ML18152A135
| ML18152A135 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 02/12/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18152A136 | List: |
| References | |
| 50-280-98-10, 50-281-98-10, NUDOCS 9902240106 | |
| Download: ML18152A135 (24) | |
See also: IR 05000280/1998010
Text
.r
U.S. NUCLEAR REGULATORY COMMISSION
REGION 11
Docket Nos.:
License Nos.:
Report No.:
Licensee:
Facility:
Location:
Dates:
Inspectors:
Approved by:
9902240106 990212
ADOCK 05000280
G
50-280, 50-281
50-280/98-10, 50-281/98-10
Virginia Electric and Power Company (VEPCO)
Surry Power Station, Units 1 & 2
5850 Hog Island Road
Surry, VA 23883
December 6, 1998 - January 16, 1999
R. Musser, Senior Resident Inspector
K. Poertner, Resident Inspector
G. McCoy, Resident Inspector (In Training)
K. Coyne, Project Engineer (In Training, Section M8.2)
D. Jones, Senior Radiation Specialist (Sections R1 .2, R1 .3, R4.1,
R7.1)
.
W. Smith, Radiation Specialist (In Training, Section R1 .1)
W. Stansberry, Physical Security Specialist (Sections S1 .1, S1 .2,
S2.1, S3.1, S4.1, S4.2, S6.1, S8.1, and S8.2)
K. Barr, Chief, Plant Support Branch (Section R1 .4)
R. Haag, Chief, Reactor Projects Branch 5
Division of Reactor Projects
Enclosure
EXECUTIVE SUMMARY
Surry Power Station, Units 1 & 2
NRC Inspection Report Nos. 50-280/98-10, 50-281/98-10
This integrated inspection included aspects of licensee operations, engineerjng, maintenance,
and plant support. The report covers a six-week period of resident inspection; in addition, it
includes the results of announced inspections by two regional radiation specialists, a regional
security specialist, a regional Branch Chief, and a regional project engineer.
Operations
Licensee actions to resolve a low pressure alarm on a spent fuel storage cask
demonstrated that cask integrity was intact and adequately returned the alarm function
to service. A negative observation was identified in that the licensee did not
expeditiously address the low pressure alarm (Section 01.2).
Maintenance
The Number 2 Emergency Diesel Generator (EDG) excitation cabinet inspection was
thorough and conducted in accordance with the procedural requirements. No
deficiencies were noted during the inspection. The licensee has completed visual
inspections of the EDG excitation cabinets initiated in response to a catastrophic
- component failure in the Number 3 EDG excitation cabinet (Section M1 .1).
Low Head Safety Injection system recirculation flow testing was performed in
accordance with approved procedures and all test acceptance criteria were met (Section
M1.2).
The incore flux mapping system was properly used to measure the incore power levels
and adequately demonstr;:1ted that the core power distribution met thermal
requirements. The engineers demonstrated detailed knowledge of the operation and
limitations of the flux measurement equipment and the effects of the testing on plant
operation (Section M1 .3).
The licensee has taken action to resolve a problem with decreasing lube oil
temperatures for the Number 2 EDG while in a standby condition. However, these
actions have not been successful and the licensee has periodically run the diesel to
increase lube oil temperatures to the normal level for standby conditions. The
inspectors have noted that operating shift personnel have displayed an appropriate level
of sensitivity to the lube oil temperature issue (Section M1 .4).
Engineering
The number of temporary modifications installed on Units 1 and 2 were minimal and
were adequately justified by the associated safety evaluations (Section E1 .1 ) .
2
Plant Support
The licensee effectively implemented a program for transportation of radioactive
materials pursuant to Department of Transportation and NRC regulations. Individuals
involved in preparing shipments of radioactive materials were adequately trained. The
licensee effectively characterized and classified radioactive waste and properly
prepared radioactive material for safe transport (Section R1 .1 ).
The licensee's water chemistry control program for monitoring primary and secondary
water quality had been implemented in accordance with the Technical Specification
requirements and industry guidelines for PWR water chemistry (Section R1 .2).
The licensee's contamination control practices were consistent with the requirements of
the Radiation Protection Program manual and were effective in minimizing the spread of
contamination (Section R1 .3).
Radiological surveys and controls for work to resolve an Independent Spent Fuel
Storage Installation cask low differential pressure alarm were sufficiently comprehensive
to control worker radiation exposure (Section R1 .4)-
Training was provided to Radiation Protection and Chemistry personnel in accordance
with the descriptions delineated in the licensee's Radiation Protection, Chemistry;*and
Nuclear Training manuals (Section R4.1 ).
Audits in the areas of chemistry, radiological controls, and transportation were of
sufficient scope and depth to identify potential problems. Corrective actions for
identified issues were documented and tracked for completion of warranted follow-up.
The licensee complied with the program requirements for conducting audits of those
activities (Section R7.1 ).
A Non-Cited Violation was identified for the failure to terminate a contractor employee's
protected area access after access authorization was no longer required. The station
badge coordinator failed to deactivate the contractor's badge and a subsequent
verification failed to identify the discrepancy (Section S1 .1 ).
Material, package, and vehicle access controls for items entering the protected and vital
areas met the criteria of the current Physical Security Plan and appropriate security
procedures. The vehicle barrier system was functional, well maintained, and effective in
its intended purpose. The licensee's vehicle barrier system met the Physical Security
Plan commitments and regulatory requirements and was considered a strength in the
security program (Sections S1 .2 and S2.1).
The licensee's security procedures were thorough, well documented, and consistent
with the Physical Security Plan commitments and 1 O CFR Part 50.54 (Section S3.1 ) .
3
The inspector concluded through observation and interviews of security force personnel,
and reviews of procedures that the security force had the requisite knowledge to cope
with the design-basis threat described in 10 CFR 73.1 (a) and the Physical Security *Plan
(Section S4.1 ).
The inspector verified that response capabilities of the security organization to security
threats, contingencies, and routine response situations were consistent with the security
procedures, the Physical Security Plan and Security Contingency Plan. The total
number of trained security officers and armed personnel immediately available to fulfill
response requirements met the number specified in the Physical Security Plan (Sections
S4.2 and S6.1 ) .
Report Details
Summary of Plant Status
Unit 1 operated at power for the entire reporting period. On December 12, Unit 1 pressurizer
power operated relief valve (PORV), 1-RC-PCV-1456, was returned to an operable status when
its associated block valve was opened. The PORV's tailpipe temperatures remained stable
during the rest of the reporting period.
Unit 2 operated at power the entire reporting period.
01
01.1
01.2
a.
b.
I. Operations
Conduct of Operations
General Comments (71707, 40500)
The inspectors conducted frequent control room tours to verify proper staffing, operator
attentiveness, and adherence to approved procedures. The inspectors attended daily
plant status meetings to maintain awareness of overall facility operations and reviewed
operator logs to verify operational safety and compliance with Technical Specifications
(TS). 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.
Independent Spent Fuel Storage Installation (ISFSI) Cask LowPressure Alarm
Inspection Scope (71707)
The inspectors reviewed the licensee's actions associated with a low pressure alarm on
a cask stored at the ISFSI.
Observations and Findings
On December 24, 1998, a low pressure alarm was received on ISFSI cask 15. The
alarm came in following a momentary loss of power at the ISFSI facility caused by
severe weather and would not clear when the operator subsequently tried to reset the
alarm. Cask 15 is a Westinghouse MC-1 O cask and was loaded in November 1991.
The Westinghouse MC-1 O cask low pressure switch measures the pressure differential
between the fuel storage area of the cask and a secondary plenum adjacent to the fuel
storage portion. The fuel storage area is pressurized slightly above atmospheric
pressure with helium and the plenum area is evacuated to an absolute pressure of less
than 5 mbars (subatmospheric). A low differential pressure alarm indicates either
leakage of helium from the fuel storage portion of the cask or in-leakage of air into the
secondary plenum. A leak in the fuel storage portion would require that the cask be
returned to the spent fuel pool to resolve the leakage. The licensee determined that the
secondary plenum had pressurized to approximately 267 mbars resulting in the alarm.
2
The licensee obtained gas samples from the secondary plenum and determined that the
leakage was into the secondary plenum from the atmosphere. The licensee performed
a leak check on the secondary plenum and evacuated the secondary plenum to 1 mbar.
The leak check determined that the integrity of the secondary plenum was intact,
however, the leakage value calculated was slightly higher than the initial leakage value
recorded during initial loading of the cask. The low differential pressure alarm cleared
following the reestablishment of the secondary plenum vacuum.
The inspectors monitored licensee actions to determine the cause of the low pressure
alarm, observed initial troubleshooting work activities and reviewed the cask design
.characteristics with respect to the operation of the pressure switch. The inspectors
determined that the integrity of the fuel storage portion of the cask was intact and that
licensee actions adequately returned the low pressure alarm function to service. The
inspectors noted that the low differential pressure alarm was not expeditiously
addressed by the licensee. The initial alarm was received on December 24, 1998, and
actions to determine the cause of the alarm were not initiated until December 30, 1998.
The corrective actions to return the alarm function to service were not completed until
January 6, 1999. The inspectors discussed this item with licensee management and
identified it as a negative observation.
c.
Conclusions
Licensee actions to resolve a low pressure alarm on a spent fuel storage cask
demonstrated that cask integrity was intact and adequately returned the alarm function
to service. A negative observation was identified in that the licensee did not
expeditiously address the low pressure alarm.
08
Miscellaneous Operations Issues (92700, 92901)
08.1
(Closed) Licensee Event Report (LER) 50-280, 281/97003-00: Loss of pressurizer
heaters results in manual Unit 1 trip and Unit 2 ESF actuation. This LER described a
Unit 1 reactor trip caused by an inability to maintain reactor coolant system pressure due
to a loss of pressurizer proportional heater Group C. The LER also described an
automatic actuation of the Unit 2 motor driven auxiliary feedwater pumps following the
Unit 1 trip due to load shed of selected station service loads. This everit was discussed
in NRC Inspection Report 280, 281/97-02. The inspectors reviewed the reactor trip
report, the associated Root Cause Evaluation and verified that the corrective actions
identified in the licensee's commitment tracking system had been accomplished.
08.2
(Closed) LER 50-280/97005-00: Unit 1 power range nuclear instrumentation inoperable
due to personnel error. This matter was discussed in detail in NRC Inspection Report
50-280, 281/97-04 and resulted in the issuance of .NCV 50-280/97004-01. The
inspectors reviewed the corrective actions delineated in the subject LER and determined
that adequate measures had been taken by the licensee to prevent recurrence.
3
08.3
(Closed) LER 50-280, 281/97008-00: Invalid actuation of engineered safety features
due to personnel errors. This matter was discussed in detail in NRC Inspection Report
50-280, 281/97-10 and resulted in the issuance of violation (VIO) 50-281/97010-05. The
closure of VIO 50-281/97010-05 is discussed in Section 08.4. The inspectors reviewed
the corrective actions delineated in the subject LER and determined that adequate
measures had been taken by the licensee to prevent recurrence.
08.4
(Closed) VIO 50-281/97010-05:. Inadequate work instructions resulted in the failure to
implement the requirements of a safety evaluation. The licensee reported the events
associated with the violation in LER 50-280, 281/97008-00. The closure of LER 50-280,
281/97008-00 is discussed in Section 08.3. The inspectors reviewed the licensee's
response to the violation dated January 14, 1998. The inspectors reviewed the
corrective actions delineated in the violation response and verified that the corrective
actions were fully implemented.
II. Maintenance
M1
Conduct of Maintenance
M1 .1
Number 2 Emergency Diesel Generator (EDG) Excitation Cabinet Inspection
a.
Inspection Scope (62707)
The inspectors observed the performance of procedure O-ECM-0704-04.
b.
Observations and Findings
On December 13, 1998, the inspectors observed work activities associated with Work
Order (WO) 00400172, Inspect EDG 2 Remote Excitation Cabinet. The work activity
was accomplished in accordance with procedure O-ECM-0704-04, "EDG. Remote
Excitation Cabinet Inspection," Revision 0. The inspection was initiated as a result of a
catastrophic component failure in the Number 3 EDG excitation cabinet during a routine
monthly surveillance. The inspection did not identify any obvious discrepancies in the
Number 2 EDG excitation cabinet components. The inspection was thorough and
accomplished in accordance with the procedural requirements. The results of the
followup inspection of the Number 1 EDG are documented in NRC Inspection Report
50-280, 281/98-09. The inspection of the Number 2 EDG excitation cabinet completed
visual inspections of the EDG excitation cabinets following the component failure in the
Number 3 EDG excitation cabinet.
c.
Conclusions
The Number 2 EDG excitation cabinet inspection was thorough and conducted in
accordance with the procedural requirements. No deficiencies were noted during the
inspection. The licensee has completed visual inspections of the EDG excitation
cabinets initiated in response to a catastrophic component failure in the Number 3 EDG
excitation cabinet.
4
M1 .2
Low Head Safety Injection (LHSI) Recirculation Flow Test
a.
Inspection Scope (61726)
The inspectors observed a quarterly performance test of the Unit 1 LHSI pumps.
b.
Observations and Findings
The inspectors observed a recirculation flow test of the Unit 1 LHSI pumps in
accordance with procedure 1-0PT-Sl-005, "LHSI Pump Test," Revision 9. The test
adequately checked the flow characteristics of the LHSI pumps and measured the
system leakage with the pumps operating. Proper radiological control methods were
used to collect the liquid released during system venting and to minimize the spread of
contamination during the test. The pre-job briefing was complete and the work was
performed in accordance with approved procedures. There was no preconditioning of
the system prior to the testing. The test results indicated that the LHSI pumps were
operating properly.
c.
Conclusions
Low Head Safety Injection system recirculation flow testing was performed in
accordance with approved procedures and all test acceptance criteria were met.
M1 .3
Unit 2 Flux Measurement
a.
Inspection Scope (61726)
The inspectors observed the measurement of Unit 2 incore power levels.
b.
Observations and Findings
The inspectors observed the plant engineers measure the incore neutron flux using
procedure 2-NPT-RX-002, "Flux Maps," Revision 11. The engineers demonstrated
detailed knowledge of the operation and limitations of the flux measurement equipment,
as well as knowledge of the effects of the testing on plant operation. Although several
flux thimble tubes are blocked or otherwise out of service, an adequate number of tubes
are available to measure the power distribution within the core.
c.
Conclusions
The incore flux mapping system was properly used to measure the incore power levels
and adequately demonstrated that the core power distribution met thermal
requirements. The engineers demonstrated detailed knowledge of the operation and
limitations of the flux measurement equipment and the effects of the testing on plant
operation .
5
M1 .4
Number 2 EDG Standby Lube Oil Temperature Concern
a.
Inspection Scope (62707)
The inspectors reviewed the licensee's efforts in troubleshooting the decrease in the
standby lube oil temperature for the Number 2 EDG.
b.
Observations and Findings
One of the functions of the EDG auxiliary lubricating oil system is to maintain lube oil
temperature at approximately 130°F while in the standby condition in order to prevent
engine damage upon receipt of a fast start signal. This function is performed by
constantly circulating lube oil through a heat exchanger via an auxiliary lube oil pump. If
the lube oil temperature decreases below 95°F, the EDG is considered to be inoperable.
On November 25, 1998, the lube oil temperature on the Number 2 EDG, with the engine
in the normal standby readiness condition, was noted to have decreased to
approximately 102°F. To alleviate the concern with low lube oil temperature, the engine
was started. Following a normal engine run and cooldown period, the lube oil
temperature returned to its normal standby temperature of approximately 130°F. The
cause of the decreasing lube oil temperature was not identified.
The phenomena of decreasing lube oil temperature was observed on at least two more
occasions in December. In each case, the engine was started and run to raise the lube
oil temperature to a standby readiness condition. On January 10, 1999, the licensee
removed the Number 2 EDG from service to perform troubleshooting activities on the
auxiliary lube oil system as recommended by the EDG's vendor and plant engineering.
Oil flows were checked and found to be satisfactory. The auxiliary lube oil pump
discharge check valve and strainer were replaced, however, the removed components
were found to be in satisfactory condition. The engine was returned to service with no
definitive corrective action performed. The inspectors reviewed the maintenan~e
performed and monitored the licensee's progress in resolving the lube oil temperature
condition. The licensee has continued to pursue identification and resolution of the
cause of the lube oil temperature decrease. The inspectors have noted that operating
shift personnel have displayed an appropriate level of sensitivity to the lube oil
temperature issue.
c.
Conclusions
The licensee has taken action to resolve a problem with decreasing lube oil
temperatures for the Number 2 EDG while in a standby condition. However, these
actions have not been successful and the licensee has periodically run the diesel to
increase lube oil temperatures to the normal level tor standby conditions. The
inspectors have noted that operating shift personnel have displayed an appropriate level
of sensitivity to the lube oil temperature issue.
. .
.*
6
MS
Miscellaneous Maintenance Issues (92700, 92902)
M8.1
(Closed) LER 50-280/97004-00: Main Steam Safety Valve As-Found Setpoint Out of
Tolerance. This LER was submitted when testing of a Main Steam Safety Valve (1-MS-
SV-104C) during a refueling outage revealed that the lift setting was 3.7% above its
nominal value. Technical Specifications allow a tolerance of +/-3% for the as-found
setpoint. This failure was attributed to setpoint drift and was not considered to be
maintenance preventable. The inspectors reviewed the LER and the proposed
corrective actions and found them adequate.
M8.2
{Closed) VIO 50-280/97004-02: Failure to follow maintenance procedures associated
with the Number 1 EDG. Contrary to procedural requirements, the licensee used an
ohmmeter/multimeter in place of an oscilloscope during performance of EDG relay
checks conducted per Electrical Corrective Maintenance Procedure O-ECM-0704-01,
"EDG Start and Shutdown Circuit Relay Adjustment and Replacement." The inspectors
reviewed the licensee's response letter, dated July 29, 1997, and verified that corrective
actions were adequate and appropriately implemented.
Ill. Engineering
E1
Conduct of Engineering
E1 .1
a.
Inspection Scope (37551)
The inspectors reviewed the Unit 1 and Unit 2 Temporary Modification logs.
b.
Observations and Findings
On January 15, 1999, the inspectors reviewed the Unit 1 and Unit 2 TM logs. Unit 1 had
one active TM. The TM was installed to allow removal of an isolation manifold
associated with main steam flow transmitter 1-MS-FT-1475. Blockage in the manifold
prevented proper operation of the flow instrument. The TM was implemented to return
the instrument to service. The associated safety evaluation adequately justified
implementation of the TM.
Unit 2 had three active TMs installed. Two of the TMs are installed on non-safety
related systems. The one safety related TM installed a passive catalytic hydrogen
recombiner in the Unit 2 containment to reduce an increased containment hydrogen
concentration due to leakage past the pressurizer vent valves. The events leading to
the installation of the recombiner in Unit 2 were previously discussed in NRC Inspection
Report 50-280, 281/98-05. The hydrogen recombiner installed in Unit 2 had been
previously installed in Unit 1 following the May, 1997, refueling outage. The inspectors
evaluated installation of the passive catalytic hydrogen recombiner in Unit 1 in NRC
Inspection Report 50-280, 281/97-07 .
7
c.
Conclusions
The number of temporary modifications installed on Units 1 and 2 were minimal and
were adequately justified by the associated safety evaluations.
EB
Miscellaneous Engineering Issues (92700)
E8.1
(Closed) LER 50-280, 281/98003-00: No procedural guidance for maintaining EDG
minimum fuel supply during LOOP. This LER described a condition where the Number
3 EDG would not have the required available fuel oil supply specified in the design basis
due to any procedural controls to reestablish power to a de-energized electrical bus
supplying a fuel oil transfer pump following a loss of offsite power (LOOP). The licensee
revised the emergency operating procedures to re-energize the electrical bus following a
loss of power to maintain the design basis fuel oil supply. The licensee plans to modify
the electrical power supply to the fuel oil transfer pumps such that power is automatically
restored to the pumps following a loss of offsite power. The inspectors verified that the
emergency operating procedures had been revised and verified that the planned
modification to the fuel oil transfer pump electrical power supply was being tracked in
the licensee commitment tracking system.
IV. Plant Support
R1
Radiological Protection and Chemistry (RP&C) Controls (71750)
On numerous occasions during the inspection period, the inspectors reviewed
radiological protection practices. Radiological postings observed by the inspectors were
in accordance with NRC regulations. Personnel within the radiologically controlled area
were observed to be following the licensee's procedures for radiological protection.
Copies of the current revision of NRC Form 3, "Notice to Employees," were posted in
designated areas as required by 10 CFR 19.11 (c)(1 ). No radiological control
discrepancies were noted.
R1 .1
Transportation of Radioactive Materials
a.
Inspection Scope (86750)
The inspectors reviewed the licensee's program for transportation of radioactive
materials to determine whether the licensee processes, packages, stores, and ships
radioactive materials in accordance with Department of Transportation (DOT) and NRC
regulations. The review included personnel training records, observation of a
radioactive material shipment, facility tours and shipping papers. The program was
evaluated for consistency with the requirements delineated in 49 CFR Parts 170 - 179,
10 CFR Part 20, 10 CFR Part 61 and 10 CFR Part 71 .
8
b.
Observations and Findings
The inspectors reviewed the training records for the three individuals authorized to
certify that radioactive material and radwaste shipments meet DOT and NRC
requirements. The inspectors also reviewed training records of three technicians that
had performed packaging and radiological shipment surveys, and one individual that
verified transport vehicle suitability. The inspectors determined that the training records
were complete and that the DOT requirement for retraining every three years was being
met.
The inspectors toured the Surry Radwaste Facility (SRF) and the low level radwaste
storage area and determined that radioactive material containers were properly labeled
in accordance with NRC requirements.
The inspectors observed the preparation of the paperwork for shipment SH-1999-02.
The shipment was properly classified as a DOT Limited Quantity using the RADMAN
computer program and packaged in excepted packaging certified to meet the DOT
general design criteria for packages (49 CFR Part 173.410). The inspectors reviewed
the licensee's shipment log for 1998 and selected ten of the eighty-six radioactive
material shipments made during the period for further review. This selection included
shipments classified as Waste Type A, Waste Type C, Low Specific Activity (LSA),
Surface Contaminated Objects (SCO) and Limited Quantity. The inspectors verified for
the shipments utilizing NRC Licensed Casks that the licensee was an authorized user
and that selected elements of the cask Certificate of Compliance (COC) were being
met. In the review of the COC and the shipping records, the inspectors noted that
shipment number B98~os using cask USA/6601/A and shipment number D98-02 using
cask USA/9249/A did not include documentation that the cask o-ring/gaskets were
replaced at the frequency required by the COCs. The licensee initiated immediate
actions to retrieve this information from the cask owner for the shipments identified and
for all cask shipments made in 1998. Based on information supplied by the cask owner,
the inspectors verified that the cask a-ring/gaskets had been replaced at the required
frequency. The licensee also initiated a deviation report to evaluate COC requirements
and take corrective actions as needed.
The inspectors reviewed the two most recent 1 o CFR 61 analysis reports for the dry
active waste, resin and evaporator bottoms waste streams. The USNRC Low Level
Waste Licensing Branch Technical Position on Waste Classification (May 1983,
Revision 0) states that, "confirmatory analysis for Class A waste should be performed on
at least a bi-annual basis, however these frequencies may be raised or lowered based
upon plant specifics." The inspectors noted that the confirmatory analysis frequency for
the evaporator bottoms, a class A waste stream, exceeded the recommended bi-annual
- frequency from approximately late January 1997 to early April 1997. Two shipments of
evaporator bottoms were made during this period. The licensee provided
documentation of the more conservative methodology used, which included the data of
a more conservative waste stream used for the shipment, approval from the waste
processor that received and held the shipment until updated sample analys.es were
performed, and revised the manifest using updated samples. Based on plant specifics,
the inspectors determined that the licensee's justification of the confirmatory analysis
frequency and classification of the shipments as waste class A was acceptable. The
..
9
inspectors also determined that the revised manifest total radioactivity was less than the
original manifested shipment.
c.
Conclusions
The licensee effectively implemented a program for transportation of radioactive
materials pursuant to DOT and NRC regulations. Individuals involved in preparing
shipments of radioactive materials were adequately trained. The licensee effectively
characterized and classified radioactive waste and properly prepared radioactive
material for safe transport.
R1 .2
Water Chemistry Controls
a.
Inspection Scope (84750)
The inspectors reviewed implementation of selected elements of the licensee's water
chemistry control program for monitoring primary and secondary water quality. The
review included examination of program guidance and implementing procedures, and
analytical results for selected chemistry parameters. Procedures and data were
compared to the requirements in Technical Specifications (TS) 3.1.D, 3.1.F and 4.1.C
for monitoring specific primary coolant chemistry parameters arid to the programmatic
requirements, delineated in License Condition 3.K, for monitoring secondary water
chemistry.
b.
Observations and Findings
The inspectors reviewed Virginia Power Administrative Procedure (VPAP) 2201,
"Nuclear Plant Chemistry Program," Revision No. 3, and determined that it included
provisions for sampling and analyzing reactor coolant at the prescribed frequency for the
parameters required to be monitored by the TSs. The procedure also included
provisions for monitoring primary and secondary water quality based on established
industry guidelines and standards, which included the Electric Power Research Institute
(EPRI) guidelines for PWR primary and secondary water chemistry. The inspectors
noted that VPAP-2201 listed the sampling frequency and typical values for each
parameter to be monitored. Action levels applicable to various operational modes were
given where appropriate. Guidance was also provided for actions to be taken if
analytical results exceeded prescribed limits. The inspectors determined that the above
guidance and procedures were consistent with the applicable TS requirements and, with
a few minor plant specific exceptions, the EPRI guidelines.
The inspectors also reviewed records of analytical results for selected parameters
generated during the period September 1998 through mid-January 1999. The
parameters selected included dissolved oxygen, chloride, fluoride, and dose equivalent
iodine-131 in reactor coolant; iron and hydrazine in feedwater; sodium in steam
generator blowdown; and dissolved oxygen in condensate. Those parameters were
maintained well within the relevant TS limits and within the EPRI guidelines for power
operations.
10
The inspectors noted that an intrusion of sodium and chloride into the Unit 1 feedwater
system occurred on November 20, 1998, during the unit startup from the refueling
outage. The licensee initiated an investigation of that event and determined that the
intrusion was caused by condenser tube leakage. The source of the leakage was 13
tubes with missing end plugs. The licensee determined that this condition was caused
by inadequate maintenance practices during the outage in that verification that the tubes
were plugged on both ends was not performed. The inspectors determined that the
chemistry control program functioned as intended by promptly detecting the impurity
intrusion and reestablishing secondary water quality following repairs to correct the
inadequate maintenance. practices.
c.
Conclusions
The licensee's water chemistry control program for monitoring primary and secondary
water quality had been implemented in accordance with the TS requirements and
industry guidelines for PWR water chemistry.
R1 .3
Contamination Control
a.
Inspection Scope (83750)
The inspectors reviewed implementation of selected elements of the licensee's
contamination control program. The review included examination of records for
personnel contamination events and independent contamination surveys in areas
adjacent to the entrance to the Radiologically Controlled Area {RCA). The licensee's
contamination control practices were evaluated for consistency with the programmatic
requirements specified in section 6.6 of the Radiation Protection Program manual
{VPAP 2101 ).
b.
Observations and Findings
The inspectors reviewed the licensee's procedures for follow-up actions to Personnel
Contamination Events {PCEs) and reviewed selected records for those events.
Procedure HP-1061.020, "Personnel Contamination 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 measured by a hand-
held frisker. The licensee's records indicated that 104 PCEs occurred during the fourth
quarter of 1998, and that 28 bioassays were performed to evaluate possible intakes of
radioactive material. Dose history records for four individuals who had bioassays during
that period were also reviewed by the inspectors. Those records indicated that the
selected individuals did not receive intakes greater than the threshold for assigning
internal dose, i.e., three tenths of one percent of the Annual Limit on Intake (ALI).
The inspectors also reviewed records for contamination surveys performed *in the areas
adjacent to the entrance to the RCA during January 1 - 14, 1999. Daily survey results
from large area smears of those areas indicated that the loose surface beta-gamma
activity was less than 1000 dpm/ ft2. At the inspector's request, a licensee Health
Physics Technician performed contamination surveys in the Men's Clean Change
Locker Room. A large area smear was taken in approximately 20 randomly selected
11
lockers and general area smears were taken in three randomly selected individual
lockers. The inspectors verified, by observing the survey instrument readings, that the
loose surface beta-gamma activity was less than 1000 dpm/100 cm2* Based on the
review of the licensee's records for contamination surveys performed in the areas
adjacent to the entrance to the RCA and the independent contamination surveys
performed by the licensee of the lockers in the men's change room, the inspectors
concluded that the licensee had maintained adequate contamination control around the
entrance to the RCA.
c.
Conclusions
The licensee's contamination control practices were consistent with the requirements of
the Radiation Protection Program manual and were effective in minimizing the spread of
contamination.
R1 .4
Spent Fuel Cask Surveys
a.
Inspection Scope (83750)
The inspectors reviewed the radiological survey records and Radiation Work Permits
(RWP) for work on cask MC-10 located at the Independent Spent Fuel Storage
Installation (ISFSI) facility to determine the adequacy of the work controls. Work
performed at the facility was in response to a cask differential pressure alarm that
occurred on December 24, 1998.
b.
Observations and Findings
Work to determine the cause of the alarm began on December 30, 1998, and used
RWP 98-2-1020, Revision 0. Work extended into the beginning of calendar 1999 and
used RWP 99-2-1010. Both RWPs were primarily focused on activities associated with
loading and transporting the cask to the ISFSI. Although not written to cover the
specific tasks performed at the ISFSI, both RWPs contained sufficient instructions to
control worker radiation exposure during the work performed.
Surveys conducted on December 31, 1998, of the cask external surfaces showed
maximum contact radiation levels of 15 mrem/hour gamma radiation and 14 mrem/hour
neutron radiation. No radiological contamination or airborne activity above background
was detected.
c.
Conclusions
Radiological surveys and controls for work to resolve an ISFSI cask low differential
pressure alarm were sufficiently comprehensive to control worker radiation exposure.
12
R4
Staff Knowledge and Performance in RP&C
R4.1
Training and Qualification of Personnel
a.
Inspection Scope (83750, 84750)
The inspectors reviewed implementation of the licensee's training and qualification
program for Radiation Protection and Chemistry personnel. The review included an
evaluation of the training provided to selected individuals for consistency with the
training program descriptions in the licensee's Radiation Protection Program and Plant
Chemistry Program manuals.
b.
Observations and Findings
As described in the licensee's Radiation Protection and Plant Chemistry program
manuals (VPAPs 2101 and 2201), the training and qualification programs for Health
Physics Technicians and Chemistry Technicians included basic health physics/chemistry
training, on-the-job training, continuing training, and speciality training. The program
was administered by the Nuclear Training Department and implemented through Health
Physics/Chemistry Technician Development Program and Continuing Training Manuals.
The inspectors reviewed the training records for two randomly selected Health Physics
Technicians and two Chemistry Technicians. Those records included listings of the
fundamental health physics/chemistry courses completed for basic training, prescribed
tasks performed during on-the-job training for qualification to perform specific functions,
and courses attended for continuing training. The inspectors determined that training
had been provided for the selected individuals in accordance with the licensee's
established training program requirements.
c.
Conclusions
Training was provided to Radiation Protection and Chemistry personnel in accordance
with the descriptions delineated in the licensee's Radiation Protection, Chemistry, and
Nuclear Training manuals.
R7
Quality Assurance in RP&C Activities
R7.1
Audits
a.
Inspection Scope (83750, 84750 and 86750)
b.
The inspectors reviewed selected audit reports for adequacy and consistency with
Technical Specifications 6.1.C.2.h and 6.1.C.2.j regarding program areas required to be
audited and audit reporting requirements.
Observations and Findings
The inspectors reviewed Nuclear Oversight Audit Reports 97-06, 97-13, and 98-06
which documented the licensee's most recent audits in the areas of chemistry,
13
radiological protection, effluent monitoring, environmental monitoring, radwaste
processing, and transport of radioactive materials. Those reports delineated the specific
elements of the program areas evaluated and included overall conclusions, based on
audit results, that the programs were being effectively implemented. The inspectors
also reviewed the completed audit checklists which provided extensive documentation of
the supporting details for the audit conclusions. - Substantive issues identified by the
audits were entered into the licensee's corrective action program by issuance of
Deviation* Reports.
c.
Conclusions
Audits in the areas of chemistry, radiological controls, and transportation were of
sufficient scope and depth to identify potential problems. Corrective actions for
identified issues were documented and tracked for completion of warranted follow-up.
The licensee complied with the program requirements for conducting audits of those
activities.
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. The inspectors concluded that security posts were properly manned and the
perimeter barrier's material condition as well as the isolation zones were being properly
maintained. Additionally, proper control of escorted individuals within the protected area
was observed by the inspectors.
S1 .1
Access Authorization Program
a.
Inspection Scope (81700)
The inspectors evaluated the key aspects of the access authorization program (AAP) to
verify that the licensee's AAP was being implemented according to regulatory
requirements and plan commitments.
b.
Observations and Findings
The inspectors reviewed and evaluated LER 50-280, 281/98S01-00. This LER was
reported to NRC on December 4, 1998, and pertained to an August 11, 1998, event. On
June 22, 1998, the licensee received a letter from Freeze Seal Incorporated, a
contractor, indicating that an employee of their company no longer required clearance
for Virginia Electric and Power Company (VEPCO) nuclear facilities. A nuclear access
specialist processed the favorable termination by revoking the individual's clearance in
the Corporate Security Information System (CSIS) database. On June 23, 1998, a Daily
Clearance Processing Report for June 22, 1998, was generated by the CSIS computer
and printed at the Surry Nuclear Station (SNS). This report listed all the clearance
revocations processed on the referenced date, including the contractor employee. To
complete the normal processing of favorable termination requests, the badging
coordinator at the station reviewed the above report on June 23, 1998. Security badges
14
for the individuals listed on the report were deactivated in the access control computer
systems. The station badge coordinator, however, failed to deactivate the badge for the
- contractor employee. Verification of the badge deactivation process was performed on
June 24, 1998, by reviewing a Badge Activation/Deactivation Report generated by the
CSIS computer for work completed on June 23, 1998. The report was compared to
individual badge data sheets which maintain a history on the badge; This verification
was inadequate because no badge data sheets were pulled and edited for the
contractor employee.
On August 11, 1998, the same contractor employee was sent to the station to retrieve
equipment left from a previous job. He verified with the badging coordinator that his
badge was still active and at 11 :49 a.m. entered the protected area (PA). At 11 :59 a.m.,
the same individual exited the PA. On November 4, 1998, a Freeze Seal Incorporated
representative called the licensee to determine the procedure for reestablishing
clearance for this contractor employee. It was discovered during the review for
reinstatement, that the employee's badge was still active in the site access control
computer systems. The badge was deactivated on November 4, 1998. On November
5, 1998, a review was performed on the access history of the contractor employee. The
review determined that the individual entered the PA only once since June 22, 1998. A
deviation report was submitted to document the event. On November 5, 1998, a 1-hour
notification was made according to 10 CFR 73.71(b)(1) due to an actual entry of an
unauthorized person into the PA .
North Anna Power Station, Surry Power Station, Independent Spent Fuel Storage
Installation Physical Security Plan (PSP), Revision 4, Chapter 3, paragraph 3.1.1 (b)
requires that an individual's unescorted access authorization be revoked when no longer
required.
Once the licensee discovered that the contractor employee's badge was active,
- immediate corrective action was taken to remove the badge from the access control
computer systems. A review was conducted to determine if there were other individuals
with active badges but without an access authorization clearance. This reviewed
indicated that this was an isolated event and there were no other individuals with active
badges and revoked clear~nces. The individual who caused this incident was
counseled and retrained. Software improvements in this area were being pursued by
the licensee. The failure to terminate an individual's PA access after access
authorization was no longer required is contrary to the PSP, Chapter 3, paragraph
3.1.1 (b). This non-repetitive, licensee-identified and corrected violation is being treated
as a Non-Cited Violation (NCV), consistent with Section VII.B.1 of the NRC Enforcement
Policy'. This matter is identified as NCV 50-280, 281/98010-01.
c.
Conclusions
A Non-Cited Violation was identified for the failure to terminate a contractor employee's
protected area access after access authorization was no longer required. The station
badge coordinator failed to deactivate the contractor's badge and a subsequent
verification failed to identify the discrepancy.
-~
15
S1 .2
Protected Area Access Control - Vehicles
a.
Inspection Scope (81700)
The inspectors evaluated the licensee's vehicle access control activities to ensure
compliance with Chapters 2, 3, and 9 of the PSP, Security Plan Implementing
Procedure (SPIP) 8, Vehicle/Material Access Control," Revision 3, and regulatory
requirements.
b.
Observations and Findings
The inspectors verified by observation that the licensee had positive access control
measures in place to properly identify, authorize, and search materials, packages, and
vehicles before allowing them to be introduced into the PA. An active land vehicle
barrier system was utilized to control vehicle access to the PA. The vehicle barrier
system (VBS) is discussed in more detail in Section S2.1. Security officers searched
vehicles and their contents entering the PA through the vehicle access portal.
Personnel accompanying the vehicles were processed through the primary access
portal.
c.
Conclusions
Material, package, and vehicle access controls for items entering the protected and vital
areas met the criteria of the current Physical Security Plan and appropriate security
procedures.
S2
Status of Security Facilities and Equipment
S2.1
Vehicle Barrier System
a.
Inspection Scope (81700)
The inspectors evaluated and reviewed Chapter 2 of the PSP and SPIP 13, "Security
Patrols," Revision 6, to ensure that the licensee was complying with the VBS
commitments and 1 O CFR 73.55(c)(7).
b.
Observations and Findings
The inspectors verified by touring the site perimeter that the VBS was in place and
functioning according to the PSP and SPIP. The licensee continued to use a
combination of double surface mounted anchored jersey barriers filledwith rock,
bollards, buildings, intake and discharge canals and natural barriers as part of the
barrier system. The licensee used both active embassy style gates and passive gate
barriers. The inspectors reviewed quarterly and annual inspection records of the VBS
and found that the licensee was complying with various testing and maintenance
commitments. The VBS was well planned and substantial in construction.
.*
16
_ c.
Conclusions
The vehicle barrier system was functional, well maintained, and effective in its intended
purpose. The licensee's vehicle barrier system met the Physical Security Plan
commitments and regulatory requirements and was considered a strength in the security
program.
S3
Security and Safeguards Procedures and Documentation
S3.1
Security Procedures
a.
Inspection Scope (81700)
The inspectors evaluated a sample of implementing procedures to ensure that the
procedures were consistent with PSP commitments in Chapters 1 and 9 and to
determine their adequacy and compliance with*10 CFR Part 50.54.
b.
Observations and Findings
The inspectors reviewed three site security procedures, one Virginia Power
Administrative Procedure and related supporting records and reports. The inspectors
also interviewed security force personnel to determine their familiarity with these
documents. The procedures reviewed pertained to format, content, and requirements
for the PSP, authorized personnel access control, vehicle/material access control, and
security and access control. The reviewed documents were consistent with plan
commitments.
c.
Conclusions
The licensee's security procedures were thorough, well documented, and consistent
with the Physical Security Plan commitments and 1 O CFR Part 50.54.
S4
Security and Safeguards Staff Knowledge and Performance
S4.1
Security Force.Requisite Knowledge
a.
Inspection Scope (81700)
The inspectors interviewed and observed security personnel to determine if they
possessed adequate knowledge to carry out their assigned duties and responsibilities,
including response procedures, use of deadly force, and armed response tactics as
committed to in Chapters 1 and 12 of the PSP.
b.
Observations and Findings
The inspector interviewed approximately 15 security personnel, including supervisors,
and witnessed approximately 1 O others in the performance of their duties. Members of
., **
17
the security force were knowledgeable in their duties and responsibilities, response
commitments and procedures, and armed response tactics. The inspector found that
armed response personnel had been instructed in the use of deadly force as required by
c.
Conclusions
The inspector concluded through observation and interviews of security force personnel,
and reviews of procedures that the security force had the requisite knowledge to cope
with the design-basis threat described in 1 O CFR 73.1 (a) and the Physical Security Plan.
S4.2
Response Capabilities
a.
Inspection Scope (81700)
The inspectors evaluated responses by the security organization to security threats,
contingencies, and routine response situations, including drills, against security
procedures and Chapters 1 and 12 of the PSP and Safeguards Contingency Plan
(SCP).
b.
Observations and Findings
The inspector evaluated the tactical equipment prepositioned within the PA to verify that
tactical equipment commitments were implemented. Tactical response personnel were
also interviewed to ascertain their familiarity with the prepositioned equipment.
Response personnel were familiar with their duties and the locations of the response
equipment, as well as the type and quantity of items at the locations. Response
personnel were familiar with the 24 event response conditions listed in the contingency
plan. Response personnel knew the shift chain of command during a tactical response.
The number of tactical responders available on each shift met the plan commitments.
c.
Conclusions
The inspector verified that response capabilities of the security organization to security
threats, contingencies, and routine response situations were consistent with the security
procedures, the Physical Security Plan and Security Contingency Plan.
56
Security Organization and Administration
S6.1
Staffing Level
a.
Inspection Scope {81700)
The inspectors reviewed the staffing of trained security officers and armed personnel
that would be immediately available at the facility to fulfill response requirements.
18
b.
Observations and Findings
The licensee had an onsite physical protection system and security organization. The
security organization and physical protection systems were designed to protect against
the design basis threat of radiological sabotage as stated in 1 O CFR 73.1 (a). At least
one full-time manager of the security organization was always onsite and had no duties
that conflicted with the assignment to direct activities during an incident. This individual
- had the authority to direct the physical protection activities of the organization. The four
shifts had the number of trained security officers and armed personnel immediately
available to fulfill response requirements and commitments of the PSP.
c.
Conclusions
The total number of trained security officers and armed personnel immediately available
to fulfill response requirements met the number specified in the Physical Security Plan.
One full-time member of the security organization who has the authority to direct
security activities did not have duties that conflicted with the assignment to direct
activities during an incident.
SS.
Miscellaneous Security and Safeguards Issues
S8.1
(Closed) Inspection Follow-up Item (IFI) 50-280, 281/98006-02: Security Uninterrupted
Power Supply (UPS) inverter was out of service and due to be replaced by December
31, 1998. The inspectors reviewed and evaluated licensees documented actions to
update the security UPS. New automatic transfer switches, a battery charger, an
inverter, static switches, and a bypass transformer were installed and made operational
on October 12, 1998. The new UPS had been satisfactorily tested twice since it was
returned to service.
S8.2
(Closed) LER 50-280, 281/98S01-00: Failure to terminate access results in
unauthorized protected area entry. The review of the subject LER is discussed in
Section S1 .1. This LER is closed.
V. Management Meetings
X1
Exit Meeting Summary
The inspectors presented the inspection results to. members of licensee management at the
conclusion of the inspection on January 26, 1999. Prior to this exit meeting, the inspectors
presented the preliminary results of the radiological protection inspection to members of
licensee management on January 15, 1999. The inspectors also presented the results of the
security inspection during a pre-exit meeting on December 11, 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, Operations & Maintenance
M. Crist, Superintendent, Operations
E. Collins, Director, Nuclear Oversight
J. Grau, Acting Superintendent, Training
E. Grecheck, Site Vice President
C. Luffman, Security Manager
R. Savedge, Security Supervisor
T. Sowers, Manager, Nuclear Safety & Licensing
B. Stanley, Supervisor, Licensing
W. Thornton, Superintendent, Radiological Protection
Opened
INSPECTION PROCEDURES USED
Onsite Engineering
Effectiveness of Licensee Controls in Identifying, Resolving, and Preventing
Problems
Surveillance Observation
Maintenance Observation
Plant Operations
Plant Support Activities
Physical Security Program for Power Reactors
Occupational Radiation Exposure
Radioactive Waste Treatment, and Effluent and Environmental Monitoring
Solid Radioactive Waste Management and Transportation of Radioactive
Materials
Onsite Followup of Written Reports of Nonroutine Events at Power Reactor
Facilities
Followup - Plant Operations
Followup - Maintenance
ITEMS OPENED, CLOSED, AND DISCUSSED
50-280, 281/98010-01
Failure to revoke an individual's unescorted
access authorization when no longer
required (Section S1 .1 ).
-
- - - -
-f ..
.~,-
.t'
20
Closed
50-280, 281/97003-00
LER
Loss of pressurizer heaters results in
manual Unit 1 trip and Unit 2 ESF actuation
(Section 08.1 ).
50-280/97005-00
LER
Unit 1 Power range nuclear instrumentation
inoperable due to personnel error (Section
08.2).
50-280, 281/97008-00
LER
Invalid actuation of engineered safety
features due to personnel errors (Section
08.3).
50-281/97010-05
Inadequate work instructions results in the
failure to implement the requirements of a
safety evaluation (Section 08.4).
50-280/97004-00
LER
Main steam safety valve as found setpoint
out of tolerance (Section M8.1 ).
50-280/97004-02
Failure to follow maintenance procedures
associated with the Number 1 EDG (Section
M8.2).
50-280, 281/98003-00
LER
No procedural guidance for maintaining
EDG minimum fuel supply during LOOP
(Section E8.1).
50-280, 281/98006-02
IFI
Security UPS inverter was out of service
and due to be replaced by December 31,
1998 (Section S8.1 ).
50-280, 281/98010-01
Failure to revoke an individual's unescorted
access authorization when no longer
required*(Section S1 .1 ).
50-280, 281/98S01-00
LER
Failure to terminate access results in
unauthorized protected area entry (Section
S8.2).