ML18152A137

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Insp Repts 50-280/99-01 & 50-281/99-01 on 990117-0227.Three Violations Noted & Being Treated as Noncited Violations. Major Areas Inspected:Operations,Maint,Engineering & Plant Support
ML18152A137
Person / Time
Site: Surry  Dominion icon.png
Issue date: 03/29/1999
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML18152A138 List:
References
50-280-99-01, 50-280-99-1, 50-281-99-01, 50-281-99-1, NUDOCS 9904150277
Download: ML18152A137 (25)


See also: IR 05000280/1999001

Text

Docket Nos.:

License Nos.:

Report No.:

Licensee:

Facility:

Location:

Dates:

Inspectors:

Approved by:

9904150277 90950030029280

PDR

ADOCK

Q

PDR

U.S. NUCLEAR REGULATORY COMMISSION

REGION II

50-280, 50-281

DPR-32, DPR-37

50-280/99-01, 50-281/99-01

Virginia Electric and Power Company (VEPCO)

Surry Power Station, Units 1 & 2

5850 Hog Island Road

Surry, VA 23883

January 17, 1999 - February 27, 1999

R. Musser, Senior Resident Inspector

K. Poertner, Resident Inspector

G. McCoy, Resident Inspector (In Training)

P. Fillion, Reactor Inspector (Sections E8.1 - E8.8)

W. Stansberry, Security Specialist (Sections S1 .5, S2.8, S3.3,

S5.1, S6.1, S7.1, S7.2, S7.3 and S7.4)

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. 50-280/99-01, 50-281/99-01

This integrated inspection included aspects of licensee operations, engineering, maintenance,

and plant support. The report covers a six-week period of resident inspection; in addition, it

includes the results of announced inspections by a regional security specialist and reactor

inspector.

Operations

Operators actions to reduce power following a steam generator chemistry excursion

resulting from loss of the condensate polishers were appropriate and met the licensee

administrative requirements associated with steam generator chemistry. Degraded

condenser hotwell chemistry due to. inleakage from the circulating water system caused

the chemistry excursion when the condensate polishers were isolated (Section 01.2).

The diesel fuel oil system was properly aligned and material condition was adequate

(Section 02.1 ).

A tagging record for maintenance on the Number 2 emergency diesel generator was

properly prepared, authorized, and implemented (Section 02.2) .

Inspectors observed operator simulator requalification training for an operating crew .

The scenario was challenging and operator performance and communications during

the exercise were exemplary (Section 05).

Maintenance

Turbine driven auxiliary feedwater pump maintenance and testing activities were

observed to be properly performed and documented. All test acceptance criteria were

met (Sections M1 .1 and M1 .2).

Corrective maintenance on the outside recirculation spray su*ction valve was performed

properly and the decision not to perform local leakrate testing after repairs was valid

(Section M1 .3).

Engineering

By completing the spent fuel pool power upgrade modification, the licensee has satisfied

all commitments associated with issues related to spent fuel pool decay heat removal

reliability and the maintenance of adequate coolant inventory in the spent fuel pool

(Section E1 .1 ).

A non-cited violation was identified for failing to provide the main control room with an

up-to-date copy of an abnormal operating procedure (AOP) relating to a loss of power

condition affecting Unit 1. The AOP was revised following a modification to the Spent

Fuel Pool Cooling pump power supplies (Section E1 .1 ).

2

Two examples of a non-cited violation were identified for inadequate design controls. In

the first example, the design reviews for Unit 2 low head safety injection pump minimum

flow requirements were inadequate. The second example involved a calculation for

Number 3 emergency diesel generator battery not recognizing a transfer switch that

allowed additional loads on the battery (Sections E8.1 and E8.4).

A non-cited violation of 1 OCFR 50.59 was identified for a 1988 modification to increase

the capacity of the 125 VDC distribution system batteries and a procedure which

allowed the interconnection of two batteries via a DC tie breaker. This condition

involved an unreviewed safety question and therefore was not allowed under 1 O CFR

50.59 (Section E8.5).

Plant Support

A primary coolant sample was properly drawn and analyzed. Proper radiological

practices were used by the technician performing the evolution (Section R1 .1 ).

A Fitness For Duty program 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> NRC notification was implemented according to

procedural commitments and regulatory requirements (Section S1 .5).

The security equipment at the Independent Spent Fuel Storage Installation was found

operational and performing as intended (Section S2.8) .

Safeguards events were logged, tracked, trended, analyzed, and resolved according to

the Physical Security Plan commitments (Section S3.3).

The security force was effectively trained and requalified according to the Training and

Qualification Plan and regulatory requirements (Section S5.1 ).

Site and security management provided support to the physical security program and

was effective in administrating the security program. Management controls of the

security program were aggressive, effective, and comprehensive (Sections S6.1 and

S7.4).

The Nuclear Oversight audits and Self-Assessment audits were thorough, complete,

and effective in uncovering weaknesses in the security system, procedures, and

practices. The audit and self assessment program was a strength to the security

program (Section S7.1 ).

The licensee assigned and analyzed problems properly so that logical conclusions could

be reached. Corrective actions were appropriately prioritized. Problem analysis was a

strength of the security program. The corrective action program was technically sound,

effective, and performed actions in a timely manner (Sections S7.2 and S7.3) .

Report Details

Summary of Plant Status

Unit 1 and Unit 2 operated at power the entire reporting period. On February 4 while Unit 2 was

at reduced power for turbine valve testing, a power reduction was started due to a secondary

water chemistry excursion. Power was stabilized at 88 percent once the chemistry parameters

improved. Power was returned to 100 percent later that day. Unit 2 began its end of cycle

power coast down on February 24. A Unit 2 refueling outage is scheduled to commence on

April 18, 1999.

I. Operations

01

Conduct of Operations

01.1

General Comments (71707)

The inspectors conducted frequent control room tours to verify proper staffing, operator

attentiveness, and adherence to approved procedures. The inspectors attended daily

plant status meetings to maintain awareness of overall facility operations and reviewed

operator logs to verify operational safety and compliance with Technical Specifications

(TSs). Instrumentation and safety system lineups were periodically reviewed from

control room indications to assess operability. Frequent plant tours were conducted to

observe equipment status and housekeeping. Deviation Reports (DRs) were reviewed

to assure that potential safety concerns were properly reported and resolved. The

inspectors found that daily operations were generally conducted in accordance with

regulatory requirements and plant procedures.

01.2

Unit 2 Power Reduction

a.

Inspection Scope (71707)

b.

The inspectors reviewed the circumstances surrounding a Unit 2 power reduction due to

steam generator chemistry problems.

Observations and Findings

On February 4, at 10:06 a.m., a power reduction to 90 percent power was commenced

on Unit 2 to allow performance of a turbine valve freedom test. During the test, the

number 4 governor valve oscillated excessively resulting in a load reject signal being

generated at 12:02 p.m. The load reject signal armed the steam dumps and bypassed

the condensate polishers as designed. The valve freedom test was suspended and the

condensate polishers were returned to service within approximately 31 minutes.

Subsequent steam generator chemistry samples indicated increasing levels of sodium

and chlorides. At 1 :55 p.m., chlorides in the A steam generator exceeded the Action

2

Level 2 criteria of 50 parts per billion (ppb). Once an Action Level 2 parameter has been

exceeded, a power reduction to approximately 30 percent within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> is required.

Chloride concentration in the A steam generator peaked at 66 ppb. Chloride

concentrations in the B and C steam generators did not exceed 50 pp,b, but did exceed

the Action Level 1 criteria of 10 ppb. Based on Action Level 2 chemistry conditions in

the A steam generator, a power reduction from 90 percent power was commenced at

2:28 p.m. The power reduction was stopped at 2:38 p.m. when chemistry samples

indicated that chloride levels in the A steam generator were below 50 ppb. The power

reduction was terminated with the unit at 88 percent power. The unit remained at 88

percent power until chloride levels were reduced to below the Action Level 1 criteria of

1 O ppb. At 8:35 p.m., a power increase was commenced and the unit was returned to

100 percent power at 11 :40 p.m.

The inspectors reviewed the chemistry sample results, reviewed the administrative

requirements associated with the steam generator chemistry conditions, and observed

the power reduction. The control room operators appropriately followed the

administrative requirements to reduce power based on a steam generator chemistry

parameter exceeding Action Level 2. The termination of the power reduction was also

appropriate following confirmation that chloride levels were below Action Level 2

conditions. The inspectors noted that condenser hotwell chemistry was degraded due to

waterbox inleakage from the circulating water system. The licensee plans to perform

maintenance on the turbine valves during the upcoming April / May refueling outage .

c.

Conclusions

Operators actions to reduce power following a steam generator chemistry excursion

resulting from loss of the condensate polishers were appropriate and met the licensee's

administrative requirements associated with steam generator chemistry. Degraded

condenser hotwell chemistry due to inleakage from the circulating water system caused

the chemistry excursion when the condensate polishers were isolated.

02

Operational Status of Facilities and Equipment

02.1

Diesel Fuel Oil System

a.

Inspection Scope (71707)

b.

The inspectors performed a system walkdown of the emergency diesel generator (EOG)

fuel oil system.

Observations and Findings

During the inspection period, the inspectors performed a detailed system walkdown of

the EOG fuel oil system. The system consists of two underground storage tanks that

are common to all three EDGs. Each EOG has two fuel oil transfer pumps that take a

suction from the underground storage tanks and deliver fuel oil to a wall mounted day

tank located in the associated EOG room. One pump is designated the ready pump and

the other pump is designated as the standby pump. The pumps take a suction off

C.

3

different underground storage tanks and operate based on an input signals from level

switches located in the day tank. The ready pump would start first based on a low level

switch actuation and the standby pump would only start if a lower level in the day tank is

detected by the level switch. Additional reviews of EOG fuel oil requirements were

performed as part of the closeout for Inspection Followup Item (IFI) No. 50-280,

281 /98001-01 and are documented in Section 08.1.

The inspectors reviewed the system valve alignment procedures and walked down

accessible portions of the system to verify proper alignment and material condition. The

inspectors also observed installed pipe supports and hangers and verified electrical

system configuration. The EOG fuel oil system was properly aligned and material

condition was adequate. During the walkdown, the inspectors identified that the

underground fuel oil storage tank vents were attached to the non-seismic above ground

fuel oil storage tank. The inspectors questioned the adequacy of attaching the tank

vents to a non-seismic structure. The licensee stated that the adequacy of the system

configuration had been previously reviewed and was found to be acceptable. The

inspectors reviewed the licensee documentation and determined that their acceptability

determination was based on engineering concluding that the loss of the vents was not a

credible event (i.e., during a seismic event the vent piping would still perform its

function). The inspectors were still reviewing this item at the end of the inspection

period .

The inspectors also questioned the licensee whether the fill piping from the non-seismic

above ground storage tank to the underground tanks, which runs through the fuel oil

transfer pump house, was seismically installed. The concern for this item dealt with a

possible rupture of the piping during a seismic event and flooding of the ready transfer

pumps. The licensee was reviewing the piping qualification at the end of the inspection

period. As an interim compensatory measure, the licensee closed the outlet valve from

the above ground storage tank while they were reviewing this issue. Additional review

of the fuel oil piping seismic requirements for the tank vent piping and the fill piping is

identified as Inspection Followup Item 50-280, 281/99001-01: Review of fuel oil piping

seismic requirements.

Conclusions

The diesel fuel oil system was properly aligned and material condition was adequate.

An inspection followup item was identified concerning fuel oil piping seismic

requirements.

02.2

Emergency Diesel Generator (EOG) Tagout

a.

Inspection Scope (71707)

The inspectors reviewed tagging record 2-99-EE-0004, "EOG Number 2 Maintenance."

b.

Observations and Findings

The inspectors reviewed tagging record 2-99-EE-0004. The tagout was implemented to

isolate the Number 2 EOG for maintenance activities. The inspectors verified the tagout

4

was properly prepared and authorized, that the tagged components were in the required

positions with the appropriate tags in place and that the tagout was adequate for the

work to be performed. The inspectors also verified that the equipment was restored to

the proper position following completion of the maintenance activity and that the tags

were removed.

c.

Conclusions

A tagging record for maintenance on the Number 2 emergency diesel generator was

properly prepared, authorized, and implemented.

05

Operator Training and Qualification (71707)

On February 5 the inspectors observed operator simulator requalification training. The

training exercise was associated with reactor trip response. The training was conducted

for an operating crew. The scenario presented was challenging. The training included

industry experience items and addressed recent plant modifications. The inspectors did

  • not identify any deficiencies and operator performance and communications during the

exercise were exemplary.

08

Miscellaneous Operations Issues (92901)

08.1

(Closed) Inspection Followup Item (IFI) 50-280, 281/98001-01: Review EOG fuel oil

requirements. This item was opened to determine the basis for the fuel oil volume

(minium 35;000 gallons) required by the TS and to review the availability of power for

the two fuel oil transfer pumps associated with the Number 3 EOG. LER 50-280,

281/98003-00 discussed the lack of procedural guidance for aligning power to Number 3

EOG fuel oil transfer pumps during loss of offsite power events. This LER was closed in

Inspection Report No. 50-280, 281/98-10 based on emergency operating *procedures

being revised to provide interim guidance and modifications that are planned to provide

permanent corrective action.

The inspectors reviewed the TS (including the basis), the UFSAR, and the original NRC

Safety Evaluation Reportrelating to EOG fuel oil requirements. TS 3.16.A.1 requires

that the underground storage tanks contain a combined fuel oil volume of 35,000

gallons and that the day tank contain 290 gallons. The TS basis and the Updated Final

Safety analysis Report (UFSAR) state that the underground EOG fuel oil storage tanks

contain a seven (7) day supply of fuel, 35,000 gallon minimum, for the full load operation

of one EOG. The Safety Evaluation Report discussed that the 35,000 gallon

requirement was based on the amount of fuel oil to supply one EOG operating at full

load for seven days. The inspectors verified that 35,000 gallons of fuel oil is an

adequate supply to operate one EOG at full load for seven days. The inspectors noted

that more than one EOG would be operating following a loss of offsite power event, and

that the EOGs would not be continuously loaded to full load" as described in the TS and

UFSAR for the entire seven days following a design basis event. The inspectors verified

that the fuel oil storage volume requirement was consistent in the TS, UFSAR and the

NRC Safety Evaluation Report and that the licensee was satisfying this requirement.

08.2

5

(Closed) IFI 50-280, 281/97010-02: Review licensee actions to resolve AMSAC enable

setpoint issues. This item involved the enable setpoint associated with arming of the

AMSAC system during power escalations. The licensee initially lowered the enable

setpoint to ensure that the AMSAC system armed prior to exceeding 40 percent power.

Based on further reviews by the AMSAC system vendor and licensee it was determined

that the original setpoint was adequate and the setpoint was returned to the original

value. The inspectors reviewed this item and discussed the final resolution with licensee

personnel. The inspectors determined that licensee actions adequately resolved this

item.

II. Maintenance

M1

Conduct of Maintenance

M1 .1

Unit 1 Turbine Driven Auxiliary Feedwater (TDAFW) Pump Valve Maintenance

a.

Inspection Scope (62707)

The inspectors observed portions of the work activity associated with Work Order (WO)

00401603 and reviewed the completed work package.

b.

Observations and Findings

On February 3, the inspectors reviewed the maintenance activities associated with WO 00401603. The work order was generated as a preventative maintenance activity to

lubricate the turbine trip valve associated with the Unit 1 TDAFW pump (1-FW-P-2).

The work activity was performed in accordance with procedure O-MCM-421-02, "Terry

Turbine Gimpel Trip Valve Maintenance," Revision 3-P1. The work activity consisted of

inspecting and lubricating the turbine trip valve, 01-MS-TV-120. The inspectors

observed portions of the work activities and noted that the procedures were being used

by the mechanics and good work practices were being followed. The inspectors noted

that the component was properly isolated to allow the work activity to commence safely.

c.

Conclusions

Auxiliary feedwater turbine trip valve maintenance activities were properly performed

and documented.

M1 .2

Unit 1 TDAFW Pump Surveillance

a.

Inspection Scope (61726)

The inspectors observed Unit 1 TDAFW pump surveillance testing.

b.

Observations and Findings

On February 3, the inspectors observed a recirculation test of the Unit 1 TDAFW pump

conducted in accordance with procedure 1-0PT-FW-003, "Turbine Driven Auxiliary

6

Feedwater Pump 1-FW-P-2," Revision 1 O-P1. The inspectors also observed the

performance of procedure 1-0PT-FW-007, "Turbine Driven AFW Pump Stea!'f1 Supply

Line Check Valve Test," Revision 1. A pre-job briefing was held and the work was

performed in accordance with approved procedures. Temporary speed-sensing

equipment was used to monitor the turbine performance during start-up, and indicated

that the governor valve was operating normally.

c.

Conclusions

The turbine driven auxiliary feedwater pump was tested in accordance with approved

procedures and all test acceptance criteria were met.

M1 .3

Outside Recirculation Spray (OSRS) Valve Maintenance

a.

Inspection Scope (62707)

b.

The inspectors observed portions of the work activity associated with Work Order (WO)

00405662 and reviewed the completed work package.

Observations and Findings

On February 23, the inspectors reviewed emergent maintenance activities associated

with WO 00405662. The work order was generated as corrective maintenance after

OSRS suction valve, 1-RS-MOV-1558, failed to fully open during testing per procedure

1-0PT-RS-007, "Containment Outside Recirculation Spray Pumps MOV Stroke Test."

The valve operator was inspected and several internal gears were found to be

damaged. The licensee determined that the damage was due to misalignment of the

gears. The valve operator had been overhauled during the previous refueling outage

(October - November 1998). The gears were replaced and the valve retest consisted of.

a stroke test per procedure 1-0PT-RS-007.

Table 5.2-2 of the UFSAR requires 1 OCFR50 Appendix J testing for this valve, with a

  • note indicating that the system is water filled and not considered a credible leakage path

from containment. Because of the note in the UFSAR and the fact that the work was

limited to the valve operator and did not affect the valve seating/ leakage characteristic,

i.e., did not invalidate the previous leakrate test, the licensee determined that no local

leakrate testing was required. The inspectors discussed with the NRC Office of Nuclear

Reactor Regulation the need to perform a local leakrate test and determined that since

the seat leakage characteristics of the valve had not been altered by the maintenance

the decision to not perform a local leakrate test was valid.

c.

Conclusions

Corrective maintenance on the outside recirculation spray suction valve was performed

properly and the decision not to perform local leakrate testing after repairs was valid .

7

Ill. Engineering

E1

Conduct of Engineering

E1 .1

Spent Fuel Pool (SFP) Cooling Pump Power Upgrade Modification

a.

Inspection Scope (37551)

The inspectors reviewed the licensee's final actions associated with SFP decay heat

removal reliability and the maintenance of adequate SFP coolant inventory.

Specifically, the plant modification to upgrade the power supply for the SFP cooling

pumps from a non-safety related source to a safety related source was reviewed.

b.

Observations and Findings

In 1996, the NRG identified a number of issues related to SFP decay heat removal

reliability and the maintenance of adequate coolant inventory in the SFP. A review was

conducted to identify plant specific and generic areas for regulatory analyses. These

matters were reviewed in detail in NRG Inspection Report No. 50-280, 281/98-04. The*

only outstanding issue was the implementation of a modification to change the power

supply for the SFP cooling pumps to a safety related source. The licensee committed to

complete this modification by the end of 1999.

The inspectors reviewed portions of Design Change Package (DCP)97-004, "Spent

Fuel Pool Cooling Pump Power Upgrade." In this DCP the power supply for pump 1-FC-

P-1 A, was changed to motor control center 1 H1 -2N, a 480 volt safety related bus

supplied from the 1 H 4160 volt safety related bus. Additionally, the power supply for

pump 1-FC-P-1 B was changed to motor control center 2H1-2S, a 480 volt safety related

bus supplied from the 2H 4160 volt safety related bus. The inspectors walked down the

new power supplies and verified that the pump motor power supplies were connected in

accordance with the DCP. With the completion of this modification, the licensee has

satisfied all commitments associated with issues related to SFP decay heat rem.oval

reliability and the maintenance of adequate coolant inventory in the SFP.

During the inspectors review of the modification, two issues were identified. Just prior to

returning the 1 A fuel pool cooling pump to service following the power upgrade, a .

discussion between the inspectors and the operating crew revealed that the operators

lacked detailed knowledge on the specifics of the modification (i.e., the location of the

circuit breakers for the SFP cooling pumps and which electrical buses will be supplying

power to the pumps). This matter was brought to the attention of operations

management. The operating shift orders were amended to ensure operators were

made aware of the specifics of the modification. On January 28, the portion of the

modification affecting the 1 A SFP cooling pump was completed and the pump was

returned to service.

On January 29, during a tour of the control room, the inspectors noted that a priority

document associated with DCP 97-004 had not been updated in the main control room

file. The licensee's design control administrative procedure, VPAP 0301, "Design

8

Change Process," Revision 9, states that priority documents must be updated prior to

system testing. Specifically, Revision 12 to Abnormal Operating Procedure, 1-AP-

10.07, "Loss of Unit 1 Power," although revised and approved by licensee personnel,

had not been provided to the main control room. This upgraded procedure provided

crucial directions to plant operators not to restart the 1 A SFP cooling pump if the 1 A

containment spray pump was in operation and being supplied power by the Number 1

EOG generator during accident conditions. The reason for the prohibition to not start

the 1 A SFP cooling pump, if the 1 A containment spray pump is running, involves the

potential for overloading the Number 1 EDG.

The inspectors brought this matter to the attention of operations management. A

deviation report (DR) was written and the upgraded copy of AOP 1-AP-10.07 was

promptly placed in the main control room abnormal operating procedures file. TS 6.4.A.3 requires that detailed procedures be provided for actions to be taken for specific

and foreseen malfunctions of systems. The failure to provide the main control room with

an up-to-date revision of AOP 1-AP-10.37, "Loss of Unit 1 Power," is a violation of TS 6.4.A.3. This Severity Level IV violation is being treated as a Non-Cited Violation,

consistent with Appendix C of the NRC Enforcement Policy. This violation is in the

licensee's corrective action program as DR S-99-0229, and is identified as NCV 50-

280/99001-02.

c.

Conclusions

By completing the spent fuel pool power upgrade modification, the licensee has satisfied

all commitments associated with issues related to spent fuel pool decay heat removal

reliability and the maintenance of adequate coolant inventory in the spent fuel pool.

A non-cited violation was identified for failing to provide the main control room with an

up-to-date copy of an abnormal operating procedure (AOP) relating to a loss of power

condition affecting Unit 1. The AOP was revised following a modification to the Spent

Fuel Pool Cooling pump power supplies.

EB

Miscellaneous Engineering Issues (92903)

E8.1

(Closed) Unresolved Item (URI) 50-281/98201-03: Unit 2 low head safety injection

(LHSI) pump minimum flow. The problem involved one of the two redundant Unit 2

LHSI pumps which was weaker than the other pump. This meant that, given the piping

configuration, the weaker pump would receive less than the manufacturer

recommended minimum flow when the two pumps operated in parallel under minimum

flow conditions, i.e., discharge pressure of the LHSI pumps is less than RCS pressure.

During these conditions the weaker pump could be subject to damage. This item is

discussed in NRC Inspection Report No. 50-280, 281/98-07, where some of the

corrective actions were reviewed. In 1988 when the licensee performed evaluations

pursuant to NRC Bulletin 88-04, "Potential Safety-Related Pump Loss," they performed

an adequate minimum flow evaluation for the Unit 1 LHSI pumps, which included

testing. The evaluation showed that the two pumps were evenly matched, and minimum

flow would be assured for all modes of operation. However, the licensee incorrectly

assumed that the Unit 2 LHSI pumps would be the same. In the Architectural/

ES.2

9

Engineering (A/E) inspection of 1998, the NRC identified that this assumption was not

correct. The Unit 2 LHSI pumps 1 A and 1 B are not evenly matched. Later, evaluations

. showed that the actual conditions would result in significantly less than recommended

minimum flow in parallel pump operation described above. The licensee evaluated this

reduced minimum flow for the weaker Unit 2 LHSI pump and determined that the pump

would remain operable for the situation described above. An important consideration in

this determination was that the operators would secure the pump within 30 minutes for a

safety injection actuation in which the LHSI pumps were not injecting water into the

RCS.

10 CFR 50, Appendix B, Criterion Ill, Design Control, requires that controls be provided

for verifying the adequacy of the design such as by the performance of design reviews

or the performance of suitable testing programs. In the case of the Unit 2 LHSI pump

minimum flow requirements, the design reviews were inadequate and failed to verify the

adequacy of the design. No testing was performed to verify the adequacy the Unit 2

LHSI pump minimum flow design. This constitutes a violation of 1 OCFR 50, Appendix B,

Criterion Ill, Design Control. This Severity Level IV violation is being treated as a Non-

Cited Violation, consistent with Appendix C of the NRC Enforcement Policy. This

violation is in the licensee's corrective action program as DR S-98-0660, and is identified

as NCV 50-280, 281/99001-03. A second example of this design control violation is

discussed in Section E8.4 .

The licensee was developing a design change package to modify the recirculation path

piping to achieve increased minimum flow. This modification was scheduled for

implementation on Unit 2 during the April/May 1999 refueling outage and later on

Unit 1. In reviewing the change package, the inspectors observed that the change

would result in improved recirculation (i.e. minimum flow) for the parallel pump case, but

would decrease flow for the single pump operation case. Documentation indicated flow

would be reduced from 340 GPM to 200 - 250 GPM. The change package did not

provide a clear basis for the adequacy of 200 GPM to preclude hydraulic instabilities.

For this reason, an Inspection Followup Item is established; IFI 50-280, 281/99001-04.

(Closed) IFI 50-280/98201-04: Motor thermal overload for LHSI pump 1-SI-P-18. The

inspectors reviewed Calculation EE-0497, Safety-Related 480 V Load Center

Coordination, Revision 1, issued October 29, 1998. The inspectors noted that the

pages covering the set points for the circuit breakers for the LHSI pump motors were

revised to obtain new set points for 1-SI-P-1 B. The inspectors reviewed these revised

calculation sheets in detail, and agreed that the new solid-state trip device and set

points will provide proper protection and coordination. The inspectors cross checked the

licensee's time-current plot against the manufacturer's published time-current

characteristic curve. The licensee developed DCP 98-056, which was in the final

concurrence stage. The inspectors observed that the DCP included the changes

recommended by calculation EE-0497. The implementation schedule was acceptable.

E8.3.

(Open) IFI 50-280, 281/98201-05: Adequacy of 4160 VAC electrical cables to withstand

fault current. This issue encompasses two related but separate concerns involving

undersized 4160 VAC electrical cables. The first concern involved the scenario of a fire

10

induced short-circuit on a cable not required for safe shutdown and possible damage to

a cable required for safe shutdown if the two cables are located in the same cable tray.

In this concern, the postulated fire starts from a non-electrical source in a different fire

zone than the safe shutdown equipment. The second concern involved postulated

random short-circuits that result in cable fires in two different fire zones (the zone where

the short-circuit occurred and a second zone through which the faulted cable is routed).

This scenario would not be bounded by the Appendix R analysis since that analysis

assumes a fire in only one zone.

The licensee calculated, using standard techniques, the temperatures at the

conductor/insulation interface that could result from plant specific short-circuits on the

undersized cables. They also calculated the maximum short-circuit for which these

cables would not exceed the rated momentary temperature of 250 °C. They also

reviewed various test reports which were generated by testing laboratories which dealt

with the effects of high currents on cables. The calculation results and test reports were

integrated into a rationale justifying the existing installation. That rationale is

summarized below.

Whenever a short-circuit occurs on a cable, the highest temperature resulting from that

short-circuit is always at the point of the fault. This statement is based on the fact that

the short-circuit must involve arcing. Therefore, even if the faulted cable is undersized

in the traditional sense from the short-circuit viewpoint, any conductor vaporization or

melting that may result would always happen first at the point of the fault. Once

conductor vaporization or melting occurs, the fault is self clearing. Vaporization with

concomitant explosion of the cable would never occur at a point along the cable

between the fault and the power source. The licensee's documentation indicated that

this concept essentially precludes and addresses the first concern stated above.

The extremely high temperatures calculated for the undersized cables were based on

solid three-phase faults and a breaker clearing time of seven cycles. In reality, any fire

induced cable fault would have to begin as a ground fault, which could then progress to

a three-phase fault. Ground faults are limited to 1400 Amperes, which is significantly

less than the maximum three-phase fault of about 33,000 Amperes. This concept

means that the circuit breaker in effect operates faster than seven cycles for the three-

phase fault. This effectively fast circuit breaker time tends to protect the cables from

severe damage along the length due to the fault currents, which is relevant to the first

concern.

Testing shows that when cables are subjected to overcurrents such as would result from

short-circuits two different results occur depending on the level of current. Extremely

high currents result in rapid melting of the conductor which stops the current flow

because there is no longer a complete path for the current. The temperature at the

surface of the conductor remains below the self ignition temperature of the insulation.

This statement is supported by test results. Therefore, extremely high currents do not

result in fires along the cable between the point of fault and power source. Current

levels about equal to motor locked rotor current when allowed to flow for extended

periods of time caused cable fires during testing for this situation. However, there is

nothing about the fact that certain cables are undersized for short-circuit that makes

them more vulnerable to long term overload type currents. Calculation showed that the

E8.4

11

cables in question are in fact protected for currents up to 11,000 Amperes, which is an

extremely high current level. The licensee's documentation indicated that these

concepts alleviate the second concern.

Pending further NRC review of the licensee's rationale, this item remains open.

(Closed) URI 50-280, 281/98201-08: EOG Battery Transfer Switch. This issue is

discussed in NRC Inspection Report No. 50-280, 281/98-07. The control panels for the

No.1 EOG are supplied 125 VDC power through a transfer switch, which provides the

capability to receive power from the No.1 EOG battery or No. 3 EOG battery. The

normal power source for No. 1 EOG control power is the No.1 EOG battery. There is a

similar arrangement for the No. 2 EOG control panel with the capability of receiving

power from the No. 3 EOG battery through another transfer switch. The transfer

switches are not described in the UFSAR. Calculation 14937.28-E-7, "Verification of

Lead Storage Battery Size for Emergency. Diesel Generator," Revision 2, issued

November 29, 1989, did not account for any increased load on No. 3 EOG battery due

to the operation of the transfer switches and the alignment of No. 3 EOG battery to

either the No. 1 or 2 EOG control panels.

Operation of the transfer switches was mentioned in two operating procedures;

Abnormal Operating Procedure, O-AP-17.04, "EOG 1or EOG 2 - Emergency

Operations," and Fire Contingency Action Procedure, O-FCA-12.00, "Emergency Diesel

Generator Operation." The current revisions for these procedures contain strict cautions

and controls on operation of the transfer switches. The previous revision of the

abnormal operating procedure contained the following cautions regarding operation of

the transfer switches: 1) an evaluation should be made before using the switch; 2) the

No. 3 EOG should already be running; and 3) the No. 1 and 2 EDGs should not be

aligned to No. 3 EOG battery at the same time. The current revision added the

statements that the transfer switches are for emergency use only and the switches can

not be used without Shift Supervisor approval. The previous revision of the fire

contingency action procedure stated that the transfer switches could be used with Shift

Supervisor direction. The current fire contingency action procedure revision contains

similar cautions described above for the abnormal operating procedure. The transfer

switches are currently padlocked and a caution tag is affixed stating: "Use of this

throwover switch requires the Shift Supervisor to invoke 1 OCFR50.54x." This was

verified by the inspectors. In addition, OCP 98-055 was prepared to remove fuses which

are located between the transfer switches and No. 3 EOG battery. The inspectors

concluded that the corrective actions stated above resolve the original concern

embodied in the URI. Also, the NRG has determined that existence of the transfer

switches with the original controls did not constitute an unreviewed safety question.

10CFR50, Appendix B, Criterion Ill, Design Control, requires that measures be

established to assure the design basis for structures, systems and components are

correctly translated into specifications, drawings, procedures and instructions. Not

having the transfer switch and potential for additional loads on the No. 3 EOG battery

addressed in calculation 14937.28-E-7, "Verification of Lead Storage Battery Size for

Emergency Diesel Generator," Revision 2, represents a violation of 1 OCFR50, Appendix

B, Criterion Ill. This Severity Level IV violation is being treated as a Non-Cited Violation,

consistent with Appendix C of the NRG Enforcement Policy. This violation is in the

E8.5

12

licensee's corrective action program as DR S-98-0605, and is identified as NCV 50-280,

281/99001-03. The first example of this design control violation is discussed in Section

E8.1.

(Closed) URI 98201-09: DC tie breaker. This issue is discussed in NRC Inspection

Report No. 50-280, 281/98-07 which states that the issue will remain open pending

review by the NRC to determine whether an unreviewed safety question was involved.

The NRC has completed its review, and determined that the circumstances surrounding

the interconnection between the two redundant trains of the 125 VDC Distribution

System involved an unreviewed safety question as defined in 10 CFR 59.59, Changes,

Tests and Experiments. It involved an unreviewed safety question because actual

operation of the tie breaker was different than described in the UFSAR and operation of

the tie breaker as described in procedures created the possibility for a malfunction of a

different type than previously evaluated in the UFSAR. Section 8.4.4 of the UFSAR

states, "The manually operated bus tie breaker provides for parallel operation of the bus

sections with either battery out of service for maintenance." This statement meant that

one battery must be disconnected from its bus before the tie breaker was closed.

These words were put into the UFSAR after the 1988 battery capacity upgrade

modification when it was recognized that the interrupting rating of individual feeder

circuit breakers would be exceeded with two batteries connected.

The molded-case tie breaker does not have any automatic tripping capability, so it was

essentially a manual switch. Maintenance Operating Procedure 1-MOP-EP-030,

"Removal from Service and Return to Service of Station Battery 1 A," Revision 0, issued

on January 30, 1997, directed that maintenance personnel first close the tie switch then

disconnect the battery which will be receiving maintenance. The practice of connecting

the two batteries via the tie breaker was only allowed and actually performed when the

plant was shutdown. The lack of circuit breaker interrupting capability when redundant

trains are connected together without any electrical isolation devices created the

  • potential for severe damage or degradation to both trains of the 125 VDC Distribution

System, which was an unanalyzed malfunction. The NRC has now analyzed this

malfunction during shutdown conditions and concluded that the increased ~isk of core

damage was very small. The longer term corrective action will be to reconfigure the tie

between the two batteries to have two automatic type molded case circuit breakers in

series. This would meet the intent of the Safety Guide requirement to have interlocks

on inter-train tie breakers.

The inspectors concluded that the circumstances of the tie switch constituted a violation

of 1 O CFR 50.59 in that the licensee did not recognize the unreviewed safety question

created by the 1988 battery capacity upgrade modification and procedure for operation

of the tie breaker. After the identification by the NRC, the licensee entered this problem

into their corrective action program and implemented adequate compensatory

measures. This Severity Level IV violation is being treated as a Non-Cited Violation,

consistent with Appendix C of the NRC Enforcement Policy. This violation is in the

licensee's corrective action program as DR S-98-0719, and is identified as Non-Cited

Violation 50-280, 281/99001-05 .

E8.6

(Closed) IFI 50-280, 281/98201-19: Recirculation Spray (RS) System flow. The

inspectors reviewed the licensee's corrective actions for this issue. The licensee

13

analyzed system flow in calculations, and determined new flow distributions taking into

consideration any diverted flow paths and repositioning of valves to limit diverted flow.

The calculations reviewed were:

ME-0418, "Outside Recirculation Spray Flow," Addendum A, dated September

30, 1998.

ME-0405, "Inside Recirculation Spray Flow," Addendum A, dated September 30,

1998.

The inspectors also reviewed DCP 98-040, "Recovery of RS System Delivered Spray

Flows - Unit 1." This modification was essentially a valve alignment procedure change

to close off certain diverted flow paths. The inspectors also confirmed through

reference to the appropriate operations procedure, 1-0P-RS-001 A, "Outside Recirc

Spray System Alignment," Revision 3, that the modification was implemented.

E8.7

(Open) VIO 50-280, 281/98007-01: Failure to take corrective action for identified design

problems. This violation had two examples cited. The first involved the set point for the

circuit breaker trip device for the inside recirculation spray pump motors. The inspectors

reviewed the revised set point calculations and the proposed design change package

prepared to implement the set point change. These were the same calculation and DCP

described in Section E8.2. The corrective actions for this example of the violation were

satisfactory. The second example cited in the violation involved lack of voltage

calculations on the 125 VDC Distribution System. Completion of work on the

calculations is scheduled for the end of 1999. Therefore, the violation*remains open

pending inspection of the voltage calculations.

E8.8

(Closed) URI 50-280, 281/98007-03: Failure to submit LER within 30 days. The NRC

has reviewed the licensee's interpretation of the 30-day reporting requirement in terms

of preliminary evaluation time in the case of design basis issues. The inspector

concluded that the licensee's interpretation was valid in this particular case. This

conclusion should not be construed as agreement that the 30-day reporting requirement

for design basis issues can be automatically extended but as an acknowledgment that

the timeliness for initial reportability determination for this case was appropriate due to

the complexity of the design basis issues.

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 .

14

R1 .1

Primary Demineralizer Influent Sample

S1

a.

Inspection Scope (71750)

The inspectors observed the drawing and analysis of depressurized primary coolant

samples.

b.

Observations and Findings

On February 3, 1999, the inspectors observed the licensee obtain primary coolant

samples from both Unit 1 and Unit 2 in accordance with procedure, CH-11.201,

"Sampling Primary Demineralizer Influent," Revision 4. The inspectors also witnessed

the analysis of the sample for boron concentration. The results were consistent with

previous samples when plotted on the unit trend graphs. The technician utilized proper

radiological control practices by using low-dose waiting areas while the sample lines

were being purged and storing the samples in shielded areas in the chemistry

laboratory.

c:

Conclusions

A primary coolant sample was properly drawn and analyzed. Proper radiological

practices were used by the technician performing the evolution .

Conduct of Security and Safeguards Activities

On numerous occasions during the inspection period, the inspectors performed

walkdowns of the protected area perimeter to assess security and general barrier

conditions. No deficiencies were noted and the inspectors concluded that security posts

were properly manned and that the perimeter barrier's material condition was properly

maintained.

S1 .5

Fitness For Duty Program

a.

Inspection Scope (81502)

The inspectors evaluated the disposition of Fitness For Duty (FFD) events to verify that

the licensee's FFD program was being implemented according to regulatory

requirements and Physical Security Plan (PSP) commitments.

b.

Observations and Findings

The inspectors reviewed and evaluated the licensee's Significant Fitness for Duty Event

NRC 24 Hour Notification form for event No. 35396 dated February 23, 1999. Licensee

personnel made the required notifications and complied with the reporting requirements

of Virginia Power Administrative Procedure (VPAP)-0105, "Fitness For Duty Program,"

Revision 11 .

C.

15

Conclusions

A Fitness For Duty program 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> NRC notification was implemented according to

procedural commitments and regulatory requirements.

S2

Status of Security Facilities and Equipment

S2.8

Independent Spent Fuel Storage Installation (ISFSI)

a.

Inspection Scope (81001)

The inspectors reviewed the physical protection system installed at the Independent

Spent Fuel Storage Installation.

b.

Observations and Findings

The ISFSI had an intrusion detection system (IDS), assessment capabilities of

annunciated alarms of the isolation zones, personnel and vehicle access control,

security equipment power supply, and a testing and maintenance program for the

protection equipment. The inspectors tested the IDS zones and found them operational.

The inspectors found that the Closed Circuit Television (CCTV) assessment equipment

provided clear and prompt assessment capabilities. The inspectors observed IDS

alarms annunciating in the alarm stations in concert with the CCTV assessments.

c.

Conclusions

The security equipment at the Independent Spent Fuel Storage Installation was found to

be operational and performing as intended.

S3

Security and Safeguards Procedures and Documentation

S3.3

Security Event Logs

a.

Inspection Scope (81700)

b.

The inspectors reviewed Security Event Logs (SEL) for 1998 to verify that the licensee

appropriately analyzed, tracked, resolved, and documented safeguards events that the

licensee had determined did not require reporting to the NRC.

Observations and Findings

This review found that the licensee tracked, trended, analyzed, and had taken corrective

actions to resolve the events described in the SELs. The inspectors also found that

there were no significant increasing or decreasing trends in the event categories. Any

increases noted were attributed to the preparation of the performance assessment

during this inspection period. The inspectors noted that the process of documenting the

events and tracking the findings within the corrective action program involved numerous

data bases and document files.

16

c.

Conclusions

Safeguards events were logged, tracked, trended, analyzed, and resolved according to

the Physical Security Plan commitments.

SS

Security Safeguards Staff Training and Qualification

S5.1

Security Training and Qualification

a.

Inspection Scope (81700)

The inspectors observed individual security officer training and reviewed training and

qualification commitments to ensure that the training met the criteria in the Training and

Qualification Plan.

,,

b.

Observations and Findings

Members of the security organization were requalified at least every 12 months in the

performance of their assigned tasks, both normal and contingency. This included the

conduct of physical exercise requirements and the completion of a firearms course.

Through the observation of security personnel performing their duties, and interviews

with security force personnel, the inspectors found that the training complied with

1 O CFR 73, Appendix B, proficiency requirements .

c.

Conclusions

The security force was effectively trained and requalified according to the Training and

Qualification Plan and regulatory requirements.

S6

Security Organization and Administration

S6.1

Management Support and Effectiveness

a.

Inspection Scope (81700)

b.

The inspectors evaluated the degree of licensee management support for the security

program and the effectiveness of licensee management relative to the administration of

the physical security program.

Observations and Findings

The inspectors interviewed management and non-management personnel and reviewed

security related documents to determine the breadth and depth of the support provided

and program effectiveness resulting from that support. The inspectors determined that

licensee management exhibited an awareness and favorable attitude toward physical

protection requirements. The following items demonstrated the support system for the

security program:

17

The support management provided for testing and maintenance of security

equipment was appropriate. A review of the maintenance request and requests

for engineering assistance (REA) records revealed that the oldest work order

was dated October 1998 and a HEA dated back to January 1998 for a

compensatory measure implemented at zone five of the protected area

perimeter was still open. The zone five REA was discussed with an

Instrumentation and Controls (l&C) supervisor to evaluate the coordination

between security and l&C.

The average time of posted security officer compensatory measures used to

compensate for equipment failures was less than three hours.

The security officer staffing level has been stable since the beginning of 1997 .

To enhance the site access program, licensee management continued to

support the work in progress for the Security Access Control System.

An effective vehicle barrier system has continued to be implemented .

Site management effectively enhanced and corrected a long term problem with

the security uninterruptable power supply .

c.

Conclusions

Site and security management provided support for the physical security program and

was effective in administrating the security program.

S7

Quality Assurance in Security and Safeguards Activities

S7.1

Audits/Self Assessment Program

a.

Inspection Scope (81700)

b.

The inspectors evaluated the audit and self assessment program and procedures. The

requirement for an annual audit of the security and contingency programs was also

evaluated.

Observations and Findings

The Nuclear Oversight (NO) audit findings for 1998 and 1999 were reviewed. NO Audit

Report 98-01 stated that no regulatory compliance issues were noted and that the

security and FFD program was a strength, proactive, thorough, detailed, and

aggressive. The security internal Self-Assessment (SA) audits for 1998 were also

reviewed. The SAs were directed by the Manager, Nuclear Security and Administrative

Services and conducted by site security personnel. Sixteen areas of the security

program, and the FFD program were reviewed. Between the NO audits and SA audits,

the security and FFD program were audited at least every twelve months. In addition,

security management initiated a Surry Nuclear Power Station Security Value

18

Assessment Program. Senior site management was queried on security services

provided to their site customers. The results were 93 percent positive comments and 7

percent negative comments. The audit and self assessment program of the security

program was found to be a strength in the management of the security program.

c.

Conclusions

The Nuclear Oversight audits and Self-Assessment audits were thorough, complete,

and effective in uncovering weaknesses in the security system, procedures, and

practices. The audit and self assessment program was a strength of the security

program.

S7.2

Problem Analysis

a.

Inspection Scope (81700)

. The inspectors reviewed and evaluated how problems related to logged safeguards

events (SEL), Deviation Reports (DR), and Licensee Event Reports (LER) were

analyzed.

b.

Observations and Findings

During the inspection, a representative sample of the problems identified by inspections,

DRs, LERs, and SELs were reviewed to verify that the problems were appropriately

assigned, analyzed, prioritized for corrective action and reached logical conclusions.

The inspectors found that problems were assigned for analysis according to VPAP -

1601, "Corrective Action," Revision 10, and were appropriately analyzed according to

VPAP - 1604, "Root Cause Evaluation Program." Six security individuals were fully

trained in Root Cause Analysis. The inspectors found this area to be a strength in the

security program.

c.

Conclusions

The licensee assigned and analyzed problems properly so that logical conclusions could

be reached. Corrective actions were appropriately prioritized. Problem analysis was a

strength of the security program.

S7.3

Corrective Actions

a.

Inspection Scope (81700)

b .

The inspectors reviewed and evaluated corrective actions implemented by the licensee

as documented in the DRs, SELs, and LERs.

Observations and Findings

The inspectors reviewed a sample of corrective actions that had been implemented to

verify that the actions taken were technically sound and performed in a timely manner.

The effectiveness of the corrective actions was reflected in the fact that most problems

19

were not repetitive. Also, contributing to the success of the corrective actions was the

concise, thorough, and timely problem analysis process cited in Section S7.2 and the

prioritizing of corrective action as required in VPAP - 2801, "Commitment Management,"

Revision 0.

c.

Conclusions

The corrective action program was technically sound, effective, and performed in a

timely manner.

S7.4

Effectiveness of Management Controls

a.

Inspection Scope (81700)

b'.

C.

The inspectors evaluated the overall effectiveness of the licensee's controls for

identifying, analyzing, and resolving problems. The inspectors evaluated the adequacy

of corrective actions to prevent recurring problems.

Observations and Findings

The inspectors reviewed previous audits, self-assessment program documents, LER,

SEL, and DR documents to ascertain the effectiveness of management controls. The

licensee's strong problem analysis program was reflected in the aggressive DR program

and documentation. Adverse events, trends, and problems were identified, analyzed,

and eventually brought to closure through the DR program. The absence of recurring

major regulatory issues, the continued strong support in upgrading the security access

program and security uninterruptable power supply, the successful preparation and

execution of the security tactical performance assessments, the adoption and

implementation of enhanced training programs, and the integration of new technology

into the training and operation of the security program were indicative of the

effectiveness and involvement of management controls. The continued expansion and

refinement of the above discussed management efforts and controls contributed to a

strong security program.

Conclusions

The management controls of the security program were aggressive, effective, and

comprehensive.

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 March 10, 1999. The licensee acknowledged the findings

  • presented .

v

20

The inspectors asked the licensee whether any materials examined during the inspection

should be considered proprietary. No proprietary information was identified.

PARTIAL LIST OF PERSONS CONTACTED

M. Adams, Superintendent, Engineering

R. Allen, Superintendent, Maintenance

R. Blount, Manager, Operations & Maintenance

E. Collins, Director, Nuclear Oversight

M. Crist, Superintendent, Operations

J. Grau, Acting Superintendent, Training

E. Grecheck, Site Vice President

B. Stanley, Supervisor, Licensing

T. Sowers, Manager, Nuclear Safety & Licensing

W .Thornton, Superintendent, Radiological Protection

IP 37551:

IP61726:

IP 62707: .

IP 71707:

IP 71750:

IP 81001:

IP 81502:

IP 81700:

IP 92901:

IP 92903:

Opened

INSPECTION PROCEDURES USED

Onsite Engineering

Surveillance Observation

Maintenance Observation

Plant Operations

Plant Support Activities

Independent Spent Fuel Storage Installation

Fitness for Duty Program

Physical Security Program for Power Reactors

Followup - Operations

Followup - Engineering

ITEMS OPENED, CLOSED, AND DISCUSSED

50-280, 281 /99001-01

IFI

Review of fuel oil piping seismic

requirements (Section 02.1)

50-280/99001-02

NCV

50-280, 281/99001-03

NCV

Failure to update a main control room

procedure prior to the return to service of a

component recently modified by a design

change (Section E1 .1)

Two examples of design control problems

identified by the A/E team (Sections E8.1

and E8.4)

\\J

,.

21

50-280, 281 /99001-04

IFI

Review the acceptability of reduced

minimum flows for the low head safety

injection pumps after piping modifications

(Section E8.1)

50-280, 281/99001-05

NCV

Failure to correctly apply 1 O CFR 50.59 for

a modification to the 125 voe batteries

when an unreviewed safety question

existed (Section E8.5)

Closed

50-280, 281/98001-01

IFI

Review EOG fuel oil requirements (Section

08.1).

50-280, 281/97010-02

IFI

Review licensee actions to resolve AMSAC

enable setpoint issues (Section 08.2).

50-280/99001-02

NCV

Failure to update a main control room

procedure prior to the return to service of a

component recently modified by a design

change (Section E1 .1)

50-281/98201-03

URI

Unit 2 low head safety injection pump

  • minimum flows (Section E8.1)

50-280, 281/99001-03

NCV

Two examples of design control problems

identified by the A/E team (Sections E8.1

and E8.4)

50-280/98201-04

IFI

Motor Thermal Overloads for LHSI pump 1-

SI-P-1 B (Section E8.2)

50-280, 281/98201-08

URI

EOG battery transfer switch (Section E8.4)

50-280, 281/98201-09

URI

DC tie breaker (Section E8.5)

50-280, 281 /99001-05

NCV

Failure to correctly apply 1 O CFR 50.59 for

a modification to the 125 VDC batteries

when an unreviewed safety question

existed (Section E8.5)

50-280, 281 /98201-19

IFI

Recirculation spray system flow (Section

E8.6)

50-280, 281/98007-03

URI

Failure to submit LER within 30-days

(Section E8.8)

Discussed

50-280, 281/98201-05

50-280, 281/98-007-01

22

IFI

VIO

Adequacy of 4160 VAC electrical cables to

withstand fault current (Section EB.3)

Failure to take corrective action for

identified design problems (Section EB. 7)