IR 05000327/1986006

Insp Repts 50-327/86-06 & 50-328/86-06 on 860106-0205.No Violation or Deviation Noted.Major Areas Inspected: Operations Performance,Sys Lineups,Radiation Protection & Security & Housekeeping

ML20154L600
Person / Time
Site:	Sequoyah, 05003288
Issue date:	03/04/1986
From:	Jenison K, Linda Watson, Weise S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20154L598	List: IR 05000327/1986006 ML20154L593
References
50-327-86-06, 50-327-86-6, 50-328-86-06, 50-328-86-6, NUDOCS 8603110536
Download: ML20154L600 (11)

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U.dlTED STATES

' NUCLEAR REOULATORY COMMISSION REolONil

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j 101 MARIETTA STREET. ,

e ATLANTA.oEORGI A 30323 .

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t Report Nos.: 50-327/86-06 and 50-328/86-06 r

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Licensee: Tennessee Valley Authority 500A Chestnut Street l l

Chattanooga, TN 37401 Docket Nos.: 50-327 and 50-328 License Nos.: OPR-77 and OPR-79 Facility Name: Sequoyah Units 1 and 2 ,

l Inspection Conducted: January 6,1986 thru February 5,1986 Inspectors: WA' D o_s /// A $fk8 L K. M. Jent s6n, Senior Kide Inspector ' Date Signed [

X Y M , ~ /// A o&hWS

! t. J. Wat@ftfenf. Ksgi 9ct6r ' Da ~e igned :

Approved by: 2 o Y b l S. P. Weise, Section Chief Date Signed i t Olvision of Reactor Projects  !

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SUMMARY Scope: This routine, announced inspection involved 417 resident inspector-hours t

. onsite in the areas of operational safety verification including or,erations i l performance, system If neups, radiation protection, security and housekeeping i inspections; surveillance and maintenance observations; review of previous  :

inspection findings; followup of events; review of Ilcensee Identified items; and I review of IE Information Notice Results: No violations or deviations were identified. One unresolved item was i

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identified involving the reagent air supply to the hydrogen analyzers as  !

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i REPORT DETAILS Licensee Employees Contacted H. L. Abercrombie, Site Director

• P. R. Wallace, Plant Manager

• L. M. Nobles, Operations and Engineering Superintendent

• B. M. Patterson, Maintenance Superintendent J. M. Anthony, Operations Group Supervisor

• R. W. Olson, Modifications Branch Manager

• R. Sedlacik Electrical Section Manager, Modifications Branch

• H. D. Elkins, Instrument Maintenance Group Manager

• C. W. LaFever, Instrument Engineering Supervisor M. A. Scarzinski, Electrical Maintenance Supervisor

• R. Harding Engineering Group Manager

• 0. C. Craven, Quality Assurance Staff Supervisor

• 0. L. Cowart, Quality Surveillance Supervisor

• 0. E. Crawley, Health Physics Supervisor

• B. kirk, Compliance Supervisor M. L. Frye, Compliance Engineer H. R. Rogers, Compliance Engineer

• R. C. Burchell, Compliance Engineer

• E. W. Whitaker, Licensing Engineer D. H. Tullis, Mechanical Maintenance Group Supervisor J. H. Sullivan, Regulatory Engineering Supervisor

"C. E. Chmielewski, Nuclear Engineer, NSS Other licensee employees contacted included technicians, operators, shif t engineers, security force members, engineers and maintenance personne Other NRC Personnel:

• P. E. Harmon, NRC Resident Inspector

• Attended exit interview Exit Interview The inspection scope and findings were summarized with the Plant Manager and members of his staff on February 13, 1985. One unresolved item described in paragraph 9 was discussed, lhe ifcensee committed to provide appropriate corrective action completion dates as discussed in paragraph 3. The licensee acknowledged the inspection findings. The licensee did not iden-tify as proprietary any of the material reviewed by the inspectors during this inspectio During the reporting period, frequent discussions were held with the Site Of rector, Plant Manager and other managers concerning r inspection findings. At no time during the inspection was written material provided to the licensee by the inspector :

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l Licensee Action on Previous Inspection Findings (92702)

(Closed) Violation 327,328/85-23-0 The inspector reviewed the licensee's response to the violation dated August 2,198 This included a review of i:

l che revision to TI-70, Cleaning and Decontamination of Plant Equipment. The  !

l procedure was revised on August 13, 1985, to clarify requirements for end  ;

caps. The inspector determined that training described in the response had  ;

been completed on January 17, 1986. The response to the violation states  ;

under the heading Corrective Steps Taken and Results Achieved, " handling l requirements for stainless steel will be reemphasized with craft personnel '

during training sessions." The response further states, under the heading  !

! Date When Full Compliance Will Be Achieved, that the plant would be in full f compliance on August 22, 198 The licensee stated that the full compliance date was intended to apply to the procedure revision and compliance with the procedure and did not include }

the training commitment. The licensee stated that no commitment date had '

I been made for the trainin I The inspector determined that there had been other responses to violations i in which dates provided under headings such as "date when full compliance

! was achieved" does not encompass all corrective actions stated. The

'j ambiguity of the wording could lead an NRC reviewer to accept a response in [

which the Ifcensee maintains that no ccmmitment date was provide ,

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The licensee is conducting a review of all open and closed NRC commitments i

! as discussed 4 the Sequoyah Nuclear Performance Plan Section 3.2. This item and the res,snse to violation 328/85-24-02 discussed below have already '

I been identified in that review. The licensee is providing revised responses ,

j to commitments missed which the licensee considers covered under the due >

dates specified in the response Consequently, any identified missed j i actions which the licensee considers to be open ended would be scheduled and i completed, but may not be identified to the NRC by lette I J This violation is closed since all corrective actions have been complete !

1 Followup on commitment dates in responses and review of the licensee's  :

l commitment tracking review is identifled as Inspector Followup Item 327, l

, 328/86-06-0 The licensee has committed to provide appropriate due dates l

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for each commitment made in future submittal (

4 (Closed) Violation 328/85-24-02. The inspector reviewed the licensee's [

i response to the violation dated September 6, 1985. The respnnse stated that '

the plant would be in full cortpliance by January 1,198 The inspector k reviewed the December 31, 1985 revision to SQM-2, Maintenan:e Management

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System, which incorporated directions on post modification testin The

! inspector also reviewed training on post modification testing for planner The training was completed on January 16, 1986. This item was identified in

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the licensee's review of NRC commitments conducted under the Nuclear i Performance Pla $1nce corrective action has been completed, this i violation is close However, followup on meeting commitment dates will bo l reviewed as discussed above in Inspector followup Item 327,328/86-06-0 ,

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4. Unresolved Items

, Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve violations or devja-tions. One unresolved item identified during this inspection is discussed in paragraph . Operational Safety Verification (71707) Plant Tours .

The inspectors observed control room operations, reviewed applicable <

' logs, conducted discussions with control room operators, observed shift turnovers, and confirmed operability of instrumentation. The inspec-tors verified the operability of selected emergency systems, reviewed i tagout records, verified compliance with Technical Specification (TS)  !

Limiting Conditions for Operation (LCO) and verified return to service  ;

of affected components. The inspectors verified that maintenance work <

orders had been submitted as required and that followup activities and  !

prioritization of work was accompItshed by the licensee.

l Tours of the auxiliary, control, and turbine buildings and containment  ;

( were conducted to observe plant equipment conditions, including poten-tial fire hazards, fluid leaks, and excessive vibrations and plant l housekeeping / cleanliness conditions.

l The inspectors walked down accessible portions of the following safety- i related systems on Unit 1 and Unit 2 to verify operability and proper i valve alignment:

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l Residual Heat Removal System (Units 1 and 2)

Diesel Generator fuel Oil System (Units 1 and 2)  !

480 Volt AC Vital Power Supply (Units 1 and 2) l

, Auxiliary Contrni Air (Units 1 and 2)

l Auxiliary Building Gas Treatment System (Units 1 and 2)

l 125 VOC Vital Battery Boards and Vital Batteries 120 VAC Vital Instrument Power Boards No violations or deviations were identifie .

i Security During the course of tre inspection, observations relative to protected '

and vital area security were made, including access controls, boundary l Integrity, search, escort, and badgin The inspector identified ;

certain facets of the licensee's implementation of personnel and package search procedures which appeared inadequat These issues were discussed with a NRC Region !! security specialis fhese issues ,

involve safeguards information and are discussed in NRC Inspection i Report 327,328/86-1 i l \

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. Radiation Protection The inspectors observed Health Physics (HP) practices and verified implementation of radiation protection control. On a regular basis,  ;

radiation work permits (RWPs) were reviewed and specific work activi-ties were monitored to assure the activities were being conducted in i accordarice with applicable RWPs. Selected radiation protection *

instruments were verified operable and calibration frequencies were reviewe No violations or deviations were identifie . Monthly Survelliance Observations (61726)  !

The inspectors observed Technical Specification (TS) required surveillance testing and verified that testing was performed in accordance with adequate procedures; that test instrumentation was calibrated; that Limiting Condi-tions for Operation were met; that test results tret acceptance criteria and l were reviewed by personnel other than the individual directing the test; i

that deficiencies were identifled, as appropriate; that any deficiencies

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identified during the testing were properly reviewed and resolved by I I

management personnel; and that system restoration was adequate, for ,

j complete tests, the inspector verified thit testing frequencies were met and tests were performed by qualified individual ,

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The inspector witnessed / reviewed portions of the following surveillance test activities:

i SI-686 Channel Calibration for High Range Accident Radiation Monitors i

, During observation of the 18 month calibration of the containment radiation monitors, 1-RE-90-212 failed to provide the appropriate l 1 control room indication when the 10R source was attached to the

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munitor. The Ilcensee has written a maintenance request to correct the proble Followup on this deficiency is identified as Inspector i followup Item 327,328/86-06-0 l

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l 51-166.6 Pust Modification Test for Category A and 0 Valves SI-7 Electrical Power Systems  :

During diesel generator (OG) testing conducted this month, testing results obtained by stopwatch indicated that one DG did not meet the i Technical Specification 4.8.1.1.2.a.4 requirement that the DG voltage l and frequency be within certain Ilmits in 10 seconds af ter a start signal. During the tests observed by the inspector, the licensee

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utilized a strip thart recorder to monitor the voltage and frequency I j af ter the start signa It wts determined that the voltage and

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frequency were within the required ranges in 7 to 8 seconds and then l 4  ;

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overshot the range, coming back within the required values in less than 11 second The review of the results of further testing and the interpretation of the requirements for the end point of the 10 second time frame required by the TS is identified as Inspector Followup Item 327,328/86-06-0 IMI-92-SRM-CAL Source Range Monitor Calibration Channel N-32 IMI-99-RT-6.22 Response Time Testing of FT-68-71A and FT-68-48A - RCS Flow During observation of the response time testing, the inspector noted that the procedure required the use of stainless steel tubes to attach the hydraulic signol generator to the RCS flow transmitters. Copper tubing had been used for the attachmen A change had not been processed for the deviation from the procedure. The technicians stated that they believed that stainless steel was only required in high pressure applications; however, the technicians decided to stop the response time test and process a change to the procedure. After review of equipment requirements, the licensee stated that the stainless steel tubing was only needed in high pressure appIlcations. In this test, pressure was approximately 15 psig. The inspector reviewed the events with management, i.e. , that the procedure had not been followed and that a change had not been sought until af ter the inspector had discussed the deviation with the technicians. The inspector emphasized the need for adherence to safety-related procedures. In this instance, the failure to follow procedure had no safety significance, therefore, no violation will be issue However, licensee actions to assure adherence to procedures will continue to be reviewed during future inspection No violations or deviations were identified.

7. Monthly Maintenance Observations (62703) Station maintenance activities of safety-related systems and components were observed / reviewed to ascertain that they were conducted in accord-ance with approved procedures, regulatory guides, industry codes and standards, and in conformance with T The following items were considered during this review: LCOs met while components or systems were removed f rom service; redundant components operable; approvals obtained prior to initlating the work; activities accomplished using approved procedures and inspected as appilcable; procedures adequate to control the activity; troubleshooting activities controlled and the repair record accurately reflected what actually took place; functional testing and/or calibrations performed prior to returning components or systems to service; quality control records maintained; activities accomplished by qualified personnel; parts and materials used properly certified; radiological controls implemented;

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QC hold points established where required and observed; fire prevention

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controls implemented; outside contractor force activities controlled in accordance with the approved Quality Assurance (QA) program; and housekeeping actively pursue IE Circular 78-19 concerned events related to safety system circuit designs which incorporate manual override (bypass) features. Thi<

issue was also addressed in an NRC March 19, 1980 letter to the licensee. The licensee's review resulted in Design Change Request (DCR) SQ-DCR-664 which was written on March 17, 1980. The DCR requested that the engineered safety system be changed so that a safety injection signal would give containment vent isolation directly without interference from override switches. TVA responded to NRC in an April 24,1980 letter which stated that design changes had been initi-

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The deficiency documented in the DCR involved an override feature which existed in the design of the containment ventilation system retentive memory circuit. The actuating signals for the circuit are a high containment radiation monitor signal or an SI signal. On manual reset, the circuit sealed in a retentive memory output signal which defeated all actuating signals until the original actuating signal was remove On this same manual reset, however, the containment ventilation i isolation was also reset independent of the retentive memory circui In an event where a high radiation signal was present the circuit could be reset without clearing that signa This deficiency could have prevented the closure of 30 containment vent isolation valves on an actual SI signal if the valves had been manually opened following manual reset of a spurious signa Administrative action was taken to preclude reset of the containment *

ventilation isolation with an actuating signal presen System Operating Instruction 501-32.28 (Unit 1 and 2) was revised on April 30, 1981 to include a caution statement under the recovery from a

containment ventilation system isolation actuation to instruct the operator not to reset the isolation until the actuating signal is

, cleare The caution states that by resetting under these circum-

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stances other isolation signals are blocked.

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The licensce requested that Westinghouse review the design problem and provide a modification to the circuitry to separate the SI signal from the high radiation signa The modification package was issued by the vendor in November, 1984. The modifications were performed in Unit 1 during October, 1985 and on Unit 2 during January, 1986. The inspector reviewed the completed workplans (WP) 117426 and 11851 for Unit 1 and proposed Wps 11887 and 11908 for Unit 2. These WPs covered the installation and post modification testing of the modification No i violations or deviations were identified.

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During discussions with the cognizant engineer for these modifications, 1 the engineer stated that the deficiency was applicable to Watts Bar and

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had been corrected at Watts Ba During this review the inspectors noted that other Engineered Safety Features (ESF) had the same type of retentive memory design; however,

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these features isolate valves that have other than containment isola-tion functions. A review of these features is identified as Inspector Followup Item 327, 328/86-06-0 During implementation of WP 11887 on Unit 2 on January 23, 1986, the Residual Heat Removal System (RHR) was isolated when the power supply to the Solid State Protection System circuitry involved in the modification was deenergized. Unit 2 had been in Mode 5 for 5 months

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at the time of the event. RHR was returned to service in one hou The licensee determined that this event.was not reportabl Followup on this ' event is identified as Inspector Followup Item 327,

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328/86-06-0 The inspector observed cable splicing and QC review of hold points for i crimping and sealing cables for the relocation of pressurizer level instrument 2-PDT-68-339 under Work Plan 1188 The inspector observed maintenance activities on the "A" Component Cooling System (CCS) Heat Exchanger (1-HEX-70-08) which was performed in order to resleeve and plug defective tubes. The following data was reviewed:

MR AS49627

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MI 6.20, Configuration Control During Maintenance Activities SMI-0-70-1, Sleeving of CCS Heat Exchanger Tubes MI 6.14, Plugging of HX Tube Leaks MI 6.15, Tightening Bolted Joints

! SI 679, ERCW Heat Exchanger Inspection Unresolved Safety Question Determination 85-24 i Drawing 47W859-1 -i i Maintenance on limit switch 2-LS-067-0345 was performed to adjust the actuation setpoint. Maintenance Request A543246 was reviewed.

. The inspector reviewed work activities on WR B108836. The work request covered the upgrade .of discharge piping in the Essential Raw Cooling Water traveling screen wash pumps from Class G to Class C piping. At

the time of the inspection, two welds had been built up to meet the '

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Class C requirement The inspector also reviewed the documentation for signoffs on QC holdpoints.

No violations or deviations were identified.

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8 Licensee Event Report (LER) Followup (92700)

-The following LERs were reviewed 'and closed. The inspector verified that:

reporting requirements had been met; causes had been identified; corrective actions' appeared appropriate; generic applicability had been considered; the LER forms were complete; the licensee had reviewed the event; no unreviewed safety questions were involved; and violations of regulations or Technical Specification conditions had been identifie LERs Unit 1 327/83155 Inoperable Feedwater Flow Transmitter 327/85048 Failure to Properly Review Maintenance Procedures 327/85049 Failure to Perform Surveillance Requirements 327/85050 Containment Ventilation Isolation 327/85051 Missed Hourly Fire Watches

.LERs Unit 2 328/84013 Rupture of Pressurizer Relief Tank Disc Rev. 1 328/83024 Inoperable Feedwater Flow Channel 9. . Event Followup (93702, 62703) -- The inspector reviewed the licensee's action in regard to the reanalysis of a main steam line break (MSLB) inside the steam vaults considering the effects of superheated steam produced when steam generator tubes uncove Safety-related equipment in the steam vault could be adversely affected by the resulting environment. The-licensee's letter to the NRC dated August 2,1984, provided the basis for the failure evaluation of the equipment located in the steam vaul The analysis submitted, which indicated that essential actions could be completed and events mitigated prior.to equipment damage, was based on the inside containment mass and energy release analysis performed by Westinghouse on the Catawba Nuclear Statio Westinghouse has completed a reanalysis of the MSLB with superheated stea The reanalysis indicated that equipment in the steam vaults could fail when subjected to the higher temperatures. This analysis, however, did not consider certain design features incorporated at Sequoyah, such as the Boron Injection Tan The licensee has performed .a comparison study with the reanalysis performed by Westinghouse on Diablo Canyon. This analysis incorporates features at Diablo Canyon which are essentially identical to Sequoyah and were not assumed in the generic Westinghouse analysis. The licensee is contracting with Westinghouse to provide a site specific analysis of the MSLB inside the steam vaults for Sequoya .

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The licensee held a telecon with the NRC on February 6,1986, to discuss the revised computer models to be utilized in the reanalysi b. On December 11, 1985, during a system walkdown conducted by the Sequoyah Nuclear Plant Quality Assurance Organization, it was discovered that the reagent air supply line for Unit 2 "A" train containment hydrogen analyzer was connected to the control air syste The control air system is nonessential and not seismic Category I. The licensee declared the Unit 2 "A" train to be inoperable. At the time the alignment error was identified, Unit 2 was in mode 5; therefore, no Limiting Condition for Operation action statement was entered. The modification resulting in the alignment error was installed in January 198 Unit 2 was operated' in violation of LCO 3.6.4.1 from approximately January 1985 to August 21, 198 ..

The inspectors reviewed licensee documents to determine adequacy of design change control Nonconformance Report NCR-SQN-EEB-8014 identified equipment which did not meet environmental qualification requirement Design Change SQ-DCR-972 was written January 5, 1984, to relocate instrumentation and equipment to accessible mild environments in accordance with . NUREG 0588. DCR-972 was implemented through approximately 99 Engineering Change Notices (ECNs). One of these ECNs, ECN L6032, was written to relocate the hydrogen monitor instrumentation as addressed in the corrective actions for NCR-SQN-EEB-801 The corrective action for NCR-SQN-EEB-8014 required, among other actions, relocation of the reagent gas, supplied by instrument air, for the hydrogen analyzers. The ECN L6032, Unreviewed Safety Question Determination (USQD), stated that the affected equipment would be relocated to a mild environment area and installed to the same require-ments of the previous location, i.e., seismic Category I, TVA Class B and Class I Field Change Request FCR 2468 was written to revise' control air flow drawings 47W848-8 and 47W848-12 to show control air going to panels 1-L-382 and 383. FCR 2468 was categorized as a Category A change, which was within the scope of the original ECN L6032 USQD. The Plant Operations Review Committee (PORC) approved FCR 2468 (which replaced auxiliary air with. control air) on July 19, 198 FCR 2468 was not implemented for Unit 2 Train B due to another field change, FCR 327 The following Work Plans (WPs) were reviewed during the evaluation of this issue:

WP 11006 WP11396 WP11002 WP 11110 WP11911 WP11019 At the end of the inspection period, the inspectors had not completed their review. Until further review of licensee design controls is completed, the resolution of the following issues is Unresolved Item 327,328/86-06-06:

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10 Adequate PORC review of ECN L6032 and its associated WPs and FCRs Adequate implementation of Design Change FCR 2468 Adequate Post Modification Test of the Hydrogen Monitor System 10. IE Information Notices (92701)

The following IE Information Notices (IENs) were reviewed and closed. The inspector verified that: correctiv'e actions appeared ' appropriate; generic applicability had been considered; the licensee had reviewed the event and that appropriate plant personnel were knowledgeable; no unreviewed safety questions were involved; and that violations of regulations or Technical Specification conditions did not appear to occu IEN 85-97 Jail Term For Former Contractor Employee 11. Independent Inspection (71707)

The inspectors accompanied NRC f Region II management on a tour of the licensee's equipment spaces during this inspection period. In addition, a

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similar tour was conducted with the Chairman of the NRC, the NRC Executive Director for Operations and other NRC management representatives. Observa-tions from these tours were documented in a February 7,1986 letter from the NRC Deputy Regional Administrator for TVA to the TVA Manager of Nuclear Operation ,

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