ML18153C700

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Insp Repts 50-280/91-18 & 50-281/91-18 on 910609-0706. Violations Noted.Major Areas Inspected:Plant Operations, Plant Maint,Plant Surveillance & Plant Procedures
ML18153C700
Person / Time
Site: Surry  Dominion icon.png
Issue date: 07/31/1991
From: Branch M, Fredrickson P, Tingen S, York J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML18153C698 List:
References
50-280-91-18, 50-281-91-18, NUDOCS 9108160225
Download: ML18153C700 (17)


See also: IR 05000280/1991018

Text

Report Nos.:

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION II

101 MARIETTA STREET, N.W.

ATLANTA, GEORGIA 30323

50-280/91-18 and 50-281/91-18

Licensee:

Virginia Electric and Power Company

5000 Dominion Boulevard

Glen Allen, VA

23060

Docket Nos.:

50-280 and 50-281

License Nos.:

DPR-32 and DPR-37

Facility Name:

Surry 1 and 2

Inspection Conducted: June 9 - July 6, 1991

Inspectors: ~

z3'v:

M. ~'

Senior Resident Inspector

~"fat:

J. W. Yokesident Inspector

c::? h ~

&=*

S. G. Ting~dent Inspector

Accompanying

Inspector

~e,l: r H~;iand, Se:for Resident

Approved by:__,,,.\\ ,,-=-----=-j---=~~-.--,,....-.,..."*_*, "L-_---7_*>,.._~--,,,,...,.-,-=--*..,,,"-.,...~.,...--..,..------

, P. E. Fredrickson, Section Chief<::......:

Division of Reactor Projects

SUMMARY

Scope:

{.~

  • 7/~/9/

Da1:egned

~//?,I

D eSi7gned

This routine resident inspection was conducted on site in the areas of plant

operations, plant maintenance, plant surveillance, and plant procedures. During

the performance of this inspection, the resident inspectors conducted review of

the licensee's backshift or weekend operations on June 9, 16, and 23, and

July 3 and 6, 1991.

Results:

In the operations area, a violation with three examples was identified for a

failure to follow or provide adequate procedures associated with reactor

coolant system filling procedure, 2-0P-5.1.1, dated May 10, 1991, and reactor

coolant system venting procedure, 2-0P-5.1.2, dated May 10, 1991 (paragraph

3. C).

In the engineering/technical support area, a non-cited violation was identified

associated with the failure to implement design output assumptions regarding

calibration requirements for instrumentation (paragraph 5.b).

2

In the_ safety assessment/quality verification function_al area, a weakness was

identified regarding the failure to q>n"trol a condition of the orig_inal safety

evaluation associated with coritrol rod guide tube insert flexures inspection

and correction.

This resulted in the operation of Unit 2 for two cycles with

possible loose parts and degraded core components (paragraph 3.a}.

In the security functional area, a weakness was identified associated with the

operability* of some of the security equipment arid its possible impact on

operations (paragraph 3.d).

In the operations functional area, a str~ngth was identified regarding the

procedural controls associated with reactor coolant system reduced inventory

operations.

During a previous inspection (50-280,281/91-14), the inspectors

had jdenti_fied that numerous procedures were necessary to perform the reduced

inventory evolution.

Prior to entering. reduced inventory during this report

period, the licensee consolidated procedures and established a periodic check-

list to be used to evaluate reduced inventory operations (paragraph 3.f).

1.

Persons Contacted

Licensee Employees

REPORT'DETAILS

R. Allen, Supervisor, Shift Operations

W. Benthall, Supervisor, Licensing

  • R. Bilyeu, Licensing Engineer

.

. D .. Christi.a*n, Ass.istant Station Manager

.

J. Downs, Superintendent of Outage and Planning

D. Erickson, Superintendent of Health Physics

R. Gwaltney, Superintendent of Maintenance

M. Kansler, Station Manager

T. Kendzia, Supervisor, Safety Engineering

  • C. Luffman, Superintendent of Security
  • G. Marshall, Operations Maintenance Coordinator

J. McCarthy, Superintendent of Operations

  • A. Price, Assistant Station Manager
  • H. Royal, Supervisor, Nuclear Training
  • E. Smith, Site Quality Assurance Manager

T. Sowers, Superintendent of Engineering

  • G. Thompson, Supervisor, Maintenance Engineering
  • NRC Personnel
  • M. Branch, Senior Resident Inspe~tor
  • S. Tingen, Resident Inspector
  • J. York, Resident Inspector
  • Attended exit interview.

Other licensee employees contacted included control room operators, shift

technical advisors, shift supervisors and other plant personnel ..

Acronyms and initialisms used throughout this report are listed in the

last paragraph.

2.

Plant Status

Unit 1 began the reporting period in power operation. * The unit operated

  • at or about 100% power for the duration of the inspection period.* The

tu~bine control system cont~nued to be operated in manual due to problems

associated with the turbine main speed controls.

Unit 2 began the reporting period with startup physics testing in progress

and at approximately 30 percent power.

On June 11, 1991 the unit was

shutdown for repairs, due to* an unlatched control rod.

The licensee's

investigation and control rod repairs are discussed in section 3.a of this

report .. The unit returned to power on Ju~y 4 ..


2

3.. Operational Safety Verification (71707 & 42700) .

a.

Daily Inspections

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 were operable; and

review of* control room operator logs, operating orders, plant

deviation reports, tagout logs, temporary modification 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.

On June 8, the licensee notified the NRC residents that analysis of

the Unit 2~ cycle 11 flux map taken at approximately 32 percent power

inditated that the RCCA in core location F6 was fully inserted rather

than withdrawn to its _demand position .of 166 steps. The subject RCCA

is an interior D control bank control rod.

The flux map analysis

determined that the ~verage incore quadrant tilt was ll percent.

In

addition, the flux map indicated that the core peaking factors were

well within the TS limits.

Further analysis and testing resulted in

the conclusion that the RCCA in core location F6 was fully inserted

and unlatched from its driveshaft. . The control rod was declared

inoperable on June 8, and the unit operated at approximately 30

percent power under the requirements of TS 3.12 until the licensee

started ramping the unit down at 2305 hours0.0267 days <br />0.64 hours <br />0.00381 weeks <br />8.770525e-4 months <br /> on June 10.

The inspectors reviewed the safety evaluation* used to assess the

operation of Unit 2 with the control rod unlatched from its

driveshaft and for .support of a procedure change to insert the RCCA

driveshaft in core locatio"n F6 to a demand position of 80 steps

withdrawn.

The demand position of the D bank rods was approximately

170 steps .. The consequence of insertion of the driveshaft by normal

control rod insertion or by tripping the rod were considered in order

to determine what position the subject RCCA driveshaft should be left

at during interim power operation. Westinghouse. recorrnnended that the

driveshaft be inserted from its required bank position of 170 steps

to 80 steps withdrawn.

The basis -for this recommendation was that

significant cross flows are encountered in the control rod guide tube

below the BO-steps-withdrawn location.

The cross flows could cause.

lateral movement and vibration of the unlatched driveshaft and could

result in damage to the control rod guide tube, the driveshaft-or the

RCCA hub~

The basis for lowering the driveshaft to*80 steps, rather

than remaining at 170 steps was to limit the height of the drop in

the event of a reactor trip,- thereby limiting the force which could

be applied to the RCCA hub and fuel assembly.

3

After the unit was placed in cold shutdown and the reactor vessel

head was removed, the F6 drive rod was removed from the guide tube on

June 17.

The compo*nents of the guide tube were examined with a

remote camera for possible damage.

This examination revealed damage

on the si~th guide card from the top in the guide tube.

The damaged

guide card was evaluated as acceptable and should not impe~e the

movement of the F6 control rod after it was relatched.

To remove the F6 drive rod from the guide tube, the guide tube insert

must be removed from the top of the guide tube.

The insert is held

in pl ace by four fl exures.

During the remova 1 of F6 guide tube

insert, one of the fl~xures was broken off and another was bent.

Remote camera examination of this area on the guide tubes for the

other 47 control rod locations revealed bent or broken flexures on 11

control rod locations.

The worst case location had three broken

flexures.

All of the broken parts were recovered.

The inspectors reviewed the licensee's investigation of the damaged

control rod guide tube insert flexures.

Unit* 1 had exhibited a

similar problem durin~ an upper internals inspection in October 1984.

The licensee replaced the Unit 1 flexures with an improved design and

Westinghouse performed a safety -evaluation for the continued

operation of Unit 2 with possible failed control rod guide tube

flexures.

This evaluation* concluded that even with a 100 percent

failure of the guide tube fl exures * and_ the loose parts they might

generate, Unit 2 could continue operation without creating the

possibility of a new accident or increasing the probability or

consequence of a previously evaluated accident.

In a letter dated June 25, 1991; Westinghouse stated that they had

reviewed the 1985 safety analysis and that it was still valid to

,support Unit 2 startup without replacing the recently identified

failed flexures.

During a conference call on Jun~ 27, 1991, bet~een

the licensee, Westinghouse, and the NRC, discusstons were held con-

cerning the defective flexures and Westinghouse's safety analyses. A

consensus was reached that operating the unit without repairing or

replacing the guide tube insert flexures was acceptable.

However,

the NRC requested additional information from Westinghouse for a

generic applicability review.

The inspectors * noted that the 1985 safety evaluation performed by

Westinghouse to support Unit 2 operation restricted the analysis to

the end of cycle 8 .. * At that time it was expected that an inspection

of the Unit 2 condition would have occurred and the flexures would

have been reevaluated or replaced.

At the time of discovery of the

recent failures, Unit 2 was starting up from cycle 11 refueling and

the inspections or replacements had not occurred.

The licensee was

unable to explain how the internal commitment to inspect Unit 2

during cycle 7 or 8 outage was missed.

The failure of the licensee

to control a condition of the original safety evaluation resulted in

4

operation of Unit 2 for two cycles with .possible loose parts or

degraded core components and is considered.a weakness.

The inspectors reviewed the licensee's 10 CFR 50.59 analysis as*well

as the core inspection results.

With exception of the weakness

discussed above no additional problems were identified.

b.

Weekly Inspections

c.

The inspectors conducted weekly inspections in the following areas;

operability verification 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, missile

hazards, and plant housekeeping conditions/cleaniness.

The

insp~ctors routinely noted the temperature of the AFW pump discharge

piping to ensure increases in temperature were being properly

monitored and evaluted 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 implemenation

of the plant problem identification system; verification of selected

portions of containment isolation lineups; and-verification that

notices to workers are posted as-required by 10 CFR 19.

During review of control room logs for June 15, the inspectors noted

that operations personnel had found the reactor head vent valve

2-RC-36 closed.

This valve was required to be open to ensure

accurate RCS standpipe level indication whenever RCS level was below

the range of the pressurizer level instrument.

The licensee

documented the configuration problem on DR S-91-0941.

The initial

investigation indicated that the valve had been closed by a -

contractor personnel working on the reactor vessel head.

The

licensee indicated that the person involved was interviewed. and

counseled.

Additionally, the licensee indicated that other valves in

the area were checked and no Other out-of-position valves were found.

The inspectors monitored the RCS fill and vent on June ~8 and July 1 .

. The inspectors monitored procedure use and operator performance

  • during these evolutions.

The

procedures monitored and the

inspectors comments are as follows:

5

(1)

2-0P-5.1.1, Filling The Reactor Coolant_ System, dated May 10,

1991..

This procedure was recently rewritten to the new format and

incorporated several industry recoll'D"llendations for criticality.

control associated with dilution.

The procedure had been

verified and validated by operations personnel as required by

the procedure development process.

During performance of the procedure on June 28, the inspectors.

noted that the CRO. was not marking the.SR flox charts at the 15

and 30 minute intervals as required .by step* 5.11.3 of the

procedure.

The audible SR indication was working at the tim~ of

the :fill.

The inspector questioned the SS as to why this was

not being performed and the SS indicated that they had not

realized that the new procedure required that action.

The SS

indicated _that*the control room had received the procedures just

prior to performance and were not familiar with the changes.

Technical Specifications 6.4.A and 6.4.D requires, in part, that

detailed written procedures with appropriate check-off lists. and

instructions be provided and that these procedur~s be followed.

Procedure 2-0P-5.1.1 was .not followed during loop filling, in

that step 5.11.3, associated with marking SR indication every 15

and 30 minutes was not being performed.

Failure to follow

procedure 2-0P-5.1.1 is identified as the first example of a

violation,

50-280,281/91-18-0l,

Operational

Procedure

Adherence/Adequacy, with Three Examples.

A det~iled review of procedure 2-0P-5.1.1 indicated an

additional

problem associated with

procedure

quality.

Specifically, step 5.2 contains the following caution~

(

11CAUTION

11

The loops should not be isolated for the fill.

Filling with the loops -unisolated ensures that the boron

concentration in the reactor vessel and loops will be equal).

This caution was fol.lowed by steps 5.2.1 through 5.2.6 which

requires a verification that the loop isolation valves are open.

However, each of the steps state that if the valves are closed

then N/A the step.

This process basically removes the caution

from the procedure.

Procedure 2-0P-5 .1.1 dated May 10, 1991 was

not adequate, in that the caution associated with having the

loop stop valves open during RCS filling is circumvented by

the procedure option to N/A steps 5.2.l through 5.2.6 associated

with yerificatidn that the valves are o~en prior to filling.

Failure to provide an adequate procedure for control of loop

stop valve position is identified as the second example of

a violation,

50-280,281/91-18-01,

Operational

Procedure

Adherence/ Adequacy, with Three Examples.

The inspection did

note that for the RCS fil1 being performed the valves were open

and the intent of the caution was accomplished.

(2)

6

.

.

2.:.oP-5.1.2, Venting the Reactor Coolant. System, dated May 10,

1991.

This proc~dure was also a newly developed procedure and had been

verified and validated by operations.

This procedure, as well

as procedure 2-0P-5 *. 1.1 discussed above, contained precautions

and limitations that allowed the SS to authorize alteration of

sequence and to N/A portions as required.

On July 1, operations* personnel had elected to use proce.dure

2-0P-5.1.2 to start a RCP.

The procedure had been performed i.n

its entire~y earlier for system venting and the operator was

utilizing only the steps in the procedure associated with

starting the RCP.

Prbcedure 2-GOP-1.1, Unit Startup, RCS Heatup

From Ambient To 195 degrees F, dated May 24, 1991 was also being

used in parallel with 2-0P-5.1.2.

The inspector noted that

procedure 2-0P-5 .1. 2 contained two precautions that were not

being followed.

Specifically, precaution 4.4 required that the

. red tag not b~ removed fr6m the RCP breaker until just before

starting the RCP and precaution 4.5 prohibited starting a second

RCP with one a 1 ready running. ,However, the inspector observed

that all three RCP red tags had been cleared with the bfeakers

racked in ind the operator was starting a second RCP with one

already running.

The inspector questioned the SS as to what

procedure was in effect and if it was acceptable to perform the

evolution in the manner described above.

The SS indicated that the precaution associated with the red

tags was N/A since it had been previously performed.

The SS

also informed the inspector that he had exited procedure

2-QP..:5.1.2, which prohibited running two RCPs by applying N/As,

and had entered procedure 2-GOP-1.1 which did not prohibit

running two p_umps simultaneously.

The inspector

discussed

these concerns with the* Superintendent of Operations and the

author of 2-0P-5 .1. 2 to determine the acceptabi 1 i ty of the

practice and the basis for the precautions.

The procedure author indicated that the basis for the precaution

of starting a second RCP with one running was for reactor

overpressure concerns when the plant is in a water solid

condition, i.e., no bubble in the pressuriz~r~

The basis for

the red tag precaution was to prevent inadvertently starting a

pump prior to ensuring that the RCS had been filled and pressur~

ized.

Starting a second pump during this evolution did not

result in system overpressurization.

The Superintendent of Operations indicated that he would check

with the NSSS on the acceptability of the practice of starting a

7

. second RCP in a water solid condition. _ He also indicated that

  • since 2-GOP-1.1 did not specifically prohibit the operation of

two pumps, the second pump was- started to increase the heatup

rate to expedite the startup schedule *.

The inspector revi~wed the basis for the cold overpressure TS

(3.1.G) to determine if it specifically prohibited the operation

of more that one RCP in a water solid condition.

The basis

indicated that the size of a single PORV could protect the

reactor vessel from over pressurization when the transient is

limited 'to either (1) the start of an idle RCP with the

secondary water temperature of a sG*less than or equal to 50

degrees F above the RCS cold leg temperature or (2) the start of

a charging pump and its irrjection into a water solid RCS.

The

basis did not discuss the acceptability of operating more than*

one RCP while in a water solid condition.

The inspectors also reviewed procedure O-DRP-004, Precautions,

Limitations and Setpoints, dated October 16, 1990.

Section 5.4

of that procedure contained many precautions a~sociated with the

RCS system, one that is directly related to this issue.

Precaution 5.4.17 indicated that if all RCPs have been idle for

more than five minutes and RCS temperatu~e is greater than the

charging* and seal injection water temperature, the first RCP

should not be started until a steam bubble has.been formed in

the pressurizer.

The precaution further stated that the ~team

bubble will minimize the pressure transient when the.cold water,

which was previously injected into the loop, is circulated and

rapidly heated.

Procedure 2-0P~5.1.2 dated May 10, 1991 was not

properly implemented,. in that precauti ans associated with

clearing RCP red tags and starting a second RCP with one pump

already running during water solid plant operations were not

adhered to.

Failure to follow procedure 2-0P-5.1.2 is identi-

fied as the third example of a violation, 50-280,281/91-18-0l,

Operational Procedure Adherence/Adequacy, with Three Examples.

Additionally, the inspector used Station Admi ni strati ve Procedure

VPAP-501,

Procedure

Admi ni strati on

Centro l

Program,

dated

February 25, 1991 as a basis for determining program compliance.

Section 6~7.2, entitled Procedure Adherence, requires that procedures

be followed.

The procedure also allows the use of ~/As to complete a

procedure, if specifically allowed by the procedure or if it is

obvious to the supervisor.

The latter case, requires the procedure

to be noted as to why the steps are not applicable.

However,

VPAP-501 does not allow a procedure, written for a specific

evolution, to be used as guidance or to be selectively applied by

ignoring prerequisites, initial conditions, or precautions .

8

d.

Physical Security Pr~gram Inspections

e.

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 including: * protected and vital areas access .

  • controls*; searching of personnel, packages and vehicles; badge

issuance and retrieval; escorting of v.isitors; and patrols and

compensatory posts.

The following conditions were noted:_

During the inspection period, the inspectors noted that the

1 icensee 1 s security group was having *to compensate for degraded

security equipment.

This condition existed for most of the

inspection period, and involved*mainly access control equipment.

The

licensee explained that problems had been experienced with outdated

equipment and plans were being made to upgrade.

The inspectors also

noted that the egress control equipment intended to detect unknowing

badge removal was not working.

The licensee indicated that the

equipment would be removed and that the posted officer as well as the

exiting employee would be relied on to ensure compliance.

Additionally, the inspectors noted that on one occasion the entrance

portal was control led by a single officer. _ This individual was

trying to monitor the X-Ray as wel 1 as ensure proper use of the

explosive and metal detectors.

Once noted, the licensee took prompt

and effective corrective action. A related issue involving security

equipment was also identified by the inspectors.

Specifically,

during times of continued use of the security computer for printouts

and personnel accountability the access to several areas of the plant

is greatly delayed.

This condition could complicate area accessi-

bility during an emergency and may delay operator followup of operat-

ing transients. Operations personnel can use emergency keys to gain

access to these areas.

However, the operators do not routinely carry

these keys and would have to return to the tontro l room or ca 11 *

security for access.

Licensee 10 CFR 50.72 Reports

On June 24, at 1245 hours0.0144 days <br />0.346 hours <br />0.00206 weeks <br />4.737225e-4 months <br />, the licensee reported to the NRC that at

about 1400 hours0.0162 days <br />0.389 hours <br />0.00231 weeks <br />5.327e-4 months <br /> on Sunday, June 23i a 12-year old *boy drowned in the *

station discharge canal.

The licensee indicated that the boy was

fishing with relatives prior to slipping into the water and had

climbed past signs and around a fence that prohibited entry into the

area. This area was within the owner controlled area, but outside the

protected area.

The body was recovered at about 2200 ho_urs on

June 23.

f.

Reduced Inventory Conditions - Unit 2

On June 25, Unit 2 entered a reduced inventory condition in order to

replace check valve 2-SI-79.

This valve is the loop A cold leg high

and 1 ow head* safety injection check valve and was i den ti fi ed as

.g

having excessive seat leakage.

Repair of fhjs valve is discussed in

paragraph 4.b.

Prior to entry into the condition, the inspectors

conducted a review of the licensee's implemented actions with regards

to- the requirements of GL 88-17, Loss of Decay Heat Removal.. No

discrepancies were noted during the review.

The specific items

reviewed were: *

GL 88-17 ~ The inspectors reviewed the subject letter including

the licensee I s response* to the letter dated January 6, 1989,

with supplemental responses dated February- 3, September 29, and

October 31, 1989, and October 5, and November 16, 1990. *

Administrative Controls - The inspectors discussed controls and

procedures in affect to control reduced inventory operation with

operations supervisory personnel.

In addition, the governing

document for reduced inventory, 2-0P-3.4, Draining the Reactor

Coolant System, dated June 13, 1991, required a pre-job briefing

to ensure that operations personnel were aware of the required

controls and procedures.

Containment Closure Activity -

The licensee's procedures

required that the status of the containment configuration be

established and verified prior to entering a reduced inventory

condition.

In addition,-_ the proJ:edure for loss of RHR

capability directed containment closure action be initiated and

continued until the RHR system is returned to service and normal

core conditions are verified. *The inspectors verified that the

licensee has prepared procedures to. reasonably assure that

containment closure would be achieved prior to the time when

core uncovery could occur.

RCS Temperature - The inspectors verified that the controlling

procedure for draining the RCS, 2-0P-3.4 required at least two

operable incore temperature indicators, one from each ICCM

train, prior to draining the RCS to a reduced 1nventory

condition.

The ICCM provides continuous indication of incore

temperature.

RCS Level Indication - The licensee has installed two means of

level indication which provide continuous readout in th~ control

room.

Both systems are calibrated and provide a low level alarm

for loss of level. - Procedure 2.;..QP-3.4 also requires that an.

operator be stationed at the reactor vessel standpipe to monitor

level locally during the draining evolution.

RCS Perturbations - The inspectors verified that the licensee's

procedure, - OC-28, Assessment of Maintenance Activities for

Potential Loss of Reactor Coolant Inventory, dated January 22,

1991, required operations assessment of work on systems for

po ten ti al. 1 oss of reactor cool ant inventory during reduced RCS

inventory conditions.

No. maintenance other than 2-SI-79 was

10

planned that could affect reactor coolant inventory during this

reduced inventory evolution.

RCS Inventory Addi ti on - The inspectors verified that procedure

2-0P-3.4 required at least two available and operable means of

adding inventory to the RCS in addition to the RHR system.

The

procedure requires that .in a reduced inventory condition, one

charging/safety injection pump and one low head safety injection

pump must be available wtth. appropriate flowpaths to the core.

Loop Stop Valves - The licensee util_izes RCS loop isolation

valves for loop isolation.

Nozzle dams are not used.

During

the reduced inventory evolution, the licensee ensured that the

reactor vessel was adequately vented by maintaining all three

loops unisolated with their loop bypass valves open.

Contingency Plans to Repower Vital Busses - The Unit 2 vital and

emergency electrical distribution system receives offsite power

. from the B and C reserve station servict;! transformers during

normal plant operations. The RHR pumps and the. CC_W pumps (which

cool .the RHR heat exchangers) operate off stub busses attached

to the 2J and 2H emergency buss es.

The stub busses are shed

during degraded or uridervoltage situations, but can be

reconnected to the emergency busses by closing a breaker.

The

equipment for the two additional means for adding inventory to

the RCS, the charging pumps and the low head safety injection

pumps, are powered off the 2H or 2J emergency buss es.

During

normal operations, the number 2 EDG supplies power to the 2H

emergency bus in case of a degraded or undervoltage situation,*

and the number 3 EOG supplies power to the 2J bus.

During this

period, the licensee had the B and C reserve station service

transformers powerihg. the emergency busses, and the number 2 and

3 EDGs avaiJable as emergency power sources.

.

.

The 1 icensee* completed the replacement of check valve 2-SI-79 on

June 28, and commenced RCS filling.

Reduced inventory was exited at

1130 hours0.0131 days <br />0.314 hours <br />0.00187 weeks <br />4.29965e-4 months <br />.

During reduced inventory opera ti ans the equipment

performed as expected and the operators were aware of plant and

equipment status at all times.

A strength regarding the procedura 1 controls associated with RCS*

reduced inventory operations was identified.

During a previous

inspection (50-280,281/91-14), the inspectors had identified that

numerous procedures were necessary to perform the reduced inventory

evolution.

Prior to entering reduced inventory during this report

period, the 1 i censee con so 1 i dated procedures and es tab 1 i shed a

periodic checklist to be used to evaluate reduced inventory

operations.

Within the areas inspected, one violation with three examples was

identified ..

. ,*

11

4.

Maintenance Inspections (62763 & 42700)

During. the reporting period, the inspectors reviewed maintenance

activities to assure compliance with the appropriate procedures.

The following maintenance activities were reviewed:

a.

Repair of Drain Line From Regenerative Heat Exchanger

This leak rate was confirmed by additional leak rate calculations

with similar results.

A w~lkdown of containment revealed the leak

was located in the regenerative heat exchanger room on a drain line

tee.

Opera tors isolated the leak and thus al so the RCS letdown fl ow

path until the repair could be made.

After draining the line, it was purged with nitrogen to give a

backing gas for welding.

Dye penetrant inspection indicated a pin

hole in the tee-to-pipe socket weld.

The repair was performed using

work request No. 3800112835.' The weld defect was removed by grinding

and removal was assured by dye* penetrant inspection.

The area was

then repaired using shielded .metal arc welding (welding procedure

technique No. PlOl-803) and austenitic stainless steel weld metal

E-308; heat No~ 04828-05-01.

Mechanical corrective maintenance

procedure MCM-1801-01, Piping/Components Repair/Replacement~ Rev. 2,

dated February 27, 1990, was used. * Visual and dye penetrant inspec-

tions were performed on the repair.

Operators returned the normal

RCS 1 etdown fl ow path to service and observed that there was no

leakage in the area of the repair.

The inspectors reviewed the documentation for the repair and the

welder qualifications. The weld filler metal qualification cduld not

be located at the time of the inspection, but will be reviewed during

the next inspection period.

b.

Repair of Check Valve 2-SI-79

The inspectors followed the replacement of check valve 2-SI-79. This

valve had exhibited a leak in excess of 20 gpm when tested at 300

psig.

The licensee decided -to replace the check valve when

disassembly and inspection revealed no obvious cause for the leakage.

Work order No. 3800112591 and mechanical maintenance procedure No.

MCM-1801-01, Piping/Components Repair/Replacement,* dated February 27,

1990, were utilized for the replacement.

The inspectors reviewed the tagout items and the weld travelers.

Gas

metal arc welding process was used with QC inspecting the* fit up and

root pass.

The licensee performed visual and radiographic inspection

on the root pass with dye penetrant and radiographic inspection being

performed on the completed weld. * One-eighth inch diameter ER-316

sta-inless. steel weld wire, heat Nos. 26568 and CT. 5839, was used.

12

The inspectors reviewed the material test .reports against the

appro~riate ASME Code sections. The sy~tem hydrostatic test for thi~

  • replacement was performed to the requirements of Table IWB-5220-:-l of

Section XI of the ASME Code.

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.

Procedures satisfied the surveillance requirements.

Adequate coordination *existed among personnel involved in the test .

Test data was properly collected and recorded *

The following surveillances were either reviewed or observed:

a.

Motor Driven AFW Pump Testing

On June 24, the inspectors witnessed the performance of periodic test

1-PT-15.18, Motor Driven Auxiliary Feedwater Pump 1-FW-P-38, dated

February 14, 1991.

The purpose of this test was to demonstrate

operability of pump l~FW-P-3B.

The inspectors observed parts of the

performance of this test from both the safeguards area and the main

contra 1 room.

The results of -the test were reviewed by the

inspectors and no discrepancies ~ere noted.*

b.

Section XI Pump Testing Program

On May 30, 1991, the licensee informed the inspectors that the flow

instrumentation used for testing pumps in accordance with the Surry

ASME Section XI pump test program may not meet the code-required+/-

2 percent accuracy.

The licensee had committed to install many new

flow instruments during the refueling outage to satisfy code require-

ments and believed that th~ instruments were in compliance with the

code accuracy requirements when a previous code relief, associated

with instr_ument accuracy, was allowed to expire.

The licensee described their interim corrective actions to evaluate

the affected equipment operability as follows:

13

(1)

Add the worst case instrument unc:ertainty to each affected

instrument loop and then verify that pump operability was still

valid.

(2) Evaluate the actual instrument loop accuracy and determine if .

the 2 percent unce.rtainty was exceeded for any of the equipment.

(3) Change

the calibrati6n procedures and recalibrate the

instruments prior to the next scheduled pump performance test.*

( 4)

Inform the NRC of any. cases where the actua 1 1 oop accuracy

exceeded the required 2 percent value and to request code relief

if required.

On June 3, the licensee submitted the results of their initial

review.

This review indicated that pump operability was evaluated by

applying the maximum potential loop uncertainty of between 2.5 and

3.19 percent to the last pump performance test.* The licensee's

submittal indicated that in each case the measuted flow rate remained

above the Action Level" per ASME Section XI.

The .licensee further

indicated that the impact of the actual loop uncertainties would be

reviewed and if the value exceeded the required 2 percent limit, a

specific interim relief request for each affected pump would be

submitted.

On June 7, the licensee submitted their interim relief request.

In

that request, the 1 icensee. indicated that 12 instrumen.t loops

exceeded the ASME Section *x1 required 2 percent accuracy requirements

at the time that they were used to verify pump performance.

The

systems involved included RHR, ISRS, AFW, CCW, LHSI and SW and

therefore the requirements of TS 4.0.3 were violated since pumps in

these systems are required to be tested with instrumentation that

satisfies the ASME Section XI accuracy requirements.

On July 1, the licensee submitted LER 91-010 to document the above

violation of TS 4.0.3.

The inspector reviewed the licensee actions

associated with this event as well as the information provided in the

LER.

The LER attributed the cause of the violation to interface

problems between project engineering and the organization that was

performing the instrument calibration.

The design engineer's

assumptions, associated with instrument and calibration tolerances,

were not communicated to the implementing organization.

The above condition, which was discovered by the* licensee, is

identified as NCV 50-280,281/91-18-02, Failure to Ensure Implementa-

tion of Design Outp~t.

This licensee identified violation is not

being cited because the ~riteria specified in Section V.G.1 of the

NRC Enforcement Policy were satisfied.

.

I

14

6.

Exit Interview

The inspection scope and results were summarized on July- 9, 1991 with *

those individuals identified by an asterisk in paragraph 1. The following

summary of inspection activity was discussed by the inspectors during this

exit.

Item Number

Description and Reference

VIO 50-280,281/91-18-01

Failure to follow or provide adequate

procedures with 3 examples, (paragraph 3~c).

NCV 50-280,2~1/91-18-02

Licensee identified violation for a failure

to ensure implementation of design output

associated with ASME Section XI instrument

accuracy, (paragraph 5.b).

The licensee acknowledged the inspection conclusions with no dissenting

comments.

The 1 i censee did not i den ti fy as proprietary any of the

materials provided to or reviewed by the inspectors during this

inspection.

7.

Index of Acronyms amd Initialisms

AFW

ASME

ccw

CFR

CRO

DR

EOG

ESF

F

GPM

GL

ICCM

ISRS

LER

LCO

LHSI

N/A

NCV

NRC .

NRR

NSSS

PSIG

. PORV

QC

RCCA

RCP

RCS

AUXILIARY FEEDWATER

AMERICAN SOCIETY FOR MECHANICAL ENGINEERS

COMPONENT COOLING WATER

CODE OF FEDERAL REGULATIONS

CONTROL ROOM OPERATOR

DEVIATION REPORT

EMERGENCY DIESEL GENERATOR

ENGINEERED SAFETY FEATURE

FAHRENHEIT

GALLONS PER MINUTE

GENERIC LETTER

INCORE COOLING MONITOR

INSIDE RECIRCULATION SPRAY

LICENSEE EVENT REPORT

LIMITING CONDITIONS OF OPERATION

LOW HEAD SAFETY INJECTION

NOT APPLICALBLE

NON-CITED VIOLATION

NUCLEAR REGULATORY COMMISSION

NUCLEAR REACTOR REGULATION

NUCLEAR STEAM SYSTEM SUPPLIER

POUNDS PER SQUARE INCH

POWER OPERATED RELIEF VALVE

QUALITY CONTROL

ROD CLUSTER CONTROL ASSEMBLY

REACTOR COOLANT PUMP

REACTOR COOLANT SYSTEM

  • '
  • I

RHR

SG

SI

SR *

ss

SW

TS

VPAP

  • -

15

RESIDUAL HEAT REMOVAL

STEAM GENERATOR

SAFETY INJECTION

SOURCE RANGE

SHIFT SUPERVISOR

SERVICE WATER

TECHNICAL SPECIFICATIONS

VIRGINIA POWER ADMINISTRATIVE PROCEDURES