ML18152A399
| ML18152A399 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 09/09/1994 |
| From: | Belisle G, Branch M, David Kern, Tingen S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18152A400 | List: |
| References | |
| 50-280-94-24, 50-281-94-24, NUDOCS 9409270088 | |
| Download: ML18152A399 (15) | |
See also: IR 05000280/1994024
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
Report Nos.:
101 MARIETIA STREET, N.W., SUITE 2900
ATLANTA, GEORGIA 30323-0199
50-280/94-24 and 50-281/94-24
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:
August 7 through September 2, 1994
Inspectors: /..u..; ~
~
M. W. Branc,Seniorlfusident Inspector
rW -<ii
fu.
S. G. Tingen~nt Inspector
D. M. Kern, Resident Inspector
Accompanying Personnel:* D. M. Tamai, Intern
Scope:.
D. R. Taylor, Resident
- Inspector North Anna
. B 1 s e, Chi e
Reacto
Projects Section 2A
Division of Reactor Projects
SUMMARY
?/!' /9<1
Date -Signed
9/FP'f
DaeSigned
4fo~1
~
This routine resident inspection was conducted on site in the areas of ~lant
status, operational safety verification, maintenance and surveillance
inspections, Licensee Event Report fol.lowup, and action on previous inspection
items.
Inspections of backshift and weekend activities were conducted on
August 11, 18 and 26 and September 2.
~~9270088 940912
Q
ADOCK 05000280
2
Results:
Plant Operations functional area
The operator's prompt response to the August 20 Unit 2 C steam generator main
feed regulating valve closure prevented an automatic reactor trip
(paragraph 3.2).
Maintenance functional area
The licensee responded to a turbine driven auxiliary feedwater pump trip with
the appropriate amount of management attention and reasonable corrective
actions (paragraph 4.1).
The corrective action audit performed by the licensee identified an area that
warranted improvement.
The audit identified that root cause evaluations were
not always effective in preventing equipment problems from recurring
(paragraph 4.2).
An apparent violation with two parts was identified for failure to promptly
identify and implement effective corrective actions' for conditions adverse to
quality. The first part of the apparent violation involved not promptly
sampling both the auxiliary ventilation exhaust filter system trains following
a chemical release that occurred in the Unit 2 containment on June 16, 1994.
The second part of the apparent violation involved not promptly correcting a
condition adverse to quality when an engineering review identified that
certain circuits were not fully being functionally tested on a monthly basis
(paragraphs 6.1 and 6.2).
1.
REPORT DETAILS
Persons Contacted
1.1
Licensee Employees
- W. Benthall, Supervisor, Licensing
- H. Blake, Jr., Superintendent of Nuclear Site Services
R. Blount, Superintendent of Maintenance
- D. Boone, Quality Assurance
- D. Christian, Station Manager
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
M. Kansler, Station Manager
C. Luffman, Superintendent, Security
- J. McCarthy, Assistant Station Manager
- D. Miller, Radiation Protection
- A. Price, Assistant Station Manager
- R. Saunders, Vice President, Nuclear Operations
- K. Sloane, Operations
E. Smith, Site Quality Assurance Manager
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
Management Changes
The following personnel changes were effective September 1:
W. Wigley, Manager, Nuclear Operations Support - Corporate, was
reassigned to a special project.
M. Kansler, Surry Station
Manager, replaced W. Wigley.
D.* Christian, Assistant Station
Manager, replaced M. Kansler. J. McCarthy, Superintendent of
Operations, replaced D. Christian. S. Sarver, Quality Assurance
Supervisor, Plant Operations, replaced J. McCarthy.
2
1.3
NRC Personnel
- M. Branch, Senior Resident Inspector
- D. Kern, Resident Inspector
- D. Tamai, Intern
D. Taylor, Resident Inspector, North Anna
- S. Tingen, Resident Inspector
- D. Verrelli, Branch Chief, Region II
- Attended Exit Interview
Acronyms and initialisms used throughout this report are listed in
the last paragraph.
2.
Plant Status
Units 1 and 2 operated at power for the entire inspection period.
Condenser water box fouling from hydroids and eels increased during this
period necessitating water box cleaning and power reduction.
3.
Operational Safety Verification (71707, 42700)
The inspectors conducted frequent tours of the control room to verify
proper staffing, operator attentiveness and adherence to approved.
procedures.
The inspectors attended plant status meetings and reviewed
operator logs on a daily basis to verify operational safety and
compliance with TSs and to maintain overall facility operational
awareness.
Instrumentation and ECCS lineups were periodically reviewed
from control room indication to assess operability. Frequent plant
tours were conducted to observe equipment status, fire protection
programs, radiological work practices, plant security programs and
housekeeping.
Deviation reports were reviewed to assure that potential
safety concerns were properly addressed and reported.
3.1
Biweekly ESF Inspections
3.1.1 EDG Fuel Oil System
The inspectors walked down the EOG fuel oil transfer system
located in the EOG rooms and diesel fuel oil transfer pump
buildings. Correct breaker position and valve alignment
were verified. Completed procedures for monthly fuel oil
system tests for 1994 were reviewed for completeness and
adequacy.
Equipment appeared to be in good overall
condition and housekeeping was acceptable.
3.1.2 Control Room Bottled Air System
The inspectors walked down the control room bottled air
system located in MER 3, Unit 1 cable vault and control room
stair well. Correct valve alignment, PCV regulator pressure
and bottled air pressure were verified.
Equipment was in
good overall condition and housekeeping was adequate.
3
3.2
Operator Response to Unit 2 C MFRV Closure
On August 20, the Unit 2 C MFRV failed closed. The MFRV's
controller was in the automatic mode of control when the valve
failed shut. Steam flow/feed flow mismatch and SG level error
annunciator alarms and closed position indication on the control
board for the C MFRV alerted the operator that an abnormal
condition existed. The operator immediately analyzed the
condition and placed the MFRV controller in manual and opened the
MFRV.
The lowest level noted in the C SG was 22%.
Failure of the
steam flow/feed flow signal comparator was determined to have
caused the MFRV to close. The signal comparator was replaced and
the C MFRV controller was returned to the automatic mode of
operation. The inspectors concluded that the operator's prompt
response to this event prevented the unit from automatically
tripping.
Within the areas inspected, no violations or deviations were identified.
4.
Maintenance and Surveillance Inspections (62703, 61726, 40500)
During the reporting period, the inspectors reviewed the following
maintenance and surveillance activities to assure compliance with the*
appropriate procedures.
4.1
TDAFW Pump Turbine Overspee~ Trip
On August 22, the Unit 2 TDAFW pump tripped on overspeed during
monthly surveillance test, 2-0PT-FW-003, Turbine Driven AFW
2-FW-P-2, revision 3.
The turbine operated for approximately
13 seconds and tripped on overspeed.
WO 297664-01 was initiated
to investigate/repair the governor valve.
The valve bonnet, stem
and packing were replaced.
The cause of the trip was determined
to be corrosion buildup on the stem in the area of the stuffing
box adjacent to the valve disc.
As immediate corrective action, the licensee initiated a new
surveillance for both units. Procedure O-MPM-1403-03, Terry
Turbine Governor Valve Stem Movement Check, revision 0, provided
instructions to manually exercise the governor valve stem in each
unit on a weekly interval. The procedure required the governor
power cylinder shaft pin and nut to be disconnected, and
measurements taken of the initial movement (breakaway) torque,
full stroke torque and full stroke length. These measurements
were followed by additional strokes to ensure free stem movement
and by linkage reconnection. The inspectors witnessed this
surveillance test performance on August 31.
Unit 1 tested
satisfactory.
On Unit 2, some governor valve stem binding was
exhibited.
Five pounds of torque greater than the breakaway
torque was required during stem travel. The licensee determined
that the governor had sufficient margin to overcome the binding.
However, the licensee reduced the time interval for the next
4.2
4
surveillance performance on Unit 2.
The next surveillance was
performed September 2 in lieu of waiting an entire week.
The
inspectors witnessed the surveillance on September 2.
Some
corrosion was evident; however, stem binding was not exhibited.
The inspectors reviewed the safety evaluation for this new
surveillance and attended the SNSOC meeting that approved it. The
SNSOC members also determined that a station JCO was needed to
adequately track the corrective action progress for governor valve
stem binding.
The surveillance procedure was effective for 30
days. After 30 days, SNSOC will review the effectiveness of the
corrective action.
As part of the longer term corrective action, the licensee ordered
chrome plated valve stems.
The chromed plated stems do not
exhibit the same corrosion as the nitrated stainless steel stems
which are currently utilized. Previously, the licensee had not
considered this as appropriate corrective action because these
stems are subject to blistering and peeling.
However, the
licensee determined that the chrome plated stems will provide a
greater assurance of pump availability than the nitrated stainless
steel stems are currently providing.
The licensee has experienced previous TDAFW pump trips. The
corrective actions are addressed in NRC Inspection Report Nos.
50-280, 281/94-17, 93-26 and 93-07.
The licensee's task team is
continuing to evaluate the trips to determine the root cause.
Differences have been identified in manufacturing the valve parts.
However, the consequences of these differences have not be
determined.
Due to recurring TDAFW pump trips, the licensee
performed a Substantial Safety Hazard Evaluation in accordance
with VPAP 2802, Notifications and Reports, revision 4.
As a
result of the evaluation, the licensee determined that a 10 CFR 21
report was necessary due to the recent TDAFW pump overspeed trips
that were attributed to corrosion in the governor valve which
caused the stem to bind.
The inspectors concluded the licensee was giving the issue the
appropriate amount of management attention and that corrective
.actions were reasonable.
The inspectors will continue to monitor
the licensee's long term and short term corrective actions.
QA Corrective Action Audit Review
The inspectors reviewed QA Audit 93-15, Corrective Action, dated
February 2, 1994.
This audit satisfied TS requirement
6.1.C.2.h.3. Areas inspected during the audit were the corrective
action associated with work requests, DRs, human performance,
operating experience, RCEs, nonconformance reports, potential
problem reports, LERs, JCOs, 10 CFR 21 reports and records.
The
audit concluded that with the exception of RCEs, the corrective
action program was effectively implemented.
5
The audit concluded that the RCE program was not always effective
in preventing recurring equipment problems.
Control Rod Urgent
Failures, Kaman Radiation Monitors, Appendix R emergency lighting
and !RPI were identified as examples of ineffective corrective
actions. The following criteria were utilized in determining if
corrective actions were effective:
The deficiency was two or more years old.
The deficiency had been identified and corrected three or
more times.
The deficiency was significant based on TSs or UFSAR
requirements and/or the high number of occurrences.
Corrective actions had been completed and closed but had not
prevented recurrence.
As corrective ~ction, the licensee generated a Corporate Level 1
assignment to evaluate current methods for identifying recurring
problems. Additionally, a review of the existing RCE program and
self-assessment of the station corrective action program was
performed .
The inspectors concluded that QA corrective action audit was
effective in identifying an area that needed improvement and was
identified as a strength.
Within.the areas inspected, no violations or deviations were identified.
5.
Licensee Event Report Followup (92700)
The inspectors reviewed the LER listed below and evaluated the adequacy
of the corrective action.
The inspectors' review also included followup
of the licensee's corrective action implementation.
(Closed) LER 50-281/92-09, Engineering Safety Feature (ESF) Actuation,
Auxiliary Feedwater MOVs Receive an Open Signal.
The details of this event were described in NRC Inspection Report Nos.
50-280, 281/92-17.
Because the event involved several equipment
problems and human performance errors, the licensee initiated a formal
root cause evaluation.
The results of RCE 92-06 and proposed corrective
action were reviewed and found to be adequate in NRC Inspection Report
50-280, 281/92-25.
The inspectors reviewed implementation of the RCE proposed corrective
actions.
The inspectors verified that revisions and training related to
several non-safety related procedures associated with the mechanical
chillers and power supplies were complete.
In addition, the chiller's
operating logic was verified and adequately documented by the licensee.
6
The inspectors concluded that actions recommended by the RCE were
satisfactorily implemented.
Within the areas inspected, no violations or deviations were identified.
6.
Action on Previous Inspection Items (92702)
6.1
(Closed) URI 50-280, 281/94-21-01, Time Constraints For
Sampling/Testing AVEF System Following Exposure To Chemicals
6.1.1
6.1.2
The Event
On June 16, 1994, a hydrazine concentration of 6 ppm
and an ammonia concentration of 30 ppm were detected
in the Unit 2 containment. These fumes were
identified after a manway was removed from the A SG
which had just completed chemical cleaning. Trains A
and B of the AVEF system were operated in order to
remove the hydrazine and ammonia fumes from
containment.
Containment was evacuated as a
precaution.
The supplier of the charcoal utilized in
the AVEF system was contacted by the licensee to
evaluate potential effects of these chemicals on the
charcoal.
The charcoal supplier informed the licensee
that exposing charcoal to the measured concentration
of fumes should not be not detrimental to the
charcoal.
AVEF Surveillance Performed
On June 28, 1994, charcoal samples were obtained from
the train A AVEF system and sent to a contractor for
analysis. This sample was obtained to meet the
TS 4.12.A.8.d requirements.
TS 4.12.A.8.d requires
that laboratory analysis on charcoal samples be
performed following painting, fire, or chemical
release in an area communicating with the AVEF system.
On July 15, 1994, the licensee was notified that the
sample's methyl iodide removal efficiency was 93.43%.
The minimum acceptable methyl iodine removal
efficiency specified in TS 4.12.B.4 was 96%.
Train A
of the AVEF system was declared inoperable on that
same day.
The charcoal was replaced and DOP and
halogenated hydrocarbon leakage tests were performed
as post-maintenance testing prior to returning the
train to service on July 20.
On July 28, 1994, charcoal samples were obtained from
the train B AVEF system and sent to a contractor for
analysis.
On August 4, 1994, the licensee was
notified that the sample's methyl iodide removal
efficiency was 90.7%.
This was below minimum TS
6.1.3
7
requirements. Train B of the AVEF system was declared
inoperable on that same day.
The charcoal was
replaced and DOP and halogenated hydrocarbon leakage
tests were performed prior to returning the train to
service on August 5.
Event Evaluation and AVEF Testing Performed
Without extensive testing of the charcoal removed from
the AVEF trains, the licensee was unable to positively
identify what caused the AVEF system charcoal to
degrade.
However, the licensee did conclude that the
cause was associated with the chemical release event
in the Unit 2 containment that occurred on June 16.
As previously stated, both trains of the AVEF system
were aligned to take a suction from containment in
order to remove the ammonia and hydrazine fumes.
At
that time the manway had just been removed from the
secondary side of the A SG and the manway from the C
SG had been removed several days earlier. Operating
both trains of the AVEF system decreased pressure in
the containment which allowed fumes from residual SGCC
chemicals to be exhausted from the SGs via the removed
manway covers into containment and then discharged
from the containment to the atmosphere via the AVEF
system.
Based on conversation with the charcoal
supplier, the licensee concluded that the noted
concentrations of ammonia and hydrazine should not
have damaged the charcoal in the AVEF system but that
other residual SGCC chemical may have degraded the
charcoal. The licensee determined that if fumes from
SG cleaning chemical EDTA were drawn through the AVEF
system, the fumes could have degraded the charcoal.
TS 4.12.A.8.d required that laboratory analysis on
charcoal samples be performed following painting,
fire, or chemical release in an area communicating
with the AVEF system.
After the A train AVEF system
charcoal sample results were identified as not meeting
minimum TS acceptance criteria, the inspectors
questioned the licensee what time constraints were
associated with TS 4.12.A.8.d.
The inspectors were
informed that there were no time constraints specified
in TSs and
II fo 11 owing
II meant when pr act i cal .
The inspectors also noted that the A train was sampled
and returned to service before the B train was
sampled.
The AVEF system is common to both units and
is required by TSs to be operational prior to RCS
temperature and pressure exceeding 350 degrees F and
450 psig respectively in either unit.
TSs allow one
train of the AVEF system to be inoperable for a period
8
not to exceed seven days.
Once the A train was
decl.ared inoperable on July 15, sampling of the B
train would have required the B train to also be
declared inoperable.
TSs do not recognize both trains
of the AVEF system being inoperable and entry into TS 3.0.1 would have been required.
The licensee's policy
is not to enter TS 3.0.l on a voluntary basis. The
inspectors determined that the B train sample was not
promptly taken after the A train was returned to
service.
TS 4.0.4 specifies that entry into an operational
condition shall not be made unless the surveillance
requirements associated with a LCO have been performed
within the stated surveillance interval or as
otherwise specified. The inspectors noted that on
June 23, Unit 2 entered the mode where the AVEF system
was required to be operable.
The inspectors
questioned the licensee why a mode change was made in
Unit 2 prior to sampling/testing the AVEF system in
accordance with TSs 4.12.
The inspectors were
informed that the AVEF system was operable to support
operation of Unit 1 and therefore operable to support
Unit 2 operations as well .
The inspectors reviewed the licensee's basis for
determining sampling priorities for the charcoal
trains. The A train of the AVEF system was sampled
and returned to service prior to sampling the B train.
Station policy is to test one train at a time. Also,
the A train operated for most the time (approximately
484 hours0.0056 days <br />0.134 hours <br />8.002645e-4 weeks <br />1.84162e-4 months <br />) during the Unit 2 SGCC outage.
The
operating time on the B train during the outage was
significantly less (approximately 117 hours0.00135 days <br />0.0325 hours <br />1.934524e-4 weeks <br />4.45185e-5 months <br />).
On
June 16, the day of the chemical release in Unit 2 the
A train of the AVEF system operated approximately 23
hours and the B train operated for approximately 8
hours.
The licensee thought that if there was a
problem, it would show up on the A train because it
was operated the most during the outage and on the day
of the chemical release.
The inspectors reviewed previous test results for the
charcoal trains to determine if there were any trends
that would indicate chronic charcoal degradation.
TSs
requires that the AVEF system charcoal be sampled
every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of operation.
The results of the last
charcoal samples obtained to meet the 720 hour0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br />
sampling requirement were reviewed.
The A train was
sampled on February 2, 1994.
The sample results
indicated a methyl iodide removal efficiency of
99.73%.
The A train had operated for approximately
6.1.4
9
657 hours0.0076 days <br />0.183 hours <br />0.00109 weeks <br />2.499885e-4 months <br /> between February 2 and June 28, 1994.
The
B train was sampled on March 6, 1994.
The results of
this sample indicated a methyl iodide removal
efficiency of 96.57%.
The B train had operated for
approximately 360 hours0.00417 days <br />0.1 hours <br />5.952381e-4 weeks <br />1.3698e-4 months <br /> between March 6 and July 28,
1994.
The inspectors concluded that the A train had
operated more than the B train but noted that the
initial methyl iodide removal efficiencies obtained
from the previous samples were lower in the B train
than the A train. A lower initial methyl iodide
removal efficiency in the B train may not have been
considered by the licensee when determining which
train should be sampled first following the chemical
release.
Following the chemical release in the Unit 2 *
containment on June 16, it was 12 days before the
A train AVEF system charcoal was sampled and 42 days
before the B train charcoal was sampled.
The
inspectors concluded that the amount of time taken to
obtain these samples was excessive in that the TS 4.12.A.8.d requirement to sample following a chemical
release was not expedited.
As a result, Unit 1 was
operated from June 16 through June 28 with the A tr~in
and through July 28 with the B train AVEF system
degraded.
Unit 2 operated from June 23 through
June 28 with the A train and July 28 with the B train
degraded.
Safety Consequence of the Event
Although the AVEF system charcoal did not meet minimum
TS methyl iodide removal efficiency acceptance
criteria and was therefore degraded, the licensee's
analysis concluded that the AVEF system was still
capable of mitigating the consequences of the design
basis accidents.
The inspectors reviewed engineering analysis
NAF-94063, Explanation of Filter Efficiency Used in
FHA and LOCA Analysis Surry Power Station, Units 1
and 2, revision 0, which the licensee provided to
address the inspectors' concerns as to whether the
function of the system was compromised.
This analysis
addressed the radiological consequences of several
accident scenarios which provide the design basis for
the AVEF system.
The LOCA scenario resulted in the
most severe off-site radiological consequences.
However, station accident analysis*do not credit the
AVEF system for methyl iodide removal following a
LOCA.
The most limiting scenario for which the AVEF
system is credited for methyl iodide removal is the FHA.
6.1.5
10
Engineering analysis NAF-94063 assumed filter removal
efficiencies of 70% for methyl iodide and 90% for
elemental iodide following a FHA.
The inspectors
independently confirmed that the assumptions used in
NAF-94063 were consistent with those specified in NRC
Regulatory Guide 1.25, Assumptions Used for Evaluating
the Potential Radiological Consequence of a FHA in the
Fuel Handling and Storage Facility for Boiling and
Pressurized Water Reactors.
The licensee evaluation
concluded, that based on 30 days of AVEF system
operation following a FHA, both off-site and on-site
exposures would remain within 10 CFR 100 regulatory
limits.
The results of the A and B train AVEF charcoal filter
efficiency analysis, measured under laboratory test
conditions, were above the 70% value used in
NAF-94063.
However, the inspectors observed that TS 4.12 states that the laboratory test conditions are
less severe than the design accident environment.
The
TS further state that 96% methyl iodide removal
efficiency provides assurance that the AVEF will
function sufficiently under accident conditions to
meet regulatory requirements for protection of the
public.
The inspectors questioned whether the
measured AVEF charcoal filter efficiencies of 90% and
93% were sufficient to assure design requirments.
Engineering analysis NAF-94063 did not specifically
.correlate laboratory test conditions to the
environment present following a design accident.
The
inspectors expressed concern that the AVEF system was
degraded in that the charcoal filters did not meet TS
required performance criteria. The licensee
maintained that the AVEF system remained functional
and indicated that further technical assessment of
this issue was in progress at the end of this report
period.
Regulatory Issues
In summary, samples were not promptly taken after a
chemical release; when sampling was performed, it was
sequential, not simultaneously; and, the B train was
not sampled promptly after the A train's sample
results were known nor after the A train was returned
to service.
10 CFR 50, Appendix B, Criterion XVI, Corrective
Action, requires that measures be established to
assure that conditions adverse to quality are promptly
identify and implement corrective action following the
chemical release that damaged the AVEF system charcoal
11
on June 16, 1994, was identified as part 1 to Apparent
Violation 50-280, 281/94-24-01, Failure to Identify
and Promptly Correct Conditions Adverse to Quality.
6.2
(Closed) URI 50-280, 281/94-21-02, TS Monthly Testing That
Requires Installation of Jumpers or Disconnection of Leads.
During the licensee's review of TS surveillance compliance,
engineering identified three instances where reactor
protection/ESF circuits were not being fully tested on a monthly
basis with the unit at power because testing required the use of
jumpers or disconnecting leads to complete.
The licensee
concluded that the following circuits were not designed to test at
power and therefore not required to be tested monthly:
Between 10% and 35% power, low RCS flow on two out of three
loops automatically opens the reactor trip breakers.
TS
Table 4.1-1, Minimum Frequencies For Check, Calibrations And
Test Of Instrument Channels, Items 5 and 26 require that .
this circuit be functionally tested on a monthly interval.
The review identified that the circuit was being tested on a
RFO interval but the entire circuit was not tested monthly.
The inspectors noted that without modification, lifting of
leads/installation of jumpers would be required to
completely test this circuit at power.
Low-low level on two out of three SGs automatically start
the respective unit's TDAFW pump.
TS Table 4.1-1, Item
32.a, requires that this circuit be functionally tested on a
monthly interval. The review identified that the circuit
was being tested ~n a RFO interval but not monthly.
The
inspectors noted that without modification, testing at power
. would render two of the three AFW pumps inoperable. This
condition would require entry into TS 3.0.1.
Undervoltage on two out of the three RCP buses automatically
starts the respective unit's TDAFW pump.
TS Table 4.1-1,
Item 32.b, requires that this circuit be functionally tested
on a monthly interval. The review identified that the
circuit was being tested on a RFO interval but not monthly.
The inspectors noted that without modification, testing this
circuit would render the TDAFW pump inoperable during the
test.
The licensee concluded that a clarification to TSs would be
requested in the future and that a TS change was not immediately
required.
The licensee did implement changes to the surveillance
intervals for the above circuits as a result of the review.
In
addition to testing the circuits during RFOs, the circuits are
required to be tested prior to starting a unit up if the circuit
was not tested during the previous 30 days.
The inspectors
discussed the requirements of TS Table 4.1-1, Items 5, 26 and 32.a
1---
!
12
and b with the cognizant NRC staff and concluded that TSs required
each of the above circuits to be tested on a monthly interval.
Through a review of the circuits in question the inspectors noted
that it was not practical to test these circuits monthly at power
and that this issue had minor safet1 significance.
10 CFR 50, Appendix B, Criterion XVI, Corrective Action, requires
that measures be established to assure that conditions adverse to
quality such as deviations and nonconformances are promptly
identified and corrected. The failure to promptly correct a
condition adverse to quality when an engineering review identified
that certain circuits were not fully being functionally tested on
a monthly basis was identified as part 2 to Apparent Violation
50-280, 281/94-24-01, Failure to Identify and Promptly Correct
Conditions Adverse to Quality.
Within the areas inspected, one apparent violation with two parts was
identified.
7.
Exit Interview
The inspection scope and findings were summarized on September 2, 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
50-280, 281/94-24-01
URI 50-280, 281/94-21-01
URI 50-280, 281/94-21-02
LER 50-281/92-09
Status
Open
Closed
Closed
Closed
Description/(Paraqraph No.)
Failure to Identify and
Promptly Correct Conditions
Adverse to Quality
(paragraphs 6.1 and 6.2)
Time Constraints for
Sampling/Testing AVEF System
Following Exposure to
Chemicals. (paragraph 6.1).
TS Monthly Testing That
Requires Installation of
Jumpers or Disconnection of
Leads (paragraph 6.2)
Engineering Safety Feature
(ESF) Actuation, Auxiliary
Feedwater MOVs Receive an Open
Signal (paragraph 5).
Proprietary information is not contained in this report. Dissenting
comments were not received from the licensee.
13
8.
Index of Acronyms and Initialisms
AVEF
AUXILIARY VENTILATION EXHAUST FILTER
CFR
CODE OF FEDERAL REGULATIONS
PENETRATION OF DIIOCTYL PHTHALATE
DR
DEVIATION REPORT
EOG
EDTA
ETHYLENE DIAMINE TETRA-ACETIC ACID
ENGINEERED SAFETY FEATURE
F
FAHRENHEIT
FUEL HANDLING ACCIDENT
IRPI
INDIVIDUAL ROD POSITION INDICATION
JCO
JUSTIFICATION FOR CONTINUED OPERATION
LER
LICENSEE EVENT REPORT
LCO
LIMITING CONDITIONS OF OPERATION
LOSS OF COOLANT ACCIDENT
MER
MECHANICAL EQUIPMENT ROOM
MAIN FEEDWATER REGULATING VALVE
MOTOR OPERATED VALVE
NRC
NUCLEAR REGULATORY COMMISSION
PRESSURE CONTROL VALVE
PARTS PER MILLION
POUNDS PER SQUARE INCH GAGE
QUALITY ASSURANCE
ROOT CAUSE EVALUATION
REACTOR COOLANT PUMP
REFUELING OUTAGE
SGCC
STEAM GENERATOR COMPONENT COOLING
SNSOC
STATION NUCLEAR SAFETY AND OPERATING COMMITTEE
TURBINE DRIVEN AUXILIARY FEEDWATER
TS
TECHNICAL SPECIFICATION
UPDATED FINAL SAFETY ANALYSIS REPORT
UNRESOLVED ITEM
VIOLATION
VPAP
VIRGINIA POWER ADMINISTRATIVE PROCEDURE
WORK ORDER