IR 05000327/1986037
| ML20215N046 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 10/16/1986 |
| From: | Debs B, Harmon P, Jenison K, David Loveless, Linda Watson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20215N042 | List: |
| References | |
| 50-327-86-37, 50-328-86-37, NUDOCS 8611040209 | |
| Download: ML20215N046 (21) | |
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>Q Mc UNITED STATES oq'o, NUCLEAR REGULATORY COMMISSION
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REGION li h
101 MARIETTA STREET, N.W.
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ATLANTA, GEORGI A 30323 l
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Report Nos.: 50-327/86-37 and 50-328/86-37 Licensee: Tennessee Valley Authority 6N38 A Loukout Place 1101 Market Street Chattanooga, TN 37402-2801 Docket Nos.: 50-327 and 50-328 License Nos.:
DPR-77 and DPR-79 Facility Name: Sequoyah 1 and 2 Inspection Conducted: June 6, 1986 thru July 5, 1986 Inspectors:
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rifEnspector Dat52 Signed
'K. M.~ Jenisore,
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[.J. Watson,Hesident/Espectg Date Signed
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P. E. Harmon, Resident Enspe#for -
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F. Loveless,nesidengnsgpEtor Date Signed Approved by:
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/O!/4/5 B. T. Debs, Chief, Sect ph 1A f ~
Date Signed Division of Reactor Projects SUMMARY Scope: This routine inspection was conducted in the areas of: operational safety verification (including operations performance, system lineups, radiation protection, safeguards and housekeeping inspections); maintenance and surveillance observations; review of previous inspection findings; followup of events; review of licensee identified items; review of IE Information Notices; and review of Inspector Followup Items.
Results:
Two violations were identified (failure to identify, control, and review in a timely manner Conditions Adverse to Quality - paragraph 13; failure to adhere to Radiation Work Permit requirements - paragraph 5).
No deviations or unresolved items were identified.
Two Inspector Followup Items (IFIs) were identified for resolution prior to the startup of either unit (IFI 327,328/86-37-04 Emergency Diesel Generators may overload under certain circumstances - paragraph 9; IFI 327,328/86-37-05 Review of licensee QA action on compliance instrument calibration history and operability - paragraph 13).
8611040209 861028 PDR ADOCK 0500
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i REPORT DETAILS
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1.
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. H. Buckholz, Site Representative
- M. 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 M. R. Harding, Licensing and Compliance Supervisor D. C. Craven, Quality Assurance Staff Supervisor D. E. Crawley, Health Physics Supervisor
- R. V. Pierce, Mechanical Maintenance Supervisor
- J. A. McPherson, Mechanical Test Supervisor i
- G. B. Kirk, Compliance Supervisor H. R. Rogers, Supervisor Plant Reporting Section
- R. C. Burchell, Compliance Licensing Engineer
- J. H. Sullivan, Plant Operations Review Staff Manager
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- W. E. Andrews, Site Quality Manager
- W. S. Wilburn, Assistant to the Maintenance Superintendent
- M. J. Blankenship, Manager Information Services
- L. D. Alexander, Mechanical Modifications Section Supervisor
- R. W. Fortenberry, Technical Support Supervisor
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R. K. Gladney, Instrument Maintenance Engineering Supervisor K. W. Fenn, Instrument Engineer J. M. Stitt, Corrective Action Coordinator, QA
- W. H. Baker, Fire Protection Engineer
- J. S. Steigelman, Radiation Control Unit Supervisor
- A. H. Ritter, Site EAE
- J. W. Kelly, EA Engineer
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- D. L. Jeralds, Instrument Craft Supervisor i
- M. A. Surrell, Compliance Engineer
- E. F. Craig, Mechanical Modification
- E. A. Craigge, Industrial Safety -Staff
- M. A. Cooper, Mechanical Engineering
- R. E. Thompson, Assistant Branch Chief
- D. H. Tullis, Maintenance Special Projects
- K. C. Weller, Systems Engineer Other licensee employees contacted included technicians, operators, shift engineers, security force members, engineers and maintenance personnel.
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Other NRC Personnel
- B. T. Debs
- W. K. Poertner
- P. B. Moore
- L. R. Moore
- M. F. Runyan
- W. H. Miller
- P. M. Madden
- J. B. Brady
- Attended exit interview 2.
Exit Interview The inspection scope and findings were summarized with the Plant Manager and members of his staff on July 11, 1986.
Two violations described in paragraphs 5 and 13 were 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 inspections findings.
At no time during the inspection was written material provided to the licensee by the inspector.
3.
Licensee Action on Previous Enforcement Matters (92702)
(Closed) Unresolved Item (URI) 327,328/86-28-15.
This item involved containment sump level transmitters being found out of tolerance during performances of SI-202.
This issue is further addressed in Paragraph-13 of this report.
(Closed) Violation 327,328/85-35-01.
This item involved several instances where maintenance and surveillance procedures used,for safety-related equipment were either not adequately implemented or established.
The licensee's actions, as stated in a January 9,1986 letter, were reviewed and found to be acceptable. This item is closed.
(Closed) Violation 327,328/85-47-03.
This item involved three instances where maintenance procedures used for safety related equipment were not adequately implemented.
The licensee's actions, as stated in a March 5, 1986 letter, were reviewed and found to be acceptable. This item is closed.
4.
Unresolved Items No unresolved items were identified during this inspection.
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. 5.
Operational Safety Verification (71707)
a.
Plant Tours The inspectors observed control room operations, reviewed applicable
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logs, conducted discussions with control room operators, observed shift-turnovers, and confirmed operability of instrumentation.
The inspectors verified the operability of selected emergency systems, and verified compliance with Technical Specification (TS) Limiting Conditions for Operation (LCO).
The inspectors verified that maintenance work orders had been submitted as required and that followup activities and prioritization of work was accomplished by the licensee.
Tours of the diesel generator, auxiliary, control, and turbine buildings, and containment were conducted to observe plant equipment conditions, including potential fire hazards, fluid leaks, excessive vibrations and plant housekeeping / cleanliness conditions.
The inspectors walked down accessible portions of the following safety-related systems on Unit 1 and Unit 2:
Upper Head Injection System (Unit 2)
Safety Injection System (Units 1 and 2)
Auxiliary Feedwater System (Units 1 and 2)
The inspectors noted several minor drawing discrepancies in drawings 47W811-2 (Unit 2) and 47W811-1 (Unit 1).
These discrepancies will be tracked to determine if they were identified during the design control walkdowns. Their final incorporation into the plant drawings will also be reviewed.
This item will be tracked as Inspector Follow-up Item (IFI) 327,328/86-37-01.
While walking down portions of the Auxiliary Feedwater Sys. tem, the inspectors noted that portion of a 6-inch piping header.was reducted to
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4 inches prior to bifurcating to two 4-inch supply lines. The question of whether reducing the 6 inch line violates design assumptions will be tracked as IFI 327,328/86-37-02.
No violations or deviations were identified.
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; t
searching of personnel and packages; escorting of visitors; badge issuance and retrieval; and patrols.
In addition, the inspectors observed protected area lighting and protected and vital area barrier j
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The inspectors also interviewed security personnel regarding their respective duties.
No violations or deviations were identified.
c.
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 activities were monitored to assure the activities were being conducted in accordance with applicable RWPs.
The inspectors observed radiation protection practices during a licen-see's inspection of eddy current equipment.
The licensee established an enclosed structure on elevation 714 to control airborne radio-activity during the i'nspection.
A double step off pad (SOP) arrange-ment also had been established. The first S0P was at the exit from the potentially airborne area (enclosed structure) into a contaminated zone (C-zone) and the second S0P was at the exit of the C-zone into the regulated area. The inspectors reviewed RWPs 86-0460-61 and 86-0460-63 which were written to cont'rol the entry and exit from the potential airborne area and the C-zone respectively.
The inspectors observed that a technicicn, assigned Health Physics duties inside the C-zone, was not wearing a protective hood required by RWP 86-0460-63.
The inspector discussed the discrepancy with the job supervisor.
During the discussion, a second individual handed the technician a hood from outside the C-zone. The technician then placed the hood on her head incorrectly and had to be reminded to comply with the RWP a second time.
In addition, the inspector expressed the concern to the licensee that the hood was donned in the C-zone while the technician was wearing potentially contaminated gloves.
TS 6.11 requires that procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure.
These requirements are implemented by Radiological Control Instruction RCI-1, Radiological Hygiene Program, and RCI-14, Radiation Work Permit Program..
RCI-14 requires each individual employee to read and adhere to all require-ments of the RWP and RWP timesheet associated with the area entered and the work performed.
RWP 86-0460-063' required that a hood be worn during work perfcrmed in the C-zone discussed above.
Failure to adhere to the requirements of RWP 86-0460-63 is identified as violation 327,328/86-37-03.
The irispector observed that technicians passed tools from the poten-tial airborne area to the C-zone.
The equipment was placed into bags inside the airborne area, then transferred to the C-zone, and then
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placed on the floor without smearing or monitoring the bags.
The inspector also observed a technician reach from the regulated area into
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-the C-zone and connect an air mask.
In addition, a large eddy current equipment storage box was opened in the regulated area.
RWP 86-0460-063 stated that an air sample should be taken and a health physicist (HP) should be present when boxes and bags were opened. The RWP was not clear whether or not this requirement included the eddy current storage box.
These activities were identified as poor HP.
practices in that the double zone was set up to minimize the spread of contamination from the airborne area to the C-zone, and further to the regulated area. These poor HP practices were discussed with licensee management and are indicative of current problems in the implementation of the Health Physics program.
IFi 327,328/86-37-08 is opened to review HP training and practices in these general areas.
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6.
Monthly Surveillance Observations (61726)
The inspectors reviewed 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 testing frequencies were met and tests were performed by qualified individuals.
The inspector reviewed portions of the following surveillance test activities:
MaintenanceInstruction(MI)-10.9.1ReactorTripSwitchgearInspection The inspector observed the post maintenance testing of reactor trip
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standby (bypass) breaker BY-2.
The test was conducted to establish baseline information after modification of the breaker to include the
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shunt trip feature. The inspector also reviewed Preventive Maintenance (PM) No.124607.
The inspector noted that Step 6 in the package had not been filled in.
This step required that the serial number of the breaker be listed.
The electrical maintenance technician stated that he had recorded the information as part of MI-10.9.1 and intended to review the PM for completeness and fill in the serial number prior to signing off the package.
The inspector also noted that the plastic case around one set of contacts in the breaker had cracked.
When questioned, the technician stated that he had noted that the case was cracked and intended to report the problem to the cognizant engineer and request that a Work Request be written to replace the case.
Work Request B112557 was written to replace the cover.
No violations or deviations were identified.
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7.
Monthly Maintenance Observations (62703)
a.
Station maintenance ertivities of safety-related systems'and components were 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 were 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; trouble-shooting activities controlled and the repair record accurately reflected what actually took place; functional testing and/or calibra-tions performed prior to returning components or systems to service; quality control records maintained; activities accomplished ' by
qualified personnel; parts and materials used were properly certified; i
radiological controls were implemented; QC hold points established '
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where required and observed; fire prevention control implemented; and housekeeping actively pursue'd.
b.
Corrective maintenance on the A-A Auxiliary Air Compressor (Units 1 and 2) was observed.
In addition, a meeting was held with the Plant
Maintenance Superintendent to discuss the maintenance performed on the Auxiliary Air Compressor and the practice of reworking a maintenance action under the original Work Request (WR) when the initial corrective maintenance did not return the equipment to operability. The following documents were reviewed:
WR B132013
MI-10.36; Auxiliary Control Air Compressor Rebuild Surveillance Instruction (SI)-689; Auxiliary Control Air Compressor Test No violations or deviations were identified.
8.
Licensee Event Report (LER) Followup (92700)
i The following LERs were reviewed and closed.
The inspector verified that:
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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 no violations of regulations or TS -
conditions had been identified.
LERs Unit 1 327/86-005 Missed Hourly Fire Watches (Revision 1)
N 327/86-006 Missed Hourly Fire Watches (Revision 1)
327/86-019 Auxiliary Building Ventilation Isolation j
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327/86-021 Control Room Isolation Due to Chlorine Detector 327/86-024'
Security Computer Malfunction
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LERs Unit 2 328/85-003 Conduit Penetration Not Sealed (Revision 1)
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9.
Event Followup (93702, 62703)
On May 15, 1986, an inadvertent containment ventilation isolation occurred while placing the Unit 1 containment purge system in service.
A second related containment ventilation isolation occurred on Unit 2 the same day.
The licensee issued LER 327/86-022.
The inspectors will determine through
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the review of LER 327/86-022 whether adequate corrective action was taken by the licensee following the initial containment ventilation isolation.
LER 327/86-022 remains open and under review.
The licensee has experienced approximately twenty separate, related actions which resulted in Engineered Safety Features actuations.
In addition, LER 327/86-022 will also be reviewed to determine if the licensee's long term generic corrective actions for inadvertent ventilation isolations were prompt and adequate.
On June 18, 1986, the licensee reported to the NRC that the emergency diesel generators may overload thirty seconds after a loss of off site power concurrent with a phase B isolation and a safety injection.
The overload was calculated to result from the starting current of the containment spray pumps.
The overload condition would cause the output breakers on the Emergency Diesel Generators (EDGs) to open and result in a loss of safety related electrical equipment.
The licensee -is analyzing the loading sequence of the EDGs for possible modifications.
This will be reviewed prior to the startup of either unit as IFI 327,328/86-37-04.
10.
IE Information Notices (92701)
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 violations of regulations or TS conditions did not appear to occur.
85-04-Security Response Drills 85-05 Pipe Whip Restraints 85-07 Contaminated Radiography Source Shipments 85-21 Main Steam Isolation Valve Closure Logic 85-26 Vacuum Relief Systems 85-29 Use of Unqualified Sources In Well Logging Applications
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85-53 Performance of NRC-Licensed Individuals 85-54 Teletherapy Unit Malfunction 85-62 Backup Telephone Numbers to NRC Operations Center
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IE Bulletins (92703)
(Closed) IE Bulletin (IEB) 85-01, Steam Binding of Auxiliary feedwater Pumps.
The inspector verified that:
corrective actions appeared appro-priate; 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 violations of regulations or
TS conditions did not appear to occur.
The inspector reviewed the actions taken by the licensee in response to the similar issues in IEN 84-06 and Institute of Nuclear Power Operations Significant Event Report (SER) 85-22.
No specific actions were required of the licensee by either of the aforementioned documents.
However, the licensee did take preventive measures.to prevent steam binding of auxiliary feedwater pumps. As a result of this review, this item is~ closed.
12.
Inspector Followup Items (92701)
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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 licens.ee
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have resolved the concern. These items are closed:
IFI 327,328/86-06-01 Commitment Dates on Response to NRC IFI 327,328/86-15-01 Revision of SI-1 i
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Unit 1 and 2.C.(16)1.(2)(c) g License (FOL) Conditions 2.C.(23)D.(2)(d)
Review of Facility Operatin Unit 2, and NUREG-0737 (TMI-2 Action Plan Commitments) II.F.1.2.e (25565)
The inspector reviewed questions raised in URI 327,328/86-28-15 concerning
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out of tolerance conditions of containment sump level transmitters and other l
Safety Injection System (SIS) instrumentation.
The item discussed
operability questions, issues with the management review process and questions concerning the adequacy of licensee corrective action.
a.
Review of Containment Sump Level Out-of-Tolerance Conditions
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(1) 'leview of Design Basis Event for Swap-Over to Containment Sump FSAR Section 6.3.2.2, pages 6.3-16 thru 19, describes the recirculation mode.
The section states that an analysis of 'the double ended cold leg break indicates that during the swap-over from injection to recirculation mode, at the time suction is first q
taken from the ECCS sump, the depth of water in the active sump -
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will be 13.2 feet (flooded to elevation 693 feet). Residual Heat
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Removal block valves and containment sump isolation valves are automatically positioned on actuation signals from the safeguards i
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protection logic.
Two of four Reactor Water Storage Tank (RWST)
low level protection signals and two of four sump high level signals are required.
TS Table 3.3-4 requires the containment sump level high trip setpoint to be 30 inches above elevation 680. The allowable value is required to be within +/- 2.5-inches of this setpoint.
A margin of approximately 10.5 feet +/- 2.5 inches exists between the TS allowable values and the analyzed swap-over point.
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Therefore, the safety significance of the later mentioned out-of-tolerance conditions appear to be minor. The wide margin assures
that the interlock from the containment sump high level
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transmitter would actuate well in advance of the low level actuation signal from the RWST transmitter.
(2) Calibration Problems The inspector reviewed out-of-tolerance conditions for the-containment sump * transmitters.
Twenty calibration tests were identified 'where the instruments were out-of-tolerance procedurally.
Of the 20 tests, 5 tests were out of TS Tolerance.
When these conditions were discovered, the licensee imediately recalibrated each instpument and returned it to operable status.
As discussed in NRC Inspection Report 327,328/86-31, the licensee has pursued numerous corrective actions for air-inleakage problems and bellows failures which may be contributing to these out-of-tolerance conditions.
The inspector expressed concern that problems with instrument drift appeared not to be addressed in corrective actions. The licensee' stated that indications of drift were difficult to distinguish due to the other problems encountered which were stated in NRC Inspection Report 50-327,328/86-28.
The licensee indicated that resolution of the out-of-tolerance
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problems with the containment sump level transmitters have not been fully successful to date.
The pursuance of corrective action through an intermediate contractor, Westinghouse, has been lengthy.
The design change most recently proposed by the contractor, the double o-ring transmitter, has not solved the problem, because these transmitters were found out-of-tolerance during their last calibration.
The licensee is currently sealing the fill tees on the instruments' sense lines with Ray-Chem heat shrinkable tubing to prevent air intrusion.
The licensee indi-cates that this may resolve the problem.
The licensee's actions to resolve this problem will be forwarded to the NRC in an update to LER 328/83-130.
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Additionally, the licensee is considering a proposed TS change to increase the TS allowable transmitter values to permit relief from the apparently conservative existing values.
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As a result of the inspector's review of the out-of-tolerance conditions for the containment sump transmitters, the. inspector concluded that these conditions had not rendered the safety injection system inoperable; therefore, URI Item 327,328/86-28-15 is closed with no violations or deviations identified.
i Until there is a satisfactory resolution of the out-of-tolerance problem associated with the aforementioned transmitters, II.F.1.2.e, Containment Sump Water Level, will remain open.
l b.
Review of Other Instruments Found Out-of-Tolerance (1) Review of Instrument Out-of-Tolerance Conditions
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The inspector performed a review of other instrumentation to determine if.out-of-tolerance conditions were prevalent.and corrective action had been taken to ensure continued -instrument operability.
Table 1 of the report identifies instruments reviewed by the inspector.
The
"X" in the table indicates procedurally out-of-tolerance conditions at the time of calibra-tion.
The table differentiates between compliance and TS instru-ments.
The licensee has defined compliance instrumentation as installed process instrumentation which is used to determine or verify compliance with plant requirements such as flows,
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pressures, temperatures, levels, voltages and currents.
TS instrumentation is defined as any instrument which has a. specific
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allowable value-listed in the TS or any instrument or ' instrument
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loop which is required to be operable during at least one operaticnal mode as required by TS.-
These definitions appear in
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.the licensee's Technical Instructions TI-54, Compliance i
Instruments (Units 1 and 0), and TI-54.2, Compliance Instruments j
(Unit 2).
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TABLE 1
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COMPLETED SURVEILLANCE INSTRUCTIONS INDICATING
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i OUT-0F-TOLERANCE CONDITIONS Instrument Name Performance Found Out
i of Procedural Tolerance
Unit 2 Unit 1 10/85 8/84 8/83 2/81 12/83 '2/82 '11/80 i
PT-63-19 C Safety Injection X
X
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System (SIS) Pump B-B Outlet Press Transmitter (XMTR)
FT-63-20 C SIS Pump B-B X
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Outlet Flow XMTR I
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LT-63-46 C SIS Refueling Water X
X X-X X
Storage Tank (RWST)
Level XMTR LT-63-49 C SIS RWST Level X
X X
XMTR I
X X
XMTR LT-63-53 T SIS RWST Level X
X X
X X
X XMTR
FT-63-91A C SIS Flow to Reactor X
X X
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Coolant System (RCS)
2&3 Cold Leg (CL)
XMTR
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FI-63-91A C SIS Flow to X
RCS 2&3 CL FT-63-918 C SIS Flow to RCS X
X X
X X
X 2&3 CL XMTR
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1&4 CL XMTR
X
'X X
X X
X 1&4 CL XMTR
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TABLE 1 (cont'd)
Instrument Name Performance Found Out of Procedural Tolerance Unit 2 Unit 1 10/85 8/84 8/83 2/81 12/83 2/82 11/80 TM-63-121 C RWST Temp. Module X
X X
X X
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TM-63-132 C RWST Temp. Module X
X X
X
I FT-63-151 C SIS Pump A-A X
i Outlet Flow XMTR FT-63-173A.C RHR Inj. or Recirc
.X After LOCA LT-63-176 T Cont. Sump Level X
X X
X X
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XMTR I
LT-63-177. T Cont. Sump Level X
X X
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XMTR LT-63-178 T Cont. Sump Level X
X X
X X
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XMTR i
LT-63-179 T.
Cont. Sump Level X
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j XMTR j
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l NOTES:
C indicates compliance instrument i
T indicates TS instrument
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(2) Review of TS Instrumentation Regarding the tabulated TS instruments:
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LT-63-52 and 53 for both Units are calibration tested by SI-202, Calibration of Safety Injection System Instruments (Refueling Outage).
Although these instruments have been found out of procedural tolerance, the inspector verified that they had never been out of TS tolerance.
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LT-63-176 through 179 were discussed earlier in this report (Section 13.a).
On November 13,1985, SI-98.5, Channel Calibration for Engineered Safety Features Instrumentation RWST (18 months) Units 1 and 2, was approved. The licensee stated that the instruments were moved into a separate procedure to segregate-TS instruments from compliance instruments and upgrade the procedure.
This instruction improves the acceptance criteria for the instruments in SI-202 and combined all RWST instrumentation calibrations together into one surveillance instruction.
(3) Review of Compliance Instrumentation
Regarding the tabulated compliance instruments, the inspector reviewed Corrective Action Report (CAR) 85-10-017 dated October 21, 1985.
This report identified a failure to adequately evaluate out-of-tolerance conditions for compliance instruments.
Specifically:
TI-54 and TI-54_.2 contain instructions on the evaluation of out-of-tolerance conditions and provide references to those surveillance instructions which utilize compliance instruments to ensure that TS are met. The CAR identified 36 compliance instruments not listed in TI-54, and TI-54.2. The CAR requested that corrected action include measures to be taken to ensure that all compliance instruments are listed.
Additionally, the CAR identified 46 cases where out-of-tolerance investigation records could not be found for various compliance instruments.
The CAR states, " Corrective action should not only address actions to correct the listed examples, but also actions to ensure future timely evaluation of out-of-tolerance compliance instruments."
The CAR also listed 23 instances where sis which utilize e
plant compliance instruments were not referenced in TI-54 and TI-54.2.
The request for corrective action required the licensee to perform a generic look at sis to identify similar deficiencie.
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The plant response to the aforementioned deficiencies indicated, in part, that in order to prevent recurrence, the review checklist and guidance in SI-1 would be revised by March 1, 1986, and timely
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investigations would be conducted on out-of-tolerance compliance instrumentation and procedures will have been revised to require issuance of a Potentially Reportable Occurrence (PRO) when compliance instruments are found out-of-tolerance.
In an internal letter dated March 10, 1986, the Quality Assurance (QA) Section notified the Plant Manager that the QA staff could not verify that corrective action had been completed. The letter stated that documentation of the investigation of out-of-tolerance
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conditions for 38 of the instruments stated in the original CAR j
could not be located.
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The plant then responded by extending the corrective action date to April 22, 1986.
A followup QA audit determined that the specific instances cited in the CAR had been corrected; however, other examples of similar deficiencies were again identified. On July 8, 1986, resolution of this CAR was escalated to the-Director, Nuclear Quality Assurance at the Corporate level.
The licensee stated to the inspector that the CAR would be resolved prior to startup of the Units.
The inspector informed the licensee of the additional out-of-tolerance conditions which appear in Table 1.
The licensee stated that these out-of-tolerance conditions will be reviewed.
Final resolution of CAR 85-10-017 will be for tracked as IFI 327,328/86-37-05.
c.
Administrative and Management Concerns (1) Regulatory Requirements Governing Conditions Adverse To Quality (CAQ)
A condition adverse to quality is defined as adverse conditions including nonconforming materials, parts, or components; failures; malfunctions; deficiencies; deviations; hardware problems involving systems which do not comply with licensing codes; specifications or drawing requirements; and non-hardware problems
.i such as failure to comply with the operating license, TSs, proce-
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dures, instructions or regulations.
10 CFR 50, Appendix B, Criteria XVI states, " Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.
In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action is taken to
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preclude repetition.
The identification of the significant
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condition adverse to quality, the cause of the condition, and the corrective action taken shall be documented and reported to appropriate levels of management."
Licensee procedure AI-12 implements these requirements.
The Nuclear Quality Assurance Manual (NQAM) states in Part III, Section 1.7 that conditions adverse to quality shall be reviewed
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by responsible supervisors to determine whether they may constitute significant conditions adverse to quality.
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NQAM Part II, Section 4.5, subsection 4.9, states that the as-found condition along with the corrective action taken, if any,
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shall be included in the surveillance package.
If the condition adverse to quality is discovered during the test activity, it i
shall be processed in accordance with NQAM, Part II, Section 4.9.
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NQAM Part II, Section 4.9, Handling of CSSC Test Deficiencies, Subsection 4.0, states that identified deficiencies, including corrective action, shall be reviewed by responsible supervision or their delegated representative who shall approve the corrective
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action and evaluate the deficiency for significance in accordance with NQAM, Part III, Section 7.2.
i NQAM Part III, Section 7.2, subsection 2.2, states that the timely i
resolution of hardware problems shall be assured through use of control mechanisms which provide for their identification as open
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items until resolution.
It also states that this is primarily accomplished through issuance of an MR, DR, test deficiency log, CAR, LERs, etc.
The NQAM supports the conclusion that test deficiencies are CAQs and states that review by the responsible supervisor shall be
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conducted.
The NQAM is implemented by Administrative Instruction (AI)-12, j
Adverse Conditions and Corrective Actions. AI-12 states that the
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purpose of the instruction is to provide measures which assure t
that conditions adverse to quality are promptly identified,
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documented and corrected, and that actions are taken to prevent j
their recurrence.
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AI-12, Section 5.1 states that Section Supervisors are responsible j
for evaluating each reported CAQ and initiating corrective action in a timely manner. CAQs shall be screened by section supervisors
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to determine whether they may constitute significant CAQs.
AI-12 Section 4.0 defines a significant CAQ as a condition that recurs with such frequency that it indicates past corrective action had been ineffective.
The inspector determined that the
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continued failures of the sump level transmitters was a signifi-cant CAQ based on the definition as described in AI-12.
AI-12, Section 5.4.1, states. that CARS shall be used to report CAQs. when i
the condition involves generic rather than isolated problems, or i
recurrence control as well as remedial corrective action is required, or. higher level management needs to be involved with the problem and/or be involved in its resolution.
AI-12 states, with regard to time frame for action, that employees
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are responsible for "promptly reporting any suspected abnormal plant condition adverse to quality."
AI-12, Section 5.1, also -
states that " corrective action shall be implemented in a timely
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manner."
Significant CAQs are required to be evaluated for reportability under 10 CFR 50.72, 50.73 and Part 21.
These requirements involve reporting times from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to 30 days.
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The inspector observed during the review of SI-202 that test results were not, in some cases, reviewed by the responsible i
supervisor for several months after determination of the test deficiency /CAQ.
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(2) Evaluation of the Review of Test Deficiencies as CAQs and Significant CAQs
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The inspector requested TVA to provide their position on the
responsibilities of the section supervisor in regard to screening l
CAQs for significance and documenting their review. The licensee
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stated that section supervisors currently screen CAQs for significance.
The licensee interprets the word " screened" as i
reviewing a subord_inate engineer's review. The supervisory review is not documented unless the supervisor determines that a i
significant CAQ is involved.
In that case, the significant CAQ is documented by the issuance of a PRO, a Deficiency Report (DR) or a I
CAR.
The inspector did not find a PRO, CAR or DR addressing j
calibration problems with the Containment Sump Level transmitters
which were identified as being out-of-TS tolerance six times during the 18 month surveillances conducted in 1984, 1985 and 1986 i
as presented in Section 13.a of this report.
Apparently, the
licensee had failed to review these out-of-calibration conditions for CAQ significance and did not initiate a CAR.
Failure to
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conduct a documented review of these deficiencies for condition i
adverse to quality significance is identified as violation 327,328/86-37-06.
l (3) Evaluation of the Timeliness of Test Results The inspectors determined that reviews of test deficiencies
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appeared to have not been done in a timely manner for the following instances:
Unit 1, SI-202, Calibration of Safety Injection System
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Instruments (Refueling Outage), was started on November 13, i
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i 1980, and completed on December 11, 1980. The Shift Engineer (SE) was notified that the test.was complete on December 6, 1980, and the test had been reviewed December 29, 1980. The SE notification of completion was actually 5 days prior to
completion of the test and 23 days prior to completion of
review.
This SI package was subsequently found to contain a number of discrepancies.
Unit 1, SI-202, was started on February 1,1982.
The last
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calibration was performed on March 2,1982.
The SE was
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notified on April 20, 1982, that the test was completed and the test review was completed on July 2,1982, approximately four months af ter completion of the test and over two months after SE. notification of test completion. The deficiency log i
on this performance included three TS and five compliance j
instruments being found out of tolerance.
Unit 2, SI-202, was started on October 6,1985, and completed
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The SE was notified of test completion on October 29, 1985. The review of the test was completed on February 1,1986, approximately three months later.
This
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review included six TS and eight compliance instruments
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showing out of tolerance conditions.
Unit 1, SI-202, was started on December 6,1983.
The last
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calibration was performed on December 19, 1983, and the review was completed on January 16, 1984, approximately one month later.
The SR0 was notified of completion of the test on December 21, 1983, and the plant was taken into Mode 4 on
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December 25, 1983, prior to the review completion.
Out of l
calibration conditions had been* noted for three TS instru-l ments and four compliance instruments.
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. Unit 2,. SI-202, was started on February 15, 1981.
The last
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calibration was completed on containment sump level instru-
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ments LT-63-176 and 178 on June 5,1981, after completion of a related maintenance request (MR).
The SI indicates that the SE was notified that the surveillance had been completed
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on March 5, 1981, three months prior to the last performance i
date. The licensee attained initial criticality on Unit 2 on 6~
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November 5,1981 and the test review was completed on
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December 10, 1981, approximately four months after the Unit entered mode 4, a total of nine months after test completion.
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Unit 2, SI-202, was started on July 15, 1983.
The last
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calibration was performed on August 2,1983, and the review
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was completed October 23, 1983, approximately two and one half months later.
In this case, the SI was reported as complete to the SR0 on October 20, 1983, and the plant was taken into Mode 4 on October 5, 1983. The TS instruments are required to be operable in this mode.
In this performance of
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the SI, 3 of 4 RWST level transmitters were out of calibra-
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tion and 4 of 4 containment sump level transmitters were out of calibration. At this time the licensee reviewed the event for reportability and issued LER 328/83-140.
The LER incorrectly identified the date when the instruments were found out-of-tolerance.
I Unit 2, SI-202, was started on August 1,1984.
The last
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calibration was completed on October 6,1984.
The SE was notified of test completion on December 1,1984, and the
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instruction review was completed on December 17, 1984, approximately 2 months after the last performance. The plant l
was taken to Mode 4 on December 3, 1984, 14 days prior to j
completion of the review.
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In addition, the review of test deficiencies by the responsible supervisor had not been completed prior to a mode change which i
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required specific instruments to be operable.
In many of these instances the SE had been notified that the tests were complete j-prior to completion of the review.
The licensee stated that the reason the test results were not reviewed prior to SE notification of test completion and prior to mode change was that the technician had verified that the test had
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met the acceptance criteria in the instruction.
This acceptance
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criteria only required that the channel be recalibrated and left within the procedural or TS tolerance rather than requiring review of the cause for the as found out-of-tolerance conditions and j
evaluation of that cause for significance.
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This weakness in acceptance criteria had been previously identified by the licensee.
Surveillance instructions are being revised to include acceptance criteria which require that the as found condition be within the required tolerance or evaluated
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prior to signoff of the acceptance criteria.
This revision to appropriate sis is being implemented as part of the comprehensive
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TS and SI program review being conducted at Sequoyah.
The inspector reviewed other sis, including the latest revision of SI-202, and SI-98.4 and SI-98.5 which are new procedures contain-ing the TS instruments deleted from 51-202, and determined that
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the acceptance criteria for the tests had been revised to include the new requirements.
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10 CFR 50, Appendix B, Criteria XVI requires that conditions adverse to quality be promptly identified and corrected.
AI-12 implements this by requiring that CAQs be evaluated "in a timely manner."
The above instances had not been reviewed in a timely manner and together constitutes a further example of violation 327,328/86-37-06.
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(4) Review of the Requirements for Trending CAQs NQAM Part III, Section 7.2, subsection 7.1, states that conditions adverse to quality shall be quantitatively evaluated in a formal trend analysis program to obtain information such as whether the quantity of similar problems indicates a generic' problem or QA program weakness, whether the quantity of specific types of problems are increasing or decreasing, whether different recur-rence control measures are needed, and whether specific program areas and/or organizations are responsible for unexpected high proportion of the total problems.
Section 7.0, trend Analysis, however, does not make specific assignment of responsibilities for trending CAQs identified in test deficiencies or for trending CAQs
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identified in many of the other documentation identified by AI-12 as mechanisms for reporting CAQs.
I The inspector reviewed the trending mechanism used to trend
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out-of-tolerance data since the end of 1984. The trending record consisted of a log of out-of-tolerance conditions identified by instrument number.
The trending method was informal, inaccurate
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and maintained by the assistant section supervisor. Additionally, j
it did not include data prior to December 1984.
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Violation 327, 328/85-45-06 cited the licensee for fail'ure to promptly correct conditions adverse to quality per 10 CFR 50, Appendix B, Criterion XVI.
The failure to provide an adequate trending method for out-of-calibration conditions identified in this report' represents a
further example of violation 327,328/85-45-06.
A formal trending program is under development as discussed in the Sequoyah Nuclear Performance Plan, Revision 1, Section 6.5.3.
The new program will be computerized and based on INP0 guidelines. A trending log of instruments will' also be utilized to evaluate repeated instrument out-of-tolerances. The program implementation
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will be reviewed by the NRC as a followup to the licensee's corrective action associated with violation 327, 328/85-45-06.
14. Drawing Control (37700)
During the inspection period, various aspects of the utility's drawing control processes were observed.
Several areas have been identified as problem areas at Sequoyah and are identified below:
a.
Drawings in the Control Room contain numerous errors.
The licensee's
design verification program includes corrective action to upgrade these i
drawings.
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Drawings are not clearly marked to delineate "As Constructed" versions of prints.
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When an "As Constructed" drawing is meant to apply to only one unit, but contains information specific to the other unit or to common equipment, the non-applicable portions are not identified in an-unambiguous manner. At present, prints are marked with a stamp " UNIT 1 ONLY" or " UNIT 2 ONLY."
Training is in progress to familiarize operations personnel with the applicability of drawings marked in this manner, but the stamp alone is inadequate to identify conclusively those portions of the prints that are not applicable, d.
Legibility and clarity of many drawings ranges from fair to unreadable.
A program to correct legibility problems of selected control room drawings has been implemented as outlined in CAR 86-01-002.
Drawings identified by the operators as both necessary and of poor quality have been placed on a list of drawings to be corrected prior to startup.
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Operations personnel do not have immediate ' access to up to date
reliable prints which can be used in the field. At present only extra l
copies of flow diagrams are kept in the Shift Supervisor's office.
These extra drawings are not marked to reflect the latest configuration changes as are the Control room prints. When the extra copy is soiled, contaminated, or otherwise rendered unusable, a new copy is ordered from Drawing Control.
No provisions exist for obtaining field-use copies of other print series, other than sending someone to the Drawing Control office to have a copy made. The operators are not required to have drawings during walkdowns, lineups, or for training purposes.
Operators may obtain controlled copies of drawings from the " extra" file for these purposes.
Controlled copies are not available in the
" extra" file for all systems. Some means of obtaining a direct copy of
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any control room drawing should be established, f.
The-Mechanical Logic Diagram series have not been maintained and corrected at the same level as other drawing series.
This entire series has been removed from the control room set of prints by the Operations Supervisor to limit their use by the operators and to help reduce the total number of prints in the control room set. These logic diagrams have been moved to an area outside the Shift Supervisor's office, and are still accessible to the operators.
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Control room prints frequently have legibility problems caused by errors in the reproduction process.
These usually appear as vertical streaks or washed-out areas.
A review process to catch these types of errors before the prints are placed in the control room racks has been initiated.
Drawing control will be followed as IFI 327,328/86-37-07.
l No violations or deviations were identified.
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15. Onsite Safety Review Committee (40700)
The inspector attended the Plant Operations Review Committee (PORC) meeting on July 3,1986.. In addition, the minutes for PORC meetings 3763 thru 3766 (conducted on February 27 and 28, 1986) were reviewed.- The inspector also reviewed informal review packages for the current revisions of SI-98.4 and SI-98.5.
These review packages appeared to be adequate and documentation complete.
No-violations or deviations were identified.
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