150-01. "Reactor Disassembly And Reassembly," Revision 4, Section 6.11,

"Reactor Cavity Seal Ring And Strongback Installation." A visual

inspection of the seal ring following the failed test revealed that

there were two areas, each about 10 inches long, where the inner J-Seal

was not touching the re~ctor vessel (1/8" gap). Additionally, the

licensee determined that they had failed to place RTV along the entire

circumference of the inner J-Seal. The licensee also identified that

six of the 20 capscrews in the diaphragm plate manway nearest the cavity

ladder were loose (not even hand tight). The outer J-Seal had been

sealed to the diaphragm plate foam using RTV, but the RTV had migrated

under the seal ring standoffs which did not allow the seal to settle

into position. These items caused the seal to leak by when the

inflatable seal was deflated. The seal ring was removed from the cavity

and one inner segment ring was found to be bent.

The bent segment was

removed, straightened, and reinstalled.

RTV was placed as required by

procedures. The air drop test was successfully repeated.

No leakage

was observed and both seals inflated and deflated as designed.

Two DRs.

97-0782 and*97-0975, were issued by Engineering and Maintenance

respectively to track this issue.

The causal factors of the event that were listed in DR 97-0975 *were

written communicati~n. work practices. and resource management.

The

licensee attributed the lack of a sign off for the procedural step which

controlled the event and this was the first time the crew had performed

the activity as contributors to the event. Although O-MCM-1150-01 Step

5

6.11.6 had a sign off blank, the proposed corrective actions were to add

a sign off to its substep, Step 6.11.6.c, and revise Figure 13 of the

procedure to show additional detail.

DR 97-0795 was closed on the basis

that 0-MCM-1150-01 had been revised to include the sign off for Step

6.11.6.c and the figure revision was being tracked by Procedure Manager

Tracking Number. MEFB 97-0031 and the revision would be completed prior

to the Unit 2 RFD.

The inspectors discussed their inability to find the

procedure revision with the licensee. The licensee provided the

inspectors with a one time only procedure action request which added the

sign off step*to Step 6.11.6.c and a change to Section 6.9. This action

changed the procedure for work during the RFD. but did not revise the

procedure.

The proposed corrective actions for DR 97-0782 were to add the sign off

as described above, add a "Caution" so that RTV is not applied under the

standoffs, and add a step after Step 6.9.7 to check the manway fastener

torque. The DR was closed out by stating that the MEFB-97-0031 had.been

issued to track the procedure revision, which will incorporate these

(and other) changes.

Both DRs were approved for closure by the Station

Nuclear Safety a_nd Operating Committee (SNSOC) on April 10; 1997.

On April 22, 1997, the inspectors reque~ted a copy of Procedure O-MCM-

1150-01 from the licensee's Document Control and received O-MCM-1150-01.

Revision 4.

The inspectors reviewed O-MCM-1150-01, Revision 4, and did

not observe a sign off for Step 6.11.6.c as indicated by the closure

document. Step 6 .11. 6. c states, "Apply a sma 11 bead of RTV seal ant

along the entire circumference of the inner J-Seal where the seal

contacts the reactor flange. (The bead should be at least 1/8 inch

thick ..... )" The inspectors consider that this step is very clear as

to what is required when applying RTV to the inner J-Seal.

MEFB-97-0031

was also reviewed and the inspectors noted that it only states under

comments that the procedure needs to be revised after the current RFD.

It references DR 97-0795 but there is no reference to the proposed

procedure revisions contained in DR 97-0782.

c. Conclusions

Maintenance personnel failed to follow the procedure in that they did

not place RTV along the entire circumference of the inner J-Seal

resulting in the cavity seal leak during post installation testing.

This is a Violation (50-280/97003-02) of TS 6.4.D. The inspectors

consider that work practice is the only causal factor described in DR

97-0795 to be valid. The procedure is clear and explicit. The

inspectors concluded that the response to DR 97-Q795 should have been

more explicit in that it did not detail the work practice/failure to

follow procedure issue. The proposed corrective actions involving

revising the procedure are enhancements and will likely not prevent

recurrence. The inspectors discussed this with plant management and

plant management stated that they would review the issue

6

Ml.2 Replacement of Service Water Valve 1-SW-MOV-105B

a.

Inspection Scope (62707)

The inspectors monitored maintenance activities involving the

replacement of service water valve 1-SW-MOV-105B.

b. Observations and Findings

On April 12, the inspectors observed portions of the replacement of

service water valve 1-SW-MOV-105B.

The work was being performed in

accordance with Work Order (WO) 00363165-03 and Design Change 97-016.

The valve was replaced because it would not satisfactorily pass a local

leak rate test. In this instance, a valve of the type previously

installed was no longer available, thereby requiring a new type valve to

be installed in accordance with an approved design change (97-016). All

work observed by the inspectors was performed properly and in accordance

with the specified work instructions. The inspectors reviewed the

associated documentation and found it satisfactory with one minor

exception. Specifically, neither the design change nor the WO provided

detailed instructions for the installation of a flange insulation kit.,

This kit was required to be installed to eliminate any galvanic

corrosion concerns due to the dissimilar metals of the new valve and the

existing piping. The inspectors questioned the maintenance personnel

performing the task about the methodology for installation of the

insulation kit. The maintenance personnel indicated that they had

received appropriate oral instructions from ~heir supervision and

engineering personnel concerning the installation of ~he insulation kit

and were cognizant of the proper installation procedure.

The inspectors

discussed with plant management that providing more detailed

installation instructions would enhance future tasks of this type*.

c. Conclusions

The work performed to install l-SW-MOV-105B was performed properly and

in accordance with the specified work instructions. Providing more

detailed instructions in the design change and WO was discussed with

plant management as a potential enhancement for future tasks of this

type.

Ml.3 Unit 1 Outage Activities

a.

Inspection Scope (61726. 62707)

The inspectors reviewed a number of activities during the Unit 1 RFO.

7

b. Observations and Finding

1.

Unit 1 Safety In,iection Accumulator lC. Change In Boron

Concentration

2.

The licensee observed that the boron concentration in Safety

Injection (SI) accumulator lC was decreasing while the level

remained constant. The accumulator is connected to the cold leg

of the C loop by a 12-inch line. The line goes from the cold leg

to the accumulator through two check valves (1-SI-147/145) and an

open motor operated gate valve (1-SI-MOV-1865C).

The check valves

are oriented to allow flow from the accumulator to the reactor

coolant cold leg. The system engineer theorized that check valve

l-SI-147 leaked by allowing the 2200° F reactor coolant to flow to

the accumulator. Thermal mixing caused the reactor coolant with a

lower boron concentration to dilute the coolant in the

accumulator.

The system engineer believed the constant level was

the result of valve 1-SI-MOV-1865C packing leakage being equal to

the 1-SI-147 inleakage.

The licensee replaced the seat ring in l~SI-147 and this was

accomplished by WO 00328809-01.

WO 00359031-01 was issued to

repack valve l-SI-MOV-1865C.

The inspectors noted during their WO

review that both check valves were overhauled on September 23,

1995, because of boron dilution in the C accumulator.

In

addition, l-SI-MOV-1865C was previously repacked on December 9,

1994. The inspectors verified that the licensee completed their

corrective actions for the boron dilution in the C accumulator.

The effectiveness of the corrective actions can not be determined

until the unit has been at power.

Primary Power Operated Relief Valve (PORV) Maintenance

During the last Unit 1 operating cycle, primary PORV 1-RC-PCV-

1455C was isolated because its associated block valve was shut due

to leakage through the PORV.

To correct this problem. the

licensee performed a complete rebuild of the valve. This included

replacement of the valve's plug, cage and stem.

The inspectors

reviewed the associated work documentation and considered that the

maintenance performed was satisfactory.

3.

Pressurizer Spray Valve Maintenance

During the last Unit 1 operating cycle, pressurizer spray valve 1-

RC-PCV-14558 was isolated due to faulty operation and seat

leakage. During the current Unit 1 outage, the valve body and

internals were replaced.

The inspectors reviewed the associated

work documentation and considered that the maintenance performed

was satisfactory.

4.

8

Pressurizer Instrumentation Nozzle Visual Inspections

During the previous Unit 1 RFO, an inspection of the pressurizer

instrumentation nozzles revealed evidence of leakage. The nozzles

in question were removed and replaced. This matter was reported

to the NRC in LER 280/95007-00.

An action to prevent recurrence

for this event was to perform a visual inspection of the nozzles

during the unit's next RFO.

The licensee performed a visual

inspection of the Unit 1 pressurizer instrumentation nozzles and

noted no leakage. The inspectors reviewed the visual examjnation

report and considered that the licensee's inspection was

satisfactory.

'

c. Conclusions

The inspectors determined that the licensee performed the appropriate

actions to correct a number of longstanding equipment problems.

The

effectiveness of these activities will be determined during the next

operating cycle.

M2

Maintenance and Material Condition of Facilities and Equipment

M2.1 Observation of Unit 1 ISI Work Activities

a.

Inspection Scope (73753)

This is the first outage, of the second inspection period. of the third

ISI interval. The applicable code for Unit 1, for the third ISI interval

was the American Society of Mechanical Engineers (ASME) Code Section XI.

1989 Edition, no Addenda.

The inspectors reviewed documentation and

observed work activities to determine whether the ISI activities were

performed in accordance with TS, the applicable ASME Code, and/or

requirements imposed by NRC/industry initiatives.

b. Observations and Findings

The inspectors reviewed the Inservice Inspection (ISI) outage

examination plan and the component examination schedule for the current

inspection period. The reviews were performed to determine if changes

to the component examination schedule for the current inspection period

had been properly documented. Certification records for examiners

performing ISI examinations this outage were reviewed. Virginia _Power

Procedure No. NDE*UT-601, "Ultrasonic Examination of Piping Welds,"

Revision 0, was also reviewed for technical content.

Ultrasonic examination of reactor coolant welds Nos. 3-0lDM and 3-02

were observed. These ASM~ Code welds were four-inches in diameter and

were located on top of the pressurizer. Although the examinations were

conducted satisfactorily, one discrepancy was noted by the inspectors.

The ISI drawing for the upstream elbow weld on the elbow (Pressurizer

L-ine No. 4"-RC-34-1502). which was attached to the reducer on the

pressurizer nozzle, was not depicted on ISI Drawing No. 11448-WMKS-

,-

9

0124Al-1.

The licensee subsequently stated that, when insulation was

removed, it was not unusual to find a weld that was previously not

identified in the program.

However, the program contained an adequate

surplus of welds, which were examined in the event that additional welds

were identified during inspection activities. The licensee also stated

that as welds were found, the ISI drawings were revised to depict the

locations of the new welds.

In addition to the above, the inspectors also observed two ultrasonic

examinations (Welds Nos. 1-02 and 1-03) on the 14-inch diameter

feedwater piping running to steam generator A and one ultrasonic

examination (Weld No. 1-01) on the 16-inch diameter. feedwater piping

running to steam generator B.

The feedwater piping examination was

performed in accordance w.ith t_he requirements of NRC Bulletin No. 79-13.

c. Conclusions

The ISI period plan, personnel certifications, weld examinations, and.

the ultrasonic examination procedure were in accordance with Code

requirements.

One discrepancy*was noted, in that, the drawing for the

upstream elbow weld on Pressurizer Line No. 4"-RC-34-1502 (weld adjacent

to Weld No. 3-02) was not depicted on the ISI reactor coolant isometric

sketch. The licensee took actions to have the ISI drawing revised .

M2.2 Observation of Unit 1 Steam Generator A Eddy Current Data Analysis

Activities

a.

Inspection Scope (73753)

The inspectors reviewed the Surry Power Station Unit's 1 & 2 Steam

Generator Monitoring and Inspection Program Plan, the Surry Site

Specific Eddy Current Data Analysis Guidelines (Procedure No. SRY-SGPMS-

002.2, Revision 0), the Westinghouse Electric Corporation Nuclear

Services Division Steam Generator Primary Maintenance Services Data

Analysis Technique Procedure No. DAT-GYD-001, Revision 7, and personnel

certification records for all of the Westinghouse examiners and

analysts.

In addition. tube evaluation and data analyst activities were

. inspected.

b. Observations and Findings

The licensee's single steam generator inspection program was initiated

on Unit 1 in 1994.

During each outage, 100 percent bobbin coil

inspections of all open tubes in one steam generator are examined.

In

addition, a 20 percent sample of hot leg tube sheet transitions in one

steam generator are examined each outage using a Motor Rotating Pancake

Coil (MRPC).

Based on this program, 100 percent of all steam generator

tubes are bobbin coil examined within a rolling 60 month schedule.

Under ASME Section XI, 1989 Edition, the extent and frequency of

examination is governed by the plant TSs. Surry Unit 1 TS, Section 4.19.C requires 3 percent of all tubes be examined (301 tubes): however,

3336 tubes were bobbin coil examined in A Steam Generator (100 percent

10

of all tubes in A).

In addition. 669 hot leg tube sheet transitions (20

percent sample) will be MRPC examined this outage.

The inspectors'

review of documentation delineated in the scope paragraph above and

observation of the online evaluation process revealed that the approved

data analysis guidelines were being followed: the data analysts were

very knowledgeable of-the requirements and operation of their equipment:

and the 100 percent bobbin coil examinations were complete with no

reportable pluggable indications identified at this point in the outage

examinations.

c. Conclusion

The review of procedures. personnel certifications. and evaluation of

recorded eddy current data for tubes in the A steam generator revealed

that the Westinghouse personnel (including their contractors) were very

knowledgeable of the eddy current examination and the data analysis

process.

M2.3 Unit 1 Flow Accelerated Corrosion (FAC) Program

a.

Inspection Scope (49001)

The licensee has approximately 5000 components in the Unit 1 FAC

program.

Approximately 110 to 121 of these components are scheduled

each outage to be examined.

The inspectors held discussions with the

licensee's erosion/corrosion engineers to determine the scope of FAC

examinations scheduled for this outage, the condition of the plant

piping as revealed by inspection: the extent of pipe replacement

required; and whether proper examination expansion was performed when

defective components were found.

b.

Observations and Findings

The licensee's initial sample of components scheduled for ultrasonic

examination this outage was 113.

The licensee had also planned to

replace 22 components without further examination. based on corrosion

growth rates confirmed last outage.

However, discussions with cognizant

personnel revealed that ultrasonic thickness examinations had identified

20 additional components that had to be replaced.

The licensee would

now have to replace 48 total components this outage.

In addition. the

sample of components was expanded to 140 total components.

The high

rejection rate of components in relationship to the average sample of

components scheduled for examination during this outage concerned the

inspectors. Therefore, discussions were held with cognizant licensee

personnel to determine the results of previous outage operations. This

review revealed that a significant number of components had been

repaired or replaced as the result of inspection for Unit 1 in both the

1994 (13) and 1995 (21) outages.

However. the inspectors found that the

licensee has not experienced any recent leaks and no sealant cans were

installed on either units. The inspectors also verified a portion of

the licensee's component expansion inspections and found that they had

been conducted properly.

11.

During a meeting with senior management. the inspectors expressed

concern over the high component rejection rate. The inspectors were

informed by senior management that they were also concerned over the

number of components requiring replacement.

Therefore, as soon as the examinations of components were completed, and

the total replacements determined, Virginia Power would review this

problem in detail, and determine an appropriate course of action. The

actions to be taken would be sent to the inspectors for review.

DR S-97-0895 was written by. the licensee to address these issues.

On April 4, 1997, a response was provided to the inspectors in Region

II. This response addressed the high rejection level issue raised by*

the inspectors. The response also addressed wear-rates seen on the

feedwater components, which were somewhat higher than predicted either

by previous evaluation or by the CHECWORKS modeling: and that

conservatism currently utilized in the prediction of component life may

not be sufficient enough to consistently prevent the violation of code

minimum wall thickness.

As a result of these concerns, an action plan

was implemented by the licensee.

On April 9, 1997, the licensee

clarified the engineering positions relative to inspection scope.

expansion and the safety of the unit's piping systems in light of the

recent FAC findings. *On April 10, 1997, a conference call was held with

representatives from Virginia Power, at both the Surry Power Station and

the Innsbrook Technical Center, and the NRC to discuss the licensee's

submittal and their action plans. The NRC agreed that the licensee was

taking appropriate action at this time.

As part of their action plan for DR S-97-0895, the licensee had

contacted the Electric Power Research Institute (EPRI) to conduct a site

visit (tentatively May 5, 1997) to perform a technical engineering

review of the Virginia Power Secondary Piping Component Inspection

Program.

CHECWORKS databases, system models and outage data have

already been transmitted to EPRI for review.

NRC personnel considered

this was a good action taken by the licensee. However, the licensee was

notified that when the EPRI assessment of the Unit 1 FAC program was

comp 1 eted, Region II wi.11 conduct an inspection at the Innsbrook

Technical Center to review the licensee's progress on each of the action

items addressed in the response,to DR S-97-0895.

c. Conclusions

Virginia Power Company has approximately 5000 components in the Unit 1

FAC program. Approximately 110 to 121 of these components are scheduled

each outage to be examined. A concern was expressed when high component*

replacement rates were experienced from the small sample of components.

examined.

The licensee issued DR S-97-0895 to address FAC concerns.

Licensee actions planned in response to this deviation were considered

good.

12

III. Engineering

El

Conduct of Engineering

El.1

RFO Modifications to Correct Long Standing Issues

a.

Inspection Scope (37551)

The inspectors reviewed two modifications which addressed longstanding

issues.

b. Observations and Finding

1.

2.

Unit 1 Steam Generator Channel Head Drain Replacement*

The licensee had experienced leakage from the Unit 2 steam

generator channel head drain. The corrective action was to remove

the drain line at the steam generator and replace it with a

stainless steel plug. Engineering developed Design Change Package

(DCP)95-046, "SG Channel Head Drain Isolation," to remove the

drain lines from the Unit 1 steam generators. The inspectors

reviewed DCP 95-046 including the safety review and the proposed

changes to UFSAR. Section 4.2.2.3.2.3. The work was controlled by

WOs 00337078-01, 02, and 03 for steam generators lA, 18, and lC

respectively. The inspectors reviewed completed WO 00337078-03

and procedure O-MCM-1801-01, "Piping, Components Repair and

Replacement," Revision 4.

The inspectors verified that applicable

sections of the procedure had been signed off and the WO closed

out.

Source Range Nuclear Instrumentation (NI) Detector Cabling

Replacement

The cables for both the intermediate and source range NI detectors

were replaced to reduce extraneous "noise" in the detectors. The

change was controlled by DCP 96-007.

On March 12, 1997, the N-31

detector was declared operable at 7:45 a.m., after completion of

post maintenance testing. However. the Raychem protector had not

been applied. At 12:30 p.m., a technician disconnected the cable

as he believed it would be easier to install the Raychem with the

cable disconnected. The control room was unaware that the N-31

cable would be disconnected.

The technicians notified the control

room of their actions and the detector was declared inoperable.

The Raychem was installed and the N-31 detector was declared

operable at 1:09 p.m., following satisfactory performance of

1-PT-1.1, "NIS Trip Channel Test Prior to Startup." The

technicians did not install the Raychem prior to acceptance

testing in the event that problems occurred during testing and the.

Raychem had to be removed.

The licensee determined that the

technician had not been briefed that the detector was energized.

DR 97-0709 was issued to follow the event .

13

The inspectors.reviewed DCP 96-007 and noted that the modification

was performed by Westinghouse. Westinghouse.procedures were used

to control the cable changeout.

The inspectors did not find any

cautions or directions relating to the sequence of installing the

1

Raychem.

The inspectors concluded that the event was caused by

poor communications.

c. Conclusions

The modification activities reviewed by the inspectors during the RFO

should correct two longstanding equipment deficiencies.

El.2 Unit 1 Letdown Line Orifice and Piping Replacement

a.

Inspection Scope (37551)

The inspectors reviewed the licensee's actions related to the

replacement of the Unit 1 letdown line piping and orifices.

b. Observations and Findings

On March 15, the licensee performed radiographic examinations on the

Unit 1 letdown orifices to check for a similar erosion condition

previou$ly seen on the B Unit 2 letdown orifice. Vibration testing of

the Unit 1 letdown lines performed at hot shutdown exhibited values

higher than those normally expected, but less that allowable.

The

results of the Unit 1 exam were as follows:

A 45 gpm Orifice: This orifice exhibited the most extensive

deterioration with its nominal 0.212 inch diameter being eroded to

an inside diameter of approximately one-inch over the last five

inches of the orifice. A microscopic examination of the sectioned*

orifice indicated the damage was caused by cavitation.

B 60 gpm Orifice: This orifice exhibited only minor erosion.

C 60 gpm Orifice: This orifice exhibited deterioration with its

nominal 0.242 inch diameter being eroded to. an inside diameter of

approximately one-half inch over the last one and one-half inches

of the orifice.

Based on the results of these examinations, the licensee replaced all

three orifices during the ongoing Unit 1 RFO.

In addition, the licensee

replaced the piping downstream of the orifices and inspected the letdown

isolation valves. The piping was fabricated with butt welds in lieu of

the existing socket welds.

The inspectors monitored the piping replacement act~vities. The

licensee has theorized that the erosion in the orifices in Unit 2 led to

increased vibration and ultimately cracking of the lines. Although Unit

1 has not experienced any letdown line cracking like those seen on

14

Unit 2, the licensee's action to replace the orifices and piping were

prudent.

c. Conclusions

Based on the deterioration seen in the Unit 1 letdown orifices following

radiographic examination, the licensee prudently replaced the orifices

and associated downstream piping during the 1997 Unit 1 RFO.

EB

Miscellaneous Engineering Issues (92902)

E8.1

(Open) LER 50-280/97001-00:

shutdown due to steam drain line weld leak.

This LER discussed the January 24, 1997, Unit 1 shutdown due to a

pinhole leak on a main steam drain line in the main steam valve house.

During the unit shutdown, both source range Nis failed after

energization. Section 4 (Immediate Corrective Actions) of this report

stated that the plant was borated to the cold shutdown condition. The

inspectors questioned the accuracy of this statement. The unit was

borated to hot shutdown conditions and shutdown margin was verified as

required by TSs.

Licensee management made a conscious decision not to

borate to cold shutdown conditions during the event. This item was

discussed with plant licensing personnel and plant management.

The

licensee agreed that the statement was not accurate and initiated a

revision to the LER to correct the matter. The inspectors identified an

example of an inaccurate LER submittal in the previous IR (50-280,

281/97002). This item is identified as Violation 50-280/97003-03. The

licensee incorporated corrective actions for this violation in their

response to the previous violation. This LER will re.Jin open pending

revision.

IV. Plant Support

Rl

Radiological Protection and Chemistry (RP&C) Controls

Rl.l Occupational Radiation Exposure Control Program

a.

Inspection Scope (83750)

The inspectors reviewed implementation of selected elements of the

licensee's radiation protection program during a segment of the Unit 1

RFO.

The review included observation of radiological protection

activities including pre.-work briefings, personnel exposure monitoring,

radiological postings, and verification of posted radiation dose rates

and contamination levels within the Radiologically Controlled Area

(RCA).

Those activities were evaluated for consistency with the

programmatic requirements, personnel monitoring requirements,

occupational dose limits, radiological posting requirements, and survey

requirements specified in Subparts B. C, F, G, and J of 10 CFR 20.

15

b. Observations and Findings

The inspectors conducted frequent tours of the RCA to observe radiation

protection activities and practices. Personnel preparing for routine

entries into the RCA were observed being briefed on the radiological

conditions in the areas to be entered.

The briefings were given by

radiation control personnel before access was granted and covered the

dosimetry and the protective clothing and equipment required by the

Radiation Work Permit (RWP) for the entry. The administrative limits

for the allowed dose and dose rate* for the entry were emphasized during

the briefings. The briefings provided thorough descriptions of the

existing dose rates which could be encountered during the entry. The

inspectors determined that personnel entering the RCA were adequately

briefed on the radiological hazards which could be encountered while in

the RCA and the radiological protective measures required to be taken

during the entry.

The inspectors observed the use of personal radiation exposure

monitoring devices by personnel entering and exiting the RCA.

.

Thermoluminescent Dosimeters (TLDs) were used as the primary device for

monitoring personnel radiation exposure.

In addition. Digital Alarming

Dosimeters (DADs) were used for monitoring the accumulated dose and the

encountered dose rates during each RCA entry. The DADs were set to

alarm at administrative limits established for the specific RWP under

which the RCA entry was being made.

As the individuals exited the RCA

the accumulated dose and encountered dose rate information was

transferred from the DADs to the Personnel Radiation Exposure Management

System (PERMS) data base in order to track individual exposures.

During

tours of the RCA the inspectors noted that the required dosimetry was

being properly worn by personnel when entering and while in the RCA.

The inspectors also noted that personnel exiting the RCA routinely

surveyed themselves for contamination using a Personal Contamination

Monitor (PCM).

The inspectors discussed with the licensee the special procedures

implemented for releasing personnel from the RCA when xenon

contamination was suspected. The licensee provided the inspectors with

the following general description of the release process. Routine

decontamination procedures and release criteria were followed if an

individual alarmed the PCM at the RCA exit portal and the contamination

was determined to have been localized. If the PCM alarm was determined

to have been caused by generally uniformly distributed activity, then

additional surveys were performed to determine which radionuclides were

present. If the activity was found to be other than xenon, such as

cesium or cobalt. then additional decontamination was performed. If the

activity was found.to be xenon. the individual was surveyed with a hand

frisker to assure that the routine release criterion of 1000 dpm was

met. A release permit was then provided to the individual in the event

that the more sensitive portal monitor at the protected area exit point

were to alarm. Overall. the routine and special procedures assured that

any individual who alarmed the PCM was required to meet the routine

release criteria established for surveys by a hand frisker. The

16

licensee indicated that the special procedures were in effect for less

than two weeks due to the short half-life of xenon.

The inspectors reviewed As Low As Reasonably Achievable (ALARA) program

details. implementation. and goals for the Unit 1 RFO.

Based on the

scheduled activities, daily and cumulative exposure projections were

established. Individual exposures, based on data from DADs and PERMS,

were summarized by RWPs on a daily basis and allocated to the various

organizational departments.

Daily reports of the collective and

departmental exposures, along with their respective projected goals were

issued for monitoring purposes. Plots of daily and cumulative exposure

vs. their respective projections were also distributed daily. The

inspectors noted that daily and cumulative projections were exceeded

early in the outage but by day 29 of the scheduled 39 day outage the

cumulative exposure was below the projected value.

During tours of the RCA the inspectors noted that general areas and

individual rooms were properly posted for radiological conditions.

Posted survey maps were used to indicate dose rates and contamination

levels at specific locations within rooms.

At the inspectors' request,

a licensee Health Physics staff member performed dose rate and

contamination surveys in several rooms and locations. The inspectors

verified that the survey instrument readings were consistent with the

dose rates and contamination levels recorded on the posted survey maps .

The licensee provided for the inspectors' review a copy of the Five-Year

Exposure and Low-Level Radwaste Management Plan .. The inspectors noted

that the plan consisted of the following four objectives: increase and

expand efforts in innovative technology application; continue source

term reduction efforts; continue waste generation reduction efforts; and

continue high worker awareness and improved job and outage planning: A

list of activities and implementing schedules for achieving those

objectives was also delineated in the plan.

c. Conclusions

Based on the above reviews. the inspectors concluded that the licensee

was properly monitoring and controlling personnel radiation exposure and

posting area radiological conditions in accordance with 10 CFR Part 20.

Rl.2 Radioactive Effluent Monitoring Instrumentation

a.

Inspection Scope (84750)

The inspectors reviewed licensee's 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 16 of VPAP-2103, "Offsite Dose Calculation Manual (ODCM)."

17

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-GW-RM-102

1-VG-RM-110

RRM-101

Radwaste Facility Liquid Effluent Line

Process Vent Noble Gas Activity Monitor

Ventilation Vent Noble Gas Activity Monitor

Radwaste Facility Vent Noble Gas Activity

Monitor

The above monitors were found to be well maintained and operable at the

time of the tours.'

The inspectors reviewed the 14 procedures related to channel checks,

source checks, channel calibrations, channel functional tests, and alarm

setpoints for the above listed monitors.

The ir:spectors 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 the most

recently completed surveillances for the above listed monitors. Those

records indicated that the surveillances were current and had been

performed in accordance with their applicable procedures. The

inspectors also verified that the alarm setpoints for the above listed

monitors were consistent with procedure HP-3010.040 and ODCM

requirements. The licensee indicated that effluent monitor percent

availability was not routinely tabulated, therefore, the inspectors

reviewed the licensee's 1996 maintenance history records for the above

listed monitors. Those records indicated that the monitors were very

seldom out of service except for scheduled preventive maintenance and

surveillance testing. The inspectors also discussed the licensee's

Radiation Monitoring Upgrade Program with the cognizant Project

Engineer.

The project included installation of new digital

display/controllers in the Control Room, installation of new detectors,

and wiring upgrades.

The licensee indicated that the project was 80

percent complete for Unit 1, 100 percent complete for Unit 2, and 50

percent complete for common systems.

The planned completion date for

the project is year end 1997.

During a tour of the Control Room the

licensee demonstrated for the inspectors the enhanced capabilities of

the new digital display/controllers. The inspectors determined that the

radiation.monitor upgrade project was a significant program improvement.

c. Conclusions

Based on the above reviews and observations, it was concluded that the

licensee was maintaining radioactive effluent monitoring instrumentation

in an operable condition and performing the required surveillances to

demonstrate their operability .

18

Rl.3 Meteorological Monitoring Program

a.

Inspection Scope (84750)

The inspectors evaluated implementation of the licensee's onsite

meteorological measurements program for consistency with the program

description contained in Section 2.2.1.2 of the UFSAR.

b. 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 records for the.most recent instrument calibrations for

wind speed, wind direction, and air temperature which were performed

during November and December 1996. These records indicated that the

calibrations were current and had been performed in accordance with the

applicable procedures. During a tour of the Control Room, licensee

personnel displayed on a monitor the computerized log of the daily

channel checks performed for the previous 2 days.

The inspectors also

noted that the meteorological monitoring instrumentation was operable at

the time of the tour.*

c. Conclusions

Based on the above reviews and observations, the inspectors concluded

that the onsite meteorological measurements program was implemented in

accordance with the UFSAR.

Rl.4 Control Room Emergency Ventilation System

a.

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 TSs 3.23 and 4.20.

b. Observations and Findings

The inspectors toured the Turbine Building, Control Room, Emergency

Switchgear and Relay Room, and Mechanical Equipment Rooms in which the

CREVSs 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 four independent 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 9.13.3.6 of the UFSAR.

The inspectors observed that the

J

19

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 testing, air flow measurements.

differential pressure measurements. and charcoal adsorption efficiency

testing. The surveillance frequency and acceptance criteria for the

test results 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.

c. Conclusions

Based on the above reviews and observations, the inspectors concluded

that the licensee was maintaining the CREVS in an operable condition and

they were performing the required surveillances to demonstrate

operability of the system.

Sl

Conduct of Security and Safeguards Activities (71750)

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 properly manned and that

the perimeter barrier's material condition was properly maintained.

V. Management Meetings

Xl

Exit Meeting SU11111ary

The, inspectors presented.the inspection results to members of licensee

management at the conclusion of the inspection on April 25 and May 14, 1997.

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.

,J

20

PARTIAL LIST OF PERSONS CONTACTED

Licensee

R. Blount, Superintendent, Maintenance

D. Christian, Station Manager

M. Crist, Superintendent, Operations

J. McCarthy, Assistant Station Manager, Operations & Maintenance

B. Shriver, Assistant Station Manager, Nuclear Safety & Licensing

T. Sowers, S~perintendent, Engineering

B. Stanley, Director, Nuclear Oversight

W. Thorton, Superintendent, Radiological Protection

NRC

N. Diaz, Commissioner, Nuclear Regulatory Commission

L. Reyes, Regional Administrator, Region II

IP 37551:

IP 40500 :.

IP 49001:

IP 61726:

IP 62707:

IP 71707:

IP 71750:

IP 73753:

IP 83750:

IP 84750:

INSPECTION PROCEDURES USED

Onsite Engineering

Effectiveness of Licensee Controls in Identifying, Resolving, and

Preventing Problems

Inspection of Erosion/Corrosion Monitoring Programs

Surveillance Observation

Maintenance Observation

Plant Operations

Plant Support Activities*

Inservice Inspection

Occupational Exposure

Radioactive Waste Treatment and Effluent and Environmental

Monitoring

ITEMS OPENED, CLOSED. AND DISCUSSED

Opened

50-280/97003-01

VIO

Loss of refueling containment

integrity (Section 01.2).

50-280/97003-02

50-280/97003-03

Closed

50-281/95001-00

VIO

VIO

LER

Failure to follow maintenance

procedure (Section Ml.l).

Failure to meet the requirements of

10 CFR 50. 9 (a) for LER 50-

280/97001-00 (Section E8.l).

Pressurizer heatup exceeded TS limit

due to lack of procedural control

(Section 08.1).

50-281/95-06-02

50-280/97006-00

Discussed

50-280/97001-00

VIO

LER

LER

21

Pressurizer heatup rate exceeded TS

limits of 100° F/hour (Section

08.2).

Loss of refueling integrity due to

inadequate containment closure

process (Section 08.3).

Shutdown due to steam drain line

weld crack (Section E8.l) .