ML18152A220
| ML18152A220 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 08/25/1988 |
| From: | Cantrell F, Holland W, Larry Nicholson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18152A221 | List: |
| References | |
| 50-280-88-28, 50-281-88-28, IEB-85-003, IEB-85-3, NUDOCS 8809140384 | |
| Download: ML18152A220 (17) | |
See also: IR 05000280/1988028
Text
Report Nos.:
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, N.W.
ATLANTA, GEORGIA 30323
50-280/88-28 and 50-281/88-28
Licensee:
Virginia Electric and Power Company
Richmond, Virginia
23261
-Docket Nos.:
50-280 and 50-281
Facility Name:
Surry 1 and 2
License Nos.:
Inspection Conducted:
'lh :;L
Date Signed rr)
<g' - fJ 5'---o o
L. E.
Date Signed
?Thsko-
trate S'i gned
SUMMARY
Scope:
This routine resident inspection was ~ondu2ted on site in the areas
of licensee action on previous enforcement matters, plant operations,
plant maintenance, plant surveillance, and plant startup from
refueling.
Results:
The following items were identified in this inspection report.
One apparent violation (paragraph 3) was identified for failure to
provide adequate procedures, and/or to follow
procedures
for
cleanliness and foreign material exclusion with regard to maintenance/
modifications on safety-related systems (280; 281/88-28-01).
One unresolved item (paragraph 5) was identified for evaluation and
review of the emergency diesel generator room louvers (280;
281/88-28-02).
One inspector followup item (paragraph 5) was identified involving a
test to demonstrate adequate service water flow to the component
coo 1 i ng water heat exchanger ( CCWHX) without the vacuum priming
system in service (280; 281/88-28-03).
One unresolved item (paragraph 7) is identified for additional review
of the original modification package, and the subsequent safety
reviews associated with the modification of the reactor trip breakers
which allow for remote connection of test equipment (280/88-28-04).
8809140384 880830
ADOCK 05000280
G
PNU
1.
Persons Contacted
Licensee Employees
REPORT DETAILS
J. Bailey, Superintendent of Operations
D. Benson, Station Manager
H. Blake, Superintendent of Site Services
R. Blount, Superintendent of Technical Services
- R. Cramer, Superintendant of Projects, Site Services
- E. Grecheck, Assistant Station Manager
- R. Johnson, Operations Supervisor
- R. MacManus, Supervisor, Surveillance and Test Engineering
G. Miller, Licensing Coordinator, Surry
- H. Miller, Assistant Station Manager
- J. Ogren, Superintendent of Maintenance
- J. Price, Site Quality Assurance Manager
S. Sarver, Superintendent of Health Physics
- Attended-exit meeting.
Other licensee employees contacted included control room operators,
shift technical advisors, shift supervisors and other plant personnel.
The NRC Region II Section Chief, F. Cantrell, visited the Surry Power
Station on July 12 and 13, 1988.
Mr.
Cantrell 1 s tour included all
accessable
uncontaminated areas of Unit 1 including the auxiliary
building, safeguards areas, control room, and emergency diesel generator
rooms.
Unit 1 was heating up from cold shutdown to hot shutdown in
preparation for restart during the tours.
On July 28, 1988, the NRC systematic assessment of licensee performance
(Inspection Report 280; 281/88-05) for the period of September 1, 1986, to
April 30, 1988, was presented to Virginia Power management and discussed
at the Surry Power Station.
The presentation was conducted by C. Hehl,
Deputy Director, Division of Rear.tor Projects (DRP), RII.
Other NRC
personnel that were in att~ndance are listed below. *
M. Ernst, Deputy Regional Administrator, RII
H. Berkow, Director, Project Directorate II-2, NRR
B. Wilson, Chief, Projects Branch 2, DRP, RII
C. Patel, Project Manager, Surry, NRR
W. Holland, Senior Resident Inspector, Surry, DRP, RII
L. Nicholson, Resident Inspector, Surry, DRP, RII
L. Engel, Project Manager, North Anna, NRR
2.
Plant Status
Unit 1
2
Unit 1 began the reporting period in cold shutdown (day 87 of a
maintenance/refueling outage). During this period, the unit completed all
outage-related work and commenced heatup above 200 degrees Fon July 9;
however, when the unit rea~hed approximately 500 degrees Fon July 10,
leakage was identified through a containment isolation valve in the
containment spray system.
The unit entered a 30 hour3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> LCD to cold shutdown
in order to repair the leaking valve.
The unit returned to cold shutdown
on July 11.
Repairs were accomplished on the leaking valve, and heatup was
resumed on July 12.
The reactor was taken critical on July 14.
An
i~advertent boration during physics testing on July 14 caused the reactor
to go subcri ti cal; therefore, the contra l rods were admi n i strati ve ly
tripped.
The unit restarted on July 15.
Physics testing was completed
late on that same day.
The final testing of the turbine driven auxiliary
feedwater pump was completed after emergency repairs were made on July 18,
and the unit returned to power operation on the same day.
(Auxiliary
feedwater pump repairs are addressed in paragraph 6.) The unit operated
at power for the remainder of the inspection period.
Unit 2
Unit 2 began the reporting period at power.
The unit operated ~t power
for the duration of the inspection period.
3.
Licensee Action on Previous Enforcement Matters
(92702)
(Closed) Unresolved Item 280; 281/88-26-02, Review of the licensee's
program for control of cleanliness and foreign material exclusion in
safety-related systems or components.
This issue was identified in
inspection report 280; 281/88-26.
In that report, the inspector reviewed
selected administrative procedures relating to cleanliness which were used
by licensee personnel and contractor personnel.
The inspector then
reviewed selected plant work orders and design change packages, and
determined that in several instances, appropriate documentation was not
available in those packages to ensure that cleanliness, or foreign material
exclusion was being maintained during the maintenance activities.
During this inspection period, the inspector continued with his review.
The inspector reviewed the Virginia Power Topical Report, VEP l-5A dated
June, 1986.
In that report, the licensee stated "Cleanliness will be
maintained, consistent with the work being perfor~ed, so as to prevent the
entry of foreign material into safety-related systems. This will include,
as a minimum, documented cleanliness inspections which will be performed
prior to system closure .
11
The inspector discussed this requi rern:ent with
the licensee, and requested that the licensee provide additional
information with regards to other administrative procedures that implement
this position.
3
The inspector continued his inspection with review of the following
administrative
procedures that were
in effect during the Unit 1
refueling/maintenance outage that was completed during this inspection
period.
SUADM-M-02, PLANT HOUSEKEEPING, dated April 30, 1985.
This procedure
provides for guidance with regard to cleanliness and accountability
in critical areas (i.e., reactor cavity when reactor vessel is open,
refueling areas, fuel building, containment, safety-related work
areas, etc.). The inspector considers that this procedure implements
the requirements of the topical report referenced above.
SUADM-M-16, OPERATION OF THE MAINTENANCE DEPARTMENT, dated March 3,
1988.
This procedure provides requirements with regard .to procedural
control of safety-related maintenance activities. The procedure also
defines minor maintenance, as maintenance of a simp1e nature that can
be safely performed without the use of a safety committee approved
procedure.
After review of the above procedures, the inspector reviewed work orders
that were accomplished in the Unit 1 containment
prior to
identification of the inside recirculation spray pump problems which were
discussed in inspection report 280; 281/88-26.
The work orders reviewed
were:
Work Order Job Number (WOJN) 3800062569,
REMOVE
RS SUMP GRATING,
dated 04/18/88.
WOJN 3800062573, INST RS SUMP BLNK (SUMP) PT-16.4, dated 04/18/88.
The inspector noted that both of the above work orders were on a safety-
related system.
However, neither job appeared to have been worked using a
procedure. Also, no documentation was available to identify cleanliness
and foreign material exclusion requirements.
The inspector did note that
WOJN 3800062573 did identify procedure number MMP-C-G-201, CMP FOR FLANGED
JOINTS IN GENERAL, as the procedure which should be used to perform this
work.
However, an add it i ona 1 note on the work order stated that no
procedure was needed.
The inspector reviewed the referenced procedure,
and noted that even if that procedure had been used, no requirements for
system cleanliness or foreign material exclusion were listed, nor would
any
11 as left
11 conditions with regard to cleanliness hav~ been documented.
The
inspector then
reviewed
Design
Change
(DC)
88-01-1,
INSIDE
RECIRCULATION SPRAY PUMP FULL FLOW TEST LINE/ SURRY/ Unit 1, which was
approved for installation by the station safety committee on March 31,
1988.
The inspector specifically looked for cleanliness/foreign material
exclusion controls in the procedure and noted the following:
4
Step 3.5 of the precautions portion of the procedure required that
system cleanliness must be maintained in accordance with ANSI N45.2.l
for a class B system.
The step also required that extreme care
should be exercised when cutting and welding piping to prevent the
introduction of foreign material into the inside recirculation spray
system.
Section 4 of the procedure was the ar.tual work performance section.
In this section, initial engineering inspections and evaluations were
accomplished, the test sump was fabricated, the discharge piping
modifications were accomplished, the pump test piping was fabricated,
and the test 1 ines were installed as required to support testing.
The inspector noted that no steps in this section documented any
cleanliness or foreign material exclusion conditions during, or after
the work was performed.
The inspector discussed the findings with
licensee endineering and management, and concluded that although the
procedure
precaution
(step 3.5
above)
identified
cleanliness
requirements, no procedural requirements were in place to document
actual conditions.
Technical Specification 6.4 requires that detailed written procedures with*
appropriate check-off lists and instructions be provided for preventive
and corrective maintenance operations which would have an effect on the
safety of the reactor, and that these procedures be followed.
The inspector identified two examples (WOJNs of previous page) of failure
to follow procedure with regard to performance of safety-related work
during the Unit 1 outage in April, 1988, as required by SUADM-M-16.
Also,
four examples of failure to follow procedure or inadequate procedure were
identified in' inspection report 280; 281/88-26 with regard to performance
of safety-re 1 ated work during the Unit 2 refue 1 i ng outage in October/
November, 1986.
In addition, documentation of cleanliness controls was
not accomplished as required by administrative procedure (SUADM-M-02).
The inspector also identified three examples of inadequate procedure in
the plant modifications area in that DC' 88-01-1, DC 86-13-1, and DC
87-22-1, were accomplished on safety-related systems during the Unit 1
outage, without documenting cleanliness or foreign material exclusion
conditions prior to system closure as required by the topical report.
In
addition, the inspector determinP-d that the engineering and construction
administrative procedures do not require documentation as stated in the
topical report.
Add it i ona 1 ex amp 1 es of inadequate procedure were i dent i fi ed when the
licensee attempted to test the lA inside recirculation spray pump, and
found foreign material (nuts, bolts, washers, welding rod, etc.) in the
discharge strainer on the test line.
Subsequent inspections of both the
Unit 1 and 2 containment sumps revealed additional foreign material in the
suction
piping
for
other
safety-related
systems
(i.e.,
outside
recirculation spray and
low head safety injection systems).
This
condition was reported to the NRC in licensee event report (LER) 280/88-17
5
(an additional example of failure to follow procedure is identified in
Section 7).
With regard to containment pump cleanliness problems, the licensee's
Engineering Work Request ( EWR)88-247 of June 16, 1988, evaluated the
material found in the Unit 2 pump and its impact on Unit 2 pumping systems
(inside recirculation spray, outside recirculation spray, and low head
safety injection) and the systems' operability.
For Unit 2, the licensee
concluded that there was a low probability of the material in the sump
affecting the ab1lity of any of these pumps to perform their function to
mitigate the consequences of an accident.
The inspectors examined a list
with a description of debris found in the Unit 1 sump.
An EWR for Unit 1
was not completed during this reporting period. Additional discussion of
sump cleanliness and pump operability are scheduled during an enforcement
conference on September 16, 1988.
From
the
information
provided
above
and
in
Inspection
Report
50-280;281/88-26,
it is apparent that foreign material exclusion/
cleanliness was not being implemented as described. by the topical report.
These problems were programmatic in nature with at least one specific
example (the two containment sump problems predominant).
The fact that
the containment sumps were not adequately maintained free of foreign
material has the potential to jeopardize the operation of safety related
systems which can mitigate the consequences of a major accident.
It is
noted that cleanliness problems associated with the safety related pumps have
been addressed by the licensee.
Both containment sumps were cleaned. The
results of the initial flow test of the Un1t 1 inside recirculation spray
pumps were marginal.
Both pumps were rebuilt, and retest results met
requirements before restart of the unit.
Failure to provide an adequate procedure, and/or to follow that procedure
for cleanliness/foreign material exclusion with regard to maintenance or
modifications
on
safety-related
systems
is
a
violation
(280;
281/88-28-01).
The above examples of the violation were discussed with station management
on several occasions during this inspection period.
The discussions with
quality assurance (QA) management provided information which indicated
that the licensee's QA performance evaluation program observations early
in the Unit 1 outa~e were identifying material control and system cleanli-
ness problems.
These QA observations were presented to station management
on May 10, 1988, well in advance of the identification of the containment
sump foreign material/cleanliness problems.
However, it should be noted
that the inspectors' findings were not as a result of the QA observations.
The inspector also was informed near the end of the inspection period that
corrective actions for the noted conditions were being implemented.
The
inspector reviewed Maintenance Department Standing Order No. 88-1 dated
July 29, 1988, and noted that the standing order provided specific
instructions to department personnel with regard to ensuring that foreign
6
material exclusion is practiced during maintenance activities. Also, the
inspector reviewed a memorandum from the site services superintendent to
station management dated July 29, 1988, that identified specific actions
relating to cleanliness inspection and protection for safety and
non-safety related systems that was in the process of being implemented by
site services.
However, the inspection period ended prior to being able
to observe any results of the above directives.
Within the areas inspected, one apparent violation was identified.
4.
Unresolved Items
Unresolved items are matters about which more information is required to
determine whether they are acceptable, or may involve violations or
deviations. * One new unresolved item (paragraph 5) was identified for
review of the licensee evaluation and corrective actions of the emergency
diesel generator r6om louvers. Also, one new unresolved item (paragraph 7)
was identified for additional review of the original modification package,
and subsequent safety reviews associated with the modification of the
reactor trip breakers which allows for remote connection of test
equipment.
5.
Plant Operations
Operational Safety Verification
(71707)
The inspectors conducted daily inspections in the following areas:
control room staffing, access, and operator behavior; operator adhererice
to approved procedures, technical specifications, and limiting conditions
for operations; 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, tagout logs, jumper logs, and tags on components
to verify compliance with approved procedures.
The inspectors conducted weekly inspections in the following areas:
verification of operability of selected ESF systems by valve alignment,
breaker positions, condition of equipment or component(s), and operability
of instrumentation and support items essential to .system actuation or
performance.
Plant tour.s included observation of general plant/equipment conditions,
fire protection and preventative measures, control of activities in
progress, radiation protection controls, physical security controls, plant
housekeeping conditions/cleanliness, and missile hazards.
The inspectors
routinely monitor the temperature of the auxiliary feedwater pump
discharge piping to ensure steam binding is prevented.
The inspectors conducted biweekly inspections in the following areas:
verification review and walkdown of safety-related tagout(s) in effect;
review of sampling program (e.g., primary and secondary coolant samples,
7
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 lineup(s); and verification that notices to workers are posted
as required by 10 CFR 19.
Certain tours were conducted on backshi fts or weekends.
Backs hi ft or
weekend tours* were conducted on July 4, 7, 9, 10, 11, 13, 14, 15, 16, 17,
18, and 29.
I_nspections included areas in the Units 1 and 2 cable vaults,
Unit 1 containment, vital battery rooms, steam safeguards areas, emergency
switchgear rooms,
diesel
generator rooms,
control
rooin,
auxiliary
building,
cable penetration areas,
independent spent fuel
storage
facility, low level intake structure, and the safeguards valve pit and
pump pit areas. Reactor coolant system 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 Independent Measurements Leak Rate Program (RCSLK9).
On a regular basis, radiation work permits (RWPs) were reviewed, and
specific work activities were monitored to assure they were being
conducted per the RWPs.
Selected radiation protection instruments- were
periodically checked, and equipment operability and calibration frequency
were verified.
In the course of monthly activities, the inspectors included a review of
the licensee 1 s physical 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.
On July 10, the inspector monitored Unit 1 heatup evolutions that were in
progress from the control room.
Earlier that morning, with heat up in
progress, and temperature greater than 400 degrees F, it was noted that
containment sump inleakage was greater than normal.
Station management
realized that a potential containment integrity issue could be developing,
and instructed operations to begin investigating. At 0900 hours0.0104 days <br />0.25 hours <br />0.00149 weeks <br />3.4245e-4 months <br />, a shift
supervisor log entry was made stating that it appears that one of the
discharge valves to a containment spray pump was
leaking through.
Operations personnel systematically investigated the_problem, and at 0930
hours it was
determined that containment
spray discharge
valve
l-CS-MOV-1018 (which indicated closed), was allowing water to leak from
the refueling water storage tank (RWST) into containment,
and was
collecting in the containment sump.
Control room operators subsequently tried to cycle and reseat the valve,
but sump inleakage remained at an elevated rate.
The inspector witnessed
the ensuing control room discussion between the shift supervisor, two
additional senior reactor operators (SRO),
and the Unit 1 reactor
operator.
The discussion concluded that the valve was in fact leaking an
8
unknown
amount,
and
as
such constituted a potential violation of
containment integrity.
At 1035 hours0.012 days <br />0.288 hours <br />0.00171 weeks <br />3.938175e-4 months <br />, the SRO responsible for Unit 1
ordered the plant heatup stopped at just below 500 degrees F, and started
a 30-hour clock (limiting condition for operation, LCD) to cold shutdown
in accordance with Technical Specification (TS) 3.0.1 due to a potential
violation of containment integrity.
Station management was informed of the shift supervisor's decision to
enter the LCD, a~d stop the heatup based on leakage past the containment
isolation valve.
The inspector monitored the station management briefing
of this situation and observed senior station management state that the
heatup should continue while at the same time remaining in the LCO to cold
shutdown.
A call was then made to the control room stating that the
Station Nuclear Safety and Operating Committee (SNSOC) had agreed that the
plant heatup should continue while a test was being developed to quantify
the leakage.
This decision was reversed, and the unit ultimately placed
in cold shutdown following further discussions between the resident
inspectors, station management, and the unit SRO.
It is important to note that the ultimate decision made by management was
not to resume heatup after entering the LCO, after the inspectors
discussed this sequence of events with station management, and expressed
concern about the message that may be conveyed to the licensed operators
when management directs them to continue with plant startup while in a
Technical Specification Action Statement that requires the unit to go to
cold shutdown.
Although station management was concerned about the
integrity of containment*, and felt that more time for evaluation was
needed to better understand if a true containment integrity problem did
exist, the order to continue heatup while in the LCO, although legally an
option, appeared to be a nonconservative approach.
On July 12, the inspector witnessed the Unit 1 heatup past 350 degrees F,
and independently verified that all engineered safety equipment required
to be operable to exceed 350 degrees F was in fact returned to service.
This review included both a procedural audit, and control board walkdown
of applicable switches and relays.
Procedure adherence was adequate with
no discrepancies noted.
The inspectors performed an operational assessment of the cooling air
supply to the emergency diesel generators (EOG) during this inspection
period.
The EOGs are completely enclosed in rooms, and depend on air
entering the room through the room's intake louvers for combustion and
cooling air. Heat is removed from the EOG cooling water by forcing air
over a radiator and exhausting out of the room.
The inspectors expressed
concern regarding the operation of the room louvers that must open to
allow air into the EOG rooms.
After identification of the issue by the
inspectors, the station secured the air supply to the louvers, causing
them to remain open, until an evaluation of the concern could be
performed .
9
The main air intake louvers are located at the top of each diesel room,
and consist of ten pane 1 s conected in pairs to five actuators.
Each
actuator requires station service air to compress a spring to keep the
louvers closed.
The station service air is supplied through two parallel
solenoid valves that reposition and vent the supply air to the actuators
on a start signal from the EOG.
The air system, valves and louvers were
not procured as safety related equipment and are not seismically
qualified.
Review of licensing documentation did not specifically
disclose safety-related considerations for this system.
Engineering Work Request (EWR)88-296 documented the station evaluation of
the concerns relating to this issue.
The inspector reviewed the EWR and
discussed the following items w1th station management and staff:
It takes a calculated differential pressure across the louvers equal
to one and one-half inches of water to force them open against the
normal pressure of service air.
Since the louvers open into the
room, the measured differential pressure of 2.6 inches across the EOG
fan should be adequate to open the louvers even if the service air
system failed to isolate and vent.
This fact was not included in the
original EWR but was stated by the licensee.
The diesel requires 35,500 CFM of air for starting and cooling.
Each
of the ten panels per diesel allows 13,500 CFM of air to enter the
rooms, thus requiring three of the ten panels to open.
A periodic verification that the louvers are functioning properly is
indirectly performed each time the EOG is started per operating
procedure 1-0P-6.1.1, No. 1 Emergency Diesel Generator, Exercise
Start From MCR.
The inspector commented that the step that checks
the louvers could easily be confused with a check of the engine
radiator louvers.
Station engineering had initiated an effort to replace the existing louver
system with an upgraded system prior to this inspection. This effort is
currently in the initial design and planning stage.
The inspectors noted
the importance of these louvers, and offered the following comments:
Field verification that the louvers will in fact open with a complete
failure of the service air system to isolate and vent off pressure
has not been performed.
Although calculations indicate that the_
differential pressure across the louvers with the EOG running should
must open for the EDGs to perform their safety function; thereby,
preventing this louver system from being an entirely passive system.
The fact that the louvers are not classified as safety related has
contributed to a lack of appropriate attention being placed on their
maintenance and upkeep.
This condition was demonstrated on July 6,
1988, when the air system was isolated from all the louvers and 11 of
the 30 panels failed to function properly.
10
The licensee agreed with the above comments and stated that the louver
system would remain in the present failed open condition until the system
is either removed, rep 1 aced, or restored to a fully operab 1 e status.
In
any case, an evaluation will be performed by the licensee to determine if
any portion of the louver system should be safety related. The licensee
stated that they will defer any decision on testing of the presently
in sta 11 ed system unt i 1 a permanent course of action is d_etermi ned.
The
inspectors will review the licensee cictions,
and final
resolution
regarding the adequacy of the louver system and its safety classification.
This item is identified as an unresolved item (URI 280; 281/88-28-02)
pending licensee actions, and the inspector's completion of these reviews.
On July 14, the inspector witnessed Unit 1 return to criticality after
completion of a three month refueling/maintenance outage.
The inspector
reviewed the procedures associated with the startup, and monitored pulling
of the control rods until the reactor was critical.
No discrepancies were
noted.
During last month
1 s exit interview with station management on July 5,
1988, the l1censee agreed to conduct a test of the component cooling water
heat exchanger (CCWHX) service water system in order to verify satisfac- *
tory operation through the CCWHX without the use of vacuum priming.
This
test will be conducted after the start of the Unit 2 refueling/maintenance
outage which is scheduled to commence in September 1988.
Prior to
testing, the licensee has agreed to maintain intake canal level at or
above 27 feet.
This test is identified as an inspector followup item (IFI
280; 281/88-28-03).
Engineered Safety Feature System Walkdown
(71710)
The inspector performed a walkdown of the containment isolation system for
Unit 1.
This verification also included the following: confirmation that
the licensee
1 s system lineup procedure matches plant drawings and actual
plant configuration; hangers and supports are operable; housekeeping is
adequate; valves and/or breakers in the system are installed correctly and
appear to be operable; fire protection/prevention is adequate; major
system components are properly labeled and appear to be operable;
instrumentation is properly installed, calibrated, and functioning; and
valves and/or breakers are in correct position as required by plant
procedure and unit status.
Within the areas inspected, no violations or deviations were identified.
6.
Maintenance Inspections (62703)
During the reporting period, the inspectors reviewed maintenance
activities to
assure
compliance with
the appropriate
procedures.
Inspection areas included the following:
OVERHAUL OF TURBINE DRIVEN AUXILIARY FEEDWATER PUMP (l-FW-P-2)
11
On July 15, the licensee attempted to run the Unit 1 turbine driven
auxiliary feedwater pump in order to verify operability as required by
technical specifications prior to the unit exceeding 10 percent power.
During the initial start attempt, the pump indicated initial flow, then
stopped running for some unknown reason.
A licensee evaluation concluded
that the pump was locked up by an internal obstruction.
The unit
operators logged this condition, and a 1 so, 1 ogged the technical specif i-
cat ion requirement that the pump must be proven operable within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />
after the unit was taken critical, or the unit must return to hot shutdown
within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
In the next 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, the licensee disassembled
the pump, inspected the pump internals and made repairs to the parts which*
caused the pump to lock up, reassembled the pump, and verified operability
in accordance with the 72-hour technical specification requirements.
The inspectors monitored the licensee actions during initial pump testing
which identified the problem, during pump repair evolutions, and during
final operability testing.
The repairs were.accomplished using mechanical
maintenance procedure MMP-C-FW-092 dated October 23, 1987.
The inspector
noted'that although the procedure did provide for a cleanliness inspection
of the lower casing prior to reassembly, it did not maintain foreign
material exclusion control through rotor installation and upper casing
placement.
The licensee also noticed this condition, and during pump
closeout, quality control inspectors were assigned to provide appropriate
coverage for foreign material exclusion during final assembly steps and to
document these cleanliness inspections.
No discrepancies were noted.
The inspectors conducted a comprehensive review of all safety related work
orders that remained outstanding on Unit 1 following the return to full
power operations.
This review also included witnessing select SNSOC
meetings that approved deferral, or recommended completion of work items
prior to leaving the refueling outage.
The inspectors found the overall
process to be adequate, but did note that 19 outstanding work orders
remained unworked which involved safety-related motor operated valves
drawing in excess of 25 percent of ful 1 1 oad amperage.
An Engineering
Work request (EWR 88-266) documented the evaluation, and conclusion that
the elevated supply voltage was the principal cause for the high current
reading on the Limitorque motor operator~.
The engineering report further
stated that although the high current readings could be a indicative of a
problem with the motor operator, a determination should be made on a case
by case basis.
The inspectors discussed the EWR with engineering and.
electricians, and reviewed supporting field data and test results.
In
addition, the EWR recommended a program be established to obtain motor
performance curves, and deve 1 op app 1 i cab 1 e acceptance criteria. * The
licensee incorporated. these recommendations into their committment
tracking system for action; therefore, the inspectors will continue to
monitor progress in this area as a part of their routine inspection
effort.
No discrepancies were noted.
Within the areas inspected, no violations or deviations were identified.
' .
12
7 .. Surveillance Inspections (61726)
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 procedures appeared to perform their intended function.
Adequate coordination existed among personnel involved in the test.
Test data were properly collected and recorded.
Inspection areas included the following:
TESTING OF THE UNIT 1 INSIDE RECIRCULATION PUMP (1-RS-P-lA)
On July 5, the inspector witnessed testing of 1-RS-P-lA in accordance with
special test 1-ST-214, Operability of IRS Pumps.
The stated purpose of
this test was to prove operability of the inside recirculation spray
pumps, and to establish reference values for inside recirculation spray
pump testing in accordance with ASME Section XI, Subsection IWP.
This
test was being accomp 1 i shed after overhaul of the pump; when, during an
earlier run the test data could not confirm that the pump met a 11
operational requirements.
The inspector reviewed the test procedure prior
to test performance, and observed the testing of 1-RS-P-lA from inside
containment.
The following items were noted by the inspector.
The test procedure was used by the craft as the working procedure to
install and remove system/test spoolpieces.
The inspector observed
the system spoolpiece on the discharge side for 1-RS-P-lA laying on
t_he deck during testing.
The flange ends were not blanked as
required by the procedure to maintain cleanliness and no steps in the
procedure-verified that cleanliness or foreign material exclusion was
maintained during the reassembly of the system to its norma 1
configuration. This is an additional example of appare_nt violation
280; 281/88-28-01.
between
room was poor:in that
time
during
testing.
containment
environment
inspectors.
the operator in containment and the control
communication was lost for short periods of
Communications
problems
in
the
noisy
Communication
has
been
frequently
noticed
by
the
Based on his observations, the inspector concluded that the testing was
accomp 1 i shed in accordance with procedure ( except as noted above), and
that results were adequate to evaluate pump operability.
i3
REACTOR PROTECTION LOGIC TESTING
On July 13, the inspector witnessed testing of the rector protection logic
system for Unit 1 in accordance with 1-PT-8.2, dated July 5, 1988, Reactor
Protection Logic.
This test is to ensure the operability of the rector
trip portion of the reactor protection system, * and is required to be
performed at the conclusion of each refueling outage.
Included in this
test are individual tests of train
11A
11 and train
11 B
11 logic channels with
their associated alarms and interlocks that are required to function
during restart and normal operations.
The inspector 'Jbserved a problem with step 5.17 of the above test
procedure that times the reactor trip relays from initiation of a trip
signal in the protection cabinets until the trip breaker ope~s.
The trip
breaker appeared to be opening correctly, but the timer used for this test
was not stopping when the breaker tripped.
The instrument technicians
performing the test repeated the step several times, and concluded that
the wiring in the breaker cubicle must be incorrect.
The problem was then
turned over to the electricians for resolution.
The electricians corrected the wiring discrepancy in the reactor trip
breaker cubicles, and the breakers were subsequently tested satifactorily.
However, the determination and retermination of the two wires inside the
breaker cubicl~ was not specified on either a work order or detailed in
any way in a procedure.
An incorrect assumption was made that the
outstanding work order that installed the breakers (WO# 68076), and the
maintenance procedure invoked by that work order (PC-DB-E/Rl, Reactor Trip
And Bypass Breaker Maintenance) contained the necessary steps to perform
the desired work.
The subject w1r1ng is connected to one of three identical relay terminals
mounted on the breaker that provides breaker status to the various logic
and interlock circuits.
Each relay has ten terminals that are wired to
the various circuits. The wiring that was incorrectly landed connects to
terminals 5 & 6 on the upper relay and runs to a test jack mounted on the
side of the breaker cubicle, thus requiring disconnecting and reconnecting
each time the breaker is removed.
The breakers were removed from their
cubicles and refurbished during the refueling outage.
The inspector
expressed concern that the wiring had previously been connected and
reconnected without
a. written procedure each ti me the breakers were
removed.
The significance of this item was amplified when the inspector obs~rved
the numerous wires connected to the terminals, and the functions the
terminals perform.
Although it is important to recognize the extensive
1 ong-range project to imp rove the procedures currently underway, the
failure to identify a procedure inadequacy and correct the situation on a
component such as the reactor trip breakers is a concern, as wel 1 as the
failure to properly recognize and change the necessary procedure when. the
wiring modification was originally installed.
The inspection period ended
14
prior to the inspector completing his review of these concerns.
This item
is identified as an unresolved item (280/88-28-04) pending completion of
additional reviews of the original modification package, and subsequent
safety reviews associated with this modification.
On July 14, the inspector witnessed testing of the main steam isolation
valves in accordance with test procedure 1-PT-14.2, Main Steam Trip Valves
and Main Steam Non-Return Valves.
This test is required by technical
specifications to ensure that the steam isolation valves will close in a
specified period of time.
The valves functioned as required with no
discrepancies noted in either the test results or the manner in which the
test was conducted.
Within the areas inspected, no violations or deviations were identified.
8.
Plant Startup from Refueling
(71711)
During this inspection period, the inspectors conducted a walkdown of the
Unit 2 containment prior to restart to independently ascertain that
a pp r o p r i a t e p o rt i o n s o f the react o r coo l a n t , rec i r c u l at i o n s p ray , a n d
auxiliary feedwater systems had been properly returned to service and that*
general
containment cleanliness was
adequate.
The
inspect~rs also
witnessed selected portions of the Unit 1 restart including the monitoring
of the following tests:
On July 13, the inspectors witnessed initiation and testing of the
Shutdown Bank A control rods in accordance with 1-PT-7.2, HOT ROD
DROPS.
The inspector noted that the test was
being properly
contra 11 ed by the senior reactor operators in compliance with the
Technical Specification.
No discrepancies were noted.
The inspectors witnessed testing and monitored activities associated
with periodic test 1-PT-28.11, Start-Up Physics Testing.
This
procedure is the contra 11 i ng procedure for several start-up tests
required to be performed at low power levels following refueling.
The inspectors witnessed pretest briefings, verified that specified
conditions were met, and witnessed portions of the following tests:
Reactivity Computer Accuracy Determination
This test determines the reliability range* of the reactivity computer
that is used in subsequent testing by inserting and withdrawing rods
to add or subtract reactivity, and measuring the resulting flux
halving or doubling.
The computer was determined to be accurate
within plus or minus 40 pcm.
No discrepancies were noted.
Isothermal Temperature Coefficient
This test involves measuring the moderator temperature coefficient by
determining the effects of plant temperature changes on reactivity
while maintaining constant rod position and boron concentration.
15
During the initial temperature swing from 546 degrees to 543 degrees,
the reactor went subcritical when
an inadvertant boration of
approximately 30 ppm boron occurred.
The boration was determined to
be from an apparent combination of operator error and leakage past a
boric acid isolation valve.
The SNSOC was convened, and the decision
was made to manualiy trip the control rods and restart the reactor.
A second reactor startup was commenced at 0109 hours0.00126 days <br />0.0303 hours <br />1.802249e-4 weeks <br />4.14745e-5 months <br /> on July 15, but
had to be stopped when an urgent rod failure occurred at 0111 hours0.00128 days <br />0.0308 hours <br />1.835317e-4 weeks <br />4.22355e-5 months <br />.
Two circuit cards were replaced in the power cabinets, and the urgent
failure alarm was cleared at 0235 hours0.00272 days <br />0.0653 hours <br />3.885582e-4 weeks <br />8.94175e-5 months <br />.
A third reactor startup was
comme~ced at 0257 hours0.00297 days <br />0.0714 hours <br />4.249339e-4 weeks <br />9.77885e-5 months <br /> with a return to criticality at 0329 hour5.
The * boron endpoint was redetermined and an average temperature
coefficient of -3.22 pcm/degree F was .measured.
The inspector witnessed the inadvertant boraticn and preperations for
return to power, and commented that communications between the test
group and the reactor operator could be improved.
The licensee
agreed with this comment and stated that the outage coordinator had
submitted a similar comment.
No
discrepancies in the actual
performance of this test were noted.
Rod Swap Reference Bank Measurement*
This test a 11 ows for measurement of the rod worth ( pcm) of the
reference bank (Control Bank B) when fully inserted from 225 steps to
0 steps.
The inspector witnessed selected portions of this test.
No
discrepancies were noted.
Integral Rod Worth Measurements Using the Rod Swap Technique
This test allows for determination of the differential rod worth of
the reference bank (Control Bank B) when one of the remaining control
rod banks is fully inserted into the core.
The inspe~tor witnessed
this portion of testing when the test bank used was Control Bank C.
No discrepancies were noted.
Additional inspection of startup testing was accomplished by a regional
based inspector during the week of July 18, 1988.
This inspection is
discussed in inspection report 280; 281/88-29.
In the areas inspected, no violations or deviations were identified.
9.
Followup on IE Bulletins (92703)
(Open) IE Bulletin 85-03. As requested by action item e. of Bulletin
85-03, Motor-Operated Valve Common Mode Failures During Plant Transients
Due to Improper Switch Settings, the licensee identified the selected
safety-related valves, the valves' maximum differential pressures, and the
licensee's program to assure valve operability in their letters dated
May 13 and October 17, 1986, and February 24, 1987.
16
Review of these responses indicated the need for addition information
which was contained in Region II letter dated August 18, 1987.
Review of the licensee's September 18,
1987, and January 5, 1988,
responses to this request for additional information indicates that the
licensee's selection of the applicable safety-related valves to be
addressed and the valves'
maximum differential pressures meet the
reqtii rements of the bul 1 et in, and that the program to assure valve
operability requested by action e. of the bulletin is now acceptable.
The results of the inspections to verify proper implementation of this
program, and the review of the final response by action f. of the bulletin
will be addressed in subsequent inspection reports.
This item remains
op~n.
10.
Exit Interview
The inspection scope and findings were summarized on August 3, 1988, with
those individuals identified by an asterisk in paragraph 1. The following
new items were identified by the inspectors duriTig this exit.
One apparent violation (paragraph 3) was identified for failure to provide
adequate procedures and/or to follow procedure for cleanliness and foreign
material exclusion with regard to maintenance/modifications on safety-
related systems (280; 281/88-28-01).
One unresolved item (paragraph 5) was identified for review of the
license~ evaluation and actions regarding the emergency diesel generator
room louvers (280; 281/88-28-02).
One inspector followup item (paragraph 5) was identified involving a test
to demonstrite adequate service water flow to the component cooling water
heat exchanger (CCWHX) without the vacuum priming system in service (280;
281/88-28-03).
One unresolved ftem (paragraph 7) is identified for additional review of
the original modification package, and the subsequent safety reviews
associated with the modification of the reactor trip breakers which allow
for remote connection of test equipment (280/88-28-04).
The licensee acknowledged the inspection findings 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.