ML18152A309
| ML18152A309 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 04/26/1990 |
| From: | Fredrickson P, Holland W, York J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18152A310 | List: |
| References | |
| 50-280-90-14, 50-281-90-14, NUDOCS 9005080044 | |
| Download: ML18152A309 (17) | |
See also: IR 05000280/1990014
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
\\
REGION II
101 MARIETTA STREET, N.W .
ATLANTA, GEORGIA 30323
Report Nos.:. 50-280/90-14 and 50-281/90-14
Licensee:
Virginia Electric and Power Company
5000 Dominion Boulevard
Glen Allen, VA
23060
Docket ~os.: 50-280 and 50-281
License Nos.:
Facility Name:
Surry 1 and 2
Inspection Conducted:
March 4 through March 31, 1990
Inspectors: ~~~
/C'-c;r;...
W. LHoi lari;SeniorRes i dent Inspector
J. w~--: ~;;,;tor&P::~
Accompanying Inspectors: K.
Approved
Scope:
Reactor Inspector, RII
tor Inspector, RII
SUMMARY
4' -:lt*-to
Date Signed
1-f - .J.t -fo
Date Signed
t/- zr;. - -~
Date Signe?r
This routine resident inspection was conducted on site in the areas of plant
operations, plant maintenance, plant surveillance, licensee event report
review, action on previous inspection findings, evaluation of licensee self
assessment capability,1and licensee quality assurance program implementation.
Certain tours were conducted on backshifts or weekends.
Backshift or weekend
tours were conducted on March 4, 5, 7, 11, 24, 25, and 27.
Results:
During this inspection period, one violation with two example was identified
(paragraph 6) for failure to follow procedure during testing of components, and
systems as required by TS 6.4.D.
The inspectors consider that the two examples
of failure* to follow procedure by craft personnel are not related to a
progranmatic problem in the surveillance area.
However, they raised concerns
about the level of reviews that are conducted by cognizant supervision who
9005080044 900427
ADOCK 05000280
G!
.
2
approve the periodic test results on the critique page of the completed
survei 11 ances.
The inspectors contend that these reviews should identify
problems similar to the ones cited in the violation and consider that
additional management attention is necessary in this area.
In addition, an
unresolved item was identified (paragraph 6) in the same inspection area with
regards to required surveillance testing frequency.
An inspector followup item (Paragraph 3.d) was identified on licensee's leak
reduction program which is required by TS 6.4.K.1.
During a review of operator performance in the control room, it was noted that
the operations staff that performs control room duties were performing these
functions in a satisfactory manner.
Cooperation between shifts was noted as a
strong area.
However, some minor problems regarding strict adherence to
requirements and attention to detail were also noted as needing additional
attention.
An inspector followup item (paragraph 4) was identified on licensee action for
replacement of type BFD 'relays.
REPORT DETAILS
1.
Persons Contacted
Licensee Employees
2.
- W. Benthall, Supervisor, Licensing
- R. Bilyeu, Licensing Engineer
D. Christian, Assistant Station Manager
D. Erickson, Superintendent of Health Physics
- G. Grecheck, Assistant Station Manager
D. Hart, Supervisor, Quality, QA Department
- E. Harrell, Vice President, Nuclear Operations
- M. Kansler, Station Manager
T. Kendzia, Supervisor, Safety Engineering
J. McCarthy, Superintendent of Operations
- R. Gwaltney, Superintendent of Maintenance
J. Downs, Superintendent of Outage and Planning
- T. Sowers, Superintendent of Engineering
- E. Smith, Site Quality Assurance Manager
NRC Personnel
- K. Poertner, Reactor Inspector, Region II
- Attended exit interview.
On March 27, 1990, a management meeting was held at
Station in order for the licensee to provide an update
headquarters personnel on issues of mutual interest.
attendance at the meeting were:
S. Ebneter, Regional Administrator, RII
the Surry Power
to NRC regional and
NRC management in
G. Lainas, Associate Director for Region II Reactors, NRR
H. Berkow, Director, Project Directorate II-2, NRR
P. Fredrickson, Section Chief, DRP, RII
B. Buckley, Project Manager, NRR
The me~ting focused on plant status and improvement updates from middle
managers 2in the areas of operations, maintenance, engineering, procedures
upgrade, assessments, quality assurance, and outage planning.
After the
meeting; t:he Station Manager conducted a plant tour for the participants.
Acronyms and initialisms used throughout this report are listed in the
last paragraph.
Plant Status
Unit 1 and Unit 2 began the reporting period at power.
Both units
operated at power for the duration of the inspection period *
2
3.
Operational Safety Verification
(71707 & 42700)
a.
Daily Inspections
b.
c.
The inspectors conducted daily inspections in the following areas:
control room staffing, access, and operator behavior; operator
adherence to approved procedures, TS, and LCOs; examination of panels
containing instrumentation and other reactor protection system
elements to determine that required channels are operable; and review
of control room operator logs, operating orders, plant deviation
reports, tagout logs, jumper logs, and tags on components to verify
compliance with approved procedures.
The inspectors also routinely
accompanied station management on plant tours and observed the
effectiveness of their influence on activities being performed by
plant personnel.
Weekly Inspeftions
The inspectors conducted weekly inspections in the following areas:
verification of operability of selected ESF systems by valve
alignment, breaker positions, condition of equipment or component,
and operability of instrumentation and support items -essential to
system actuation or performance.
Plant tours were
conducted which
included observation of general plant/equipment conditions, fire
protection and preventative measures, control of activities in
progress, radiation protection controls, physical security controls,
plant housekeeping conditions/cleanliness, and missile hazards.
The
inspectors routinely noted the temperature of the AFW pump discharge
piping to ensure increases in temperature were being properly
monitored and evaluated by the licensee.
Biweekly Inspections
The inspectors conducted biweekly inspections in the following areas:
verification review and walkdown of safety-related tagouts in effect;
review of sampling program (e.g., primary and secondary coolant
samples, boric acid tank samples, plant liquid and gaseous samples);
observation of control room shift turnover; review of implementation
of the plant problem identification system; verification of selected
p.9r~tons of containment isolation lineups; and verification that
notites to workers are posted as required by 10 CFR 19.
d.
Other: Inspection Activities
Inspections included areas in the Units 1 and 2 cable vaults, vital
battery rooms, steam safeguards areas, emergency switchgear rooms,
diesel generator rooms, control room, auxiliary building, cable
penetration areas, independent spent fuel storage facility, low level
intake structure, and the safeguards valve pit and pump pit areas.
RCS leak rates were reviewed to ensure that detected or suspected
leakage from the system was recorded, investigated, and evaluated;
3
anq that appropriate actions were taken, if required.
The inspectors
routinely independently calculated RCS leak rates using the NRC
Independent Measurements Leak Rate Program ( RCSLK9).
On a regular
basis RWPs were reviewed, and specific work activities were monitored
to assure they were being conducted per the RWPs.
Selected radiation
protection instruments were periodically checked, and equipment
operability and calibration frequency were verified.
Based on inspections at North Anna, the inspectors examined the
licensee's program for compliance with TS 6.4.K.1. This TS requires
establishment of PM and inspection requirements as part of a leak
reduction program for systems outside containment that would or could
contain highly radioactive fluids during a serious accident or
Licensee personnel indicated that they consider the
Recirculation Spray, Low Head Safety Injection, and High Head Safety
Injection Systems to fall under this requirement.
The 1 icensee
further stated that the following procedures provide a program to
meet the requirements:
SUADM-M-43
ENG-40
PT-16
PT-17.3
PT-18.1
PT-18.7
Material Condition and Housekeeping Inspections
Quantification of External System Leakage
Series Leak Tests Surveillance Procedures~ After
Each Outage
Periodic Test Surveillances for the Systems
Periodic Test for Low Head SI Pumps
Periodic Test for High Head SI Pumps
ASME Pressure Tests and Type A&C Leakage Tests
Although the above documents may cover the required elements of the
program, there is no cohesive program document detailing the required
PMs and visual inspection requirements to meet this TS requirement.
Without a cohesive program document, it is not clear that all systems
needing to be covered by the program are being included.
This matter
wjll be inspected further in future inspections and is identified as
an Inspector Followup Item on licensee's leak reduction program which
is _r~~uired by TS 6.4.K.1 (280,281/90-14-01).
e.
Sustained Control Room and Plant Observations (71715)
On February 14, 1990, the inspectors conducted a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> monitoring
watch of the operations department staff in the performance of their
duties.
The inspection specifically focused on the performance of
control room operators in the following areas:
Operator attentiveness and response to plant parameters.
-
4
)
Planning and control of plant evolutions and testing.
Adherence to procedures.
Communication and documentation of equipment status changes to
other appropriate personnel.
Effective monitoring of operating conditions and initiation of
corrective actions when required.
Effective usage of backup instrumentation and other information
when normal instrumentation is found to be defective or out of
tolerance.
Timely and accurate log keeping which adequately reflects plant
activities and status.
Operator adherence to good operating practices when conducting
plant operations.
During this inspection, the following observations were noted with
regards to operating shift performance:
The inspectors noted that the operations crews were generally
responsive to each annunciated condition and performed the
required responses.
However, some hesitation was noted with
regards to some annunciated conditions which were repetitive and
related to a known problem. Examples of these were the eves HEAT
TRACE TROUBLE and the FIRE DETECTED annunciators. These specific
annunciators were received several times during this inspection
and did not receive the attention that was'afforded others.
A review of selected portions of the plant status log for Unit 1
indicated that some confusion may still exist with regards to
requirements.
The inspectors consider that, although the
operators were knowledgeable on system configuration status,
they did not always follow through with assuring that the
temporary status indication was updated as required.
The inspectors observed the resolution of a problem that
- occurred during the performance of a periodic test on one of the
emergency service water pumps.
This problem resulted in a 50.72
- call to the NRC.
The operational personnel involved during the
- day shift extended their hours to help the on-coming shift
resolve this problem.
The cooperation exhibited by these two
shifts is viewed as a strength.
In summary, the inspectors consider that the operations staff that
performs control room duties are performing these functions in a,
satisfactory manner. Cooperation between shifts was noted as a strong
area.
However, some minor problems regarding strict adherence to
5
requirements and attention to detail were also noted as needing
additional attention.
f.
Physical Security Program Inspections
g.
h.
In the course of monthly activities, the inspectors included a review
of the 1 i censee
I s phys i ca 1 security program.
The performance of
various shifts of the security force was observed in the conduct of
daily activities to include: protected and vital areas access
,controls; searching of personnel, packages and vehicles; badge
issuance and retrieval; escorting of visitors; and patrols and
compensatory posts.
Licensee 10 CFR 50.72 Reports
On March 14, 1990, the licensee made a report in accordance with
10 CFR 50.72 concerning the operability of the emergency service
water pumps.
The B emergency service water pump diesel failed to
start during the running of a periodic test because an air box damper
was determined to be closed.
The closed dampers prevented the supply
of air necessary to run this diesel engine.
A check of the A and C
diesels revealed these same dampers were closed thus rendering the
engines i noperab 1 e.
The air dampers were opened and a 11 three
diesels were tested successfully.
The licensee has appointed a
committee to perform an indepth root cause analysis as to why the
dampers were closed when they should have been open. The licensee has
modified the operating procedure to look for this condition prior to
starting the diesel.
Also currently, the operations personnel who
perform a walkdown of this area once a shift have been instructed to.
assure that these dampers are in the correct position.
Followup on Events
On March 23, 1990, at approximately 2305 hours0.0267 days <br />0.64 hours <br />0.00381 weeks <br />8.770525e-4 months <br />, a* secondary leak on
the discharge piping of Unit 1 low pressure heater drain pump 28
occurred.
The unit was operating at approximately 87% power at the
time due to ongoing correction of problems associated with maintain-
ing required level conditions in the condensate and feedwater system
heaters. Operators took immediate action to secure the affected pump
and isolate the discharge flow path.
However, the water that escaped
from-the break resulted in local wetting of some control components
near the break location in the Unit 1 turbine building.
Unit 1
continued to operate at power during the event.
One of the emergency
ventilation supply fans for the Unit 1 emergency switchgear room was
rendered inoperable by wetting of electrical circuitry.
This fan
problem did not require entry into any TS LCO due to other equipment
being operable.
No other safety-related equipment was affected.
Other wetted electrical components caused a spurious discharge of the
emergency switchgear room fire protection system (Halon) into the
rooms. Two sprinklers in the turbine building also actuated.
Also
affected were security system automatic access control components
6
and/or alarms and the radiation monitor for the service water
discharge from the D component cooling water heat exchanger
(RM-1070).
In addition, personnel who were performing periodic
testing on Unit 2 and a TS required fire watch had to leave the
emergency switchgear room because of the Halon discharge.
The line
involved in the event was a 4-inch, schedule 40, carbon steel pipe.
The size of the piping failure appeared to be approximately 3 inches
long in a fishmouth configuration~
The licensee formed a task team
to review the event.
Initial recommendations of the team included
inspection of the other Unit 1 low pressure heater drain train piping
at the same location and inspection of both Unit 2 trains in the same
locations.
The inspectors monitored the licensee actions through the weekend and
a maintenance team which arrived onsite the following Monday reviewed
the licensee
1s corrective actions associated with piping repair and
their erosion/corrosion monitoring program.
The inspectors concluded
that licensee actions with regards to event response and pipe
evaluations were adequate.
Additional information is available in
NRC Inspection Report 280,281/90-07.
i.
Temporary Waiver of Compliance - Unit 1
On March 15, 1990, at 2008 hours0.0232 days <br />0.558 hours <br />0.00332 weeks <br />7.64044e-4 months <br /> both of the Unit 1 containment
vacuum pumps were determined to be inoperable by the operators.
One
pump is required to be operable by TS 3.15.B when the unit is above
350 degrees or 450 psi g.
The 1 i censee requested a waiver of
compliance of this requirement for 72* hours to affect repairs and
provided justification for this request.
The waiver of compliance ,
was granted by the NRC and was docketed to the licensee by letter
dated March 19, 1990.
The licensee completed repairs to one of the
vacuum pumps and returned the system to service on March 16, 1990 at
1225 hours0.0142 days <br />0.34 hours <br />0.00203 weeks <br />4.661125e-4 months <br />.
Within the areas inspected, no violations was identified.
4.
Maintenance Inspections (62703 & 42700)
During the reporting period, the inspectors reviewed maintenance
activities to assure compliance with the appropriate procedures.
Inspec'tion areas included the following:
Replacement of*a BFD Type Relay
During the performance of periodic test, PT-8.1, relay PRB-XB failed.
The
inspectors review of EWR No.88-385, Installation of Westinghouse Type
NBFD65NR Relays As Replacements for BFD Relays, noted that the BFD relay
failures occur mainly due to heat generated by each continuously energized
relay coil and poor heat dissipation caused by close spacing of the
relays.
These relays are 125 volt de used mainly in the reactor protec-
tion and safeguard circuits.
On March 13, 1990, the inspectors observed
7
the process for replacing one of these relays with the newer two coil
relay.
Initially the station safety committee (SNSOC) review of the
drawings and amended procedure was observed.
The actions of the systems
engineer, QC inspector, and the electricians performing the work were
noted.
The procedure used for replacing the relay was ECM-1801-1,
Westinghouse Type BFD Relay Replacement, dated November 18, 1989. Work
Order No. 38000093038 was used to perform the work.
No discrepancies were
noted.
However, after this relay was replaced, two other relays of this type were
found to have failed.
The inspectors were informed by the licensee that
they were considering replacement of the subject relays during the next
outage.
The inspectors will review ongoing licensee action for these
relays and will open an inspector followup item, on licensee action for
replacement of type BFD relays (280,281/90-14-02).
Within the areas inspected, no violations were identified.
5.
Surveillance Inspections (61726 & 42700)
During the reporting period, the inspectors reviewed various surveillance
activities to assure compliance with the appropriate procedures as
follows:
Test prerequisites were met.
Tests were performed in accordance with approved procedures.
Test procedures appeared to perform their intended function.
Adequate coordination existed among personnel involved in the test.
Test data was properly collected and recorded.
Inspection areas included the following:
a.
Turbine Inlet Valves Unit 1
On March 8, 1990, the inspectors witnessed the performance of
perio9ic test 1-PT-29.1, Turbine Inlet Valve Stroke and Oil Pump
Autostart Tests, dated January 16, 1990.
This test is performed to
ensure proper operation of the turbine stop valves, governor valves,
retiea:t valves, and the interceptor va 1 ves.
The inspectors observed
parts of the test being performed
from the control room.
No
discrepancies were identified.
b.
Heat Tracing For the Hydrogen Analyzer
On. March 9, 1990, the inspectors witnessed the performance of
periodic test 1-PT-27F, Heat Tracing (H2A-GW-104) dated October 16,
1989.
This test is performed to ensure that the heat trace circuits
8
for two independent containment hydrogen analyzers are operable.
The
inspectors observed the energizing of several channels in cabinet No.
HTP-6 and the observation of the time required to reach a specified
minimum temperature.
One channel had a deviation for a light
indication and this was noted on the test results.
No discrepancies
were identified.
Within the areas inspected, no violations were identified.
6.
Surveillance Procedures and Records (61700)
During this inspection period, the inspectors reviewed the licensee's
program for implementation and scheduling of the surveillance requirements
required by the TS.
The licensee's program
consists of a computerized
system to schedule routine surveillance requirements and procedur.al
controls to schedule non-routine surveillance requirements.
Surveillance
requirements to be performed during refueling outages are scheduled in
accordance with procedure ENG-39.3, Refueling Outage Periodic Test
Scheduling. Surveillance requirements
r.equired to be performed during
maintenance outages are scheduled in accordance with procedure ENG-39.2,
Maintenance Outage Periodic Test Scheduling.
The inspector reviewed
ENG-39.3 and 39.2 against the TS requirements and did not identify any
surveillance requirements that were not addressed .
The inspector reviewed SUADM-LR-05, Attachment 1, Summary of Surveillance
Requirements and Test Procedures, against the TS surveillance require-
ments.
The inspectors verified that the surveillance requirements were
identified in the SUADM and that the specified frequency for performance
corresponded to the TS required frequency.
The inspector reviewed PT-17.4
which implements the requirements of TS 4.5C and is required to be
performed every 18 months during shutdown.
This review identified that
the frequency of every refueling outage, specified for PT-17.4, did not
meet the 18-month frequency specified in the TS.
The inspector discussed
this item with the licensee and determined that the licensee was aware
that PT 17.4 was required to be performed every 18 months during shutdown.
The licensee presently has a submittal to the NRC requesting that PT-17.4
be deferred to the next scheduled refueling outage.
The licensee al so
plans to initiate a TS change to modify the required frequency from 18
months during shutdown to refueling.
Based on these discuss ions the
l i cens.ee changed the PT scheduled frequency from refueling to 18 months
until the TS change is received to ensure that the TS requirement as
presently_ state_d is not exceeded.
The inspector verified that this PT
frequency 1naccuracy had not resulted in any TS violations.
The licensee's method for scheduling PTs consists of scheduling the PTs
~aving a constant routine frequency for all departments except Operations.
The Operations Department schedules routine PTs to be performed on the
same day of the month as the previous PT was performed.
The licensee .
schedules PTs on a specified date and identifies an early completion date
and a late completion date.
If the PT is performed between the early and
late date, the surveillance is considered to have been completed within
9
the TS required frequency.
The early date ,is established by subtracting
25 percent of the specified frequency from the scheduled date and the late
date is established by adding 25 percent of the specified frequency to the
scheduled date.
TS 4.0.2 states that surveillance requirements specified
time intervals may be adjusted plus or minus 25 percent to accommodate
normal test schedules.
During review of the licensee's program for
scheduling PTs, the inspector identified that if a PT was performed on the
early date during one scheduled performance and then performed on the late
date during the next scheduled performance, the time interval between
performance would exceed the specified surveillance frequency plus 25
percent (i.e., performing a 31 day surveillance seven days early during
one scheduled performance and then performing the next scheduled
performance seven days late would results in a time interval between
surveillances of 45 days.
The inspector identified the following instances where the surveillance
interval between PTs exceeded the specified frequency:
Periodic Test 1-PT-2.26 was performed on 5/10/89 and again on
6/19/89.
The interval between surveillances was 40 days.
The PT was
performed on 10/12/89 and again on 11/21/89.
The interval between
surveillances was 42 days.
1-PT-2.26 is a monthly test, with monthly
being defined in station administrative procedures as 31 +/- 7 days.
The performance of the PT exceeded the 38 day maximum allowable by
two days and four days, respectively.
Periodic Test 1-PT-18.9* was performed
on 1/17/88 and again on
5/10/88.
The interval between survei 11 ances was 124 days.
The PT
was also performed on 9/30/88 and again on 1/26/89.
The interval
between surveillances was 118 days.
1-PT-18.9 is a quarterly test
with quarterly being defined in station administrative procedures as
92 +/- 23 days.
The performance of the PT exceeded the 115 day maximum
allowable by nine days and three days, respectively.
The inspector questioned the licensee as to whether the present method of
scheduling PTs meets the requirements of TS 4.0.2 in that the surveillance
interval could exceed 1.25 times the specified' frequency.
The licensee's
position is that the scheduling of PT's as presently implemented is
acceptable and meets the requirements of the TS. The licensee stated that
the progrijm for scheduling PTs has been the same since the units were
licensed~~and that this issue had been discussed and reviewed by the NRC in
the past and found acceptable.
However, the licensee was unable to
_ _I;roduce * a*ny documentation to support the statement that the NRC had
approved the present method of scheduling PTs.
Based on*the licensee's
-position that their program meets the requirements of the TS for test
frequency, this issue is identified as an unresolved item (280,
281/90-14-02) pending further NRC review and resolution.
The inspector also reviewed several PTs for conduct and performance.
The
inspector reviewed 2-PT-23.88, Main Station Battery 28 Cell Voltage Check,
that was performed on December 29, 1989.
The inspector determined that
10
the acceptance criteria for Battery Cell 51 had not been satisfied. The
PT requires the voltage of each battery cell to be more than 2.13 volts
for the battery to be considered fully operable. If cell voltage is less
than 2.13 volts but greater than 2.07 volts, the battery is still consid-
ered operable, however, the battery is required to be placed on an
equalizing charge for 135 hours0.00156 days <br />0.0375 hours <br />2.232143e-4 weeks <br />5.13675e-5 months <br /> and noted on the PT Critique Sheet.
The
cell voltage for Cell 51 was recorded as 2.12 volts. The battery was not
placed on an equaliting charge as required nor was the condition noted on
the
PT Criti ql:le Sheet.
The inspector discussed this item with the
Battery System Engineer.
The system engineer had identified the discre-
pancy and evaluated the operability of the battery based on subsequent
performances of 2-PT-23.8B.
The system engineer also stated that Battery
Cell 51 was scheduled to be replaced during the next refueling outage.
After this discussion, a plant deficiency report was initiated to document
that the requirements of 2-PT-23.8B had not been satisfied on 12/29/89
when it was performed.
TS 6.4.D requires that detailed written procedures with appropriate
check-off lists involving the testing of instruments, components, and
systems with regard to the ,nuclear safety of the station shall be
followed.
The fail_ure to adequately implement the requirements of
2-PT-23.8B conducted 12/29/89 is identified as a violation of TS 6.4.D,
(280,281/90-14-03).
On March 20, 1990, the inspectors observed the licensee performing PT
25.3C, Emergency Service Water Pump (1-SW-P-lC) dated October 10, 1989.
The inspectors observed the running of the diesel pump and noted some of
the parameters being recorded i.e., temperature, pressure, amperage, etc.
The inspectors noted one of the craftsmen taking an electrical reading .
with a digital ammeter and observed that the readings were fluctuating
between 0.2 amperes and 1.4 amperes.
These readings were being taken to
satisfy step 5.10 of the procedure which required the use of an ammeter on
the positive lead of the alternator circuit*to measure the current.
A
value of 0.5 amps plus or minus (no value recorded) was recorded on the
procedure and the* test was accepted as satisfactory.
When the test was
questioned by the inspectors, the licensee voided it and reran the test
the next day with the system engineer present.
The system engineer
observed that the electrician was taking the readings on small cables to
the battery charger.
These cable currents should have essentially been
zero.
This was the wrong location specified for taking. the readings in
step 5.10 of the procedure.
The fluctuating current readings observed
during the first test by the inspectors was due to the changing distance
(causing -*a:. charige in the interference) between adjacent battery cables.
The failure of the electrician to follow the procedure for taking the
readings is a second example of violation 280,281/90-14-03.
The inspectors consider that the two examples of failure to follow
procedure by craft personnel are not related to a programmatic problem in
the surveillance area.
However, they raise concerns about the level of
reviews that are conducted by cognizant supervision who approve the
periodic test results on the critique page of the completed surveillances .
11
The inspectors reviewed the following periodic tests to verify that the
Technical Specification surveillance requirements were specified in the
procedures.
PT-24.SA, Reactor Coolant Pump Heat Detectors
PT-24.SC, Smoke and Thermal Detectors - Robertshaw System
PT-24.33, Fire Protection - Valve Position Surveillance
PT-17.3, Containment Outside Recirculation Spray Pumps
PT-18.7, Charging Pump Operability and Performance Test
PT-23.7A, Batteries Weekly Pilot Cell Check (2A, 28, EDG2, Black
Battery)
PT-2.26, Reactor Coolant System Pressure (P-1-458)
PT-2.26, Reactor Coolant System Pressure (P-1-403)
PT-38.41,,Main Steam System
PT-38.1, Primary Coolant Chemistry
PT-2.6, Steam Line Pressure (P-2-475)
PT-36, Instrument Surveillance
PT-24.12, Fire Pump Flow Rate Test
PT-24.1, Fire Protection Water Pump
During review of PT-2.26, the inspector questioned the adequacy of the
periodic test.
TS 4.1.B.1.a requires that each PORV be demonstrated
operable at least once per 31 days by performance of a channel functional
test, excluding valve operation. TS table 4.1.2A requires that the Reactor
Vessel Overpressure Mitigating System be functionally and setpoint tested
prior to decreasing RCS temperature below_350 degrees F and monthly while
the RCS is less than 350 degrees F and the reactor vessel head is bolted.
PT 2.26 performs a functional test of the Reactor Coolant Narrow Range
Overpressure Mitigating System and a quarterly stroke time test of the ,
PORV block valves.
The PT did not perform a functional test of the PORV
circuits for normal operating pressure conditions.
Based on the
inspectors review of TS 4.1.B.1.a and TS table 4.1-2A the inspector
questioned the licensee on March 9, 1990, as to whether the requirements
of TS 4.1.B.1.a was being adequately implemented.
The licensee reviewed
the concern and concluded that the TS survei 11 ance was not being
adequately implemented.
The licensee entered the applicable action -
statement for inoperable PORVs and discussions were held between the
licensee,- Region II, and NRR.
Based on the fact that this issue is
currently under NRR review for another licensee, a decision was made not
to tak.e ~PY enforcement action at this present time.
The licensee agreed
to test '{fiis function of the PORV circuitry based on the Emergency
TechnicaJ_ Speci_fication change for pressurizer safety valves, issued on
November 16, 1989.
This TS required at least one PORV be operable. The
licensee completed
testing of the PORV high setpoint on both units prior
to midnight on March 9, 1990.
The licensee plans to continue testing of
the PORV high setpoint monthly as long as PORV operability is necessary to
support the pressurizer safety valve interim TS.
Within the areas inspected, one violation was identified.
12
7.
Action on Previous Inspection Findings (92701, 92702)
Summary of Closeout Actions for Enforcement Letter Issued on May 18, 1989.
The following is a listing of all violations that were identified in the
subject enforcement 1 etter a 1 ong with identification of inspection
activity that closed out the licensee's corrective action for each item:
VIOLATION# AND DESCRIPTION
I.A.1 - Inadequate safety evaluation for
cavity seal design modification resulting
in violation of 10 CFR 50.59.
I.A.2 - Inadequate evaluation of true
nature of the cavity seal failure
resulting in violation of 10 CFR 50, Appendix B, Criterion XVI.
I.B.1 - Inadequate procedures for the
operation of air and backup nitrogen systems
to the cavity seal inflatable portion.
I.B.2 - Inadequate abnormal operating procedure
for a rapid loss of cavity seal level and
failure to assure actions developed in
response IE Bulletin 84-03 were maintained.
I.B.3 - Inadequate procedures for
recovery of reactor cavity level
after cavity seal event.
II.A - Failure to identify a significant
condition adverse to quality in a timely
manner with regards to potential gas
binding of high head SI pumps.
II.B - Failure to conduct a safety
evaluatiort of a reduction in control
room clifl'"fer which was identified by
a devia~i~n rep~rt in 1987
II.C -* Failure to identify a significant
condition adverse to quality in a timely
manner with regards to operability of the
control room and emergency switchgear
room ventilation system *
REPORT CLOSEOUT#
280,281/88-34
280,281/88-41
280,281/88-45
280,281/88-47
Item closeout is
discussed at the end
of this listing
280,281/88-38
280,281/88-38
280,281/88-38
280,281/89-20
280,281/89-28
280,281/90-05
280,281/90-05
280 ,281/89-17
?80,281/90-05
13
II.D - Failure to identify a significant
condition adverse to quality in a timely
manner with regards to the use of nonqualified
parts in a safety-related applications.
II.E - Failure to identify a significant
condition adverse to quality in a timely
manner with regards to wetting of safety-
related components for long periods of time.
II.F - Failure to document corrective
actions for QC inspection identified
deficiencies.
II.G - Failure to take adequate
corrective actions for repeat QA
audit findings.
III.A - Failure to translate the
design basis into specifications,
drawings, and/or procedures for the
RSHXs with regards to intake canal level.
III.B - Failure to translate the
design basis into specifications,
drawings, and/or procedures with regards
to effects of temperature ranges on
emergency pump house equipment.
III.C - Failure to translate the design
basis into specifications, drawings and/or
procedures with regards to the effects of
added loads on the 125 VDC Vital Bus
III.D - Failure to translate the
design basis into specifications,
drawings, and/or procedures with regards
to the effects of minimum wall thickness
on CCWHX l~CC-E-1B.
IV - Violation of TS 3.14.A.4 with
regards *to~haviTig at least two ESW pumps
operable prior to taking the reactor(s)
critical.
V.A - Failure to test RS system
service water valves as required by
the ASME code.
280,281/90-05
280,281/90-05
280,281/89-36
280,281/89-36
280,281/89-36
280,281/89-36
280,281/89-36
280,281/89-36
280,281/89-36
280,281/89-36
V.B - Failure to provide adequate
procedures for ESW pump battery
14
testing and for checking of disc to
seal clearances on SW check valves.
V.C - Failure to provide adequate
procedure for proper torquing of safety-
related system closure fasteners.
V.D. - Failure to establish measures for
identification and control of materials
with regards to material control tags
being missing from work order packages.
V. E - Failure to properly test a safety-
related pressure control valve after
conducting maintenance on the valve.
280,281/89-36
280,281/89-36
This issue was
addressed in report
280, 281/89-36. The
issue remains open
pending resolution
of items identified
in that report.
280,281/89-36
-
-
--
~~~~
(Closed) Item I.A.2 - Inadequate evaluation of true nature of the cavity
seal failure resulting in violation of 10 CFR 50, Appendix B,
Criterion XVI.
The licensee actions with regards to this issue included
revision of the administrative procedure associated with identification
and review of conditions adverse to quality (Station Deviation Reports).
The inspectors have reviewed *the licensee's latest revision to administra-
tive procedure
SUADM-LR-13,
11Station Deviation Reports
11
,
dated
December 29, 1989.
This procedure establishes a deviation report review*
process including classification, multidiscipline review, cause determina-
tion evaluation, and root cause evaluation process. This process has been
reviewed by several different NRC inspectors and is considered adequate.
This item is closed.
8.
Exit Interview
The inspection scope and results were summarized on April 4, 1990, with
those individuals identified by an asterisk in paragraph 1.
The following
summary of inspection activity was discussed by the inspectors during this
exit._
An inspec.:tor fqllowup item (Paragraph 3.d) was identified on licensee's
leak reduction program which is required by TS 6.4.K.1 (280,281/90-14-0l).
During a review of operator performance in the control room, it was noted
that the operations staff that performs control room duties are performing
these functions in a satisfactory manner.
Cooperation between shifts was
noted as a strong area.
However, some minor problems regarding strict
adherence to requirements and attention to detail (paragraph 3.e) were
also noted as needing additional attention.
15
An inspector followup item (paragraph 4) was identified for followup on
licensee action for replacement of type BFD relays (280,281/90-14-02).
During this inspection period, one violation with two examples was
identified (paragraph 6) for failure to follow procedure during testing of
components, and systems as required by TS 6.4.D (280,281/90-14-04).
The
inspectors consider that the two examples of failure to follow procedure
by craft personnel are not related to a programmatic problem in the
surveillance area.
However they raise concerns about the level of reviews
that are conducted by cognizant supervision who approve the periodic test
results on the critique page of the completed surveillances.
The
inspectors consider that these reviews should identify problems similar to
the ones cited in the violation and consider that additional management
attention is necessary in this area.
In addition, an unresolved item was
identified in the same inspection area with regards to required surveil-
lance testing frequency (280, 281/90-14-03) .
. 9.
Index Of Acroynms And Initial isms
CCWHX
CFR
eves
DR
LER
LCO
NRC
OP
SNSOC
TS
URI*
Component Cooling Water Heat Exchanger
Code Of Federal Regulations
Chemical And Volume Control System
Deviation Report
Engineered Safety Feature
Engineering Work Request
Emergency Operating Procedures
Final Safety Analysis Report
Heat Exchanger
Licensee Event Report
Limiting Conditions Of Operation
Nuclear Regulatory Commission
Operating Procedure
Preventative Maintenance
Pressure Operator Relief Valve
Pounds Per Square Inch Gauge
Periodic Test
Quality Assurance
Quality Control
Regulatory Guides
.Reactor Operator
Recirculation Spray Heat Exchanger
Radiation Work Permit
Station Nuclear Safety and Operating Committee
Senior Reactor Operator
Technical Specifications
Technical Suppory Center
Updated Final Safety Analysis Report
Unresolved Item