ML18153C967

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Insp Repts 50-280/92-04 & 50-281/92-04 on 920202-0307. Violations Noted.Major Areas Inspected:Operations,Maint, Surveillance,Quality Verification & Safety Assessment Review,Independent Plant Evaluation & Licensee Event Review
ML18153C967
Person / Time
Site: Surry  Dominion icon.png
Issue date: 03/26/1992
From: Branch M, Fredickson P, Tingen S, York J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML18153C965 List:
References
50-280-92-04, 50-280-92-4, 50-281-92-04, 50-281-92-4, NUDOCS 9204140048
Download: ML18153C967 (18)


See also: IR 05000280/1992004

Text

UNITED STATES.

NUCLEAR REGULATORY COMMISSION

REGION II *.

101 MARIETTA STREET,N.W.

ATLANTA, GEORGIA 30323

Report Nos.i * 50-280/92-04 and 50~281/92~04

License~: *. Virginia Electric and Power Company

5000 Dominion Boulevard

~len Allen, VA* 23060

Docket Nos.:

50~280 and 50-281

Facility Name:

Surry 1 and 2 *

License Nos.:

DP~-32 and DPR-37

Inspection Conducted:

February 2 through March 7, 1992.

Inspectors:

M. ~ikident Inspector

a~~**

-3. L-/ff2

. .0'a~i gned

3.&~d~

Dci'te S"i gned

s iclen tinspec tor

~~~~~.L-.--,--~---.:... 30,:/9 .

DfuSign~

Approved by:

SUMMARY

Scope:

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

operations,* maintenance, surveillance, quality verification and safety

assessment review, independent plant evaluation, and licensee -event *review.

During the performance of this inspection, the resident inspectors conducted

reviews of the licensee's backshift or weekend pperations on February 2; 13, 16,

17, 19, 23, March 1, 3, 4, and 5, 1992.

Results:

In the operations area, the follow,ng items were noted:

A weakness was identifi~d in that~ procedures do not recognize the

manual mode of operation of the ventilation system (paragraph 3.a).

The .ability to trend hours spent in action statements will.

significantly enhance the licensee's ability to focus on problem areas

(paragraph 3.e).

Housekeeping throughout the plant is generally good (paragraph 3.c).

9204140048 920326

.PDR

ADOCK 05000280

G_

. ____!:PR __

2

In the maintenance/surveillance area, the follo.wi.ng items were noted:

Planning and implementation of the switchyard CT replacement (paragraph

  • 3.b) demonstrated the following:.

Coordination of many parallel and series ictivities as well as the

regulatory awareness was observed as a strength *

  • - The switchyard design does not allow for normal preventive and

corrective maintenance of some switchyard- equipment .

. Th~ failure to provide adequate procedures to calibrate the station

blackout motor driven AFW. pump start relays and to test the T average

port of the ESF*logic circuits a~e non-cited licensee identified

. violations -u,aragt:"aphs _10.a and b). *

. . .

The ESF logjc testing observed was well coordinated and ~eceived ~ high

level of management attention as evidenced by assignment of the Senior

Operations Mana~er to this infrequent task (paragraph 4.b).

In the SA/QV area, the following items were noted: .

. The TS and FSAR failure to describe the ventilation systems .manual mode

of operation was identified *as a weakness (paragraph 8) .

. The *corporate IR, IDER,. and CNS assessment. and event review programs

~ere found to be effective and met TS requirements (paragraph 6).

The failure to properly correct HHSI *pump lube oi"l temperature control

valve deficiencies is identified as a violation and weakness

(paragraph 3.g}.

REPORT.DETAILS

1.

Per~ons Contacted

Licensee Employees

  • W. Benthall, Supervisor, Licensing
  • R. Bilyeu, licensing Engfneer

H. H. Blake, Nuclear Safety

  • D. Christian,:Assistant Station Manager

J. Downs, Superintendent_of Outage and Planning

  • A. Fletcher, Assistant Superintendent of Engineering
  • R. Gwaltney, Superintendent of Maintenance
  • D. Hart, Supervisor,.Quality Assurance

M. Kansler, Station Manager

  • J. McCarthy, Superintendent of Operations
  • K~ Moore, Vice President-Nuclear Engineering Servites
  • A. Pri~e~ Assistant Station Manager
  • R. F. Saunders, Assistant Vice President.;.Nuclear
  • S. Semmes, Senior Staff Engineer
  • E. Smith, Site Quality Assurance Manager

T. Sowers, Superintende~t of Engineering

NRC Personnel

  • M. Branch, Senior Resident Inspector*
  • S. Tingen, Resident Inspector
  • J. York~ Resident lnspect6r
  • Attended exit interview.

Other licensee employees contacted included control room operators, shift

techni~al advisors, shift supervisors and other plant personnel.

Acronyms and initial isms used throughout this report .*are listed in the -

last paragraph.

2.

Pl ant Status

  • ,

Unit 1 began the reporting period at 97 percent power.

On* January 30,

1992, coastdown began and on February 29, the unit was shutdown from 73

percent _power to, begin_ a* s~heduled 64-day refueling outage.

Unit 2 began the reporting period in power operation.

The unit was at

power at the end of th~ inspection period, day 80 of continuous operation.

2

3.

Operational Safety Verification (71707,42700~37828)

The inspectors conducted frequent tours of the* control * rooni to verify

proper *staffing,. operator attentiveness and aqherence to approved

procedures.

The inspectors ~ttended plant status meetings and reviewed

operator logs on a daily basis to verify operations safety and compliance

with TS and * to maintain awareness of the overall operation of the

. facility.

Instrumentation and ECCS lineups were periodically reviewed

from control- room indication to assess operability.

Frequent plant tours

were conducted to_ observe equipment status, ffre protection programs,

_ radiological work practices, plant security programs and housekeeping.

Deviation reports were reviewed_ to assure that potential safety concerns

-were properly addressed and re~orted.

a~

Operation Of Th~ Ventilation System

The inspectors reviewed the various operational modes for the

emergency ventilation system.

When both units are operating at

power, the ventilation system will automatically realign when an SI

signal occurs in either unit_.

When .the ventilation system realigns,

the areas that contain ECCS pumps are exhaust~d through filters to

remove fission products and _provide cooling for pump motors.

In

addition, ventilation to the non-~CCS areas is ~ecured, and

ventilation is p~ovided for the operating charging ~ump in the other

unit.

When one unit is operating and the other unit is moving fuel,

the ventilation system is aligned _such that the primary objective is

to ensure that the fuel building and containment exhaust is

discharged through filters.

In the ventilation system's*refueling mode alignment, if an SI stgoal

occurred in the operating unit, the ventilation system would not

automatically realign to the SI mode of operation. It would remain in

the refueling configuration. - Operators would be required to place

the fuel in a safe condition and then manually realign the

ventilation system for the SI mode of operation.

Step 18 of EP

1-E-O, Reactor Trip or Safety Injection, dated January 16, 1992,

provides instructions for realignment of the ventilation system when

in the refueling mode of operation.

Operators estimated that it

would take approximately five minutes to pl ace the fuel in a safe*

condition and realign the ventilation system if required.

The

ventilation system can be realigned.from the control room.

The inspectors reviewed DC 78-S34, Auxilary Ventilation System,

dated *April 27, 1979.

This DC was implemented in. 1980 and

significantly modified the ve*ntilation system.

One of the

ventilation system changes implemented by DC 78-S34, added the need

to manually realign the system as previously discussed.

Prior to

1980, the ventilation system would automatically realign on recei~t

of an SI signal during the movement of fuel in the ~ther unit.

The

safety analysis performed for DC 78-S34 recognized this change of

b.

3

operation and cohsidered it acceptable.

The safety evaluation, dated

January 17, 1984, performed by the NRC staff for amendments 91 and 92

to the operating l i cense, approved this . method of operation.

The

licensee stated that*the offsite dose during a refueling accident was

significantly higher if the ventilation system exhaust was not

filtered; however, not filtering the exhaust from ECCS areas during

the first twenty minutes following a LOCA had only a minor effect on

the off-site dose. *

.

.

The inspectors reviewed section- 3.22 of the TS and FSAR chapters 5~3

and 9.13 in order determine if the ventilation system was required to

realign automatically or manually upon receipt of an SI signal during

the movement of fuel.

The FSAR only discussed the automatic features

of the system and did not describe the need to manually realign the

ventilation system in the event of an SI signal in one unit when

  • moving fuel in the other unit. The TS did not state that the system

was required to be a~tomatic, but the basis section did de~cribe the

system as automatic.

The TS and FSAR failure to describe . the

ventilation systems manual mode of operation was identified as a

weakness.

The inspectors noted another example where *the emergency ventil ati_on

system was aligned such that manual action was required if the system

was required to .respond to an SI. :During this inspection period,

operators placed the controllers-for the emergency ventilation fans

from automatic to manual. In this -alignment, operators would have to

make ventilation system flow rate adjustments during an SI wh_ere

normally the flow* rate is automatically adjusted~

Also, this

alignment increases the potential for a fan to tri~ due to excessive

fl ow rates.

Procedures do not recognize this a 1 ternate mode of .

opera ti on.

This is considered a weakness because procedures should

alert the operators that additional precautions are invoked when in

this configuration.

Opera.ti onal Activity Associated With The Replacement of Swi tchyard

Bus #5 Current Transfonner.

-

On February 28, the licensee replaced ~ current tran~former on one

of the three phases *of bus #5.

This activity involved several TS

action statements and was closely observed by the inspectors.

Switchyard bus #5 supplies power to 2 of .the 3 RSSTs, A and B.

The A

RSST provides off-site power to emergency bus 1-J and the B RSST

provides off-site power to the 2-H emergency bus.

The CT which provides protective and metering_ functions for the

34.5kva/120 vac was noted as having a low fluid level and was leaking

fluid.

The licensee postulated that failure was eminent.

Failure

would cause an unplanned loss of 2 of.the 3 RSSTs which has in the

past _resulted in turbine runbacks due to !RPI power spikes.

Also,

the failure would affect both units and challenge the fast start of 2

4

of_the 3 EDGs .. Several TS action statements impa~t taking the CT

and bus #5 out-of-service:

.

-

TS 3.*9

11Station Services Systems" requires that the 4160

emergency buses to beenergized as explained in TS 3.16

TS 3.16

11Emergency Power System

11

requires two EDG to be

operable, two emergency buse.s energized-, and two independent

offsite circuits to energize the 4160v buses.

TS 3.16.B.2

_

  • allows the primary source of offsite power to be unav_ailable for

up to seven* days as long as back-feed capability exists.

TS 3.16.B requires that the EDGs be 6p~rable when offsite power

i-s degra_ded (i.e. 3.16.B only allows 3.16.B.1 or 3.16.B.2).

-.

TS 3.0.2,

11Limiting Conditions For Operation

11 specifies that_if

the emergency power supply for equipment on one train is

inoperable that the normal and backup power supplies for the

other equipment must be operable.

The licensee decided to replace the defective CT prior to Unit 1

shutdown with both uni ts at power with the lJ and 2H * emergency

buses being powered by the #3 and #2 EDGs.

Leaving Unit 1 on .

line allows for emergency backup power by backfeeding the

emergency buses if necessary from the station* service trans-

formers.

During the 6-8 hour time that bus #5 would be unavai 1-

abl e, primary offsite *power and

EDG alignment would be as

follows:

RSST A would be deenergized.-

RSST B would be deenergized.

RSST C would be energized.

EDG#3 wi 11 be in standby for the lH bus.

EDG#2 will be running and s~pplying power to the 2H bus.

EDG#3 will be running and ~upplying power to the lJ bus.

EDG#3 is the swing EDG and would not be 100 p_ercent operable to

supply the Unit 2J bus in an emergency.

It would swap to the 2J

bus on an ESF signal, but would not on degraded or under voltage

conditions.

The above offsite pow~r alignment and EOG availabilitj for the 2J bus

would result in violation of TS 3.16.& and, therefore, TS 3.0.1 rir

3.0.2 wo~ld apply.

To replace the CT with both units ai power would

require entry into TS 3.0.1 if it could be accomplished within the

  • time allowed by TS 3.0.1. .However, the licensee determined that

based on their estimates the repair would take longer then allowed by

IS 3.0.1 and would require a waiver of compliance .

  • -*

5

On February 28, at 1236, TS 3.0.1 LCO was entered and the repairs to

switchyard bus #5 b~~an.

The inspectors monitored the establishment

of the required electrical alignment, bri~fing of the shifts, and

starting of and operational parameters for the #2 and #3 EDG's. The

licensee used te_mporary maintenance operating procedure No. TMOP-312,

Removal From Service of 34.5 KV Bus #5, dated March 2, 1992.

The-

.. inspectors made several trips to the switchyard and verified that

swi tchyard access was under control of the security department and

that bus #6 had access restricted by barriers.

The inspectors

observed the removal and replacement of the defective CT and the

inspection of the other two CTs which were found to be acceptable.

The inspectors also monitored* the* restoration of the plants

electrical systems after replacement of the CT.

The actual time

spent in the action of TS 3.0.1 was such that the waiver of*

compliance was not needed.

However, the provisions in the licensee's

written request for TS waiver, dated February 28, were verified by

the inspectors.

The NRC acknowledged the waiver request in a March 2

letter from the Region II Regional Administrator to the Senior

Vice-President, Nuclear. The NRC recognized the licensee's extensive

planning and* regulatory awareness as contributors iii reducing the

time for repairs* such that the requested waiver ~as not actually

needed.

c.

Housekeeping

d.

Housekeeping throug~out the plant is generally good.

The licensee

. has significantly.improved housekeeping in the condensate polishing

building, boric acid flats, Unit 1 charging pumps -cubicles, cable

fa*ults, emergency switchgear room, turbine building, and auxiliary

builping by refinishing the floors and/or repainting wall and

component surfaces.

The licensee is in the process of repainting the

No. 1 EDG room and Unit 2 charging pump cubicles..

Prior _to

repainting, the original surfaces were sanded or chipped away which

sometimes resulted in poor housekeeping in the adjacent areas.

Station management * has reemphasized the need to maintain good

housekeeping to station personnel while painting or other maintenance

is in process.

Operations TPUP Review

The. TPUP program has completed approximately 1162 of the 3700

_

procedures requiring upgrade in the operatfons area.

The number of

completed procedures exceeded _the program goals.

This program is

closely monitored by management and reports are routinely issued in

order to inform management of program completion status.

The

inspectors routinely monitor the performance of upgraded procedures*

and consider them to be of good quality.

The licensee utilized QA

assessments and quarterly procedure ~pgrade surveys to e~aluate the

  • - effectiveness of this program.

Approximately 100 randomly picked

procedure users are surveyed quarterly in order to track the stations

6

perception of new procedures.

The results of these surveys are

utilized to further enhance the quality of procedures.

Vendor manuals are being updated in accordance with the Configuration

Management Program.

The inspectors were irifonned that procedures are

being upgraded* prior to updating vendor manuals and that any vendor

manual update that effected procedure*s would have to be incorporated

into procedures at a later date.

  • *

.e~

Computer Programs

The Operations department has implemented a new computer program,

VPASS, which aid operators: in performing their duties and* also_

records and trends hours* ~pent in TS action statements.

Whenever a

TS acti o*n statement is entered, operators are required to enter the

appropriate data into VPASS.

At shift turnovers, operators are able

to print out all TS action statements for review.

Also, the VPASS

record of action statements is provided to station management. for

review. *The program is able to sort and- trend action statements in

many different ways, and provide valuable historical information

relative to action statements.

F6r ~xample, the licensee is able to

accurately specify how*many hours were spent in TS action statements -

_ in 1991 due to inoperable charging pumps *or.any other component or

system covered by the TS.

The ability to trend hours spent in _a~tion

statements will significantly enhance the licensee's ability to focus

ori problem areas:

f:

HHSI Pump Lube Oil Cooler TCVs

Each of the six HHSI pumps hai a lube oil cooler. Service ~ater is

aligned to each cooler tQ remove heat .from the lube oil.

As the lube

oil ;temperature increases, a TCV .automatically opens and regulate SW

flow through the cooler. Review of 1990 and 1991 statfon deviations

revealed that failure- of TCVs to automatically control lube oil

temperature in the required band was a reoccurring problem.

The

primary f~ilure mechanisms were the .TCV being stuck in the shut or

intermediate position due to debris from the SW system that accumu-

lated in the valve internals or the temperature controller not

maintaining the proper setpoi nt.

In order to correct these TCV

. deficiencies, the licensee has .replaced TCV disks ~ith disks that are

different in material and design on five of the six HHSI pumps and

initiated routine flushes to remove silt and other debris from the SW

system.

The new TCV disks were installed in June, 1990 on all three

Unit 1 HHS! pumps and the Unit 2A HHSI pump and in July 1991, on the

Unit 2C HHSI pump.

This modification has not been performed on the.

Unit 28 HHSI pump.

On August 26, 1991, the licensee began to rou-

tinely flush the valves oh a two-week interval.

The licensee's corrective actions have reduced TCV failure rates, but

the problem continues to exist. OnSeptember 10, 1991, the TCV on

the Unit 18 HHSI pump failed to properly oper~te.

on* November 10 and

7

December 3, 1991 and on March 2, 1992, the TCV on the Unit 28 HHSI

failed to properly-operate.

On March 6, 1992, the TCV on the Uhit 2A

HHSI pump failed to properly operate. Whe~*these failures- occurred,_

operator manual action or maintenance was required to correct. the

problem.

The licensee* is aware that the corrective actions

_- _

implemented have not eliminated this problem and was in the process

of procuring redesigned TCVs and contra 11 ers.. . The materials and

procedures requir~d t6 accomplish this modification are scheduled to

be available* May 1, 1992.

Installation of these new components has

not been scheduled.

The modification does not require an outage and

therefore could be started when materials and procedures are

available._

The inspectors concluded- that until the *proposed modifi-

cation is installed, the .li.censee needs to implement additional

  • temporary corrective measures to preclude repetitive TCV failures .

HHSI pumps are required to automati~ally start and operate on receipt

of an SI signal.

By design, operator manual actions are not required

for pump operation during the inittal phases of a LOCA~ In addition~

during the LOCA RMT phase, high radiation levels. in the area of the .

HHSI pumps would prohibit operators from manipulating the TCV

controllers.

The inspectors are concerned _that if a TCV failed to -

_ properly control lube oil -temperature during a LOCA, significant HHSI

pump degradation or failure would occur.*

The fai 1 ure to implement adequate corrective actions to prevent _

t~petitive TCV failures was identified as Violation 280,281/92-04-01.

Within the areas inspected, one violation was identified.

4.

Mainte~ance Inspections (62703, 42700, 71500)

During the reporting period, the inspectors reviewed maintenance

activiti~s to assure compliance with the appropriate procedures.

The following maintenance activities were reviewed.

a. * * Roofing Leaks

One of the areas examined during the last inspection period involved

the number of roofing leaks present at the Surry plant.

During this

inspection period,* a meeting was held with. the *manager of

Civil/Mechanical Engineering to discuss the roof program~ There wete

several parts to this program; and one part,_ the a_uxiliary building

roof replacement, has had the ~pecifications established and the roof

designed.

The total roofing program wi 11 be prioritized with the

auxiliary building roof being first.

The presentation-of the roof

m_anagement program recommendations to upper management is scheduled

for March 31, 1992.

These recommendations will include- repair,

replacement, and retrofit for a five-year period.

The inspectors

will continue to follow this program and its effect -On decreasing the

number of leaks.

b.

8

Maintenance Program Innovations

The inspectors observed several maintenance innovations that are

being implemented to improve the overall perfor~ance of the

maintenance department.

These innovations are as follows:

During a maintenance self assessment, it was determined that

there was a lack of corrununi cation between the maintenance

manager ind the maintenance craftsmen.

The maintenance manager

decided to alleviate this situation by holding quarterly

meetings starting February 1992.

The inspectors attended one of

these meetings and noted that there was a good exchange of

information.

The maintenance department has started issuing a maintenance

department report on a monthly basis.

It's purposes are to

explain various department tasks and processes, to make

individuals more cognizant of their own and other depart~ents

1

work.

Inputs to the December~ 1991 report are from electrical

maintenance, mechanical maintenance, maintenance engineering,

preventive maintenance, MOV, predictive analysis, and welding

groups.

These articles included such topics as ALARA update on

  • exposure reduction, challenges identified by the maintenance

self assessment, EOG task team report, and malfunction of a

control rod that caused a manual trip.

Another innovation involved the meeting of individual

maintenance teams with the QMT/ALARA coordinator and some of the

managers to establish goals that will improve quality of work

and reduce the radiation exposure.

The inspectors will monitor the effect of these innovations with

respect to the effects on the quality of maintenance.

c.

Feedwater Regulation Valve Repair

During the last two inspection periods, the inspectors have followed

the repair of FRVs.

In the December period, these valves may have

contributed to a turbine/reactor trip caused by a high f eedwater

level iri the B steam generator. A review was made of the 'licensee's

evaluation of the FRV oscillation, including testing and modification

documentation.

Modification documents and current evaluation showed

that a smaller size tubing had been installed for the supply.air

lines. This smaller tubing size could cause a longer stroka time for

the valves.

A station deviation (No. S-92--0121) was written.

The licensee

reviewed the time for the closing of the valves by reviewing a

previous trip/ESF actuation and noted that it took seven seconds to

close the valves. Analysis assumptions were for no more than a 10 to

9

15 second closing time.

Th~ licensee is replacing the Unit 1 tubing

with the proper size during this outage and the valves wil.l be placed

in an ISI .program *that will provide per*iodic timing testing of the

_valves.

Within the areas inspected, no violations were identified.

5.

Surveillance Inspections (61726, 42700)

  • During th~ reporting period, the inspectors reviewed surveillance

activities to assure compliahce with the appropriate procedure and TS

requirements.

The following surveillance activity was reviewed:

a.

Testing of Unit 1 and 2 Relays

During a review of TS change no. 235, the licensee discovered.that a

relay in the SI system logic sequence was not-adequately tested as an

active component.

The subject relay actuates on low Tave* and makes

up the matrix needed for high steam flow in coincidence with low Tave

  • or low steam line pressure.

The monthly periodic. test checks

continuity but does not test for relay actuation at the SI contacts~

The licensee entered a six hour clock to hot sh~tdown (TS 3.7 t~ble

3.7-2). at 1413 on February 14.

The appropriate perodic tests,

1-PT-8.3A (dated June 27, 1989) and 2-PT-8.3A (dated October 2,-

1990), Safety Injection and Feedwater Control Isolation Lo.gic, were

  • revised to include the testing for these relays. * The inspectors

observed this testing in the ESGR room for both units and reviewed

the documentation.

Both units were successfully tested and the six

hour clock was exited at 1434 hours0.0166 days <br />0.398 hours <br />0.00237 weeks <br />5.45637e-4 months <br />.

_An LER {no. Sl-92-003) was .

written to cover this event and i*s discussed further in paragraph

10.b.

.

b.

lJ Bus ESF Actuation with Undervoltage and Degraded Voltage

The inspectors * witnessed the tes.ting of ESF actuation with

undervoltage on the lJ bus.

The test was accomplished in accordance

with procedure 1-0PT-ZZ-002, ESF Actuation With Undervol tage and

Degraded Voltage - lJ Bus, dated February 27, 1992.

The inspectors

-reviewed the test instructions. and attended the pre-evolution

briefing.

The. licensee had assigned a Senior Operation Manager on*

duty during performance of this infrequently performed task.

This

provided the shift crews with the needed support as well as allowing

the managers to participate iri the briefing *and monitor the

  • performance~

Within the areas inspected, no violations were identified .

6.

10

Quality Verification and Safety Assessment Review (40500)

The inspectors conducted a review of the licensee's corporate independent

review functions and 'industry operating experience program.

TS 6.1.C.2

    • requires that the MSRC be responsible* for the review of safety

eva*luations, unreviewed safety_ questions, -TS changes, violations,

.. significaDt abnor~alities, LERs, deficiencies that could affect nuclear

safety, and SN SOC meeting minutes.

the licensee implemented the

requirements by submitting all LERs, violations and TS changes to MSRC

members for review.

-

Additionally, al_l safety evaluations are independently reviewed *by CNS

while performing as a subcommittee to the MSRC.

CNS also reports to the

Manager of Nuclear Licensing and Programs when conducting independent

assessments of station activities and when implementing the industry

operating experience program.

The inspectors* reviewed the following

program implementing procedures:

LICP-4000 Corporate Nuclear Safety,

LICP-2001 Independent Review Program~ NLP ADM 4.1 Review and Processing of

Industry Operating Experience Documents and VPAP 3002 Operating Experience

Program.

.a *

Independent Review Process

  • Throu~h t~e Independent Review program, CNS independently reviews all

safety evaluations performed in accordance with lOCFRS0.59 and

reviews a 11 SNSOC meeting minutes.

The inspectors discussed the

program with responsible -personnel, reviewed selected independent

verification packages for effectiveness and reviewed qualifications

of individuals.

P_ersonnel assigned to perform the reviews a*ppeared

to collectively possess experience* and competenc~ in the diverse

disciplines necessary to be effective.

However, the training folders

for the persons assigned the IR function were not always complete and

were difficult to audit.

The inspectors questioned the licensee on the use of the 1R process

to meet the MSRC oversight requirements of TS 6.1.C.2 since the.TS

did not specifically discuss the use of subcommittees.

Tlie

licensee's TS amendment that invoked the current MSRC oversight does

discuss the use of subcommittees in the support information and the

use of subcorrmittees is described in the NRC's guidance on oversight*

o.f offs i te committees.

The inspector found the licensee process

acceptable and .in complian_ce with TSs.

The IR program was clearly

defined by the controlling proc~dure and appeared to be effective in

i dent ifyi ng and resolving concerns as we 11 as tracking and reporting

the status of items.

The inspectors noted that while safety _

evaluations-were reviewed, the licensee's program had no requirements

to independently review a sample of activity screening checklists. * *

Improper use of screening checklists could.res~lt in not performing

the necessary written safety evaluation.

Additionally, the person

assigned the primary review function for the SNSOC meeting minute*s

does not attend the meetings.

The licensee agreed to consider the

J

b.

c.

11

need to have the reviewer periodically attend SNSOC meetings and to

continue with their assessment of the quality of the safety evalua-

tion screening process.

Industry Operating Experience Review

CNS is responsible fcir maintaining the licensee's IOER Program with

the purpose of reviewing IOER documents to assess . ap*pl i cabi 1 i ty and

develop action plans necessary to. prevent or minimize the _ *

consequences of previously* experienced industry events.

IOER.

documents include NRC Inf_ormation Notices, Generic Letters, Virginia

Power LERs, *10 CFR 21 Notifications, INPO event reports and

Westinghouse Technical Bul_l~tins.

IDER documents are initially

sc_reened within 10 days and assigned a- priority to prepare an

analysis report and develop all acti.on plan within 30, 60, or.90 days

to address the concern. The inspectors selected a sampling of

documents and determined that appropriate priority had been assigned

and that action plans were of high quality, clearly identifying the

concerns and needs for further action.

IOERs selected for review

ihcluded IN 91-46, GL 91-05, IN 88-60, and GL 90-05.

The insp~ctors

identified weaknesses with the licensee's tracking system for

documents. In many cases, due dates were not assigned, due dates had

been exceeded or proposed acti ans had been rejected with no

.indication that followup was* being pursued.

The inspectors

determined that in general the actions were being adequately pursued

and the problems were confined to maintenance of the tracking system

data base.

CNS Assessments and Event Reviews

The CNS assessment and event review process is controlled by

procedure LICP-4000, Procedure for Performing Assessments and Event

Reviews.

At the time of the inspection, this procedure was in the

concurrence cycle for approval.

The new procedure replaced procedure

NL&P~ADM-2.2

and

incorporated changes in the. program and

organization. The assessment and event review process is not required

by the TS. The stated purpose of the CNS event review and assessment

process is to independently evaluate technical issues, performance

problems or other areas as requested by the MSRC, senior management,

or statfon management and make recommendations for improvements.

The inspectors discussed the ass~ssment and review process with the

supervisor of nuclear safety review and several members of his staff.

The planned CNS assessments are integrated. with other review

activities scheduled at the station. In some cases, personnel from

other organizations are included as part of the team.

The list of

1991 assessments and reviews were discussed and management's

involvement in the process was evident by the number of senior

management requested assessments that were performed ..

Within the areas inspected, no violations were identified.

12 _

7.

IPE Internal Flooding Corrective Action Review (71500)

Surry Power Stati.on's IPE determined that it had a higher than expected.

degree of vulnerability for turbine building flooding.

A team inspection

was made in November, 1991, to as~ess the licensee's correcti~e action

plans *and interim protective measures.

The Chairman held.a public meeting

ori this subject at the Surry Nuclear Information Center on November 29,

1991.

Certain actions were taken to reduce this vulnerability, among* them

was* inspection of one of the main condenser outlet expa*nsion joints by the

licensee.

This was done in order to estimate the service life of the

-

eight affected expansicin joints.

The inspection showed degradation of

this expansion joint and the licensee decided to inspect the remaining

expansion joints.

There were varying degrees -of degradation found in

these remaining joints *. * Consequently, the licensee decided to replace all

of these 96 inch diameter expansion joints and committed to accomplish

this by February 28.

_Cln .. February 22, this task was completed.

Each

expansion joint replacement took about ten days and initially the licensee

believed that TS waivers would be required for four of these replacements

(2 for each unit) because emergency service water lines would have to be

isolated by stop log installation.

However, the licensee developed and

designed a system that did ncit compromise safety, gave two barriers for

worker safety, and eliminated the need to isolate a safety system train

thereby neQating the need for an TS waivers.

Within the areas inspected, _no violations were _identified.

8.

ESF Verification -(7171b)

The inspectors walked down the safety related portions of the ventilation

system.

The ventilation system is shared between the units. Sheets 1, 2,

and 3 of drawing 11448-FB-6D were utilized for this walkdown.

The

fo 11 owing discrepancies were i dentifi_ed during tlie wa lkdown:

.

-

.

Overall labelin~ of ventilation system compone~ts was poor.

Manual

dampers were not labeled, many had the identification numbers and

open/closed positions annotated in handwriting with a felt marker on

the component.

The handwheel on the motor operated dampers to the

chargin~ pump motors were not labeled. Other components were labeled

with red tape, duct tape, pencil, or felt marker.

The inspectors

walked this system down with the Configuration Management labeling

personnel, and were informed that the relabeling program which is

scheduled for completion in March, 1993 would resolve these

deficiencies.

bil was dripping from 1-MOD-VS-lOdB hydraulic actuator:

There was

oil on the piping and wall below the MOD.* The inspectors hated that

a work order to repair the oil leak was initiated in February 1990,

but was classified as low priority and had not been scheduled to be

.worked.

1-MOD-VS-lOOB is required to automatically operate on an SI

signal.

The inspectors were informed'that monthly periodic testing

13

on the ventilation system verifies that* the MOD repositions.

The

inspectors were al~o informed that if the oil level in the damper's

reservoir got too low, the MOD would not open as required .. The MOD

oil leak hai been scheduled to be repaired during the second week of

March, 1992. *

The insp~ctors noted that the physical condition of the ventilation system

was in the process of being improved.

Some of the duct work ~as recently

painted or primed, but the majority of the duct work still needed

painting. Housekeepi~g in the ventilation system areas was adequate.*

Within the areas inspected, no violations were- identified.*

9.

Technical Procedures Upgrade Program. (42700).

The inspectors discussed the technical procedure upgrade program with the*

licensee on*March 3 and 5.

This program was started December 31,-1989, *

and is sc_heduled to be completed by December 1996.

The following table

shows the disciplines and the number of technical procedure that are to be*

written over the life of the program.

Discipline

Electrical

Mechanical

I&C

  • Ops (Dual)
    • Ops (Single)
      • Other
  • Annunciator Procedures and EOPs
    • Nonnal OPS Procedures
      • Special Tests, etc.

.

.

  • Number of Procedures
  • 1072

585

1538

1915

1784

588

A review of the status of the TPUP revealed that most cf the procedure

disciplines are above or just slightly below .the goal with the exception

of the I&C procedures.

The procedures. group exceeded the 1991 yearly goal

for writing I&C pro~edures, but still continues t6 be below the overall

goal, i.e. 210 procedures complet~d and the goal was approximately 410

completions.

.

The inspectors also ~eviewed the backlog of PAR's that are used to change

or modify the procedures.

The PAR program was started in February 1990.

Actual procedur~ revisions would be made when SNSOC directed the proce-

dures group to make the change.

In July 1990, this committee directed the*

procedure~ group.to incorpor~te changes to procedures when the number of*

PAR

I s reached five or more and on February 10, 1992, the process .of

incorporatiori of all PAR's into procedures was included in VPAP 0502.

As

of D~cember 1991, the number of outstanding PARS was 1323 and this appears

excessive to the inspectors.

Al so as of this date there were 23 proce-

dures outstanding that had five or more PARS's and 339 PARS's outstanding

14

  • that were written .in 1990. (161 of these PARS's were for the I&C

.procedures). Approxi~ately 15 percent of*thi upgraded procedures have one

or more (open or closed) PAR

I s and approximately 31 percent of the.

.

rion-upgraded procedures have on~ or more. This indicates that the upgraded

procedures are of better quality and require fewer changes within the

areas inspected*.

No violations were identified.

16.

Licensee Event-Rev~e~ (92700)

The inspectors reviewed _the LER's listed below and evaluated the adequacy.

of corrective ~ction.

The inspector's review also included followup on

the licensee's implementation of corrective action.

.

.

.

.

.

a.

(Closed) LER 280,281/92-002, 4160 Volt Transfer Bus D, E, and F

Undervoltage Relay Trip Setpoints Set Below TS Limit Due to Procedure

Error.

This issue involved not setting the station blackout motor

driven AFW pump start relays in accordance with the values specifiep*

fn TSs. * This issue and corrective actions were discussed in

Inspection R~port 280,281/92-02.

This event was caused by an error

.in calibration procedures in that an incorrect" UV relay trip setpoint

was Specified.

TS 6.4.A.2 requires detailed written procedures for

ca 11-brati on of components i nvol vi ng nuclear safety of the* station.

The failure to provide an adequate procedure to calibrate the station

blackout motor driven AFW pump start relay~ is identified as NCV

280,281/92-04-02 .. This violation will not be subject to enforcement

action because the 1 i censee' s efforts in identifying and correcting

the violati~n meet the criteria specified in Section V.G. of the

Enforcement Policy.

b.

(-Closed) LER 280, 281/92-003, Incomplete Engineered Safety Features

Testing Due to Procedure Defici~ncy. This issue in~olved the failure

to fully test certain ESF system logic actuati6n relays in accordance

with TS Table 4.1-1, Item 26.

Specifically, actuation of the relays

which energize on low reactor coolant average temp~rature were ~ot

being verified (see paragraph 5.a for more d~tails).

The-licensee

discovered this during a procedure upgrade. TS 6.-4.A.2 requires

detailed written procedures for calibration of components involving

nuclear safety of the station.

The procedures were revised and the

relays were tested. This failure to provide an* adequate procedure to

fully test the ESF system logic actuation relays is i~entified as NCV

280,28l/92-04-03.

This violation will not be subject to enforcement

  • action because the 1 i censee I s efforts* in i den ti fyi ng and correct fog

the violation meet the criteria specified in Section V.G. of the

Enforcement Policy.

c.

(Closed) LER 280/91-13, MCC Room Fire Suppression System Inoperable

Due to Personnel Eiror in Administratively Controlling the MCC Room

Exit Door,

This issue involved personnel blocking open the Unit 1

cable vault upper level MCC room exit door without es_tablishing

!

15

provisions to shut the door if a fire in the area would have

occurred.

.This issue was discussed in Inspection Report

280,281/91-29 and was 1 eft open because the 1 icensee had not

completed corrective actions:_ The licensee has install~d si9ns on

fire doors that explain the special precautions that must be followed -

when the door 1s open.

Within the areas inspected, no violations were identified.

11~

Exit Interview

The inspection scope and results were summarized on March 9, 1992~ 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

Status

VIO S0-280,281/92-04-0l

Open

NCV 50-280;281/92-04-02

Closed

NCV 50-280,281/92-04-03

Closed

LER-50-280,281/92-002

Closed -

LER 507280,281/92-003

Closed

LER 50-280/91-13

Closed

12.

Index of Acronyms and Initialisms_

Description and Reference

Ineffective Corrective.Action

Associated With HHSI Pump

Lube-Oil Cool er TCVs ( paragraph

3.g}.

Fai 1 ure to Properly Test the

.

Blackout Relays for Starting Motor*

Driven AFW {paragraph 10.a).

Failure to P~operly Teit the

Average Temperature Portion of ESF

Logic Circuits (paragraph 10.b).

4160 Volt Transformer Bus D, E,

and _F Undervoltage Relay Trip

Setpoints Set Below TS Limit Due

to Procedural Error- (paragragh

10.a).

Incomplete Engineered Safety

Features Testing Due to Procedural

Deficiency (paragraph 10.b)..

-

MCC Room Fire Suppression System

Inoperable (paragraph 10.c).

  • ALARA

AFW

AS LOW AS REASONABLY ATTAINABLE

AUXILIARY FEEDWATER

16

CFR

CODE.OF FEDERAL REGULATIONS

CNS

CORPORATE NUCLEAR SAFETY.

CT

. CURRENT TRANSFORMER

DC

Design Change

ECCS

EMERGENCY CORE COOLING SYSTEM

EDG

EMERGENCY DIESEL GENERATOR

EO.P

EMERGENCY OPERATING PROCEDURE

EP

EMERGENCY PROCEDURE

ESF

ENGINEERED SAFETY FEATURE

ESGR

~

EMERGENCY SWITCHGEAR ROOM

FRV

FEED REGULATING VALVE

FSAR

FINAL SAFETY ANALYSIS REPORT

GL

GENERIC LETTER

HHS!

-

HIGH HEAD SAFETY INJECTION

I&C

INSTRUMENTATION AND CALIBRATION

IN

INFORMATION NOTICE

INPO

INSTITUTE OF NUCLEA~ POWER OPERATION

IOER *

INDEPENDENT OPERATIONAL EVENT REVItW

IPE

INDEPENDENT PLANT EVALUATION

IR

INDEPENDENT REVIEW

!RPI

. INDIVIDUAL ROD POSITION INDICATION

ISI

lNSERVICE INSPECTION

LCO

-

LIMITING CONDITIONS OF OPERATION

LOCA

  • LOSS OF COOLANT ACCI~ENT

LER

-

LICENSEE EVENT REPORT

MCC

-

MOTOR CONTROL CENTER

MOTOR OPERATED DAMPER

MOV

MOTOR OPERATED VALVE

MSRC

MANAGEMENT SAFETY REVIEW COMMITTEE

NCV

NON-CITED VIOLATION

NRC

.-

. NUCLEAR REGULATORY COMMISSION

OPS

OPERATIONS

PAR

PROCEDURE ACTION REQUEST

QA

QUALITY ASSURANCE*

QMT

QUALITY MAINTENANCE TEAM

RHR

RESIDUAL HEAT REMOVAL

.

I

RPM

REVOLUTIONS PER MINUTE

RSST

RESERVE STATION SERVICE TRANSFORMER ..

SA/QV

SAFETY ANAL YSIS/QUAL!lY VERIFICATION

SI

SAFETY INJECTION

SNSOC

STATION NUCLEAR AND SAFETY .OPERATING COMMITTEE .

SW

SERVICE WATER

TCV

TEMPERATURE ~ONTROL VALVE

TPUP *

TECHNICAL PROCEDURE UPDATE PROGRAM

TS

-

TECHNICAL SPECIFICATIONS

UV .

UNDERVOLTAGE

VPAP

VIRGINIA POWER ADMINISTRATIVE PROCEDURES

VPASS

VIRGINIA POWER ACTION STATEMENT SYSTEM