ML18152A166

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Insp Repts 50-280/91-10 & 50-281/91-10 on 910331-0511.No Violations Noted.Major Areas Inspected:Plant Operations, Maint & Surveillance
ML18152A166
Person / Time
Site: Surry  Dominion icon.png
Issue date: 06/10/1991
From: Fredrickson P, Holland W, Tingen S, York J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML18152A167 List:
References
50-280-91-10, 50-281-91-10, NUDOCS 9106270082
Download: ML18152A166 (19)


See also: IR 05000280/1991010

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION 11

101 MARIETTA STREET, N.W.

ATLANTA, GEORGIA 30323

~eport Nos.:

50-280/91-10 and 50-281/91-10

Licensee:

Virginia Electric and Power Company

5000 Dominion Boulevard

Glen Allen, VA

23060

Docket Nos.:

50-280 and 50-281

License Nos.:

DPR-32 and DPR-37

Facility Name:

Surry 1 and 2

Inspectors:~\\\\,:;::,~,..........~.....,.....~--=~--=-~:--.=.-.,.-.....,...~---.,--~~~~~

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te igned

G/~ C//c;'/

Dake Signed

G /; ~h 1

DateSfgned

Approved

SUMMARY

Scope:

Thi.s routine resident inspection was conducted on site in the areas of plant

operations, plant maintenance, and plant surveillance.

In addition, a region

based inspector supported the inspection of testing of the Unit 2 service water

portion of the recirculation spray. system.

During the performance of this

.inspection, the resident inspectors conducted review of the licensee'*s

backshift or weekend operations on April 5, 6, 7, 8, 9, 10, 14, 21, 23, 28, 29,

May 2 , 7 , and 8.

Results:

In the engineering/technical support functional area, the failure to provide

administrative instructions to ensure that design control is maintained for

setpoints was identified as a programmatic weakness (paragraph 4.a).

9106270082 910610

PDR

ADOCK 05000~80

Q

PDR

2

In the operations and maintenance functional areas, inadequate inter-department

corrmunications between operations and maintenance engineering regarding the

operability of component cooling water pump 1-CC-P-lB*was considered a weakness

{paragraph 3.b).

.

In the opetations functional area, s~veral problems were identified which were

associated with a lack of operator

1s attention to detail and sensitivity to

control of plant configurati~n.

These problems resulted in identification of

NCVs for failure to tag out the correct emergency diesel generator fuel

transfer pump, failure to sample service water to the component cooling water

heat ~xchangei as required by ~he Technical Specifications, failure to properly

control system configuration that technically caused the inoperability of both

trains of a safety system, and failure to properly control the Unit 2 transfer

canal filling process that resulted in an overflow of contaminated water into

clean areas, (paragraph -3.d).

Management involvement in review of the events

and action after the last event appeared effective in refocusing personnel

accountability and attention to detail.

In the engineering/technical support functional area, an NCV

was identified

for failure to assure that proper system configuration was being maintained.

The original plant construction problem which* caused the violation was*

identified during modification of the recirculation flowpaths for the auxiliary

feedwater pumps and could not have been reasonably identified through any

previous station activities.

Good communication was observed between depart-

ments (engineering, construction, and operations) during troubleshooting and

identification of the problem {paragraph 3.d).

In the engineering/technical support functional area, a strength was identified

regarding the licensee's engineering involvement in identifying and resolving

the discrepancy concerning testing of the sample pumps for the recirculation

spray heat exchanger se~vice water radiation monitor and the overall support

provided throughout the test (paragraph 5.a).

.

In the maintenance/surveillance functional area, a weakness was identified**

associated with periodic maintenance on pressure switches.

Pressure switches

installed on systems important to safety were not in a routine calibration

program (paragraph 4;a).

In the maintenance/surveillance functional area, an NCV was identified for

failure to test the emergency diesel generator fuel oil transfer pumps more

. frequently or take corrective action in accordance with the Inservice Test

Program when vibration readings were in the alert range (paragraph 5.b) *

1.

Persons Contacted

Licensee Employees

REPORT DETAILS

R. Allen, Supervisor, Shift Operations

  • J. Artigas, Supervisor, Quality, Q.A.
  • W. Benthall, Supervisor, Licensing
  • R. Bilye~, Licensing Engineer
  • M. Bowling, Manager, Nuclear Licensing and Pro_grams
  • D. Christian, Assistant Station Manager
  • J. Downs, Superintendent of Outage and Planriing

D. Erickson, Superintendent of Health Physics

R. Gwaltney, Superintendent of Maintenance

  • M. Kansler, Station Manager

T. Kendzia, Supervisor, Safety Engineering

  • J. Logan, Senior Staff Engineer *
  • J. McCarthy, Superintendent of Operations
  • A. Price, Assistant Station Manager
    • E. Shaub, Licensing Engineer
  • R. Saunders, Assistant Vice President, Nuclear Operations

E. Smith, Site Quality Assurance Manager

  • T. Sowers, Supe~intendent of Engineering

NRC Personnel

  • W. Holland, Senior Resident Inspector
  • M. Branch, Senior Resident Inspector

S. Tingen, Resident Inspector-

J. York, Resident Inspector

M. Thomas, Reactor Inspector, Division of Reactor Safety

  • Attended exit interview.

Other licensee employees contacted included control room operators, shift

technical advisors, shift supervisors and other plant personnel.

Acronyms and initial isms used throughout this report are listed in *the

last pa_ragraph.

On May 1 and 2, 1991, the Division of Reactor Projects Branch Chief,

M. Sinkule, visited the Surry Power Station.

Mr. Sinkule toured the Unit

2 containment and held discussions with the residents.

On May 2, Mr.

B. Mallett, Deputy Director, Division of Radiation Safety and Safeguards,

visited the Surry Power Station.

Mr. Mallett and Mr Sinkule discussed

current plant status and ongoing projects with plant m*anagement, toured

the new radwaste processing facility, and toured the station with the

residents and the Surry Station Manager.

2.

2

Plant Status

Unit 1 began the reporting period in power oper~tion. * The unit operated

at power for the duratjon of the inspet~ion period.

Unit 2 began the reporting period in cold shutdown (day 2 of a scheduled

67 day refueling/maintenance outage). During this period the unit entered

reduced. inventory conditions for approximately one day.

This item is

further discussed in paragraph 3.g.

Also the unit was refueled and,

tow a rd the end of the period, the reactor ves se 1 head was being

reinstalled.

Unit 2 remained in refueling sh~tdown condition (reactor

vessel head reinstalled but studs not tensioned - day 44 of the outage)

when the inspection period end~d.

3.

Operational Safety Verification (71707 & 42700)

a.

Daily Inspections

The inspectors conducted daily inspections in the following areas:

control room staffing, access, and operator behavior; operator

adherence to approved procedures, TS, and LCOs; examination of panels

containing instrumentation and other reactor protection* system

elements to determine that required channels are operable; and review

of control room operator logs, operating orders, plant deviation

reports, ta gout logs, temporary modi fi cation 1 ogs, and tags on

components to verify comp 1 i ance with approved procedures.

The

inspectors also routinely accompanied station management on plant

tours and observed the effectiveness of their influence on activities

being performed by plant personnel.

b.

Weekly Inspections

The inspectors conducted weekly inspections in the following areas:

operability verification of selected ESF systems by valve alignment,*

breaker positions, condition of equipment or component, 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, niis.sile

hazards, and plant housekeeping conditions/cleanliness.

The

inspectors routinely noted the temperature of the AFW pump discharge

piping to ensure i ncrea~es in temperature were being properly

monitored and evaluated by the licensee.

On May 1, operators logged that the outboard bearing on CCW pump

1-CC-P-lB felt hot and that its bearing oil smelled like tar and

looked deteriorated. The pump was secured, placed in automatic start

and a work request was submitted.

On May 2, operators logged that

pump 1-CC-P-lB had bad oil and was for emergency use only.

On May 3,

--*---~~*---**-

' **

3

the inspectors questioned the operability of pump 1-CC-P-lB, and the

pump was subsequently declared inoperable.

Discussio.n between

operations, maintenance engineerjng, and th~ inspectors revealed that

an oil sample had been obtained from pump 1-CC-P-IR outboard bearing

and maintenance engineering had determined from the oil sample that

the pump bearing was possibly damaged and the pump was inoperable.

On May 2, maintenance engineering considered that the pump was

inoperable but inadequate inter-department co11111uni cations between

operations and maintenance engineering failed to conununicate that

engineering considered the pump inoperable.

TS 3.13 requires that for one unit operation, two CCW pumps* be

operable.

The fospectors verified that on May 1-3 the requirements

of TS 3.13 were met with pump 1-CC-P-lB inoperable.

The inadequate

inter-department communications between operations and maintenance

engineering regarding the operability of 1-CC-P-lB was considered a

weakness.

c.

Biweekly Inspections

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 identification system; verification of selected

portions of containment isolation lineups; -and verification. that

notices to workers are posted as required by 10CFR19.

d.

Other Inspection Activities

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

battery rooms, steam safeguards areas, emergency switchgear r,ooms,

diesel generator rooms, control room, auxiliary building, cable

penetration areas; Unit 2 containment, *1ow level intake structure,

and the safeguards valve pit and pump pit areas.

RCS leak rates were

reviewed to ensure that detected or suspected leakage from the system

was recorded, investigated, and evaluated; and that appropriate

actions were taken, if required.

The inspectors routinely

independently calculated RCS leak rates using the NRC Independ_ent

Measurements Leak Rate Program (RCSLK9).

On a regular basis, 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.

During this inspection period, several problems were identified which

were associated with a lack of operator's attention to detail and

sensitivity to control of plant configuration.

The events are

described below.

4

On April 9~ the inspectors were informed by the licensee that one of

the two fuel oil transfer pumps (1-EE-P-lF) for the No. 3 EOG had

been inadvertently tagged out.

This problem was discovered *during

operator rounds on April 9. * Unit 1 entered TS LCO 3.0.1 at that

time.

The tagout was cleared and the pum~ was returned to service

within one hour allowing for exit of the LCO.

The operations super-

intendent conducted a review of the problem and provided a report to

station management on April 10.

The inspectors reviewed the

preliminary report and noted the following:

Planning personnel identified the incorrect pump to be tagged

and also identified the wrong electrical breakei to be tagged.

Licensed operators who initiated the component isolation did not

use good self-checking techniques in the performance of this

evolution. Procedures were available for tagout of the fuel oil*

transfer pumps; however, these procedures were not specifically

written for the work to be performed and, therefore, were not

used.

The inspectors also were informed that CNS would conduct a review of

this event and provide additional *conclusions.

The inspectors were

briefed on the preliminary findings by CNS.

The inspectors consider

that the licensee's review of this event will allow for adequate

corrective action to prevent recurrence.

Failure to tag out the

correct EOG fuel transfer pump is identified as NCV 280/91-10-01~

This licensee-identified violation is not being cited because the*

criteria specified in Section V.G.1 of the NRC Enforcement Policy

were satisfied.

On April 12, the inspectors noted, during a review of operator logs,

that operators identified that a CCW heat exchanger sample was not

taken within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> as required by TS.

This* was a repeat of a

previous similar occurrence.* Corrective action included taking -

samples at six hour intervals.

In addition, prior to the end of the

inspection period, the licensee had installed and placed in operation

the fourth CCW heat exchanger service water radiation monitor, which

eliminated the sampling requirement.

This corrective action was the

permanent solution to a long-standing operational distraction.

Failure to sample the CCW heat exchanger service water as required by

TS is identified as NCV 280,281/91-10-02.

This licensee-identified

violation is not being cited because the criteria specified in

Section V.G.1 of the NRC Enforcement Policy were satisfied.

On April 22, the inspectors noted, during review of operator logs,

that operators identified both_ trains of the auxiliary building

emergency ventilation exhaust fans as inoperable at the same time,

which was in violation of TS.

The problem occurred when operators

tagged out the A train fan at the same time that the B train fan's

emergency power supply was out for maintenance.

This condition

placed Unit 1 in TS 3.0.1 at that time.

Immediate actions were to

5

return the A train fan to service.

The time period when both fans

were technically inoperable was approximately 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

CNS was

requested to review this problem.

Failure to properly control system

configuration resulting in both trains of a safety system being

technically inoperable is identified as NCV 280/91-10-03.

This

licensee identified violation is not being cited because the criteria

specified in Section V. G .1 of the NRC Enforcement Po 1 icy were

satisfied.

On April 23, the inspectors rioted, during review of operator logs,

that operators identified a condition that allowed overflowing of the

Unit 2 fuel transfer canal to the fuel building floor during a

filling evolution. The filling evolution was being accomplished.as a

"skill of the craft" job with no specific guidance on the monitoring

frequency for the fi 11 process.

A licensee review of the event

concluded that the cause* was personnel error.

Corrective action

included discussions with operations personnel on control of

evolutions not requiring written procedures.

Failure to properly

control the Unit 2 transfer .canal filling process resulted in the

overflow of contaminated water into clean areas. This is identified

as NCV 280,281/91-10-04.

This licensee identified violation is not

being cited because the criteria specified in Section V.G.1 of the

NRC Enforcement Policy were satisfied.

The inspectors noted that management attention was focused on each of

the aboveevents and CNS involvement in the review process indicated

an increased corporate awareness and involvement in assuring that

appropriate corrective actions were being taken.

Deviation reports

were written for each event.

In addition, after the April 23 event,

management had all superintendents discuss recent the performances*

and these events with their respective departments~

The inspectors

monitored selected discussions which were held with operating shifts.

The Operations Superintendent's discussions focused on the problems

discussed above and emphasized attention to detail, self-checking, -

and conununications.

The Assistant Station Manager for Operations and

Maintenanc~ was present for these discussions and also talked to the

shifts.

His talk focused on personal responsibility and

accountability.

The inspectors concluded that the discussions were

effective and well received.

On April 19, the licensee determined that a configuration problem

existed for the Unit 2 AFW system since the plant was constructed.

Because of underground crossing of lines during ori gi na l pl ant

construction involving the CST supply to the suction of the Unit 2 B

AFW pump and the CST fill line, an improper isolation resulted from a

modification by a DCP activity.

This occurred during performance

of DCP 87-09-2, AFW Full Flow Recirculation Lines.

The isolation

of the CST fill line resulted in isola{ion of the B AFW pump.

This

condition was contrary to TS requirements for maintaining cross-plant

AFW capabilities. After licensee identification of the problem, Unit

1 entered the TS action statement and inunediate actions were taken to

6

uni sol ate the maintenance fl owpath which was at this time known to be

the AFW pump B suction line from the CST.

Additional licensee

actions included verification that this condition did not exist on*

the Unit 1 AFW pump suction lines from the Unit 1 CST.

The li~ensee

also performed calculations to confirm that adequate NPSH was avail-

able for the Unit 2 B AFW pump from the smaller fill line.

The inspectors reviewed the problem' and the licensee's corrective

actions and concluded that they were adequate.

The review also

brought out the fact that the licensee had fire main backup water

available to the B AFW pump during the. period when its water supply

from the CST was isolated.

The original plant construction

deficiency was identified during modification of the tecirculation

flowpaths for the auxiliary feedwater pumps and could only have been

identified during a modification of this nature.

Good communications

was observed between departments ( engineering, construction, and

operations) during troubleshooting and identification of the problem.

Fai 1 ure *to assure that proper system configuration was being

maintained during modification activities resulted in a violation

when the required cross plant AFW system operability issue was

identified. This is identified as NCV 280/91-10-05.

This licensee

identified violation is not being cited because the criteria

specified in Section V.G.1 of the NRC Enforcement-Policy were

satisfied.

e.

Physical Security Program Inspections

f.

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

of the 1 i censee 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 posts.

No discrepancies were noted.

Licensee 10 CFR 50.72 Reports

On April 26, 1991, at approximately 0140 hours0.00162 days <br />0.0389 hours <br />2.314815e-4 weeks <br />5.327e-5 months <br />, the licensee made a

report in accordance with 10 CFR 50.72 for entry in the emergency

plan (UE) due to a TS required shutdowm initiation on Unit 1.

At

2255 hours0.0261 days <br />0.626 hours <br />0.00373 weeks <br />8.580275e-4 months <br /> on April 25, the licensee discovered that the A main

control room chiller would not load and declared the chiller

inoperable.

TS 3.23 requires that all three of the main control room

chillers be operable whenever either unit ts above cold shutdown and

also allows for one control room chiller to be inoperable for a

period not to exceed seven days.

At the time of this event, the

emergency power supply to the B main control room chiller was not

available due to maintenance on the No. 3 EOG.

TS 3.0.2 requires

both normal and emergency power supplies be operable for redundant

I~

7

equipment when a required component is inoperable.

Therefore, when

the A main control room chiller became inoperable, the B main control

room chiller was also declared inoperable.

TS 3.0.2 invoked a

six-hour clock to hot shutdown.

At 0115 hours0.00133 days <br />0.0319 hours <br />1.901455e-4 weeks <br />4.37575e-5 months <br /> on* April 26, the

licensee initiated a controlled shutdown of Unit 1, and declared a

UE.

The A main control room chiller was repaired and returned to

service.

At 0222 hours0.00257 days <br />0.0617 hours <br />3.670635e-4 weeks <br />8.4471e-5 months <br /> the Unit 1 ramp was stopped at 78% power

and the UE terminated.

At 0425 hours0.00492 days <br />0.118 hours <br />7.027116e-4 weeks <br />1.617125e-4 months <br /> the unit was at 100% power.

A review of this evolution indicated that 1 icensee actions were

conservative and in accordance with TS requirements.

g.

Reduced Inventory Conditions - Unit 2

Unit 2 entered a reduced inventory condition on April 4, 1991 in

order to drain the primary side of *the steam genera tors. The

condition was exited on *April 5, 1991.

Prior to entry into this

condition, the inspectors . conducted a review of the 1 icensee' s

responses and implemented actions with regards to the requirements of

Generic Letter 88-17, Loss of Decay Heat Removal.

No discrepancies

were noted during the review.

The specific items reviewed were:

Generic Letter 88-17 - The inspectors reviewed the subject

letter including the licensee's response to the letter dated

January 6, with suppl ementa 1 responses dated February 3,

September 29, October 31, 1989, October 5, and November 16,

1990.

-

Administrative Contrnls - The inspectors discussed controls and

procedures in affect to control reduced inventory operation with

station management.

Containment Closure Activity - The licensee's procedures require

that the status of the containment configuration be established

and verified prior to entering a reduced inventory condition.*

In addition, the procedure for loss of RHR capability di rec ts

containment closure action to be initiated and continued until

the RHR system is returned~~ service and core conditions are

verified normal. The inspectors verified that the licensee has

prepared procedures to reasonably assure that containment

closure will be achieved prior to the time when core uncovery

could occur.

This was done by reviewing 2-0P-3.4, Draining the

Reactor Coolant System, dated March 28, 1991, 2-0P-lG, Refueling

Containment Integrity and RCS Mid-Loop Containment Closure.*

Checklist, dated April 28, 1989, and 2-AP-27, Loss of Decay Heat

Removal Capability, dated March 28, 1991. * Other than the

containment personnel entry hatch, no containment openings will

exist.

RCS Temperature - The inspectors verified that the controlling

procedure for draining the RCS, 2-0P-3.4, required at least two

operable incore temperature indicators prior to draining the RCS

8

to a reduced inventory condition.

The inspectors also verified

that the control room operators record the temperatures every

. six hours in their .log as required* by* periodic test 2-PT-36,

Instrument Surveillance.* In addition a supplemental check list,

Control Room Operator Reduced RCS Inventory Relief Checklist,

requires at least two operable core exit thermocouples (i.e. one

from each train).

RCS Level Indication - The licensee has installed one means of

level indication which provides continuous readout in the

control room.

This system is calibrated and provides an alarm

for both low level and. loss of level.

In a letter dated

October 31, 1989, the licensee committed to install a second

means of RCS level indication prior to the end of the current

Unit 2 refueling outage.

Until this second means of level

indic:ation is* installed, the licensee will utilize only one

means of RCS level indication.

RCS Perturbations - The inspectors verified that the licensee

has a procedure, OC-28, Assessment of Maintenance Activities for

Potential Loss of Reactor Coolant Inventory dated January 22,

1991, that allows operations' assessment of work on systems for

potent i a 1 1 oss of reactor coo 1 ant inventory during reduced RCS

inventory conditions.

RCS Inventory Addition - The inspectors verified that procedure

2-0P-3.4 required at least two available and operable means of

adding inventory to the RCS.

These are in addition to the RHR

system.

The procedure requires that in a reduced inventory

condition, one charging/safety injection pump and one low head

safety injection pump must be available with appropriate

flowpaths to the core.

Loop Stop Valves - The licensee utilizes RCS loop isolation

valves for loop isolation.

Nozzle dams are not .used.

The

licensee uses a checklist (OC-28) to ensure that the RV upper

plenum is adequately vented when maintenance activities require

opening of an RCS cold leg pressure boundary.

The licensee .will

ensure the reactor vessel is adequately vented by maintaining A

and Bloops unisolated with their loop bypass valves open.

Contingency Plans to Repower Vital Susses - The vital and

emergency electrical distribution system receives offsite power

from the A and C reserve station service transformers during

normal plant operations.

The RHR pumps and the CCW pumps, the

latter provide cooling water to the RHR heat exchangers, operate

off stub busses attached to the 2J and 2H emergency busses..

The

stub busses are shed during degraded or undervoltage situations,

but can be reconnected to the emergency busses by closing a

9

breaker.

The equipment for the two additional means for adding

jnventory to the RCS, charging pumps and low head safety

injection pumps, are powered off the 2H and 2J emergency busses.

During normal operations, the number 2 EOG supplies power to the

2H emergency bus in case of a degraded or undervol tage

situation, and the number 3 EOG supplies power to the .2J bus.

During this period, the licensee will have the A_and C reserve

station service transformers powering the emergency busses, and

the No. 2 and 3 EDGs available as emergency power sources.

Within the areas inspected, five NCVs were identified. _

4.

Maintenance Inspections (62703 & 42700)

During the reporting period, the inspectors reviewed maintenance

activities to assure compliance with the appropriate procedures.

The following maintenance activities were reviewed:

a.

Instrument Calibrations

During the previous inspection period, discrepancies associated with

the ca 1 i brat ion of the containment spray pump pressure switches were

identified.

These discrepancies involved conflicting and incomplete

information specified in the Units 1 and 2 setpoint documents and

instrument history folders.

During this inspection period,

calibration procedures, setpoint documents, and instrument history

folders were reviewed.

The inspectors reviewed the setpoint DRPs,

1-DRP-005, Instrument Setpoints, dated July 24, 1990, and 2-DRP-005,

Instrument Setpoints, dated July 24, 1990.

The licensee informed the

inspectors that the design basis for all reactor protection and

safeguards setpoints were reverified in 1989 with no discrepancies

noted.

The inspectors did not verify the basis of the setpoints or

the loops' scaling and bias factors but a review of the procedures -

associated with the calibration of reactor protection instrumentation

and SI instrumentation indicated that the procedures were adequate

and contained all the required information necessary for I&C

technicians to accomplish the work.

Reactor protection calibration

procedures reviewed were:

1-PT-2.2A (F-1-415), Reactor Coolant Flow, dated October 31,

1989

2-PT-2.5A (L~2-474), Steam Generator Level, dated October 31,

1989

2-PT-2.4A (P-1-455), Pressurizer Pressure Protection, dated

September 3, 1989

SI calibration procedure 1-PT-2.18 (P-1-927),

B Safety

Injection Accumulator Tank Pressure, dated October 31,1989

10-

Although all the required calibration specifications were contained

in the individual calibration procedures, the setpoint DRPs also

contained calibration specifications for the same instruments~

The inspectors identified discrepancies between the calibration

specifications provided in the calibration procedures and the

setpoint DRPs.

Examples of discrepancies were that the setpoint DRPs

specified incorrect tolerances for the pressure comparaters

associated with the Unit 2 SI accumulators and Unit 1 pressurizer

pressure instruments.

The inspectors a 1 so noted that in many

instances the setpoint DRP did not provide all the necessary

calibration specifications (instrument span, setpoint tolerance, .

reset point, etc.) that were specified in the calibration procedures.

  • Since all calibration specifications for ttie reactor protection and

SI instrument calibrations were specified in the procedures, the

instrument history folders and setpoirit DRPs were not utilized by the

I&C technicians to obtain calibration specifications. * The inspectors

concluded that these calibrations procedures were adequate; however

the setpoint DRPs were considered inadequate because. of the

discrepancies noted.

The inspectors reviewed procedure IMP-C-G-35, Pressure Switch

Checkout, dated November 27, 1988.

This is a generic procedure

currently utilized to calibrate pressure switches installed on

safety-related systems throughout the plant. The procedure provides

general guidance but does not provide the pressure switch setpoint

specifications.

The s.etpoint specifications are obtained from the

unit's setpoint DRP.

As discussed in the previous inspection period,

during_ the calibration of pressure switch l-CS-PS-103A, setpoint DRP

and instrument history file setpoint discrepancies were noted.

Tolerances for setpoints and switch reset values were not provided.

Information detailing pressure switch actuation on increasing or

decreasing pressure was also not provided. Technicians were required

to review the e1ectrical schematics in order to determine whether the

pressure switch contacts are required to open or close at the desired

setpoint.

The inspectors reviewed the calibrations of pressure

switches 2-PS-CC-202 and 2-PS-DG-200 and identified findings similar

to the 1-CS-PS-103A calibration findings.

2-PS-CC-202 provides a

control room alarm of low CC pump pressure to the Unit 2 charging

pump sea1 coolers and 2~PS-DG-200 controls the rate of leakage from

the reactor coolant system leakoff into the PDTT.

Based on the

examples reviewed, the inspectors concluded that in the area of

pressure switch calibration specifications, the setpoint DRPs were

inadequate because the required information was not provided and

other information specified in the setpoint DRPs was inconsistent.

The inspectors also reviewed deviation reports that documented

discrepancies associated with RTD, flow, and level instrumentation

calibration procedures and indicated that the Units 1 and 2 setpoint

DRPs wer~ not in agreement.

'*-* --*-:>. .

11

The Units 1 and 2 setpoint* DRPs were issued in July, 1990.

The

purpose of these documents was to provide an official procedure

containing instrument s_etpoint data that had been approved by *sNSOC.

I&C personnel were required to obtain the required calibration

specifications from these documents when the information was not

available in the instrument calibration procedure.

The setpoint

DRPs have been under continuing revision since being issµed.

The

inspectors reviewed SUADM-ENG-04, Setpoint Change Control Program,

dated October 17, 1990, and concluded that administrative

instructions required that instrument setpoints be established or

changed by a prescribed design process.

The licensee stated that I&C

technicians had been informed to initiate an EWR and engineering

would provide the required setpoints.

Discussions with I&C

technicians indicated that this method was burdensome and resulted in

I&C personnel researching instrument history files to. obtain

setpoints which complicated the performance of the instrument

calibration procedure.

During this inspection period, the licensee

had developed a new process for I&C technicians to obtain calibration

specifications when not in the calibration procedure or the setpoint

DRP.

I&C technicians were required to research the instrument

history files and any other necessary documents and drawings to

determine setpoints and forward this information to engineering for

review.

The technicians would perform the calibration and at a *

later date engineering would review the setpoints provided by I&C

and update the setpoint DRP.

If the engineering review of the

I&C-provided setpoints identified that the setpoints were incorrect,

a deviation report would be initiated.

The inspectors concluded that the licensee did have a formal

administrative process for obtaining setpoint specifications when not

provided by a calibration procedure or a setpoint DRP.

However,

during this inspection period, that process was not being used for

those examples of pressure instrumentation setpoints reviewed by the

inspectors. Although the setpoint DRP discrepancies identified by the

inspectors did not result in any significant safety issues, the

inspectors were concerned that required administrative guidelines

were not in place to provide design input of setpoints variances.

This problem appeared to be extensive and is identified as a program-

matic weakness.

The inspectors also

noted that pressure switches 2-PS-CC-202 *and

2-DG-PS-200 had not been in a periodic calibration program.

D~ring

the Unit 2 outage these switches were not able to be calibrated and

were replaced.

The inspectors consider it a weakness in the

licensee

I s periodic maintenance program that pressure switches

installed on systems important to safety were not routinely

calibrated.

When I&C personnel discover that these components were

not routinely calibrated they were adding them to the calibration

program.

12

b.

Replacement of Pressurizer Heater Breakers

On April 25, the inspectors observed the replacement of breaker No. 5

in the pressurizer heater breaker panel.No. 2.

The craft were using

work order 3800110459 and corrective electri~al maintenance procedure

EMP-C-EPL-73, Safety Related Molded-Case Circuit Breakers, dated

April 14, 1987.

The inspectors observed the meggering of the No. 1

breaker in this panel and the signing off and recording of.some of

the vendor information .into steps- of the procedure.

No discrepancies

were identified.

  • *

Within the areas inspected, one violation_was identified.

5.

Surveillance Inspections (61726 & 42700)

During the reporting period, the inspectors reviewed various surveillance

activities to assure compliance with the appropriate procedures as

follows:

Test prerequisites were met.

Tests were performed in accordance with approved procedures.

Test proced_ures appeared to perform their intended function ..

Adequate coordination existed among personnel involved in the test.

Test data was properly collected and recorded.

The following surveillances were either reviewed or observed:

a.

Flow Testing of the ~ervice Water Side of the Unit 2 RSHXs

During this inspection period~ the inspectors witnessed flow testing

of Unit 2 RSHXs 2-RS-E-lB and 2-RS-E-lC.

The test was performed in

accordance-with special test procedure 2-ST-301, "Recirculation Spray

Heat Exchangers Service Water Flow Test", dated March 26, 1991~

During Unit 1 RSHX SW flow testing in October, 1990, concerns were

  • identified over the control of macrofouling which could limit the

ability of the RSHXs to adequately perform their functions during an

accident.

As a result of these concerns, the licensee performed flow

test verification on the Unit 2 RSHXs.

The Unit 1 testing was

discussed in detail in NRC Inspection Reports *50-280,281/90-30 and

50-280,281/90-36.

-

This Unit 2 test involved removal of service water valves 2-SW-MOV-

204B and 2-SW-MOV-204C and their respective expansion joints.

A

special venturi test spool piece was installed in the place of each

valve to measure SW inlet flow to the RSHXs.

Instrumentation was

al~o installed to measure differential pressure across the RSHXs and

-to gather additional flow data.

13

The inspectors- observed pretest preparations which included

installation and checkout of test equipment and the pretest briefing.

The inspectors reviewed procedure 2-.ST-301,* including the changes,

and found the procedure to be technically adequate.

The inspectors

noted that change 91-47 to the procedure involved adding steps to

test the .RSHX SW radiation monitor pumps 2-SW-P-58 and 2-SW-P-5C

under design conditions.

The inspectors discussed this change with

1 icensee personnel who stated that the pumps were being tested

because there was no documentation to show that the pumps had ever

been tested to demonstrate their capability to provide the required

flow rate under actual RSHX SW flow conditions.

The pumps are

currently being tested quarterly under periodic test procedure

2 ... PT-17.7, Recirculation Spray Heat Exchanger Service Water Radiation

Monitor Pump Test.

Condensate was used to test the pumps during

surveillance testing.

The condensate is applied to the suction of

the pumps through a test and flush connection.

At 0534 hours0.00618 days <br />0.148 hours <br />8.829365e-4 weeks <br />2.03187e-4 months <br /> on April 6, 1991, the test began by initiating SW flow

through the Unit 2B and C RSHXs.

Approximately one minute after

initiation of SW flow, radiation monitor pumps 2-SW-P-58 and

2-SW-P-5C were manually started from the control ,room.

The

. inspectors monitored testing from the control room and the Unit 2

safeguards room.

The inspectors noted that the test instrumentation

indicated that the SW flows appeared to be within the expected

ranges.

The flows were approximately 11,000 gpm through each RSHX

and the differential pressure across each RSHX was approximately

150-155 psig.

The additional instrumentation being used to monitor

SW flow were in close agreement with the values obtained from the

venturi test devices.

The inspectors observed that the control room

flow indicators were erratic and not reliable. For example, control

room flow indicator 2-SW-FI-206B was reading approximately 3000 gpm

less than the venturi test device which was installed for RSHX B.

A

SW flow of approximately 4800 gpm was read from RSHX A flow indicator

2-SW-FI-206A and 3800 gpm was read from RSHX D fl ow i ndi ca tor

2-SW-FI-206D.

There was no flciw through either the A or D RSHXs

because the SW inlet supply valves to these HXs were closed.

Deficiencies related to incorrect control room flow indicators are

being tracked by IF! 280,281/90-30-01.

After the RSHX SW radiation monitor 2-SW-P-58 and SC pumps were

started, the low flow alarm annunciated in the control room.

  • The

discharge pressure was 5.5 psig for pump 58 and 6 psig for pump 5C.

Licensee personnel attempted to take SW samples from the sample lines*

but the 58 pump sample line was only dripping and the SC pump sample

line yielded one liter in approximately one and one-half minutes~

The flow rate requirements stated in the FSAR was 5-10 gpm and the

discharge pressure stated in the surveillance procedure was greater

than 25 psig.

Licensee personnel decided to open the condensate

  • '.

14

supply, which is nonnally used during su*rveillance testing, to the

pumps but the pumps only showed a slight increase in flow rate and

. discharge' pressure.

The pumps were secured at 0612 hours0.00708 days <br />0.17 hours <br />0.00101 weeks <br />2.32866e-4 months <br /> after.

approximately 45 minutes of operation.

The low flow alarm never

cleared whi'le the 58 pump was running *. The low flow alarm cleared

several times for pump 5C but reannunctated each time after clearing.

The inspectors questioned licensee personnel concerning failure of

the SW radiation monitor pumps to operate properly and 1 icensee

personnel stated that they believed. the vacuum on the discharge

tunnel may be having some affect on the inability of the pumps to

operate properly.

Licensee personnel restarted the pumps after the

Unit 2 discharge tunnel pressure had reached zero.inches Hg atid the

vacuum breaker was opened.

After being started, the discharge

pressure for the 58 pump was 35 psig and a one liter sample was

obtained from the sampl_e line in four seconds.

The low flow alarm

did not annunciate.

The *discharge pressure for the 5C pump was 34

psig and a two gallon sample was obtained in 41 seconds.

The

inspectors questioned whether these flow rates met the design

requirements and licensee personnel stated that when the samples were

taken, the sample lines were not isolated from the Unit 1 discharge

tunnel.

Another sample was taken after the sample line for pump 5C

  • was isolated from the Unit 1 discharge tunnel and a two gallon sample

was obtained in 24 seconds.

This flow rate met the design *

requirements and appeared to resolve the problems encountered earlier

i~ the test.

It appeared that while the Unit 2 discharge tunnel was

still under vacuum, it affected the suction pressure to the pumps and.

the pumps were not adequately primed.

The inspectors further questioned 1 icensee personnel concerning

whether a similar concern existed on Unit 1 and, if so, what was

being done to address the Unit 1 concern.

Licensee personnel stated

that a similar problem did exist on Unit 1 and consideration was

being given to opening the Unit 1 vacuum breakers and continuing to

operate with the vacuum breaker open.

The 1 icensee conducted a

safety evaluation of this concern and concluded that in the event of

a DBA, operators would be required to break the discharge vacuum

condition by manually opening a vacuum breaker valve.

A JCO-was

prepared and approved by the SNSOC for operators to accomplish this

task in order to continue operation of Unit 1.

The inspectors

verified.that the JCO was implemented.

During the test, the inspectors monitored RSHX SW flow for six hours.

The Band C RSHX SW flow~ and discharge pressures remained in the

acceptable range.

_The data collected during this test had to be*

evaluated by the licensee's engineering organization in order to

determine whether the data met acceptance criteria. Preliminary data

reviewed by the inspectors appeared to indicate that flow rates were

adequate.

-

,=

15

The inspectors considered the licensee's engineering involvement in

identifying and resolving the test discrepancies of the *RSHX SW

radiation monitor sample pumps and _the overall support provided

throughout the test to be a strength. *

b.

EDG Fuel Oil Transfer Pump Testing

During a tour of the EDG fuel oil transfer pump area, the inspector

noted that No. 2 EDG fuel oil transfer pump 1-EE-P-18 had a work

request tag attached, dated January 25.

The tag stated that vibra-

tions were higher than normal and that the pump was noisy.

The 6 EDG

fuel oil transfer pumps are safety related and c;1re in the licensee's

IST program.

In order to evaluate pump 1-EE-P-18 high vibration

  • readings, the inspectors requested the pump's vibration history.

On

January 25, 1991 vi bra ti on readings for pump 1-EE-P-18 exceeded the

IST program normal Vibration limits and were in the alert range.

These pumps are normally tested quarterly, but if pump readings are

in th.e alert range the I ST program requires the pump to be tested

monthly.

The inspectors identified that after the high vibration

readings were obtained on January 25, the pump's test frequency was

not increased to monthly.

The inspectors reviewed the vibration

histories for the five remaining fuel oil transfer pumps and identi-

fied that occasionally vibration readings would be in the alert

range.

Test frequency was not increased to monthly when the vibra-

tion readings were in the. alert range. The inspectors reviewed

2-PT-22.3M, Diesel Generator No. 2 Quarterly Exercise Test.

The

procedure required that pumps 1-EE-P-lB and 1-EE-P-lE vibration

readings be taken but did not require the readings to be recorded nor

did the procedure provide vibration acceptance criteria. Procedures

1-PT-22.3L and 1-PT-22.JN, which tested EDGs Nos. 1 and 3 fuel oil

transfer pumps, were similar.

They required that vibration readings

be taken but. not recorded and they did not provide a vibration

acceptance criteria.

,

Failure to test the EDG fuel oil transfer pumps monthly or take

corrective action in accordance with the IST program when vibration

readings were in the alert range is identified as NCV 280,281/

91-10-06.

This violation is not being cited because the criteria

specified in Section V.G.1 of the NRC Enforcement Policy were

satisfied.

The licensee's corrective actions involved retesting pump

1-EE-P-18 in order to obtain vibration readings.

Procedural changes

were initiated to record vibration readings and to provide an

acceptance criteria.

Within the areas inspected, one NCV was identified.

- . --**-***-'*, ..... ~-~-

,:'

.

..

16

8.

Exit Interview*

The inspection scope and results were summarized on May 14, 1991" with

those individuals identified by an asterisk in paragraph 1. The following

su1Ti11ary of inspection activity was discussed by the inspectors, during this

exit.

Item Number

Description and Reference

NCV 50-280/91-10-01

Failure to tagout the correct EDG fuel

transfer pump.

NCV 50-280,281/91-10-02

Failure to sample the -CCW heat exchanger

service water as required by TS.

NCV 50-280/91-10-03

Failure to

properly control

system

_ configuration

resulting

in

rendering

technically inoperable both trains of a

safety system.

NCV 50-280,281/91-10-04

Failure to properly control the Unit 2

transfer canal filling process which

resulted in overflow of contaminated water

into clear areas.

NCV 50-280/91-10-05

Failure to assure_ that proper system

configuration was being maintained during

modification activities.

NCV 50-280,281/91-10-06

Failure to test the emergency diesel

generator fuel oil transfer pumps monthly or

-take corrective in accordance with the

Inservice Test Program when v1bration

readings were in the alert range.

The licensee acknowledged the inspection conclusions with no dissenting

comments.

The licensee did not identify as proprietary any of the

materials provided to or reviewed by the inspectors during this .

inspection.

At a supplement~d exit on June 7, 1991, the licensee

co1T111itted to provide additional information and corrective action to the

setpoint control program problem discussed in paragraph 4.~.

12.

Index of Acronyms amd Initialisms

AFW

CFR

CCW

CNS

CST

OBA

DCP

AUXILIARY FEEDWATER

CODE OF FEDERAL REGULATIONS

COMPONENT COOLING WATER

CORPORATE NUCLEAR SAFETY

EMERGENCY CONDENSATE STORAGE TANK

DESIGN BASIS ACCIDENT

DESIGN CHANGE PACKAGE

...

~ ,, ..

i

DRP

EDG

ESF

EWR

FSAR

GPM

Hg

HX

I&C

IFI

ISi

1ST

LER

LCO

NCV

NPSH

NRC

PDTT *

PSIG

RCS

RHR

RSHX

RTD

RV

RWP

SI

SNSOC

SW

TS

UE

17

DESIGN REFERENCE PROCEDURE

EMERGENCY DIESEL GENERATOR

ENGINEERED SAFETY FEATURE

ENGINEERING WORK REQUEST

FINAL SAFETY ANALYSIS REPORT

GALLONS PER MINUTE

MERCURY

HEAT EXCHANGERS

INSTRUMENTATION AND CALIBRATION

INSPECTOR FOLLOWUP ITEM

INSERVICE INSPECTION

INSERVICE TESTING

LICENSEE EVENT REPORT

LIMITING CONDITIONS OF OPERATION

NON-CITED VIOLATION

NET POSITIVE SUCTION HEAD

NUCLEAR REGULATORY COMMISSION

PRIMARY DRAIN TRANSFER TANK

POUNDS PER SQUARE INCH

REACTOR COOLANT SYSTEM

RESIDUAL HEAT REMOVAL

RECIRCULATION SPRAY HEAT EXCHANGER

RESISTANCE TEMPERATURE DEVICE

RELIEF VALVE

RADIATION WORK PERMIT

SAFETY INJECTION

STATION NUCLEAR AND SAFETY OPERATING COMMITTEE

SERVICE WATER

TECHNICAL SPECIFICATIONS

Unusua 1 Event