ML18153B168
| ML18153B168 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 11/23/1994 |
| From: | Belisle G, Branch M, David Kern NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18153B166 | List: |
| References | |
| 50-280-94-32, 50-281-94-32, NUDOCS 9412060102 | |
| Download: ML18153B168 (8) | |
See also: IR 05000280/1994032
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETIA STREET, N.W., SUITE 2900
ATLANTA, GEORGIA 30323-0199
50-280/94-32 and 50-281/94-32
Licensee: Virginia Electric and Power Company
Innsbrook Technical Center
5000 Dominion Boulevard
Glen Allen, VA
23060
Docket Nos.:
50-280 and 50-281
License Nos.:
Facility Name:
Surry 1 and 2
Inspection Conducted: October 27 through November 14, 1994
Inspectors:
- W.--Sranc,Senlor Resident Inspector
re w ,xi~ £.,.-
D. M. Kern, Resientlnspector
Approved by~G.v.~l~
Scope:
Reactor Projects Section 2A
Division of Reactor Projects
SUMMARY
//-;u .. 9ti
Date Signe
//-Z1-9y
Date Signed
This special inspection was conducted on site to review the circumstances
whic.h led to the reported October 27-28 inoperability of the Unit 2
2A station battery. Specific emphasis was focussed in the areas of related
maintenance and surveillance activities, performance trend analysis, and the
timeliness/effectiveness ~f corrective actions.
Results:
One violation was identified for ineffective corrective actions that resulted
in operation with a degraded station battery .
9412060102 941123
ADOCK 05000280
- . PDR.
Q
REPORT DETAILS
I.
Persons Contacted
l~l
Licensee Employees
- L. Baker, Operations
- W. Benthall, Supervisor, Licensing
- H. Blake, Jr., Superintendent of Nuclear Site Services
- R. Blount, Superintendent of Maintenance
- B. Bryant, Licensing Engineer
- D. Christian, Station Manager
- J. Downs, Superintendent of Outage and Planning
- B. Garber, Licensing Engineer
D. Green, System Engineer
M. Haduck, Electrical Supervisor
- D. Hayes, Superintendent of Administrative Services
- R. Johnson, Operations Supervisor
H. Jones, Electrical Supervisor
I. Jones, Electrical .Supervisor
- R. MacManus, Supervisor, Station Engineering
G. Marshall, Operations Maintenance Advisor
- J. McCarthy, Assistant Station Manager
- J. McGinnis, Site Nuclear Safety
- A. Price, Assistant Station Manager
- R. Saunders, Vice Pr~sident, Nuclear Operations
- E. Smith, Site Quality Assurance Manager
- T. Sowers, Superintendent of Engineering
- D. Sommers, Supervisor, Corporate Licensing
B. Stanley, Station Procedures
- J. Swientoniewski, Supervisor, Station Nuclear Safety
Other licensee employees contacted included plant managers and
supervisors, operators, engineers, and technicians.
1.2
NRC Personnel
- M. Branch, Senior Resident Inspector
- D. Kern, Resident Inspector
- S. Tingen, Resident Inspector
- Attended Exit Interview
Acronyms and initialisms used throughout this.report are listed in .the
last paragraph .
2.
2
2A Station Battery Declared Inoperable
2.1
Event Description
At 11:0'0 am on October 27, the licensee declared the Unit 2,
120 VDC 2A station battery inoperable when cell 52 failed the
monthly TS required surveillance test. Station procedure
O-EPT-0102-01, Monthly Station Battery Cell Voltage Check,
revision 0, specifies the_individual cell voltage acceptance
criteria as~ 2.13 volts. Cells below 2.13 volts are categorized
in the ALERT range which indicates marginal performance.
Cell
voltage~ 2.07 indicates that the cell is inoperable. Procedure
O-EPT-0102-01 directs technicians to notify the shift supervisor
and the system engineer of any ALERT or inoperable test results
for increased monit~ring and performance evaluation. Cell 52
voltage was measured to be 2.067 volts. Technicians promptly
notified the shift supervisor who appropriately entered a 24-hour
LCO shutdown action statement as required by TS 3.16.B.3.
NRC
enforcement discretion, as documented in NRC Inspection Report
Nos. 50-280/94-28 and 50-281/94-28,- was granted to allow an
additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to complete corrective actions.
The licensee
exited TS 3.16.B.3 at 6:15 pm on October 28, thereby terminating
the NRC enforcement discretion.
2.2
Immediate Corrective Action
Immediate corrective action, taken upon the October 27 licensee's
determination that the 2A station battery was inoperable, was
good.
Engineering evaluations, maintenance planning, and
management oversight effectively developed and implemented
corrective actions to jumper around cell 52.
This restored the
2A station battery to an operable condition.
The licensee's
response and corrective maintenance activities are documented in
NRC Inspection Report Nos. 50-280/94-28 and 50-281/94-28.
3.
Activities Which Led to the Event
The inspectors observed licensee activities, conducted interviews, and
reviewed maintenance and engineering records to determine the
circumstances and assess licensee performance which led to the event.
A chronology of the relevant occurrences is listed below.
7/25/94
Observation/Action
Electricians performed the monthly station battery ,voltage'
surveillance (TS 4.6.C.l.b). Cell 52 voltage was 2.08
volts. Cell 52 was placed in ALERT status (<2.13 volts) in
accordance with station surveillance procedures. A priority
three work request for a 2A battery charge was initiated.
8/23
9/02-06
9/11
9/20
3
Observation/Action
Electriciari*s performed the monthly station battery voltage
surveillance. Cell 52 voltage was 2.10 volts {ALERT).
The
system engineer learned that the 7/25 requested battery
charge had not been performed and requested an individual
cell 52 charge be performed promptly.
Electricians performed a cell 52 charge.
- 9/02. As found cell 52 voltage was 2.08 volts (ALERT).
- 9/06 Post charge cell 52 voltage was 2.14 volts
( out of ALERT) .
Electricians performed the quarterly station battery
temperature/specific gravity/water level surveillance
(TS 4.6.C.l.c). The system engineer recommended a
2A battery charge based on divergent specific gravity of
some of the battery cells (not cell 52).
Electricians performed the monthly station battery voltage
surveillance. Cell 52 voltage was 2.09 volts (ALERT).
- 9/28-10/07 Electricians performed a 2A battery charge based on the 9/11
surveillance results.
- 10/07 Post charge cell 52 voltage was 2.07 volts
(ALERT).
10/07-10
Electricians performed a cell 52 charge due to the low
cell 52 voltage measured following the 2A battery charge.
- 10/07 Began the 30-hour charge of cell 52.
- 10/08 A quick check of cell 52 voltage immediately
following the charge, but prior to the post
charge 72-hour settle period, measured 2.12 volts
{ALERT).
- 10/08 Electricians began a second 30-hour cell 52
charge based on the quick check voltage.
10/13-16
Post charge cell 52 voltage was .not measured or recorded on
10/13 following the 72-hour settle period.
- 10/17
Electricians measured the post charge cell 52 voltage at
2.07 volts (ALERT).
10/20
Maintenance personnel initiated a work request for a cell 52
charge after discussing the 10/17 voltage reading with the
system engineer.
- 10/22-26
Electricians performed a cell 52 charge.
- 10/22 As found cell 52 voltage was 2.06 volts {ALERT).
- 10/26 As left cell 52 voltage was 2.07 volts {ALERT) .
10/27
10/28
4
Observation/Action
Electricians performed the monthly station battery voltage
surveillance. Cell 52 voltage was 2.07 volts (ALERT).
Electricians and the-system engineer determined that this
voltage reading made cell 52 inoperable in accordance with
station surveillance procedure O-EPT-0102-01.
Electricians
initiated a DR and informed the SS that the 2A station
battery was inoperable.
11:00 am
The shift supervisor declared the 2A station
battery inoperable and entered a 24-hour LCO
shutdown action statement.
The licensee requested and was granted NRC enforcement
discretion to extend the LCO period an additional 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />
to facilitate on-line corrective maintenance.
Licensee
management was unaware that cell 52 voltage had degraded to
~ 2.07 volts prior to 10/27.
6:15 pm
The licensee completed corrective maintenance and
exited the LCO.
- Documented test data shows cell 52 voltage~ 2.07 volts. Per
O-EPT-0102-01, cell 52 should have been declared inoperable and a DR
written. Neither station management nor licensed personnel were aware
of this information at- the time of these occurrences and therefore
operability of the 2A station battery was not questioned.
4.
Licensee Actions and Inspector Findings
Maintenance and surveillance data indicated degradation of cell 52 of
the 120 VDC 2A station battery since July 25, 1994. Station procedure
O-EPT-0102-01 requires battery cells with measured cell voltages~ 2.07
volts be declared inoperable. This is consistent with standard TS and
IEEE 450-1987, Recommended Practice for Maintenance, Testing, and
Replacement of Large Lead Storage Batteries for Generating Stations and
Substations. Operation of a battery cell below 2.13 volts can reduce
the life expectancy of the cell.
IEEE 450-1987 further states that cell
voltage of 2.07 volts or below indicates internal cell problems and may
require cell replacement.
Immediate corrective action, usually in the
form of an equalizing charge, is recommended.
Several equalizing
charges were performed on the cell, but the cell failed to adequately
hold the charge.
The inspectors determined that the licensee was slow to take effective
corrective action. Initial corrective action requested in July, an
equalizer charge of the 2A battery (WO 296592), was not performed.
The
requested battery charge had been assigned a routine work order
priority. System engineers were unaware of the low priority assigned
and did not follow-up on the correctiv~ action results until after the
next monthly surveillance. The routine priority assignment combined
5
with absence of follow-up by maintenance or engineering personnel
delayed the start of corrective action by approximately five weeks.
Work priorities are assigned by the OMA or SS in accordance with the
general criteria contained in VPAP-2002, Work Requests and Work Order
Tasks.
The inspectors discussed the priority assignment for WO 296592
with the OMA.
VPAP-2002 does not specifically highlight components in
ALERT status for additional operability review or priority
consideration.
Work priority is assigned based upon information written
on the WR ticket and the personal experience of the SS or OMA.
The OMA
stated that a more in depth priority review is typically conducted when
the DR block on the WR ticket is checked off. Some, but not all,
maintenance procedures direct the submittal of a DR when a component
does not meet procedurally specified.performance criteria. Procedure
O-EPT-0102-01 did not require a DR to be submitted if cell voltage was
measured *in the ALERT range.
The original WR, submitted in response to
the low cell 52 voltage measured on July 25, did not indicate a station
battery operability concern or DR and was therefore assigned a routine
priority three. Following this event the .Station Manager issued a
directive "Problem Reporting" which requires that DRs be submitted when
components are found in the ALERT range, or where trend data indicates
ah approach to an ALERT value.
The inspectors determined this was an
appropriate interim action pending further licensee review of the event.
The inspectors identified that maintenance records documented
information indicating cell 52 voltage had been below station
operability criteria on several occasions between October 7-27. * Neither
station management nor licensed personnel were aware of this information
at time of these occurrences and therefore operability of the 2A station
battery was not questioned.
The inspectors observed that the corrective
maintenanceprocedures used for battery charges do not identify post
maintenance testing requirements to be performed to determine the
success of the corrective maintenance activity. The absence of post
maintenance test requirements contributed to the failure of maintenance
. and engineering personnel to inform management of the unacceptable as
left cell 52 condition.
.
.
The inspectors questioned why post charge voltage was not measured on
October 13 immediately following the 72-hour settling period, as is
normally done.
The measurement delay was inconsistent with the level of
i~portance indicated by charging this cell 3 times in the previous 10
days.
The inspectors discussed work priority assignment, the absence of
post maintenance test requirements, and the delay in measuring post
charge cell voltage with licensee management.
The licensee stated that*
these issues wer~ under review, but were not fully evaluated at the
close of this inspection report.
The licensee initiated DR S-94-1994 to
determine the reason why the severe degradation of cell 52 had not been
identified, raised to management's attention, and evaluated for
operability in a timely manner.
The licensee intends to document
resulting corrective actions in a Licensee Event Report .
6
Degrading cell 52 performance was identified in the system engineer's
quarterly report that was issued in early October. This document stated
that cell 52's performance was not adequate to achieve full operability.
Based on this quarterly report, station management began to review the
performance of cell 52. A work plan to replace or jumper cell 52 was
initiated on October 26 and implemented on October 28 as documented in
NRC Inspection Report Nos. 50-280/94-28 and 50-281/94-28.
Licensee
corrective action systems did not elevate the questionable cell 52
performance to the appropriate station management's attention in a
timely manner.
Ineffective management of this issue and limited
tracking of corrective maintenance effectiveness resulted in operation
with a degraded safety component.
The licensee had the opportunity, while cell 52 was in ALERT
(July - September), to develop a contingency work plan to jumper the
cell in the event that cell 52 further degraded to an inoperable
condition. The-licensee began preparing the work plan on October 26,
but the plan was not ready for implementation when the 2A station
battery was declared inoperable on October 27.
The inspectors concluded
that this untimely planning led to the need to obtain NRC enforcement
discretion from TS 3.16.B.3 in order to complete corrective maintenance.
During post event review, station management recognized that multiple
factors had contributed to the organization's failure to promptly
address the degrading condition of the 2A station battery. Management
therefore elevated the level of review and directed that a Case Study be
performed.
This action is independent of the DR and LER corrective
action processes.
The Case Study process uses a time line development
approach to provide independent insight into causal factors.
Management
requested the Case Study to include independent recommendations
regarding corrective action.
The inspectors discussed the Case Study
process with licensee personnel and concluded that this tool was
appropriate to evaluate this event.
Station procedure O-EPT-0102-01 specifies that a battery cell be
considered inoperable and a DR be submitted if a cell voltage
measurement of~ 2.07 volts is recorded.
On October 7, 17, 22,
and 26, 1994, although not during the performance of procedure
O-EPT-0102-01, cell 52 voltage of the 2A station battery was~ 2.07
volts and the cell was not declared inoperable and DRs were not issued.
10 CFR SO, Appendix B, Criterion XVI, as implemented by the Operational
Quality Assurance Program Topical Report (VEP-1-SA, Section 17.~.16)
requires that measures be established to assure that conditions adverse
to quality are promptly identified and corrected.
Failure to establish
measures to assure that a condition adverse to quality 1 a degraded
station battery, were promptly identified and corrected is identified as
VIO 50-281/94-32-0l, Ineffective Corrective Action Associated With The
2A Station Battery.
..
7
- 5.
. Exit Interview
The inspection scope and findings were summarized on November 15, 1994,
with those persons indicated in paragraph 1.
The inspectors described
the areas inspected and discussed in detail the inspection result
addressed in the Summary section and listed below.
Item Number
VIO 50-281/94-32-01
Status *
Open
Description/(Paraqraph No.)
Ineffective Corrective Action
Associated With The 2A Station
Battery (paragraph 4)
Proprietary information is not contained in this report. Dissenting
comments were not received from the licensee.
6.
Index of Acronyms and Initialisms
CFR
CODE OF FEDERAL REGULATIONS
DR
DEVIATION REPORT
IEEE
INSTITUTE OF ELECTRICAL AND*ELECTRONICS ENGINEERS, INC
LCO
LIMITING CONDITIONS OF OPERATION *
LER
LICENSEE EVENT REPORT
NRC
NUCLEAR REGULATORY COMMISSION
OPERATIONS MAINTENANCE ADVISOR
SHIFT SUPERVISOR
VDC
VOLTS DIRECT CURRENT
VIOLATION
WORK ORDER
WORK REQUEST