ML18152A259
| ML18152A259 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 12/02/1994 |
| From: | Belisle G, Branch M, David Kern, Tingen S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18152A260 | List: |
| References | |
| 50-280-94-28, 50-281-94-28, NUDOCS 9412130095 | |
| Download: ML18152A259 (19) | |
See also: IR 05000280/1994028
Text
Report Nos. :
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, N.W., SUITE 2900
ATLANTA, GEORGIA 30323-0199
50-280/94-28 and 50-281/94-28
Licensee:
Virginia Electric and Power Company
Innsbrook Technical Center
5000 Dominion Boulevard
Glen Allen, VA
23060
Docket Nos.:
50-280 and 50-281
License Nos.:
Facility Name:
Surry 1 and 2
Inspection Conducted:
October 2 through November 5, 1994
Inspectors:
Approved by:
Scope:
M. W. Branch, Senior Resident Inspector
G. Tingen, Resident Inspector
D. M. Kern, Resident Inspector
J~
~.A.
React r Projects Section 2A
Division of Reactor Projects
SUMMARY
11-1-rr-
Date Signed
I).- /-fy.
Date Signed
/ 7--/-9'-f
Date Signed
/l. *i- ttcf
Date Signed
This routine resident inspection was conducted on site in the areas of plant
status, operational safety verification, maintenance and surveillance
inspections, plant support, Licensee Event Report followup, and action on
previous inspection items.
Inspections of backshift and weekend activities
were conducted on October 3, 6, 7, 12, 27, 28, 29, 31 and November 4, 1994 .
9412130095 941202
ADOCK 05000280
O
....
2
Results:
Plant Operations
The Unit 1 charging pump A cubicle was recently decontaminated and equipment
and housekeeping in the cubicle were good.
Housekeeping in the Unit 1
B charging pump cubicle was poor (paragraph 3.1.2).
Recurring annunciation of several control room alarms and C Steam
Generator (SG) level oscillations placed a heightened demand on operator
attentiveness.
Operators took appropriate action and effectively maintained a
safe operating environment.
The decision to reduce reactor power to control
SG level oscillations demonstrated a good safety perspective (paragraph 3.3).
On October 27, the 2A station battery was declared inoperable and on
October 28 the licensee requested and was granted enforcement discretion to
complete on-line repair.
Station Nuclear Safety and Operating Committee
review of this request was thorough and technically sound.
Licensed personnel
implemented appropriate operator actions while the 2A station battery was
inoperable (paragraph 3.4).
Maintenance
A violation was identified for failure to stop work and revise or obtain a new
procedure when the instructions in the design change to modify the charging
pump temperature control valve positioners could not be followed
(paragraph 4.2).
Operations, maintenance, and engineering personnel coordinated efficiently and
minimized the amount of time that the 2A station battery was out of service to
complete repairs.
Management oversight was evident and the temporary
modification was performed in a quality manner (paragraph 4.3).
Engineering
System engineer trending and evaluation of Unit 1 steam generator oscillations
was comprehensive.
Engineering technical support was timely and provided
valuable information to operations personnel for safe power operation
(paragraph 5.1).
An engineering evaluation of proposed modification to the 2A station battery
was sound (paragraph 5.2).
The charging pump lube oil temperature control systems in both units have a
history of operational difficulties.
Short term corrective actions were good
in that system operability was promptly evaluated and deviation reports
initiated when problems occurred.
However, the long term corrective actions
were not fully effective in that operational problems continue to occur
(paragraph 5.3) .
3
Plant Support
The general material condition and housekeeping within the turbine, security,
auxiliary, and safeguard buildings were good.
Minor discrepancies were
promptly corrected.
Radiological personnel were pro-active in establishing
measures to reduce the potential for spread of contamination during
preservation activities within the auxiliary building (paragraph 6.1) .
- .
REPORT DETAILS
1.
Persons Contacted
1.1
Licensee Employees
- W. Benthall, Supervisor, Licensing
- M. Biron, Supervisor, Radiological Engineering
- H. Blake, Jr., Superintendent of Nuclear Site Services
- R. Blount, Superintendent of Maintenance
- R. Cherry, Licensing, Corporate
- D. Christian, Station Manager
- R. Cross, Coordinator of Station Procedures
J. Costello, Station Coordinator, Emergency Preparedness
- J. Downs, Superintendent of Outage and Planning
D. Erickson, Superintendent of Radiation Protection
- A. Friedman, Superintendent of Nuclear Training
B. Garber, Licensing
B. Hayes, Supervisor, Quality Assurance
- D. Hayes, Superintendent of Administrative Services
- A. Keagy, Superintendent, Nuclear Materials
- J. Kilmer, Licensing
- C. Luffman, Superintendent, Security
- R. MacManus, Supervisor, System Engineering
- J. McCarthy, Assistant Station Manager
- W. Miles, Supervisor, Quality Assurance
D. Miller, Radiation Protection
- A. Price, Assistant Station Manager
- R. Saunders, Vice President, Nuclear Operations
K. Sloane, Operations
E. Smith, Site Quality Assurance Manager
- D. Sommers, Supervisor, Licensing, Corporate
T. Sowers, Superintendent of Engineering
B. Stanley, Station Procedures
- J. Swientoniewski, Supervisor, Station Nuclear Safety
G. Thompson, Supervisor, Maintenance Engineering
E. Turko, Engineering
G. Woodzell, Nuclear Training
Other licensee employees contacted included plant managers and
supervisors, operators, engineers, technicians, mechanics, security
force members, and office personnel.
1.2
NRC Personnel
- M. Branch, Senior Resident Inspector
- D. Kern, Resident Inspector
S. Tingen, Resident Inspector
- Attended Exit Interview
Acronyms and initial isms used throughout this report are listed in the
last paragraph.
- .
2.
2
Plant Status
Units 1 and 2 operated at power for the entire inspection period.
Reactor power on Unit 1 was reduced to 97 percent on October 15 to
reduce SG level oscillations (paragraph 3.3) and remained at this power
level through the end of the inspection period.
3.
Operational Safety Verification (71707)
3.1
Biweekly ESF Inspections
3.1.1 RSHX SW Supply/Discharge Piping
The inspectors walked down the RSHX SW supply and discharge
piping located in the Unit 1 and 2 safeguards buildings.
Proper containment isolation and SW radiation monitor and
SW flow instrument valve alignments were verified.
Equipment was in good overall condition and housekeeping was
adequate.
Housekeeping in these areas was recently improved
by cleaning the sumps and maintaining them in a dry
condition in lieu of being full of water.
3.1.2 Unit 1 Charging Pump Cubicles
On November 4, the inspectors walked down the Unit 1
charging pump cubicles.
Items inspected were charging pump
lube oil system, lube oil temperature control system,
charging pump seal cooling system and general equipment
condition.
Lube oil was present on the base plates of all
three charging pumps which indicated that there were minor
lube oil leaks.
Charging pump A had been decontaminated and
equipment and housekeeping was good.
Charging pump B had a
large quantity of boric acid on the base plate which was
considered contaminated.
The boric acid appeared to be from
RCS leakage past the pump outboard seal.
Also boric acid
was present at the outboard seal cooler mechanical joints
which indicated that the joints were leaking.
It appeared
that SW was leaking from the capped joint downstream of
valve l-SW-183.
Debris was present on the pump base plate
and on the cubicle floor.
The inspectors concluded that
housekeeping in charging pump B cubicle was poor.
Although
leaking joints were identified, the leakage did not appear
to be serious.
The overall condition of the equipment in
the cubicle was considered satisfactory.
Charging pump C
seal cooler mechanical joints had some boric acid present
but overall housekeeping and equipment condition was good in
the cubicle.
The above observations were presented to
maintenance management for evaluation and correction.
- .
3.2
3.3
3
RCP lC Seal Degradation
Prior to the 1994 Unit 1 RFO, the #1 seal leakoff for RCP lC was
approximately 1.25 gpm.
After seal maintenance during the RFO,
the measured seal leakoff was approximately 1 gpm.
The design
flow rate through the #1 seal is approximately 3 gpm.
Westinghouse Product Update S-009, issued in March 1988, specifies
the normal operating range for #1 seal leakoff flow at NOP to be
from 1.0 to 5.0 gpm.
Current leakoff flows on the three Unit 2
RCPs was approximately 2.5 gpm.
Beginning in July, 1994, the #1 seal leakoff flow for RCP lC
slowly trended down from the 1 gpm value.
The licensee's
operating and abnormal procedures cautioned against continued RCP
operation with a low seal leakoff condition.
The technical
information provided to the licensee indicated that seal leakoff
values between 1 gpm and 0.8 gpm indicated a degraded RCP seal
which should be closely monitored, and at a value below 0.8 the
pump should be secured.
The licensee's monitoring of seal leakoff included validation of
control room flow indication by performing what the licensee
termed as a "bucket check".
This involved sending personnel into
containment to operate several local valves in order to divert and
collect the #1 seal leakoff in a graduated container.
Several
"bucket checks" were performed which determined that indicated
flow was approximately 0.2 gpm less than actual measured leakoff
fl ow.
At the inspection period's end the licensee continued to closely
monitor RCP seal leakoff flow.
A 21-day maintenance outage that
includes repair/replacing the RCP lC seal has been scheduled to
commence on November 27, 1994.
Unit 1 Operator Response to Control Room Alarms and Indications
Recurring annunciation of several control room alarms and C SG
level oscillations placed a heightened demand on operator
attentiveness early in this report period.
Degraded RCP seal
leakoff (paragraph 3.2) necessitated frequent reliance on abnormal
operating procedures and multiple containment entries to confirm
control room indication.
On October 10, operators observed five
percent peak-to-peak C SG level oscillations.
The magnitude of
the level oscillations increased slowly over the next several
days.
On October 12, the PZR Relief Valve Low Air Pressure alarm
locked in indicating that the backup actuating air supply to the
PZR PORVs was degraded.
A containment entry was required to
investigate the cause.
On October 13-14, the PZR PORV/SV Open
alarm annunciated approximately twenty times.
Initial
investigation verified that none of the PZR PORV/SVs had opened .
However, the alarm continued to recur whil~ technicians worked to
identify the cause of the erroneous alarm.
The inspectors
- .
3.4
4
observed that control room operators responded appropriately to
each of the above alarms and effectively maintained a safe
operating environment.
The inspectors expressed concern that operators could become
unnecessarily challenged if additional alarms or further increases
in SG level oscillations occurred.
Station management was
sensitive to this concern and discussed potential compensatory
actions such as staffing an additional control room operator in
the event that the control room tempo further increased.
On
October 15, SG level oscillations increased to twenty percent
peak-to-peak.
The Shift Supervisor directed that reactor power be
reduced, which eliminated the SG level oscillations.
The
Operations Superintendent issued an operations standing order
which instructed operators to maintain reduced power levels to
minimize SG level oscillations until plant shutdown for SG
chemical cleaning (paragraph 5.1).
The decision to lower reactor
power significantly reduced the level of demand placed upon
operators in the control room by reducing the need to devote
special attention to steam generator levels.
Technicians subsequently repaired the circuit which had caused the
false PZR PORV/SV Open alarms.
The inspectors noted good system
engineer involvement in the evaluation and repair of this alarm.
On October 19, operators entered containment, identified an air
fitting leak which had caused the PZR Relief Valve Low Air
Pressure alarm, and placed the standby air bottles in service.
The inspectors concluded that licensee response to the elevated
control room tempo was appropriate.
Power reduction to reduce SG
level oscillations demonstrated a good safety perspective.
Management has scheduled a 21-day maintenance outage commencing
November 27, 1994, to repair/replace the RCP IC seal and
chemically clean the Unit 1 SGs.
Request for Enforcement Discretion
At 11:00 am on October 27, the licensee declared the Unit 2
120 vdc 2A station battery inoperable when a battery cell failed
the monthly surveillance test (paragraph 4.3).
The licensee
appropriately entered a 24-hour LCO shutdown action statement as
required by TS 3.16.B.3.
The inspectors observed station
management's discussion of corrective options and SNSOC's review
of the resulting corrective action plan.
The proposed plan
involved jumpering a degraded battery cell to restore the
operating integrity of the 2A station battery.
The engineering
basis for modifying the station battery and status of corrective
action planning was presented for SNSOC review.
On October 28,
the licensee concluded that evaluation and corrective maintenance
would not be complete within the TS permitted 24-hour period.
SNSOC subsequently approved a justification for continued Unit 2
operation at power for an additional 24-hour period to complete
corrective maintenance to the 2A station battery.
The inspectors
5
concluded that SNSOC adequately addressed pertinent safety
concerns to support the licensee's request for enforcement
discretion.
The licensee verbally requested NRC enforcement discretion via a
telephone conference call at 7:45 am on October 28.
Specifically,
the licensee requested enforcement discretion from TS 3.16.B.3 to
permit continued power operation for an additional 24-hour period.
NRC Region II and NRR representatives listened to the licensee's
request and asked questions concerning the current condition of
the station battery, safety aspects of continued power operation
in this condition for an additional 24-hours, and design
capability of the intended battery modification.
The licensee
responded that the remaining 59 battery cells showed no sign of
degradation, operational experience from a similar power plant
would be used for the battery modification, and that continued
operation did not create a significant hazards consideration as
defined in 10 CFR 50.92.
System engineers further described the
mechanism which had degraded the single battery cell and indicated
that the condition was unlikely to significantly worsen in the
next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Subsequent to the conference call, the inspectors requested
further information regarding the relative risk of continued
operation for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for on-line repairs as compared to
performing the corrective repair while shutdown.
Station
management determin~d that the likelihood of occurrence for the
most challenging station battery significant event was on the
order of IOE-7.
SNSOC further determined that the inherent risk
associated with the battery jumper installation process was not
sign~ficantly altered by maintaining the plant at power.
The NRC
further internally reviewed the technical aspects and safety
significance of the request.
The NRC concluded that exercise of
enforcement discretion was appropriate to minimize the potential
safety consequences of unnecessary plant transients and the
accompanying operational risks and impacts.
At approximately
9:30 am, the NRC verbally granted the licensee enforcement
discretion from TS 3.16.B.3, extending the LCO action statement
for an additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
The licensee promptly submitted a written request for enforcement
discretion to follow-up the conference call. The inspectors
observed that the document did not directly discuss the projected
condition of the degraded cell or its affect on the 2A station
battery during the additional 24-hour period.
However, this
information was provided during the conference call in appropriate
detail.
In addition the licensee stated that a TS amendment
request to clarify the narrative description of the station
battery in TS 4.6.C.l would be submitted.
The inspectors
determined that the document accurately recorded the safety basis
for the request.
3.5
6
At 11:00 am on October 28, operators entered TS 3.0.l which is a
six-hour shutdown LCO action statement.
Earlier, operators had
been informed that the NRC had tentatively, verbally granted the
requested enforcement discretion, but were awaiting confirmation
from the corporate staff.
The corporate staff confirmed NRC
approval at 1:30 pm and the licensee promptly exited TS 3.0.1.
Corrective maintenance was performed (paragraph 4.3) and the
licensee exited the exited TS 3.16.B.3 at 6:15 pm, thereby
terminating the NRC enforcement discretion.
Monthly Verification of Containment Isolation Valve Lineups
The inspectors walked down containment penetrations and verified
that the containment isolation valves were properly aligned,
vent/drain connections were capped, and that there was no leakage
from the piping.
Unit 1 exterior containment penetrations 79
through 86 were inspected.
These penetrations contain the SW
supply and discharge piping to the RSHXs.
The inspectors verified
locally that the air operated containment isolation valve in each
line was shut and verified that the control room indications also
indicated shut.
Unit 2 exterior containment penetrations 79
through 86 were also inspected. These penetrations provide the
same function as the Unit 1 penetrations and the containment
isolation valve in each line was verified to be shut in the same
manner as the Unit 1 valves.
3.6
Monthly Review of Safety-Related Tagouts
The inspectors reviewed the following safety-related tagouts and
verified that the tagouts were prepared and implemented in
accordance with OPAP-0010, Tagouts, revision 4, and that the
tagged components were in the required position:
Tagging Record No.: l-94-EP-0116, Replace l-VS~E-48 Normal
Supply Breaker.
Tagging Record No.: 2-93-EP-0050, Issue to shift supervisor
(emergency bus cross-tie breaker).
Within the areas inspected, no violations or deviations were identified.
4.
Maintenance and Surveillance Inspections (62703, 61726, TI 2515/125)
The inspectors observed various maintenance and surveillance activities
to verify proper calibration of test instrumentation, use of approved
procedures, performance of work by qualified personnel, conformance to
LCOs, and correct system restoration following the completion of
maintenance and post maintenance .
4.1
7
FME Controls (TI 2515/125)
The inspectors reviewed VPAP-1302, FME Program, rev1s1on 6, and
concluded that provisions for material, parts, and tool
accountability to ensure loose items are not inadvertently left
inside structures, systems, or components after the completion of
work activities were properly addressed.
Work activities
involving entry into SGs, reactor cavity when the reactor vessel
head is removed, fuel pool, containment sump and SI, RHR, AFW and
RC system openings were examples where FME controls were invoked.
Methods for maintaining FME include establishing an FME controlled
work area where items entering and exiting the work area are
logged in and out, covering system openings when work is not being
done, maintaining cleanliness when the work is performed and
performing closeout inspections after completion of the work to
ensure that all FM was removed.
In June 1994, the licensee noted an increasing trend in deviations
associated with FME controls. A task team was assembled to review
recent FME events and to evaluate the overall effectiveness of the
program and its requirements.
The task team concluded that the
station FME program was adequate and that the increasing trend in
deviations was primarily due to a lack of awareness of FME
standards on the part of individuals not directly involved in the
implementation of FME controls. Also in June 1994, Violation
50-280, 281/94-17-02 was issued for failure to prop~rly install
FME covers over RCS maintenance openings and the failure to remove
scaffold material after cleaning a CCW heat exchanger.
The
inspectors reviewed the licensee's response to the violation and
considered that it was adequate.
The inspectors also reviewed the
corrective actions recommended by the task team to improve station
awareness of FME controls and considered them to be adequate.
The
inspectors will review implementation of these as part of the
violation closure.
During monthly maintenance observations the inspectors routinely
checked for proper FME controls.
FME controls were observed to
have been properly implemented during the recent maintenance
activities associated with cleaning CC heat exchanger 1-CC-E-lD,
overhaul of EOG fuel oil transfer pump 1-EE-P-lD and replacement
of the AVEF train A charcoal filter media.
FME controls have improved.
FME covers were installed over the
- 1 EOG air intake filters for welding and grinding activities;
however, the same level of protection was not provided for the air
cooling louvers for the electrical generator.
During grinding and
weld activities, the inspectors noted that metal grinding material
was entering the electrical generator housing.
The inspectors
questioned the craft personnel about FME controls and was told
that grinding was now complete and that they had not considered
the air louvers as an area needing protection.
The inspector
notified the SE who exhibited a great deal of concern with metal
4.2
8
material entering the electrical generator.
The SE directed
electrical maintenance to remove the generator covers and vacuum
out the metal grinding material. Additionally, procedural
controls for work on the other two EDGs was modified to specify
more complete FME controls.
Modification To Charging Pump SW TCV Positioners
On October 23 and 24, the inspectors witnessed the modification of
the positioner to A charging pump TCV, l-SW-TCV-108A.
The purpose
of this modification was to change the positioner from reverse
acting to direct acting and was accomplished in accordance with
WO 271507-05 and portions of DCP 92-27-3, Charging Pump SW TCV
Replacement Surry Units 1 and 2, field change 3.
The inspectors witnessed the technicians removing the positioner
and modifying the positioner in the shop.
The instructions
required that the positioner be partially disassembled in order to
perform the modification.
The instructions specified that the set
screw be removed from one side of the disc assembly and installed
on the opposite side of the disc assembly.
The inspectors noted
that technicians removed and reversed the disc assembly in lieu of
removing and relocating the set screw.
The inspectors were
informed that the design did not lend itself to removing and
relocating the set screw.
The positioner was reassembled and
reinstalled.
During subsequent testing the positioner did not
properly operate.
The positioner was removed and disassembled.
Technicians concluded that the disc assembly was not properly
oriented during the initial modification attempt.
The assembly
was reoriented and the positioner reassembled and reinstalled.
During subsequent testing the positioner again failed to properly
operate.
During the third attempt to modify the posit i oner
technicians noted that other parts were not properly assembled in
the positioner.
The positioner was properly reassembled and
satisfactorily operated during subsequent testing.
Step 3.3.f of DCP 92-27-3 specified that the positioner be
modified in accordance with Appendix 4-12.
Following the
modification of the positioner for the Unit 1 A charging pump TCV,
the inspectors questioned if Appendix 4-12 needed to be revised to
provide correct instructions.
The DCP was subsequently revised.
This revision also ctarified how the positioner was to be
reassembled.
Subsequent investigation revealed that the licensee's controlled
vendor technical manual for the charging pump TCV positioners did
not provide instructions for modifying the positioner.
The
instructions in the DCP for modifying the positioner were provided
directly to station engineering by the vendor and incorporated
into DCP 92-27-3.
The vendor was contacted by the licensee and
questioned why these instructions would not work.
The licensee
was informed that the instructions were not applicable to the
...
9
licensee's TCV positioners and were provided in error.
The vendor
subsequently approved the licensee's method of modifying the
pas it i oner.
This same modification was previously performed on the positioner
for the Unit 2 B charging pump TCV, 2-SW-TCV-208B.
The inspectors
reviewed WO 272634-03 completed on September 2, 1994.
The WO
summary sheet completed by the technicians that performed the work
did not discuss that the instructions in the DCP could not be
followed.
A change to DCP 92-27-3 instructions was not issued
during that time.
The inspectors were informed that the
positioner for the Unit 2 B charging pump TCV was modified by
reversing the disc assembly in lieu of removing and relocating the
set screw as specified in the DCP.
Step 6.10.2.b of VPAP-0801, Maintenance Program, rev1s1on 4,
requires that when a work instruction cannot be followed the items
shall be placed in a safe condition, work stopped, and a new or
r~vised instiuction be prepared.
The failure to stop work after
it was identified that instructions for modifying Unit 1 A
charging pump and Unit 2 B charging pump TCV positioners could not
be followed was identified as VIO 50-280, 281/94-28-01, Failure to
Stop Work When Work Instructions Could Not Be Followed .
4.3
Unit 2 Online LCO Maintenance - Station Battery
On October 27, the 2A station battery cell 52 voltage was measured
at 2.067 volts and the 2A station battery was declared inoperable
(paragraph 3.4).
An event chronology and enforcement action
associated with this event are addressed in a special report,
NRC Inspection Report Nos. 50-280/94-32 and 50-281/94-32.
The licensee developed TM S2-94-15, Station Battery 2A Cell 52
Bypass Jumper, revision 0, and corrective maintenance procedure
2-ECM-0101-10, Cell 52 Of Main Station Battery 2A - Jumper Cable
Installation or Removal Provision, revision 0, to jumper out
cell 52 from the 2A station battery while the plant remained at
power.
Experience gained from similar maintenance at the North
Anna Power Station was effectively used.
The inspectors observed
SNSOC's review of the TM and installation procedure.
SNSOC
members demonstrated strong safety sensitivity to performing this
maintenance on-line and asked detailed questions which improved
the quality of procedure 2-ECM-0101-10.
The inspectors' questions
regarding procedural guidance to open circuit the battery were
appropriately addressed in the SNSOC review.
The inspectors attended the licensee's pre-brief for the
installation of TM S2-94-15.
The work plan (WO 302410) was
reviewed thoroughly by maintenance, operations, and management
personnel.
Specific precautions and preparations for a potential
loss of DC power were implemented in accordance with abnormal
procedure 2-AP-10.06, Loss of DC Power, revision 2.
The licensee
- .... ~.
10
also implemented senior management oversight controls using
VPAP-0108, Infrequently Conducted or Complex Tests.
Maintenance
technicians observed that procedure 2-ECM-0101-10 provided
detailed instruction for the installation of a permanent jumper,
but did not specifically indicate that two permanent jumpers were
required to complete the TM.
Management personnel reviewed this
concern and confirmed with SNSOC that installation of the second
jumper was within the scope of the procedure.
Maintenance
personnel were directed to perform the TM using the procedure as
written.
The inspectors evaluated the increased safety risk of
delaying the TM for further refinement of the procedure and
concluded that the management decision was appropriate.
The pre-
brief for this safety related maintenance was excellent.
Maintenance personnel commenced WO 302410 at 3:21 pm on
October 28.
The inspectors observed maintenance activities in the
control room and in the battery room.
Communications were
effectively established and management oversight was appropriate.
The inspectors observed excellent second checking by electricians
while performing each step of the jumper installation procedure.
System engineers provided close technical support to technicians
in the battery room.
Materials were properly staged and access to
the work area was effectively controlled.
TM S2-94-15 was
completed, the 2A station battery was declared operable, and the
licensee exited TS 3.16.B.3 at 6:15 pm on October 28.
Operations,
maintenance, and engineering personnel coordinated efficiently to
minimize the amount of time that the 2A station battery was out of
service and to complete the TM in a quality controlled manner.
Constructive comments and lessons learned from this first
performance of 2-ECM-0101-10 were collected for incorporation into
a procedure revision.
Within the areas inspected, one violation was identified.
5.
Onsite Engineering Review (37551)
5.1
SG Level Oscillations
Unit 2 SG level oscillations had been observed as early as
May 1993.
The licensee evaluated the condition, modified plant
operations, and eventually resolved the issue by chemically
cleaning the SGs in June 1994.
Engineers determined that the
oscillations resulted from buildup of a hard iron-copper scale on
the SG tube support plates.
The blockage caused an increased
pressure drop in the two-phase flow zone which in turn resulted in
hydrodynamic instability (SG level oscillations).
Licensee root
cause evaluation determined that Unit 1 was susceptible to the
same problem.
Further assessment of Unit 2 identified several SG
water chemistry trends as precursors to the onset of SG level
oscillations.
The vendor performed a visual inspection of the
Unit 1 SG tube support region in March 1994 and identified
significant tube support plate blockage in the A and C SGs.
The
-.
11
licensee commenced monitoring SG chemistry following the restart
of Unit 1 and observed gradual development of the same trends
which had preceded oscillations on Unit 2.
The inspectors
discussed the SG inspection results and trend analysis with system
engineers and concluded that the licensee maintained a good
technical understanding of the SG level oscillation phenomenon.
On October 10, operators began to observe Unit 1 C SG level
oscillations (paragraph 3.3).
On October 15, operators reduced
reactor power to eliminate the oscillations as had been previously
recommended by engineering to address Unit 2 oscillations.
The
inspectors questioned whether continued operation with
oscillations, and thereby a reduced SG operating inventory, posed
an unreviewed safety question.
Engineering prepared Safety
Evaluation 94-183 and determined that continued operation with
oscillations did not present an unreviewed safety question.
Engineering Transmittal S-94-0171 was then developed to provide
interim operating guidance until the plant could be shut down for
SG cleaning.
Engineering recommended reactor power be limited to
98 percent to eliminate SG level oscillations.
Further power
reductions in one percent increments were projected as necessary
to compensate for continuing tube sheet blockage prior to plant
shutdown for SG cleaning.
The inspectors reviewed Safety
Evaluation 94-183 and Engineering Transmittal S-94-0171 and
determined them to be technically sound.
Use of previous
experience from Unit 2 and engineering support for continued power
operation was comprehensive.
5.2
Evaluation of Unit 2 Station Battery Temporary Modification
Safety Evaluation 94-185 and TM S2-94-15 were created to support
on-line modification of the 2A station battery.
The modification
was written to temporarily jumper out degraded cell 52, thereby
restoring integrity to the 2A station battery.
The inspectors
reviewed the documents and determined that they had been properly
prepared in accordance with VPAP-1403, Temporary Modifications.
SNSOC's evaluation of the TM was detailed.
The licensee developed Engineering Transmittal CEE-94-063 and
Calculation EE-0046 to evaluate the capability of the 2A station
battery to perform its design function with up to two of the
original 60 cells jumpered out of service.
Engineering determined
that the 2A station battery would remain operable with two cells
jumpered.
The inspectors concluded that the documents technically
justified the licensee's determination that the 2A station battery
was operable following the installation of TM S2-94-15.
5.3
Charging Pump Lube Oil Temperature Control System
The charging pump lube oil temperature control systems in both
units have had a history of operational difficulties.
In 1992,
the TCVs on all six charging pumps were replaced to improve system
~.
12
operation.
Prior to 1992, SW flow blockages in the system were a
major problem.
Replacement of the TCVs solved the blockage
problem but additional problems developed following the
installation of the new TCVs.
Through review of the DRs initiated
on the charging pump TCVs, the inspectors noted that 24 DRs were
initiated since 1993 due to operational problems.
On several
occasions charging pumps were rendered inoperable due to TCV
operational problems.
Sluggish operation of the TCV appeared to
be the problem in the majority of DRs submitted.
After the TCVs were replaced, a stem wiper ring was subsequently
installed on each TCV to prevent mud/silt from accumulating in the
packing.
In December 1993, field change 3 was issued to
DC 92-27-3 to implement additional changes in the charging pump
lube oil temperature control systems to reduce stem friction and
improve TCV operation.
Modifications to be implemented included
installation of differently designed TCV stem packing material and
modified wiper rings and increasing valve actuator air pressure
operating range.
These modifications have been recently
implemented on the Unit 2 B charging pump lube oil temperature
control system and these modifications are to be completed on the
remaining Unit 1 and 2 charging pump lube oil temperature control
systems.
However, sluggish operation of the Unit 2 B charging
pump TCV has been noted since completion of the DC 92-27-3
modifications.
Corrosion of the TCV guide bushings and packing follower has also
been identified as a cause of excessive valve stem friction.
The
licensee was developing a schedule to replace the packing follower
and guide bushings on all six charging pump TCVs with a less
corrosive material.
The licensee's 1994 third quarter DR trend report identified that
charging pump lube oil temperature control system problems were
recurring.
Also, the licensee has a Level I Project on this
issue.
The inspectors concluded that when charging pump lube oil
temperature control system problems occur, short term corrective
actions were good, in that, system operability was promptly
evaluated and DRs initiated.
However, the long term corrective
actions were not fully effective in that operational problems
continue to occur.
Within the areas inspected, no violations or deviations were identified.
6.
Plant Support (40500, 71707, 71750)
The inspectors conducted facility tours, work activities observations,
personnel interviews, and documentation reviews to determine whether
licensee programs were effectively implemented to comply with regulatory
requirements in the areas of radiological protection, security,
emergency preparedness, and fire protection.
13
6.1
Plant Tour Observations
The inspectors observed radiological control practices and
radiological conditions throughout the plant.
Portal and handheld
monitors were observed to be in good condition and within proper
calibration periodicities.
Radiological postings and control of
contaminated areas were good.
Workers complied with radiation
work permits and appropriately used required personnel monitoring
devices.
Plastic sheets were installed as a vertical extension of
the contaminated area boundary within portions of the auxiliary
building.
The inspectors determined this to be a pro-active
measure which reduced the potential for spread of contamination
during preservation activities within the auxiliary building.
The general material condition and housekeeping within the
turbine, security, auxiliary, and safeguard buildings were good.
Minor discrepancies such as improperly stored anticontamination
clothing were identified and reported to the shift supervisor.
The inspectors confirmed, on subsequent plant tours, that the
discrepancies had been corrected.
The inspectors observed that
some of the cable penetrations through the Unit 2 cable vault/pipe
tunnel wall were not sealed and questioned whether these
penetrations were credited as a fire barrier.
The licensee
presented controlled station drawings which showed that this wall
and penetrations were not credited as a fire barrier. A recent
design change package relocated the cable vault fire barrier to
the pipe tunnel/auxiliary building wall.
The inspectors reviewed
controlled station drawings and confirmed that penetrations in
question were not currently credited as a fire barrier.
No
discrepancies were identified.
Selected aspects of plant physical security were reviewed during
regular and backshift hours to verify controls were in accordance
with the security plan and implementing procedures.
This review
included security measures, vital and protected area barrier
integrity, maintenance of isolation zones, personnel access
control, searches of personnel, packages and vehicles, and
escorting of visitors.
No discrepancies were noted.
Use of
security cards for access to the Unit 2 battery room was relaxed
on October 28 to facilitate maintenance activities
(paragraph 4.3). A security guard was stationed to hold open the
door and verify that personnel entering the room had proper access
authorization.
The number of people involved in the maintenance
and turnover of guard personnel midway through the evolution posed
a challenge to access control.
The inspectors questioned the
stationed security personnel concerning their access control
responsibilities and actions to be taken in the event that the
battery room maintenance resulted in a fire.
Security personnel
were knowledgeable and performed their duties in an acceptable
manner .
- ..
14
6.2
Management Safety Review Committee
The inspector reviewed the meeting minutes from MSRC meeting 94-08
and attended portions of the most recent MSRC meeting, convened on
October 4.
The committee is comprised of both licensee and
non-licensee personnel, who provide independent review and audit
of a wide variety of Surry Station activities.
Both Surry and
North Anna power station activities are reviewed at each MSRC
meeting.
The MSRC currently meets eight times per year, which is
more frequent than required by TS.
A quorum was properly
established on October 4, with fourteen of the seventeen committee
members present.
The committee reviewed current operating status,
NRC reportable events and violations since the last MSRC meeting,
key management personnel changes, and significant events including
the recent chemical contamination of the auxiliary ventilation
system charcoal filters discussed in NRC Inspection Report Nos.
50-280/94-24 and 50-281/94-24.
Questions raised by committee
members were generally of an in-depth nature.
Station personnel
provided supplemental information when requested to clarify
actions which the station has taken to address both industry and
Surry specific issues.
The inspector concluded that MSRC
effectively performed review and audit of station activities.
Within the areas inspected, no violations or deviations were identified.
7.
Licensee Event Report Followup (92700)
The inspectors reviewed LERs submitted to the NRC to verify accuracy,
description of cause, previous similar occurrences, and effectiveness of
corrective actions.
The inspectors considered the need for further
information, possible generic implications, and whether the events
warranted further onsite follow-up.
The LERs were also reviewed with
respect to the requirements of 10 CFR 50.73 and the guidance provided in
NUREG 1022, Licensee Event Report System, and its associated
supplements.
(Closed) LER 50-280/94-004, Loop Isolation Valve Not Open Within TS
Limit Due to Personnel Error.
Violation 50-280/94-08-01, Failure to
Open the Unit 1 B Loop Hot Leg Stop Valve Within 2 Hours, was issued as
a result of this event.
Corrective actions for this event will be
reviewed during the closeout of Violation 50-280/94-08-01.
(Closed) LER 50-280, 281/94-008, Both Auxiliary Ventilation Fans
Inoperable Due to a Single Event.
Violation 50-280, 281/94-24-01,
Failure to Identify and Promptly Correct Conditions Adverse to Quality,
was issued as a result of this event.
Corrective actions will be
reviewed during the closeout of Violation 50-280, 281/94-24-01.
(Closed) LER 50-281/94-003, Failure to Isolate Primary Grade Water to
Blender.
Violation 50-281/94-17-01, Failure to Close Unit 2 Makeup
15
Water Isolation Valve Within Fifteen Minutes After Makeup, was issued as
a result of this event.
Corrective actions will be reviewed during the
closeout of Violation 50-281/94-17-01.
Within the areas inspected, no violations or deviations were identified.
8.
Exit Interview
The inspection scope and findings were summarized on November 8, 1994,
with those persons indicated in paragraph 1.
The inspectors described
the areas inspected and discussed in detail the inspection results
addressed in the Summary section and those listed below.
Item Number
VIO 50-280, 281/94-28-01
LER 50-281/94-003
LER 50-280/94-004
LER 50-280, 281/94-008
Status
Open
Closed
Closed
Closed
Description/(Paraqraph No.)
Failure to Stop Work When Work
Instructions Could Not be
Followed (paragraph 4.2).
Failure to Isolate Primary
Grade Water to Blender
(paragraph 7).
Loop Isolation Valve Not Open
Within TS Limit Due to
Personnel Error (paragraph 7).
Both Auxiliary Ventilation
Fans Inoperable Due to a
Single Event (paragraph 7).
Proprietary information is not contained in this report.
Dissenting
comments were not received from the licensee.
9.
Index of Acronyms and Initialisms
AVEF
AUXILIARY VENTILATION EXHAUST FILTER
COMPONENT COOLING WATER
CFR
CODE OF FEDERAL REGULATIONS
DESIGN CHANGE PACKAGE
DR
DEVIATION REPORT
EOG
EE
ENGINEERING EVALUATION
ENGINEERED SAFETY FEATURE
GPM
GALLONS PER MINUTE
LCO
LIMITING CONDITIONS OF OPERATION
LER
LICENSEE EVENT REPORT
MSRC
MANAGEMENT SAFETY REVIEW COMMITTEE
NOTICE OF ENFORCEMENT DISCRETION
NORMAL OPERATING PRESSURE
..
NRC
PZR
RC
SNSOC
sv
TI
TM
TS
voe
VPAP
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
POWER OPERATED RELIEF VALVE
PRESSURIZER
REACTOR COOLANT PUMP
REFUELLING OUTAGE
RECIRCULATION SPRAY HEAT EXCHANGER
SYSTEM ENGINEER
SAFETY INJECTION
STATION NUCLEAR SAFETY AND OPERATING COMMITTEE
SAFETY VALVE
TEMPERATURE CONTROL VALVE
TEMPORARY INSTRUCTION
TECHNICAL SPECIFICATION
VOLTS DIRECT CURRENT
VIOLATION
VIRGINIA POWER ADMINISTRATIVE PROCEDURE
WORK ORDER