IR 05000327/1986028
| ML20211F810 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 06/02/1986 |
| From: | Debs B, Harmon P, Jenison K, David Loveless, Linda Watson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20211F796 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-1.C.5, TASK-1.D.2, TASK-2.B.1, TASK-2.F.1, TASK-TM 50-327-86-28, 50-328-86-28, IEIN-85, IEIN-85-083, IEIN-85-83, IEIN-86-022, IEIN-86-22, NUDOCS 8606190039 | |
| Download: ML20211F810 (20) | |
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Report Nos.:
50-327/86-28 and 50-328/86-28 Licensee: Tennessee Valley Authority 6N38 A Lookout Place
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1101 Market Street
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Chattanooga, TN 37402-2801
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Docket Nos.: 50-327 and 50-328 License Nos.: DPR-77 and DPR'-79
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Facility Name:
Sequoyah Units 1 and 2
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Inspection Conducted: April 6, 1986 thru May 5, 1986
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Inspectors:
/84 AM SM/LM294 K.M.Jenison,SeniorRgdentAspector
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Dat% Sig7 Fed Approved by:
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2 BrnH T. Debs, Chief, Section 1A
/Date Signed Division of Reactor Projects l
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SUMMARY
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Scope:
This routine, announced inspection was conducted onsite in the areas i
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operational safety verification (including operations performance, system lineups, radiation protection, safeguards and housekeeping inspections); sur-ve111ance and maintenance observations; review of previous inspection findings; followup of events; review of licensee identified items; review of IE Informa-i tion Notices; and review of inspector followup items.
Results:
One violation, one additional example of a violation issued in NRC Inspection Report 327,328/85-45 and one additional example of a violation issued in NRC Inspection Report 327,328/86-19 were identified.
One deviation was identified.
8606190039 860613 PDR ADOCK 05000327 O
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Violations 1.
Failure to meet the requirements of Technical Specification (TS) 6.15 for analysis, PORC review and reporting to NRC of a major change to the liquid radwaste system (paragraph 3).
2.
An additional example of failure to maintain housekeeping in accordance with procedure (paragraph 3).
3.
An additional example of failure to implement procedures for adequate review and independent check of a modification to the plant (paragraph 3).
Deviation Deviation from commitment to provide a procedure for use of pressurizer power operated relief valves as reactor coolant system high point vents (paragraph 12).
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REPORT DETAILS 1.
Persons Contacted 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
- M. R. Sedlacik, Electrical Section Manager, Modifications Branch H. D. Elkins, Instrument Maintenance Group Manager C. W. LaFever, Instru:nent Engineering Supervisor M. A. Scarzinski, Electrical Maintenance Supervisor
- M. R. Harding, Engineering Group Manager D. C. Craven, Quality Assurance Staff Supervisor D. L. Cowart, Quality Surveillance Supervisor
- D. E. Crawley, Health Physics Supervisor
- G. B. Kirk, Compliance Supervisor M. L. Frye, Compliance Engineer H. R. Rogers, Compliance Engineer
- R. C. Burchell, Compliance Engineer D. H. Tullis, Mechanical Maintenance Group Supervisor J. H. Sullivan, Regulatory Engineering Supervisor P. R. Hitchcock, Mechanical Engineer, Mechanical Maintenance L. S. Bryant, Engineering Supervisor, Mechanical Maintenance W. E. Andrews, Site Quality Manager, QA T. A. Kontovich, Electrical Maintenance Engineering Supervisor
- M. J. Blankenship. Manager, Information Services J. S. Steigleman, Unit Supervisor, Health Physics C. L. Lagasse, Instrument Maintenance Foreman K. W. Vandergriff, Systems Analyst L. C. Rose, Senior Instrument Mechanic Foreman K. R. Palm, Instrument / Computer Engineer D. L. Widner, Supervisor, Special Projects Closure Group R. J. Dwyer, Reactor Operator F. C. Higdon, Supervisor, Drawings & Vendor Manual Control M. M. McGuire, Q.A. Analyst
- J. W. Kelly, DNE/EA Engineer
- J. E. Maddox, DNE/ Project Engineering
- A. H. Ritter, DNE/EAE
- R. M. Sexton, QA Evaluator
- R. V. Pierce, Mechanical Maintenance Supervisor Other licensee employees contacted included technicians, operators, shift engineers, security force members, engineers and maintenance personnel.
- Attended exit interview
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2.
Exit Interview The inspection scope and findings were summarized with the Plant Manager and members of his staff on May 2, 1986. One violation and two additional examples of previous violations, described in paragraph 3, were discussed.
One deviation, described in paragraph 12, was also discussed. The licensee acknowledged the inspection findings. The licensee did not identify as proprietary any of the material reviewed by the -inspectors during this inspection.
During the reporting period, frequent discussions were held with the Site Director, Plant Manager and other managers concerning in-spection findings. At no time during the inspection was written material provided to the licensee by the inspector.
3.
Licensee Action on Previous Inspection Findings (92702)
(Closed) Unresolved Item 327,328/85-43-03, Auxiliary Building Gas Treatment System ( ABGTS) Discrepancies.
This item was reviewed in NRC Inspection Report 327,328/85-46 and was included in violation 327,328/85-46-04. This unresolved item is closed.
(0 pen) Violation 327,328/85-45-09. Failure to Follow Procedure. Additional examples of inadequate housekeeping were identified by the inspectors as described in paragraph 7.e.
These are further examples of the failure to follow SQA-66, Plant Housekeeping. The licensee's response dated March 20, 1986, stated that general cleanup activities were continuing and that a comprehensive cleanup program will be performed before startup of the units.
The inspector will verify completion of the corrective action prior to startup of the units.
Violation 327,328/85-45-09 also addressed inadequate use of vendor manuals in preparing.the Preventive Maintenance (PM) program for the auxiliary air compressor dryers.
In the licensee's response dated March 20, 1986, they stated that, "...the statement in the violation that no PM was established or implemented on these dryers is inaccurate." This statement is false.
Revision of SI-689, Auxiliary Control Air Operability Test, to include dew point measurements of the system per the vendor manual was not initiated until after inspection 85-45 was complete. However, regional management has determined that the statement lacks materiality in that the violation was still acknowledged. This item remains open pending an updated response from the licensee.
(0 pen) Violation 327,328/86-19-06.
Failure to Implement Procedures. The inspector identified an additional example of a failure to implement an adequate review and independent check of a modification to the plant. This example, described in paragraph 11, involved the improper installation of upper head injection level switches. As discussed in paragraph 11, this additional example indicates that programmatic problems exist in regard to the adequacy of systems training provided for engineers in the Division of Nuclear Engineering (DNE).
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(Closed) Unresolved Item 327,328/86-19-02. Evaluation of Compliance With TS 6.15.
In 1982, the licensee changed the permanent lineup of the radwaste system to allow the CDWE to process all radwaste produced by the plant. The licensee removed the original waste and auxiliary waste evaporators from service.
Previously, the CDWE only processed waste from the condensate demineralizer system and the floor drain collector tank. The new configu-ration allows the CDWE to process the contents of the tritiated drain tanks.
In addition, the licensee installed and utilized mobile radwaste processing equipment with temporary connections to the radwaste system.
The licensee stated that permanent piping changes were not made to accom-plish the above functions. These changes in the permanent lineup involved a major change to the liquid radwaste system and thus should have been
reviewed in accordance with TS 6.15.
The licensee provided the inspector with a safety evaluation report dated April 26, 1985. The inspector reviewed the safety evaluation and although it discussed the 10 CFR 50.59 evaluation, the inspector determined that it did not meet all the requirements for the review required by TS 6.15.
The licensee also provided an FSAR update on April 11, 1985.
The FSAR update did not accomplish all the actions required of TS 6.15. Also, the licensee was not ab1( to provide evidence of a PORC review of the radwaste system change.
Failure to comply with the review and reporting requirements of TS 6.15 is identified as Violation 327,328/86-28-01.
Unresolved item 327,328/86-19-02 is closed.
4.
Unresolved Items Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve violations or deviations. One unresolved item was identified during this inspection as discussed in paragraph 12.
5.
Operational Safety Verification (71707)
a.
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 in-spectors verified the operability of selected emergency systems, reviewed tagout records, verified compliance with TS Limiting Condi-tions 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 prioriti-zation of work was accomplished by the licensee.
Tours of the diesel generator, auxiliary, control, and turbine build-ings and containment were conducted to observe plant equipment conditions, including potential fire hazards, fluid leaks, and excessive vibrations and plant housekeeping / cleanliness conditions.
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The inspectors walked down accessible portions of the following safety-related systems on Unit 1 and Unit 2 to verify operability and proper valve alignment:
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Residual Heat Removal System (Units 1 and 2)
Component Cooling System (Units 1 and 2)
Meteorological Instrumentation System (Common)
During control room walkdowns, the inspectors identified three areas of concern which will be carried as Inspector Followup Items (IFIs).
1.
Drawing control in the areas of unit applicability, drawing clarity, temporary changes and administrative procedures miy not be adequately controlled.
This item will be followed as IFI 327,328/86-28-02.
2.
The component cooling system (CCS) has experienced an in-leakage from an unidentified radioactive source.
The present level of long lived contamination in the CCS and the number of plant components serviced by the system indicates an eventual increase in the number of contaminated areas due to leaks and spills.
Leakage into the system has existed for approximately 18 months.
The leak is intermittent, slow, and appears to coincide with RHR cooldowns.
Licensee programs to locate the source of the leak have been unsuccessful to date. This item will be followed as IFI 327,328/86-28-03.
3.
Operational configuration control through the use of the control room configuration log may not be uniformly applied for all operational modes and for all aspects of plant maintenance, surveillance testing and modification work.
This item will be followed as IFI 327,328/86-28-04.
On April 23, 1986, at approximately 2:15 p.m. EST, the inspector noted that door A132 popped open when opening door A133 on the 714' elevation of the Auxiliary Building. These doors are mechanically interlocked to facilitate keeping a negative vacuum in the Auxiliary Building.
The inspector noted that Work Requests had been written for both doors.
When returning through these doors, the inspector observed workers removing scaffolding from the area.
The workers were holding both doors open simultaneously. The inspector will review the requirements for Auxiliary Building Secondary Containment Enclosure (ABSCE) in mode 5 and the procedure for breaching this airlock.
This will be identified as IFI 327,328/86-28-05.
b.
Safeguards Inspection In the course of the 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 including: protected and vital area access controls; I
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searching of personnel, packages and vehicles; patrols and compensatory posts; badge issuance and retrieval; and escorting of visitors.
In addition, the inspectors observed protected area lighting, protected and vital area barrier integrity, and verified the interface between the security organization and operations and maintenance.
On April 15,1986, at 4:45 p.m. the inspector noted that the Auxiliary Building airlock providing access to the Unit 1 Auxiliary Instrument Room failed to secure properly. A Public Safety Officer was posted on the other side of the airlock. The officer approached and assisted the inspector in properly closing the door. When questioned, the officer stated that she was posted there, per procedure, because of the faulty airlock.
The inspector noted that a Work Request had been established.
On April 23, 1986, the inspectors noticed that the explosives monitor at the power block entrance was out of service.
The Public Safety Officers were conducting a random 2C% petdown of individuals entering the protected area utilizing a pat down checklist. The Security Plan requires at least a 10% random search of entries with one machine out-of-service.
No violations or deviations were identified.
c.
Radiation Protection 1.
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 activities were monitored to assure the activities were being conducted in accordance with applicable RWPs.
Selected radiation protection instruments were verified operable and calibration frequencies were reviewed.
2.
On April 26, 1986, the inspector observed water flowing from door
'A151 in an unregulated portion of the Auxiliary Building.
The inspector ques,tioned an HP technician in the area and determined that the technician was not aware of the water.
The inspector
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informed the Unit I reactor operator of the water and continued to investigate the situation. The inspector then determined that the
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water was flowing from a regulated area into a non-regulated area via door A152.
An auxiliary unit operator (AV0), dispatched by the Unit I reactor operator, told the inspector that he believed the leakage was probably coming from the raw cooling water booster pump seals.
This was apparent from an inspection of the pumps. While inside the regulated area the inspector observed the HP technician taking wet swipes of the leakage, which were later determined to be within releasable radioactive limits.
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The inspector discussed the following concerns with the licensee:
The water was flowing outside the regulated area
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without being properly surveyed.
Individuals were allowed to walk through the water with
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no warning that the area was potentially contaminated.
No provisions were made to perform a frisk upon exit
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from the area.
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The inspector questioned HP personnel about procedures to handle the event.
Licensee personnel stated that although no formal procedure addressed this occurrence, new zones were established at the discretion of the technician on duty.
The inspector will review the following items:
Requirements for identification and monitoring of
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leakage from a regulated area to a non-regulated area
- Requirements for establishing a temporary zone prior to completing the radiological surveys Operations knowledge of the leakage prior to
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notification by NRC These items will be addressed as IF1 327,328/86-28-06.
3.
On April 13, 1986, a worker who was handing scaffolding material to a point above his head was contaminated when material on the scaffolding touched his chin.
The level of contamination on the chin was determined to be 5000 dpm.
After the individual was
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decontaminated there was no detectable radiation present.
Internal contamination was not present as indicated by the lack of contamination within the nostrils.
No violations or deviations were identified.
6.
Monthly Surveillance Observations (56700, 61700, 61726)
a.
The inspectors observed TS required surveillance testing and verified that testing was performed in accordance with adequate procedures; that test instrumentation was calibrated; that LCOs were met; that test results met acceptance criteria and were reviewed by personnel other than the individual directing the test; that deficiencies were identified, as appropriate; that any deficiencies identified during the testing were properly reviewed and resolved by management personnel; and that system restoration was adequate.
For complete tests, the inspector verified that tes+ing frequencies were met and tests were performed by qualified individuals.
The inspector witnessed / reviewed portions of the following surveillance test activities:
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SI 206 - Radiation Monitoring System Sample Flow Calibrations and Functional Tests b.
The licensee has had a TS surveillante review initiative in effect for an extended period. As a result of this team effort and other licensee efforts several issues involving TS required surveillance were identified.
The inspector is aware of eleven separate issues which require resolution.
These issues will be reviewed as IFI 327,328/86-28-07.
c.
The inspectors toured the facilities at the meteorological tower to insure compliance with TS. The following procedures were reviewed:
SI-3 Rev. 47:
Daily, Weekly, and. Monthly Logs SI-89 Rev. 5: Meteorological Monitoring Instrumentation Channel Calibrations (Semiannual), - Unit 0 The inspectors found the equipment to be operabic per TS 3.3.3.4, Table 3.3-8.
The technicians appeared to be knowledgeable about the equip-ment and the procedures met the requirements of Surveillance 4.3.3.4, Table 4.3-5.
No violations or deviations were identified 7.
Monthly Maintenance Observations (62703)
a.
Station maintenance activities of safety-related systems and components were observed / reviewed to ascertain that they were conducted in accordance with approved procedures, regulatory guides, industry codes and standards, and in conformance with TS.
The following items were considered during this review: LCOs met while components or systems were removed from service; redundant components operable; approvals obtained prior to initiating the work; activities accomplished using approved procedures and inspected as applicable; 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; QC hold points established where required and observed; fire prevention controls implemented; outside contractor force activities controlled in accordance with the approved Quality Assurance (QA) program; and housekeeping actively pursued.
b.
On April 15, 1986 the inspectors observed modifications work being performed on 2-FCV-1-51, the trip and throttle valve for the 2A auxiliary feedwater turbine. The work being performed under Work Plan 12006 was a modification to remove the torque switch from the
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limitorque valve operator.
The inspector reviewed the following procedures:
M&AI-07 Rev. 7: Cable Terminations, Splicing, and Repair of Damaged Cables Instruction Change From 85-1675 to M&AI-07 AI-19 Part IV: Plant Modifications - After Licensing
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The inspector determined that the electricians appeared to be working in accordance with procedure and were following the work plan.
Design drawings were out and in use. The workers stated that they had removed the motor control box cover and had subsequently determined that there was still power on the valve because the valve's internal heater was
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still hot. A worker was sent to the Control Room to get a Hold Order so that power could be removed from the valve. When questioned, the workers stated that they had believed power was removed from the valve before they opened the valve.
The inspectors reviewed the circumstances associated with this event
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and found that the Shift Engineer had signed the valve out of service in the WP on March 19 for the purpose of performing this modification.
This signature does not indicate that power had been removed from the valve. Between March 19 and April 15 the valve had been worked on by several groups and had been on two different Hold Orders. The last Hold Order had been lifted on April 14. A Hold Order was again taken out by the Modifications Engineer in charge of the WP after the electricians had opened the valve cover.
The inspector expressed concern that work was performed on a valve that was believed to have power removed when in fact power was still on the valve. The heater used by the craftsmen to determine that power was on the valve is not supplied in all valve operators.
The inspector was concerned that personnel injury could have resulted. It was noted that the Shift Engineer on duty shared the inspector's concerns.
The inspector will review the Hold Order process under IFI 327,328/
86-28-08.
c.
Corrective maintenance on the shield building exhaust radiation monitor (2-RM-090-100) was observed. The following documents were reviewed:
Work Request (WR) 8119787 Maintenance Instruction MI 6.20 Technical Manual (TM) 92759 WR B119787 - required the use of TM 92759.
It appeared that minimal procedural guidance existed in the manual and WR on which to base the corrective maintenance. The adequacy of the TM and procedural guidance will be reviewed as IFI 327,328/86-28-09.
d.
On April 23, 1986, the inspectors observed leak testing of the 2B residual heat removal (RHR) heat exchanger. This testing was being
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performed as a part of the overall program to find the radiological leak into the component cooling system. The following procedures were reviewed:
Technical Instruction TI-58 Leakrate Measurements Instruction Change Form 86-696 to TI-56 j
Instruction Change Form 86-703 to TI-58
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The inspector expressed concern that during reproduction of TI-58, a caution statement (concerning the potential for oxygen deficiency when using large volumes of nitrogen and helium) was removed from the bottom of the page.
The workers were aware of the caution statement and controls were in effen which required an outside watch when making area entries and an oxygen detector to be set up in an appropriate location. The inspector expressed a concern that the safety informa-tion was not brought to the attention of the workers in the procedure.
The Radiation Work Permit (RWP) associated with the job was reviewed, and it was determined that conditions of the RWP were being met and that individual doses remained under the administrative guidelines in the RWP.
The inspector walked down the test boundary to verify proper valve alignment and testing conilitions. An excessive amount of debris on the upper deck of the 2B RHR < bat Exchanger Room was noted. This included trash, wire, wood, old 1ight bulbs and pieces of tubing and pipe. This is a further example of Violation 327,328/85-45-09.
The inspectors observed portions of both parts of the test.
Part I clearly showed no sign of tube to shell leakage.
Part 2 had no acceptance criteria in the procedure and the inspector was unsure of how this data was to be utilized. Determination of how this data was used and why acceptance criteria were not designated will be tracked as IFI 327,328/86-28-10.
e.
During the inspection period, additional examples of a previous violation, 327,328/85-45-09, were discovered by the inspectors during plant tours and system walkdowns.
These housekeeping items were principally of two categories: work left unattended and open, and instrument panels with missing covers. These specific items are listed below and will be reinspected prior to startup.
Work left unattended and open:
(1) Motor operator cover removed on UHI isolation valve 2-FCV-87-23.
(2) Cover removed on air solenoid relay for FCV-62-74, letdown isolation valve.
(3) Motor operator, valve disc, and valve body open and exposed to outside atmosphere on FCV-3-191, condensate recycle valv. -
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s (4) Motor operator cover removed on FCV-1-51, AFW steam turbine stop valve.
(5) Emergency boration valve 1-FCV-62-138 had the valve stem, yoke, and bearing plate exposed while the motor operator was removed.
(6) Steam driven AFW pump control panel 1-L-326-B cover removed.
(7) Steam generator number 3 blowdown restraint disconnected, snubber pin removed.
Instrument panels with missing covers:
(1) Auxiliary building gas treatment fan IB-B flow controller FC-30-138.
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Ice condenser temperature monitor panel 1-L-437.
(3) Charging pump cooler outlet temperature transmitter 1-TM-70-173.
(4) Engineered safety features "B" return temperature transmitter 1-TM-70-72.
(5) Seal water heat exchanger outlet temperature transmitter 1-TM-70-175.
(6) Control rod ventilation cooler
"C" supply control valve module 2-TC-67-93.
(7) RHR mechanical seal outlet temperature alarm transmitter 2-TIS-74-7.
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Letdown heat exchanger relief outlet temperature monitor 1-TM-62-80C.
(9) Letdown heat exchanger relief outlet temperature monitor 2-TM-62-80C.
(10) Emergency boration local flow indicator 2-FI-62-1378.
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 TS conditions had been identifie T
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LERs Unit 1 327/86-004 Improper Entrance into a High Radiation Area - This issue was reviewed and it was determined that~the high radiation area was initially posted and an adequate RWP did exist. The inspector discussed the general area of posting and radiation and contamination zone management with licensee management. This issue will be reviewed as IFI 327,328/86-28-11.
327/86-005 Missed Hourly Fire Watches 327/86-006 Missed Hourly Fire Watches 327/85-042 Containment Ventilation Isolation LERs Unit 2 328/83-181 Return of Vital Inverter to Service 328/84-010 Failure to Test Containment Purge Isolation Valves 328/83-086 Steam Generator Blowdown Valve Failure 9.
Event Followup (93702)
The licensee was notified by Westinghouse Corporation that as a result of fuel pellet design improvements such as chamfered pellets and increased nominal density that the amount of fuel in certain fuel rods had increased several grams above the 1766 grams stated in TS 5.3.1.
The inspector will review this issue for reportability, TS compliance, and justification for operation as IFI 327,328/86-28-12.
10.
IE Information Notices (92701)
a.
The following IE Information Notices (IENs) were reviewed and closed.
The inspector verified that: corrective 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 TS conditions did not appear to occu *
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IEN 85-08 - Industry Experience on Certain Materials Used in Safety Related Equipment
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IEN 85-12 - Recent Fuel Handling Events IEN 85-15 - Nonconforming Structural Steel for Safety Related Use IEN 85-17 Sup.1 - Possible Sticking of ASCO Solenoid Valves IEN 85-98 - Missing Jumpers From Westinghouse Reactor Protection
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System Cards for the Over-Power Delta Temperature Trip Function IEN 85-47 - Potential Effect of Line Induced Vibration on Certain Target Rock Solenoid Operated Valves.
IEN 85-83 - Potential Failures of General Electric PK-2 Test Blocks. This problem was originally identified by the licensee in 1985.
The failures have been attributed to improper heat treatment of certain lots of PK block terminal posts.
Torque tests and visual inspections have been performed on PK block terminal posts on all safety related systems and those in outside environments. No failures were identified in the 6.9 kV shutdown boards, 6.9 kV start boards, 6.9 kV unit boards, common boards, 161 kV switchyard and 500 kV switchyard. Failures were identified on main transformer bank terminal post (16 of 144), main transformer bank 2 termninal post (8 of 144), intertie transformer bank terminal. posts (7 of 208 posts), and diesel generator boards'
terminal posts (7 of 112 posts).
All failed posts have been replaced with posts in stock or from Watts Bar and tested.
To assure future reliability, the licensee presently plans to change out posts on all safety-related equipment with a phased replace-ment program. GE will provide qualified replacement posts based on an analysis of the failures.
The analysis is expected to be completed in the near future. Followup on these additional actions is identified as IFI 327,328/86-28-13.
The Part 21 Report (P2185-02) concerning failures of General Electric PK-2 test blocks was reviewed and considered closed.
IEN 86-22 - Underresponse of Radiation Survey Instrument to High Radiation Fields.
IEN 86-22 addresses the underresponse of Eberline's Model ESP-1 survey instrument with a HP-290 gamma probe to high radiation fields.
Sequoyah currently does not utilize this model instrument.
Therefore, this item is considered closed.
b.
The following IE Notice was reviewed but was not closed for the reasons discussed below:
(0 pen) IEN 85-94 - Potential for Loss of Minimum Flow Paths Leading to ECCS Pump Damage During a LOCA. IEN 86-94 discussed in
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part the potential for damaging low and intermediate pressure ECCS
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pumps during small break LOCAs by pumping against a shutoff head with zero flow caused by a single failure of the common minimum flow recirculation (mini recirc) line. At Sequoyah each RHR and containment spray pump has an individual mini recirc line. The Safety Injection (SI) Pumps have a common recirc line.
Valve FCV-63-3 on the common line is maintained in an open position by procedure System Operating Instruction SOI 63.1, Emergency Core Cooling System - Unit 1 and 2.
This valve is motor operated and is designed to " fail-as-is."
With this valve incorrectly positioned, the SI pumps could experience damage within a few minutes following an initiation signal. The licensee considered the possibility of locking this valve open; however, operators are required to close this valve after initiation of the recirculation phase to keep radioactive containment sump water from being pumped outside the containment to the Refueling Water Storage Tank (RWST). The inspector will review this item to determine that the current program for controlling this valve is adequate to assure operability of the SI system.
The Notice also discusses failure of these valves to meet both recirculation flow requirements and containment isolation requirements. Sequoyah does not have ECCS minimum flow lines that penetrate the containment. Therefore, this portion does not apply to Sequoyah.
This item remains open and will be tracked as IFI 327,328/86-28-14.
11.
Inspector Followup Items (92701)
Inspector Followup Items (IFIs) are matters of concern to the inspector which are documented and tracked in inspection reports to allow further review and evaluation by the inspector.
The following IFIs have been reviewed and evaluated by the inspector. The inspector has either resolved the concern identified, determined that the licensee has performed adequately in the area, and/or determined that actions taken by the licensee have resolved the concern. As a result of this review these items are closed.
IFI 327,328/84-28-01 Changes to Liquid Radwaste IFI 327,328/85-26-06 Control of Root Valve Positions IFI 327,/85-27-02 and Initials Used as Signoffs on Procedures IFI 328/85-28-02 IFI 327,328/85-43-08 Containment High Range Monitor Post Modification Testing IFI 327,328/85-26-10 This inspector followup item involved hanger analysis on two failed chemical volume control system (CVCS) sample lines.
Each sample line had a high cycle low stress fatigue failure as a result of unidentified vibrations.
This
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item was also identified under URI 327,328/
85-29-03 and will be reviewed under the URI.
The IFI is therefore closed.
IFI 327,328/85-43-11 This item concerning the calibration of containment level switches is discussed in paragraph 12 of this report.
This IFI is closed, but the item will continue to be tracked as URI 327,328/86-28-15.
IFI 327,328/85-43-05 A review of Shift Technical Advisor Safety Parameter Display System (SPDS) training was
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conducted as a portion of the Sequoyah Nuclear Performance Plan evaluation. The training appeared to be adequate.
The Technical Support Center computer manual established by the licensee to direct the operation of the SPDS appeared to adequately address the operation of the SPDS. The Technical Support Center computer manual is treated as a controlled document under Standard Practice SQA 125.
IFI 327,328/86-19-11 The inspector reviewed the events that resulted in the improper installation of the Upper Head Injection (UHI) accumulator level switches previously identified as IFI 327,328/
86-19-11.
The root cause of the improper installation was the failure of the OE Design Engineer and an independent checker to care-fully review design drawings and documents.
Drawing 47W600-276 indicated that valves on the dif ferential pressure cell reference leg were open to atmosphere.
Both individuals interpreted drawing 47W600-276 to indicate that the reference leg was dry (empty) when in fact the reference leg is water filled.
System knowledge at even a rudimentary level would have alerted the responsible engineers that the reference leg vents could not be left open since the accumulator is pressurized to 1350 psig. This inadequate review and the in-adequate independent check is a sixth example of a previous violation (327,328/86-19-06).
Identification of this additional example of failure to perform adequate reviews of modifications to the plant indicates a programmatic problem in the training of engineers in the DNE. The root cause of the improper installation of the UHI level switches and the improper installation of the hydrogen analyzer (also is ified in violation 327,328/86-19-06) is directly attributable to
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knowledge - of the responsible design engineers.
Interviews with the
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, engineers indicate that the engineers have not been given systems training prior to performance of. design and verification work for
modifications to the plant.
Also, as indicated in. the following paragraph, engineers are not cognizant of recent events affecting the
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design of safety related systems. Corrective action in these areas is
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considered essential to-the correction of the root cause of this
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violation.
During the inspector's review of the inadequate review and check per-
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formed by DNE personnel, no evidence was found of DNE's participation
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in the Nuclear Experience Review Program.
No formal review by DNE personnel of IE Notices exists. Neither of the engineers involved in
the inadequate review of the UHI level switch modification and instal-
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lation had seen IEN 85-23. IEN 85-23 describes a similar incident at
another utility in Region II where functionally identical level switches were incorrectly installed.
That incident was a direct parallel to the occurrence at Sequoyah.
The lack of a Nuclear
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Experience Review Program utilized by DNE~ will be followed as -IFI 327,328/86-28-16.
IFI 327,328/86-19-11 is closed.
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12. Review of Facility Operating License (FOL) Conditions, and NUREG-0737-(TMI-2
- Action Plan Commitments) (25565)
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FOL No. DPR-77 Section 2.C.(23)E. and FOL No. DPR-79 Section 2.C.(16)f.; NUREG-0737, Item II.B.1 - Reactor Coolant System Vents
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The inspector reviewed the licensee's commitments for operability and
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environmental qualifications of the pressurizer power operated relief i-valves (PORVs) and block valves.
The inspector reviewed the environ-
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mental qualification documents, SQNEQ SOL - 002 and SQNEQ MOV - 001.
No concerns were identified.
In a letter dated July 16, 1982, the licensee committed to provide procedures for use of the PORVs in the event of the failure of the
Reactor Vessel Head Vent System (RVHVS). By letter dated February 15, i
1984, the licensee stated that the procedures for use of the RCS highpoint vents would be implemented when the complete set of emergency
operating -instructions were implemented. An order was issued by the NRC on June 15, 1984, confirming that the upgraded emergency operating instructions would be implemented by August 1985 for both units.
The inspector-r_eviewed the. Emergency Instructions (EIs) to determine if the commitment had been met. The inspector determined that the EIs
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did not include this information.
This failure to include procedures
for use of the pressurizer PORVs as reactor coolant system high point vents is identified as a deviation from the commitment in the July 16, 1982, and February 15, 1984 letters (DEV 327,328/86-28-17). TMI Item t
i II.B.1 will remain open until said procedure is provided.
b.
NUREG-0737, Item I.D.2 - Safety Parameter Display System
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The i spect6r reviewed the licensee's implementation of the SPDS installed et Sequoyah.
The system meets the requirements of NUREG-0737, Supplement 1, Item I.D.2.
'The' installation, verification and validation program for the SPDS appears adequate. The systems were declared operable within the licensee's commitment dates.
IFI 327, 328/85-43 05 concerning training of STAS for the SPDS is closed as discussed in paragraph 11.
TMI item I.D.2 is closed.
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During the' riview of the SPDS system, the inspector expressed concern that access to software programs should be further tightened. This will be,followed as IFI 327,328/86-28-18.
NUREG-0737,ItemII.F.1.5-ContainmhntWaterLevel c.
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The -inspector reviewed questions rais'ed in IFI 327,328/85-43-11 about the containment water level transmitters. The inspector reviewed all previous performances of Surveillance Instruction SI-202, Periodic Calibration"of Safety Injection System (Refueling Cycle). The Barton Model 764 level transmitters (LT-63-176,177,178,179) were found out of calibration 76% of the time. Every performance of the SI determined at least one of the transmitters to be out of specification limits. In addition, the channels were recalibrated between SI performances when they failed the channel checks. Modifications were performed in 1983; however, these apparently did not correct the problem.
The inspectors will review the adequacy of previous corrective maintenance, the licensee's trending of corrective maintenance on these transmitters and the question of whether. the system has been operable with the transmitters continuously out of tolerance.
This item is considered to be unresolved and will'be tracked as URI 327,328/
86-28-15.
Item II.F.1.5 remains open.
13.
Review of Operational Experience (90714)
A review of designated Nonconformance Reports was conducted to establish if the licensee was obligated to report these issues under 10CFR50.55e, to determine appropriate operational experience ' reviews, and to determine whether appropriate corrective action had been taken to resolve the
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discrepancy. The following Nonconformance Reports (NCR) were reviewed.
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SQN-QAB-8103 SQN-QAB-8104 SQN-QAB-8105 SQN-NEB-8316 t
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l The low power licenses for Unit I and Unit 2 were issued in February 1980 and June 1981, respectively. Each of the above NCRs, with the exception of
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SQN-QAB-8105 were written after the low power license issue date for both units.
Therefore the reportability requirements of 10 CFR 50.55e do not
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apply. These NCRs were also not reportable under 10 CFR 50.73. In the case
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of SQN-QAB-8105 the issue was identified prior to the low power license issue date however an NCR was not issued and the problem was not reported to the NRC as a result of personnel error. The technical resolution of the
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above issues appeared to be adequate with the exception of SQN-QAB-8104 which may. involve unanalyzed installation of piping insulation. The insu-lation analysis will be reviewed as IFI 327,328/86-28-19 in coordination with the closure of IEB 79-14 on Unit 1. -
The inspectors reviewed the licensee's standard practice SQA26: Review, Reporting, and Feedback.of Operating Experience Items.
Several Operating Experience items were reviewed and are addressed in paragraphs 9, 10 and 11.
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This area will continue to be reviewed for adequacy and for meeting the requirements of NUREG-0737 item I.C.S.
No violations or deviations were identifie \\
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