ML18152A131
| ML18152A131 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 11/23/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18152A132 | List: |
| References | |
| 50-280-98-08, 50-280-98-8, 50-281-98-08, 50-281-98-8, NUDOCS 9812010006 | |
| Download: ML18152A131 (24) | |
See also: IR 05000280/1998008
Text
U.S. NUCLEAR REGULATORY COMMISSION
REGION II
Docket Nos.:
License Nos.:
Report Nos.:
Licensee:
Facility:
Location:
Dates:
Inspectors:
Approved by:
9812010006 981123
- oR
ADOCK oso00280
50-280, 50-281
50-280/98-08, 50-281 /98-08
Virginia Electric and Power Company (VEPCO)
Surry Power Station, Units 1 & 2
5850 Hog Island Road
Surry, VA 23883
September 6 - October 24, 1998
. R. Musser, Senior Resident Inspector
K. Poertner, Resident Inspector
G. McCoy, Resident Inspector (In Training)
G. Warnick, Resident Inspector, St. Lucie (In Training) (Sections
02.1, 04.1 and M1 .1)
R. Chou, Reactor Inspector, RII (Sections M1 .6, MB.2 and E8.2)
D Jones, Senior Radiation Specialist, RII (Section R1 .1)
R. Haag, Chief, Reactor Projects Branch 5
Division of Reactor Projects
ENCLOSURE
EXECUTIVE SUMMARY
Surry Power Station, Units 1 & 2
NRC Integrated Inspection Report Nos. 50-280/98-08, 50-281/98-08
This integrateo inspection included aspects of licensee operations, engineering,.maintenance,
and plant support. The report covers a seven-week period of resident inspection; in addition, it
includes the .results of announced inspections by a regional reactor inspector and a senior
health physics specialist.
Operations
The shutdown of Unit 1 for a scheduled refueling outage was well executed. During a
problem with an electrical breaker, plant conditions were well managed by the control
room operations staff (Section 01.2),
The inspectors performed a detailed walkdown of the Unit 1 containment following plant
shutdown. Overall condition of the Unit 1 containment was observed to be very good
with minimal leaks noted (Section 01.3).
Reactor coolant system draindown activities to flange level were well controlled and
accomplishe.d in accordance with the procedural requirements (Section 01.4).
Two tagouts were technically adequate and were in accordance with the licensee's
administrative procedures (Section 02.1 ).
Portions of the Unit 1 Component Cooling Water system which support spent fuel pit
cooling and residual heat removal and the Unit 2 Low Head Safety Injection system
were properly aligned and material condition of the equipment was 9009 (Sections 02.2
and 02.3).
The inspectors determined that the Component Cooling Water system valve alignment
procedure did not address all the valves in the system. The licensee issued a deviation
report after the inspectors informed management that some of these problems had been
identified in June 1997 and no permanent procedure change had been initiated (Section
02.2) ..
The reactor operator restoration brief for uninterruptible power supply 282 was
thorough. Operators exhibited a good questioning attitude by asking questions to
- ensure that requirements were understood and by discussing previous restoration
problems. The operators correctly used simultaneous verification, verified expected
system response and adhered to procedures during the restoration (Section 04.1 ).
Management Safety Review Committee members exhibited a questioning attitude and
utilized open discussion to effectively identify, assess and recommend solutions to
technical issues. The inspectors also verified that a quorum was present (Section
08.1) .
2
Maintenance
'
Maintenance personnel completed the reactor coolant filter replacement using approved
procedures. Appropriate coordination, pre-job preparation, and supervisory oversight
enabled the maintenance crew to successfully replace the filter while giving appropriate
consideration to as-low-as-is-reasonably achievable principles (Section M1 .1 ).
Work activities associated with a 480 volt breaker preventive maintenance work order
were accomplished in accordance with the procedure requirements (Section M1 .2).
Service water strainer maintenance activities were completed in a thorough and
professional manner. Maintenance personnel were knowledgeable of the assigned
task, procedures were detailed and actively used on the job, and cooperation and
coordination between the various plant groups were good (Section M1 .3).
Control room leakage testing using the Unit 1 cable tunnel air bottles was performed in
accordance with procedural requirements and demonstrated the ability to maintain the
control room envelope at positive pressure for one hour. Additionally, senior reactor
operator oversight was detailed (Section M1 .4).
A violation was identified for failing to follow procedure requirements by running the
control room air filtration system with painting occurring in the vicinity of the intake of the
system. Pending the licensee's development of corrective actions, this matter will be
tracked as an EEi (Section M1 .5).
The post maintenance testing (PMT) program was effective for its intended function and
was impl~mented properly. The PMT program self-assessment identified valuable
recommendations, which were being implemented, for improving the program.
Deviation reports related to PMT were adequately dispositioned. Post maintenance
tests were performed as stated in work orders (Section M1 .6).
Engineering
An informal process was used to ensure an adequate water thermal barrier was being
maintained on the containment side of the safety injection containment suction gate
valves to prevent pressure locking of these valves during an accident. Once the
inspectors identified this to the licensee, a procedure change was issued to give specific
formal guidance to plant operators. A 1 O CFR 50.59 safety evaluation was performed
which supported the revision (Section E1 .1 ).
Plant Support
Health physics practices were observed to be proper (Section R1 ).
The licensee was properly monitoring and controlling personnel radiation exposure
during the Unit 1 Refueling Outage and posting area radiological conditions in
accordance with 1 O CFR Part 20. The licensee had implemented an effective shutdown
3
chemistry control plan and closely monitored primary coolant chemistry during the
shutdown for the Unit 1 Refueling Outage (Section R1 .1 ).
The overall performance of the emergency response organization during,an emergency
drill demonstrated the licensee's ability to adequately execute the emergency plan
(Section P1 .1 ).
Improper pre-staging of some personnel during an emergency drill resulted in a failure
to demonstrate, by one position, that minimal staffing in the Technical Support Center
could be accomplished within the required time frame (Section P1 .1 ).
Security and material condition of the protected area perimeter barrier were acceptable
(Section 81).
Report Details
Summary of Plant Status
Unit 1 operated at power until October 19, 1998, when the unit was shutdown for a
scheduled 32-day refueling outage. The unit remained shutdown for the remainder of
the inspection period.
Unit 2 operated at power for 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 a"Yareness of overall facility operations and reviewed
operator logs to verify operational safety and compliance with Technical Specifications
(TSs). Instrumentation and safety system lineups-were periodically reviewed from
control room indications to assess operability. Frequent plant tours were conducted to
observe equipment status and housekeeping. Deviation reports (DRs) were reviewed to
assure that potential safety concerns were properly reported and resolved. The
inspectors found that daily operations were generally conducted in accordance with
regulatory requirements and plant procedures.
01.2
Unit 1 Shutdown for Refueling Outage
a.
b.
Inspection Scope {71707)
The inspectors observed and assessed the performance of the operating crew during
the shutdown of Unit 1 for a planned refueling outage.
Observations and Findings
On October 19, the inspectors observed the shutdown of Unit 1 for a planned 32-day
refueling outage. At 1 :51 a.m., the unit was removed from the grid, and the reactor was
manually tripped at 1 :59 a.m. Prior to removing the unit from the grid, the operators
experienced a problem in shifting house electrical loads from the unit station service
transformers to the reserve station service transformers due to a breaker malfunction.
This problem was well managed by the control room staff. All necessary operations
personnel were kept well informed of the status of the troubleshooting activities. While
personnel were evaluating the matter, the power reduction was halted, and all key plant
parameters were closely monitored by the operators until the breaker malfunction was
resolved. Overall, the shutdown was well executed and performed in accordance with
plant procedures .
2
c.
Conclusions
The shutdown of Unit 1 for a scheduled refueling outage was well executed. During a
problem with an electrical breaker, plant conditions were well managed by the control
room operations staff.
01.3
Unit 1 Containment Walkdown
a.
Inspection Scope (71707)
The inspectors performed a detailed walkdown of the Unit 1 containment following entry
into the cold shutdown condition.
b.
Observations and Findings
C.
On October 20, the inspectors performed a detailed walkdown of all major areas of the
Unit 1 containment once containment vacuum was broken and cold shutdown was
- achieved. The walkdown included all elevations, reactor coolant pump cubicles, reactor
coolant system (RCS) loop rooms, the pressurizer cubicle, the containment sump, and
seal table room. The overall condition of the containment for a unit that had been
operating for an extended period was very good in that; 1) Leakage from piping
systems was noted to be minimal, 2) The sump was free of any debris, 3) Material
condition of components was good, and 4) No excess material was located within the
containment.
Conclusions
The inspectors performed a detailed walkdown of the Unit 1 containment following plant
shutdown~ Overall condition of the Unit 1 * containment was observed to be very good
with minimal leaks noted.
01.4
Unit 1 Draindown to Flange Level
a.
b.
Inspection Scope (71707)
The inspectors observed portions of the activities associated with lowering RCS water
level to allow removal of the Unit 1 reactor vessel head.
Observations and Findings
The 'inspectors observed control room activities associated with lowering RCS level from
22 'percent pressurizer level to flange level to allow removal of the reactor vessel head.
The activity was controlled by procedure 1-0P-RC-004, "Draining the RCS to Reactor
Flange Level," Revision 9. The inspectors reviewed the procedure prior to initiation of
the draindown and verified that the required initial conditions were met. The inspectors
also independently verified that the RCS standpipe was properly aligned and capable of
providing accurate RCS indication prior to initiation of the evolution. The activity was
well controlled arid accomplished in accordance with the procedural requirements.
C.
3
Conclusions
Reactor coolant system draindown activities to flange level were well controlled and
accomplished in accordance with the procedural requirements.
02
Operational Status of Facilities and Equipment
02.1
Equipment Tagging Observations (71707)
The inspectors reviewed equipment isolation tagouts, 2-98-EP-0022, "Uninterruptible
Power Supply (UPS) Panel 282," and 1-98-VS-0115, "Self Cleaning Strainer Continuous
B #3 MER." The tagouts, while in effect, were reviewed for technical and administrative
adequacy. Tagout, 2-98-EP-0022, was also reviewed after it had been cleared. The
inspectors verified that the equipment was restored, returned to service appropriately,
and that tags were removed. The inspectors found that the two tagouts were technically
adequate and were in accordance with the licensee's administrative proce.dures.
02.2 Unit 1 Component Cooling System
a.
Inspection Scope (71707)
The inspectors walked down portions of the Unit 1 Component Cooling (CC) system and
reviewed the system valve alignment procedure against the system drawing. The
inspectors performed the walkdown on the portion of the CC system associated with the
spent fuel pit coolers and the Unit 1 residual heat removal system outside containment.
b.
Observations and Findings
The CC system is not required to mitigate an accident; however, the system supplies
cooling water to the spent fuel pit heat exchanger and makeup to the. charging pump
cooling water system. The CC system was properly aligned and material condition was.
good on the portion of the system reviewed. During review of the system alignment
procedure 1-0P-51.1 A, "Component Cooling System Alignment," Revision 5,* the
inspectors identified a large number of valves that were not addressed in the procedure.
The vast majority of. the valves identified as not being in the valve alignment procedure
were vent and drain valves, however, some flow path valves were identified that were
not verified by the valve alignment procedure. The inspectors identified that in
procedure 1-0P-51.1A valves 1-CC-710 and 1-CC-781 were incorrectly identified and
were specified to be in an incorrect position. These two valves were actually part of the
charging pump cooling water system and were in the correct position as specified by
that system's operating procedure. The inspectors also identified several pieces of
equipment that had been isolated and abandoned in place. The procedure specified
valve alignments that would place some of the abandoned equipment in service.
The inspectors discussed these items with operations personnel and independently
verified that the flow path valves were in their correct position, including the valves that
4
were incorrectly identified on the valve alignment procedure. Subsequent discussions
with operations personnel determined that the incorrectly identified valves and the valve
position discrepancies associated with abandoned in place equipment had been
previously identified by operations personnel in June 1997 and that a one time use only
procedure change had been issued at that time. The licensee had not initiated a
permanent procedure change. The licensee issued a deviation report to document and
correct the procedure problems identified by the inspectors. The inspectors expressed
a concern to licensee management that a procedure problem involving configuration
management had been allowed to remain uncorrected for over a year.
c.
Conclusions
The portions of the Unit 1 Component Cooling Water system supporting spent fuel pit
cooling and residual heat removal were properly aligned and material condition of the
equipment was good.
The inspectors determined that the Component Cooling Water system valve alignment
procedure did not address all the valves in the system and required two valves to be in
incorrect positions. The licensee issued a deviation report after the inspectors informed
management that some of these problems had been identified in June 1997 and no
permanent procedure change had been initiated.
02.3
Unit 2 Low Head Safety Injection System
a.
Inspection Scope (71707)
The inspectors performed a walkdown of the Unit 2 Low Head Safety Injection (LHSI)
system.
b.
Observations and findings
During the inspection period, the inspectors performed a walkdown of the Unit2 LHSI
system. The inspectors reviewed the associated system drawings, valve alignment
procedure, and inspected accessible portions of the system to verify proper valve
. alignment and material condition. The system was found to be in good material
condition and properly aligned for standby operation.*
c;
Conclusions
The Unit 2 Low Head Safety Injection system was found to be in good material condition
and properly aligned for standby operation .
04
5
Operator Knowled_ge and Performance
04.1
Uninterruptible Power Supply (UPS) 2B2 Restoration
a.
Inspection Scope (71707, 62707)
b.
The inspectors observed the control and performance of the UPS 2B2 restoration
following preventive maintenance.
Observations and Findings
The inspectors attended the brief held for the operators participating in the restoration of
UPS 2B2. The brief was conducted by the reactor operator supervising the evolution.
The brief was very thorough, using a briefing checklist to ensure that all important
information was addressed and understood. The operators exhibited a good
questioning attitude, drawing upon lessons learned from past UPS restorations to avoid
potential problems.
The UPS 2B2 restoration was observed by the inspectors, and was found to be well
coordinated and systematically controlled. The operators correctly used simultaneous
verification for equipment tag removal and component operation to ensure that the
sensitive evolution of restoring UPS 2B2 was completed in accordance with procedural
requirements. The inspectors observed the operators display the good practice of
verifying proper system response after the performance of each action. Operators
performing the UPS 2B2 restoration were observed to use proper three part
communications with one another throughout the evolution.
c.
Conclusions
The reactor operator restoration brief for the uninterruptible power supply 2B2 was
thorough. Operators exhibited a good questioning attitude by asking questions to
ensure that requirements were understood and by discussing previous restoration
problems. The operators correctly used simultaneous verification, verified expected
system response and adhered to procedures during the restoration.
- 04.2
Tour with the Service Building Inside Operator (71707, 71750)
On October 8, the inspectors accompanied the service building inside operator during
his routine rounds. This tour included the Unit 1 and Unit 2 switchgear rooms, number
1, 2, and 3 emergency diesel generator rooms, number 1, 2, 3, and 4 mechanical
equipment rooms, the station battery rooms, Unit 1 and Unit 2 emergency switchgear
rooms and Unit 1 and Unit 2 cable vaults. The inspectors evaluated the operator's
attention to detail, familiarity with plant systems, and thoroughness of rounds. The
inspectors also checked the rooms for general housekeeping conditions. The
inspectors discussed with the operator the operation of several components including
the rod control motor generators, the starting air compressors for the emergency diesel
Jenerators, and the main feedwater regulating valves. The operator conducted his
6
rounds in a thorough and professional manner and was knowledgeable of plant
systems.
04.3 Tour with the Service Building Outside Operator (71707, 71750)
On October 14, the inspectors accompanied the service building outside operator during
his routine rounds. This tour included the auxiliary building, the fuel building, Unit 1 and
Unit 2 safeguards buildings, and Unit 1 and Unit 2 main steam valve houses. The
inspectors evaluated the operator's attention to detail, familiarity with plant systems,
thoroughness of rounds, and radiological work practices. The inspectors also checked
the buildings for general housekeeping conditions. The inspectors discussed with the
operator the operation of several systems including containment spray, low* head safety
injection and the fuel oil transfer systems. The operator conducted his rounds in a
thorough and professional manner and was knowledgeable of plant systems.
08
Miscellaneous Operations Issues (92700, 40500)
08.1
Management Safety Review Committee (MSRC) (40500)
On September 9, 1998, the inspectors attended the quarterly meeting of the MSRC.
The committee reviewed and recommended two changes to the Surry Technical
Specifications. The committee also reviewed the scope and schedule for the October
1998 Unit 1 outage. The inspectors observed that the MSRC members exhibited a
questioning attitude and utilized open discussion to effectively identify, assess and
recommend solutions to technical issues. The inspectors also verified that a quorum
was present.
08.2
(Closed) Licensee Event Report (LER) 50-281/96006-00: Auto reactor trip due to
steam/feed flow mismatch coincident with a low SG level. This LER describes a reactor
trip from 11 percent power during a reactor shutdown. The event was discussed in NRC
Inspection Report Nos. 50-280, 281 /96-12. The inspectors reviewed the LER and found.
the licensee corrective actions acceptable.
08.3
(Closed) LER 50-281/97001-00: Manual reactor trip and ESF actuation due to loss of
EHC coritrol power. This LER describes a manual reactortrip due to a loss of electro-
hydraulic control power. The event was discussed in NRC Inspection Report Nos. 50-
280, 281/97-02. The inspectors reviewed the LER and found the licensee corrective
actions acceptable .
l'
7
II. Maintenance
M1
Conduct of Maintenance
M1 .1
Reactor Coolant Filter Replacement
a.
Inspection Scope (62707)
.
The inspectors witnessed maintenance personnel perform the replacement of a reactor
coolant filter. The inspectors reviewed procedures associated with the activity.
b.
Observations and Findings
C.
On September 29, the inspectors witnessed maintenance personnel perform the
replacement of the 1-CH-FL-2 reactor coolant filter. The activity was performed in
accordance with Procedure O-MCM-0605-04, "Reactor Coolant Filter Replacement,"
Revision 5-P4. During the procedure review, the inspectors found minor errors
associated with several procedural. steps, and referred these procedural discrepancies
to the licensee for correction.
The inspectors observed that the filter replacement evolution was well coordinated with
adequate supervision present. Supervision provided direction and past lessons learned
to the individuals performing the maintenance to assist in minimizing the radiation
exposure received. Maintenance personnel involved were successful in completing the
filter replacement while implementing methods to maintain the associated dose as-low-
as-is-reasoAably achievable (ALARA).
Conclusions
Maintenance personnel completed the reactor coolant filter replacement using approved
procedures. The inspectors identified to the licensee several minor procedural
.
- deficiencies. Appropriate coordination, pre-job preparation, and supervisory oversight
enabled the maintenance crew to successfully replace the filter while giving appropriate
consideration to as-low-as-is-reasonably achievable principles.
M1 .2
Breaker Maintenance
a.
b.
Inspection Scope (62707)
The inspectors observed motor operated valve breaker maintenance activities.
Observations and Findings
The inspectors observed maintenance activities associated with Work Order (WO)
00382734, "PM 480 Volt MCC Breaker 1-98-81-0012." The work activity was
accomplished in accordance with procedure O-ECM-0306-02, "Motor Control Center
Maintenance," Revision 19 .. The work activity was accomplished in accordance with the
work order.
C.
8
Conclusions
Work activities associated with a 480 volt breaker preventive maintenance work order
were accomplished in accordance with the procedure requirements.
M1 .3
Control Room Chiller 4A Service Water Strainer
a.
Inspection Scope (62707)
The inspectors observed the activities associated with the cleaning of the Y-strainer for
the Control Room Chiller 4A Service Water system.
b.
Observations and Findings
The inspectors observed maintenance personnel cleaning the Y-strainer in the service
water supply for the control room chiller in accordance with WO 00397694-01. The
chiller had been declared inoperable because of indications that the service water
strainer had clogged. Upon opening the strainer, maintenance personnel found mud
and biological matter, mainly consisting of worms and hydroids. The strainer was
cleaned and the chiller was returned to service. The inspectors determined that the
work instructions were adequate and followed, and that technicians were knowledgeable
of the assigned task.
c.
Conclusions
Maintenance activities involving the service water strainer were completed in a thorough
and professional manner. Maintenance personnel were knowledgeable of the assigned
task, procedures we~e detailed and actively used on the job, and cooperation and
coordination between the various plant groups were good.
M1 .4
Control Room Leakage Test Using the Unit 1 Cable Tunnel Air Bottles*
a.
Inspection Scope {61726)
The inspectors observed the performance of procedure 1-0SP-VS-002, "Control Room
Leakage Test Using the Unit 1 Cable Tunnel Air Bottles," Revision 3, to ensure that the
control room could be maintained at positive pressure for one hour using the volume of
air from the Unit 1 cable tunnel air bottles.
b.
Observations and Findings
On October 18, the inspectors observed the performance of procedure 1-0SP-VS-002.
A thorough pre-job brief was conducted by the operator in charge of the test. The test
was conducted in accordance with procedural requirements. The control room pressure
was maintained at least 0.05 inches of water higher than the adjoining turbine building
for one hour as required by TS. In addition, detailed oversight of the test was performed
by the Unit 1 senior reactor operator.
, .
C.
Conclusions
n
- J
Control room leakage testing using the Unit 1 cable tunnel air bottles was performed in
accordance with procedural requirements and demonstrated the ability to maintain the
control room envelope at positive pressure for one hour. Additionally, senior reactor
operator oversight was detailed.
M1 .5
Painting During Control Room Air Filtration System Flow Test
a.
b.
Inspection Scope (62707)
The inspectors reviewed the circumstances involving the running of the control room
emergency ventilation system with painting in the vicinity of the ventilation. system
suction.
Observations and Findings
On October 5, during a routine tour of the power station, the inspectors detected the
odor of fresh paint near the entrance to the main control room annex. The control room
annex entry door provides passage to and from the turbine building breezeway. Upon
entering the control room, the inspectors noted that plant operators were performing test
O-OPT-VS-004, "Control. Room Air Filtration System Flow Test," Revision 1, which
involved the running of the control room emergency ventilation system (fan/filter train 2-
VS-F-41 ). This system contains charcoal filters, which if exposed to paint fumes,
degrades the filter's radioiodine retention capability. The inspectors informed the
operations staff that a strong odor of paint was evident at the entrance to the control
room annex, and expressed a concern of the possible exposure of the charcoal to the
paint fumes due to the close proximity of the suction of the 2-VS-F-41 fan to the area in
which the fumes were noted.
The operations staff quickly located and secured the painting activity in the cable
spreading room. This area is located above the control room and is in the vicinity of the
control room air filtration system air intakes. Paint fumes were being drawn into the
turbine building from the cable spreading room. The charcoal in the filters was replaced
as recommended by the ventilation system engineer, and a deviation report was issued .
. These actions represented prompt and effective initial followup to this matter.
- Following this event, the inspector reviewed procedure O-OPT-VS-004, and noted that
"Precautions and Limitations" Section 4.2 states that to prevent damage to the filter
internals, this test shall not be conducted if painting is occurring near the intakes of the
Control Room Air Filtration System. This matter is a violation of NRC requirements in
that the licensee failed to follow the requirements specified in procedure O-OPT-VS-004.
At the end of the inspection period, the licensee was developing corrective actions to
address this event. Pending review of the licensee's proposed corrective actions this
matter is identified as EEi 50-280, 281/98008-01 .
C.
10
Conclusions.
A violation was identified for failing to follow procedure by running the control room air
filtration system with painting occurring in the vicinity of the system intake. Pending the
licensee's development of corrective actions, this matter will be tracked as an EEi.
M1 .6
Post Maintenance Testing (PMT) Program
a.
b.
Inspection Scope (62702)
The inspectors reviewed the PMT program, deviation reports (DRs), and work orders
(WOs) and observed PMT performance to determine if the PMT program was.
implemented in accordance with proper procedures and was effective.
Observations and Findings
The inspectors discussed the PMT program with the program coordinator and
engineers. The procedure for this program is VPAP-2003, "Post Maintenance Testing
Program," Revision 7. This program includes the testing of modifications and new
installations after the work is completed and before the components or systems are
released to service. The PMT program provides the vehicle for electronically tracking
the testing requirements or technical reviews following maintenance, modifications, or
new installations. Testing for modifications and new installations were normally
specified in design change packages.
The licensee oversight group performed self-assessment SLA 98-09, "Effectiveness of
the PMT Program," in June 1998 in response to Violation 50-281/97012-03 which was
issued for missed PMT after maintenance was completed on the Unit 2 turbine driven
auxiliary feedwater pump governor. The purpose of the self-assessment was to ensure
the PMT program was effective and implemented properly. The self-assessment
reviewed the adequacy of the program, reviewed PMT related DRs, evaluated process
and implementation of the PMT, and discussed the program with the personnel of
various departments using the program. The self-assessment concluded that the
program was effective to identify the required PMT. The licensee was in the process of
implementing the self-assessment's five .recommendations for improving the program.
The inspectors reviewed the self-assessment and its recommendations and considered
that the assessment was a good vehicle for making valuable recommendations.
The inspectors reviewed 25 DR summaries generated in the last one and one half years
related to PMT. The inspectors discussed 10 DRs with the program coordinator and
reviewed the details contained in the DRs. The inspectors found that only three cases
were related to PMT problems. The inspectors found that the DR related to the
problems stated in Violation 50-281/97012-03 for failure to follow work procedures was
the only example were PMT was missed. The second case was one where the required
PMT was not performed for the component and was detected through the PMT data
review. The licensee then performed the PMT for the component. The third case
involved required PMT that was added through the PMT data review after the
maintenance was completed. These cases were considered isolated cases.
11
The inspectors reviewed 30 work orders which were completed in the last five years on
valves and valve operators for the residual heat removal and safety injection systems.
The purpose of the review was to determine if PMT was performed in*accordance with
the requirements stated in the PMT data sheets. Based on the documentation reviewed
the inspectors det.ermined that the PMT were performed as required.
The inspectors observed two post maintenance test in the field.* One was related to
returning UPS 28-2 to service after maintenance and cleaning. The licensee used
procedure 2-MOP-EP-004, "Removal from Service and Return to Service of UPS 28-2
Components," Revision 2, for the testing. The tests included functionality checks for the
breaker, switch, and light indicators. The UPS 28-2 was successfully returned to
service. The other observed post maintenance test was associated with emergency
service water pump 1-SW-P-1A. The maintenance performed on the pump included
repacking the annubar (WO 00395683-01) and replacing shims and aligning the engine
(WO 00389989-01 ). The tests performed were associated with maintenance and
operation of the pump. The procedure used for the maintenance test was O-MCM-0703-
01, "Emergency Service Water Pump Diesel Engine Service and Inspection," Revision
3. Maintenance personnel performed an overspeed trip test to adjust the governor trip
setpoints within 1920 and 1960 RPMs. Maintenance personnel made several
adjustments before obtaining trip setpoints within the allowable range. Operation
personnel performed a functional test by using procedure O-OP-SW-002, "Emergency
Service Water Pump Operation," Revision 7. Pump vibration data taken during the test
was within the acceptable range. All the tests were performed in accordance with the
correct procedures and were adequate.
The inspectors concluded that the PMT program was effective as stated in the self-
assessment.
c.
- Conclusions
The post maintenance testing (PMT) program was effective for its intended function and
was implemented properly. The PMT program self-assessment identified valuable
recommendations, which were being implemented, for improving the program.
Deviation reports related to PMT were adequately dispositioned. Post maintenance
tests were performed as stated in work orders.
MS
Miscellaneous Maintenance Issues (92700, 92902)
M8.1
(Closed) LER 50-280, 281/97007-00: Outside Appendix R design basis due to vital Bus
isolation issue. This LER was submitted when it was noted that there was no means to
isolate the UPSs from the 120 VAC vital busses in the event of a control room fire. This
condition could lead to a loss of power to the Appendix R Remote Monitoring Panels.
This event was discussed in NRC Inspection Report Nos. 50-280, 281/97-09 and
resulted in the issuance of a Notice of Violation (EA 97-474, 01013). The inspectors
reviewed the LER and the proposed corrective actions to prevent recurrence and found
. them adequate.
12
M8.2
(Closed) Violation (VIO) 50-281/97012-03: Failure to follow work instructions related to
the Unit 2 TDAFW governor replacement. The licensee revised the response to this
violation in correspondence dated April 14, 1998. The revised response listed five
commitments for corrective actions to resolve the _violation. The five con:imitments were
case study training, additional training for mechanical maintenance supervisors,
procedural clarifications, PMT matrix revisions, and an assessment of the PMT program.
The inspectors reviewed the five commitments stated in the response. Only the
procedural clarifications remain to be completed. The licensee sent seven people to
Woodward Governor Company for governor maintenance and adjustment training. The
licensee conducted several meetings to discuss the problems among management,
supervisors, engineers, and maintenance personnel for the root cause and resolution of
this violation. The PMT matrix was revised. A self-as~essment was performed, SLA 98-
09, "Effectiveness of the PMT Program," which was evaluated in Section M1 .6 of this
report.
Ill. Engineering
E1
Conduct of Engineering
E1 .1
Operation of Containment Sump Pumps to Ensure Adequate Coverage of Safety
Injection (Recirculation Spray) Sump Suction Valves
a.
Inspection Scope (37551)
b.
The inspectors reviewed the licensee's practice of periodically placing the containment
sump pumps in the off position during normal at power operation.
Observations and Findings
The licensee periodically places the containment sump pumps in the off position during
normal at power operation. These sump pumps are used to remove routine sump
inleakage during normal operation and are not used for accident mitigation. When
questioned about this practice, the licensee stated that this was done to ensure that a
thermal barrier of water was kept on the containment side (in the recirculation spray
sump) of the safety inje~tion containment suction gate valves to prevent pressure
locking of these valves during an accident (as described in NRC Generic Letter 95-07,
"Pressure Locking and Thermal Binding of Safety-Related Power-Operated Gate
- Valves"). Specifically, when recirculation spray sump level indication drops below the
minimal detectable reading (due to evaporative losses), the containment sump pumps
are placed in the off position so that the containment sump will fill and overflow into the
adjoining recirculation spray sump (a weir divides the two sumps). Once the
recirculation spray sump level indication is returned to a detectable level, the
containment sump pumps are returned to a normal status with one pump in automatic
and one in standby. While the pumps are in the off position, the containment sump high
level alarm is locked in until the sump pumps are returned to the normal status. Thus,
neither the alarm function nor indications of the sump pumps cycling on and off are
available to the operators to provide indication of abnormal leakage inside the
containment.
C.
13
Review of the matter by the inspector revealed that this practice was not recognized by
the Updated Final Safety Analysis Report (UFSAR), rior was it procedurally controlled.
UFSAR paragraph 4.2.7.1.4 states that the containment sump level instrumentation is
one of the backup methods of detecting primary system leakage. These, facts were
brought to the attention of licensee management. The licensee took the following
actions; 1) Initiated and completed a procedure change to 1-PT-36 and 2-PT-36,
- "Instrumentation Surveillance," to give the operators specific instructions to add water to
the recirculation spray sump by placing the sump pumps in the off position, and 2)
Performed a 1 O CFR 50.59 safety evaluation which supports this practice. The
inspectors reviewed these actions and found them to be satisfactory. In no case, did the
inspectors observe or determine that an adequate amount of water was not being
maintained on the containment side of the safety injection containment suction gate
valves. The lack of a procedure for maintaining an adequate thermal barrier constituted
an informal control of an important action necessary to ensure the valves could be
operated under accident conditions. The licensee's actions to correct this matter were
. appropriate.
Conclusions
An informal process was used to ensure an adequate water thermal barrier was being
maintained on the containment side of the safety injection containment suction gate
valves to prevent pressure locking of these valves during an accident. Once the
inspectors identified this to the licensee, a procedure change was issued to give specific
formal guidance to plant operators. A 1 O CFR 50.59 safety evaluation was performed
which supported the revision.
. Miscellaneous Engineering Issues (92903)
E8.1
(Closed) VIO 50-280, 281/96010-01: Failure to promptly identi.fy and correct deficient
Unit 2 FLOWCALC condition. This item was previously addressed in NRC Inspection
Report Nos. 50-280, 281/98-04. That inspection determined that all but low priority
corrective actions had been completed. The inspectors reviewed the licensee actions to
address the open items. The inspectors determined that progress had been made in .
closing the items and that documented due dates had been established and are being
tracked in the commitment tracking system for items not closed.
E8.2
(Closed) VIO 50-281/96013-01: Weld undersize problems for supports in letdown line
piping. This violation was issued for several undersized welds found in various supports
in the weld shop after the licensee weld inspector accepted the welds. The licensee
immediately issued DR S-96-2702 for the root cause analysis and corrective actions to
prevent recurrence. The undersized welds were immediately upgraded to meet
drawing requirements and the supports were installed on the letdown line piping. The
violation response stated that the root cause was that the individual weld inspector
misunderstood the weld acceptance requirements. The corrective actions committed in
the response included a retest of this individual to regain his certificate, reinforcements
of the weld acceptance requirements for other weld inspectors, and reexamination of the
welds performed by this individual after he received the certificate as a weld inspector .
..
14
The inspectors reviewed the root cause analysis arid corrective actions completed which
were consistent with the response.
IV. Plant Support
R1
Radiological Protection and Chemistry Controls (71750)
- On numerous occasions during the inspection period, the inspectors reviewed Radiation
Protection (RP) practices including radiation control area entry and exit, survey results,
and radiological area material conditions. No discrepancies were noted, and the
inspectors determined that RP practices were proper.
R1 .1
Occupational Radiation Exposure Control Program
a.
Inspection Scope (83750)
b.
The inspectors reviewed implementation of selected elements of the licensee's radiation *
protection program during the current Unit 1 Refueling Outage (RFO). The review
entailed observation of radiological protection activities including personnel exposure
monitoring, radiological postings, verification of posted radiation dose rates and
contamination levels within the radiologically controlled area (RCA), and primary coolant
shutdown chemistry controls for dose rate reduction. 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 1 O CFR 20.
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.
Individuals at selected job sites were interviewed and it was determined that the workers
were aware of their administrative dose and dose rate limits, the work area dose rates,
the proximate low-dose waiting areas, areas of high contamination, and protective
clothing required by the RWP. The inspectors concluded that the licensee had
adequately informed workers of the radiological conditions existing in work areas and
the protective measures required to be taken while in the work areas.
The inspectors observed the use of personal radiation exposure monitoring devices by
personnel entering and exiting the RCA. Thermoluminescent dosimeters (TLDs) were
15
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 (PREMS) 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 personal contamination monitors (PCMs). The inspectors
concluded that the licensee was closely monitoring personnel radiation exposure in a
manner consistent with 1 O CFR 20.1502.
During tours of the RCA the inspectors noted that general areas and individual rooms
were properly posted for radiological conditions. Survey maps indicating dose rates and
contamination levels at specific locations within the RCA were posted at the entrance to
the RCA. Radiological postings were also conspicuously displayed at individual
contaminated and high radiation areas. Color coded signs were also used throughout
the RCA to indicate the general area dose rates. At the inspector's request, a licensee
Health Physics Technician performed dose rate and contamination surveys in several
rooms and locations. The inspectors verified that the survey instrument readings were
consistent with the posted area dose rates. Contact dose rates from several radioactive
material bearing containers were also verified to be consistent with the dose rates
recorded on container labels. Independent contamination surveys performed around
several posted contaminated areas indicated that contamination was not being tracked
out of the contaminated areas. The inspectors concluded that the licensee's practices
for radiological postir:ig and labeling were consistent with the requirements of Subpart J
of 10 CFR 20.
The inspectors reviewed the 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
PREMS, 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 versus their respective projections were also
distributed daily. The inspectors noted that the cumulative projection was being met as
of day three of the scheduled 32 day outage. Based on the scope of work, the
licensee's ALARA Committee established an official ALARA goal of 113 man-rem for the
1998 Unit 1 outage and an aggressive challenge goal of 98 man-rem. The inspectors
concluded that the Committee's practice of establishing challenging goals reflected
licensee management's support and commitment to overall dose reduction.
The inspectors reviewed the licensee's procedures for follow-up actions to Personnel
Contamination Events (PCEs) and reviewed selected records for those events which
occurred during 1998. Procedure HP-1061.020, "Personnel Contamfnation Monitoring
and Decontamination," indicated that the threshold for initiating follow-up actions was
skin or clothing contamination in excess of 100 net counts per minute (ncpm) as
,I
16
measured by a hand held frisker. The licensee's records indicated that 52 PCEs
occurred prior to the start of Unit 1 outage on October 19 and that 20 occurred during
the first three days of the outage. The inspectors discussed with the licensee the
increased frequency of PCEs during the early stages of the outage. The, licensee
- indicated that the issue was being reviewed. The predominant contaminant was
identified as 6°Co in several of the events. The licensee indicated that one possible
source of the 6°Co, which has a relatively long half-life, was residual contamination on
protective clothing. The licensee launders reusable protective clothing onsite and
surveys the laundered clothing before releasing it for reuse. The licensee indicated that
the alarm threshold for the monitor used to survey the clothing had been reduced by
approximately 40 percent in order to reduce the potential for similar events. The
inspectors concluded that the licensee had effectively impleme.nted a process for
identifying and correcting trends related to personnel contaminations.
Bioassays were performed on four individuals involved in PCEs which occurred before
the outage but there were no uptakes of radioactive material greater than the threshold
for assigning internal dose, i.e., three tenths of one percent of the Annual Limit on
Intake (ALI). No uptakes occurred during the first three days of the outage. One of the
PCEs which occurred before the outage resulted in the assignment of 1.4 rem to an
individual as a skin dose from a hot particle. Skin dose assessments from hot particles
had been initiated for three other individuals as a result of PCEs which occurred during
the first three days of the outage. Preliminary estimates indicated that all were less than
5 rem. The inspectors reviewed selected dose calculations and determined that they
were consistent with licensee dose calculation procedures. No regulatory dose limits
were exceeded. The inspectors concluded that the licensee had implemented an
effective process for identification and assessment of potential personnel exposure from
. internal, skin, and hot particle contamination.
The inspe~tors reviewed the licensee's records for contaminated floor space within* the
RCA Radiation protection personnel maintained records of the areas within the RCA,
excluding the Containment Buildings, which had contamination levels in excess of 1000
disintegrations per minute per 100 square centimeters (dpm/100 cm2). Contaminated
areas were categorized as either temporarily contaminated recoverable areas or non-
recoverable areas. Generally the recoverable areas were temporarily established work
areas in which planned activities had the potential for causing the proximate area to
become contaminated and after which would be decontaminated, i.e., recovered. The
non-recoverable areas were infrequently accessed high radiation areas and the
exposures which would be incurred to decontaminate the area would not be consistent
with ALARA principles. The recoverable square footage was tracked on a daily basis
and monthly averages were calculated. The inspectors noted that during non-outage
periods the monthly averages for recoverable contaminated floor space during 1998
were less than one percent of the RCA floor space and the non-recoverable area was
approximately 2.5 percent. The inspectors concluded that the licensee had aggressively
minimized the contaminated floor space within the RCA
The inspectors also reviewed the licensee's plans for primary chemistry controls during
the reactor shutdown for the Unit 1 RFO; The general plan for the shutdown chemistry
controls included early injection of boric acid into the RCS during cooldown followed by
injection of hydrogen peroxide after cooldown. The objective of the plan was to cause a
.
I
I
"
17
controlled release of radioactive materials from the internal surfaces of the RCS and to
remove those materials from the coolant by use of the reactor water clean-up system.
Specific plans consisted of injecting boron at a controlled rate to achieve an acid
reducing environment, controlling the pH such that the coolant remained ,acidic until the
coolant changed to an oxidizing environment by the injection of hydrogen peroxide, and
maintaining the coolant's lithium, hydrogen and oxygen concentrations within specified
ranges during cooldown in order to keep the released material in soluble chemical
compoun9s. One specific goal of the chemistry control plan was to reduce the
combined total activity concentration of the gamma emitters 58Co, 6°Co, 134Cs, 137Cs,
54Mn, and 51Mn to less than 0.5 micro-Curies per milliliter (µCi/ml) in order to assure
adequate clean-up of the coolant. The inspectors reviewed trend plots for several
chemistry parameters monitored by the licensee during the shutdown, including the
58Co concentration, which was one of the major contributors to the total activity
concentration. The 58Co concentration peaked at approximately 0.26 µCi/ml during the
oxidizing phase of the process and was then reduced to 0.05 µCi/ml after 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> of
clean-up operations. The inspectors reviewed analytical results for selected chemistry
parameters and concluded that the licensee had closely monitored and controlled
primary coolant chemistry during the shutdown for the Unit 1 RFO.
c.
Conclusions
The licensee was properly monitoring and controlling personnel radiation exposure
during the Unit 1 Refueling Outage and posting area radiological conditions in
accordance with 1 O CFR Part 20. The licensee had implemented an effective shutdown
chemistry control plan and closely monitored primary coolant chemistry during the
shutdown for the Unit 1 Refueling Outage.
P1
Conduct of Emergency Preparedness (EP) Activities
P1 .1
Annual Emergency Drill Conducted During Off Hours
a.
Inspection Scope (82301)
b.
The inspectors observed the licensee's annual emergency drill. The off hours drill was
conducted on Saturday, September 19, 1998.
Observations and Findings
On September 19, 1998, the licensee conducted an off hours emergency drill to
exercise the emergency response plan. The inspectors observed activities in the
simulator control room, Technical Support Center (TSC) and Operations Support Center
(OSC). The inspectors determined that the licensee emergency response call out
system provided notification to designated individuals in a timely manner and that overall
manning of the TSC and OSC was accomplished in a reasonable time frame. The
licensee and the inspectors did identify areas for improvement in the area of personnel
response to the site in that one position in the TSC was not manned in the required time
frame. Seven individuals were determined to have pre-staged themselves in areas
close to or at the plant such that they responded in a time frame much quicker than had
18
they been at home. These individuals were excluded from being considered as
acceptable responders, thereby resulting in one position in the TSC not being manned
in the required time frame. The inspectors discussed the identified deficiency with
regional emergency preparedness inspectors, who concluded that being ,one person
short of minimal manning within the required time frame, while not optimum, was
acceptable,
The inspectors observed and evaluated the licensee's implementation of the emergency
plan during the drill. Management and control of the facility was performed in a manner
that ensured the missions of the facility would be properly carried out. Accident
assessment and classification was performed in accordance with the emergency plan.
The overall performance of the emergency response organization demonstrated the
licensee's ability to adequately execute the emergency plan.
c.
Conclusions
The overall performance of the emergency response organization during an emergency
drill demonstrated the licensee's ability to adequately execute the emergency plan ..
Improper pre-staging of some personnel during an emergency drill resulted in a failure
to demonstrate, by one position, that minimal staffing in the Technical Support Center
could be accomplished within the required time frame.
S1
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
- X1
Exit Meeting Summary
The inspe_ctors presented the inspection results to members of licensee management at .
the conclusion of the inspection on November 6, 1998; The licensee acknowledged the
findings presented.
The inspectors asked the licensee whether any materials examined during the
inspection should be considered proprietary. No proprietary information was identified .
19
PARTIAL LIST OF PERSONS CONTACTED
M. Adams, Superintendent, Engineering
R. Allen, Superintendent, Maintenance
R. Blount, Manager, Nuclear Safety & Licensing
E. Collins, Director, Nuclear Oversight
M. Crist, Superintendent, Operations
E. Grecheck, Site Vice President
B. Shriver, Manager, Operations & Maintenance
T. Sowers, Superintendent, Training
B. Stanley, Supervisor, Licensing
W. Thornton, Superintendent, Radiological Protection
IP 37551:
- 1p 40500:
IP 61726:
IP 62702:.
IP 62707:
IP 71707:
IP 71750:
IP 82301:
IP 83750:
IP 92700:
IP 92902:
IP 92903:
- opened
INSPECTION PROCEDURES USED
Onsite Engineering
Effectiveness of Licensee Controls in Identifying, Resolving, and Preventing
Problems
Surveillance Observation
Maintenance Program
Maintenance Observation
Plant Operations
Plant Support Activities
Evaluation of Exercises for Power Reactors
Occupational Radiation Exposure
Onsite Followup of Written Reports of Nonroutine Events at Power Reactor
Facilities
Followup - Maintenance
Followup - Engineering
ITEMS OPENED AND CLOSED
50-280, 281/98008-01
EEi
Failure to follow the requirements specified in
procedure O-OPT-VS-004 (Section M1 .5)
Closed
50-281 /96006-00
LER
50-281/97001-00
LER
Auto reactor trip due to steam/feed flow mismatch
coincident with a low SG level (Section 08.2)
Manual reactor trip and ESF actuation due to loss
of EHC control power (Section 08.3)
50-280, 281/97007-00
LER
50-281/97012-03
50-280, 281/96-01001
50-281/96013-01
20
Outside Appendix R design basis due to vital bus
isolation issue (Section M8.1)
.Failure to follow work instructions related to the
Unit 2 TDAFW governor replacement (Section
M8.2)
Failure to promptly identify and correct deficient
Unit 2 FLOWCALC condition (Section E8.1)
Weld undersize problems for supports in letdown
line piping replacement (Section E8.2)