IR 05000327/1987043

Insp Repts 50-327/87-43 & 50-328/87-43 on 870612-0705.No Violations Noted.Major Areas Inspected:Operational Safety Verification,Including Operations Performance,Sys Lineups, Radiation Protection & Safeguards & Housekeeping Insps

ML20237K537
Person / Time
Site:	Sequoyah
Issue date:	08/10/1987
From:	Jenison K, Mccoy F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20237K507	List: IR 05000327/1987043 ML20237K505
References
50-327-87-43, 50-328-87-43, NUDOCS 8708270206
Download: ML20237K537 (10)

Text

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.[[ - - REGloN li g  j  101 MARIETTA STREET. '?,  t  ATLANTA, GEORGI A 30323 I

k...../ , Report Nos.: 50-327/87-43, 50-328/87-43

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Licensee: Tennessee Valley Authority 500A Chestnut Street Chattanooga, TN 37401 Docket Nos.: 50-327 and 50-328 License Nos.: DPR-77 and DPR-79 Facility Name: Sequoyah Units 1 and 2 Inspection Conducted: ~ June 12,1987 - July 5,1987 Lead Inspector: bM/, d $/d/87

      [ Tate' Si g'ned K. M. Jenison, Senior g s y t Inspector Accompanying Inspectors:     j P. E. Harmon, Resident Inspector D. P. Loveless, Resident Inspector W.K.Poertner,DestpentInspector M. W. Branch Sey fa tart Coordinator Approved by:  a u g_ e F.R.JMcCoy,d'hlP;-PfojectsSection1  8 /o 67 C   pate' Signed i M TVA Projects Division    !

Summary Scope: This routine, announced inspection involved inspection onsite by the Resident Inspectors in the areas of: operational safety verification (including operations performance, system lineups, radiation protection, safeguards and housekeeping inspections); maintenance observations; review of previous inspection findings; followup of events; review of licensee identified  ; items; review of IE Information Notices; and review of inspector followup item Results: No violations were identifie One unresolved item was identified: 327,328/87-43-01, Containment spray valve interlock (paragraph 9c).

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REPORT DETAILS Licensee' Employees Contacted H. Abercrombie,cSite Director

 'J. T. La Point, Deputy' Site Directo .
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 *L. M. Nobles, Plant Manager  .

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 *B. M. Willis, Operations and Engineering Superintendent l  *B. M. Patterson, Maintenance Superintendent R. J. Prince, Radiological Control Superintendent
 * R. Harding, Licensing Group' Manager
 *L. E. Martin, Site Quality Manager D..W.fWilson, Project Engineer R. W.'Olson, Modifications Branch Manager L  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 l  R. S. Kaplan, Site Security Manager
 'J..T. Crittenden, Public Safety' Service Chief
 *R. W. Fortenberry, Technical Support Superviso * B., Kirk, Compliance Supervisor
 *D.- C. Craven, Quality Assurance Staff Supervisor      ,
 ' *J. H. Sullivan, Regulatory Engineering Supervisor
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 *J..L. Hamilton Quality Engineering Manager
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 *D. L. Cowart, Quality Engineering Supervisor
 *H. R. Rogers, Plant 0perations Review Staff
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 *R.-H. Buchholz, Sequoyah Site Representative
 *M. A. Cooper, Compliance Licensing Engineer Other. licensee employees contacted included technicians, operators, shift engineers, security force members, engineers and maintenance personne !
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 * Attended exit interview Exit Interview The inspection scope and findings were summarized with the Plant Manager     !
 . and members of his staff on July 6,198 No violations or deviations     !

were discussed. The licensee acknowledged the inspection findings and did not identify as proprietary any of the material reviewed by the inspectors l during.this inspection. During the reporting period, frequent discussions ' were held with the Site- Director, Plant Manager and other managers con-  ! cerning inspection finding l

          ' Licensee Action on Previous Inspection Findings (92702)
 (Closed) URI 327,328/87-08-04, Inadequate Diesel Generator Test. The inspector questioned the adequacy of a surveillance test of the emergency     j diesel generator (EDG) differential fault relay circui The instruction

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used'was DPSO.SMI-1-DG. The instruction requires the attempted start 'of

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the EDG while'the subject relay is activated to prove that the relay will prevent starting the EDG. Since the attempted start. of the EDG is only veri _fied at the local panel,.the inspector questioned whether other start ~ locations were. required .to be _ tested. 'Further. review of relevant control diagrams. demonstrated that the . relay is common to all start circuits,.  ! regardless : of location. ' The test as written is adequate. This item is therefore close . Unresolved Items Unresolved items are matters about which more .information is required to determine whether they are acceptable or may involve violations or deviations. 'One unresolved item was identified during this inspection, , and is identified in paragraph 9 . Operational Safety Verification (71707) Plant Tours The inspectors observed control room operations, reviewed applicable logs, conducted discussions with control room operators, observed shift. turnovers, and confirmed operability of instrumentatio The

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inspectors verified the' operability of selected emergency systems, and verified compliance with Technical Specification (TS) Limiting Conditions for Operation (LCO). The . inspectors verified tha maintenance work ' orders had been submitted as required and that-followup activities and prioritization. of work was accomplished by the license 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 condition No violations or deviations were identifie Safeguards Inspection In the course of the monthly activities., the inspectors included a review cf 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 i< ' controls; searching of personnel and packages; badge issuance and retrieval; patrols and compensatory posts; and escorting of visitor In addition, the inspectors observed protected area lighting, protected and vital areas barrier integrity. The inspectors verified an interface between the security organization and operations or maintenanc Specifically, the Resident Inspectors: witnessed

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firearms training and qualification; observed emergency drills; interviewed individuals with security concerns; and verified protec-tion of safeguards informatio No violations or deviations were identifie Radiation Protection-The inspectors observed Health Physics (HP) practices and verified implementation of radiation protection control. On a regular basis, radiation work permits (RWPs) were reviewed and specific work activi- , ties were monitored to ensure the activities were being conducted in ! accordance with applicable RWPs. Selected radiation protection instruments were verified operable and calibration frequencies were reviewe No violations or deviations were identifie . 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 deficiencies 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 individual The inspector observed a portion of Special Test Instruction (STI)-24,DC High Voltage Test for Selected IE Cables With Potential For Cable Pullby Damage Conduit MC1750 No discrepancies were note SI-26.1A, Loss of Offsite Power, was observed and is discussed in detail in Section 9 of this repor . Monthly Maintenance Observations (62703) i Station maintenance activities of safety-related systems and com-ponents were observed / reviewed to ascertain that they were conducted in accordance with approved procedures, regulatory guides, industry codes and standards, and in conformance with T The following items were considered during this review: LCOs were met while components or systems were removed from service; redundant components were operable; approvals were obtained prior to initiating the work; activities were accomplished using approved procedures and were inspected as applicable; procedures used were adequate to control the activity; troubleshooting activities were controlled and _ __ ________ -

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the repair record accurately reflected what actually took place; functional testing and/or calibrations were performed prior to returning components or systems to service; quality control records were maintained; activities were accomplished by qualified personnel; parts and materials used were properly certified; radiological controls were implemented; QC hold points were established where required and were observed; fire prevention controls were imple-mented; outside contractor force activities were controlled in accordance with the approved Quality Assurance (QA) program; and housekeeping was actively pursue The inspector observed a portion of the maintenance activities associated with work request (WR) B125591 which rebuilt a unit 2 lower compartment purge isolation valve. The inspector reviewed the work package for adequacy and noted no discrepancie No violations or deviations were identifie . Event Followup (93702, 62703) During the inspection period two separate inadvertent emergency diesel generator (EDG) starts occurred. Both starts were caused by spurious fuse failures in the EDG control circuitry. The failed fuses were FLAS-5 type fuses manufactured by Littlefuse company. These are indicating type fuses

- purchased by the licensee under a special contract to replace the MIS-5 type previously installed. The fuse replacement program had been tracked under IFI 327,328/86-60-05, which was closed in Inspection Report 327, 328/87-2 Since the time this IFI was inspected and closed, approx-imately 54 spurious failures of the new, FLAS-5 type fuse have occurre This item is currently a Startup Action List item, the corrective action for which will be completed prior to startu No deviations or violations were identifie . Restart Test Program (RTP) Review During this inspection period the inspectors continued their review of the Sequoyah Restart Test Progra Details regarding program scope and implementing procedure review were discussed in Inspection Report 50-327,328/87-30. Currently no system package has been processed through the entire review and approval process and all material reviewed by the inspectors was in the draft state. The purpose of the inspection was to make an early assessment of the applicas . .n of the functional matrix review process to those systems packages reviewed. Additionally, this initial review allowed the inspectors to determine the following:

Status of the functional review process regarding the identification of component / system functions that will require testin Effectiveness of the RTP implementing procedures to provide a comprehensive review of component / system function _ - . - .

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Adequacy of documentation available to demonstrate that component / system functions have been tested previously and have not been degraded by past maintenance, modifications, procedure inadequacies, et Indication of any important component / system functions that are not being periodically teste The functional review process requires that the following documents be developed and submitted to the Joint Test Group (JTG) for review and approval: Functional Analysis Report (FAR); this is a written narrative report, issued for each system, which details the major component / system functions. Additionally, this report documents the validation review of the FSAR, TS, Design Criteria Document (DCD) and provides for the evaluation of the impact of other Sequoyah programs on the validity of previous functional verification test This report will also , document the resolution of Punch-list items and provide a listing of ' required testing as well as providing conclusion Function and Test Document Validation Matrix (FATDVM); a computer listing of component / system functions, test status, RTP reviews and result Punch List Report (PLR); this computerized report lists outstanding ' tests to be accomplished, and other deficiencies that need corrective action. Responsible groups for the items are identified as well as disposition and completion date The inspectors reviewed those systems which showed the most schedule progress. A listing of systems reviewed and inspectors comments are l provided below: System 18, Diesel Fuel Oil; This system is described in section 9.5.4 of the Sequoyah FSAR with surveillance requirements contained in section 3/4.8 of the TS. The review of the system by the restart test engineer (RTE) identified a potential discrepancy with the required pump capacity for the transfer pump which provides makeup from the 7-day tank to the 1-day tan Specifically, the FSAR requires in section 9.5.4 that two 15 gpm pumps be provided and this value was verified during preoperational testin However, upon an initial review of the current surveillance instruction (SI)- revision "0" the RTE determined that the SI only requires the pump to provide a minimum flow rate of 10 gpm. During a meeting on June 29, 1987, with plant management (Surveillance Instruction Review Program Manager and Mechanical Test Section Supervisor) this apparent dis-crepancy was discussed. The mechanical test group engineer respon-sible for SI-7.3, stated that the value measured by SI-7.3 was the day tank makeup capacity of the pump with the diesel consumption

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  '6 being approximately 5 gpm, thereby equalling the delivery capacity of'

15 gpm' stated in the FSAR. The inspector reviewed the recommended

' design requirements contained in ANSI N196-1978, Fuel Oil System for Standby Diesel Generators, which. requires the transfer pump capacity to exceed the consumption rate of' the diese Per discussion with the RTE this consumption rate was determined to be approximately 5 gpm and therefore the transfer pump tank makeup capacity of 10 gpm appears to satisfy the design requirement for the syste System 32, Control Air: this system is described in section 9.3.1 o the FSAR and is not discussed in TS. Per discussion with the system RTE several additional sy st'em test / retests may be necessary to establish system performance confidence. Specifically, it appears that compressor, capacity has not been reverified since initial  q preoperational . testing. Since~the compressors are.not included as !

part of the ' ASME section XI pump program their performance is not-periodically evaluated and it appears that due to system loads or leaks that this standby system is required to operate on a frequent basis through the auto start on low system pressure. Additionally, the. RTE 'has identified several set point functions that -in his opinion should be reverified. The inspector did not review the FAR as its status was too preliminary and a review of the final FAR is planned for a. subsequent inspectio System 72, Containment Spray; this , system is described in section 6.2.2 of the FSAR and section 3/4.6.2.1 of the TS. .The inspector reviewed the .FATDVM as well as having discussions .with the RT During the course of this review the inspector. determined that several important . functions, which if not operable could impact on system - performance,. were not being periodically retested / verifie ' Examples of these functions include; room cooler fan ~ starts on pump starts, heat-exchanger D/P, local hand-switch operation, and many pump protection and operator assisted interlock The inspector discussed this observation with the manager RTP as well as with several of the test program advisors which were associated with the Davis Besse restart test program. It appears that these functions are not routinely reverified after the initial preoperational test program and after discussion it appears that this is a common finding for other systems being reviewe The inspector discussed this finding with members of the Engineering Division, Office of Special

' Projects -(OSP) and although the functions must be available for equipment operability there is no fixed requirement to periodically test these functions. The inspector discussed this issue with plant management and the JTG will determine if additional testing should be q performe .

TS 4.6.2.1.c.1 requires that each automatic valve in the flow path ! actuates to its correct position on a containment pressure high-high test signal each 18 months. The current SI-68 for valves FCV-72-39 and FCV-72-2 verifies that the valves open as required. However, the interlock which prevents the valves from opening until the pump

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i l i starts are bypassed during this . test. The inspector was unable to j locate a periodic test that verifies that the interlock contact will l not malfunction thereby preventing containment spray. A meeting was requested with the SI review group to discuss the inspectors con-cerns. During that meeting it was determined that the contact discussed above was never tested and it is TVA's position (Plant Manager and Licensing Manager) that the TS required surveillance is being satisfied. This interlock feature does not appear to be prudent or desirable and is not specifically discussed in the FSA However, logic diagram 47W611-72-1 revision 13, (figure 6.2.2-3) does show this interlock. This item is identified as Unresolved Item 327,328/87-43-01, pending further discussion of this issue with TVA and OS d. System 250, Vital Control Power 125VDC and Uninterruptable 125VAC; This system is discussed in section 8.3 of the FSAR and section 3/ .2 of TS. The initial functional review package was issued June 10, 1987, and has not received final approval by the JTG. .The RTE for system 250 indicated that the review process was approximately 95% complete. The inspector reviewed the DNE functional input to the review matrix and determined that it provided all but one function that the RTE determined to be necessary to satisfy all desi functions of the system. Specifically, the RTE determined that design criteria SQA-DC-V11-2, which requires the station batteries to be recharged within 12 hours following a 30 minute station blackout, was not listed by DN The initial review of system 250 indicated that the functional review process was effective and comprehensiv i e. System 92, Neutron Monitoring; This system is described in section 7.2.1.1 of the FSAR and section 3.1.1.1 of TS. The inspector reviewed the draft copy of the FAR and discussed the review process with the  ! RTE. During this discussion the inspector determined that the review ] was being conducted in accordance with established procedures and . that the RTE was knowledgeable of his system. The RTE identified I several functions that needed additional testing as a result of a -I recent TS amendment which affected the negative flux rate setpoin ! The inspector verified that these tests were listed en the punchlist  ; and are currently scheduled on the plants planning and scheduling P-2 I schedul Additionally, the inspector attended the June 30,1987, 1 JTG meeting where this package was discusse Review of the final l approved FAR is planne f. System 90, Radiation Monitoring; This system is described in section l 11.4 of the FSAR and sections 3.3.3.1, 3.3.3.9, and 3.3.3.10 of the 1 TS. The inspector reviewed the FATDVM as well as having discussions L with the RTE and RTP manager. The review of the system by the RTE l identified two valves that were required to reposition after  ? receiving a signal from the appropriate radiation monitor are not l being tested on a routine basi Since these valves are not in j system 90 boundaries the RTE did not determine if these valves had j l

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been previously tested; however, the RTE did add these valves to the Punchlist Report. At this time this has not been resolved. The inspector selected the Fuel Pool Radiation Monitor, 0-RE-90-103, from the FATDVM and reviewed S/1-83 in order to verify that the functicns of 0-RE-90-103 were tested as stated in the FATDVM and FA The inspector concluded that the functions were adequately tested by S/I-83 on a routine basis. The inspector also compared information from the FATDVM against the tables contained in section 11.4 of the FSA From this review it was evident that the FSAR has not been updated to recognize the addition of numerous radiation monitors to the plant since construction. Per discussion with the licensee the FSAR will be updated per previous commitments. The inspector also observed the licensee perform portions S/I-26.1A, Loss of Off Site Power with Safety Injection-D/G 1A-A Containment Isolation Tes The inspector had the following concerns (1) steps 3.0.9 and 6.2.3.c.2 were not performed and identified by the Test Director as test deficiencies, however these steps do not meet Sequoyah guide-lines to qualify as test deficiencies, (2) section 6.1 was performed without completing prerequisite step 6.1.1 which states " verify data sheet 3" and (3) four S/G blowdown sample line valves and the CCS thermal barrier booster pump switch were out of the required position after the SI had verified them to be in the correct positions. These items have been punchlisted against the final system review and will be discussed with the licensee at a later date. The conduct of testing administrative instruction currently being developed by the licensee should resolve the root causes of these issue . Design, Design Changes, and Modifications (37700) An inspection was conducted on the procedures used to maintain equipment certification for the life of the plant. ANSI 18.7-1976, "Admini strative Controls and Quality Assurance for Operational Phase of Nuclear Power Plants," which is committed to by the licensee in the Topical Report, Table 17D2, indicates that modifications shall be performed in a manner to ensure quality at least equivalent to that specified in the original design bases and requirement Variance 3.2, Rev. 5, " Variances to NEP 3.2," was reviewed. This variance specifies the procedure for generatirig modification criteri Attachment A to Variance 3.2 is the Modification Criteria form which, when filled out specifies the scope, the design bases, tests and inspection requirements, effects on design documents, and references that effect the modification. Additionally an operability, reliability, maintainability, and performance analysis is performed. The use of the Modification Criteria per Variance 3.2 provides the means to ensure quality at least equivalent to that specified by the original design bases and requirement Engineering Change Notices (ECN) were reviewed and found to include the required Modification Criteri No employee concerns were found relating to this topic. No deficiencies were identified during this inspection.

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11. IEBulletins(92701) IE Bulletins 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 IE bulletin. The inspector verified that: corrective actions appeared appropriate; generic applicability had been considered; the licensee had reviewed the event and that appropriate plant personnel were knowledgeable; no unreviewed safety questions were involved; and that violations of regulations or TS condi-tions did not appear to occu (Closed) 327/80-BU-02, Inadequate Quality Assurance for Nuclear Supplied Equipmen This Bulletin dealt with inadequate QA for nuclear supplied equipment related to internal feedwater spargers for boiling water reactor The response required was only applicable to boiling water reactors; consequently, this bulletin was not applicable to Sequoya . 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 IFI has been reviewed and evaluated by the inspecto 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 concer (Closed) IFI 327/76-04-02, procedures Do Not Address How Long Completed-Instructions Are to be Retained as QA Records. Since this iten was opened, TVA has delineated controls for retention of various types of QA records. Existing controls appear adequate. This item is close . Thimble Tube Ejection Event of April 19, 1984 The 1984 seal table /incore thimble tube ejection event generated three violations (327-84-24-01, 327-84-24-02, and 327-84-24-03) and two IFIs (84-11-03 and 84-24-04). Internal NRC reviews of the closure of these items have raised questions regarding the adequacy of the corrective actions implemented by TVA for the violations and their acceptance and closure by NRC. Considered a matter to be resolved prior to restart, the resident inspectors will reopen the five items, review the corrective actions, and document the findings in subsequent NRC inspection report (0 pen) Violation 84-24-01, Failure to Implement / Establish TS Section 6 Administrative Controls (0 pen) Violation 84-24-02, Failure to Conduct Adequate PORC Reviews (0 pen) Violation 84-24-03, Inadeouate Tool Control (0 pen) IFI 84-24-04, Generic Fitting Issues (0 pen) IFI 84-11-03, Thimble Tube Incident Review I _ - _ _ - _ - _ - - _ - _ - _ _ _ _ _ _ _ _ ___ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ___ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ }}