ML18152A246
| ML18152A246 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 06/25/1993 |
| From: | Belisle G, Branch M, Tingen S, York J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18152A247 | List: |
| References | |
| 50-280-93-13, 50-281-93-13, NUDOCS 9307220061 | |
| Download: ML18152A246 (18) | |
See also: IR 05000280/1993013
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, N.W .
. ATLANTA, GEORGIA 30323.
Report Nos.:
50-280/93-13 and 50-281/93-13
Licensee: Virginia Electric and Power Company
5000 Dominion Boulevard
Glen Allen, VA
23060
Docket Nos.:
50-i8o and 50-281
License Nos.:
Faci 1 i ty Name:
Surry 1 and 2.
Inspection Conducted:
May 2 through June 5, 1993.
Inspectors:
Approved by:
Scope:
//_ ~
- z%:-::
~ork~~Inspector
S. G. Tinge~ Inspecto
. . 71;{ [I ~lV(~ .
G. A. Belisle, Section Chief
Division of Reactor Projects
SUMMARY
- 0¢--'
Da
Si ed
_
o~/iiJ
- ~~3
D e Si ned
._
t/15/13
Date Signed
This routine resident inspection was conducted on- site in the *areas of plant
status, operational safety verification, maintenance, surveillance, safety
assessment and quality verification, licensee event review, and action on
previous inspection items. During the performance of this inspection, the
resident inspectors conducted reviews of the licensee's backshifts, holiday or
weekend operations on May.2, -16, -23, 27-, and--29.
Results:
In the operations area, the following item was noted:
The use of an operations review board to review, answer, and maintain
status of open deviations report action items,-commitment tracking
9307220061 * 930625 -~
PDR -ADOCK 05000280
G
PDR:;:*.
t~
2
system items, and quality assurance findings assigned to oper~tions was
identified as a strength (paragraph 3.b).
In the maintenance/surveillance area, the.following items were noted~
The maintenance associated with the replacement of 1-VS-S-IA was well
planned and conducted.
The installation of this new strainer improved
the material condition of the plant (paragraph 4.a).
From April 1992 through the present inspection period, the number of
non-outage corrective maintenance work orders decreased by approximate.ly
one-half and the average age of these work orders also decreased by
approximately one-half (paragraph 4.b).
From January.1992 through the present inspection period, the Cause
Determination Evaluation (CDE) backlog has been reduced to 21 CDEs which
is a reduction of approximately 95%.
The licensee's action of assigning
additional engineers to the maintenance engineering department and
establishing CDE backlog goals has*been effective in.reducing the CDE
. backlog (paragraph 4.c).
The present Technical Procedure Upgrade Program schedule calls for
approximately 39QO*upgraded*procedures to be issued and-only 2888 have
been issued. At the present upgraded procedure issuance *rate, the. 1996
target date for program completion will not be met.
The Licensee has *
added additional staff to support this procedure upgrade effort
(paragraph 4.d).
The PASSPORT Maintenance Management System is in the process of being
implemented.
The main purpose of this* new program is to improve *
accessibility to the engineering data base required to plan work orders
(paragraph 4.f).
In the engineering/technical support area, the following item was noted:
Non-cited violation 50-280,281/93-13-0l was identified for failure to
adequately control revised motor operated valve setpoints (paragraph
6.a).
-
REPORT DETAILS
1.
Persons Contacted
Licensee Employees
R. Allen, Supervisor, Operations
W. Benthall, Supervisor, Licensing
- R. Bilyeu, Licensing
H. Blake, Superintendent of Site Services
- R. Blount, Superintendent of Engineering:
- D. Christian, Assistant Station Manager
- J. Downs, Superintendent of Outage and Planning
- D. Eritkson, Superintendent of Radiation Protection
A. Friedman, Supervisor, Nuclear Training
- R. Gwaltney, Superintendent of Maintenance
- R. Hayes, Quality Assurance
M. Kansler, Station Manager
A. Meekins, Supervisor, Administrative Services
- J. McCarthy, Superintendent of Operations
J. O'Hanlon, Vice President, Nuclear Operations
- A. Price, Assistant Station Manager
E. Smith, Site Quality Assurance Manager
- J. Swientoniewski, Supervisor, Station Nuclear Safety
- W. Woodzell, Senior Instructor
NRC Personnel
M. Branch, Senior Resident Inspector
j_ York, Resident Inspector
- S. Tingen, Resident Inspector
- Attended Exit Interview
Other licensee emplojees contacted included control room operators,
shift technica.l advisors, shift supervisors *and other plant personnel.
Acronyms and initialisms used throughout this report are listed in the
last paragraph:
2.
Plant Status
Unit 1 began the reporting period in power operation. The Unit was at
power at the end of the inspection period, day 115 of continuous
operations.
Unit 2 began the reporting period in hot shutdown, day 58 of a RFO.
The
unit was returned to power on May 6 and operated at power until May 31.
On May 31, the unit was taken off-line but remained critical in order to
balance the turbine generator.
On June 1, the unit was returned to
power and operated at power for the remainder of the period.
.
3.
2
Operational Safety Verification (71707, 42700)
The inspectors conducted frequent tours of the-control room to verify
proper staffing, operator attentiveness and adherence to approved
procedures.
The inspectors attended plant status meetings and reviewed
operator logs on a daily basis to verify operations safety and
compliance with TSs and to maintain awareness of the overall operation
of the facility.
Instrumentation and ECCS lineups were periodically
reviewed from control room indication to assess operability. Frequent
plant tours were conducted to observe equipment status, fire protection
programs, radiological work practices, plant security programs and
housekeeping.
Deviation reports were reviewed to assure that potential
safety concerns were properly addressed and reported.
a.
Design Basis Documentation Project Update
A meeting was held in Region II on May 3, 1993, to review the
status of the DBD Program and to address concerns expressed in
North Anna NRC IR 50-338, 339/92-32, and Surry NRC IR
50-280, 281/93-07, regarding the review of open items identified
by this program.
The licensee discussed their evaluation of
design basis documents, the 1dentification and resolution of
engineering issues, and the review and classification of items
opened as a result of the DBD Program.
Further NRC review of the
disposition of open items will be conducted in a future
inspection.
b.
Activities of the Operations Review Board
The inspectors attended a meeting of the ORB on May 28.
This
board consists of two to three operators that are usually
nonlicensed (currently has one licensed RO), the Superintendent of
Operations, one or more shift representatives, and a special
projects representative.
The ORB was formed by the Superintendent
of Operations in September 1992 and is responsible for reviewing,
answering, and tracking all deviations, conunitment tracking system
items, and QA items that are assigned to operations. Requests for
engineering assistance from the operations group and assisting in
resolving items of inunediate concern are handled by this group.
This board has removed some of the administrative burden from
operations management and decreased the backlog of QA items,
deviations, and CTS items assigned to the operations department.
Besides the previous accomplishments-of the ORB, the experience
gained in working on problems and interacting with other
departments is very valuable in training the current and future
Since each of the permanent members are rotated,
this experience will be distributed throughout the operations
department in the future.
The formation and functioning of the
ORB is identified as a strength.
c.
--~-----
3
Emergency TS Change to Operate Unit 2 at Reduced Power
- On April 29, 1993, during the hydroslati.c test of Unit 2 following
the RFO, RCS leakage past the pressurizer A and/or~ s~fety valves
was observed. The leakage was attributed to loss of the water in
the loop seal upstream of the safety valves which affected the
valve seat leakage.
The hydrostatic test was terminated and the
RCS,pressure reduced to prevent further leakage through the safety
valves.
To complete the ASME required hydrostatic test and to
prevent further leakage past the safety valves, _the valves were
gagged which was discussed in NRC IR 50-280, 281/93711.
After the gagging devices were removed, the A pressurizer safety-
valve continued to leak by the seat. _ The RCS pressure was reduced
to.1800 psig and slowly repressurized to 2135 psig. The safety
valve did not leak at 2135 psig.
By letter dated May 4, 1993, the
licensee requested and was granted enforcement discretion to _
operate Surry, Unit 2 at reduced nominal operating pressure, 2135.
psi g, until an emergency TS change could be submitted.
By letter
dated May 6, 1993, the licensee requested an emergency-TS
amendment to allow operation at a reduced pressure of 2135 psig in
lieu of 2235 psig un~il the next scheduled RFO.
In a letter dated
May 14, 1993, the NRC approved the emergency TS amendment to al)ow
operation at reduced pressure.
4.
Maintenance Inspections (62703) (42700)
During the reporting period, t~e inspectors reviewed the following
maintenance activities to assure compliance with the appropriate
procedures.
a.
Replacement of Strainer 1-VS-S-lA
On May 13, mi nor flooding was reported in MER 4 due to a hole in* a
carbon steel flush line (SW system) for strainer l~VS-S-lA.
The
SW system was realigned and the leak was isolated. The inspectors
observed the replacement of the leaking pipe and the upgrade of
the material condition of the system at the same time.
The
upgrade consisted of replacing the motorized strainer, two valves,
and piping.
The inspectors observed the pre-job briefing and prestaging of the
strainer, valves, gaskets; bolts, etc. Several procedures were
used to rep 1 ace the* components: *procedure O-MCM-1801-01,
Piping/Components Repair/Replacement, dated May 6, 1993; procedure
0-MCM-1001-01, Stud Replacement, dated October 5, 1990; procedure
O-MCM-1401-01, Flange Gasket Replacement, dated June 14, 1991.
Work orders 3800131336 and 3800135428 were used to perform_the
maintenance.
Some of the removal and replacement activities were observed
including torquing, grouting of new studs, and post maintenance
. *~ ....
4
testing (uncoupled run of the strainer motor).
The use of
procedures and sign offs was observed during the operation~
The
maintenance activity was* well planned and conducted and no
discrepancies were noted.
b.
Corrective Maintenance WO Backlog
The inspectors reviewed the distribution of open WOs for the
period ending May 23.
There were a total of 3507 open SR and NSR
WOs for both units. Of these WOs, 1012 were classified as outage
WOs, and 2495 were classified by the licensee as non-outage WOs.
Of the 2495 non-outage WOs, 166 were classified as CM work orders
with an average age of 46 days.
The licensee's goal for 1993 is
to maintain less than 250 non-outage CM WOs with an average age of
45 days or less.
-
The inspectors also reviewed the distribution of open WOs for the
period ending April 5, 1992. There were a total of 5947 open SR
Of these WOs, 3063 were classified by the licensee
as outage WOs, and 2884 were classified as non-outage WOs.
Of the
2884 non-outage WOs, 406 were classified as CM work orders with an
average age of 90 days.
The licensee's goal for 1992 was to
maintain less than 350 non-outage CM WOs with an average age of 45
days or less.*
The inspectors contluded that from April 5, 1992, through the
present inspection period the number of non-outage CM WOs
decreased by approximately one-half and the average age of these
WOs also decreased by approximately one-half.
- -
c.
CDE Backlog
d.
The inspectors reviewed the status of the CDE backlog. During the
previous SALP assessment periods, the backlog of CDEs increased.
At the beginning of the present SALP assessment period there was a
backlog ~f over 400 CDEs.
Throughout the present SALP assessment
period, the CDE backlog has been reduced to 21 CDEs which is a
reduction of approximately 95%.
The inspectors concluded that the
licensee's actions of assigning additional engineers to th~
maintenance engineering department and establishing CDE backlog
goals have been effective in reducing the CDE backlog.
Station Technical Procedure Upgrade Program
The inspector reviewed the station Procedure Groups 1992 and 1993
status reports. These reports indicated that the licensee had
exceeded their yearly goals for issuing upgraded procedures.
The
goal for 1992 was to issue 600 upgraded procedures and
approximately 625 procedtires were issued.
The goal for 1993 is to
issue 800 upgraded procedures and approximately 400 procedures
have been issued.
5
The present target end date for the TPUP is scheduled for December
1996 and 6639 procedures have been identified for upgrading.
In
order to meet the target date of December, 1996, the TPUP plan
calls for 150 upgraded procedures to be issued every month.
The
inspectors noted that the 1992 and 1993 goals of 600 and 800
issued upgraded procedures do not meet the TPUP plan of 150
procedures per month.
The present TPUP plan calls for
approximately 3900 upgraded procedures issued and only 2888 have
been upgraded. *The inspectors concluded that at the present
upgraded procedure issuance rate the 1996 target date wil 1 not be
met.
The TPUP is divided into electrical, mechanical, I&C, operations,
and other areas.
Each area- is assigned a goal for the number of*.
upgraded procedures to be issued * .In 1992 all departments met or
came very close in meeting their goals. It appears that all
departments with the exception of I&C will meet or exceed their
1993 goals for number of upgraded procedures issued. A goal of
174 I&C upgraded procedures has been established for 1993 and 23
were issued in the first four months.
The delay is due primarily
for critical process loop data and scaling factors.
The licensee
has recognized that I&C upgraded procedures are behind ~chedule
and have implemented corrective actions. A person has been added
to the procedure writers group to determine scaling factors and
additional procedure writers have been assigned to the I&C area~
In addition, engineering has been assigned the responsibility to
- provide critical p~ocess loop data in a manner to support the
procedure upgrade efforts.
The licensee monitors the number of pro~edural changes made to
upgraded and non-upgraded procedures.
Upgraded procedures
required approximately one third fewer changes than non-upgraded
procedures ..
During the previous SALP assessment period problems were
i dent if fed with procedures for repair of AOVs.
During this SALP *
assessment period, sixteens AOV upgraded procedures have been
issued.
NRC IR 50-280, 281/93-05 identified problems with MS PORV
repair procedures and these procedures are presently being
upgraded.
e.
Troubleshootin~ of the Unit 1 Rod Control System
On June 3*Unit !*experienced problems with the Rod Control system_
while performing the bi-weekly rod exercise test as required by
TS.
When the operator was inserting the* A shutdown bank of rods, *
the group 1 rods inserted ten steps and the group 2 rods did not
move as indicated by IRPI.
The operator also noted that rods in
the A control bank had moved in approximately ten steps even
though that bank of rods was not selected~
By design this
condition did not cause a rod drive urgent failure alarm even
though the failure caused non-selected rods to move.
6
The inspectors monitored the licensee's troubleshooting activities
associated with the rod control failure. The troubleshooting was
controlled by an emergency WO which included i~~tructicins for
u~ing the vendor manuil. The technicians replaced several power
supply cards which were suspected of being defected but the
problem was not resolved.
The old cards were reinstalled and
after the cards were wiggled the problem was resolved. This
indicated to the licensee that either a loose card or dirty
contacts was the problem.
The licensee repeated the rod exerci~e
test as discuss~d in section 5.c of this report and after
satisfactory results were aihieved, declared the system fully
operable. However, several days later the problem reappeared and
after additi-0nal troubleshooting, the licensee replaced a
stationary firing card, performed the rod exercise test and
verified that proper rod motion was achieved.
During the troubleshooting on Ju~e 3, the inspectors noted that
-the vendor manual being used was -in complete disarray with pages
torn out of the book .. In addition, the drawings were also removed
from the book.
The inspectors also noted that the craft personnel
were using uncontrolled drawings and training material in
conjunction with the vendor manual.
The inspectors questioned the
use of the uncontrolled material and held discussions with
maintenance management personnel. The-licensee pointed out that
in the area of troubleshooting, administrative procedure
VPAP-0601, Document Distribution and Control, had been recently
modified through the issuance of PAR PS-01 dated April 29, 1993,
to allow the use of information copies of drawings and training
material to supplement the working copy.
The inspectors noted
that other administrative procedures VPAP-0801, Maintenance*
Program, Revision 2, and MDAP-0002, Conduct of Maintenance,
Revision 0, indicate that only controlled information be used for
the conduct of safety related maintenance. A review of the PAR to
VPAP-0601 indicated that the use of supplemental information in
.conjunction with controlled information for troubleshooting
activiti~s did not violate the other procedures.
However, in the
case of emergency work being performed under a short TS outage
time window it was not clear to the inspectors that only
controlled information would be used.
The inspectors will monitor
additional troubleshooting activities in the future to ensure that
the work is properly controlled.
The inspectors noted that a recent rod control event occurred at
/ '-~nether station as indicated in IN 93-46, Potential Problems With
,.,-
Westinghouse Rod Control System And Inadvertent Withdrawal Of A
Single Rod Control Cluster Assembly.
Surry personnel were aware
of and are following the event that is described in the IN.
They
have been in contact with Westinghouse and are evaluating the rod
system failure described above as to similarity and significance *
The failure of the control rod system is described in Chapter
14.2.4 of the UFSAR which indicates that misalignment of rods are
indicated by asymmetric power distribution as seen on the ex-core
-- 'I
7
Nis or a rod deviation alarm. The UFSAR further indicates that
protection.is afforded by the.reactor protection system in the
form of low or high power reactor trips .. Additional followup of
- rod control problems by the licensee will be monitored by the.
inspectors.
f.
PASSPORT/Maintenance Management System
In January 1993 the licensee initiated a pilot program, PASSPORT,
for processing WOs whi_ch is scheduled to fully_ implemented by
July 31, 1993. * The main purpose of the new program is to improve
accessibility to the engineering data base required to plan WOs.
Information required for planning a mainten_ance item such as,
safety category, prints, pro.cedures, EQ classification, drawings,
technical m~nuals, and parts will be specified in bne area iri lieu
of ciifferent areas*. This new program will also simplify the WO_
planning process and improve WO history traceability.
Within the areas inspected, no violati6ns were identified.
5.
Surveillance Inspections (61726,-42700)
During the r~porttng period, the inspectors reviewed surveillance
activities to assure tompliance with the appropriate procedure and TS
requirements.
a.
Unit 2 Containment Sump Inspection
TS 4.5.D requires a visual inspection of the containment sump, IRS
pump wells and the engineered safeguards suction inlets be *
performed at least once each refueling period and/or after major
maintenance activities in the containment.
The inspection should
verify that the containment sump and *pump wells are free of debris
that*could degrade system operation and that the sump components
are properly installed and show no sign of .structural distress or
excessiv~ corrosion.
The inspectors reviewed the results of 2-MPT-1205-01, Unit 2
Containment Sump Inspection and Test Setup, dated January 21,
1993*. This procedure was accomplished during the Unit 2 RFO and
one of the purposes of this procedure is to perform the visual
inspections required by TS 4.5.D. During these inspections,
- foreign material was found inside the ORS and LHSI p*umps
.
containment sump cross connect suction piping.
The following was
found in the ORS pumps sump cross connect suction piping which is
12 inches in diameter and approximately 25 feet long:
2-5/8 inch SS nuts
1-5/8 inch ss steel washer
1-3/8 inch SS washer
I-1/4 inch SS tubing, 1/4 inch long
1-allen wrench, #6
8
1-3/16 inch drift punch, 8 inches long, 1/2 inch diameter *
body
3-3/32 inch diameter tig wires, two were 18 inches and the
third one was 3 inches long.
2-1/8 inch diameter tig wires, 9 and 14 inches long
1..:s/8 inch diameter SS stud, 2 inches long
I-bracket, 2 inches by I inch with a key hole
I-welding rod, 1/16 inch diameter and 2 inches long
8-pieces of SS wire, 1/16 inch diameter and 1/2 inch long
IS-carbon steel sections 1/2 inch by 1/8 inch by I inch
The following foreign material was found in the LHSI pump sump
cross connect piping which is 12 inches in diameter and
approximately 11 feet long:
1-3/16 inch diameter wire, six inches long
1-3/8 inch SS nut
2-welding rod stubs
The licensee concluded that the foreign material was introduced
prior to 1988.
Engineering concluded that the size of some of the
debris could have potentially caused degradation of an ORS pump
but neither of the pumps were considered to be inoperable.
Both
LHSI pumps were also.considered operable with the foreign material
in the system.
In 1988, foreign material was identified in the IRS an LHSI pump
suction piping at. the Units I and 2 containment sump.
The cause
of the foreign material in containment sump piping was identified
as inadequate contra l of foreign material during the perform*ance
of maintenance or introduced during initial construction.
As a
result of inadequate control of foreign material, a civil penalty
w_as issued.
As corrective action, the licensee inspected the
containment sumps piping. Also the licensee implemented a program
to inspect the containment sumps and piping every RFO.
TSs were
changed to require this inspection.
The inspectors reviewed the procedures that were used to inspect
the containment sump ORS and LHSI pump suction piping in 1988 and
during the subsequent RFOs for both units and concluded that the
piping was inspected with remote optical inspection equipment.
In
1993, the licensee utilized more sophisticated remote optical
inspection equipment to inspect Unit 2 ORS and LHSI containment
sump cross connect suction piping and identified the presence of
some foreign material.
In order to retrieve the foreign material
mop heads were tied together and pulled through the piping.
During this process, more foreign material was identified in the
piping and maintenance personnel continued to pull mop heads
through the piping until no foreign material was present.
Afterwards the piping was reinspected with remote optical
inspection equipment and no foreign material was identified.
9
The -inspectors questioned why the optical equipment utilized to
accomplish the visual inspections did not identify all the foreign
material in the piping.
The inspectors .were informed that at the
bottom of the piping there was a layer of black soft silt. The
foreign material noted above*was contained in the silt at the
bottom of the piping and, therefore, not identified by the remote
optical inspection equipment.
The inspectors concluded that the requirements of TS 4.5.D were
adhered to.
b.
. Unit 2 CROM Coil and Insulation Checks
The inspectors reiiewed the results of EMP-C-EPCR-16, Connecting
Reactor Head Control Rod Drive and Positions Indication, dated
August 6, 1992. This procedure was performed during the Unit 2
1993 RFO.
One of the purposes of this procedure was to obtain
bridge and meggar readings on the CROM stationary, lift, and
movable coils. All measured readings were within the procedure's
acceptance criteria.
On three separate occasions in 1991 and 1992, individual rods
dropped into the core in Units 1 and 2.
The cause of the dropped
rods was attributed to degraded control rod drive coil stacks.
The licensees routinely performs EMP-C-EPCR-16 each RFO in order
to identify degraded coil stacks. Also the licensee has improved
the material condition of the containment ventilation system that
provides cooling for the CRDMs.
Individual Rods have not dropped
in either unit since January 1992.
c.
Unit 1 Control Rod Assembly Testing
On June 3, 1993, Unit 1 experienced problems with the Rod Control
system while performing the bi-weekly rod exercise test l-PT-6.0,
Control Rod Assembly Partial Movement, dated February 23, 1993.
This event was previously discussed in paragraph 4.e. After
indication that the rod control system problem had cleared, l-PT-
6.0 was performed to verify operability of the rod control system.
The inspectors witnessed the performance of this test and reviewed
the test data.
No discrepancies were identified.
Within the areas inspected, no violations were identified.
6.
Safety Assessment and Quality Verificati~n (40500)
a.
Review of Deviation Report S-93-0741
- On June 2 the licensee identified via DR S-93-0741 that during the*
Unit 2 RFO, 17 MOVs were tested and left with thrust values
outside of values specified in Design Reference Procedure 2-DRP-
007, MOV Setpoints, dated August 20, 1991.
The DR stated that the
MOVs were returned to service without properly documenting that
10
the as-left thrust values were not in accordance with 2-DRP-007.
The DR stated that although the MOVs were not set in accordance
with 2-DRP-007, they were evaluated as operable with the as-left
settings.
The iispectors discussed this DR with the MOV coordinator and
reviewed 2-DRP-007; SSES 3~03, Controlling Procedure for Providing
Guidelines for the Responsibilities of MOV Engineer, dated January
16, 1992; O-ECM-15090-1, VOTES MOV Testing, dated April 9, 1993;
EWR 93-004, Evaluation of MOV Setpoints, dated April 20, 1993; EWR 93-011, MI Valves Thrust Bands/Surry/1&2, dated March 22, 1993;
and Engineering Transmittal Records dated March 25 and April 19,
1993.
The revised MOV setpoints were not being adequately
controlled in that:
1.
Station personnel did not submit DRs when allowable thrust
limits were exceeded. Step 6.4 of SSES 3.03 states that
when a MOV allowable thrust limit is exceeded, the MOV
cannot be returned to service unless a DR is submitted and
.evaluated. Maintenance personnel verbally notified
engineering or recorded the condition on the WO, notified
operations that the VOTES testing was satisfactorily
completed and the MOV would be returned to service.
2.
Different documents specified different MOV settings for the
same MOV.
The*purpose of 2-DRP-007 is to specify MOV
setpoints. These setpoints are consistently under revision
due to extensi.ve MOV research and testing that is presently
underway.
EWRs and maintenance transmittals were used to
revise setpoints in lieu of revising 2-DRP-007.
The *
inspectors reviewed the required setpoints for specific MOVs
and noted that 2-DRP-007, EWRs, and maintenance transmittals
would specify different setpoints for the same MOV.
The licensee is in the process of correcting these discrepancies
in accofdance with their corrective actions program.
10 CFR 50, Appendix B, Criterion III, Design Control, requires
that measures be established to assure design basis for components
are correctly translated into procedures and instructions. These
measures shall include provisions to assure that appropriate
quality standards are specified and included in design documents
and that deviations from such standards are controlled. Failure
to adequately control MOY setpoints was identified as a violation,
NCV 50-280, 281/93-13-01. This violation will not be subject to
enforcement action because the licensee's efforts in identifying
and correcting the violation meet the criteria specified in
Section VII.B of the Enforcement Policy~
Within the areas inspected, one NCV
was identified.
. 7.
8.
11
Licensee Event Review (92700)
The inspectors reviewed the LERs listed below.and evaluated the adequacy
of the corrective action.
The inspectors' review also tncluded followup
of the licensee's corrective action implementation.
(Closed) LER 50-281/91-010, Loss of Containment Integrity Caused by
Failure of Main Steam Trip Valve Bypass Valve.
During a startup of Unit
2 on October 31, 1991, the C SG MSTV manual bypass valve, 2-MS-155,
became stuck in the mid position. Containment isolation valve, 2-MS-
155, could not be closed, and a loss of containment integrity was
dee la red. A six hour LtO to Hot Shutdown was entered. The valve was *
closed using a hydraulic jacking device, mechanically blocked closed,
- and the six hour LCO was exited.
As corrective action, the valve was
repaired during a subsequent outage and a CDE was performed on the
failed components.
The inspe*ctors reviewed CDE 119254 which concluded
that the failure was due to inadequate stem lubrication, which ~aused
heavy friction on the stem, and event~al yoke sleeve failure.
The CDE
stated that similar type failures had occurred previously.
As
corrective action, a PM item was implemented to periodically lubricate
the stem on 2-MS-155 and other similar MS valves.
The inspectors
verified that stem lubrication was present on all valves inspected and
that the licensee had developed a PM to periodically lubricate the
applicable MS valves.
The PM requires the stems to be lubricated every
other RFO and will be implemented during the 1994 Fall Unit 1 RFO.
(Closed) LER 50-280/92-05, Loss of Refueling Integrity Due to Inadequate
Procedures and Work Practices. Violation 50-280/92-07-02 was issued as
a result of this event.
Corrective actions will be reviewed when the
violation is closed out.
(Closed) LER 50-280/92-08, Unit 1 Charging/HHS! SI Pump Configuration
Outside Plant Design Basis Because of Inadequate Procedure Change
Implementation. Violation 50-280/92-12-01 was issued as a result of
this event. Corrective actions were reviewed as part of the violation
closed out as *described in paragraph 8 below.
Within the areas inspected, no violations were identified.
Action on Previous Inspection Items (92701,92702)
(Closed) VIO 50-280, 281/91-24-02, Failure to Comply With tbe
Requirements of TS 3.3.B.2 With the A HHSI Pump Inoperable. Since 1981,
both units operated with one of three HHSI pumps in PTL, and under
certain HHSI pump electrical configurations, the A HHSI pump would
- lockout on an undervoltage condition on its emergency bus.
Operator
action would have been required to manually start the A pump.
This use
of manual operator action to start a HHSI pump during an accident
condition was not part of the plant's licensing basis and therefore
considered a violation of TS 3.3.B.2 which required two HHSI pumps be
operable when critical.
In letters dated November 20 and December 20,
1991, the licensee re~ponded to this violation and in these letters
12
stated that the following corrective actions would be implemented to
prevent reoccurrence:
- Revise ~rocedures to ensure that the HHSI pumps are aligned in a
corifiguration where automatic HHSI* pump actuation capability is
maintained.
Review EOPs in order to determine if other major plant components
require manual operator action which is not consistent with design
basis op~ration.
Develop a policy with regard to acceptable operator manual*
intervention which is consistent with the TS definition of
operability.
. .
Issue an Engineering Technical Bulletin to engineering personnel
describing the event and emphasizing the need to ensure solutions
to design issues do not inappropriately substitute manual operator
actions for automatic design functions.
The inspectors reviewed procedures l-OP-CH-002,003, and 004, Charging
Pump A, B, and C Operations, dated July 2, 1992, and October 8, 1992,
and verified that these procedures contained appropriate instructions
for configuring HHSI pumps when a HHSI ~ump is taken out of service.
The licensee has modified HHSI pump configuration such that all three
pumps in each unit are aligned for automatic start during normal
operation.
In this configuration, no operator intervention is required
to mitigate the initial phase of an accident~
The licensee reviewed EOPS to determine if other major plant components
require manual operator action which is inconsistent with design basis.
This review identified no additional concerns.
The policy developed by the licensee with regard to acceptable operator
manual intervention that is consistent with the TS definition of
operability was previously reviewed by the inspector and considered
adequate. This was discussed in NRC IR 50-280, 281/92-23.
{Closed} VIO 50-281/91-21-01, Failure to Maintain RMT Interlocks
TS 3.3.A.6 requires that with the reactor critical, all
valves, piping, and interlocks associated with the RWST and high and low
head SI pumps that are required to operate under accident conditions be
operable. This issue involved the licensee violating TS 3.3.A.6 by
placing the RMT key switches in the refueling position and bypassing the
automatic mode of operation.
In a letter dated October 15, 1991, the
licensee responded to this violation.
In the letter, the licensee
stated that TSs would be revised to add explicit operability
requirements for the RMT system and the use of administrative control
would be reviewed to ensure that manual operator actions are not
inappropriately substituted for automatic actions required by TSs.
On
August 7, 1992, the licensee submitted a TS change to the NRC for
' ;
9 .
13
approval.
The inspectors reviewed the proposed change-and concluded
that RMT automatic mode of operation was adequately addressed~
The
inspectors also have routinely monitored the licensee's use of
administrative controls and have noted that manual operator actions have
not been inappropriately substituted for automatic action.
(Closed) VIO 50-280, 281/92-04-01, Failure to Implement Adequate
Corrective Actions to Prevent Repetitive HHSI Pump Lube Oil TCV
Failures.* This issue involved inadequate corrective actions which
resulted in reoccurring HHSI pump lube oil TCV failures. The licensee
responded to this violation in letters dated April 27, and September 22;
1992~
In these letters, the licensee stated that six TCVs would be
replaced with an improved design as a long term corrective action. The
inspectors reviewed DCP 92-27-03, Charging Pump SW TCV Replacement,
dated April 28~ 1992, and verified that the TCVs were replaced with.new
globe valves d~signed to be less *susceptible to clogging from debris in
the SW system.
(Closed) VIO 50-280/92-12-0l, Failure to have HHSI Pumps Operable in
Accordance With TS 3.3.B.2. This issue is similar to VIO 50-280,281/91-
24-02 in that HHSI pumps in-unit 1 were configured such that operator
action would have been required to start*a HHSI pump under certain
accident scenarios which is not in accordance with the facility design
basts. Although these violations were similar, they were attributed to
different root causes.
The first violation occurred because manual
operator intervention was accepted as an alternative to automatic
action, and the second violation occurred due to inadequate development
and implementation of a procedure change.
In a letter dated August 12,
1992, the licensee responded to VIO 50-280/92-12-01.
In this letter,
the licensee stated that station processes which change or modify *
procedures, programs or plant systems would be reviewed to ensure that
change control or process was properly managed.
A task team, led by the
Assistant Station Manager, O&M, was formed to review this area. The
task team concluded that the procedures and program change processes
were adequate, but that the station processes for modifying plant
systems needed enhancement. There was not adequate accountability for
changes and too many modifications were being implemented to effectively
manager As a result, the engineering modification backlog was reviewed
- and reduced from 333 proposed modifications to 162 proposed
modifications.
The backlog was reduced by canceling modifications or
scheduling modifications for completion. Other enhancements were made
in the areas of preparation of modification procedural changes and in
training plant personnel on plant modifications. Meetings were held
with station personal emphasizing accountability.
Within the areas inspected, no violations were identified.
Exit Interview
The results were summarized on June 9, 1993, with those individuals
identified by an asterisk in Paragraph 1. The following summary of
inspection activity was discussed by the inspectors during this exit:
Item Number
NCV 50-280,281/93-13~01
LER 50-281/91-010
LER 50-280/92-05
LER 50-280/92-08
VIO 50~280,281/91-24-02
VIO 50-281/91-21-01
VIO 50-280,281/92-04-0l
VIO 50-280/92-12-01
14
Status
Closed
Closed
Closed
Closed
Closed
Closed
Closed
Closed
Description
(Paragraph No.)
Failure to Adequately Control
- Revised MOV Setpoints
(paragraph 6.a).
Loss of Containment Integrity
Caused by Failure of Main
Steam Trip Valve Bypass Valve
(paragraph 7). _
Loss of Refueling Integrity
Due to Inadequate Procedures
and Work Practices {paragraph
7).
Unit 1 Charging/HHS! SI Pump
Configuration Outside Plant
Design Basis Because of
Inadequate Procedure Change
Implementation (paragraph 7)'.
Failure to Comply With the
Requirements of TS 3.3.B.2
With the A HHSI Pump
Inoperable (paragraph 8).
Failure to Maintain RMT
Interlocks Operable (paragraph
8).
Failure to Implement Adequate
Corrective Actibns to Prevent
Repetitive HHSI Pump Luba Oil'
TCV Failures {paragraph 8)~.
Failure to have HHSI Pumps
Operable in Accordance With TS 3.3.B.2 {paragraph 8).
Proprietary information is not contained in this report. Dissenting conunents
were not received from the licensee.
15
10. . Index of Acronyms and I nit i a 1 isms
ASME -
CTMT -
CROM -
ECCS -
EOPS -
ESGR -
HHS!
-
IN
IR
!RPI -
IRS
LCO
LHSI
-
LER
MER
MS
MSTV
NI
NRC
ORS
PORV -
PSIG -
UFSAR -
RMT
RSD
SALP. -
SR
ss
TPUP -
AIR OPERATED VALVE
AMERICAN SOCIETY OF MECHANICAL ENGINEERS
CAUSE DETERMINATION EVALUATION
CORRECTIVE MAINTENANCE
CONTAINMENT
CONTROL ROD DRIVE MECHANISM
DESIGN BASIS DOCUMENTATION
DESIGN CHANGE PACKAGE
EMERGENCY OPERATING PROCEDURES
ENVIRONMENTAL QUALIFICATION
EMERGENCY SWITCHGEAR ROOM
ENGINEERING WORK REQUEST
HIGH HEAD SAFETY INJECTION
INFORMATION NOTICE
INSPECTION REPORT
INDIVIDUAL ROD POSITION INDICATION
INSIDE RECIRCULATION SPRAY
INSTRUMENTATION AND CALIBRATION
LIMITING CONDITION FOR OPERATION
LOW HEAD SAFETY INJECTION
LICENSEE EVENT REPORT
MECHANICAL EQUIPMENT ROOM
MAIN .STEAM
MAIN STEAM TRIP VALVE
NON-CITED VIOLATION
NUCLEAR INSTRUMENT
NUCLEAR REGULATORY COMMISSION
NON SAFETY RELATED
OPERATIONS REVIEW BOARD .
OUTSIDE RECIRCULATION SPRAY
POWER OPERATED RELIEF VALVE
POUNDS PER SQUARE INCH GAUGE
PULL TO LOCK
.
UPDATED FINAL SAFETY ANALYSIS REPORT
REFUELING OUTAGE
REFUELING MODE TRANSFER
REACTOR OPERATOR
REFUELING SHUTDOWN
.
REFUELING WATER STORAGE TANK
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
SAFETY RELATED
STAINLESS STEEL
TEMPERATURE CONTROL VALVE
TECHNICAL PROCEDURE UPGRADE PROGRAM
~-
TS
TECHNICAL SPECIFICATION
VIOLATION
WORK ORDER