ML18152A156
| ML18152A156 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 05/02/1989 |
| From: | Fredrickson P, Holland W, Larry Nicholson, York J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18152A157 | List: |
| References | |
| 50-280-89-08, 50-280-89-8, 50-281-89-08, 50-281-89-8, IEB-84-03, IEB-84-3, NUDOCS 8905190130 | |
| Download: ML18152A156 (22) | |
See also: IR 05000280/1989008
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, N.W.
ATLANTA, GEORGIA 30323
Report Nos.:
50-280/89-08 and 50-281/89-08
Licensee:
Virginia Electric and Power Company
Richmond, Virginia 23261
Docket Nos.:
50-280 and 50-281
Facility Name:
Surry 1 and 2
License Nos.:
Inspection Conducted: March 5 through April 1, 1989.
Scope:
0n. ).
Inspector
J.
Inspector
te"si gned
SUMMARY
This routine resident inspection was conducted on site in the areas
of plant operations, plant maintenance, plant surveillance, licensee
event report review, and followup on inspector identified items.
A
special evaluation of the licensee 1 s program that was used to walk
down selected systems prior to unit restart was documented in the
last two resident inspector 1 s reports and this inspection effort
continues in this inspection report.
Certain tours were conducted on backshifts or weekends.
Backshift or
weekend tours were conducted on March 5, 11, 18, 26, 27, 28, 29, and
April 1, 1989.
Results:
During this inspection period, two violations were identified. The
first violation (paragraph 3.f(2)) concerns failure of the operators
to use procedures for realigning
and indicates that the
licensee 1 s corrective actions for past problems in the operations
area (reference NRC Inspection Report 280,281/88-51) has not been
entirely
effective
and
continues
to
require
additional
&9os 1 901 -.0
f'DR
Al:11'.J-,-=:1., a*;,051 ()
l:J.
_.,., 05000280
I
2
management attention.
The second violation contains three examples
of failure to meet the requirements of 10 CFR 50, Appendix B,
Criterion V.
These examples include problems
with
regard to
configuration control of instrumentation lines downstream of system
root valves (paragraph 4.a(2)), problems associated with returning
systems
to
service
after
modification
and/or
maintenance
(paragraph 4.b), and examples of inadequate instruction of personnel
performing inspection of cable splices indicating a lack of train~ng
and/or procedural guidance (paragraph 5.a).
One weakness was identified in paragraph 4.a(l) concerning an
apparent
lack of sensitivity to
harmful
contamination (i.e.
chlorides) on safety-related stainless steel piping .
REPORT DETAILS
1.
Persons Contacted
2.
Licensee Employees
- W. Benthall, Supervisor, Licer.sing
- R. Bilyeu, Licensing Engineer
- R. Blount, Superintendent of Technical Services
- D. Christian, Assistant Station Manager
D. Erickson, Superintendent of Health Physics
- E. Grecheck, Assistant Station Manager
- M. Kansler, Station Manager
- J. McCarthy, Superintendent of Operations
G. Miller, Licensing Coordinator, Surry
J. Ogren, Superintendent of Maintenance
- T. Sowers, Superintendent of Engineering
J. Price, Site Quality Assurance Manager,
Other licensee employees contacted included control room operators, shift
technical advisors, shift supervisors and other plant personnel.
- Attended exit interview
Acronyms and initialisms used throughout this report are listed in the
last paragraph.
Plant Status
The inspection period began with Units 1 and 2 in cold shutdown.
The
units remained in cold shutdown for the duration of the inspection period,
while substantial operational reviews and maintenance activities were
being conducted.
3.
Dperattonal Safety Verification (71707)
a.
Daily Inspections
The inspectors conducted daily inspections in the following areas:
control room staffing, access, and operator behavior; operator
adherence to approved procedures, technical specifications, and
limiting conditfons for operations; examination of panels containing
instrumentation and other reactor protection system elements to
determine that required channels are operable; and review of control
room operator logs, operating orders, plant deviation reports, tagout
logs, jumper logs, and tags on components to verify compliance with
approved procedures .
I J
b.
c.
2
During review of the control room logs, the inspectors noted that on
April 1, 1989, operators failed to properly align the flowpath to the
B boric acid transfer pump (1-CH-P-28) as required by OP 8.5.2, Batch
Mixing and Transfer to 1-CH-TK-18 Using 1-CH-P-28.
This condition
resulted in the pump being operated for approximately one minute
without a suction flowpath.
The operator recognized the error and
stopped the pump prior to pump damage occurring. The pump suction
valve was opened and the batching evolution was completed.
This
valve alignment discrepancy was properly identified to the control
room and a deviation report was submitted.
The nonlicensed operator
voluntarily submitted a detailed report to operations supervision
describing the event and how it could be prevented in the future.
The inspector considers that although the event had mininal safety
significance, the operator's response appears to indicate increased
sensitivity and accountability on the part of working level personnel
to identification of operational problems.
Weekly Inspections
The inspectors conducted weekly inspections in the following areas:
verification of operability of selected ESF systems by valve align-
ment, breaker positions, condition of equipment or components, 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, plant
housekeeping conditions/cleanliness,
and
missile hazards.
The
inspectors routinely monitored the temperature of the auxiliary
feedwater pump discharge piping to ensure steam binding is prevented.
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 implementation
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.
d.
Areas Inspected
Inspections included areas in the Units 1 and 2 cable vaults*, vital
battery rooms, steam safeguards areas, emergency switchgear rooms,
diesel generator rooms, control room, auxiliary building, cable
penetration areas, independent spent fuel storage facility, low level
intake structure, and the safeguards valve pit and pump pit areas.
3
Reactor coolant system leak rates were reviewed to ensure that
detected or suspected leakage from the system was
recorded,
investigated, and evaluated; and that appropriate actions were taken,
if required.
The inspectors routinely independently calcuiated RCS
leak rates using the NRC Independent Measurements Leak Rate Program
(RCSLK9).
On a regular basis, RWPs were reviewed and specific work
activities were monitored to assure they were being conducted per the
RWPs.
Selec,ted :adiation protection instruments were periodically
checked, and equipment operabi 1 i ty and calibration frequency were
verified.
e.
Physical Security Program Inspections
In the course of monthly activities, the inspectors included a review
of the licensee's physical security program.
The performance of
various shifts of the security force was observed in the conduct of
daily activities to include: protected and vital areas access
controls; searching of personnel, packages and vehicles; badge
issuance and retrieval; escorting of visitors; and patrols and
compensatory posts.
f.
Licensee 10 CFR 50.72 Reports
(1)
(2).
On March 10, 1989, the licensee made a report in accordance with
10 CFR 50.72 with regards to questionable operability of the
Unit 1 inside recirculation spray pumps due to installation of
non original equipment manufacturer parts.
The parts had been
installed during the Unit 1 refueling outage in the summer of
1988.
This report was made after the licensee reviewed the
results of an engineering evaluation, which concluded that
operability of the pumps with these parts cannot be analytically
assured.
This issue was discussed in detail in NRC Inspection
Report 280,281/88-51.
In that inspection report, a followup
item was opened to monitor licensee evaluation of the issue.
However, additional NRC staff review of this issue resulted in
identification of an apparent violation in NRC Inspection Report
280,281/89-06.
On March 18, 1989, the licensee made a report in accordance with
10 CFR 50.72 with regards to increase in the Unit 1 RCS
temperature over a period of approximately 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> due to an
improper RHR system alignment.
This condition resulted in RCS
temperature increasing approximately 14 degrees F from 103F to
117F.
After correction of the system alignment problem, which
involved opening one valve to reestablish CCW flow through the
operating RHR heat exchanger, RCS temperature was reduced to
approximately 100 degrees F as desired for continuance of
maintenance evolutions.
The unit has been shut down since
September 14, 1988.
4
The sequence of events was as follows:
March 17, 1989 at approximately 10:00 p.m.
Operators were realigning the Unit 1 CCW system auxiliary loads
in containment from the A header to the 8 header in accordance
with a special test procedure.
RHR alignment at this time
consistec.1 of the A RHR pump running and providing RHR flow
through the A RHR heat exchanger.
The 8 RHR heat exchanger was
in normal alignment with its RHR discharge manual isolation
valve shut.
CCW flow into containment was through the A header
(A RHR heat exchanger).
CCW fl ow to the B RHR heat exchanger
was isolated by containment isolation valve TV-CC-1098 being
closed. TV-CC-1098 was closed as a result of the performance of
the special test.
During realignment of CCW auxiliary loads,
the operators realized that they would need to open the
TV-CC-1098 valve in order to reestablish CCW flow through the
CCW system auxiliary loads. This requirement was not identified
tn the special test procedure.
The operators bpened TV-CC-1098'
to reestab 1 i sh fl ow to the B CCW header.
They a 1 so shut the A
header containment isolation valve
TV-CC-109A.
When
TV-CC-109A was shut,
CCW to the A RHR heat exchanger was
secured.
With no
RHR water fl ow through the B RHR heat
exchanger, decay heat removal for the unit was secured.
March 17, 1989 - 10:00 p.m. to 12:00 a.m.
Shortly after realigning the system as described above, the
operators noticed a slow heat up rate on Unit 1; however, they
thought that the B header CCW manual throttle valve in contain-
ment needed adjustment and turned this condition over to the
oncoming midnight shift.
March 17, 1989 - 12:00 Midnight
Shift turnover to the midnight shift stated that the alignment
for decay heat removal on Unit 1 was through the B RHR heat
exchanger.
The turnover also indicated that a slow heatup was
in progress due to throttled CCW flow.
March 18, 1989 - Midnight to 8:00 a.m.
The midnight shift made a containment entry to increase CCW flow
through the B RHR heat exchanger and monitored the heatup
throughout the night.
March 18, 1989 - 8:00 a.m.
The oncoming day shift operators noticed that the unit
temperature was higher than it was the night before and
questioned other potential problems, including a possible valve
5
misalignment.
The operations superintendent also reviewed the
situation and directed that a containment entry be made to
verify valve alignment status for the RHR system.
March 18, 1989 - approximately 9:30 a.m.
The operators in containment verified that the discharge valve
for R~R flow through the B RHR heat exchang~r was shut.
The
operations supervisor directed that TV-CC-109A be reopened.
This evolution was accomplished and unit cooldown recommenced
when CCW flow was restored to the A RHR heat exchanger.
After the alignment deficiency was corrected, the licensee
stopped all abnormal evolutions and conducted a detailed review
of the event.
That review concluded that the swing shift had
realigned the CCW system as required by procedure during
recovery from a special test. However, the procedure being used
was not adequate to restore CCW flow through the B header. The
operators concluded that additional
valve operations were
necessary and performed these operations without the use of
procedures resulting in the loss of CCW fl ow through the
operating RHR heat exchanger.
The operators involved in this
evolution (Unit 1 RO and SRO) were not assigned to normal
control room shifts. They had been assigned to a control room
shift in order to satisfy the required time on shift to maintain
an active license.
Turnover to the midnight shift (which was
al so manned by an SRO not usually assigned to shift as a
licensed operator) identified a potential problem with regard to
a slow unit heatup; however, the operators initially thought
that this was due to inadequate CCW flow through the B RHR heat
exchanger, resulting in the oncoming shift continuing to monitor
the condition and adjust CCW flow to correct the problem.
All
attempted corrective actions involved containment entries to
operate manual
valves (average
containment
entry
takes
approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />).
When the day shift arrived, it became
apparent that some other problem existed and a verification of
valve alignment for the CCW and RHR system valves was commenced.
This check confirmed that the RHR system was aligned with flow
i so.lated . through the B RHR heat exchanger.
The operators
immediately corrected the condition.
The inspectors monitored the licensee's actions with regard to
review of this event on March 18, and conducted an independent
review of the sequence of events.
The inspectors were a 1 so
present when licensee management was provided an overview of the
sequence of events by the operations staff.
The inspectors
noted that the licensee identified that several onshift
personnel during the time that the CCW system was improperly
aligned were not routinely assigned on shift. In addition, the
6
swing shift operators properly recognized a problem with flow
through the B CCW header; however, they failed to obtain a
procedure change prior to realigning the system.
Surry Technical Specification 6.4 requires that detailed written
procedures with appropriate check-off lists and instructions be
provided and followed for normal
startup, operation, and
shutdown of all systems and components involving nuclear safety
of the station.
Failure to properly realign the Unit 1 decay
heat removal system following testing is identified as a
violation of T~chnical Specification 6.4 (280/89-08-01).
The inspector noted that licensee management, including the
Station Manager and the Vice President - Nuclear, reported to
the station immediately after the event and conducted a review
to assess required immediate actions.
Licensee management is
continuing to maintain appropriate sensitivity to operational
events; however, additional actions are warranted to export this
sensitivity down to the working levels.
Within the areas inspected, one violation was identified.
4.
Operational Readiness Program Review (71710)
The inspectors continued to review the licensee's operational readiness
program as discussed in NRC Inspection Reports 280,281/88-51 and 89-06.
This .effort is. being performed in accordance with EWR 88-584, System
Review For Startup, and includes both field walkdowns and a review of
outstanding issues by the system engineers.
The resident inspectors are
routinely monitoring all aspects of this readiness program.
The following
details some specific inspection areas and findings from this review.
a.
Plant Configuration Confirmation
This portion of the program, performed in accordance with Attachment
u- to the above EWR,
consisted of the station system engineers
conducting field walkdowns of the systems and noting discrepancies
for resolution. These discrepancies were then evaluated to determine
if they should be corrected before unjt startup, and a justification
was written if deferral was recommend~d.
The inspectors continued to
monitor the licensee actions associated with this effort and
subsequently ide~tified the following concerns:
(1)
The inspectors independently walked down portions of the safety
injection and charging systems and noted a considerable amount
of paint on some of the systems' stainless steel piping. This
piping is located in and around the containment penetration area
of the auxiliary building basement and the paint appears to be
the result of inadequate protective techniques when the walls
and floor were painted.
7
Protective coatings used inside containment are procured per
Specification No. NUS-3003, which specifically prohibits the use
of coatings with water leachable chlorides.
Coatings used
outside containment, however, are procured per Specification No.
NUS-3004 and does not contain a requirement that the paint be
non-halogenated.
In
addition,
Section
C of
NUS-3004
specifically requires that stainless steel piping be protected
?rom paint.
A review of selected certificates of conformance
for paint recently used in the auxiliary building basement
indicates that the paint was supplied free of water leachable
chlorides, other halogens, and low melting point metals.
During the wa l kdown of the above systems by the app l i cab 1 e
system engineers, the engineers did not identify for evaluation
the paint on the stainless steel piping of safety-related
equipment. Although it appears that the paint being used in the
area is acceptable, the inspector expressed concern that an
apparent weakness exists regarding sensitivity to harmful
contamination of stainless steel pipe.
(2)
During the inspector's overview of the walkdown effort, a
concern was identified regarding the responsible organization
for operation and contra 1 of instrumentation va 1 ves.
Valve
operating checkoff procedure l-OP-7.lA, Engineering Safeguards-
Safety Injection System, was revised on December 23, 1988, to
delete the vent valves upstream of the safety injection
accumulator pressure transmitters from the valve checkoff list.
The reason stated for this deletion was that the vent valves
were removed when pressure transmitters were relocated by DC
87-01-1.
The subject vent_ valves (1-SI-401 through 406) were
in fact relocated along with the pressure transmitters versus
removal as stated on the procedure deviation. These valves are
located between the root isolation valves, upstream of the
reducer, and the transmitter isolation valve located at the
transmitter.
When questioned by the inspector, operations
personnel stated that these valves are under the cognizance of
the instrumentation shop and therefore do not belong in the
valve checklist.
The instrumentation shop subsequently denied
cognizance of these valves and stated that operations was
responsible for verifying proper alignment.
On March 27, the inspector met with the appropriate licensee
staff and concluded the following:
Valves associated with instrumentation are not consistently
depicted and labeled on station drawings and in the plant.
For example, the accumulator level transmitters are shown
on the station drawings with all the associated equalizing
and isolation valves, whereas other transmitters are shown
8
with no valves detailed or assigned numbers.
The licensee
stated that while this inconsistency has not caused a
previous plant operational problem, the situation has been
identified and will be addressed during the upcoming
component tagging upgrade program.
The licensee does not define in any procedure or document
the interface point between th Operations Department and
the Instrumentation Department regarding the operation and
position verification of valves.
For example a typical
instrumentation arrangement has a tee off the process line
with a normal sized root isolation valve.
Downstream of
this valve is a reducer down to tubing and a tubing run to
the instrument isolation valve that is just upstream of the
actual instrument.
The safety injection vent valves that
are discussed above are between the reducer and the
instrument isolation valve.
The Operations Department stated that it was their understanding
that they control up to and including the root isolation valve
that is just prior to the reduction down to instrumentation
tubing.
The Instrumentation Department stated that they control
only the instrument isolation valve that is immediately upstream
of the transmitter or sensor.
This informal understanding of
responsibilties as stated above means that valves and components
in the tubing between the two boundaries may not be adequately
controlled, and in fact, on December 23 1988, resulted in the
safety injection vent valves described above being deleted from
procedures.
The above item is identified as a violation
(280,281/89-08-02) of 10 CFR 50, Appendix 8, Criterion V, for
fa~lure to provide adequate instructions for control
of
instrumentation valves.
A subsequent verba 1 agreement was
reached among the licensee staff that the Instrumentation
Department would assume cognizance of all components dow~stream
of the reducer.
b.
Assessment of Oustanding Issues
This item is covered in Attachment IV to EWR 88-584 and includes a
review of oustanding temporary modifications and/or jumpers, station
deviations, commitment items, oustanding safety-related work orders,
_outstanding EWRs and open Type 1, 2, and 3 engineering evaluations.
The system engineers have been tasked with reviewing the above items
pertaining to their system and evaluating if closure of the item
should be performed prior to unit startup.
For those items that will
not be closed prior to startup, a justification for not completing
the item must be written and approved by the Superintendent of
Technical Services .
9
In addition to the above items for review, a revision to the EWR was
issued to require review of all
closed Type
1 engineering
evaluations.
A Type 1 study is the method used by the station to
request either the corporate design authority or any outside
engineering firm to perform an engineering analysis. A Type 2 study
is the conceptual engineering study that must be performed to support
a major plant design change, and a Type 3 document is the actual work
instructions to perform the modificaticn.
In the past, many Type 1
studies have been issued that made specific recommendations that the
plant should consider instead of proceeding to a major Type 2 study
and design change.
For these recommendations, the completed analysis
and recommendations would be sent to the Superintendent of Technical
Services and the Type 1 study would be classified as closed.
The
decision to
perform
subsequent corrective actions that were
recommended by the engineering study was at the sole discretion of
the Superintendent of Technical Services. The licensee realized that
approximately 620 closed Type 1 studies were on file with no
assurance that the necessary corrective actions were performed.
The
licensee stated that this situation was eliminated with the
January 1,
1989
reorganization of the
company 1 s
engineering
structure.
The inspectors reviewed the following closed Type 1 items and the
determinations for startup evaluation:
ST NP No. 1630, Control Room Habitability, Startup Issue
ST NP No. 1688, Evaluate Upgrade of the EOG Speed Sensing
Panels, Startup Issue (Type I closed, opened Type 3)
ST NP No. 1532, Control Room Habitability Evaluation (Charcoal
Filters), Startup Issue
ST NP No. 1584, Instrumentation for Main Control Room HVAC
System, Startup Issue
ST NP No. 1007, 35 KV Primary Feeder Cable To RSSTC, (Concerned
evaluation of different types of cable), Not A Startup Issue
ST NP No. 1065, Voltage Profile and Short Circuit Computer
Program, (No evaluation required, computer program has been
verified), ~ot A Startup Issue
ST NP No. 1149, Control Room Annnunciators, (Engin'eering Work
Request, Work Orders, and Technical Review Referenced), Not A
Startup Issue
10
The inspectors reviewed the following EWRs and the determinations for
startup evaluation:
EWR No. 89-94, Evaluate VS Strainer Piping (1-VS-S-18), Startup
Issue
EWR No.89-101, Evaluated Air Bottles in Mechanical Equipment
Room 3, Startup Issue
EWR No.89-122, Evaluate Ventilation Air Filter, Startup Issue
- EWR
No.
86-457G,
Replacement
of
Control
Room
Chiller
(1-VS-E-4A),(Work Complete), Not a Startup Issue
Switchgear Room, (Work Complete), Not A Startup Issue
- EWR No. 86-288A, Evaluate Replacement of Exhaust Ducting in
System 1EL47, (Work Complete), Not a Startup Issue
Engineering determines *if a technical review must be performed before*
a system/component is returned to service.
Procedure SUADM-ENG-01,
dated November 3, 1987, paragraph 6.7.1 states in part, "If a
technical review is required, the system or component shall not be
considered operational until completion of the technical review."
The three asterisk marked items above indicate EWRs which work was
completed, but a technical review was not performed before the
system/component was returned to service. During the last inspection
period, URI 280/89-06-04 identified the fact that EWR No.88-440
(installation of high point vents) did not have a technical review
performed before the system was returned to service (Unit 1 only).
While a 11
EWR work performed does not require a change in the
drawing/procedure, the ex amp 1 e i dent ifi ed in the unreso 1 ved i tern
required changes in both areas.
The example in the URI along with
the failure to perform technical reviews for the three additional
EWRs above are identified as an example of violation 280,281/89-08-02
for failure to follow the procedure for performing technical reviews
before returning components/systems to service on Unit 1.
Other EWRs and closed Type 1 items reviewed were determined to be
acceptable.
c.
Inspection and [eview Status
The overall status of the engineering work as it pertains to Unit 1
as of March 28, 1989, was as follows:
Walkdowns
Total Items:
3332
Items Reviewed:
3076
Startup Items:
165
Commitments
Total Items:
743
Items Reviewed:
384
Startup Items:
79
11
Closed Type 1
Total Items:
631
Items Reviewed:
336
Startup Items:
6
Total Items:
605
Items Reviewed:
51
Startup Items:
10
Open Type 1,2&3
Tota 1 Items:
261
Items Reviewed:
204
Startup Items:
56
Temp. Mods.
Total I terns:
16
Items Reviewed:
16
Startup Items:
5
Within the areas inspected, two violations were identified.
5.
Maintenance Inspections (62703)
During
the
reporting period,
the inspectors reviewed
activities to assure compliance with the appropriate
Inspection areas included the following:
a.
Evaluations of Motor Terminations
maintenance
procedures.
On March 9, the inspectors witnessed the lifting and inspection of
the motor leads for the auxiliary feedwater pump 2-FW-P-38. This work
was authorized on work order 78859 and was being performed in
accordance with EWR 89-148, Evaluate Misc. Motor Termination Quality,
dated February 23, 1989.
Previous inspection of the inside and
outside recirculation spray motors identified multiple installation
problems with the Raychem splice connection between the field cables
and the motor leads.
These problems included wrong sized and
improperly crimped lugs, damaged insulation, improper adhesion
materials and inadequate substrate length. The purpose of the above
EWR is to assure that these problems do not extend to other motors.
The inspection effort included witnessing the removal of the Raychem
and the subsequent inspection and documentation of the results.
These results were forwarded to design engineering for a fi na 1
_assessment of w~ether the quality of the terminations is acceptable
or require repairs.
Specific discrepancies noted on the 2-FW-P-38 motor were as follows:
Lugs connected back. to back resulting in maximum conductor
misalignment
Bolts were 1 inch long, resulting in sharp protrusion *Of splice
and excessive stretching of Raychem covering material
12
Breakaway torque of connecting bolts was only 4 to 5 ft-lbs
Lugs on field cable were 600V instead of 5kV
Damaged field lug from torquing against smaller motor lug
The above discrepancies were reported on station deviation S2-89-276,
dated March S, 1989.
The inspector noted during the witnessing of
the inspection that the entire Raychem (shims) was not removed.
The
discussion section of the above EWR states that the Raychem will be
completely removed on all motors in environmentally harsh areas. The
AFW motors are located in the steam side of the safeguards area which
is susceptible to a steam line break.
The licensee agreed that the
entire Raychem should have been removed and subsequently completed
its removal. The inspector considers that additional guidance should
have been provided to specify classification of environments in order
to ensure appropriate inspections are conducted.
This item is an
example of a lack of adequate instruction for the inspection of motor
terminals.
Attachment II, Record 48 of EWR 89-148, contains the procedure for
removal, inspection and retermination of the motor leads for
- 2-FW-P-38.
On March 28, 1989, the inspector reviewed the official
copy of this procedure and discovered a problem with the method of
documenting and resolving the discrepancies. Specifically, step 1.4
of this procedure was signed by the design engineer and a sketch was
incorporated specifying the requirements for retermination of this
connection.
The next step (step 1.5) directs the craft to
reterminate the cable in accordance with the generic station Raychem
instructions and the sketch provided in the previous step.
The
sketch that was included by the design engineer did not adequately
address the deficiencies noted during the 'as found' inspection (i.e.
600V lugs) and was incorporated into the procedure without any review
process. The actions taken by the design engineer appears to be in
compliance with the EWR as it is currently written. The end result
is that a single individual can issue instructions to disposition
defects and assemble a field connection without prior review or
approval.
The licensee agreed with the inspector's findings and
placed an. engineering hold on the EWR until the problem is reviewed
and resolved.
This item, as well as the example discussed above,
are identified as one example of violation 280,281/89-08-02, for
failure to provide adequate instruction for inspection of motor
terminals.
-
b.
Evaluation of Training For Installation of Raychem Electrical
Insulation Kits
The inspectors attended a training session for the electrical craft
in regards to the installation of Raychem kits.
These heat
shrinkable components are installed over electrical cable bolted
splices for (1) mechanical protection, (2) electrical insulation, and
as only 4 to 5 ft-lbs
of SkV
t smaller motor lug
- ation deviation S2-89-276,
during the witnessing of
ims) was not removed.
The
that the Raychem will be
,mentally harsh areas. The
f the safeguards area which
e licensee agreed that the
.nd s*ubsequently completed
additional guidance should
on of environments in order
inducted.
This item is an
for the inspection of motor
contains the procedure for
- f the motor leads for
- tor reviewed the official
p
with the method of
e
ecifically, step 1.4
n e ,neer and a sketch was
for retermination of this
directs the craft to
the generic station Raychem
the previous step.
The
~ngineer did not adequat:lY
, *as found' inspection (1.e.
- procedure without any rev~ew
, engineer appears to be ,n
tly written. The end r~sult
nstructions to cfisposition
n without prior review or
~ inspector 1 s'findings and
ntil the problem is reviewed
- e example discussed above,
1 t; on 280, 281/89-08-02, for
., for inspection of motor
ion of Raychem Electrical
sion for the electrical craft
~a-
kits.
These heat
,e
ctri cal cab 1 e bo 1 ted
(
ectrical insulation, and
13
1t moisture.
The course was conducted by a Raychem
and a licensee electrical engineer.
The training
1ychem basic installer/inspector course, which included
of what heat shrinkable tubing is and how it is made.
were various installation techniques and potential
removal
of the tubing after installation.
The
ed that most problems encountered in the field are not
perforr.1ance, but to misapplication of the ~aychem
- ture,
smaller groups
performed actual
Raychem
ing training kits.
The groups were then required to
chem material
from
the electrical cables.
The
rved various groups and their techniques during the
1ing. The inspectors noted by discussions with three
in the training class that they had used Raychem
in the field numerous times.
was made by a licensee electrical engineer regarding
- oblems associated with Raychem applications on
,nents found at Surry. The groups were informed to be
rt any of these conditions.
The engineer also
,f the requirements in procedure NUS 2030, Specifica-
- ical Installation, and noted several areas where
1ractices varied from the Raychem instructions.
The
der that the training was accomplished in an adequate
1aintenance/Modification On
The
Low Head Safety
currently removing the Unit 1 low head safety
-SI-P-lA in order to r~place the replica parts (non
nt manufacturer parts) previously placed in the
ector reviewed procedure MMP-P-C-SI-090, Remova 1,
pection, Repair, Reassembly, and Reinstallation of
Injection Pump
11Safety -Related", dated August 20,
and signed off portions of this procedure were
spector attended two of the pre-job briefings held
e team performing this job.
_ 1d, part of the column and part of the shaft have
1 the pump well.
The inspectors will follow the
?maining parts, including removal of the two stage
TI of the well, and observe the replacement of the
ing the next inspection period.
iected, additional examples of a violation were
14
6.
Surveillance Inspections (61726)
During the reporting period, the inspectors reviewed various surveillance
activities to assure compliance with the appropriate procedures as
fo 11 ows:
Test prerequisites were met.
Tests were performed in accordance with approved procedures.
Test procedur2s appeared to perform their intended function.
Adequate coordination existed among personnel involved in the test.
Test data were properly collected and recorded.
Inspection areas included the following:
a.
Containment Spray Check Valves
The inspector reviewed periodic test 1-PT-17.4, Containment Spray And
Recirculation Spray Check Valves, dated February 16, 1989.
This
surveillance
procedure,
performed
during
refueling
shutdown
conditions, implements the requirements of Technical Specification
paragraph 4. 5. A. 4 that each weight 1 oaded check va 1 ve within the
containment be tested to verify capability to open by pressurizing
upstream and verifying air flow through the check valve.
In
addition, verification of seating of the check valves is accomplished
by applying a vacuum upstream of the valves and verifying no air
flow.
The inspector discussed the test method with the operations staff
that performs the test, as we 11
as the appropriate cognizant
engineer, and expressed concern that the test procedure was not
specific as to which rotameter to use when verifying the presence or
absence of flow.
The procedure requires that an air test rig with a
rotameter be in sta 11 ed upstream of the valve to be tested and a
rotameter to be installed downstream of the valve.
The procedure
step that verifies flow states: "Note the flow on the rotameter when
the check valve lifts".
The use of the rotame.ter installed on the
test rig may not provide positive verificatio*n that air flow is
passing through the check valve in lieu of leaking out an unknown
path in the maintenance boundary.
Discussions with operational
- -personnel that have performed the test indicate that the common
practice is to use the downstream rotameter.
The system engineer
concurred and agreed to clarify the test procedure.
No additional
discrepancies or outstanding concerns were noted.
b.
15
Special Test 242, Unit 1 B Train Bus Deactivation Test
During the week of March 13 - 17, 1989, the inspectors witnessed
performance of ST-242.
The purpose of the test was to systematically
deenergize the Unit 1 J bus and to verify that B train components are
powered by the lJ bus.
The inspectors monitored performance of
testing from the control room including discussions with the test
di rector and unit SROs.
The contra 11 i ng procedure was frequer.t ly
reviewed during test performance.
The inspectors noted th~t the test
evolutions were being properly controlled and that unit status was
not adversely affected.
No discrepancies were noted.
c.
Flowtesting of the Unit 2 Inside Recirculation Spray Pumps
The inspector reviewed ST-233, Operability of IRS Pumps, which was
issued and approved on December 2, 1988.
The purpose of the test is
to measure pump flow, system pressure, and motor current over a range
of different fl owrates, and to evaluate these recorded parameters
against pump data associated with the manufacturers pump curves.
This engineering evaluation will establish pump operability status as
well as setting reference values for the IRS pumps in accordance with
Section XI of the ASME code.
The inspector reviewed the initial
conditions, precautions, and instrumentation requirements listed in
the test as well as the actual performance steps.
The inspector
identified the following test procedure weaknesses to the licensee:
Provide a means for monitoring of containment sump water
temperature.
This requirement is based on precaution 4.2 which
states that the temperature of the sump water should remain
below 120 degrees F for personnel protection.
Add steps that verify remova 1 of cleanliness covers from the
system I s permanent spool pieces and piping prior to their
reinstallation.
The licensee incorporated the above items into the test procedure.
The inspector conducted a walkdown of the 8 inch flow test line in
the Unit 2 containment and verif.ied that the pressure gages and
flowmeter calibration were withfn the required frequency.
The
inspector noted that the test line valves were not tagged with their
_respective va 1 ve numbers.
The licensee test di rector stated that
these va 1 ves would be properly tagged prior to test performance.
A
subsequent inspection verified proper tagging of the test valves.
ST-223 was initiated on March 23, 1989, and the inspector witnessed
system alignment, filling .and venting of the test instrumentation,
and initial pump operation. However, during the test, the flowmeter
exhibited large fluctuations .such that meaningful flow data could not
be obtained. The test was secured to resolve the flowmeter problem.
Additional test monitoring was not accomplished for this test during
this inspection period.
16
Within the areas inspected, no violations or deviations were identified.
7.
Licensee Event Report Review (92700)
The inspectors reviewed the LERs listed below to ascertain whether NRC
reporting requirements were being met and to determine appropriateness of
the corrective actions. The inspector's review also included followup on
implementation of corrective action and review of licensee docum~ntation
that all required corrective actions were complete.
LERs that identify violations of regulations and that meet the criteria of
10 CFR, Part 2, Appendix C,Section V are identified as LIV in the
following closeout paragraphs.
LIVs are considered first-time occurrence
violations which meet the NRC Enforcement Policy for exemption from
issuance of a Notice of Violation.
These items are identified to allow
for proper evaluations of corrective actions in the event that similar
events occur in the future.
(Closed) LER 280/88-17, Debris in Containment Sumps Due to Inadequate
Inspection Program.
The issue involved licensee identification of foreign
material which was discovered in the Unit 1 containment sump during pump
testing.
Licensee corrective action included cleaning of the sumps and
associated piping.
In addition, the licensee instituted improvements to
their foreign material exclusion program to prevent recurrence.
This
i~sue resulted in enforcement action which was discussed in NRC Inspection
Report 280,281/88-28.
This LER is closed.
(Closed)
LER 280/88-18, Personnel Overexposure.
The issue involved
exposure to a contract employee of radiation in excess of the quarterly
limit as specified in 10CFR20.
Corrective action for this condition
included enhancements to the radio l ogi cal protection program at the
station. This issue resulted in enforcement action which was discussed in
NRC Inspection Report 280,281/88-25.
This LER is closed.
(Closed) LER 280/88-22, Unit Rampdown to Cold Shutdown Due to MOV-CS-1018
...Leakage.
The issue involved leakage past a containment isolation valve
when Unit 1 was at intermediate shutdown conditions.
The unit was
returned to the cold shutdown condition as required by Technical
Specifications and repairs were made to the subject Vijlve.
The inspector
verified that the valve repairs were comp 1 eted and that the va 1 ve was
properly retested. This LER is closed.
(Closed) LER 280/88-19, Reactor Trip/Safety Injection Due to Spurious Hi
CLS Signal as a Result of a Malfunctioning Relay.
The issue involved a
reactor trip/safety injection of Unit 1 from 100 percent power.
The trip
was caused by a failed relay.
The relay was replaced and satisfactorily
tested.
The inspector reviewed the post-trip report and monitored
licensee SNSOC actions prior to restart.
This LER is closed.
I
I
17
(Closed) LER 280/88-31, Potential for an Inadequate Service Water Supply
During a LOCA with a Loss of Offsite Power.
The issue involved the
licensee's review of the design bases of the Service Water System.
During
that review several deficiencies were identified which required corrective
actions prior to unit restart.
The corrective actions have been
identified and are ongoing.
This issue resulted in enforcement action
which was discussed in NRC Inspection Report 280,281/88-32.
Th.;s LER is
closed.
(Closed) LER 280/88-32, Potential for Overload of EDGs During a LOCA with
LOOP Due to Design Deficiency.
This issue involved the licensee's review
of a design deficiency associated with potential overload of the EDGs
during a design bases accident followed by a LOOP.
The licensee placed
the operating unit in cold shutdown and has subsequently modified the
emergency busses to a 11 ow for appropriate sequential loading of these
buses in the worst case scenario.
The inspector reviewed the licensee's
LER and has monitored licensee corrective actions and testing.
This LER
is closed.
(Closed) LER 280/88-33, Main Control Room Envelope AC System Inadequate.
This issue involved the licensee's review of present capacity of the
subject system based on initial evaluation of system test results which
were conducted in the Fall 1988.
Testing concluded that the system would
not perform its design function.
Corrective actions included design
changes and refurbishment of the present system for interim use.
Additional long term corrective action will include development and design
of new equipment.
The inspectors will continue to monitor the licensee's
interim and long term corrective actions.
This issue resulted in
enforcement action which was discussed in NRC Inspection Report 280,
281/88-41.
This LER is closed.
(Closed) LER 280/88-40, Accumulation of Gases in Suction Piping of HHSI
Pumps Due to Inadequate Design.
The issue involved potential accumulation
of gases in the suction piping of both units' HHSI pumps.
Corrective
-action* included installation of high point vents in the suction lines for
each unit.
The inspector verified that the high point vents were
installed as specified.
This issue resulted in enforcement action which
was discussed in NRC Inspection Report.280,281/88-41.
This LER is closed.
(Closed) LER 281/88-05, Inoperable Control Rods Due to Failed Phase
Control Cards.
The issue involved a failure of the rod control system
requiring initiation-of a unit ramp to shutdown conditions as required by
Technical Specifications.
Licensee corrective actions included repairs to
the rod control system and testing to confirm operability.
Testing was
accomplished satisfactorily; however, this issue resulted in enforcement
action which was discussed in NRC Inspection Report 280,281/88-11. This
LER is closed .
J
18
(Closed) LER 281/88-06, Fail~re to Comply with Technical Specification Due
to Personnel Consideration.
The issue involved failure to post a fire
watch in the Unit 2 containment within Technical Specification time
requirements while the unit was at full power.
Corrective action included
alternate monitoring for a containment fire. Additional corrective action
included submittal of a Technical Specification change ,to allow for
alternate monitoring for a fire. The inspector verified that the licensee
prerared a Technical Specification change which was consistent with
requirements of other similar plants.
This LER is closed.
(Closed) LER 281/88-08, Inadequate Boric Acid Flowpaths Due to Personnel
Error and Inadequate Procedures.
The issue involved a loss of boric acid
flowpath to the suction of the charging pumps in violation of Technical
Specification 3.2.B.4.
The cause of this violation was personnel error
and inadequate procedure.
Corrective actions included a procedure
revision to provide for proper system alignments. The inspector verified
that the procedure revisions were accomplished and appropriate operator
training was conducted .. This item is identified as a LIV (281/89-08-03)
for failure to provide adequate procedure to ensure
Technical
Specifications are complied with.
This LER is closed.
(Closed) LER 281/88-10, Reactor Trip Due to Low Low Steam Generator Level
Due to Closure of Turbine Governor Valves.
The issue involved a Unit 2
reactor trip from full power due to a valid steam generator low low level
signal.
The cause of the valid trip signal was rapid closure of the
turbine governor valves. Licensee actions after the trip and appropriate
inspector followup were discussed in NRC Inspection Report 280,281/88-18.
This LER is closed.
(Closed) LER 281/88-24,
11A
11 and
118
11 Inside Recirculation Spray Pumps Found
with Internal Damage.
The issue involved discovery of internal damage to
the subject pumps during refurbishment.
Licensee corrective actions
included overhaul of the pumps.
In addition, full flow testing will be
conducted on these pumps during each refueling outage to prove continued
operability. The inspectors reviewed the licensee actions and witnessed
IRS pum*p testing.
This LER is closed.
(Closed) LER 281/88-25, LHSI
Pump Discharge MOVs 2863A and B Power
Sup.plies Interchanged. The issue involved licensee determination that the
subJect valves were powered from the wrong train power supply.
Licensee
corrective action included correcting the power supply discrepancy.
In
addition, an extensive test program was instituted to determine if any
additional problems of this nature existed.
The inspectors monitored
licensee corrective actions and evaluations in this area.
This issue
resulted in enforcement action which was discussed in NRC Inspection
Report 280,281/88-45.
This LER is closed.
19
8.
Action on Previous Inspection Findings (92702)
(Closed) URI 280/89-06-04, Requirements for Returning Safety-Related
Syst~ms to Service After Maintenance or Modification. This item involved
additional review of the l icensee 1 s program which requires a technical
review of modifications to systems prior to returnin§ to service.
Additional reviews were conducted by the inspector during this period and
are addressed in paragraph 4.b.
This URI is closed.
(Reinspected/Closed) IE Bulletin 84-03, Refueling Cavity Water Seal.
The
licensee's January 9, 1989 revised response to IE Bulletin 84-03 provided
additional corrective actions with regard to the reactor cavity seal
assembly.
These corrective actions have been verified, as documented in
NRC Inspection Reports 280,281/88-38 and 88-47, and this item is closed.
9.
Exit Interview
The inspection scope and findings were summarized on April 4, 1989, with
those individuals identified by an asterisk in paragraph 1. The following
new items were identified by the inspectors during this exit:
One violation (paragraph 3.f(2)) was identified regarding a failure to
provide and/or follow procedure involving startup, operation, and shutdown
of systems and components involving nuclear safety of the station
(280/89-08-01).
One violation, with three examples, was identified for failure to meet the
requirements of 10 CFR 50, Appendix B, Criterion V (280,281/89-08-02).
The examples included failure to provide adequate procedures for the
operation and control of instrumentation valves (paragraph 4.a.(2)),
failure to follow procedure for performing technical reviews before
returning components/systems to service (paragraph 4.b), and failure to
provide adequate instructions for the inspection and retermination of
motor connections (paragraph 5.a).
_One weakness was identified_ (paragraph 4.a.(l)) concerning an apparent
lack of sensitivity. to harmful contamination (i.e. chlorides) on safety
related stainless steel piping.
The licensee acknowledged the in"spection findings with no dissenting
comments.
The licensee did not identify as proprietary any of the
materials provided to or reviewed by the inspectors during this
insp-ection.
10.
Index of Acronyms and Initialisms
cc
ccw
ABNORMAL OPERATING PROCEDURE
COMPONENT COOLING
COMPONENT COOLING WATER
20
CFR
CODE OF FEDERAL REGULATIONS
CIRCULATING WATER
DESIGN CHANGE
DP!
DELTA PRESSURE INDICATORS
DR
DEVIATION REPORT
EOG
EMP
ELECTRICAL MAINTENANCE PROCEDURE
ENGINEERED SAFETY FEATURE
EMERGENCY SERVICE WATER
ENGINEERING WORK REQUEST
HEAT EXCHANGER
HIGH PRESSURE SAFETY INJECTION
INSPECTION AND ENFORCEMENT
IF!
INSPECTOR FOLLOWUP ITEM
IRS
INSIDE RECIRCULATION SPRAY
!SI
INSERVICE INSPECTION
LER
LICENSEE EVENT REPORT
LIV
LICENSEE IDENTIFIED VIOLATIONS
LHSI
LOW HEAD SAFETY INJECTION
LOSS OF COOLANT ACCIDENT
MOTOR OPERATED VALVE
NRC
NUCLEAR REGULATORY COMMISSION
NUCLEAR REACTOR REGULATION
OP
OPERATING PROCEDURE
PRESSURE INDICATOR
PREVENTATIVE MAINTENANCE
POUNDS PER SQUARE INCH
POUNDS PER SQUARE INCH GAUGE
PERIODIC TEST
QUALITY ASSURANCE
QUALITY CONTROL
REACTOR OPERATOR
RECIRCULATION SPRAY SYSTEM
RADIATION WORK PERMIT
SAFETY INJECTION
SNSOC
STATION NUCLEAR SAFETY AND OPERATING COMMITTEE
SENIOR REACTOR OPERATOR
TS
TECHNICAL SPECIFICATIONS
UNRESOLVED ITEM
VS
- VENTILATION SYSTEM