IR 05000327/1987017

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Insp Repts 50-327/87-17 & 50-328/87-17 on 870306-0405.No Violations or Deviations Noted.Major Areas Inspected: Operational Safety Verification,Previous Insp Findings, Followup of Events & Review of IE Info Notices
ML20214J936
Person / Time
Site: Sequoyah  Tennessee Valley Authority icon.png
Issue date: 05/08/1987
From: Brady J, Branch M, Michael Brown, Carroll R, Harmon P, Hunegs G, Jenison K, David Loveless, Mcoy F, Poertner W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II), NRC OFFICE OF SPECIAL PROJECTS
To:
Shared Package
ML20214J910 List:
References
50-327-87-17, 50-328-87-17, IEB-80-12, NUDOCS 8705280259
Download: ML20214J936 (21)


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[2 KfCg UNITED STATES

'o NUCLEAR REGULATORY COMMISSION j *

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REGION 11 n

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,j 101 MARIETTA STREET, N.W.

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ATLANTA, GEORGI A 30323

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Report Nos.:

50-327/87-17, 50-328/87-17

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Licensee:

Tennessee Valley Authority

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500A Chestnut Street

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Chattanooga, TN 37401 l

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Docket Nos.:

50-327 and 50-328 License Nos.: DPR-77 and DPR-79 i

i Facility Name:

Sequoyah Units 1 and 2

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j Inspection Conducted: March 6, 1987 thru April 5, 1987 Inspectors:

8/f/8u Mr l<n 4/r3 /97 K fM.' Jenison, pior' Resident Inspector Date Signed

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K. Branch, StarJ6p 04ordinator Date Signed i B AuA zm

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l V. E. Harmon, ~Rysiderft Inspector Date Signed

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p. 'P. Loveless /Residen't Inspector Date Signed

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W K. Poertner/Resfdent Inspector Date Signed l A Aurdi kn 4N3/S 7 f. E. Carroly Pridject Engineer Date Signed j

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G.8.Brady,gtoje~tEngineer Date Signed c

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G~. K.' flu 6egt Prg'ect Engineer Date Signed l

l A /!wd 11 963/.97 ft. P. Brown fr:6 ct Engin1er Date Signed Approved by'

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i F. McCo9, SectionLChier'

gape SYgned Division of Special Projects

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SUMMARY Scope: This routine, announced inspection involved inspection onsite by the Resident Inspectors in the areas of:

operational safety verification (including operations performance, system Ifneups, radiation protection, safeguards and housekeeping inspections); review of previous inspection findings; followup of events; review of licensee identified items; review of IE Informatien Notices; and review of inspector followup items.

Results:

No violations or deviations were identified.

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REPORT DETAILS

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1.

Licensee Employees Contacted

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H. L. Abercrombie, Site Director

  • L. M. Nobles, Plant Manager

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B. S. Willis, Operations and Engineering Superintendent i

  • A. M. Qualls, Bellefonte Plant Manager i

B. M. Patterson, Maintenance Superinterdent R. J. Prince, Radiological Control Superintendent

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  • M. R. Harding, Licensing Group Manager
  • L. E. Martin, Site Quality Manager D. W. Wilson, Project Engineer R. W. Olson, Modifications Branch Manager i

J. M. Anthony, Operations Group Supervisor R. V. Pierce, Mechanical Maintenance Supervisor

M. A. Scarzinski, Electrical Maintenance Supervisor H. D. Elkins, Instrument Maintenance Group Manager

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R. S. Kaplan, Site Security Manager

  • R. W. Fortenberry, Technical Support Supervisor
  • G. B. Kirk, Compliance Supervisor ^

D. C. Craven, Quality Assurance Staff Supervisor

  • J. H. Sullivan, Regulatory Engineering Supervisor J. L. Hamilton, Quality Engineering Manager D. L. Cowart, Quality Engineering Supervisor

H. R. Rogers, Plant Operations Review Staff j

  • M. A. Cooper, Conipliance Engineer R. H. Buchholz, Sequoyah Site Representative-Other licensee employees contacted included technicians, operators, shift engineers, security force members, enginedrs and maintenance personnel.

Other NRC Contributors J. B. Brady

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  • Attended'exttIEterview.

s 2.

Exit Interview

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The inspection scope and findings were summarized with the Plant Manager and members of his staff on April 6,1987. No violations which resulted from this inspection were discu'ssed. No deviat' ions were discussed.

The licensee acknowledged the inspectfon findings.. The licensee did not

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identify as proprietary any of the' material reviewed by the inspectors during this inspection. During the reporting period, frequent discussions

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were held. with the Site Director, Plant Manager and other managers

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concerning inspection findings.

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3.

Licensee Action on Previous Inspection Findings (92702)

(Closed) Violation 85-17-05, Failure to Follow Emergency Diesel Generator (EDG) Procedure. The licensee's response of August 28, 1985, was reviewed and the indicated corrective action was audited.

The corrective action stipulated was to revise the affected procedure to eliminate confusing statements in the body of the procedure and in the data sheets used to transcribe surveillance information.

Specifically, the procedure was revised to provide detailed instructions to improve communications between the technician and the oper ator while raising the EDG speed, and to add

"approximately 850 rpm" to allcw more flexibility in recording data. The licensee's actions are considered complete.

This item is closed.

(Closed) Violation 327,328/86-37-03, Failure to Comply with Radiation Work Permit (RWP).

The violation occurred when an HP technician entered a contamination zone without wearing a protective hood contrary to the requirements of RWP 86-0460-63.

Following identification, the licensee documented the incident and took disciplinary action against the individual.

The inspector reviewed a February 1987 update of Radiological Control Instruction RCI-1, " Radiological Hygiene Control", which impressed upon workers the importance of following good radiological work practices ar.d adhering to the instructions specified on RWPs when working in radiological controlled areas of the plant.

This item is closed.

(Closed) Violation 327,328/86-46-09, Failure to Wear Protective Clothing as Required by RWP. The violation occurred when three individuals entered the Unit 2 containment wearing canvas hoods improperly, which was contrary to the requirements of RWP 86-2-216-117.

Following discussions with the resident inspectors all three individuals properly closed the protective hoods.

This event occurred in the same time frame as the event addressed in violation 327, 328/86-37-03 above. The corrective action taken to prevent further violations is the same for both. The inspector noted that there was a heightened awareness of the issue among health physics (HP)

personnel. This item is closed.

(Closed) Violation 327,328/86-46-01, Failure to Barricade High Radiation Area and Follow RWP. The violation occurred when two individuals entered a high radiation area and failed to ensure that either of the two available entry barriers were returned to a position which barricaded access to the area. The resident inspectors returned both barriers to the closed position shortly after the occurrence.

The inspector reviewed two letters written by the Superintendent, Radiological Controls. One letter was addressed to the Radiological Field Operations (RF0) personnel and included a discussion of the subject j

violation. The second letter was sent to plant supervisors. The letter

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provided a brief description of the violation, gave the requirement for the gates, and requested assistance in observing the gates for compliance requirement.

The inspector also reviewed changes to RCI-1 which required HP personnel to observe the barriers for degradation which could prevent their automatic closure.

Hardware modifications were also performed on certain barriers to correct the problems.

This item is closed.

(Closed) Violation 327,328/86-46-03, Failure to Submit Report on Steam Generator Tube Plugging per TS 4.4.5.5.a.

The inspector reviewed Revision 11 to MI-3.2, Method of Plugging Steam Generator Tubes.

This revision included a signoff to ensure that Site Licensing was notified of the tube pluggings. The procedure also indicated to Site Licensing the date by which the NRC had to be notified.

The inspector reviewed the latest report sent to the NRC on March 13, 1987. This report was sent out within appropriate time frames and met the requirements of the TS. This item is closed.

(Closed) Unresolved Item 327,328/86-71-02, Restricted Area Access Controls.

The inspector observed personnel leaving a restricted area without frisking out.

This issue was addressed by regional personnel during an inspection June 16-20, 1986.

Although the posting was inappropriate, it did not violate the requirements of 10CFR20.

The licensee corrected the posting problem and discussed the issue with HP personnel. This item is closed.

(Closed) Violation 327,328/86-15-06, Independent Safety Engineering Group (ISEG) Review Reporting. The licensee's response of April 4,1986, was reviewed and corrective actions audited. The licensee currently has a Technical Specification change request under consideration by the NRC, which will change the organizational composition of the ISEG. This item is closed.

(Cirod) Unresolved item 327/328,86-42-07, Use of Inoperable ERCW Pump to Perforn SI-26.2A. This item concerned the use of an inoperable essential raw cooling water (ERCW) pump during the performance of SI-26.2A, Loss of Offsite Power With Safety Injection D/G 2AA Containment Isolation Test, Unit 2.

The inspector reviewed the following documents:

Work Request 115764 SI 45.1 performed on July 28, 1986 SI 26.2A performed on July 10, 1986 Work request 115764 was initiated June 6, 1986, to install new packing and 0-rings on ERCW pump RA. Physical work on the pump was completed July 9, 1986.

SI-26.2A was performed July 10, 1986, prior to the performance of the post maintenance test specified on work request 115764.

The post maintenance test was successfully completed on July 28, 1986. Although technically inoperable during the performance of SI-26.2A the RA ERCW pump was functional and was determined to be operable on July 28, 1986. The fact that the RA ERCW pump was technically inoperable during the performance of SI-26.2A did not invalidate the surveillance. This item is close.

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(0 pen) Unresolved item 327,328/86-46-06, Locate and Review Documentation of Licensee's Reviews Required by IEB 80-12. This item is addressed in paragraph 7 under IEB 80-12. This item remains open.

(Closed) Unresolved Item 327,328/86-49-07, License Conditions. Formal NRC staff response of a'cceptance of licensee submittals could not be identi-fied during inspection 327,328/86-49. As a result, a memorandum (Zech/

Youngblood) dated January 9, 1987, was written requesting resolution.

This memo referenced conditions 2.c.6, 2.c.18, 2.c.21 for unit 1 and 2.c.16 for unit 2.

In a memo (Yourgblood/Zech) dated February 2,1987, the staff determined that TVA responded to the above stated conditions by i

providing the required information and thereby satisfied the license condition despite the fact that formal staff acceptance could not be identified.

This item 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 l

deviations. One unresolved item was identified during this inspection, and is identified in paragraph nine.

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 inspectors verified the operability of selected emergency systems,

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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

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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, 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:

Essential Raw Cooling Water Emergency Gas Treatment System Auxiliary Building Gas Treatment System

No violations or deviations were identified.

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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; searching of personnel and packages; badge issuance and retrieval; patrols and compensatory posts; and escorting of visitors.

In addition, the inspectors observed protected area lighting, pro-tected and vital areas barrier integrity. The inspectors verified an interface between the security organization and operations or main-tenance.

Specifically, the. Resident Inspectors inspected security during outages, visited central or secondary alarm station, and verified protection of Safeguards Information.

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 ensure the activities were being con-ducted in accordance with applicable RWPs.

Selected radiation protection instruments were verified operable and calibration-frequencies were reviewed.

No violations or deviations were identified.

6.

Monthly Surveillance Observations (61726)

The inspectors observed / 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 requirements and were reviewed by personnel other than the individual directing the test; that deficien-cies were identified, as appropriate, and 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 a performance of SI-307.2, Degraded Voltage Functional Test, conducted on 6.9 kv shutdown board 28-B.

During the performance of the SI all four diesel generators (DGs) started and DG 2B-B loaded onto its shutdown board. The start signal was generated when the technician plugged in the 115 Vac power supply to the test box.

The cause is theorized to be a current surge that picked up the undervoltage relay. This procedure is presently in the SI review process and the licensee plans to revise the procedure to prevent recurrenc.

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7.

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; correc-tive 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 Technical Specification conditions had been identified.

LERs Unit 1 327/80-22 Revision 2, Isolation of essential control air. This revision, dated November 28, 1986, was written by the licensee to change a commit-ment on the additional actions on non-essential air compressors.

327/80-041 Revision 3, Isolation of essential control air. This revision dated November 28, 1986, was written by the licensee to change a commit-ment on the additional actions on non-essential air compressors.

327/86-025 Revision 1, Two inadvertent standby diesel generator starts.

The inadvertent diesel generator starts involved one personnel error and component failure. The licensee's additional corrective actions appear to be acceptable.

327/86-032, Fire barrier breaches.

This LER involved two separate breaches of a fire barrier. One breach involved cab.e tray penetration AB745A311Q19 which may have existed from original construction activities.

The licensee's corrective actions appear to be acceptable.

327/86-055, Auxiliary building isolation.

The licensee determined that the cause of the auxiliary building isolation was an electrical spike on a radiation monitor. The licensee's specific corrective actions to correct the specific radiation monitor appear to be acceptable.

327/86-60, Control room isolation. The licensee determined that the cause of the control room isolation was an electrical spike on a radiation monitor.

The licensee's specific corrective actions to correct the specific radiation monitor appear to be acceptable.

8.

IE Bulletins (92701)

IE bulletins (IEBs) are documents issued by the NRC which require certain specific actions of the addressee. The inspector has reviewed the actions taken by the licensee as a response to the below listed IEBs.

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 Technical Specification conditions did not appear to occu,

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(0 pen)' IEB 80-12, Decay Heat Removal System Operability.

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Paragraph 7 of the bulletin required the licensee t'o report to the NRC

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within three days of the date of the bulletin the results of certain

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reviews and analyses.

The. response _ to the bulletin was required to include, among other things, changes to procedures.

TVA's response to paragraph 7 of the bulletin addressed three potential loss of decay heat removal capability scenarios that required modifications to plant pro-cedures:

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The RCS partially drained but prior to reactor vessel head deten-tioning.

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The reactor. vessel head detentioned, but still in place.

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The reactor vessel head removed, but prior to filling the refueling j

cavity.

The licensee identified procedural and other changes in response to the

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first scenario only and did not address the other two.

i The inspector reviewed an October 13, 1981 letter from Westinghouse to TVA l

addressing issues in the bulletin.

This letter addressed the. event

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involving a loss of RHR with the vessel partially drained. This aspect

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does not appear to have been addressed by the licensee.

The inspector could not determine that items 1-6'of the bulletin had been appropriately addressed.

The licensee was notified and is currently gathering information on these reviews.

In addition, the - licensee is

gathering information on the specific actions taken per the commitments in the June 9,1980 response.

The following items are required for final bulletin closure:

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Inspect documentation of items 1-6 reviews

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Inspect corrective actions taken on RHR-procedures

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Inspect areas noted, but not addressed in the June 9, 1980 response

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Inspect licensee response to items in Westinghouse letter October 13, l

1981 This item remains open.

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9.

Event Followup (93702)

10n March' 11, 1987, an ASE isolated valve 1-FCV-67-127 in a Hold Order for

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work to be performed on the ERCW piping. This rendered A train equipment-inoperable. The operator failed at this. time to realize that.0-FCV-67-208 l

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was isolated making inoperable a portion of the B train. Approximately i

three hours later it was discovered that the station air compressors-had

tripped on lack of cooling water.

This resulted in a loss of air to i

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valves in both. trains of control room ventilation and isolated four

radiation monitors. This event occurred because the~ operator failed to verify that all of the B train ERCW was operable before isolating the A train.

In addition, the RHR 1A pump room temperature was noted to be increasing following the event. This was caused by continued operation of the IA RHR pump following room cooler isolation.

The inspector will consider the following in review of this event:

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Appropriate use of procedures

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Independent verification of actions affecting. quality

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Configuration control throughout the event

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Corrective actions taken following initial discovery of a problem This item is considered unresolved and will be further reviewed until the

regulatory questions are resolved.

This. item will be tracked as unresolved item 327,328/87-17-01.

10.

Inspector Followup Items

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

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reviewed and evaluated by the inspector.

The inspector has either resolved the concern identified, determined that the licensee has per-formed adequately in the area, and/or determined that actions taken by the licensee have resolved the concern.

a.

(0 pen) IFI 327,328/85-47-02, Review of Procedure Revision and AOI-27 for Update af ter Workplan.

The inspector reviewed the current revision of A01-27, Control Room Inaccessibility, and determined that the specific issue had been corrected. AI-19, Plant Modifications,

was reviewed and the procedure appeared to be adequate and prescrip-tive. The following items need to be addressed for final closure of the item:

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Review a selection of PR0s for events caused by inadequate procedures following system modification

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Interview operations personnel to determine if the problems have been corrected

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Review QA documents generated for potential AI-19 deficiencies This item remains open.

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(Closed) IFI 327,328/86-28-11, Radiation Zone Management.

The inspector discussed the contamination zone management program with licensee personnel and noted major improvements.

The plant is now tracking new contamination zones to ensure that they will be closed out as plant configuration allows. Old zones are being reviewed and-decontaminated as appropriate. The inspector has noted large areas

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of contamination zones being decontaminated. and released over the

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last several months.

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The area of posting was reviewed by regional personnel in an inspec-l tion June 16-20, 1986. The inspectors determined that the postings were being handled in accordance with 10CFR20.

Licensee management was informed, however, of certain areas that, even though posted in accordance with regulations, appeared to be confusing to the workers.

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This item is closed.

c.

(Closed) IFI 327,328/86-28-05, Auxiliary Building Secondary Contain-

ment Enclosure (ABSCE) Boundary Door Requirements.

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observed a breach of an ABSCE boundary door with both units in l

mode 5.

L TS 3.7.8 requires two trains of Auxiliary Building Gas Treatment System (ABGTS) to be operable in modes 1-4.

This is verified in part by verifying that the system maintains portions of the Auxiliary Building at a vacuum of at least one quarter-inch water gauge rela-tive to the outside atmosphere.

This ability is maintained utilizing TI-77, Breaching the Shield Building, ABSCE, or the Control Building. This procedure sets down requirements for maintaining the boundary and allowances for breaching it when required.

This procedure states that, "When breaching the auxiliary building boundaries the ABGTS shall be

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able to maintain the auxiliary building at a pressure equal to or more negative than 0.25 inch water gauge relative to the outside atmosphere. This fulfills SR 4.7.8.d.3 and is applicable with either unit in modes 1-4.

With both units in mode 5 or 6, integrity of the ABSCE is not required, i.e., one train ABGTS is required operable but there is no auxiliary building pressure (vacuum) requirement."

TS 3.9.12 requires one train of ABGTS to be operable when irradiated fuel is in the storage pool. However, this does not require that a vacuum be drawn in the auxiliary building as in TS 3.7.8.

This item is closed.

d.

(Closed) IFI 327,328/86-19-13, Follow Procedural Requirements to Report Part 21 in Two Days. The inspectors noted that AI-18, Plant Reporting Requirements, File Package 18, Notification and Licensee Event Reports (LERs), addressed reporting Part 21 requirements in LER format.

The 30 day reporting requirements of the LER are substan-tially different from the two day reporting requirements for Part 21.

However, this difference is not proceduralized.

The inspector reviewed a February 9,1987 revision of AI-18 which incorporated File Package number 75,10CFR21 Evaluation and Reporting Requirements.

This included a note in the beginning of the package stating, " Initial notification to the NRC with two days following receipt of information reasonably indicating a failure to comply or a defect.

If initial notification is by means other than written

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communication, a written report to the NRC is required within 5 days after receipt of information."

This item is closed.

e.

(Closed) IFI 327,328/86-06-03, EDG Testing.

This IFI questioned whether the surveillance on the EDGs was performed properly. The IFI was based on interpretation of the 10 second time frame for reaching rated speed and voltage.

After reviewing applicable technical manuals and procedures, the inspector agrees with the licensee's interpretation that the 10 second limit is an end point limit. This means that the rated limits must be reached within 10 seconds rather than that the speed and voltage is at rated at the 10 second mark.

This IFI is closed, f.

(Closed). IFI 327,328/86-06-05, RHR Isolation.

This IFI questioned whether a residual heat removal isolation that occurred on January.2, 1986, should have been reported to the NRC.

After reviewing the event and referring to the applicable 10CFR sections, it was deter-mined that the event was not reportable.

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(Closed) IFI 327,328/86-19-05, AUD Check of EDG Fuses.

This IFI identified incidents resulting from fuse checks as recurring events.

While attempting to positively identify fuse size and type, the operators performing the check have caused several events by allowing the fuses to pop out of their clips while rotating them to view the fuse markings.

The licensee has instituted training sessions and issued night order letters to provide guidance on rotating fuses and to replace them so that they can be identified.

This IFI is closed.

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(Closed) IFI 327,328/86-28-16, UHI Level Switch, DNE Programmatic

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Training Issue. This IFI questioned whether the Division of Nuclear Engineering (DNE) had an adequate experience review program. This

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was based on an event involving a lack of awareness of IE notices in general and a notice involving an almost identical. event at another plant.

After reviewing applicable DNE procedures, the inspector

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determined that adequate procedures and processes are in place to

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ensure DNE participation in the experience review process.

Changes to Engineering Procedure 2.10, "NRC-0IE Bulletins, Circulars, and Information Notices Distribution," appear adequate to ensure experience review at the engineer / reviewer level.

This item is closed.

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(Closed) IFI 327,328/86-20-07, QA Inline Function - Writing Line Procedures. The procedures identified in this issue were transferred away from QA line responsibility. This IFI is closed.

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(Closed) IFI 327,328/86-44-02, Review of ISEG Responsibilities. This item was discussed under '/IO 327,328/86-15-06 previously.

This IFI is closed.

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Plant' Operations Review Committee (40700)

The inspector observed'a meeting of the plant operations review committee (PORC) chaired by the plant manager.

Safety related procedures, work

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plans, and changes were reviewed during_the meeting. A representative of the department that authored - the document or change was present to summarize it for PORC members. If any of the members were unfamiliar with the document or change, a detailed review was undertaken by the represen-tative including in some cases reading of the changes. The review of each item continued until all questions were either answered to the satisfac-tionaof the committee members or it was determined that additional clari-fication including appropriate documentation would be required before PORC could satisfactorily complete the review.

Approximately 25% of the documents reviewed at this meeting were returned by PORC for clarification

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of the documentation.

No violations or deviations were identified.

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12.

Surveillance Review Program (61700)

The licensee is currently in a large scale surveillance instruction (SI)

review. The inspector reviewed that process and determined that the pro-cedures process appears to be producing completed procedures at an ade-quate rate in order to meet the anticipated NRC SI inspection date.

The following issues were evaluated by the inspector during a review of the licensee's SI review process:

LER 327/86-031 Inadequate valve stroke procedure LER 327/86-039 Surveillance requirement not performed

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because of inadequate surveillance

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instruction LER 327/86-042 Surveillance requirement not performed

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because of inadequate surveillance instruction LER 327/86-051 Inadequate procedure resulting in some valves not being retained in their i

surveillance frequency LER 327/86-054 Procedural deficiency resulting in i

inadequate battery voltage determination LER 327/86-056 Inadequate verification of incore detector tips LER 328/86-06 Fire detection instrument not tested

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LER 328/86-07 Surveillance instruction procedural error

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IFI 327,328/86-20-04 Failure to establish manual engineered safety function SI

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IFI 327,328/86-44-03 160 enhancement items identified during SI review IFI 327,328/86-49-02 SI deficiencies not identified during SI review program IFI 327,328/86-49-03 Pump parameters not maintained during SI-130.2 J

The above issues will be included with the issues identified in URI 327,328/86-60-10, and are administratively closed. URI 327,328/86-60-10 will be addressed during the NRC SI inspection.

13. Operation Readiness (71715)

During this inspection period a special inspection was conducted in the area of.Sequoyah's evaluation and correction of deficiencies necessary to support unit 2 restart. This inspection occurred during the week of March 23-27, 1987, and involved the effort of four inspectors. The'objec-

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tive of the inspection was to review TVA's evaluation of. identified deficiencies as.to whether evaluation and correction should be scheduled prior to or after restart.

A brief description of the restart evaluation process is provided-below:

The Sequoyah Activities List ~ (SAL), as described in the Sequoyah Nuclear Performance Plan (SNPP), is the list used by the licensee to track and close those items requiring completion prior to restart.

The SAL was initially developed as part of the Sequoyah Restart Force

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effort and was a product of startup items screened from discussion with personnel and review of several different tracking lists and programs. The programs and lists reviewed by TVA included Signifi-

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cant Condition Reports (SCRs), Corrective Action Reports (CARS),

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Discrepancy Reports (DRs), and Work Requests (WRs).

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developed by. the task force was a snap-shot of issues which existed j

during the March 1987 time frame.

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To ensure that the SAL was being maintained current, so as to be a useful management tool, the inspectors reviewed the program that was established by TVA. This program is described in Sequoyah Standard Practice, SQA-190 revision 0, "Sequoyah Activities List Restart It'em Disposition".

This procedure describes in detail how an item is removed from the SAL. However, little guidance is provided as to how I

a new issue is placed on the SAL. The' current practice of how a new item is placed on the SAL was described to the inspectors as follows:

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Item identified

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Item reviewed to determine if-it can be corrected by the normal maintenance process or whether the item constitutes a condition adverse to quality (CAQ) which requires evaluation under one of the Sequoyah CAQ programs.

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Supervisor evaluates item per SQA-190 to determine if it is a restart item If an item is determined to be a restart item that decision

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is reviewed and approved by the restart director or his staff

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Restart item is assigned a SAL number and then the work activity is loaded on the restart P-2 planning schedule

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Restart item disposition is tracked and documented on Attachments B, C, and D of SQA-190 The SAL described above is the vehicle TVA uses to track and close an item once it has been determined to meet the restart criteria.

However, in order to assess the restart determination process, the inspectors had to review lists from - numerous Sequoyah tracking systems to evaluate those items TVA had determined to be Non-Restart items. These lists are feeders to the restart determination process and constitute the method the licensee would use to track an item under normal conditions. The feeder lists reviewed included the following:

- Potential Reportable Occurrences (PR0s)

- Licensee Event Reports (LERs)

- Problem Identification Reports (PIRs)

- Significant Condition Reports (SCRs)

- Deficiency Reports (DRs)

- Corrective Action Reports (CARS)

- Condition Adverse to Quality Reports (CAQRs)

- Work Requests (WRs)

The inspectors selected several deficiencies from the above lists and performed an independent restart determination using TVA's restart criteria described in SQA-190. The list groupings and the inspectors findings are as follows:

PR0s and LERs PR0s are tracked by the licensee using the commitment action tracking system (CATS).

Based on discussions with the Plant i

Operations Review Staff (PORS), the restart determination is not a formal process (ie. no documentation of determination and the only indication of the restart /non-restart decision may be the corrective action completion date which appears on the CATS

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print-out). Additionally, the cognizant section responsible for corrective action makes the restart decision, but the P0RS group does not control or review that decision.

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Specific problems identified with the restart /non-restart determination are listed below:

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PRO 1-86-209, " Meteorological tower inoperable due to power supply problems".

This item was determined to be non-restart by TVA. However, the inspector considered the item should have been categorized as restart based on criterion 2.1 of SQA-190. Criterion 2.1 requires an item be catego-rized as restart if it adversely affects a program such as radiological emergency preparedness. -This PRO referenced an October 9,1985 memorandum from H. L. Abercrombie, Site Director to Maurice G. Msarsa, Director of Service and Field Operations which stated that Technical Specification action statements were being entered approximately once a month due to equipment failure. This memorandum further stated that the problem should be investigated and resolved in a timely manner. The corrective action completion date indicated on the March 5, 1987 CATS print-out is August 1, 1987. By inference, this item is non-restart, as this date is after TVA's currently projected restart date of July 1987.

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PR0s 1-86-006 and 1-86-351, " Crack in wall of the conden-sate demineralizer waste evaporator (COWE) building". This item was determined to be non-restart by TVA. However, the inspectors determined that the item should have been categorized as restart based on criterion 2.j of SQA-190.

Criterion 2.j requires an item be categorized as restart if the uncorrected deficiency could lead to a spread of radioactive contamination beyond the regulated area.

A sketch included in PRO 1-86-351 shows that the regulated area had to be expanded by temporary barriers. The correc-tive action completion date indicated on the March 5, 1987 CATS print-out is January 1, 1988. By inference, this item also has been categorized as non-restart.

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LERs85-003, Revision 1 and 85-018, Revision 1 deals with

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the need to install fire barrier sealant to meet 10CFR part 50, appendix A requirements.

The licensee has been relying on fire watches as compensatory measures until the defi-ciency is corrected.

LERs are tracked on the Corporate Commitment Tracking System (CCTS).

The March 24, 1987 print-out of CCTS for LER status indicated that correction of the deficiency is not considered a restart item.

The inspectors determined, based on criterion 2.g of SQA-190 that the items should have been categorized as restart.

Specifically, criterion 2.g requires an item be categorized as restart if it could adversely affect fire protection.

The inspectors could not find any mention of compensatory measures being utilized as an alternative to fixing the deficiency.

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LER 83-097, Revision 1 deals with leakage of air into the containment level transmitters.

This air leakage has resulted in instrument drift and has necessitated a change in transmitter type.

The LER indicated that two of the

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i four transmitters had been replaced and the other two would have their fill tees capped and sealed.

Discussion with

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i the PORS group also indicated that plans were being made to i

monitor performance of the transmitters during plant operations until they are replaced.

The March 24, 1987 CCTS print-out indicated that correction of the deficiency

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is not considered a restart item.

The inspectors deter-mined, based on criterion 2.a of SQA-190, that the item should have been considered as a restart item. Criterion 2.a requires an item to be categorized as a restart item if

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it directly or adversely affects safety related equipment

function, performance, reliability, or response time.

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CARS, DRs and CAQRs

The inspectors reviewed the CAR and DR lists to determine the

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adequacy of the evaluation of CARS and DRs for restart using the

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restart criteria contained in SQA-190. CARS and DRs are tracked on a Tracking and Reporting of Open Items..(TROI) computer

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program. A member of the QA staff is responsible for main-taining documentation on each individual file.

A review of several CAR files and DR files was performed.

Inconsistencies

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between the TROI classification of the item and the actual file were identified. It also did not appear that the DRs had been

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adequately evaluated under the classification criteria.

For.

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example, approximately 30 DRs dealing with inadequate surveil-lance instructions were categorized as non-restart. When the inspector questioned the classification of these DRs, the licensee provided a handwritten list which indicated those DRs were related to a restart CAR. However, review of the DR files

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and referenced CAR file indicated no formal link between the files (CAR-86-050, DR-86-229R, DR-86-227R).

This discrepancy

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j was corrected by the licensee in the course of this inspection.

Other DRs which were identified as non-restart in TROI and/or in the DR file, by the QA individual responsible for generating the

file, were found to be considered as restart items by the QA individual assigned to work the file (DR-86-184R). The licensee

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was reevaluating the classification of this file at the conclu-

sion of this inspection.

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An additional problem identified upon reviewing the CAR /DR files was the failure of the QA individual responsible for tracking the CAR /DR files to determine if a completion date of " Prior to

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Restart" indicated a restart item or not (DR-86-184). 'Inconsis-tencies were also found in the classification of CARS.

For example, CARS dealing with drawing inadequacies or configuration control were inconsistently classified (CAR-86-012R and CAR-86-

016R restart and CAR-86-054R and CAR-86-065R non-restart), when all the above CARS fall into the category of commitments to the

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NRC.

Classification of CARS which dealt with the employee concerns program also appeared to be inconsistent. CAR-87-002R

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was identified as non-restart, but the employee concern file

(ECP-86-SQ-441-01) contained information to the effect that the concern was a potential restart issue.

PIRs and SCRs An evaluation of a sample of mechanical engineering branch (MEB)

SCRs' and PIRs was performed to determine if an item should be considered as a restart item.

The licensee restart criteria from SQA-190 was also used to evaluate this area. The following items were identified as nor-restart on the GAQ master tracking list (MTL).

Justification was not available as to how this

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determination was made.

Item Description SCR-SQN-MEB-8633

" Spring on the Main Steam Isolation Valve."

This item could adversely affect the. ability of a system to meet its safety function. Also, the asso-ciated engineering report indicated it would be a restart item. The licensee told the inspector that this item was complete and therefore not included as i

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a restart item. However, this informa-tion could not be verified prior to the r

completion of the inspection.

i SCR-SQN-MEB-8612

" Ability to. maintain core subcritical at cold. conditions during loss of coolant accident (LOCA)".

This i tem could potentially affect the plants safe shutdown capability.

It was not indicated as either a restart or non-restart item on the CAQ MTL and is apparently still under review by the licensee.

SCR-SQN-MEB-8634

" Containment fire barrier penetrations are not installed in a fire rated configuration".

This item was cate-gorized as non-restart.

However, the condition, if left uncorrected, could adversely affect fire protection.

PIR-SQN-MEB-8684

" Work plan 9930 specified incorrect hydrostatic test pressure for the high pressure fire system containment isolation check-valves". This item was

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categorized as non restart.

However, if left uncorrected, it could adversely

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affect fire protection.

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Persornel in the MEB have been using the mechanical CAQ status report for tracking items instead of using the CAQ MTL as directed by TVA's management. The mechanical CAQ status report and CAQ MTL are inconsistent in that the CAQ MTL indicates some items (approximately 10) as restart items which are not indi-cated as restart items on the mechanical CAQ status report. An example of this situation is SCR-SQA-MEB-8677.

This inconsis-tency is being corrected by the licensee.

Many civil, mechanical, nuclear, and electrical engineering branch SCRs and PIRs are still under review by the licensee to determine if the items are restart items.

The TVA schedule indicates completion of this review by April 11, 1987.

The inspector's review of this area revealed that justification for determining an item is non-restart is not required and not apparent.

Different personnel relayed a variety of information concerning the categorization of the items-for restart.

Work Requests (WRs)

Various groups such as design services, modifications, main-tenance, security, inservice testing, DPS0, DNE, system engineering, quality assurance, etc., have work requests for which they are responsible.

However, the only groups specifi-cally tracking WRs as restart items are mechanical maintenance, electrical maintenance, and instrument maintenance. All three

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groups utilize a computerized WR backlog list, flagging those items considered necessary for completion prior to restart.

A review of the WR backlog list was conducted for selected safety systems in order to evaluate each of the three main-tenance group's restart. categorization process.

This review indicated that the restart criteria in SQA-190 was being followed and, for the most part, items considered to be neces-sary for restart by the inspector were indicated as such on the WR backlog list.

There were however, several WRs that-were considered by the inspector, and subsequently agreed to by the

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licensee, to be restart items, but were not flagged as such on

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the WR backlog list. With the exception of-two of these WRs, all were considered too recent to be captured by the groups'

last monthly review.

The two restart items that were not properly categorized were WR-B125695 (containment sump level i

transmitter, dated September 3,1986) and WR-B217786 (auxiliary feed water level control pressure switch, dated January 21, 1987).

Each group indicated that the WR backlog list was presently being reviewed for restart items approximately every month and, with the exception of the instrument maintenance group, this

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computerized listing is updated shortly thereafter to flag the restart items. In the case of the instrument maintenance group,

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that the most recent review was March 8, 1987.

Unlike the

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mechanical and electrical maintenance groups, instrument main-i tenance requires the maintenance planner supervisor to review

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each of the identifind restart items prior to updating the computerized listing.

Because the instrument maintenance foremen use the computerized listing to prioritize work, it appears that the resultant delay in updating the list may

prevent resources from being utilized in an effective manner to support the restart effort.

The licensee indicated that the

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potential problem was recently perceived within the group, and efforts to eliminate the delay by obtaining a dedicated SRO for this review are presently being pursued. Additionally, it was determined that unlike the other two groups, there is no P-2

schedule item for the instrument maintenance group to review the outstanding WRs prior to startup. The licensee indicated in the exit meeting that the P-2 schedule would be changed accordingly.

At the conclusion of the inspection, the inspectors identified

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the following concerns to the licensee:

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Restart -determination is not being made solely on the

technical merit of the issue, (i.e. if - correction is scheduled to be completed in the near future or if the evaluator thinks the item is complete, the item is deter-mined to be non-restart).

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Evaluation of restart, in most cases, is not a formal i

process and no standard exists which identifies who does i

the determination.

(i.e.

in some cases the initiating group categorizes an item,'where in other cases the evalua-

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ting group performs the function and still in other cases -

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the group assigned corrective action responsibility does the review).

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The current process does not require documentation of the

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evaluation and no documentation existing detailing why an i

item is considered non-restart. In.the area of engineering this lack of documentation is apparent. For-example, when

i questioned, many engineers could not justify the non-

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restart determination and several -engineers expressed'

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different opinions on the technical merit of the documented decision.

The current feeders for maintaining the SAL as a useful

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management tool are not working in the area of engineering, where the normal tracking list (TROI) has been demonstrated

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as not being accurate.

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The use of umbrella SAL items does not appear to have adequate controls to ensure that a large number of items

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are not determined to be startup items until just before

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i restart, thereby delaying restart.

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In the area of LERs, several. items were determined as non-restart based on compensatory measures being taken.

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The use of compensatory measures to defer an item correc-tion until after after restart does not appear to be

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' allowed by SQA-190.

  • The details of the above items were discussed with the licensee and the following actions were proposed by the licensee:

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Revise SQA-190 to better describe the SAL process.

This revision will include detailed instructions on what-items need to be reviewed, who does the review, how the non-restart decision is documented, and how to control the umbrella SAL items.

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DNE is going to review and document their restart decision

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on all of their open items.

QA will conduct a sample review of all feeders to the SAL.

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This review will sample SAL input items since the original i

SAL and will provide a basis for the scope of any "look back" review of the feeder lists.

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This area will be reviewed during a subsequent inspection and con-tinues to be followed by the inspector.

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