ML18152A271
| ML18152A271 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 03/05/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18152A272 | List: |
| References | |
| 50-280-98-01, 50-280-98-1, 50-281-98-01, 50-281-98-1, NUDOCS 9803180111 | |
| Download: ML18152A271 (21) | |
See also: IR 05000280/1998001
Text
Docket Nos:
License Nos:
Report Nos:
Licensee: *
Facility:
Location:
Dates:
Inspectors:
Approved by:
9803180111 980305
ADOCK 05000280
G
U.S. NUCLEAR REGULATORY COMMISSION
REGION II
50-280. 50-281
50-280/98-01. 50-281/98-01
Virginia Electric and Power Company (VEPCO)
Surry Power Station. Units 1 & 2
5850 Hog Island Road
Surry. VA 23883
December 28. 1997 - February 7. 1998
R. Musser. Senior Resident Inspector
K. Poertner. Resident Inspector
R. Gibbs. Reactor Inspector (Sections M8.l through
M8.7 and X2)
H. Whitener. Reactor Inspector (Sections Ml.2 and
Ml.3)
R. Haag, Chief. Reactor Projects Branch 5
Division of Reactor Projects
Enclosure 2
EXECUTIVE SUMMARY
Surry Power Station. Units 1 & 2
NRC Inspection Report Nos. 50-280/98-01. 50-281/98-01
This integrated inspection included aspects of licensee operations.
engineering, maintenance. and plant support.
The report covers a six-week
period of resident inspection; in addition. it includes the results of
announced inspections by two regional reactor inspectors.
Operations
Unit 1 plant response following an automatic reactor trip was normal and
plant systems operated as designed. Subsequent startup activities were
conducted in accordance with approved procedures and in a controlled
manner.
Operator actions during initial power escalation and placing
the generator on line were well coordinated (Section 01.2).
The licensee was unable to identify the cause of the Unit 1 voltage
regulator failure that resulted in a reactor trip. The voltage
regulator was in manual at the time of the trip. The unit was returned
to service with the voltage regulator in automatic (Section 01.2).
Cold weather preparations were adequately implemented and were in
accordance with approved procedures (Section 01.3).
Adequate procedural controls were implemented to ensure the Number 3
Emergency Diesel Generator fuel oil supply was adequate to meet design
basis requirements (Section 01.4).
A review of the Institute of Nuclear Power Operations operating plant
evaluation report was performed and no further follow-up is planned
(Section 01.5).
The Unit 2 high head safety injection system was properly aligned and in
generally good condition (Section 02.1).
Maintenance
A violation of 10 CFR 50. Appendix B. Criterion XVI was identified for
failure to promptly correct a degraded Number 3 Emergency Diesel
Generator auxiliary oil pump motor (Section Ml.1).
Replacement of a gamma-metrics excore power supply was performed
successfully.
The technicians demonstrated attention to detail and a
questioning attitude while following up on the cause of the power supply
failure (Section Ml.2).
Surveillance activities involving the analog rod position system .
charging pump operability and the reactor trip portion of the reactor
protection system were completed in a thorough and professional manner.
Personnel were knowledgeable of the assigned tasks.
Procedures were
detailed and actively used (Section Ml.3).
2
- The licensee has made significant improvements since the original
Maintenance Rule baseline inspection and now has a very comprehensive
Maintenance Rule program (Sections MB.1 through MB.7).
Engineering
Temporary Modification Sl-98-02 to install a temporary resistance
temperature detector in the C main feedwater line was adequately
implemented and the associated safety evaluation justified
implementation of the temporary modification (Section El.1).
Plant Support
Health physics practices were observed to be proper (Section Rl).
Security and material condition of the protected area perimeter barrier
were acceptable (Section Sl) .
Report Details
Summary of Plant Status
Unit 1 operated at power until February 2. 1998 when the unit automatically
tripped from 100 percent power (See Section 01.2). The unit*was returned to
service on February 4. 1998.
The unit operated at power for the remainder of
the inspection period.
Unit 2 operated at power the entire reporting period.
I. Operations
01
Conduct of Operations
01.1 General Comments (71707. 40500)
The inspectors conducted frequent control room tours to verify proper
staffing, operator attentiveness. and adherence to approved procedures.
The inspectors attended daily plant status meetings to maintain
awareness of overall facility operations and reviewed operator logs to
verify operational safety and compliance with Technical Specifications
CTSs).
Instrumentation and safety system lineups were periodically
reviewed from control room indications to assess operability. Frequent
plant tours were conducted to observe equipment status and housekeeping.
Deviation Reports (DRs) were reviewed to assure that potential safety
concerns were properly reported and resolved.
The inspectors found that
daily operations were generally conducted in accordance with regulatory
requirements and plant procedures.
01.2 Unit 1 Reactor Trip and Restart
a.
Inspection Scope (71707)
The inspectors reviewed the plant response following a reactor trip and
monitored licensee activities during the unit restart.
b.
Observations and Findings
On February 2. 1998. at approximately 5:26 a.m. with the unit at 100
percent power. Unit 1 experienced a reactor trip following a main
generator trip. The generator trip resulted in a turbine trip and
subsequent reactor trip on turbine trip. The unit was stabilized at hot
shutdown with temperature being maintained via the steam dumps to the
At the time of the reactor trip the generator voltage regulator was
being operated in base adjust (manual) due to failure of the automatic
portion of the voltage regulator earlier in the cycle. Approximately
one minute after the main generator voltage was adjusted by an operator.
a low voltage alarm was received in the control room and the generator
C.
2
tripped on a differential lockout signal. Voltage had dropped from
approximately 22.5 Kilovolts (kV) to 18.5 kV just prior to the unit
trip.
The inspectors reviewed the plant response following the unit trip. All
systems functioned as designed. Auxiliary feedwater actuated on low
steam generator level following*the trip as required and no primary or
secondary relief valves actuated. All control rods indicated less than
10 steps following the trip and all rod bottom lights lit. The
inspectors attended the post trip review meeting conducted after the
unit was stabilized.
The licensee initiated troubleshooting of the generator voltage
regulator to determine the cause of the generator trip. A vendor
representative assisted in the troubleshooting effort. Testing of the
voltage regulator did not identify a specific failure mechanism.
however. a bad relay in the automatic portion of the circuity was
identified and replaced. This relay prevented operation of the voltage.
regulator in automatic.
The troubleshooting effort also identified a
loose wire in an alarm circuit that was repaired prior to restart. The
licensee (with vendor assistance) performed checks of the voltage
regulator in automatic and manual and determined that the regulator was
operating properly .
The unit was returned to service on February 4. 1998. with* the generator
voltage regulator in automatic.
The inspectors reviewed the trip report
and diicussed the voltage regulator troubleshooting efforts with plant
management prior to restart of the unit.
The inspectors observed
portions of the unit restart. Activities observed were conducted in
accordance with approved procedures. and operator actions during initial
power escalation and placing the generator on line were well coordinated
and performed in a controlled manner.
Conclusions
Unit. 1 plant response following an automatic reactor trip was normal and
plant systems operated as designed.
Subsequent startup activities were
conducted in accordance with approved procedures and in a controlled
manner.
Operator actions during initial power escalation and placing
the generator on line were well coordinated (Section 01.2).
The licensee was unable to identify the cause of the Unit 1 voltage
regulator failure that resulted in a reactor trip. The voltage
regulator was in manual at the time of the trip. The unit was returned
to service with the voltage regulator in automatic (Section 01.2).
01.3 Cold Weather Preparations
a . Inspection Scope (71714)
The inspectors reviewed the licensee's program to protect safety related
systems against extreme cold weather.
3
b.
Observations and Findings
The licensee implements cold weather protection from October through
March.
The program is controlled by procedure O-OSP-ZZ-001. "Cold
Weather Protection." and procedure O-EPM-1303-01. "Freeze Protection
Inspection." Procedure O-OSP-ZZ-001 is performed by operations
personnel to walk down systems and components and procedure O-EPM-1303-
01 is performed by electrical maintenance personnel to verify proper
operation of heat tracing and strip heaters.
The licensee also
implements cold weather protection utilizing Operations Checklist-21.
"Severe Weather." The checklist is implemented based on outside air
temperature.
The inspectors verified that procedures O-OSP-ZZ-001 and O-EPM-1303-01
had been implemented as required.
The procedures are performed monthly
during the time period that cold weather protection is required.
The
inspectors reviewed the procedures and verified that identified
discrepancies were addressed prior to the onset of cold weather.
During
periods of cold weather the inspectors performed tours of station areas
and equipment to verify cold weather preparations were effective and
discussed cold weather preparation activities with cognizant licensee
personnel.
No discrepancies were identified during these reviews.
c. Conclusions
Cold weather preparations were adequately implemented and were in
accordance with approved procedures.
01.4 Emergency Diesel Generator (EOG) Number 3 Fuel Oil Supply
a.
Inspection Scope (71707)
The inspectors reviewed licensee actions associated with a 50.72
(b)(l)(ii)(C) one-hour non-emergency event report concerning the
Number 3 EOG fuel oil capacity requirements.
b. Observations and Findings
On February 6, 1998. the licensee identified a condition where the
Number 3 EOG would not meet the design basis fuel ciil supply
requirements.
The Updated Final Safety Analysis Report and Technical
Specifications require that a minimum of 35,0000 gallons of fuel oil be
available.
The 35,000 gallon requirement is based on full load
operation of one EOG for seven days.
The safety related portion of the
fuel oil transfer system consists of two 20,000 gallon underground
storage tanks that are not cross connected under normal operation.
The
underground storage tanks provide fuel oil to all three EDGs.
Each EOG
is provided with two fuel oil transfer pumps that take a suction on a
separ~te underground storage tank and discharge to the associated EOG
day tank .
4
One fuel oil transfer pump for the Number 3 EOG is powered from the Unit
1 J emergency bus and the other fuel oil transfer pump is powered from
the Unit 2 J emergency bus.
During a loss of offsite power to the
station the Number 3 EOG will automatically start and energize either
the Unit 1 or Unit 2 J emergency bus.
This results in one unit's J
emergency bus not being energized and one fuel oil transfer pump not
. being available to supply fuel oil to the Number 3 EOG.
With only one
fuel oil transfer pump available. a seven-day supply of fuel oil would
not be available to the Number 3 EOG unless actions were taken to cross
connect the fuel oil storage tanks or to cross connect the non-energized
J emergency bus with the H emergency bus for that unit.
Neither of
these actions were addressed in the Emergency Operating Procedures
(EOPs).
Based on the potential to have less than a seven-day supply of
fuel oil available to'the Number 3 EOG. the licensee declared one of the
two fuel oil flow paths to the Number 3 EOG inoperable and entered a 24-
hour TS limiting condition of operation to return the flow path to an
operable status or declare the Number 3 EOG inoperable.
The licensee
notified the NRC via a one-hour non-emergency event report that the
plant was operating in a condition not covered by the plant's operating
or emergency procedures.
The licensee revised the EOPs to require that power on the J emergency
buses be verified following entry into the EOPs.
If a unit's J
emergency bus is not energized. the EDP requires entry into an Abnormal
Operating Procedure to transfer oil from the above ground fuel oil
storage tank to the underground fuel oil storage tanks if available or
to cross connect the deenergized J emergency bus to the unit with the
energized H emergency bus after stripping unnecessary loads. After
implementation of the procedural controls. the licensee declared both
fuel oil flow paths operable.
The procedural controls were implemented
prior to exceeding the 24-hour TS limiting condition of operation.
The inspectors reviewed the licensee's safety evaluations and
corresponding procedure changes and found them adequate to control the
operation of the Number 3 EOG fuel oil transfer pumps following a loss
of offsite power to the station. The inspectors were still reviewing
this item at the end of the inspection period and further review of EOG
fuel oil requirements is identified as Inspection Followup Item (IFI)
50-280, 281/98001-01.
c. Conclusions
Adequate procedural controls were implemented to ensure the Number 3 EOG
fuel oil supply was adequate to meet design basis requirements.
An
Inspection Followup Item was identified to review EOG fuel oil
requirements .
5
01.5 Institute of Nuclear Power Operations (INPO) Operating Plant Evaluation
Report
a.
Inspection Scope (71707)
The inspectors reviewed the INPO evaluation report dated January 7.
1998. for the evaluation conducted during April 1997.
b.
Observations and Findings
On January 13-14. 1998. the inspectors reviewed the INPO operating plant
evaluation report for the review conducted in April. 1997.
Based on
this review of the INPO evaluation. no further follow-up is planned.
c . Cone l us i oris
A review of*the Institute of Nuclear Power Operati*ons operating plant
evaluation report was performed by the inspectors and no further follow-
up is planned.
02
Operational Status of Facilities and Equipment
02.1 High Head Safety Injection
a.
Inspection Scope (71707)
During the inspection period the inspectors performed a walkdown of the
Unit 2 high head safety injection system.
b.
Observations and Findings
The inspectors performed a walkdown of accessible components associated
with the Unit 2 high head safety injection system.
The walkdown
encompassed the pump suction piping from the refueling water storage
tank and the pump discharge piping up to the containment penetrations.
The inspectors referenced the system piping and instrument diagrams and
procedures 2-0P-SI-OOlA. "Safety Injection System Alignment." and 2-0P-
CH-OOlA. "CVCS Valve Alignment." for proper system alignment and
component descriptions.
The inspectors checked system hangers and supports. general
housekeeping, valve positions. and labeling.
The inspectors determined
that the system was properly aligned and in generally good condition.
The inspectors verified that the valve alignment procedures adequately
aligned the system for normal operation.
c.
Conclusions
The Unit 2 high head safety injection system was properly aligned and in
generally good condition.
6
II. Mai'ntenance
Ml
Conduct of Maintenance
Ml.1 Inadequate Evaluation of Number 3 EOG Auxiliary Oil Pump Motor Vibration
Data
a.
Inspection Scope (62707)
b.
The inspectors conducted a review of the circumstances leading to and
following the failure of the Number 3 EOG auxiliary oil pump.
Observations and Findings
On January 29. 1998, operators in the control room received a Number 3
EOG trouble alarm. Operators were dispatched to the Number 3 EOG room
and determined that the auxiliary oil pump had failed.* Earlier in the
shift. operations personnel performing a tour of the diesel room noted a
noise coming from the auxiliary oil pump motor.
The noise was
indicative of metal to metal contact on the outboard side of the pump
motor.
The shift was in process of planning the replacement of the
motor when the failure occurred.
The EOG was declared inoperable and a
72-hour limiting condition for operation was entered.
The pump motor
was replaced and the EOG was returned to service later that same day .
The following day, the auxiliary oil pump was noted to have vibration
readings greater than those observed the previous day following the
motor replacement.
The EOG was again taken out of service. and the pump
was replaced.
Vibration readings were acceptable and the EOG was
returned to service.
An examination of the Number 1 and 2 EOG auxiliary
oil pump vibration readings did not indicate that their failure was
eminent.
The licensee continues to monitor all the EOG auxiliary oil
pumps and motor vibrations at an increased frequency.
A category 2 root cause evaluation. performed by the licensee. developed
proposed corrective actions to address the vibration issue.
Proposed
corrective actions included preparing a design change to allow the
installation of the auxiliary oil pump and motor as a skid and to change
the suction and discharge piping to flexible metal hose.
Approximately 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> following the Number 3 EOG auxiliary oil pump
motor failure. the inspectors toured the EOG room and observed a work
request tag (number 070525) in the vicinity of the failed pump.
The tag
stated that the vibration of the pump motor was at higher than normal
levels and that the motor bearings were degraded.
The tag was dated
January 14, 1998, which was fifteen days prior to the failure of the
motor.
The work request was initiated following discovery that the pump
motor vibration readings had increased. The increased vibration
information was not forwarded to or reviewed by cognizant technical
personnel. Therefore, the significance of the increased vibration was
not adequately assessed and the repair work effort was only given a
normal priority classification. Further review of the pump vibration
7
data indicated that the auxiliary oil pump had been operating at
increased vibration levels for several months prior to the increase that
was measured on January 14. 1998. Discussions with cognizant licensee
personnel revealed that the auxiliary oil pump motor's increased
vibration readings were a valid indication of the motor's degrading
condition which should have been acted upon.
The licensee's failure to
act upon this information is considered an example of inadequate
corrective action and is a violation of 10 CFR 50. Appendix B. Criterion
XVI. Corrective Action. This matter will be tracked as Violation (VIO)
50-280, 281/98001-02.
c.
Conclusions
A violation of 10 CFR 50. Appendix B. Criterion XVI was identified for
failure to promptly correct a degraded Number 3 Emergency Diesel
Generator auxiliary oil pump motor.
Ml.2 Power Supply Replacement for Gamma-Metrics Monitoring System
a.
Inspection Scope (62707)
The inspectors observed the corrective maintenance to replace a failed
low voltage power supply for the Gamma-Metrics Excore Neutron Monitoring
System.
b.
Observations and Findings
On January 6, 1998, the inspectors observed the replacement of the low
voltage power supply for excore detector indicators in accordance with
1-CAL-510. *Gamma-Metrics Excore Neutron Flux Monitoring System White
Channel NFD 1270.* Revision 7. This was corrective maintenance
performed under Work Order (WO) 00380561.
The problem was that the
channel monitoring indicators failed to zero.
The inspectors verified that breaker tagout SI 98-NI-001 was performed
and verified by technicians prior to starting the job.
The technicians
were methodical and precise in lifting and landing leads.
Each lead was
entered into the lifted lead log and double verified before proceeding
to the next wire.
Independent verification was performed after all
leads were lifted or landed.
When all leads had been lifted. taped.
logged and verified. the technicians removed the hard wired board
containing the low voltage power supply from the control cabinet.
The
cause of the failure was overheating of a shorted transformer which had
released gas and ruptured the casing of the power supply.
Some
discoloration of the board could be observed on close inspection.
The
technicians took the board to a module repair specialist who verified
that the hard wiring on the board was not damaged prior to replacing the
power supply.
The technicians demonstrated a questioning attitude and
attention to detail in -the performance of the task .
8
c. Conclusions
Replacement of a gamma-metrics excore power supply was performed
successfully.
The technicians demonstrated attention to detail and a
questioning attitude while following up on the cause of the power supply
failure.
Ml.3 Surveillance Observations
a.
Inspection Scope (61726)
The inspectors observed all or portions and/or reviewed documentation
for the surveillances discussed below.
b.
Observations and Findings
Charging Pump Operability and Performance Test
On January 7. 1998. the inspectors attended the pre-job briefing in the
Unit 1 control room for the monthly operability and performance test of
charging pump 1-CH-P-lA.
The briefing was thorough.
Procedure 1-0PT-
CH-001. "Charging Pump Operability and Performance Test For 1-CH-P-lA."
Revision 24. was walked-through by the test director. Responsibilities
were assigned. questions were answered and precautions. limits and
communications were discussed.
The inspectors accompanied operators to the field and observed the
positioning of various system valves. instrument valves and electrical
breakers per procedure 1-0PT-CH-001.
The procedure was present and
followed.
The steps were signed off as they were accomplished.
The
operators were familiar with the task.
Analog Rod Position Indication System Functional Test
On January 7. 1998. the inspectors observed the operability test on the
Unit 1 rod bottom bistables performed in accordance with procedure 1-IT-
FT-RI-001. "Analog Rod Position Indication System Functional Test."
Revision 1.
The test involved setting up instrumentation to input a
voltage signal to the rod bottom bistables and varying the signal to
determine at what voltage and rod position the bistables would trip.
The test also verified consistency between the relay racks and the
control room position indicators. Annunciator response was also
verified.
The procedure was detailed and was followed step-by-step. Signoffs and
setpoints were recorded as steps were performed and compared to the
acceptance range specified in the procedure.
One bistable was below the
acceptance range and was corrected on the spot. Three other bistable
setpoints were near the low end of the acceptance range and were
adjusted to the center of the tolerance range. Test instrument
calibrations were current. and personnel were knowledgeable of the
tasks.
9
Reactor Protection System Logic Test
On January 8. 1998. the inspectors observed portions of logic testing
conducted per 1-PT-8.1. "Periodic Test of the Reactor Trip Portion of
the Reactor Protection System." Simulated sensor signals were input to
the logic circuits from the test panel and operation of the logic relays
was confirmed by annunciators and indicator lights.
Pumps and valves
were not actually operated since the system was in a test configuration.
The inspectors observed the majority of test from the reactor trip
breaker cubicle.
Both maintenance. operations. and the shift supervisor
had responsibilities in performing the actual trip of the main reactor
trip breaker.
The reactor trip bypass breaker was tested and then put
into service.
Instrumentation was set up to measure the closure time of
the main reactor trip breaker.
The coordination of the station groups
was excellent.
Instrument calibration was current. the procedure was
present and carefully followed. and communications between relay room.
control room and the breaker cubicle were good.
Review of the procedure
showed that it was detailed and thorough.
In the course of this test.
192 logic functions were verified.
The operators and technicians were properly aware of the potential to
trip the reactor. The test personnel performed the procedure
methodically and demonstrated a knowledge of the systems and task.
c. Conclusions
Surveillance activities involving the analog rod position system.
charging pump operability and the reactor trip portion of the reactor
protection system were completed in a thorough and professional manner.
Personnel were knowledgeable of the assigned tasks.
Procedures were
detailed and actively used.
MB
Miscellaneous Maintenance Issues (92902, 62706)
M8.1
(Closed) EEI 50-280. 281/97001-09:
Inadequate corrective action for
self-assessment deficiencies. This item became an escalating and
mitigating factor in the enforcement package for EA 97-055. and as a
result was not issued as a part of the Notice of Violation.
Followup to
the licensee's corrective actions for Maintenance Rule self-assessments
during the North Anna Maintenance Rule baseline inspection determined
that corrective actions were acceptable with some minor weaknesses.
During this inspection. the inspectors reviewed the corrective actions
for the licensee's January 13. 1997. Maintenance Rule self-assessment
and the January 9. 1997. Sargent & Lundy assessment at Surry. and
determined that the status of each item was well known. corrective
actions were well documented. and corrective actions for identified
problems were adequate.
M8.2
(Closed) IFI 50-280. 281/97001-02:
Followup on licensee actions to
provide performance criteria for structures after industry resolution of
this issue. This item was issued to review the Maintenance Rule
10
structures performance criteria at Surry following development of an
industry standard in that area.
The industry guideline was approved by
the NRC in Regulatory Gui de 1.160. Revision 2. dated March 1997.
The
inspectors reviewed the licensee's instruction. Technical Report CE
0087. "Guidelines for Monitoring of Structures Surry Power Station."
Revision 2. and determined that the guidance for performance criteria
had been incorporated.
In addition. the inspectors reviewed the status
of the inspection of structures at Surry, and determined that all
accessible structures had been subjected to an initial baseline
inspection by the licensee.
MB.3
(Closed) VIO EA 97-055. 01013:
Inadequate goals and monitoring for the
Emergency Switchgear (ESG) Heating Ventilation and Air Conditioning
(HVAC) system. This violation identified that the licensee had not
established adequate goals and monitoring for the ESG HVAC system in
accordance with 10 CFR 50.65. the Maintenance Rul.e.
As a result of this violation and the other violations identified in the
Maintenance Rule baseline inspection and issued in EA 97-055, the
licensee established a Maintenance Rule recovery team to revise and
revalidate Virginia Power's entire Maintenance Rule program. This
recovery team took action to: rescope all SSCs under the Maintenance
Rule; risk-rank the SSCs; revise performance criteria to comply with the
guidance in NUMARC 93-01; re-perform the historical review of plant and
industry operating data; and reinforce the necessity for compliance with
The inspectors reviewed the results of this effort. and
verified that the results were consistent with the NUMARC guidance for
implementation of the Maintenance Rule.
The inspectors reviewed the
revised scoping matrix. verified by sampling that performance criteria
were in accordance with NUMARC guidance. verified that the historical
review had been completed and that data had been loaded into the
licensee's Maintenance Rule database. and verified that current
monitoring of SSC performance was being accomplished.
In addition. the licensee placed the ESG HVAC system air handling units
and chillers in (a)(l) status under the Maintenance Rule and established
goals and monitoring for this equipment.
The inspectors reviewed the
goals and monitoring and determined they were adequate to meet
Maintenance Rule requirements.
No deficiencies were identified during
this review.
MB.4
(Open) via EA 97-055. 01023:
Failure to demonstrate performance of SSCs
had been adequately controlled through the performance of appropriate
preventive maintenance. This violation identified seven examples of
failure to demonstrate the adequacy of SSCs performance through
appropriate preventive maintenance.
These deficiencies were due to the
failure to establish adequate performance criteria for monitoring SSCs.'
failure to perform adequate historical review of operating data for
SSCs. and failure to adequately evaluate operating data and take
appropriate action under the Maintenance Rule when data indicated
unacceptable performance.
11
The corrective actions. which were accomplished by the licensee's
Maintenance Rule recovery team and verified by the inspector as
discussed under the closeout of EA 97-055. 01013 in Section M8.3 of this
report. apply to the closure of this violation.
In addition. the following specific corrective actions were taken by the
licensee and verified by the inspectors:
Example 1: This example identified that no historical review or
inadequate historical reviews had been done for direct current
power. ESG HVAC. service water. emergency lighting and condensate
polishing systems.
The inspectors verified that the historical
review had been done for each of these systems. the data had been
loaded into the licensee's Maintenance Rule database. and the data
had been evaluated against the new performance criteria for
appropriate actions under the Maintenance Rule.
This example is
closed.
Example 2:
This example identified that the performance criteria
for the radiation monitoring system was inappropriate and failures
of the system had not been adequately evaluated for appropriate
actions under the Maintenance Rule.
The inspectors verified that
new performance criteria had been established for the radiation
monitoring system. the historical review had been done and data
had been loaded into the Maintenance Rule database. *and the data
had been evaluated against the performance criteria for
appropriate actions under the Maintenance Rule.
This example is
closed.
Example 3: This example identi1ied that the performance criteria
for the reactor protection system and the safety injection
actuation system were not commensurate with safety, due to the
fact that they were not in accordance with the licensee's
Probabilistic Risk Assessment (PRA).
The inspector did not review
the specific corrective actions for this item due to the fact that
the Surry PRA has recently been identified to have s*imilar
problems to those identified in the North Anna Maintenance Rule
Baseline inspection conducted in October 1997 and documented in
NRC Inspection Report Nos. 50-338. 339/97-08. Additional review
of performance criteria as they relate to PRA will be conducted
concurrently with a review of the North Anna performance criteria
at a later date. This example remains open.
Example 4: This example identified that there were no performance
criteria established for the risk-significant component cooling
water pumps and the instrument air compressors.
The inspectors
verified that the licensee had established performance criteria
for monitoring these SSCs for reliability and unavailability in
accordance with NUMARC guidance. This example is closed .
Example 5: This example identified that no performance criteria
had been established to monitor setpoint drift of the reactor
12
coolant system code safety*valves. The inspectors verified that
new performance criteria had been established to monitor setpoint
drift of these SSCs.
This example is closed.
Example 6: .This example identified that the licensee had not
adequately evaluated service water system failures under the
Maintenance Rule prior to placing the system in (a)(2) status.
The inspectors verified that the licensee had properly evaluated
the failures. re-classified the system as (a)(l), and established
- goals and monitoring as required by the Maintenance Rule.
This
example is closed.
Example 7:
This example identified that the licensee had not
established reliability performance criteria to monitor the
standby functions of the electro-hydraulic control system. bearing
cooling system. boric acid transfer pumps (emergency boration
mode). the auxiliary building HVAC, and the control room HVAC in
accordance with NUMARC guidance.
The inspectors verified that
reliability performance criteria were established for these SSCs.
This example is closed.
This violation remains open .. With the exception of example 3, all the
remaining examples of this violation were closed. Additional review is
required for example 3 prior to closure .
MS.5
(Closed) VIO EA 97-055. 01033:
Inadequate instructions concerning cause
determinations for maintenance preventable functional failures. This
item identified that the licensee's Maintenance Rule implementation
procedure provided inadequate instructions for the evaluation of
maintenance preventable function failures under the Maintenance Rule.
The corrective actions. whith were discussed under the closeout of EA 97-055, 01013 above. apply to the closure of this violation:
The inspectors verified that Virgin1a Power Administrative Procedure
VPAP-0815, "Maintenance Rule Program.* Revision 7. had been changed to
be consistent with the NUMARC guidance regarding evaluation of
maintenance preventable functional failures.
The re-evaluation of
historical data under the new requirements would compensate for any
failures evaluated under the old procedural requirements. This
violation is closed.
MS.6 (Closed) VIO EA 97-055. 01043:
Failure to follow procedure concerning
performance criteria for the reactor protection system. This violation
identified that the licensee had failed to obtain working group approval
for a change to the performance criteria for the reactor protection
system in accordance with VPAP-0815, "Maintenance Rule Program.*
Revision 3.
The licensee determined that this problem was caused by a
lack of emphasis on compliance with the Maintenance Rule program.
As a
result. the licensee trained personnel regarding their responsibilities
under the Maintenance Rule.
In addition. the Senior Vice-President.
Nuclear. issued a memorandum reinforcing managements expectations for
13
complete compliance with the Maintenance Rule program. This action was
verified by the inspectors.
M8.7
(Closed) VIO EA 97-055. 01053:
Failure to follow procedure concerning
approval of a risk-significant plant configuration. This violation
involved a failure to follow procedural requirements concerning
management approval of a risk-significant plant configuration. The
licensee has significantly changed the process for risk-evaluation of
on-line removal of equipment from service.
The process now involves
assessment by the licensee's PRA group for any plant configurations not
previously evaluated. This process is defined in VPAP-2001. "Station
Planning and Scheduling." Revision 5. and NAF-97-0086. "PSA (a)(3)
Maintenance Rule Risk - Significant Equipment - Surry Power Station
Units 1&2." Revision 0.
This process was reviewed during the North Anna
Maintenance Rule baseline inspection and found to be acceptable with the
exception of its PRA basis.
The same situation regarding problems with
the PRA exists at Surry, and as a result. additional inspection of this
process will be required after PRA revision. This followup will be
conducted under IFI 50-280. 281/97001-01: Followup licensee actions to
strengthen risk-assessment for on-line maintenance activities. which
remains open from the original baseline inspection at Surry.
Conclusions (Sections M8.1 through M8.7)
The licensee has made significant improvements since the otiginal
Maintenance Rule baseline inspection and now has a very comprehensive
III. Engineering
El
Conduct of Engineering
El.l Temporary Modification Sl-98-02
a.
Inspection Scope (37551)
The 1nspectors reviewed Temporary Modification (TM) Sl-98-02 that
installed a temporary replacement Resistance Temperature Detector CRTD)
in the C main feedwater line.
b.
Observations and Findings
On January 15. 1998. the C main feedwater temperature detector 1-FW-RTD-
lllC failed.
Failure of the RTD resulted in the P-250 calorimetric
program being unreliable for determination of reactor power and required
that manual power calculations be performed to determine reactor power.
The licensee determined that the RTD failed due to water intrusion into
the RTD that resulted from a failed thermowell.
The licensee
implemented TM Sl-98-02 to install a temporary replacement RTD in the
thermowell associated with local temperature indicator TI-FW-154C .
Implementation of the TM would allow the P-250 computer calorimetric
14
program to be returned to service and cessation of manual calorimetrics.
The TM was implemented January 16. 1998.
The inspectors reviewed the TM and associated safety evaluation and held
discussions with reactor engineering personnel about implementation of
the TM.
The inspectors determined that the TM was adequately
implemented and that the associated safety evaluation adequately
justified implementation of the TM.
c.
Conclusions
Temporary Modification Sl-98-02 to install a temporary RTD in the C main
feedwater line was adequately implemented and the associated safety
evaluation justified implementation of the temporary modification.
IV. Plant Support
Rl
Radiological Protection and Chemistry Controls (71750)
Sl
On numerous occasions during the inspection period. the inspectors
reviewed Radiation Protection (RP) practices including radiation control
area entry and exit. survey results. and radiological area material
conditions.
No discrepancies were noted. and the inspectors determined
that RP practices were proper .
Conduct of Security and Safeguards Activities (71750)
On numerous occasions during the inspection period. the inspectors
performed walkdowns of the protected area perimeter to assess security
and general barrier conditions.
No deficiencies were noted and the
inspectors concluded that security posts were properly manned and that
the perimeter barrier's material condition was properly maintained.
V. Management Meetings
Xl
Exit Meeting Summary
The inspectors presented the inspection results to members of licensee
management at the conclusion of the inspection on February 20 and on March 2.
1998.
The licensee acknowledged the findings presented.
The inspectors asked the licensee whether any materials examined during the
inspection should be considered proprietary.
No proprietary information was
identified.
X2
Enforcement Meeting
On March 11. 1997. a Predecisional Enforcement Conference for EA Case 97-055.
covered in Inspection Report Nos. 50-280. 281/97-01. was held in the Regional
Office with the licensee in attendance.
The following EEis were discussed:
EEI 50-280.
EEI 50-280.
EEI 50-280.
EEI 50-280.
EEI 50-280.
EEI 50-280.
EEI 50-280.
281/97001-03
281/97001-04
281/97001-05
281/97001-06
281/97001-07
281/97001-08
281/97001-09
15
Following the conference. a Notice of Violation (NOV) was issued on August 29.
1997.
Based on the NOV issued. the above EEis are administratively closed.
with the exception of EEI 50-280. 281/97001-09 which is closed in Section MB.1
of this report.
The violations identified in the above Notice of Violation
will be tracked as:
EA 97-055 VIO 01013: Inadequate goals and monitoring for the emergency
switchgear heating ventilation and air conditioning system (Closed
Section MB. 3).
EA 97-055 VIO 01023: Failure to demonstrate performance of SSCs had been
adequately controlled through the performance of appropriate preventive
maintenance (Open Section MB.4).
EA 97-055 VIO 01033: Inadequate instructions concerning cause
determinations for maintenance preventable functional failures (Closed
Section MS.5).
EA 97-055 VIO 01043: Failure to follow procedure concerning performance
criteria for the reactor protection system (Closed Section MB.6).
EA 97-055 VIO 01053: Failure to follow procedure concerning approval of
a risk-significant plant configuration (Closed MS.7).
16
PARTIAL LIST OF PERSONS CONTACTED
M. Adams. Superintendent. Engineering
R. Allen. Superintendent. Maintenance
R. Blount. Assistant Station Manager. Nuclear Safety & Licensing
D. Christian. Station Manager
M. Crist. Superintendent. Operations
- E. Collins. Director. Nuclear Oversight
B. Shriver. Assistant Station Manager. Operations & Maintenance
T. Sowers. Superintendent. Training
B. Stanley. Supervisor. Licensing
W. Thorton. Superintendent. Radiological Protection
IP 37551:
IP 40500:
IP 61726:
IP 62706:
IP 62707:
IP 71707:
IP 71714:
IP 71750:
IP 92902:
Opened
.INSPECTION PROCEDURES USED
Onsite Engineering.
Effectiveness of Licensee Controls in Identifying. Resolving. and
Preventing Problems
Surveillance Observation
Maintenance Rule
Maintenance Observation
Plant Operations
Cold Weather Preparations
Plant Support Activities
Followup - Maintenance
ITEMS OPENED, CLOSED, AND DISCUSSED
50-280. 281/98001-01
50-280, 281/98001-02
EA 97-055. 01013
IFI
Review EOG fuel oil requirements (Section 01. 4).
EOG aux oil pump failure (Section Ml.l).
Inadequate goals and monitoring for the
EA 97-055. 01023
EA 97-055. 01033
EA 97-055. 01043
emergency switchgear heating ventilation and air
conditioning system (Section X2).
Failure to demonstrate performance of SSCs had
been adequately controlled through the
performance of appropriate preventive
maintenance (Section X2).
Inadequate instructions concerning cause
determinations for maintenance preventable
functional failures (Section X2).
Failure to follow procedure concerning
performance criteria for the reactor protection
system (Section X2).
EA 97-055, 01053
Closed
50-280, 281/97001-02
50-280, 281/97001-03
50-280. 281/97001-04
50-280. 281/97001-05
50-280, 281/97001-06
50-280, 281/97001-07
50-280, 281/97001-08
50-286. 281/97001-09
EA 97-055. 01013
EA 97-055. 01033
EA 97-055. 01043
17
Failure to follow procedure concerning approval
of a risk-significant plant configuration
(Section X2).
IFI
Followup on licensee actions to provide
performance criteria for structures after
industry resolution of this issue (Section
M8.2).
Failure to establish adequate performance
criteria for monitoring systems resulting in
inadequate implementation of the maintenance
rule (Section X2).
Inadequate procedural requirements resulting in
inadequate implementation of the maintenance
rule (Section X2).
Failure to accomplish adequate historical
reviews resulting in inadequate implementation
of the maintenance rule (Section X2).
Goals and monitoring not established for ESW and
ESG HVAC systems resulting in inadequate
implementation of the maintenance rule
(Section X2).
Performance criteria changed without approval of
the WG (Section X2).
Management approval not obtained for high risk
plant configuratibn (Section X2).
Inadequate corrective action for self-assessment
deficiencies (Section M8.1).
Inadequate goals and monitoring for the
emergency switchgear heating ventilation and air
conditioning system (Section M8.3).
Inadequate instructions concerning cause
determinations for maintenance preventable
functional failures (Section M8.5).
Failure to follow procedure concerning
performance criteria for the reactor protection
system (Section M8.6).
EA 97-055. 01053
Discussed
EA 97-055. 01023
50-280, 281/97001-01
18
Failure to follow procedure concerning approval
of a risk-significant plant configuration
(Section M8.7).
Failure to demonstrate performance of SSCs had
been adequately controlled through the
performance of appropriate preventive
maintenance (Section M8.4).
IFI
Followup licensee actions to strengthen risk-
assessment for on-line maintenance activities
(Section M8.7).