ML18152A210
| ML18152A210 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 01/26/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18152A211 | List: |
| References | |
| 50-280-97-12, 50-281-97-12, NUDOCS 9802040061 | |
| Download: ML18152A210 (21) | |
See also: IR 05000280/1997012
Text
Docket Nos:
License Nos:
Report*No:
Licensee:*
Facility:
Location:
Dates:
Inspectors:
Approved by:
9802040061 980126
ADOCK 05000280
8
U.S. NUCLEAR REGULATORY COMMISSION
REGION II
50-280-. 50-281
.. 50-280/97-12. 50-281/97-12
Virginia Electric and Power Company (VEPCO)
Surry Power Station. Units 1 & 2
5850 Hog Island Road
Surry, VA 23883
November 16 - December 27. 1997
R. Musser. Senior Resident Inspector
K. Poertner. Resident Inspector.
D. Jones. Senior Radiation Specialist. (Sections Rl.2.
Rl.3 and Rl.4)
H. White_ner. Reactor Inspector. (Sections Ml.2 and
Ml.3)
W. Miller. Reactor Inspector. (Section F8.1)
R. Haag. Chief. 'Reactor Projects Branch 5
Division of Reactor Projects
Enclosure 2
EXECUTIVE SUMMARY
Surry Power Station. Units 1 & 2
NRC Inspection Report Nos. 50-280/97-12. 50-281/97-12
This integrated inspection included aspects of licensee operations.
engineering, _maintenance. and plant support. The report covers a 6-week
period of resident inspection and includes the~results of:announced
inspections by a regiona-1 radiation specialist and a regional reactor
inspector .. In addition,. the report includes the results of an inoffice review
by a regional: reactor inspector.
Ope rat i ans*
- ,
A violation was identified for the failure to have appropriate
i nstructi ans aya_i 1 ab] E\\'tq ** return the Alternate Alternating Current
Diesel Generator to service following maintenance activities. This
condition resulted in the generator being unavailable to auto_matically
connect to the station electrical busses for a period of approximately
36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> (Section 01. 2).
'
A violation was identified involving the failure to proper.ly perform the
verification that the Alternate.Alternating Current Diesel Generator
breaker control switches were in the Auto-after-Trip position as *
..
required by operator logs (Section 01. 2).
. .
While returning the Alternate *Alternating Current Diesel Generator to
service. the operating crews demonstrated a willingness to accept
inadequate instructions and exhibited a lack of attention to detail and
questioning attitude. This evolution also revealed a weakness in the
control of trainees by qualified watchstanders (Section 01.2).
The plant response to a Unit 2 manual reactor trip was normal except for
a problem with control rod indications. With the unit stabilized at hot
shutdown. inattention of the operating crew to plant conditions resulted
in steam generator power operated relief valve actuations. Maintenance
items identified following the trip were corrected prior to restart of
the unit (Section 01.3).
The shift brief prior to startup and operator performance while taking
the Unit 2 reactor critical were excellent (Section 01.3).
Management's decision to hold Unit 2 power at approximately 35% while
resolving issues with an Anticipated Transients Without Scram Mitigating
System Actuation Circuitry setpoint and with the Turbine Driven
Auxiliary Feedwater Pump was conservative and demonstrated a good safety
perspective (Section 01.3).
Maintenance
A violation was identified for failure to perform post maintenance
testing which was specified in work instructions for the Unit 2 Turbine
Driven Auxiliary Feedwater Pump governor replacement (Section Ml.I) .
2
Maintenance activities involving. emergency diesel generator radiator
louvers. control room chiller. and the screen wash system were completed
in a -thorough and professional *manner.
Maintenance personnel were
knowledgeable of the assigned tasks. procedures were detailed and
_actively used on the job. and cooperation and coordination between
various plant groups were good (Section Ml.2).
Surveillance activities involving the control room chillers. ~n
emergency servicewater pump. and the turbine driven auxil.iary.feedwater
pump were completed in a thorough and professional manner.
Maintenance
- .personnel were knowledgeable .of the assigned tasks. :procedures were
detailed and actively used on the job. and cooperation and coordination
between various plant groups were good (Section Ml.3).
A non-cited violation was identified for failing to test the remote
manual undervoltage.trip prior toplacing,the reactor trip bypass
breakers inservice as required by Technical Specifications
(Section MB.1).
The operating experience review staff failed to r~cognize the
applicability of improper reactor trip bypass breaker testing to Surry
after this issue was i denti fi ed *in October 1996 at the licensee* s North
Anna Station (Section MB.1).
Engineering
The total number of temporary modifications. four on Unit 1 and none on
Unit 2 .. indicated a willingness to correct problems in an expeditious
manner.
The temporary modifications had safety evaluations which were
completed prior to installation (Section El.1).
Plant Support
Health physics practices were observed to be proper (Section Rl.l).
The licensee's program for transportation of radioactive materials had
been effectively implemented pursuant to Department of Transportation
and NRC regulations.
Enhanced procedures for shipping radioactive
materials were found to be a program strength (Section Rl.2).
The licensee's water chemistry control program for monitoring primary
and secondary water quality had been implemented in accordance with the
Technical Specification requirements and industry guidelines for
pressurized water reactor water chemistry (Section Rl.3).
The licensee had implemented and maintained a program for obtaining and
analyzing samples of reactor coolant and containment atmosphere under
accident conditions in accordance with Technical Specification
requirements and Updated Final Safety Analysis Report commitments
(Section Rl.4) .
3
Security and material condition of the protected area perimeter barrier
were acceptable (Section Sl).
Report Details
Summary of Plant Status
Unit 1 operated at power the ent~re reporting period.
Unit 2 operated at power until December 2 when the unit was manually tripped
by the operating crew (See Section 01.3). The:unit was returned to service on
December 3 and achieved 100 percent power on December 6.
The unit-operated at
or near power for the remainder of the inspection period.
I . Ope rat i ems
01
Conduct of Operations
'
.
.
.
01.1 General Comments (40500. 71707)
The inspectors conducted freque*nt control room tours to verify proper
staffing, operator attentiveness. and adher~nce to approved procedures.
The inspectors attended daily plant status meetings to maintain
awareness of overall facility operations and reviewed operator logs to
verify operational safety and compliance with Technical Specifications
(TSs).
Instrumentation and safety system lineups were peri odi ca 11 y
reviewed from control room indications to assess operability. Frequent
plant tours were conducted to observe equipment status and housekeeping.
Deviation Reports (DRs) were reviewed to assure that potential safety
concerns were properly reported and resolved.
The inspectors found that
daily operations were generally conducted in accordance with regulatory
requirements and plant procedures.
01.2 Inoperable Alternate Alternating Current (AAC) Diesel Generator (DG)
a.
Inspection Scope (71707)
The inspectors reviewed the circumstances surrounding a failure to
ensure that the AAC DG was properly aligned following return to service.
b. Observations and Findings
On November 25: the AAC DG was tagged out for preventative maintenance
activities on the associated electrical busses and breakers.
On
November 26. at 10:30 p.m .. maintenance activities were completed. the
associated tagout was cleared and the AAC DG was returned to service in
accordance with Procedure O-MOP-AAC-002. "Return to Service of the AAC
Diesel Generator." Based on the maintenance activities performed the
licensee determined that an AAC DG run was not required to return the
diesel to an operable status.
On November 28. during the performance of the quarterly AAC DG test. six
breaker control switches were found in the Pull-to-Lock (PTL) position.
With the switches in the PTL position the AAC DG would not have
automatically aligned to the associated station busses.
The switches
were returned to Auto-after-Trip and the quarterly AAC DG test was
subsequently performed satisfactorily.
2
Although not addressed in TS. the AAC DG was installed to meet
regulatory requirements.
Consequently, the licensee has established a
14 day administrative limit for the allowed outage time of the AAC DG.
The 14 day administrative limit was not exceeded during the time frame
that the AAC DG was inoperable.
The*switches found
0in the ,PTL position were not addressed in Procedure
O-MOP-AAC-002.
The tagout associated with the maintenance activity
(S0-97-AAC-006) had a hand written note in the comments section that
stated "ensure all switches that have a Pull-to-Lock position are
left in auto after clearing tagout. This applies to 0-AAC-BKR-Ml..
Q.:.AAC-'-BKR-'-M2.' O-AAC.,BKR-M3. O-MC-BKR-L2. O-AAC-'BKR-L3. they are *not
addressed by MOP."
The switches were* not *included in the actual tagout
portion of the clearance.
The tagout comment listed. by equipment
number. the breakers that are controlled by the switches. but did not
provide the applicable switch equipment numbers.
The tagout comment did
not mention that the actual switches which had the PTL feature were
located on a panel that was separate from the actual breakers listed in
the tagout comment.
In addition. the tagout comment did not identify
a 11 the switches . that were subsequently .. found out . of pas it ion.
The
operators performing the return to service did not have a good
understanding of the AAC DG and associated system controls. The
operators did not question that the test switches they verified (located
on the breakers and referenced in the comments section of the tagout)
did not contain a PTL position. This discrepancy was not *identified to
the operator's supervisor.
While returning the AAC DG to service the
operators did not check the control switches with the PTL feature that
were located on another panel.
Technical Specification 6.4.A.7 requires that detailed written
procedures with appropriate check-off lists and instructions be provided
for preventive or corrective maintenance activities which would have an
effect on the safety of the reactor. Procedure O-MOP-AAC-002 and Tagout
S0-97-AAC-006 did not contain appropriate check-off lists and
instructions to return the AAC DG to service following maintenance
activities. The failure to have detailed written procedures and
appropriate check-off lists to return the AAC DG to service is
identified as Violation 50-280. 281/97012-01.
The inspectors reviewed the operator logs associated with the AAC DG.
Procedure "Outside Log" required that the fo 11 owing switches be verified
in the Auto-after-Trip position on a daily basis: O-AAC-1-05M3. O-AAC-1-
05L2. O-AAC-1-05L3. O-AAC-1-05Ll. and O-AAC-1-05Ml.
The operator logs
performed on November 27 did not identify that the switches were in the
PTL position. Discussions with the Operations Department determined
that.the AAC DG logs were taken by a trainee on November 27 with a
qualified operator present. The qualified operator was in the room but
did not directly observe the trainee when the logs were taken.
If the
operator had properly performed his log taking responsibilities the
inoperable AAC DG would have been identified on November 27.
The
failure to follow the requirements of Procedure "Outside Log" is
identified as Violation 50-280. 281/97012-02.
J
3
The licensee initiated a Category 2 Root Cause Evaluation following
discovery of the mispositioned switches.
The licensee had not completed
the evaluation by the end of the inspection period.
c. Conclusions
.
- ,
-
,,
A violation was identified for the.failure to have appropriate
instructions available to return the Alternate Alternating Current
Diesel Generator to service following maintenance activities. This
condition resulted i~the generator being unavailable to automatically
connect to the station electrical busses for a period of approximately
36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />,
A violation was identified involving the failure to properly perform the
verification that the Alternate Alternating Current Diesel Generator
breaker control switches were in the Auto-after-Trip position as
required by operator logs.
While returning the Alternate Alternating Current Diesel Generator to
service. the operating crews demonstrated a willingness to accept .
inadequate instructions and exhibited a lack of attention to detail and
questioning attitude. This evolution also revealed a weakness in the
control of trainees by qualified watchstanders.
01.3 Unit 2 Reactor Trip and Restart
a.
Inspection Scope (71707)
The inspectors reviewed the activities associated with a Unit 2 manual reactor trip.
b. Observations and Findings
On December 2. Unit 2 was manually tripped from 100 percent power when
Annunciator H-A-8, "Main Steam Trip Valve Closed." was received in the
control room and the reactor operator observed that the "A" Main Steam
Trip Valve (MSTV) indicated an intermediate position. The unit was
stabilized at hot shutdown.
During the reactor trip, six control rods
did not indicate less than 10 steps as required by Emergency Operating
Procedures (EOPs) and the Reactor Coolant System (RCS) was borated an
additional 1100 gallons as required by the EOPs.
All six control rod
indications drifted to zero steps following the reactor trip. Both
source range instruments automatically energized as designed when power
decreased into the source range.
Following the unit stabilization at hot shutdown. the "A" and "B" Steam
Generator Power Operated Relied Valves (PORVs) opened automatically due
to a RCS temperature increase. The operators lowered RCS temperature to
terminate the PORV actuations. Through interviews with the operators.
the inspectors determined that inattention of the operating crew to
4
plant conditions and equipment status caused the unintended RCS
temperature increase and resulting steam generator PORV actuations.
The "A" MSTV did not close during the event.
Inspection of the "A" MSTV
determined that the open limit switch arm was displaced below the valve
position arm resulting in an intermediate indication in the control room
and the annunciator alarm.
When the limit switch was reset. the limit
switch arm and valve position arm had marginal overlap. Prior to
returning the unit to service. the limit switch mounting was modified to
provide more contact area.
The reason the switch became disengaged from
the valve position arm could not be determined.
However. insulation
work_ on,the '.',A" MSJV wa.s Jhought to _be a potential contributor to the
malfunction.
The six rod position indicators that did not indicate less than 10 steps
following the reactor trip were calibrated prior to restart of the unit.
The unit was returned to service at 11:42 p.m. on December 3.
The
inspectors observed the reactor startup. The shift briefing prior to
startup and operator performance while taking the reactor critical were
excellent. Following the return to service of the unit. power was
maintained at approximately 35 percent to resolve an issue with the
Anticipated Transients Without Scram Mitigating System Actuation
Circuitry (AMSAC).
AMSAC is not required below 40 percent reactor
power.
The licensee had previously identified that the system may not
automatically enable prior to 40 percent reactor power based on the fact
that the enable setpoint actuates off turbine first stage pressure.
This item was discussed in more detail in NRC Inspection Report Nos. 50-
280. 281/97-10.
The licensee lowered the AMSAC enable setpoint to
ensure that the system would enable pri.or to 40 percent reactor power.
While the unit was holding at 35 percent power to resolve AMSAC enable
setpoint concerns. the Turbine Driven Auxiliary Feedwater Pump (TDAFWP)
was tested as required by the TS.
During the test. the turbine tripped
on overspeed.
The licensee decided to maintain power at 35 percent
power until the cause of the turbine overspeed was identified and
corrected. The TDAFWP trip is discussed in more detail in Section Ml.1.
The unit was returned to 100 percent power on December 6. following the
replacement of the TDAFWP governor.
c. Conclusions
The plant response to a Unit 2 manual reactor trip was normal except for
a problem with control rod indications. With the unit stabilized at hot
shutdown. inattention of the operating crew to plant conditions resulted
in steam generator power operated relief valve actuations. Maintenance
items identified following the trip were corrected prior to restart of
the unit.
The shift brief prior to startup and operator performance while taking
the reactor critical were excellent.
. -
5
. Management's decision to hold power at approximately 35% while resolving
issues with an Anticipated Transients Without Scram Mitigating System
Actuation Circuitry setpoint and with the Turbine Driven Auxiliary
Feedw.ater Pump was .conservative and demonstrated a good safety
perspective:
08
Misce.llaneous*Operations tssues (90712)
08.1 (Closed) Licensee Event Report (LER) 50-280. 281/97010-00: Missed fire
- protection survei 11 ance due to personnel.error. .This event-was
.
discussed in NRC Inspection Report Nos. 50-280 .. 281/97.-10 :and resulted
iri the issuance of a Non-cited Violation; The. inspectors reviewed the
LER and determined that the report adequately described the event ~nd
a-ssoci ated corrective actions.
II. Maintenance
Ml
Conduct of Maintenance
Ml.1 Unit 2 Turbine Driven Auxiliary Feedwater Pump CTDAFWP) Overspeed Trip
a .. Inspection Scope (61726) (62707}
The inspectors reviewed a overspeed trip event of the Unit 2 TDAFWP
- during testing.
b. Observations and Findings
On December 4. following the return of Unit 2 to operational status. a
TDAFWP performance test was conducted in accordance with Procedure
2:..oPT-FW-003. "Turbine Driven Auxiliary Feedwater Pump 2-FW-P-2." The
Unit 2 TDAFWP operated normally for approximately one minute. and then
began to experience divergent speed oscillations which resulted in an
Subsequent to the TDAFWP trip. the licensee started the TDAFWP several
times. and no overspeed trips occurred.
However. computer traces of the
TDAFWP's speed indicated an instability in the operation of the TDAFWP
governor as indicated by convergent oscillations at low speeds.
The
licensee replaced the TDAFWP governor and tested the TDAFWP
satisfactorily on December 6.
An in depth review by the licensee revealed that the Unit 2 TDAFWP
governor had been r-eplaced during the October 1997 Refueling Outage.
The governor was replaced in accordance with Work Order 00310109-01
and-Procedure O-MCM-1403-01. "Terry Turbine Overhaul. 1-FW-T-2 and
2-FW-T-2," Revision 8.
An examination of the maintenance documentation
revealed that Section 6.12 (Governor Post-Maintenance and Operational
Checks) of Procedure O-MCM-1403-01 had not been performed although it
was designated as a post maintenance test requirement in Work Order 00310109-01. Specifically, Section 6.12 of Procedure O-MCM-1403-01
provided instructions to perform final tuning/adjustment of the governor
6
following installation and/or maintenance.
These instructions had been
added earlier as corrective actions for previous problems experienced
with the TDAFWP governors.
The Unit 2 TDAFWP- was tested s.atisfactorily following the October 1997
Refueling Outage.
An examination of the speed traces taken during this
test did not reveal a governor- malfunction. :on December 2. during the
manual reactor trip from 100 percent power.* the TDAFWP automatically
started -.and i nJected as expected.
Based on the.inspectors
1 and
licensee:s review- ofcthese circumstances. past inoperability (from the
refueling outage, until the December" 4,TDAFWP trip) could not.be
cone l us i ve l y demonstrated. : * :
The failure to perform adjustments to the Unit.2 TDAFWP governor in
accordance with Section 6.12 of Procedure O-MCM-1403-01 prior to
returning the machine to :service is* a failure to follow safety related
work procedures. This is a violation of TS 6.4.A.7 and will be tracked
as Violation 50-281/97012-03.
c. Conclusions
A violation wa?_ i_dentified.for-faHure* to**perform post maintenance
testing which was specified in work instructions for the .Unit 2 Turbine
Driven Auxiliary Feedwater Pump governor replacement.
Ml.2 Maintenance Observations
a.
Inspection Scope (62707)
The inspectors observed all or portions of and/or reviewed documentation
for the Work Orders (WOs) and the Design Change Packages (DCPs)
discussed below.
b. Observations and Findings
Emergency Diesel Generator (EOG) No. 1 Radiator Louvers
The inspectors*observed the licensee initiate a troubleshooting process
in accordance with WO 003730130. Troubleshoot/Repair East Louver
Control.
The WO contained very specific instructions from the system
engineer for the troubleshooting process. The process was performed in
accordance with O-ECM-0701-01. "Emergency Diesel Generator Maintenance."
Revision -4.
The inspectors reviewed the WO and procedure which were
present and followed at the jobsite. The system engineer was present to
support maintenance and observe work progress. The inspectors observed
that the craft were methodical and professional in performance of their
duties and coordination between maintenance. engineering and operations
was good.
The problem was identified as a feedback circuit in the
actuator. A new actuator was tested and installed. Subsequently, the
east EDG radiator louvers functioned correctly during the post-
maintenance test.
7
In conjunction with the above maintenance activities. the licensee
implemented DCP 94-011.27 using WO 00377350-01. WO 00377350~02 and a
generic procedure. "Standing MI Low Voltage Modifications -Surry/Units
1&2." The inspectors reviewed portions of the design package and
determined that the safety evaluation was appropriate.
The modification
involved the removal of a capacitor in the louver control circuit which
was, initially intended to act as an arc suppressor.
The vendor
indicated that arc suppression was not needed and the capacitors might
cause harm to internal switches. The vendor. Barber-Colman. recommended
removal of the capacitors.
Control Room and Emergency Switchgear Room Chillers
The inspectors observed Preventative Maintenance (PM) activities
performed-on Control Room Chiller 1-VS-E-4B.
The PM was performed in
accordance with WO 00373029-01 and Procedure O-MCM-0814-01. "Control
Room Chiller Maintenance." Revision 1. The PM involved the change out
of compressor oil. inspection and cleaning of oil and suction strainers.
and cleaning of the reservoir.
The inspectors determined that the
procedure was at the jobsite and was followed. the procedure
instructions were thorough. and the technicians were knowledgeable of
the assigned task. Also. foreign material exclusion control was
maintained while the chiller was open.
Screen Wash Pump 2A Discharge Check Valve
The inspectors observed maintenance personnel replacing a check valve in
the discharge piping of Screen Wash Pump 2A.
The check valve was stuck
open causing Pump 2A to spin backwards when parallel Pump 2B was
operated.
The job was performed in accordance with WO 00373932.
The
valve was a flanged connection and involved removal of eight bolts in
each flange and a spool piece between the pump expansion joint and the
valve.
Work instructions were adequate and followed. personnel were
knowledgeable of the task and engineering support was evident from valve
specifications and torque tables being included in the work package.
Screen Wash Pump 2A Motor Replacement
The inspectors observed replacement of the Screen Wash Pump 2A Motor
which had shorted out when the licensee attempted to run the motor after
the maintenance on the discharge check valve.
The licensee stated that
there was not an apparent connection between the failure and the
previous maintenance.
The work was performed in accordance with Urgent
WO 00379533-01 and Electrical Corrective Maintenance Procedure O-ECM-
1404-02. "Low Voltage Motor Maintenance." Revision 1. The work package
was maintained at the jobsite and was followed.
Good coordination was
noted between electrical and mechanical groups.
Welders were available
as needed to remove the pump to motor coupling.
The job was difficult
due to severe corrosion resulting from the salt water environment but
was thoroughly performed.
8
Replace High Level Intak~ Structure Level Probe
The inspectors observed the licensee change out the high level intake
structure level probe in accordance with WO 00376855-01.
Previous
failures of these probes due to biofouling resulted in the licensee
changing out the Unit 2 probe to monitor probe function and the degree
of biofouling. The response time of the old probe was measured at 31
seconds before removal. After installation. the new probe's response
time was 26 seconds.
The acceptance limit for response time was less
than. 66 seconds.
- *
The inspectors observed that safety measures and foreign material
exclusion control were. in force at;_.the jobsite. Change-out of the
probes involved sending divers into high level screen wash well 2A to
remove the bottom bracket of the probe and sending a technician into the
well to remove the upper bracket. Communication was maintained with
these personnel at all- times and appropriate safety lines were *used. :
Tools used in the well were tethered and an inventory maintained. Also.
a guard was posted at the entrance to the well while the floor grating
was removed.
The various groups involved in the job were well
coordinated and knowledgeable of their assigned tasks. The inspectors
verified that procedures were at the jobsite and followed.
c. Conclusions
Maintenance activities involving emergency diesel generator radiator
louvers. control room chiller. the screen wash system. and the high
level intake structure level probe were completed in a thorough and
professional manner. Maintenance personnel were knowledgeable of the
assigned tasks. procedures were detailed and actively used on the job.
and cooperation and coordination between various plant groups were good.
Ml.3 Surveillance Observation
a.
Inspection Scope (61726)
The inspectors observed all or portions and/or reviewed documentation
for the surveillance activities discussed below.
b. Observations and Findings
Control Room Chiller Performance Tests
The inspectors observed performance testing of Control Room Chillers
1-VS-E-4B and 1-VS-E-40 in accordance with Procedure O-MPM-0210-01.
This procedure provided instructions for verifying chiller and service
water temperature and pressure parameters and is performed three times a
week for early indication of chiller problems.
The procedure was
thorough and provided acceptable ranges for the various parameters.
This test also served as a post maintenance test for the chiller PM.
The inspectors observed that the procedure was at the jobsite and was
9
followed. technicians were knowledgeable of their assigned tasks and
results were documented.
Emergency Servi*ce Water Pump Diesel
-
The inspectors observed the check out of the diesel for Emergency
Service Water Pump 1-SW-P-lC iri accordance with Procedure O-MCM-0703-01.
This test was a combined effort by Operations. Electrical and Mechanical
Maintenance .. and the vendor representative. The inspectors observed *
erigine preparation for start-up, inspection of the engine after start.
adjustment of the idle* speed. -veri fi cation of valve clearance and *.
verification that the ,air shutdown valve would manually trip. the engine.
The test was thorough and -we 11 moni tared. Personnel .were knowledgeable
of the task. and coordination between groups was good.-
Auxiliary Feedwater System
The inspectors observed the functional checkout of the TDAFWP in
accordance with Procedures l-OPT-FW-003 and l-OPT-FW-007.
The
inspectors attended the pre-job briefing and determined that the
briefing was thorough and complete.
Procedures were walked through and
responsibilities were identified. The inspectors observed the periodic
testing of the TDAFWP including verification of steam supply check valve
full flow and backseating, the stroke time of the steam admission
,
valves. vibration measurements and pump flow and pressure measurements
using the recirculation flow path. All parameters were in the
acceptable range and the test was successfully completed. Coordination
between various plant groups was good.
c.
Conclusions
Surveillance activities involving the control room chillers. an
emergency service water pump. and the turbine driven auxiliary feedwater
pump were completed in a thorough and professional manner.
Maintenance
personnel were knowledgeable of the assigned tasks. procedures were
detailed and actively used on the job, and cooperation and coordination
between various plant groups were good.
MB
Miscellaneous Maintenance Issues (92700)
M8.l (Closed) LER 50-280. 281/97011: Improper bypass breaker testing due to
inadequate definition of "in service.* This LER reported the failure to
perform a surveillance test required by TS 4.1.A and TS Table 4.1-1.
item 36.
More specifically, the licensee was not testing the remote
manual undervoltage trip prior to placing the reactor trip bypass
breakers in service as required by TS. Rather. the licensee was testing
the remote manual undervoltage trip after placing the breaker(s) in
service. This matter was discovered at a Management Safety Review
Committee Meeting during a discussion of a similar matter related to an
occurrence at the licensee's North Anna Power Station (Reported to the
10
NRC in LER.338. 339/96009).
The* operating experience review staff
failed to recognize the applicability of improper reactor trip bypass
breaker testing to Surry after this issue was identified in October 1996
at the licensee's North Anna Station.
As corrective action for this matter. the licensee performed the
following;
1) a station deviation report was issued to document the
matter. and 2) the surveillance testing -procedures (for both Unit 1 and
2) were revised to provide.instructions to-test the remote manual
undervoltage trip*prior to placing the reactor trip bypass breaker(s) in
service, The inspectors*observed*the testing-of the Unit 1-reactor trip
bypass breakers fo 11 owing. the revision of the survei 11 ance testing
procedwre.
The remote manual undervoltage trip was tested prior to
placing the reactor tri'p bypass breakers in service.
Failure to test the remote manual undetvoltage trip prior to placing the
reactor *trip bypass breakers inservice is a violation of TS 4.1.A. Table
4.1-1. item 36. This non-repetitive. licensee identified and corrected
violation is being treated as a Non-cited Violation (NCV) consistent
with Section VII.B.l of the NRC Enforcement Policy. This matter is
identified as NCV 50-280, 281/97012~04.
El
Conduct of Engineering
-a.
Inspection Scope (37551)
III. Engineering
The inspectors reviewed the active Unit 1 and Unit 2 Temporary
Modifications (TMs).
b. Observations and Findings
At the end of the inspection period Unit 1 had four active TMs installed
and Unit 2 had no active TMs.
The inspectors verified that safety
evaluations had been performed and approved for all the active TMs prior
to installation of the TM and that the operators were aware of the
i nsta 11 ed TMs .
c. Conclusions
The total number of temporary modifications. four on Unit 1 and none on
Unit 2. indicated a willingness to correct problems in an expeditious
manner.
The temporary modifications had safety evaluations performed
prior to installation .
. ~
11
IV. Plant Support
Rl
Radiological Protection and Chemistry Controls
Rl.1 General Comments (71750)
On numerous occasions <luring the inspection period. the inspectors
reviewed Radiation Protection (RP) practices including radiation control
area entry and exit. survey results. and radiological area material
condi ti ans . * No discrepancies were noted .. and the inspectors determined
that RP practices were proper ..
'
.
Rl.2 Transportation of*Radioactive Materials
a.
Inspection Scope *(86750)
The inspectors reviewed selected elements of the licensee's program for
transportation of radioactive materials to determine whether the
licensee properly processes. packages. stores. and ships radioactive
materials and whether the changes to the Department of Transportation
(DOT) and NRC regulations. which became effective on April 1.1997. had
been implemented.
The review included records for training of personnel
on the changes to the regulations. procedures for prepari.ng radioactive
material for shipment. and shipping papers for selected recent
shipments.
Those procedures and records were evaluated for consistency
with the requirements delineated in 49 CFR Parts 170 - 179. 10 CFR Part
20. and 10 CFR Part 71 for licensed material transported outside the
confines of the plant.
b.
Observations and Findings
The inspectors reviewed the training records for selected individuals
authorized to sign shipping papers and determined that training on the
changes to the regulations had been provided during February, June and
August 1996. i.e .. prior to the effective date of the changes.
The
selected individuals included two *Health Physics (HP) area supervisors
and two HP technicians. The manuals for the above training were also
reviewed and found to have specifically addressed the new rules for the
following topics: Low Specific Activity (LSA) and Surface Contaminated
Object (SCO) hazards. definitions. and requirements; placarding.
labeling. and marking of vehicles and packages; use of Systems
Internationals (SI) units on shipping papers. labels. and emergency
response instructions; package selection; waste classification; shipping
papers; and receipt procedures and surveys. The inspectors reviewed HP
Procedures HP-1071.021. 1071.030. 1071.040. 1072.010. 1072.020.
1072.030. 1072.040. 1072.050. and 1072.060 and determined that the
instructions therein were consistent with applicable DOT and NRC
requirements for selection of an acceptable container for various types
of materials. LSA and SCO classifications. vehicle placarding, package
marking and labeling, use of SI units. contamination and radiation
levels. shipping papers. vehicle inspection. driver's instructions.
emergency response information. and material receipt. The inspectors
' -
12
noted that the procedures included attachments for specific types of
shipments which delineated the pertinent requirements applicable to the
material and/or~hipment type and checklists for assuring that each of
the requirements were met.
The licensee indicated those attachments
were d~veloped to provide the individuals involved in the preparation of
shipments with a readily available listing of the applicable
-
requirements.-
Imp 1 ementat ion of enhanced procedures for shipping
radioactive materials was deemed by the inspectors to be a program
strength.
The licensee used computer programs (RADMAN) for guidance in preparing
radioactive materials for shipment and for generating shipping papers.
~hose programs included libraries of A1 and A v~lues. i.e .. radio
nuclide activity levels used for selection of proper shipping packages.
The inspectors verified that the A1 and A2 values for five selected
radio nuclides listed in those libraries were accurate.
The licensee's shipment logs indicated that. as of mid-November. the
licensee had made 78 shipments of radioactive material this year.* The
inspectors reviewed the shipping papers for four recent shipments
consisting of: liquid waste shipped to a licensed waste processor: dry
active waste shipped to a licensed waste processor for volume reduction:
a cask of resin shipped for disposal: and contractor owned outage
related tools returned as SCOs.
The information on the shipping papers
was found to be consistent with applicable DOT and NRC requirements and
the licensee's procedures.
The inspectors toured interior and exterior storage areas used for
temporary storage of packaged low'."level radwaste awaiting shipment.
radwaste awaiting further processing. or slightly contaminated equipment
held for reuse.
The inspectors noted that the containers were
appropriately labeled.
During the inspection the inspectors called the
emergency response telephone number listed on the shipping papers for a
shipment which was currently in transit and determined that emergency
response and incident mitigation information was readily available.
c.
Conclusions
The licensee had effectively implemented a program for transportation of
radioactive materials pursuant to DOT and NRC regulations.
Enhanced
procedures for shipping radioactive materials was found to be a program
strength.
Rl.3 Water Chemistry Controls
a.
Inspection Scope (84750)
The inspectors reviewed implementation of selected elements of the
licensee's water chemistry control program for monitoring primary and
secondary water quality.
The review included examination of program
guidance and implementing procedures. and analytical results for
selected chemistry parameters. Those procedures and data were compared
13
to the requirements in TSs 3 .1 0-. 3 .1. F and 4 .1 C for monitoring
specific primary coolant chemistry parameters and to the programmatic
requirements. delineated in License Condition 3.K. for monitoring
secondary water chemistry.
b.
Observations and Findings
The inspectors reviewed Virginia* Power Administrative Procedure (VPAP)
2201. "Nuclear Plant Chemistry Program". Revision No. 2. and determined
that. it included provisions for sampling and analyzing reactor coolant
at the prescribed frequency for the parameters required to be monitored
by the TSs.
The procedure also included provisions for monitoring
primary and secondary water quality based on established industry
guidelines and standards. Although the licensee's procedure did not
specifically indicate that their program included implementation of the
Electric Power Research Institute (EPRI) guidelines. for Pressurized
Water Reactor (PWR) primary and secondary water chemistry. the
inspectors used those guidelines as references for evaluating the
effectiveness of the licensee's program. The inspectors noted that VPAP-
2201 listed the sampling frequency and typical values for each parameter
to be monitored. Action levels applicable to various operational modes
were given where appropriate. Guidance was also provided for actions to
be taken if analytical results exceeded prescribed limits. The
inspectors determined that the above guidance and procedures were
consistent with the applicable TS requirements and. with a few minor
exceptions for good cause. the EPRI guidelines.
The inspectors also reviewed records of analytical results for selected
parameters generated during the period September through November 1997.
The parameters selected included dissolved oxygen. chloride. fluoride.
pH, and dose equivalent iodine-131 in reactor coolant; copper and
hydrazine in feedwater; sodium in steam generator blowdown; and
ethanolamine in condensate. Those parameters were maintained well
within the relevant TS limits and within the EPRI guidelines for power
operations. The inspectors noted that the dose equivalent iodine-131 in
the Unit 1 reactor coolant was approximately an order of magnitude
higher than that of Unit 2 due to a leaking fuel rod in Unit 1.
c.
Conclusions
Based on the above reviews. the inspectors concluded that the licensee's
water chemistry control program for monitoring primary and secondary
water quality had been implemented in accordance with the Technical
Specification requirements and industry guidelines for pressurized water
reactor water chemistry.
Rl.4 Post Accident Sampling
a.
Inspection Scope (84750)
The inspectors reviewed implementation of the licensee's program for
obtaining and analyzing samples of reactor coolant and containment
14
atmosphere under accident conditions.
The review included examination
of procedures and records for operation of the High Radiation Sampling
System (HRSS). training of personnel on operation of the system. and
calibration of the system's in-line analytical instrumentation.
The
procedures and records were evaluated for consistency with the
programmatic requirements specified in TS 6.4.M and with the design
bases for system capabilities as described in Section 9.6 of the Updated
Final Safety Analysis Report (UFSAR).
b .. Observattons 1and Findings
The inspectors reviewed 13 procedures pertaining to operation. training.
and calibration of the HRSS.
The procedures included provisions for
operating the system on a monthly basis. alternating between units. for
the purposes of verifying the functionality of the equipment and to
provide continuing on-the-job tratning of personnel in the use of the
equipment. Acceptance criteria were specified for comparison of the
analytical results from the HRSS to results from the routine sampling
methods.
The procedures also provided for weekly calibration of the in-
line analytical instrumentation.
The inspectors determined that the
licensee's procedures were consistent with TS 6.4.M and UFSAR Section
9.6.
The licensee's records for the monthly operational tests of the
HRSS during the period May through October 1997 and the weekly
calibrations of the HRSS in-line analytical instrumentation during the
period September through October 1997 were reviewed by the inspectors.
The records indicated that the tests and calibrations had been performed
at the prescribed frequency and that the results were generally
satisfactory. During October 1997. the licensee had experienced
problems with the apparatus for in-line measurement of pH and boron
concentration of reactor coolant samples.
Work requests were promptly
issued for repair of the equipment.
The inspectors noted that the HRSS
included equipment for collecting diluted and undiluted grab samples for
analysis by onsite or offsite laboratories if necessary.
c. Conclusions
Based on the above reviews and observations. the inspectors concluded
that the licensee had implemented and maintained a program for obtaining
and analyzing samples of reactor coolant and containment atmosphere
under accident conditions in accordance with Technical Specification
requirements and Updated Final Safety Analysis Report commitments.
Sl
Conduct of Security and Safeguards Activities (71750)
On numerous occasions during the inspection period. the inspectors
performed walkdowns of the protected area perimeter to assess security
and general barrier conditions.
No deficiencies were noted and the
inspectors concluded that security posts were properly manned and that
the perimeter barrier's material condition was properly maintained .
- -
F8
15
Miscellaneous Fire Protection Issues (71750)
F8.l Fire Protection Predecisional Enforcement Conference
On December 4, 1997. an open predecisional enforcement conference was
held to discuss_the results of an NRC inspection conducted durin~ the
period-of August -24 through October 4. 1997.
The inspection-results
-were documented in NRC Inspection Report Nos. 50-280. 281/97-09 which
were se~t to the licensee by letter dated October 30. 1997.
Four
apparent violations were identified in this report.
EEI 50.:280, 281/97009-03, Failure to meet the requirements of Appendix R
for vital bus isolation.
EEI 50-280; 281/97009-04: Failure to meet the requirements of Appendix R
for circuit breaker coordination.
, .
EEI 50-280. 281/97009-05: Failure to promptly correct licensee
identified Appendix R fire protection discrepancies.
EEI 50-280, 281/97009-06: Fai*lure to report Appendix R fire protection
discrepancies which were outside the design basis of the plant.
Based on information developed during the inspection and information
provided during the predecisional enforcement conference. the NRC
determined that violations of NRC requirements had occurred. Apparent
violations EEI 50-280. 281/97009*-03. and EEI 50-280. 281/97009-05 were
identified as Violations (VIOs) 50-280. 281/EA 97-474 01013 and 50-280.
281/EA 97-474 01023 which constituted a Severity Level III problem.
Apparent violation EEI 50-280, 281/97009-06 was identified as a Severity
Level IV violation. VIO 50-280. 281/EA 97-474 02014.
Apparent Violation EEI 50~280, 281/97009-04. has been re-characterized
as a deviation from a commitment in UFSAR Section 9.10. This deviation
is identified as DEV 50-280. 281/97009-09.
V. Management Meetings
Xl
Exit Meeting Summary
The inspectors presented the inspection results to members of licensee
management at the conclusion of the inspection on January 7, 1998,
The
licensee acknowledged the findings presented.
The inspectors asked the licensee whether any materials examined during the
inspection should be considered proprietary.
No proprietary information was
identified.
PARTIAL LIST OF PERSONS CONTACTED
M. Adams. Superintendent. Engineering
R. Allen. Superintendent. Maintenance
..
16
R. Blount. Assistant Station Manager. Nuclear Safety & Licensing
D. Christian. Station Manager
E. Collins. Director. Nuclear Oversight
M. Crist. Superintendent. Operations
B. Shriver. Assistant Station Manager. Operations & Maintenance
T. Sowers*. Superintendent.* Training
B. Stanley .. Supervi so*r. Licensing
_
W. *Thornton. ~uperintendent. RadiologicaJ Protection
IP 37551:
IP 40500:
IP 61726:
IP 62707:
IP 71707:
IP 71750 :.
IP 84750:
IP 86750:
IP 90712:
IP 92700:
Opened
INSPECTION PROCEDURES USED
I ~
Onsite Engineering
Effectiveness of Licensee Controls in Identifying, Resolving, and
Preventing Problems
Surveillance Observation
Maintenance.Observation
Plant *operations
Plant Support Activities
Radioactive Waste Treatment. and Effluent and Environmental*
Monitoring
. ..
.
..
Solid Radioactive Waste Management and Transportation of
Radioactive Materials
Inoffice Review of Written Reports of Nonroutine.Events at Power
Reactor Facilities
Onsite Followup of Written Reports of Nonroutine Events at Power
Reactor Faciliti.es
ITEMS OPENED AND CLOSED
50-280. 281/97012-01
Failure to have appropriate
procedures/checklists to return the AAC
diesel generator to service following
maintenance activities (Section 01.2)
50-280. 281/97012-02
Failure to properly perform operator logs
(Section 01. 3).
50-281/97012-03
Failure to follow work instructions
related to the Unit 2 TDAFWP governor
replacement (Section Ml.1).
50-280. 281/97012-04
Improper bypass breaker testing due to
inadequate definition of "in service*
(Section M8.1).
50-280. 281/EA 97-474 01013
Failure to meet the requirements of
Appendix R for vital bus isolation
(Section F8 .1).
~ -
17
50-280. 281/EA 97-474 01023
Failure to promptly correct licensee
identified Appendix R fire protection
discrepancies (Section FB.1)~
50-280, 281/EA 97-474 02014
Failure to report Appendix R fire
protection discrepancies which were
outside the design basis of the plant
(Section FB.1).
50-280. 281/97009-09
DEV
Failure to meet the commitments to
Appendix R for circuit breaker
coordination (Section FB.1).
Closed
50-280. 281/97010-00
LER
Missed fire protection surveillance due to
personnel error (Section 08.1).
50-280, 281/97012-04
Improper bypass breaker testing due*to
inadequate definition of "in service"
(Section MB .1).
50-280, 281/97011-00
LER
Improper bypass breaker testing due to
inadequate definition of "in service"
(Section MB.1).
50-280, 281/97009-03
Failure to meet the requirements of
Appendix R for vital bus isolation
( Sect i on FB. 1) .
50-280, 281/97009-04
Failure to meet the requirements of
Appendix R for circuit breaker
coordination (Section FB.1).
50-280, 281/97009-05
Failure to promptly correct licensee
identified Appendix R fire protection
discrepancies (Section FB.1).
50-280, 281/97009-06
Failure to report Appendix R fire
protection discrepancies which were
outside the design basis of the plant
(Section FB.1).