ML18152A150

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Insp Repts 50-280/88-51 & 50-281/88-51 on 881218-890128. Violations Noted.Major Areas Inspected:Licensee Action on Previous Enforcement Matters,Plant Operations,Plant Maint, LER Review & Followup on Inspector Identified Items
ML18152A150
Person / Time
Site: Surry  Dominion icon.png
Issue date: 02/22/1989
From: Fredrickson P, Holland W, Larry Nicholson, York J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML18152A151 List:
References
50-280-88-51, 50-281-88-51, NUDOCS 8903130270
Download: ML18152A150 (21)


See also: IR 05000280/1988051

Text

UNITED STATES

NUCLEAR REGU.LATORY COMMISSJOi\\'

REGION II

101 MARIETTA STREET, N.\\'\\'.

ATLANTA, GEORGIA 30323

Report Nos.:

50-Z80/88-51 and 50-281/88-51

Licensee:

Virginia Electric and Power Company

Glen Allen, VA

23060

Docket Nos.:

50-280 ,and 50-281

License Nos.: DPR-32 and DPR-37

Facility Name:

Surry land 2

Inspection Conducted:

December 18, 1988 - January 28, 1989

Inspectors:

  • 1). S. /_**fd-6/t;

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Date S i7gned

'-J)) ) __ /::~ ,._. "c .*

Ir*(

__________ _

Ll, ::. York, Seni~r' Resirn*~ liiSpector

/

_ ?/12/57

Date Signed

(

L.

Inspector

onnel: \\,JJ L~F?e, NRR

Approved by:

,

u__ 7.l_ tJ;kV'v\\..

(')_

P.

Fredrickso:n, Chief, sicfun 2A

P'(~v/s4

Date s'i gned

Scope:

Results:

Division of Reactor Projects

SUMMARY

This routine resident inspection was conducted on site in the areas

of licensee action on previous enforcement matters, plant operations,

plant maintenance, p~ant surveillance, licensee event report review,

followup on inspector identified items, and evaluation of the

licensee quality assurance program.

A special evaluation of the

licensee's program used to walk down selected systems prior to unit

restart was also in.eluded in this report.

This evaluation will

continue and be further documented in the next resident inspection

report.

Certain tours were conducted on backshifts or weekends.

Backshift or

weekend tours were conducted on January 2, 7, 8, 10, 11, 12, 14, 15,

16, 17, 21, 22, 23, and 28.

During this inspection period, one additional example of an apparent

violation listed in NRC Inspection Report 280, 281/88-32, one new

violation, and three inspector followup items were identified. These

items. are listed below .

One additional example of apparent violation 280, 281/88-32-01 was

identified in paragraph 8.a during closeout of unresolved item 280,

281/88-28-02 regarding the emergency diesel generator (EOG) room

louvers.

Th2 ,.:xar:1ple involved a f2ilure to translate appropriate

design requirements into specifications and procedures.

2

One violation was identified in paragraph 3.b with regard to several

examples of operations problems with failure to fol]ow procedures

and/or inadequate procedures (280, 281/88-51-01).

One inspector followup item was identified in paragraph 4.b with

regard to the review of the instrument air system for operability

(280, 281/88-51-02).

One inspector followup item was identified in paragraph 8.d with

regard to a reviev1 of the evaluation of Whip restraints on the

pressurizer surge line (281/88-51-03).

One inspector followup item was identified in paragraph 9.a with

regard to followup on licensee evaluation of replica parts issue

(280, 281/88-51-04) .

REPORT DETAILS

1.

Persons Contacted

2.

Licensee Employees

  • J. Bailey, Superintendent of Operations
  • R. Bilyeu, Licensing Engineer
  • R. Blount, Superintendent of Technical Services
  • E. Grecheck, Assistant Station Manager
  • M. Kansler, Station Manager
  • G. Miller, Licensing Coordinator, Surry
  • H. Miller, Assistant Station Manager
  • J. Ogren, Superintendent of Maintenance
  • T. Sowers, Superintendent of Engineering
  • D. S. Hart, Supervisor, Quality

Other licensee employees contacted included control room operators, shift

technical advisors, shift supervisors and other plant personnel.

  • Attended exit meeting .

During this inspection period, a third NRC resident inspector reported for

duty at the Surry Power Station.

The third inspector, Mr. John W. York,

was assigned to the station to supplement the resident inspection effort

due to the NRC management's increased concern of recent events and

identification of programmatic issues associated with the design and

management overview of operation of the facility.

The NRC Region II Section Chief, F. Cantrell, visited the Surry Power

Station on January 12 and 13, 1989.

Mr. Cantrell toured the plant

including the low level intake structure and the Unit 1 containment.

Mr. Cantrell also participated in a meeting between the NRC.residents and

licensee management.

The meeting was held to discuss the current status

of issues and the schedule for corrective actions associated with the

issues.

Plant Status

Unit 1 began the reporting period in a refueling shu.tdovm.

The reactor

vessel head was properly torqued and the unit entered cold shutdown

conditions.

After completion of work which required maintaining vessel

water level below the flange, the reactor coolant system was filled and

reactor coolant pumps were jogged to vent the system.

The reactor coolant

sys tern temperature was increased and a bubb 1 e was formed in the

pressurizer on January 11.

Reactor coolant temperature was increased

above 150 degrees F and a satisfactory hydrostatic test of piping repairs

1.,ias accomplished on the

11 B" steam generator feedwater piping.

The unit

2

remained in cold shutdown at the end of the inspection period while

repairs continued on safety-related pumps.

Unit 2 began the reporting period in a refueling shutdown.

Fuel offload

was completed on December 19, 1988, and empty vessel work was accomplished

including an inspection for foreign material in the system.

After

completion of empty vessel work, the core reload was completed on

January 6, 1989.

The head was properly torqued and the unit entered the

cold shutdown condition on January 16, where it remained while repairs

continued on various plant components.

3.

Operational Safety Verification

(71707)

The inspectors conducted daily inspections in the following areas:

control room staffing, access, and operator behavior; operator adherence

to approved procedures, technical specifications, and limiting conditions

for operations; examination of panels containing instrumentation and bther

reactor protection system elements to determine that required channels are

operable; and review of control room operator logs, operating orders,

plant deviation reports, tagout logs, jumper logs, and tags on components

to verify compliance with arproved procedures.

The inspectors conducted weekly inspections in the following areas:

verification of operability *of selected engineered safety feature (ESF)

systems by valve alignment, breaker positions, condition of equipment or

components, and operability of instrumentation and support items essential

to system actuation or* performance. Plant tours were

conducted which

included observation of general

plant/equipment conditions, fire

protection and preventative measures, control of activities in progress,

radiation protection controls, physical security controls, plant

housekeeping conditions/cleanliness, and missile hazards.

The inspectors

routinely monitor the temperature of the auxiliary feedwater pump

discharge piping to ensure steam binding is prevented.

The inspectors conducted biweekly inspections in the following areas:

verification review and walkdown of safety-related tagouts in effect;

review of sampling program (e.g., primary and secondary coolant samples,

boric acid tank samples, plant_liquid and gaseous samples); observation of

control room shift turnover; review of implementation of the plant problem

identificatio1 system; verification of selected portions of containment

isolation lineups; and verification that notices to workers are posted as

required by 10 CFR 19.

Inspections included areas in the Units 1 and 2 cable vaults, vital

battery rooms, steam safeguards areas, emergency switchgear rooms, diesel

generator rooms, control room, auxiliary building, Units 1 and 2

containments, cable penetration areas, independent spent fuel storage

facility, 1 ow 1 evel intake structure, and the safeguards va 1 ve pit and

pump pit areas. Reactor coolant system leak rates were reviewed to ensure

that detected or suspected 1 eakage from the system was recorded,

investigated, and evaluated, and that appropriate actions were taken, if

3

required.

The inspectors routinely independently calculated reactor

coolant system (RCS) leak rates using the NRC Independent Measurements

Leak Rate Program (RCSLK9).

On a regular basis, radiation work permits

(RWPs) were reviewed and specific work activities were monitored to assure

they were being conducted per the RWPs.

Selected radiation protection

instruments were periodically checked, and equipment operability and

calibration frequency were verified.

In the course of monthly activities, the inspectors included a review of

the 1 i ce_nsee

I s phys i ca 1 security program.

The performance of various

shifts of the security force was observed in the conduct of daily

activities to include: protected and vital areas access controls;

searching of personnel, packages and vehicles; badge issuance and

retrieval; escorting of visitors; and patrols and compensatory poits.

a.

b.

Walkdown o( Instrumentation and 125VDC Cabinets

On December 23, the inspector witnessed field walkdowns in progress

in the Unit 2 7100 Series Instrumentation cabinets.

This field

verification, detailed in an engineering memo dated December 6, 1988,

was in reaction to an NRC concern identified during the service water

Safety System Functional Inspection (SSFI).

The scope of this effort

involved inspecting all external connections in both units cabinets

using the latest drawings.

The licensee engineering staff at their

Innsbrook office has been tasked with evaluation and disposition of

the discrepancies that are identified.

The inspector observed the

wa 1 kdowns in progress and discussed the overa 11 process with the

staff.

No discrepancies were noted.

Operational Problems Encountered During This Inspection Period

During the latter part of this inspection period, several operational

related problems occurred that appeared to be a result of inattention

to detail. Although all of the problems were not directly attributed

to operator mistakes, the operations department had involvement in

all areas.

The following is a listing of these problems.

( 1)

CC-TV-209A Mechanical Stop Blocking Device Failed.

On January 11, operators attempted to block open the air

operated containment isolation valve (CC-TV-209A) which allows

for fl ow of component coo 1 i ng water to the

II A

II residua 1 heat

removal (RHR) heat exchanger for Unit 2.

This evolution was

being done in preparation for maintenance on the air portion of

the valve.

When the air was restored to the valve after

installing the blocking device, the valve unexpectedly closed,

shearing the blocking bolt.

The operators immediately reopened

the valve to restore component cooling water flow to the RHR

heat exchanger and wrote a deviation report

(S2-89-035)

documenting the unexpected action.

(2)

4

Inadvertent Flooding of Unit 2 Cavity Area Due to Improper

System Alignment.

On January 11, operators were completing a system realignment on

Unit 2 in accordance 1vith procedures.

While completing

operational procedure 14.3, the refueling water storage tank

(RWST) backflowed into the reactor coolant system and out of the

reactor vessel flange.

The reactor vessel head had just been

reset earlier that day.

The problem occurred due to improper

system alignment and related to a procedure which had temporary

changes and was difficult to follow.

Operators secured the

improper flowpath and drained the excess water to the

containment sump.

The operators wrote a deviation report

( S2-89-037) documenting the pro bl ems.

The operators involved

met with the Operations Superintendent to discuss the problems

associated with this event.

It was concluded that while the

procedure could have been clearer, the operator failed to follow

the procedure guidance for recovery from this abnormal system

alignment.

(3)

1-SW-432 Tagged Open, Found Closed.

On January 13, during a walkdown by the Institute of Nuclear

Power Operations (INPO), service water drain valve l-SW-432 was

found to be shut although it was tagged open in accordance with

station procedures.

Operations personnel returned the valve to

the -open position and wrote a deviation report ( Sl-89-88) to

document the problem.

Operations personnel also conducted a

selected tagout audit and no additional problems were

identified.

(4)

Suction to Unit 1 Operating Charging Pump Isolated

On January 14, Unit 1 operators received an alarm on seal

injection to the reactor coolant pump (RCP) decreasing to

approximately

11 0

11 flow.

Also, the operators noticed a low

amperage reading on the operating charging pump.

Additional

evaluation of the control panel determined that the suction

flowpath to the charging pump from both the RWST -and the volume

control tank (VCT) were isolated.

This isolation resulted in a

partial loss of seal injection to the running RCP, and operation

of a chargin[ pump with an inadequate suction supply of water

for one or two minutes.

The operators reestablished a flowpath

from the RWST to the operational charging pump and indication of

flows and amps returned to normal.

Operations personnel then

documented the problem with a deviation report (Sl-89-94) and

also determined that the charging pump which was running had an

inboard seal leak .

Initial investigation of the problem determined that the

assigned unit operator had turned the unit over to the third

( 5)

(6)

5

operator approximately five minutes prior to the event.

During

the turnover, the unit operator failed to speci fi ca lly identify

that the charging pump suction was aligned to the RWST during

the board walkdown.

This information may have contributed to a

slight recovery delay; however, the reason that the RWST suction

flowpath was lost (LCV-11150 shut) has not been determined.

The

personnel involved performed a detailed review of the event,

including construction of the sequence of events from the

Emergency Response Facility Computer System (ERFCS).

In

addition, personnel in the vicinity of the LCV-11150 breaker at

the time of the event were interviewed.

No cause for the

closure of the suction valve has been determined at this time.

CC-TV-109A Mechanical Stop Blocking Device Failed.

On January 15, operators were attempting to block open the air

operated containment iso-lation valve (CC-TV-109A) that allows

for flow of component cooling water to the

11A

11

RHR heat

exchanger for Unit 1. This evolution was being done to test the

blocking device and the operators had the

11 B

11 RHR heat exchanger

in service, which did not require the flowpath through the 109A

valve.

Also, an operable RCS Loop was available to remove decay

heat, if required.

When the air was restored to the valve after

installing the blocking device, the valve went unexpectedly to

the closed position shearing the blocking bolt. This action was

similar to the problem that occurred on the Unit 2 valve on

January 11.

The operators wrote a deviation report (Sl-89-102)

to document the action.

The licensee concluded that the

b 1 oc king .device is not designed to keep the va 1 ve open with

instrument air pressure inadvertently acting to close the valve.

Initial

investigation determined that the shift orders

instructed the operators to install the blocking device in

accordance with procedure FCA 1. 00 ( 120) to determine if the

device wou 1 d work.

The 1 i censee has determined that the

procedure would work satisfactorily for its intended purpose

(i.e. loss of instrument air).

However, in the presence of

instrument air, the pneumatic relay causes the valve to go

closed with a force sufficient to break the blocking device.

The licensee concluded that FCA 1.00 should not be used for

maintenance evo 1 uti ons and wi 11 prepare a new procedure to

address establishment of proper controls for maintenance.

Drain Valves in Turbine Building Found Shut With Pipe Caps

Installed; But Were Tagged Open.

On January 17, during an INPO walkdown three additional service

water drain valves were found to be shut when they were tagged

open in accordance with station procedure.

Also, one secondary

plant drain valve was found open when it was tagged shut.

Operations personnel wrote four deviation reports (Sl-89-121,

6

122, 123, 124) documenting the problems.

This condition is

similar to the January 13 problem.

Licensee management, by memo

dated January 18, reemphasized to all personnel the policy that

only operators, properly authorized, are permitted to operate

plant components.

(7)

Reactor Coolant Pump Start Without Proper Verification That Loop

Flow Instrumentation Was Available.

On January 19, the Unit 1

11 B

11 reactor coolant pump was started

in accordance with procedure.

After approximately 10 seconds,

the pump was secured due to no flow indication in the loop.

Subsequent investigation determined that the loop flow

transmitters were tagged out.

Operations personnel wrote a

deviation report (Sl-89-139) documenting the problem.

Licensee

management stated that the requirements to verify that al 1

supporting components are available prior to operation of a

cpmponent is the responsibility of the Shift Supervisor.

The

licensee is still reviewing the causes of this event.

(8)

Operation of Charging Pump Without Proper Recirculation Flow

Alignment.

( 9)

On January 19, the Unit 1

11 P..

11 charging pump was started in

accordance with procedure.

After running for several minutes,

operators noticed that the pump amperage was oscillating and the

discharge piping at the pump was vibrating.

The

11 B

11 charging

pump was started and the

11A

11 charging pump discharge valve was

shut.

After approximately 20 seconds, the

11A

11 charging pump

amperage started to decrease.

The operator immediately secured

the

11A

11 charging pump.

Review of the control panels determined

that the red and green valve position indication lenses for the

11A

11 charging pump recirculation isolation valve 1-1ere reversed.

This condition resulted in the operators thinking that the

recirculation flow isolation valve was open prior to pump start

when the valve was actually closed.

The reversed lens condition

was corrected and a review of all other indication lens

positions was conducted.

Operations personnel wrote a deviation

report (Sl-89-144) documenting the problem.

The licensee is

reviewing this problem to determine if any additional corrective

actions are required.

Operation of Containment Vacuum Pump with Blank Installed in

Suction Flowpath.

On

January 21, operations personnel attempted to start

containment

1A

1 vacuum pump (1-CV-P-lA) and determined that no

flow was occurring during operation.

The pump was secured and

subsequent investigation determined that a blank was installed

in the suction line at penetration # 72 in containment.

Operations personnel wrote a deviation report (Sl-89-159)

7

documenting the problem.

A review of the temporary

modifications logs indicates that the subject blank was properly

documented as being ins ta 11 ed and removed as required by

procedure.

The licensee is reviewing this problem to determine

why the blank was still installed.

After the first two problems occurred, the reside*nt inspectors

discussed the situation with licensee management including the

operations supervisor and station manager.

Initial action taken

by the 1 icensee was a briefing of all operations shifts by the

operati~ns supervisor.

The briefing specifically emphasized

that the operators must pay attention to detail and ensure that

each evolution being performed is done correctly.

After the next three problems occurred, the resident inspectors

again discussed the situation with station management.

On

January 14, the senior resident inspector discussed the problems

1-Jith the station manager and the Vice President - Nuclear.

The

inspector expressed concern with regard to the situation and

stated that. licensee actions in these areas will be closely

monitored.*

The inspector was informed that additional actions

were being implemented, which requires each operations evolution

to be reviewed by two operators (person performing evolution and

his supervisor) prior to performance.

Management also stated

that they were reemphasizing to station personnel that doing the

job right the first time and not using schedule as the primary

requirement over qua 1 ity is the way that management wants the

job done.

During the following week, the last four problems occurred.

The

residents

held several

discussions with station management

during this time frame, and again expressed concern that it was

not evident that management

1 s actions to correct the problems

were effective.

The station manager assured the resident

inspectors that the adverse trend would be corrected.

He stated

that station management met with all department heads

on

January 20, to review these and other occurrences, and to

discuss common threads and corrective actions.

Each occurrence

was reviewed with emphasis on determining lessons learned and

accountability, as well as methods to communicate the standards

to all personnel.

As a result of the meeting, as well as

earlier discussions between the Superintendent .of Operations and

operations supervision, station management took the following

actions:

A requirement that the shift supervisor pre-brief all off-normal

operational evolutions with the personnel involved in order to

provide additional assurance that proper preparation and review

are being conducted .

C.

8

Implementation of a policy in which

any

operations

personnel involved in an event are immediately, relieved of

watch duties, and required to prepare and present a report

detailing

the

event problem,

causes,

and

corrective

actions.

A requirement that operations perform a 100% audit of

current tagging records to assure that pl ant status is

accurate.

The primary responsibility for the Unit 1 component status

control has been returned to the on-shift Shift Supervisor.

This action allows for more shift involvement in the

control and review of the return of components and systems

from maintenance.

A meeting with operations personnel, the station manager,

and

the

operations

superintendent

to

discuss

job

performance, attention to detail, and doing the job right

the first time.

This meeting reiterated the management

requirement that doing the job right is paramount over

schedule.

The residents consider that the senior station management is properly

sensitized to correcting the problems.

Virginia Power Corporate

Management also considers that attention to detail, doing the job

right the first time, and not trying to maintain schedule at the cost

of quality are requisite requirements.

However, the failure to get

this message down to the working level is one of the reasons that the

problems listed above are still occurring.

Surry Technical Specification 6.4 requires that detailed written

procedures with appropriate check-off lists and instructions shall be

provided and followed *for normal startup, operation, shutdown,

testing, and conduct of preventative or corrective maintenance

operations of all systems and components involving nuclear safety of

the station.

The operations related problems as listed in paragraphs

3.b.l, 3.b.2, 3.b.3, 3.b.5, 3.b.6, 3.b.8, and 3.b.9 above are

identified as a violation* of Technical Specification 6.4.

Violation

280, 28J/88-5J-Ol, Failure to follov, procedure and/or inadequate

procedure.

Licensee 10 CFR 50.72 Reports

On January 6, a four hour report in accordance with 10 CFR 50.72 was

made to the NRC with regards to an inadvertent start of the No. 3

EOG.

During of testing of the EOG, the diesel automatically started

after shutdown.

The restart occurred when the diesel control switch

was returned to- auto.

Investigation by the licensee revealed that

one of the electrical relays supplied the auto start signal due to

failure of a diode in the start circuitry.

No valid start signal was

9

determined to be at the start relay.

The relay and diode were

replaced and appropriate post maintenance testing was performed.

On January 26, 1989, the licensee reported to the NRC in accordance

with 10 CFR 50.72 that damaged power cables had been discovered for

both Unit 2 inside recirculation spray (IRS) pumps.

During previous

work to replace a damaged flex conduit on the Unit 1-B IRS pump, the

licensee noted that the fiberglass braid jacket was frayed and in

some areas missing.

In addition, the silicon rubber insulation was

cracked, exposing the copper wiring.

This prompted additional

inspection of the other Unit 1 pump and the two pumps in Unit 2.

From the results of this inspection, the licensee determined that the

B pump in Unit 1 and the A and B pumps in Unit 2 were potentially

inoperable due to degraded power cables.

A region-based inspector

examined the cable as discussed in NRC Inspection Report 280,

281/89-03.

The licensee evaluation of the failure mechanism was

being conducted when the inspection period ended.

4.

Operational Readiness Program Review

(71710)

During the last half of 1988, several problems have been identified at the

Surry Power Station which resulted in questioning the design basis of the

Service Water System and also in questioning the known configuration of

other safety-related systems.

As a result of these problems, the

licensee, in a meeting in NRC headquarters on December 22, 1988, stated

that they would conduct a safety system review to assure a comprehensive

search and resolution of problems prior to the initial unit startup. This

review effort was sorted by systems that are referenced in the station

Emergency Operating Procedures (EOP) and assigned to the newly formed

systems engineering group at the station.

The licensee presented a broad

overview of the review and concluded that a Station Nuclear Safety and

Operating Committee (SNSOC) review and acceptance of the findings would be

required prior to restart.

In conjunction, the licensee stated that the

site Quality Assurance (QA) group would perform an independent assessment

of the review activities.

The licensee was unable to address in detail

the specifics of the review activities and, therefore, agreed to meet at a

later date.

The licensee, in a January 5, 1989, meeting in the NRC Region II offices,

presented a more detailed overvi~w of the operational readiness program.

The licensee's Vice President - Nuclear presented a chart which outlined

the new engineering organization and discussed to some extent how this

organization would be providing support to the stations in the future.

The Surry Station Manager then provided a fairly detailed overview of how

system reviews would be conducted.

The controlling Engineering Work

Request (EWR), which is discussed below, was the major topic of

discussion.

Additional licensee personnel addressed the mechanics of the

system/component selection, the method and technique to be used for system

\\\\1alkdowns, the power supply verification process, and how additional

i

10

testing and documentation review would be accomplished.

The meeting

generally provided a satisfactory understanding of the operational

readiness program to the NRC staff.

The controlling document for this effort was stated to be the Engineering

Work Request (EWR)88-584,

11System Review for Startup/Surry/Units 1 & 2.

11

The stated purpose of this EWR was to bolster confidence that systems will

operate as expected.

The scope of this EWR outlines the overall method in

which this task is to be performed as follows:

a.

Determination of Systems to Be Included

b.

Plant Configuration Confirmation

c.

Power Supply and Train Independence Confirmation

d.

Assessment of Outstanding Issues for Each System

e.

Functional Testing

f.

Documentation and Acceptance of Results

The resident inspectors extensively monitored the licensee actions as

. implementation of each of the above items began.

The following details

the specifics of this inspection effort.

a.

Determination of Systems to Be Included.

The licensee utilized the EOPs to identify components or systems

requiring review.

This broad group of procedures included Emergency

Procedures (EP), Fire Contingency Action (FCA) Procedures, Emergency

Contingency Action (ECA) Procedures, and Functional Restoration

Procedures ( FRP).

A task team was formed that reviewed the above

procedures and identified all components or systems that require

review.

The team, which included a senior reactor operator (SRO),

determined if each component was necessary for the safe completion of

the procedure, and annotated this evaluation on the master list. The

EWR required this determination to be made based on the Updated Final

Safety Analysis Report (UFSAR) assumptions, safety related versus

non-safety related equipment, and the technical specification

requirements.

The inspectors reviewed the final results of the task team and were

in agreement with the general method used to bound the scope of this

effort.

This review included a sample of components that are

referenced in a procedure, yet determined to be exempt from the

walkdowns.

The inspectors noted that the systems review for each

unit did not include the entire cross-tie piping and the required

equipment in the opposite unit.

The licensee acknov1ledged this

comment and was developing an evaluation as the inspection period

ended.

The inspection will continue in this area.

l

11

b.

Plant Configuration Confirmation

This portion of the EWR deals with the system walkdowns performed by

the system engineers.

The intent of these walkdowns is stated as

follows:

Insure that components are physically located in the system as

per the station drawings.

Insure that proper identification is provided for the

components.

Insure that components are in proper orientation (e.g. check

valves in proper direction).

Insur~ that discrepancies are identified and addressed.

The method utilized for these walkdowns was for the system engineers

to take the marked up drawings provided by the task team previously

discussed and, starting from a known location, confirm the location

of co~ponents with respect to the identified drawings.

The results.

of these walkdowns were documented on a

11Walkdown Report

11

, \\vith any

discrepancies listed on an attached

11 Items of Note

11 page.

Following

the walkdown, the system engineers discussed their findings with a

designated SRO and determined whether the discrepancy constituted a

11 startup concern

11 and required any other appropriate action to be

taken.

This action to resolve each issue was documented adjacent to

each item on the

11 Items of Note

11 page.

The inspectors

1

review of the system walkdowns included the

following:

Independent walkdowns and comparison with the licensee results

for portions of the following systems:

Safety Injection Accumulator lA

Emergency Diesel Generator Starting Air

Containment Spray

Auxiliary Feedwater - Main Feedwater (Feedwater) Outside

Containment

Main Steam (licensee had not completed walkdown)

Compressed Air

Walkdowns with the system engineers to observe t~chnique and

identification of items for portions of the following systems:

Service Water

Chemical and Volume Control

12

Witness the determination of actions to resolve each item

by

the systems engineer and the SRO on portions of the following

systems:

Service Water

Radiation Monitors

Residual Heat Removal

Component Cooling

Containment Spray

Auxiliary and Safeguards Building Ventilation

Main Control Room Envelope Ventilation

Review the system engineer

1s items identified during their

walkdown of the following systems:

Emergency Diesel Generator Starting Air

Containment Spray

Inside & Outside Recirculating Spray

Residual Heat Removal

The following are examples of the licensee

1s findings that were

identified during walkdowns of some of the systems:

Numerous tagging problems, e.g., brass instead of stainless*

steel tag, no tag, tag attached to the wrong part of component,

etc.

Broken or loose electrical conduits

Housekeeping

Electrical junction boxes, e.g., no cover, missing screws, or*

bolts, boric acid leak onto box, etc.

Missing insulation

Outdated calibration stickers

Valve handwheels loose, missing or obstructed

Material conditions, e.g., rusty fasteners, rusty base plate,

rusty piping, cracked concrete, etc.

Too much grease on motor operated valves (MOV)

Bent travel indicator on valve, bent scale plate

Supports/restraints, e.g., missing, missing spring can

The inspectors concluded that the system engineering walkdowns

appeared adequate.

In some instances, deficiencies were identified

13

by the walkdown on portions of the system that were not highlighted

to be included.

The inspectors also concluded that the threshold for

categorizing deficiencies for startup was adequate.

A concern was

raised, however, during the inspectors in depth look at the station

instrument air system.

The instrument air compressors are identified

in the UFSAR as being the primary (normal) supplier to the instrument

air system.

In addition, the instrument air compressors are powered

from an emergency bus to mitigate the consequences of a loss of

offsite power event.

In reality, and as described in the plant

training manual,

the service air compressors are used as the primary

supply to the instrument air system.

It was evident from the

instrument air system walkdown that the instrument air compressors

have not been routinely maintained in an operable and usable

condition.

The 1 i censee acknowledges the above comments and has

committed to return the instrument air compressors to full

operability prior to a unit restart.

This item is identified as an

Inspector Followup Item (IFI) 280, 281/88-51-02, Review of the

Instrument Air System Status Prior to a Unit Restart.

c.

Power Supply and Train Independence Confirmation.

This subject was inspected by reg1on-based inspectors and documented

in NRC Inspection Report 280, 281/89-01.

d.

Assessment of Outstanding Issues for Each System.

This item is covered in Attachment

IV to EWR 88-584 and includes a

review of outstanding temporary modifications and/or jumpers, station

deviations, commitment items, outstanding safety-related work orders,

outstanding EWRs and open Type 1 engineering evaluations .. The system

engirieers have been tasked with reviewing the above items pertaining

to their particular system and evaluating if closure of the item is

possible prior to unit startup.

For those items that \\vill not be

closed prior to startup, a justification for not completing the item

must be completed and approved by the Superintendent of Technical

Services.

-

The overal 1 status of the engineering work as of January 26, 1989,

was as fo 11 ows:

System Walkdowns

Discrepancies Identified

Discrepancies Cleared

Startup Issues

89% Complete

2853

703

55

It should be noted that a large majority of the discrepancies identified

consisted of minor concerns that do not hinder operation of the systems.

The appropriate system engineers were just starting their document review

when the inspection period ended.

The inspectors performed a broad

overv i ev1 of each document fl owpath and wi 11 continue this inspection

effort by following a representative sample of each of the above subjects

14

through the system engineer and on to final disposition.

In addition, the

inspectors will continue to perform some additional walkdowns of systems

as well as observe selected deficiencies that have been identified.

Within the areas inspected, no violations or deviations were identified.

5.

Maintenance Inspections (62703)

During the reporting period, the inspectors reviewed maintenance

activities to assure compliance with the appropriate procedures.

On January 19, the inspectors witnessed routine disassembly and cleaning

of the

1 B

1 train chiller and associated service water strainer and piping

that supplies chilled water to the main control room and emergency

switchgear rooms.

This \\'/Ork was being performed in accordance with

maintenance procedtJrP.~ MMP-C-VS-269,

11 Control Room Chiller Condenser Tube

Cleaning

11

, and VS-YS-M/2W,

11 Cleaning of Control/Relay Room Chiller Pump

Inlet Y-Type Strainers

11

The inspector examined the condition of the

condenser prior to cleaning and noted a fairly extensive buildup of river

sludge in the tubes.

The maintenance staff indicated that this was

representative of a condenser unit that had remained idle for some period,

and noted that there was no strong evidence of biological growth present.

The inspector verified procedure adherence for the work being performed.

No discrepancies were noted.*

Within the areas inspected, no violations or deviations were identified.

6.

Surveillance Inspections

(61726)

During the reporting period, the inspectors reviewed various surveillance

activities to assure compliance with the appropriate procedures as

follows:

a.

Test prerequisites were met.

Tests were performed_ in accordance with approved procedures.

Test procedures appeared to perform their intended function.

Adequate cocrdination existed among personnel involved in the test.

Test data were properly collected and recorded.

Component Cooling Water Heat Exchanger Test

The inspectors revievJed the special test of the component cooling

water heat exchangers (CCWHX) in accordance with Special Test ST-243,

11 Component Cooling Water Heat Exchanger Water Box Level Test

11

, dated

January 19, 1989.

This test collects performance data of the two

upper CCWHX without the aid of the vacuum priming system and with the

intake canal level at 20 feet plus or minus 1 foot.

This issue was

b.

15

initially identified and discussed in NRC Inspection Report 280,

281/88-14, when the inspector observed an apparent dependency of the

CCWHX on the non-safety related and non-seismically qualified vacuum

priming system.

The licensee committed to testing this system to

demonstrate that adequate service water flow can be maintained as

documented in

NRC Inspection Report 280, 281/88-28 (IFI 280,

281/88-28-03).

The inspectors reviewed the proposed test, witnessed

installation of test equipment, and discussed the test with the

operations staff.

The actual test was delayed due to plant

conditions, therefore, this inspection effort will continue into the

next inspection period. This IFI remains open.

Charging Pump Operability Test

On

January 20,

1989,

the inspectors witnessed operability

verification of the 1-CH-P-lA charging purip in accordance \\'Jith

periodic test procedure 1-PT-18.7,

11 Charging Pump Operability And

Performance Test.

This test was being conducted to assess any

damage that may have occurred when the pump was started with the

recirculation line inadvertently isolated (discussed in paragraph

3.b.8). The pump met the acceptance criteria for fully operable with

the exception of the vibrations on the outboard pump bearing, which

were slightly in the alert range.

The inspector witnessed the

communic_ation and data collection in addition to verification of

compliance with the test procedure.

No discrepancies were noted.

7.

Licensee Event Report (LER) Review

(92700)

The inspectors reviewed the LER's listed below to ascertain whether NRC

reporting requirements were being met and to determine appropriateness of

the corrective actions. The inspector's review also included followup_ on

implementation of corrective action and review of licensee documentation

that all required corrective actions were complete.

LERs that identify violations of regulations and that meet the criteria o~

10 CFR, Part 2, Appendix C,Section V shall be identified as Licensee

Identified Violations (LIV) in the following closeout paragraphs.

LIVs

are considered first-time occurrence violations which meet the NRC

Enforcement Policy for exemption fro~ issuance of a Notice of Violation.

These items are identified tc allow for proper evaluations of corrective

actions in the event that similar events occur in the future.

(Closed)

LER 280/88-30,

Excessive Leakage Past Reactor Cavity Seal Ring.

The LER involved the leakage of approximately 25,800 gallons of water past

the reactor cavity seal and into the containment sump.

This event was

investigated by an NRC Augmented Inspection Team with the results

documented in NRC Inspection Report 280, 281/88-33.

The redesign of the

seal and additional corrective actions were inspected by region-based

inspectors as documented in NRC Inspection Reports

280, 281/88-38 and

88-47.

Appropriate testing inspections were documented in NRC Inspection

Reports 280, 281/88-41 and 88-45.

This LER is considered closed.

  • 8.

16

Licensee Action on Previous Inspection Findings (92701 and 92702)

a.

(Closed) Unresolved Item (URI) 280, 281/88-28-02, Review of Safety

Classification of Emergency Diesel Generator (EOG) Room Louvers.

This item involved the non-safety grade room louvers that must open

to allow combustion and cooling air to the EDGs.

In addition, the

proper operation of the louvers was not verified by a periodic test

and the maintenance on the louvers was not commensurate with their

importance to safety.

The licensee has subsequently maintained the

louvers in a failed open condition until the system can be upgraded.

This item is identified as an additional example of apparent

violation 280, 281/88-32-01 for failure to translate appropriate

design requirements into procedures and drawings.

b.

(Closed)

URI 280, 281/88-36-03, Review of Additional Licensee

Evalu?.tion Addressing Timely Determination of System Operability and

Generic Evaluation of Problems.

This item was identified in NRC

Inspection Report 280, 281/88-36.

In that report, the inspectors

determined that the licensee's actions with regard to timely

eva 1 uati on of operabi 1 i ty from a design and emergency procedures

perspective should be reviewed.

Licensee management agreed with the

inspector's concern and revised the administrative procedure

(SUADM-0-12, "Operational Department Notifications") to insure that

better guidance is provided to the Shift Supervisor in order to

properly evaluate operability of safety-related components.

The inspectors also identified a concern with regard to generic

evaluation of the leaking pipe joint as related to other similar

joints in the system.

During this inspection period, the inspector

was provided a copy of the engineering evaluation of the pipe joint

condition.

In that report, the engineer stated that all similar

joints would be reviewed and repaired as necessary.

The inspector reviewed the licensee's response to the generic

concerns and also determined that generic reviews would be

appropriately addressed in the future by the new realignment of the

engineering organization.

The inspector considers that licensee

response in this area is adequate to close this unresolved item.

c.

(Closed) (IFI) 280/88-36-02, Walkdown of Containment Spray System.

d.

This item identified several minor discrepancies discovered during an

inspector ~alkdowrr of selected portions of the Unit 1 containment

spray system.

The inspector reviewed the same discrepancies noted by

the system engineer during his walkdown of this system, and reviewed

the documented corrective actions to be performed.

The actions taken

by the licensee regarding these discrepancies appear to be adequate,

therefore this item is considered closed .

(Open)

NRC

Bulletin 88-11, Pressurizer Surge Line Thermal

Stratification.

This bulletin concerns the unexpected movement of

the pressurizer surge line due to thermal stratification which could

17

result in high local stresses, fatigue or functional impairment of

the line.

The inspectors observed the licensee action taken to

satisfy paragraph 1 a. of the bulletin.

This paragraph requested

that the licensee conduct a visual inspection of the pressurizer

surge line to determine if there is any gross discernible distress or

structural damage in the line, including piping, piping supports,

pipe whip restraints, and anchor bolts.

On Unit 1, no gross deformation of supports or piping was noted.

One

flat area on the inside diameter approximately six by six inches was

noted.

This area was not near a support and probably occurred during

pipe bending.

In the area Qf the five C-shaped whip restraints, the pipe had small

smoothly worn areas approximately two inches long by one inch wide by

a maximum of 1/64 inch deep.

The most notable indications were on

the bottom of the pipe, but indications were also noted on the top of

the pipe in the area of several whip restraints.

The indications

were caused when a two-inch wide buildup area on the whip restraint

was contacted by the surge line during thermal expansion.

Stone and

Webster has evaluated the indications for the licensee and they are

acceptable.

On Unit 2, none of these types of indications were noted.

However,

some loose nuts were noted on the inside of whip restraint No. 3.

One restraint had a bent rod and two other spring can rods were

offset approximately three inches from plumb.

This offset would

increase once the surge line grows due to thermal expansion.

Three

of the five spring cans were bottomed out on the load indicator. All

of this is being evaluated by Stone and Webster engineering.

This is

identified as IFI 281/88-51-03, Evaluation of Whip Restraints on

Pressurizer Surge Line.

The inspector entered Unit 1 containment with the cognizant Stone and

Webster engineers on January 16, 1989, and Unit 2 on January 18,

1989. * The inspectors performed a visual inspection to verify the

above reported results and also inspected the surge line supports and

whip restraints to determine if the licensee had detected all

apparent damage.

The inspectors did not note any other damage.

9.

Evaluation of Licensee Quality Assura~ce Program Implementation

(35502)

a.

Replica Parts in Safety-Related Valves and Pumps

During this inspection period, the licensee identified a potential

problem associated with the station procurement process for the

purchase of sleeves, bushings, bearings, and/or shafts during the

period from approximately 1975 to 1983.

The potential problem was

discussed between the residents and the station manager on

January 11, 1988.

In that discussion, the station manager stated

that the problem was limited to approximately 270 to 280 purchase

18

orders (POs) from two suppliers (STURM and BEAVCO).

The issue had to

do with inappropriate documentation of the procured parts for use in

safety-related applications.

When the procurement problem was

discovered in 1983, the licensee took actions to purge the suspect

parts from the warehouse inventory.

However, at the time of

reassembly of the Unit 2 inside recirculation spray pumps during this

current outage, inappropriate parts procured from STURM were

discovered, prompting a reviev1 of the procurement process.

This

review identified the fact that actions to purge the suspect parts in

1983 were not adequate.

On January 13, 1989, the licensee held a meeting on site at which

time the residents and the NRC section chief for Surry were briefed.

The licensee also provided a plan to resolve the issue.

In that

meeting the 1 icensee identified all susceptible safety-related

components which must be evaluated for possible replica parts.

These

components include the pressurizer power operated relief valves

(PORVs), charging pumps, inside and outside recirculation spray

pumps, containment spray pumps, residual heat removal

pumps,

auxiliary feedwater pumps, low head safety injection pumps, emergency

service water pumps, component coo 1 i ng water pumps, boric acid

transfer pumps, charging pump cooling water pumps, charging pump

service water pumps, emergency diesel generator fuel oil transfer

pumps, spent fuel pit cooling pumps, and control room chiller service

water pumps.

The licensee formed a task team to identify the

component priority list, to identify replica parts in the components

if applicable, to resolve acceptability of replica parts in

components, and to document all corrective actions associated with

this issue.

The residents were provided with a listing of the team

members and also provided assurances that no other known replica

parts problems presently existed.

On January 25, the residents were provided with a memorandum from the

Engineering Superintendent to the Surry Station Manager addressing

the status of the replica parts issue.

In that memo, the licensee

stated that based.on a review of the maintenance and procurement

history for safety-related pumps and PORVs listed above, the task

team has determined that no replica parts are installed in the

safety-related pumps and PORVs except for one low head safety

injection pump (1-SI-P-lJl.), one spent fuei cooling pump, and one

component cooling water pump.

The licensee intends to replace the

replica parts in the low head safety injection pump prior to Unit 1

restart.

The residents will monitor the maintenance activity on this

pump and conduct additional reviews of documentation in this area

prior to restart.

This item is identified as IFI 280, 281/88-51-04,

Followup on Licensee Evaluation of Replica Parts Issue.

10.

Other Items

In January 1989, the Virginia Power Nuclear Engineering Organization was

reorganized to better support the requirements of the two nuclear power

19

stations.

This reorganization resulted in realignment of the Surry Power

StatioD engineering staff.

A new Superintendent of Engineering position

was created at each station to better coordinate engineering efforts.

Under this position, five new engineering supervisory positions were

created (Supervisor, System Engineering; Supervisor, Advisory Operations;

Supervisor, Configuration Management; Supervisor, Design; Supervisor, NOE)

to better coordinate the engineering support during the design

reconstitution effort at the station.

11.

Exit Interview

The inspection scope and findings were summarized on February 2, 1989,

with those individuals identified by an asterisk in paragraph 1.

The

following new items were identified by the inspectors during this exit:

One additional example of apparent violation 280, 281/88-32-01 was

identified in paragraph 8.a during closeout of unresolved item 280,

281/88-28-02 regarding the EOG room louvers.

The example involved a

failure to translate appropriate design requirements into specifications

and procedures.

One violation was identified in paragraph 3.b with regard to several

examples of operations problems with failure to follow procedures and/or

inadequate procedures (280, 281/88-51-01).

One inspector followup item was identified in paragraph 4.b with regard to

the review of the instrument air system for operability (280,

281/88-51-02).

One inspector followup item was identified in paragraph 8.d with regard to

a review of the evaluation of whip restraints on the pressurizer surge

line (281/88-51-03).

One inspector followup item was identified in paragraph 9.a with regard to

followup

on

licensee evaluation of replica parts issue (280,

281/88-51-04).

The licensee acknowledged the inspection findings; however, the following

comment was provided with regard to the additional example of apparent

violation 280, 281/88-32-01, which was discussed in paragraph 8;a.

The

1 i censee stated that appropriate engineering cal cul ati ons demonstrated

that the emergency diesel generator room 1 ouvers would have opened if

required due to the differential pressure created during EOG operation.

Therefore they considered that the classification of the louvers as not

safety-related was appropriate.

The licensee did not identify as proprietary any of the materials provided

to or reviewed by the inspectors during this inspection.