ML18152A799
| ML18152A799 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 03/17/1988 |
| From: | Cantrell F, Holland W, Larry Nicholson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18152A798 | List: |
| References | |
| 50-280-88-04, 50-280-88-4, 50-281-88-04, 50-281-88-4, NUDOCS 8804010047 | |
| Download: ML18152A799 (14) | |
See also: IR 05000280/1988004
Text
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UNITED STATES .. WJCLEAR REGULATORY COMMISSION W' REGION II 101 MARIETTA STREET, N.W. ATLANTA, GEORGIA 30323 Report Nos.: 50-280/88-04 and 50-281/88-04 Licensee: Virginia Electric and Power Company Richmond, Virginia 23261 Docket Nos.: 50-280 and 50-281 Facility Name: Surry 1 and 2 License Nos.: DPR-32 and DPR-37 Inspection Conduc~;~~_-'.;' Feb;f~g-r~. ~!~~ough February 27., Inspectors: /1 l / /--:-r.:~-{/f W. E. Holland, S.enior Resident Inspector
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L. E. Nichol~on, Resid~~t Inspector Approved by: ~~ .f'-: S. Can tr~_ ect ion Chief Division of Reac or Projects _ SUMMARY 1988. 3 ,;;-" ( -~11-/7 ...
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Scope: This routine inspection was conducted in the areas of plant operations, plant maintenance, plant surveillance, followup on inspector identified items, and licensee event report review. Results: One violation was identified for failure to maintain and verify operability of heat trace circuitry for boric acid flow path as required by the Technical Specifications (paragraph 6). This violation is being considered for escalated enforcement action and will be forwarded under separate cover . 8804010047 880321 PDR ADOCK 05000280 Q DCD
REPORT DETAILS 1 ~ Persons Contacted Licensee Employees
- D. L. Benson, Station Manager
- H. L. Miller, Assistant Station Manager
- E. S. Grecheck, Assistant Station Manager
- J. A. Bailey, Superintendent of Operations
- D. J. Burke, Superintendent of Maintenance
S. P. Sarver, Superintendent of Health Physics e
- R. H. Blount, Superintendent of Technical Services
R. L. Johnson, Operations Supervisor
- J. A. Price, Site Quality Assurance Manager
- G. D. Miller, Licensing Coordinator, Surry
- Attended exit meeting.
Other licensee employees contacted included control room operators, shift technical advisors, shift supervisors and other plant personnel. The NRC, Region II Section Chief, F. S. Cantrell, attended the exit meeting on March 1, 1988. 2. Exit Interview The inspection scope and findings were summarized on March 1, 1988, with those individuals identified by an asterisk in paragraph 1. The following new items were identified by the inspectors during this exit. One violation (paragraph 6) was identified for failure to maintain and verify operability of heat trace circuitry for boric acid flowpaths as required by Technical Specifications 3.2.B.5, 3.2.C.5, 3.2.D.3, and 4.1.A, Table 4.1-2A, Item 12 (280; 281/88-04-01). One unr~solved item (paragraph 6) was identified with regards to licensee evaluation of steam flow indication at low power levels from a design, safety analysis, and operator action point of view, (280, 281/88-04-02). One unresolved item (paragraph 8) was identified with regards to review of licensee clarification of the requirements of ASME, Section XI, IWV-3417 for valves failing to meet acceptance criteria during exercising, (280, 281/88-04-03). The section chief discussed NRC 1 s concern involving the inadequate management action to correct the heat tracing alarm in the control room until the resident inspector identified a *problem with boric acid heat tracing.
- e 2 The licensee acknowledged the inspection findings with no dissenting comments. The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspection. 3. Plant Status Unit 1 Unit 1 began the reporting period at power. The unit operated at power until February 16, when th'e unit experienced an automatic reactor trip from full power. The trip was due to personnel error during performance of surveillance testing of the reactor protection logic. The unit returned to power operation on February 17, and operated at power for the duration of the inspection period. Unit 2 Unit 2 began the reporting period at power. The unit operated at power for the duration of the inspection period. 4. Licensee Action on Previous Enforcement Matters (92702) (Closed) Violation 280; 281/87-21-01, Failure to conduct evaluations for unreviewed safety question determination as required by the Technical Specification and 10 CFR 50.59. The subject violation was identified in Inspection Report 280; 281/87-21. Licensee actions, after identification of the violation, have included implementation of a detailed administrative procedure to provide guidance in screening potential changes and performing the required safety evaluations; training of employees and supervisors responsible for performing the evaluations; and training of the members of the Station Nuclear Safety and Operating Committee (SNSOC). In addition, all listed examples of the violation were corrected using the new procedure requirements. The inspector reviewed the new Administrative Procedure (SUADM-LR-012, "Safety Analysis/10 CFR 50.59/10 CFR 72.35 Review 11 , dated October 23, 1987) and concluded that the necessary guidance for performing a safety evaluation in order to determine whether a proposed change, test, or experiment would have an adverse effect on plant systems, equipment, or the FSAR is addressed. Also, the inspector reviewed the training conducted on this new procedure and considers that adequate instruction was provided to station personnel to implement the procedure requirements. This item is closed. Within the areas inspected, no violations or deviations were identified .
e 3 5. Unresolved Items Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve violations or deviations. Two new unresolved items are identified in paragraph 6 and paragraph 8. 6. Plant Operations Operational Safety Verification (71707) The inspectors conducted daily inspections in the following areas: Contra 1 room staffing, access, and operator behavior; operator adherence to approved procedures, technical specifications, and limiting conditions for operations; examination of panels containing instrumentation and other reactor protection system elements to determin~ that required channels are operable; 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 conducted weekly inspections in the following areas: Verification of operability of selected ESF systems by valve alignment, breaker positions, condition of equipment or component(s), and operability of instrumentation and support items essential to system actuation or performance. Plant tours 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 monitor the temperature of the auxiliary feedwater pump discharge piping to ensure steam binding is prevented. The inspectors conducted biweekly inspections in the following areas: Verification review and walkdown of safety-related tagout(s) 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 portions of containment isolation lineup(s); and verification that notices to workers are posted as required by 10 CFR 19. Certain tours were conducted on backs hi fts or weekends. Backs hi ft or weekend tours were conducted on February 2, 10, 13, 15, 16, 17, 22, and 24. 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 struc-
ture, and the safeguards valve pit and pump pit areas. Reactor coolant
4 system 1 eak rates were reviewed to ensure that detected or suspected leakage from the system was recorded, investigated, and evaluated; and that appropriate actions were taken, if required. The inspectors routinely independently calculated RCS leak rates using the NRC Indepen- dent Measurements Leak Rate Program (RCSLK9). On a regular basis, radiation work permits (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. In the course of monthly activities, the inspectors included a review of the 1 icensee' s physical 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. On February 16, at 1143 hours, Unit 1 automatically tripped from 100% power. The trip was caused by personnel error. Instrumentation technicians were performing surveillance testing of reactor protection logic when they inadvertently cleared the P-10 permissive block for the 118 11 protection train instead of the 11A 11 protection train. The require- ments were clearly defined in PT-8.1, "Periodic Test - Reactor Protection Logic (Normal Operating Conditions)"; however, the technicians operated the test circuits from the wrong train test rack in violation of procedure. The inspector was informed that this trip is the first trip in four years that was caused by instrumentation technician personnel error. All systems performed as designed during the trip except for the Inter- mediate Range Nuclear Instruments (IR Nis), which failed to reinstate source range Nis automatically. The IR Nis were adjusted in accordance with procedure; and, after review of the post trip report and approval by the station safety committee, the unit was restarted in accordance with normal procedure. The unit was critical at 0410 hours on February 17, and recommenced power operation at 1144 hours the same day. The resident inspector observed operator performance from approximately one minute after the reactor trip through completion of appropriate reactor trip procedures, and selected restart evolutions. The inspectors also reviewed the actions taken by the station as a result of identification of the trip cause. This included initiation of review of the event by the Human Performance Eva 1 uat ion System program and add it i ona 1 rei nstruct ion by station management to all instrumentation personnel on procedure adherence and attention to detail. The residents wi 11 fo 11 owup on any add it i ona 1 corrective actions during later inspections when the LER is reviewed for closeout. During the initial power ascension of Unit 1 on February 17, the inspector monitored the response of the steam flow instrumentation on the main control board (flow indicators FI-474 and 475, S/G A steam flow; FI-484
5 and 485, SIG B steam flow; FI-494 and 495, SIG C steam fl ow). The following information was recorded: POWER LEVEL Stearn Flow Indication % (X 10 6 LBM/HR) 474 475 484 485 494 495 5 0 .5 0 0 0 0 7 0 . 5 0 0 0 0 9 0 . 5 0 0 0 0 11 0 .6 0 0 0 0 13 0 .6 0 0 0 0 15 0 .7 0 0 .3 0 17 .1 .75 0 0 .3 0 19 .5 .8 . 5 . 5 .4 .5 21 .6 .8 .6 .6 .6 .6 The recorded data implies that reliable steam flow indication was not available for operator information until indicated power level reached approximately 18%. The inspector questioned the licensee with regard to whether steam flow instrumentation was providing indication within the design accuracy of the system at low power level. Also, the inspector requested that the licensee review their accident analysis and operating procedures to evaluate if current low power indication of the instrumen- tation provides for appropriate automatic and/or operator actions during low power operation. This issue is identified as an unresolved item (280; 281/88-04-02) pending licensee review of the issues. Engineered Safety Featu~e System Walkdown (71710) The inspector performed a walkdown of the accessible areas of the safety related portions of the Chemical Volume and Control System. This verification included the following: Confirmation that the licensee's system lineup procedure matches plant drawings and actual plant configura- tion; hangers and supports are operable; housekeeping is adequate; valves and/or breakers in the system are installed correctly and appear to be operable; fire protection/prevention is adequate; major system components are properly labeled and appear to be operable; instrumentation is properly installed, calibrated, and functioning; and valves and/or breakers are in correct position as required by plant procedure and unit status. In conjunction with the above walkdown, the inspectors examined the operation and testing of the two channels of heat tracing required for the boric acid flowpaths to the core (Technical Specification 3.2.B.5 and 3.2.C.5). This area was reviewed in part due to annunciator panel VSP, window E-8 ( 11 CVCS HEAT TRACE TROUBLE") in the main contro 1 room (MCR) being lit for an extended period. This Thermon heat tracing system is comprised of three primary panels (HTP-2Al, -2A2, and -2A3) and three
6 backup panels (HTP-2Bl, -2B2, and -2B3), located in the auxiliary bui 1 ding, which provide contra l of circuits designed to maintain the temperature of the boric acid piping between 125 and 185 degrees F. The heat tracing temperature is normally maintained by the 11A 11 panel, with the associated 118 11 panel circuit set to energize when the temperature drops 15 degrees below the 11A 11 panel setpoint. An undertemperature or fault sensed by any of the circuits on the above panels causes a light to i 11 umi nate brightly on the MCR heat trace monitoring panel for Units 1 and 2 indicating which auxiliary building panel the prob 1 em is on. This 1 i ght al so causes a 11 CVCS HEAT TRACING TROUBLE 11 window to annunciate on the common annunciator panel in the MCR. Operator response procedure (VSP-47) requires the operator to evaluate the alarm cause and circuit operability based on system conditions; however, based on discussions with operators, this annunciator has been locked in for an extended period (months) resulting in minimal operator action based on control room indication. The operability of the circuits are verified monthly by performing surveillance tests l-PT-27H, l-PT-27I, or 2-PT-27G, depending on the circuit. These tests only verify that the actual watt output for each circuit is within its specified tolerance band, with no reference or check of the controller that is required t6 function for the circuits to perform properly, and no criteria for actual pipe temperature. On February 11, 1988, the inspector reviewed the status of the overtemper- ature, setpoi nt, and undertemperature i ndi ca tor 1 i ghts on the three primary panels (HTP-2Al, -2A2, and -2A3) and three backup panels (HTP-2Bl, -2B2, and -2B3). These lights should be set to indicate an overtempera- ture of 180 degrees F, an undertemperature of 130 and 120 degrees F, and a setpoint at which the circuit energizes of 145 and 130 degrees F. for the primary and backup circuits, respectively. The scope of this inspection was limited to the circuits installed on the primary piping flow path from the boric acid tanks to the charging pump suction for each unit. The results of this review revealed that the operability of approximately 25% of the required circuits could be questioned. Criteria for questioning operability included such cases as an unenergized circuit indicating undertemperature, or a backup circuit indicating energized with an undertemperature and its corresponding primary circuit not energized. The inspectors also reviewed completed PTs l-PT-27H, 11 Periodic Test - Heat Tracing (Panels 2Al, 2Bl, and 5 Thermon and Strip Heaters) 11 ; l-PT-27!, 11 Periodic Test - Heat Tracing (Panels 2A2 and 2B2 Thermon) 11 ; and 2-PT-27G, 11 Periodic Test - Heat Tracing (Panels 2Al, 2Bl, 2A2, 2B2, 2A3, and 283 Thermon and Strip Heaters) 11 which were performed in 1987. The inspector noted that heat trace circuits which were identified by an* in the PTs were designated as Technical Specification circuits. The inspector also noted that in the following listed PTs, circuits identified as Technical Specification circuits had recorded temperature readings below 90 degrees F. The calculated temperature to maintain solubility was 92 degrees F.
e 7 PT NUMBER DATE COMPLETED PANEL/CIRCUIT NUMBER TEMPERATURE (degrees F) 1-PT-27H 1-7-87 2Bl / 41 87 1-PT-27H 10-29-87 2Bl I 40 89 1-PT-27H 10-29-87 2Al I 39 81 1-PT-27H 10-29-87 2Al I 40 76 1-PT-27H 10-29-87 2Al I 41 80 1-PT-27H 12-7-87 2Al I 39 81 1-PT-27H 12-7-87 2Al I 40 76 1-PT-27I 1-28-87 2B2 / 45 85 2-PT-27G 3-20-87 2Bl I 43 88 2-PT-27G 9-22-87 2Al I 42 88 2-PT-27G 9-22-87 2Al I 43 89 The inspector noted that although there was no known instance of technical specification flow path blockage due to boric acid (7 percent) solution not maintaining solubility. On February 12, 1988, the inspectors discussed with station management the results of the inspection review on February 11, and voiced a concern regarding the operability of the heat trace circuits and the inability to continually monitor the heat tracing system status due to alarm conditions for heat trace panels in the MCR continually being displayed. Licensee management stated that although corrective actions to provide an early warning of heat trace problems from the control room annunciators has not been actively pursued; they considered that current surveillance perform- ances verified full operability in accordance with Technical Specifica- tions. However, the licensee did agree that the inspector's findings did warrant further review and implemented a program to assess the current situation. The results of.their assessment agreed with that of the inspectors, thereby requiring the licensee to declare many CVCS heat tracing circuits inoperable on Februaury 19, 1988; and to enter a 6 hour LCD per Technical Specification 3.0.1. The licensee subsequently repaired the controllers required for the boric acid flowpaths and exited the LCD. In addition, the licensee commenced walkdowns each shift by the operators to specifically verify operability of the heat trace circuits required by technical specification in the current flowpaths from the boric acid tanks to the charging pumps suction for each unit. The licensee was continuing with additional extensive corrective actions when the inspection period ended.
- - 8 Technical Specification 3.2.B.5 and 3.2.C.5 for one-unit and two-unit operation, respectively, requires that two channels of heat tracing be operable for the flow paths requiring heat trac~ng. Technical Specifica- tion 3.2.D.3 allows one heat tracing circuit to be inoperable for a period not to exceed 24 hours provided immediate attention is directed to making repairs. Technical Specification 4.1.A requires testing of instrumenta- tion channels be performed as detailed in Table 4.1-2. Table 4.1-2A, Item 12, requires that the Boric Acid Piping Heat Tracing Circuits be verified as operable on a monthly basis. The monthly surveillance test performed to verify operability as required by Technical Specification Table 4.l-2A, Item 12, wa*s inadequate in that it did not test the controllers of each circuit or verify adequate temperature was being maintained on the pipe. In light of the inadequate monthly surveillance test methodology, the defective heat trace circuits identified by the inspector and licensee above were last verified as being operable during system modifications in December 1984 for Unit 1, and May 1985, for Unit 2. This item is identified as a violation of Technical Specifica- tions 3.2.B.5, 3.2.C.5, 3.2.D.3, and 4.1.A, Table 4.1-2A, Item 12, Failure to maintain and verify operability of heat trace circuity for boric acid flowpaths (280; 281/88-04-01). Within the areas inspected, one violation was identified. 7. Maintenance Inspections (62703) During the reporting period, the inspectors reviewed activities to assure compliance with the appropriate Inspection areas included the following: maintenance procedures. On February 10, the inspector witnessed maintenance activities which were being conducted on the Unit 2 individual rod position indication (IRPI) for control rod 010. The indication meter in the control room for rod 010 was providing erratic readout whenever pressure was applied to its bank mounting panel in specific locations. This condition indicated a loose connection within the bank IRPI panel for control bank B. Repair to this pane 1 re qui red that the IRPI for the eight rods in this bank pane 1 be deenergized for a short period of time. Temporary rod position indication for the affected rods was provided by computer printout to the operators during the time that the repairs to the bank panel were being accom- plished. The station safety committee (SNSOC) approved the deviated procedure to perform the maintenance activity prior to performance of the work. The work took approximately 2 hours and post maintenance testing was satisfactorily accomplished after repair was completed. The inspector observed the troubleshooting of the faulty IRPI and followed the process to completion of the repair and post maintenance testing of the system. The proper technical specification LCD was entered when troubleshooting began, operator briefing on indication provided by computer was conducted, safety committee overview of activities as the work progressed was adequate, and appropriate testing of the completed repair verified operability. The inspector also reviewed the completed
9 maintenance procedure_ ( IMP-C-RPI-32, 11 Instrument Maintenance Procedure - Checking, Repairing, or Replacing a Component in the Rod Position Indication System 11 with changes dated February 10, 1988); and the completed procedure which was used for post maintenance testing (2-PT-5.2, 11 Periodic Test - Analog Rod Position Instrument,ation 11 with changes dated February 10, 1988). No discrepancies were noted. Within the areas inspected, no violations or deviations were identified. 8. Surveillance Inspections (61726) During the reporting period, the ihspectors reviewed various surveillance activities to assure comp 1 i ance with the appropriate procedures as fo 11 ows: 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: On February 10, the inspectors witnessed the performance of the monthly surveillance test 2-PT-15.lB, "Periodic Test, Motor Driven Auxiliary Feedwater Pump (2-FW-P-38) 11 * The test verifies operability of the pump as required by Technical Specification 4.8. No discrepancies were noted. On February 16, the inspector reviewed the performance of l-PT-14.2, 11 Periodic Test - Main Steam Trip Valves and Main Steam Non-Return Valves 11 * The test verifies operability of the MSTVs prior to restart as required by Technical Specification 4.7. No discrepancies were noted. On February 17, the inspector witnessed the performance of l-PT-15.lC, 11 Periodic Test - Turbine Driven Auxiliary Feedwater Pump (1-FW-P-2) 11 * The test verifies operability as required by Technical Specification 4.8. No discrepancies were noted. During this inspection period, the inspector reviewed the following periodic test procedures in order to evaluate compliance with ASME Section XI valve testing and corrective action requirements. l-PT-18.6A, 11 Periodic Test - Quarterly Testing of Safety Injection MOV 1 s and HCV 1s 11 completed on February 8, 1988; October 30, and August 3, 1987.
10 2-PT-18.6A, "Periodic Test - Quarterly Testing of Safety Injection MOV 1 s and HCV 1 s 11 completed on February 5, 1988; November 4, and August 1, 1987. 1-PT-18.68, "Periodic Test - Quarterly Testing of Miscellaneous Containment Trip Valves" completed on November 12, and August 12, 1987. 2-PT-18.68, "Periodic Test - Quarterly Testing of Miscellaneous Containment Trip Valves" completed on January 6, 1988. 1-PT-41.2, "Periodic Test - CSD Testing of CC Check Valves and Trip Valves for RHR and RCP 1 s 11 completed on May 27, 1987. 2-PT-41.2, "Periodic Test - CSD Testing of CC Check Valves and Trip Valves for RHR and RCP 1 s 11 completed on April 15, 1987. 2-PT-18.6C, "Periodic Test - CSD Testing of Charging & Safety Injection MOV 1 s and HCV 1 s completed on June 24, and November 26, 1986; and December 19, 1987. During the review of the preceeding proc~dures, the following noncon- forming items were noted: During performance of 1-PT-18.6A which was completed on February 8, 1988, MOV-18648, (Low Head Safety Injection Pump B Discharge Isolation Valve to Cold Legs) would not fully stroke. In accordance with procedure and Technical Specifications, a deviation report (Sl-88-0024) and a work request (167413) were written; and a 24 hour LCO in accordance with TS 3.3.8.4 was entered. Immediate corrective action restored the valve to manual operation, and after the valve was manually fully opened, the TS LCO was exited as approved by the station safety committee. Additional corrective action to restore el ectri cal operation has been deferred pending receipt of repair parts. The inspector verified that control room operators were alerted to the fact that ~he valve will not operate electrically by a note placed adjacent to the valve switch. Also, the valve does not receive SI signal and is in the required initial SI position. The inspector al so reviewed emergency procedures and concluded that operators could take appropriate actions as required. During performance of 1-PT-18.6A which was completed on August 3, 1987, MOV-1860A (Low Head Safety Injection Pump A Suction Valve from Containment Sump) did not cycle properly. In accordance with procedure, a deviation report (Sl-87-0638) and a work request (055630) were written. However, the valve clutch lever was repositioned after the valve failed to stroke, and the valve was operated electrically satisfactorily afterwards. The work request is still outstanding as of February 22, 1988, with work tentatively scheduled for next refueling. The valve has been cycled satisfac- torily during performance of the PT in October 1987, and February 1988.
e 11 During performance of 2-PT-18.6A which was completed on February 5, 1988, MOV-28628 (Low Head Safety Injection Pump B Suction Valve from RWST) failed to stroke on the first attempt. In accordance with procedure, a deviation report (S2-88-0067) was written. However, at the time of testing, the valve was recycled two times satisfactorily, and no work request was written for corrective action. When the deviation report was reviewed by engineering, a recommendation fo.r
- additional MOVATS testing was added and a work request (354261) was
written. The inspector also was informed that the station safety committee had approved a requirement to perform two successive successful stroke tests on any va1ve which has a stroke failure prior to considering the valve operable. MOVATS testing of MOV-28628 was accomplished on February 26, 1987. The test determined that the valve was fully operable and no additional corrective action was necessary. The inspector, after discussing initial licensee actions with Region II, informed licensee management that stroking of valves after indicated failures to confirm operability did not constitute corrective action as required by the code. The licensee stated that they wi 11 review the requirements. This i tern is unreso 1 ved pending review of licensee clarification of the requirements of ASME, Section XI, IWV-3417, for valves failing to meet acceptance criteria during exercising with regards to operability considerations . During performance of 2-PT-18.6A which was completed on February 5, 1988, SOV 202A-2 and SOV 202B-2 (Unit 2 SOVs which supply air to RWST cross connect trip valves TV-SI-202A and TV-SI-2028 respectively) exceeded stroke time of 10.0 seconds which was maximum allowable in PT. Based on review of the PT critique sheet, the inspector noted that engineering work request (EWR) 87-371 had been performed which justified a maximum stroke time of 13 seconds. Additional reviews of earlier PTs also indicated that this problem had existed since February 1987. The inspector discussed this issue with station management and concluded that although documentation for the increased stroke time was delinquent, the licensee was reviewing required stroke times after initial identification of the discrep- ancy. The inspector also concluded that present controls which are in place would insure that safety committee review of a condition of this type with appropriate documented operability considerations is normal operating procedure. During performance of l-PT-18.6B which was completed on November 12, 1987, TV-IA-100 (Unit 1 Containment Instrument Air Isolation Trip Valve) failed to close. In accordance with procedure, a deviation report (Sl-87-0927) and a work request (067951) were written. An operator was immediately dispatched to the valve location, and determined that the failure was due to mechanical binding of stem by the electrical cable from the SOV. The cable was repositioned and the valve was stroke tested satisfactorily. An inspection of both
e 12 Units was made for similar conditions and no similar adverse configuration was found. During performance of 1-PT-18.6B which was completed on November 12, 1987, HCV-1200C (Unit 1 C Letdown Orfice Isolation Valve) failed to cycle properiy. Based on review of the PT critique sheet, the inspector noted that a deviation report ( Sl-87-837) and a work request (409804) were written for this valve on October 6, 1987. The valve was closed (required containment isolation position) and would not open on demand. Repairs accomplished included reinstallation of a cap in air supply line which was found off and retest of valve on November 28, 1987. Retest was satisfactory. The inspector reviewed the deviation report and the work order summary. During performance of 2-PT-18.6B which was completed on January 6, 1988, HCV-2200A (Unit 2 A Letdown Orfice Valve),was verified to be operable. The inspector observed that the maximum allowable stroke time in the PT had been changed from 10 seconds to 15 seconds. Actua 1 stroke time was 11. 76 seconds. The inspector then reviewed appropriate safety committee minutes which justified the new maximum stroke time. The valve had been overhauled in December 1987, and a new base line time was being established. During performance of 2-PT-18.6C which was completed on December 19, 1987, MOV-2289A and MOV-2289B (Unit 2 Normal Charging Flowpath Isolation Valves) failed to stroke in the required time of 10 seconds or less. In accordance with procedures, a deviation report ( S2-87-526) and work requests ( 409293 for MOV-2289A, 409292 for MOV-2289B) were written. Corrective action for both valves included adjustment of limit switches. Both valves were retested satisfac- torily in accordance with the, PTs on December 21, 1987. The inspector reviewed the test results and the work order summary. Based on review of the preceding work accomplished on valves experiencing problems during performance of required surveillance testing in accordance with ASME, Section XI, Article !WV, the inspector considers that appropriate corrective action is being accomplished, with the exception being that initially identified for MOV-2862B. This issue is unresolved pending review of licensee clarification of the requirements of ASME, Section XI, IWV-3417 for valves failing to meet acceptance criteria during exercising, (280, 281/88-04-03). Within the areas inspected, no violations or deviations were identified. 9. Followup on Inspector Identified Items (92701) (Closed) !FI 280/87-33-01, Followup and Review of the Evaluation for Auxiliary Feedwater Pump Discharge Piping Movement During Normal System Operation. This item was identified in Inspection Report 280; 281/87-33. In that report the inspector requested that the report on analysis of the data taken relating to the AFW discharge piping movement during system
4i
13 operation on December 2, 1987, be provided for review. During this inspection period, the inspector was provided a copy of a report from Virginia Power Engineering dated December 4, 1987. This report concluded that the subject piping movement was within allowable stress loading and the structural integrity of the lines was not adversely impacted. Based on the conclusions of this report, this item is closed. 10. Licensee Event Report (LER) Review (92700) The inspector reviewed the LERs listed below to ascertain whether NRC reporting requirements were being met and to determine appropriateness of the corrective action(s). The inspector's review also included followup on implementation of corrective action and review of licensee documen- tation that all required corrective action(s) were complete. LERs that identify violation(s) of regulation(s) and that meet the criteria of 10 CFR, Part 2, Appendix C, Section V are identified as Licensee Identified Violations (LIV) in the following closeout paragraphs. LIVs are considered first-time occurence violations which meet the NRC Enforcement Policy criteria for exemption from issuance of a Notice of Violation. These items are identified to allow for proper evaluation of corrective actions in the event that similar events occur in the future . (Closed) LER 280/87-39, Protection System Channel Inoperable Due To Failed Sumrriator In Signal Conditioning Circuit. The issue involved the failure of the Unit 1 Reactor Coolant System 1C1 loop average temperature protection channe 1 summator. This fa i 1 ure caused the Channe 1 3 Over- Temperature and Over-Power Delta Temperture reactor trips and turbine runback setpoints to fail high, and in such violated the minimum degree of redunancy required per Techn i ca 1 Specification. A 1 though the Techn i ca 1 Specification is sil~nt in this area, the correct actions were performed by placing the affected channels in the trip mode. A Technical Specifica- tion revision request has been submitted to address this situation in the future. This LER is closed. }}