IR 05000327/1987054
| ML20236Q276 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah |
| Issue date: | 11/02/1987 |
| From: | Jenison K, Mccoy F NRC OFFICE OF SPECIAL PROJECTS |
| To: | |
| Shared Package | |
| ML20236Q266 | List: |
| References | |
| 50-327-87-54, 50-328-87-54, IEB-85-003, IEB-85-3, NUDOCS 8711190289 | |
| Download: ML20236Q276 (24) | |
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UMITED STATES
[AR RECuq'
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' NUCLEAR REGULATORY COMMISSION
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REGION 11 o
,j 101 MARIETTA STREET, N.W.
- ATLANTA, GEORGI A 30323
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Report Nos.:
50-327/87-54 and 50-328/87-54
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l Licensee:
Tennessee Valley Authority.
6N38 A Lookout Place
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1101 Market Street j
Chattanooga, TN 37402-2801 Docket Nos.-
50-327 and 50-328 License Nos.:
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Facility'Name:
Sequoyah 1 and 2
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Inspection Conducted: August 6 - 5, 1987
/# 4/87 Lead Inspector: -)/
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K. Jensioni SenioV Reside g nsp Date S'igned'
Accompanying Personnel:
P. E. Harmon, Resident Inspector i
D. P. Loveless, Resident Inspector W. K. Poertner, R.3sident Inspector i
W. C. Bearden, Resident Inspector W. Branch, Sequ h Restart Coordinator N[z[9")
Approved by:
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,,, m F. R. tECoy,~ Chief, Projects Seg-Ddt/ Sign'ed Division of TVA Projects j
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SUMMARY l
Scope: This routine, announced inspection involved inspection onsite by the Resident Inspectors in the areas of: operational safety verification (including
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operations performance, system lineups, radiation protection, safeguards and i
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 items.
Results:
No violations or deviations were identified.
Two unresolved items were identified:
i 327, 328/87-54-01; Implementation of Commitments, Paragraph 7.
327, 328/87-54-02; Adequacy of Licensee's Seismic Qualification Program, Paragraph 10.
8711190289 871112 PDR ADOCK 05000327 g
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REPORT DETAILS
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Licensee Employees Contacted
H. L. Abercrombie, Site Director j
J. T. La Point, Deputy Sit'e Director J
L. M. Nobles, Plant Manager
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B. M. Willis, Operations and Engineering Superintendent
B. M. Patterson, Maintenance Superintendent i
R. J. Prince, Radiological Control. Superintendent M. R. Harding, Licensing Group Manager i
L. E. Martin, Site Quality Manager D. W. Wilson, Project Engineer R. W. 01 son, Modifications Branch Manager i
J. M. Anthony, Operations Group Supervisor j
R. V. Pierce, Mechanical Maintenance Supervisor i
M. A. Scarzinski, Electrical Maintenance Supervisor j
H. D. Elkins, Instrument Maintenance Group Manager i
R. S. Kaplan, Site Security Manager
.j J. T. Crittenden, Public Safety Service Chief i
R. W. Fortenberry, Technical Support Supervisor
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G. B. Kirk, Compliance Supervisor l
0. C. Craven, Quality Assurance Staff Supervisor j
J. H. Sullivan, Regulatory Engineering Supervisor J. L. Hamilton, Quality Engineering Manager D. L. Cowart, Quality Engineering Supervisor l
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- H.'R. Rogers, Plant Operations Review Staff l
- R. H. Buchholz, Sequoyah Site Representative
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- M. A. Cooper, Compliance Licensing Engineer l
- L. L. Jackson, Assistant to Plant Manager-
- E. K. Sliger, Manager of Projects l
l Other licensee employees contacted included technicians, operators, shift engineers, security force members, engineers and maintenance personnel.
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- Attended exit interview l
2.
Exit Interview The inspection scope and findings were summarized with the Plant Manager and members of his staff on September 4,1987. The-licensee acknowledged the inspection findings and 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 inspection findings.
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Licensee Action on previous Inspection F_indings. (92702)
(Closed) Violation l(VIO) 327,328/86-19-01;. Control' of. Valves? Critical:
to the Operation of Safety Related Systems. This violation was' preceded
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by an Unresolved Item 327,328/85-43-02, ~which was' closed :when L the '
violation was issued.
The-inspector; reviewed ' the licensee'.s response -
(J. Domer/J. Grace) dated August 19, 1986, and NRC' response (G. Zech/L S. White) dated October 23, 1986.
Corrective ~ actions 'for the - above concerns regarding' the. ABGTS and EGTS have been1 accomplished by adding' a.
note to related procedures and all procedures requiring. aivalve' position check ~ for air operated ; valves.
The' note defines the proper 1 actions'
required to ' complete the check for air operated. valves. LThat portion o.f the violation de'aling with the lock'on the -UHI isolation' v'alves:has been j
withdrawn by NRC letter dated October.. 23,1986.
Corrective-actions for:
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the specific air operated' valves cited in' this violation 'were determined :
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by the inspector to be adequate. However, the ' control of valves criticali to the operation of safety related systems is a cur. rent. issue-addressed in inspection report 327, 328/87-52.
The fspecific example cited in' report 327,328/87-52 involved uncontrolled essential raw Lcooling water -valves located on the skid mounted portions of safety related pumps.
This violation is closed.
(Closed) VIO 328/86-19-12; Failure.To' Meet Limiting Condition 'for.
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Operation. (LCO) for 'the Hydrogen Analyzer. ' The ' inspector reviewed the l
licensee's response (J. Domer/J. Grace) dated August 19,21986 ~ and 1 NRC.
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response (G. Zech/ S. White) dated October 23, 1986t The LNRC i response
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stated that " corrective actions for - violation.. 86-19-06-have been--
l determined to be appropriate for violation 86-19-12;as well. Therefore, L
no further response regarding this ' matter is required." Current ii s' sue s-I with respect to the : operability of the. hydrogen ' analyzer l aref being '
addressed in inspection report 327,328/87-60.- This item is closed.
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(Closed) VID 327,328/86-42-01; Failure to Reconfigure.10 CFR;50.49 Valves.
This violation addressed the fact that work plan :11806 did ' not give adequate instructions for craf t personnel. to reconfigure 110 CFR.50.49 -
ASCO solenoid valves for proper installation.
The -inspector reviewed the licensee's. responses (Gridley/ NRC Document Control'. Desk) dated ~
October 24, 1986 and April 6,1987. The inspecto'r also reviewed' the NRC responses (Zech/ White) dated. February 26, 1987 and July' 22,11987. -In' the
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final NRC response it was concluded that the reason for denial of~ example-2 of the violation by TVA was valid based on new information presented by'
the licensee and Franklin Research Center. Therefore example 2 of the violation was withdrawn.
Example 1 of th'e violation was admitted.by'the licensee and the corrective actions appear to have ' been' adequately implemented.
This item is closed.
(Closed)
VIO 327,328/86-11-04; Inadequacies in. Development < and Implementation of Maintenance! Instruction' MI-10.9 and, Surveillance Instruction SI-227.1.
Deficiencies related, to MI-10.9. included:
(1) performing fewer undervoltage trip tests ~than recommended by ' a
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Westinghouse Bulletin; (2) poor quality drawings,LnumerousLtypographical
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errors, and lack of tracking undervoltage trip actuation (UVTA) cycles to justify maintenance / replacement schedules; and (3) inadequate maintenance history specific to individual breakers. The inspector reviewed the new-TVA MI for breaker inspection and test (MI-10.9.1, Revision 3), TVA's response to the Notice of Violation, and related correspondence The discrepancies identified in the earlier procedure have been corrected or justified by TVA.
Deficiencies related to SI-227.1 were procedural inadequacies and improper testing conduct by instrument mechanics. The
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inspector reviewed TVA's Revision 3 to SI-227.1 and found it to be an extensive revision which provides more detail and clearer instructions.
Responsible personnel have been reinstructed concerning proper test preparation and scheduling.
This item is therefore closed.
(Closed) VIO 327,328/86-59-01; Failure to Meet Test Frequency Requirements for Testing Category A and B Valves.
This violation resulted from TVA's failure to meet the stroke time test frequencies of ASME Section XI valve and pump testing program (with Technical Specification extension tolerance) for valves required to be operable during cold shutdown. TVA determined the cause of this violation was inadequate procedures that:
(1) required the initiation of surveillance test " packages", not testing of individual valves, within the time allowed, and (2) did not identify j
the valves that required continued testing during Mode 5.
TVA has issued j
an LER on this issue which identified 18 additional valves that had not
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met the required test frequency.
TVA revised valve stroke time test surveillance instructions to provide separate instructions for testing valves required to be operable during Mode 5 and included steps that required the individual tests involved to be completed within the required time limits. The inspector reviewed both the new and revised procedures, and examined the valve test summary documentation for 20 valves selected at random from the 91 specified as required to be operable for Mode 5.
l Each valve had been tested within the time limits or had appropriate
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documentation of tagout, repair, etc. when. schedules were not met.
The procedure changes made should facilitate avoidance of future violations.
The inspector also reviewed check valve operation test records for l
sis-166.15, 166,19 and 166.26 performed from 1983 to the present to verify
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that test frequency requirements had been met.
No discrepancies were noted.
This item is therefore closed.
(Closed) VIO 327,328/86-46-08; No Preventive Maintenance Program per TS 6.8.5.
This violation was identified as failure to incorporate preventive maintenance (PM) into the Sequoyah program for reducing leakage from systems outside containment that could contain highly radioactive fluids, as required by TS.TVA corrective actions included a review of past leakage data and generation of F# tasks where necessary. Only the Unit 2 review has been completed to date.
Additional actions committed to were j
l revision of applicable inspection program instructions to ensure that
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l results are input to the site maintenance trending program and a review of vendor technical manuals for leak reduction recommendations that need to be included in site procedures.
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.1 The inspector examined the report of TVA's past leakage data review for Unit 2 and the six resulting PM tasks and discussed this activity with the
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responsible maintenance engineer.
Revisions to the SI-632 series
.f instruction that specify inclusion of. inspection results in the trending program were reviewed and the trending process was discussed with the responsible test and trending engineers.
The inspector noted that-SI-632.0 repeatedly refers to totaling, summarizing and trending of valve i
leaks when, in fact, the inspections also involve a large number of pumps, flanged joints, instruments, etc., which are reflected on the data sheet
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listings.
However, from discussions with responsible personnel, " valves" is being interpreted as " items" or " equipment" for summary or trending purposes.
Performance of the review of past leakage data on Unit 1 prior to restart is being tracked by TVA as commitment tracking item NC0-86-0461-010.
Performance of the technical manual review is being tracked by TVA as item.
NCO-86-0461-011.
TVA's actions adequately address this violation.
This item is therefore closed.
(Closed) VIO 327,328/87-08-03; Failure to Perform an Adequate Fri sk.
i During an auxiliary building tour the inspectors observed approximately ~
l six workers exit the radiologically controlled area (RCA) without properly j
frisking. The workers were performing tasks in the auxiliary building while wearing heavy work gloves.
They removed their gloves' at the frisking station, frisked their hands and then put their gloves back on.
The gloves were not frisked prior to leaving the area.
Sequoyah Radiological Control Instruction (RCI) -1 was revised June 11, 1987, to include specific guidance regarding proper frisking of personal effects, including work gloves, when exiting RCAs.
The inspector reviewed the
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Radiation Worker II training lesson plan and found the guidance provided
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for f ri sking to be adequate.
Attendance records were reviewed and
indicate that the licensee is aggressively pursuing the Radiation' Worker l
II training program.
VIO 327,328/87-08-03 is closed.
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(Closed) VIO 328/87-28-01; Hanger Design Loads Exceeded Snubber Capacity.
l Undersized snubbers had been installed in four safety-related pipe hangers.
This condition resulted from the use of inadequate design drawings for these hangers.
This problem was identified to the licensee as unresolved item 328/86-24-02, which was closed and ' upgraded to a Violation 328/87-28-01.
Inspection report 327,328/87-28 stated that Field Change Request (FCR) 4644 was written to modify the hanger sketches for the subject snubbers and that new snubbers.had been verified to be installed as required by the revised sketches.
In addition'to the above corrective action the licensee has incorporated a requirement into MI-6.13A, Removal and Reinstallation of Hydraulic.and Mechanical Snubbers, which requires a quality. control inspector to verify the reinstalled snubber is sized as specified by the detail drawing and that capacity is adequate for the design load shown on the drawing. Violation 328/87-28-01 is close.
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(Closed) Violation - -327,328/86-43-01;. Failure to Perform Adequate' Post:
Modification Testing. The licensee's response. to the Notice of Violation
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dated October 31, 1986 (RIM L44 8610310805), committed.to i review? thel-adequacies of past post modification testing as ' part of. the L Design Baseline and Verification P.rogram (DBVP). The results:of'thislr'v'iew were-e evaluated as part of ;the specialitest inspection' conducted March 16-27: and April ' 13-17, 1987, and documented in, IR.'327,328/87-18. : That inspection.-
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determined that the licensee's review was thorough and; properly focused.
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This item'is closed.
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(Closed). Unresolved Item (URI) '327,328/87-43-01;. Testing lof-Containment Spray Pump Discharge Valve Interlock.
As previously. stated ~in.IR 327,,
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328/87-43, the inspector identified. a l condition wher'e the interlock between the Containment Spray Pump. and Lits discharge valve was not being >
periodically tested during. the 18 month surveillance ' test.
Surveillance l-Instruction (SI) -68, which satisfies. the surveillance requirements for the' valves in this system, did test: the discharge valves < for operation but the. pump-running ' interlock was" bypassed 'during this test. ; After the inspector identified this item, a discussion was ; held and the' licensee -
committed to changing the SI to test this interlock. The inspector
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reviewed revision 4 to SI-68 which incorporated this interlock test las
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part of the 18 month surveillance test.
I The intent of the-TS surveillance was to verify power was'available to.the valve'through the pump running contact, as well as verifying the operation-of. 'the reactor protection containment high-high ' pressure signal. The revision to SI-68 should verify proper ; valve operation. This item is
closed.
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i (Closed) URI 327,328/86-60-09;. Unlocked High Radiation ? Storage Area.
Inspection Report 327,328/87-03 discussed this item. under ' the review: of LER 86-052.
In the inspection report the item was. determined - to be-Licensee Identified Item 50-327/87-03-01 and. 50-328/87-03-01.
LURI 86-60-09 is therefore closed.
(Closed) URI 327,328/87-30-11; Diesel Generator Air Tank Pressure.
Information from licensee personn'el indicates.that, although paragraph.
4.2.6 of SI-166.36, Rev. 5 requires verification-that tank pressure.is
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recovering after the air. start test,.this. action, in - fact, is: only required to be performed during testing of 'the air supply check valves, which occurs during time frame B testing. As the witnessed portion of i
this SI entailed only time frame A testing, verification of tank pressure
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recovery was not required.
Subsequently, SI-166.36 Rev. 6 (6-4-87) has
.j been issued to more clearly identify the required actions and verifi-i
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cations to be performed during each time' frame.
This item' is closed.
(Closed) URI U-2.1-1 (Report 327,328/86-68); Environmental Qualification L
(EQ) of ASCO Model 8316 Valves.
This item related to whether TVAL had.-
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evaluated the concerns detailed in NRC Information Notice (IN) 84-23 with regard.to ASCO Model 831654E solenoid ' valves purchased. in 1985. and-j installed'at Sequoyah. The inspector reviewed the information contained, q
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in the Sequoyah EQ Binder for' this.modell ASCO valve.
The - EQ Binder
included 'an evaluation of..IN; 84-23,- which: concluded that sthe-purchased!
l valves were qualified because. an ear. lier ASCO report had' qualified.similar j
valves under conditions thatcenveloped TVA ' site - specific i environment'1;
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conditions.
The inspector reviewed the : remainder of ; the-EQ ' Binder
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information and determined that the TVA disposition. was Ladequate.
This-item is' closed.
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(Closed)'URI U-2il-2 (Report 327,328/86-68);- No Erigineering Justification-
Documentation Provided for' Upgrading BournsLTrimpot; Resistor from.QA; j
Level III to QA. Level II. TVA -has. located ' and provided 'a copy of the.
c AI-11, : Attachment 10, QALLevel Assignment Change Documenti for ' upgrading j
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.this resistor. This component met.the requirements 1for classification as -
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QA Level II as detailed in SQA 45
- This unresolved itemLis closed.
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H (Closed) VIO 86-56-A;. A Nonconformance' at LSequoyah Was Identified.Through
.q Followup of Watts' Bar NCR WBNSWP8265- (Ref.1-4). ' After ~a= site review.by:
q TVA in March 1984 (Ref. 1-23) at Sequoyah, it was determined that Class 1E
electrical components in the 'auxi.11ary,' control, and = diesel generator
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buildings are susceptible 'to potential water spray 1 from 'nonseismically qualified piping.
This was evaluated ' by TVA and found' as not' conforming.
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to the intent of NRC Regulatory Guide 1.29,
" Seismic Design
Classification," Revis;on 3, : September 1978 '_(Refi 1-18.
Thejlicensee's-j corrective actions ' included. identification of piping hazards in those
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areas susceptible to potential water spray from:nonseismically' qualified i
i:l piping.' Piping modifications to insure pressure boundary: integrity or by sealing / shielding the IE electrical equipment against: water spray have i
been completed in the-identified areas; LER 87-020 dated April' 16,E 1987 I
was prepared to document the above event. and to describe 1the corrective action. Al'1 required work for Unit 2 ris, reported: complete-per ECNLL6770 on the Corporate Commitment. Tracking System (CCTS)- asfof July 7,1987,.
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Work plans WP12231 and WP12243~,: currently in: Drawing. Control for drawing s
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revisions, were reviewed and appearL to ; adequately' document 1 the. work
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accomplished. This. item is closed.
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URI U-2.1-4 (Report 327,328/86-68);
Seismic. Qualification Information for Valves 2-3-610 and. 2-3-611 Could 'Not Be Located. :The purchase order indicated that' the valves were non-seismic..However, the-
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valves are installed in locations requiring seismic qualifications. - The.
inspectors reviewed the purchaseDrequisition (Interproject TransferL0rder
No. MM-N2-567) which transferred the-va1ves from the Be11efontejproject to i
Sequoyah.
This requisition' states:
" Seismic qualification' performed by:
TVA (reference CEB83051252)".
CEB 830512252 1s a: memorandum prepared by
Civil Engineering Support Branch -(CEB) that states' thei subject;valvelis :
j seismic accepted for SQN application since the valve.' pressure -capability.-
or rating exceeds the SQN requirement, ie., 1085 psi de' sign. pressure... TVA Design Specification SQN-DS-1940-5566 for Equipment ' Isolation' Valve ECN L-5024 states that the valves used were seismically qualified 'per Seismic-Criteria Doc. No. ' WB-DC-40-31.12.
Based on the ' above s findings : URI'
U-2.1-4.is closed.
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I (Closed) Deviation (DEV) 327,328/3 H 8-17; Deviation From a License Commitment to Use the Power OperatiORelief Valves as High Point Vents.
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This is the last remaining open Aue for TMI Action Flan / Commitment
II.B.1, : Reactor Coolant System Vent 6 The inspecterfrMiewed the
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licensee's responses (Gridley/Graie) dated July 15, 1986 Md. (Gridley/
f Youngblood) dated August: 38,,1986. The latter response Tcated that the
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Sequoyah nuclear plant had, adopted procedwes. based on the V6stinghouse l
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Owners Group Function Restoration Guidelines. These guideline recommen--
s tien.5 have been included in Sequoyah Procedure FRG L3, response to voidy in reactor vessel.
Therefore, this iter and 'iPI. Action, Plan Comf tment
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11.B.1 are closed.
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(Open) DEV 327,328/86-11-05; faDure tb / Establish a Formalized Trending Program for Reactor Trip Breated. _As 'of February 1986 TVA had not yet met a November 1983 commitment ;to ' develop a program for trending. of
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parameters to iden ti fy degradation of reactor trip breakers.
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programmatic aspects of this deviation have been addressed by TVA
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implementing a corporate commitment, tracking system. With regard to the i
specific deviation, TVA has issued an extensive revision to the reactor trip breaker MI that provides much greater detail for recording and
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evaluating important parameters. The pdeventive maintenance (PM) program j
provides for compilation of, breaker testresults from M1-10.9.1 into PM 836-099 and PM 1617-099. However, three concerns remain to be resolved by TVA.
Naither MI-10.9.1, nor the PM program require a signature attesting to the. review and acceptance of trended data.
The FM progrart, does not pfWde any evaluation guidance or acceptance criteria for 'the' trended parameters.
Section 6.10 of MI-10.0 1 and,the PM program only evaluate / trend the breaker dropout voit' ge a fter Lubrication, i.e., the a
as-lef t condition, not ' the a s-found condi t; ion. ! Trending of the as-found condition is critical to joentOy; degradation of the equipment, lubricant, etc.
Pending resolJti[n of drey concerns this item remains ocen.
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(Ciosed) ~ DEVD 3F,3M/S7-0E-0]; Depfation frcin FSAR Coditsne.s on CDWE J
Ma i n t e n a'n'ce.
Section 11.2.4 of thi l'inal Safety Evaluation Report (FSAR)
states that "All equipmmik installed to reduce radioactive effluents to the minimum practicable lehl is maintained in good operating order...In l
order to ensure that thet,e donditione are met, administrative controls are exercised on overall operajir.;n of the systet; preventive maintenanc6 is utilized to maintain equipmert in peak condition; and experience 7.vailable from similar plants is used in planning for operation at Sequoyah' tiuclear plant." The inspector was not able to ident'#y any routine preventive ma i.' t e n <c.n c e performed on the CDWE system a..J there is no objective evidence thet industry expe,rience is used in planning for operation of the CDWE.
The licansee is cut!reatly reviewing changes to the FSAR and as of August ;9E
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on requiru r;.
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.. of the current FSAR changes proposed by the i]
licensee is te alin.inate the requirement for vendor recommended preventive maintenance in thi, section of the FSAR. A review of the PM program for l
the CDWE system was conducted to determine that prescribed maintenance was j
conducted.
The PM histury for system 77 (Waste Disposal) indicates that j
the prescribed procedurer,.were accomplished f rom about March 1985 to j
April 1987 (end of history reviewed). The inspector spot checked several j
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of the data sheets' associated with the maintenance programLand-determined
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that the data adequately supports the PM history for' system 77. ' A change to the FSAR has been prepared for ~ inclusion. in-the April 1988 FSAR revi-:
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sion11n ' order to address the.new PM program requirements. The proposed
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change-was reviewed and appears adequate.
This item is closed.
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l (Closed) VIO 3D,328/89 68-06.'c;. Acceptance During ' Receipt Inspection.
This violation identified a number of cases in which items not meeting'the purchase order specifications had been signed-off as ' accept'able during receipt inspections Example.(c)
identified 3 problems:
missing
I documentation for impact test results:for a 5-inch round Lstainless steel
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bar, missing hardness values for a.31;'2-inch bar, and missing bend test
results for a 1-inch carbon steel plate.
The TVA July 16,.1987 response to the violation stated 'that TVA would perform an end-use. evaluation on.the 5 inch bar stock by August.14,l1987..
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'The non-conformance and end-use evaluation was reviewed and~is' documented
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on CAQR SOP 871080.
Licensee action' on this item appears adequate.
The TVA respon'se. stated that the 3 1/2" bar' stock had not been used in the-plant and would be scraped if the material qualification could. not be obtained. The non-conformance is documented on CAQR SQP 871079. Licensee action on this item appears satisfactory.
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The TVA response stated that the Certificate of Tests for the material j
(heat No. 7437245) was procured under Request for De' livery - (RO). No.
901513. Licensee action on this item appears satisfactory. This item is closed.
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i (Closed) VIO 327,328/86-68-07.b; Safety System Outage Modification Report.
l WP 11174 required System Operating Instructions -S01-68, 50I-2, 501-3, and'
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S01-55 to be revised as a result of this modification. Signatures on page
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I-6 of each instruction certified-that the instruction-was revised on i
April 25, 1985.. The plant instruction revision logs ~ for SOI-68, S0I-2,
S01-3, and S0I-55 indicated ' that no change-had, been made to the
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instructions between February and July of 1985.
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The TVA response to the violation stated a' verification 'that S0I. changes.
identified in WP 11174 have been properly incorporated into the procedures-
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will be completed by July 31, 1987; Revisions to S0Is required' as a
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result of WP 11174 was verified on July 17, 1987 and documented on SQA135
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Attachment B, Commitment / Action : Item Completion' and Verification Form.
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Licensee action on this item appears adequate. This item is closed.
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Operational Safety Verification-(71707)-
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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
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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 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
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buildings, and containment were conducted to observe plant equipment conditions, including potential fire hazards, fluid leaks, and excessive. vibrations and plant housekeeping / cleanliness conditions.
The inspectors reviewed design documentation for four polar crane-wall (PCW) penetrations on. Unit 2.
This review involved an as-constructed walkdown of penetration numbers 217, 276, 322 and 379.
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These penetrations.are all part of the containment sump boundary and are representative of.the four types of sleeves. The following items were noted by the inspector:
(1) Penetration # 276 appears.to be a type III penetration. Drawing 478473-3 shows it as a Type I.
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(2) A portion of the G. E. RTV (white) is cut on sleeve #278 outside PCW, and appears to be too thin or filled with RTV foam (black).
(3) Sleeve #379 steel plate is welded outside PCW.
The drawing shows the plate inside PCW.
(4) Sleeve #217 is brown and appears to be installed differently inside PCW than it is outside PCW.
(5) Sleeve #322 has paint / caulk inside PCW and inner link seal appears damaged.
(6) Sleeve #322 has a 2" washer sitting inside on outer PCW.
The inspector is currently reviewing licensee corrective action, 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 irluding protected and vital area access controls; searching of personnel and packages; escorting of visitors; patrols and compensatory posts; and badge issuance and retrieval.
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 j
maintenance.
Specifically, the Resident Inspectors observed l
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emergency drills, 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 j
The inspectors observed health physics (HP) practices and verified implementation of radiation protection control. On a regular basis, l
radiation work permits (RWPs) were reviewed and specific work I
activities were monitored to ensure the activities were being I
conducted in accordance with applicable RWPs.
Selected radiation l
protection instruments were verified operable and calibration l
frequencies were reviewed.
No violations or deviations were identified.
'I 5.
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 individuals.
a.
On August 28, 1987, the inspector observed portions of SI-83.2, Channel Calibration for Radiation Monitoring System, in progress.
The work involved calibration of Containment Purge Air Exhaust Radiation Monitor 2-RM-90-131, and met the criteria. of TS 4.3.2.1.1.
and 4. 3. 3.1.
The SI was allowed by. extension to be performed on or before May 15, 1987.
Although overdue, this calibration is not required by TS during this mode. The technicians were following the procedure and appeared to be knowledgeable of their function.
The inspector had no further questions, b.
The inspector witnessed a portion of SI-158.1, Containment Isolation Valve Leak Rate Test. The inspector noted that the valve alignment requirements did not include vent or drain valves within the test boundary and that the surveillance instruction did not provide I
instructions for draining the test. boundary.
The inspector I
considered that these items would enhance the performance of the I
instruction but that the procedure was adequate to perform the leak rate test observed. The inspector noted no discrepancies during the performance of the surveillance.
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6.
Monthly Maintenance Observations (62703)
Station maintenance activities of safety-related systems and components I
were observed / reviewed to ascertain that they were conducted in accordance I
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
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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 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
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properly certified; radiological controls were implemented; QC hold j
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points were established where required and were observed; fire prevention controls were implemented; outside contractor force activities were controlled in accordance with the approved Quality Assurance (QA) program; and housekeeping was actively pursued.
a.
The inspector observed a portion of the work activities associated with work request (WR) 8221846. The purpose of the WR was to inspect I
the motor shaft key of valve 63-94 for signs of cracking or deformation.
The inspector noted no discrepancies with the portion of the work observed.
b.
The inspector observed the performance of WR 295688, Reinstallation of Vital Battery Room I Ventilation Low Flow Alarm Switch.
This switch had previously been found with loose mounting bolts during a system walkdown by licensee personnel.
Mounting studs were found broken when the switch assembly was removed for inspection.
The broken studs were repaired and the switch was installed..The calibration was checked and found in specification. No discrepancies were observed.
No violations or deviations were identified.
7.
Licensee Event Repcrt (LER) Followup (92700)
The following LERs were reviewed and closed. The inspector verified that:
reporting requirements had been met; causes had been identified; corrective actions appeared appropriate; generic applicability had been considered; the LER forms were complete; the licensee had reviewed the event; no unreviewed safety questions were involved; and no violations of regulations or TS conditions had been identified.
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l LERs Unit 1 l
LER 86-052; Personnel Errors Resulting in Failure to Maintain Administrative Control of a High Radiation Area. This LER was reviewed by
NRC Region II personnel in inspection report 87-03 and licensee actions
!
were determined to be acceptable. The findings are discussed in paragraph 3 above in the review of URI 86-60-09.
This LER is closed.
LER 86-053, revision 1; Failure to Comply with the Action Statement for j
Limiting Condition for Operation on the Auxiliary Building Vent Radia-l tion Monitor. After the auxiliary building vent radiation monitor was
'
declared inoperable the licensee installed a backup temporary sampler.
Approximately eleven days after installation of the backup temporary
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sampler the licensee discovered that the flow rate of the backup sampler -
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was not being estimated every four hours.
The root cause.of this event i
was the cancellation of SI-470.5, Auxiliary Building Iodine Sampler Flow j
Estimation, which was used to comply with TS.
SI-470.5 was cancelled i
under the mistaken assumption that the TS surveillance requirements were met by a second procedure.
The inspector reviewed' the licensee's corrective actions, which included reinstating SI-470.5, and considers this LER to be closed.
However, it was noted during the review of the LER (dated December 10, 1986) that the licensee committed to have SI-470.5 completely reinstated I
by December 21, 1986. This Action was not completed until December 24, 1986. As a result, the Corporate Commitment Tracking System (CCTS) was also reviewed by the inspector. It was determined that the entry into the CCTS (S10 870220 823) indicated that this particular commitment had not been met.
No indication of management action was identified by the inspector. A discussion was held with the site Manager of Licensing to determine if other licensee commitments were outstanding and had not been met A review of the CCTS August 20, 1987 status package indicated that i
i five licensee CCTS commitments were not met and no formal written relief had been granted by the NRC or requested by the licensee. They were as i
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follows:
A commitment to review, update or regenerate the essential
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calculations required to support restart of Sequoyah Unit 2 by April 1, 1987; submitted in TVA letter L44 870227 812.
A commitment to include the completed water hammer analysis of the containment spray system as an appendix in the containment spray system calculation package by July 1987; submitted in TVA letter L44 870702 800.
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A commitment to determine the sequence of weld identification
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deletion from ERCW-4 and ERCW-5 by July 31, 1987; submitted in TVA-
letter L44 870709 809.
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A commitment to conduct an engineering evaluation and disposition of j
certain valve gaskets by August 3, 1987; submitted in TVA letter L44
870709 809.
A commitment to complete a change to drawing 47W809-5. before
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August 7, 1987; submitted in TVA. letter L44 870724 800.
The implementation of commitments was discussed with the licensee on
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September 3,1987 (DSP Sequoyah Section Chief, TVA Deputy Site Director, and Senior Resident Inspector).
During this mneting the licensee described corrective actions that were put in place as' a result of a previous meeting between the Senior Resident Inspector and the Deputy Site Director.
The implementation of commitments is unresolved item - 327, 328/87-54-01 pending review of implementation of corrective actions.
LER 86-059, revision 1; TS Fire Barrier Penetrations Not Vr. "f ed to be Functional.
This LER addressed inadequate surveillance
- truction SI-233.3, Visual Inspection of Penetration Fire Barriers - Fire Dampers.
The inspector verified that the ten fire dampers that were omitted from the SI were added in the most recent revision (dated April 10, 1987).
Corrective actions appear to be adequate.
However, the root cause determination of the LER is not accurate. The LER states that "the cause of these conditions is determined to be a personnel error in that these
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ten TS fire dampers were omitted during initial preparation of the SI.
This issue of root cause analysis was discussed with Sequoyah plant management which is reviewing Plant Operations Review Staff activities in this area. The resident inspector staff is reviewing the licensee's root cause analysis as a separate inspection activity and as addressed in NRC Inspection Reports 50-327,328/87-50.
This LER is closed.
LER 87-005; Inadvertent Reactor Trip Breaker Opening. This issue involved a performance of SI-227.1, Post Maintenance Response Time _ Test of Reactor Trip Breakers RTA and RTB. An instrument technician rotated the logic A test switch for the solid state protection ' system (SSPS) in the wrong direction.
As a result of rotating the iogic A test switch in the wrong direction the permissive P-7 block was defeated which allowed the "at power" trip signals to trip the reactor trip breaker.
The inspector reviewed the licensee's corrective action which appeared to be adequate.
This LER is closed.
8.
IE Bulletins (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 bulletins. 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 occur.
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.l (0 pen) IEB 85-03; Motor-0perated Valve Common Mode Failures During Plant Transients Due to Improper Switch Settings.
The inspector reviewed'the licensee's actions taken to date, as documented in the below listed references, and considers them adequate to meet the requirements of the bulletin. However, a number of actions are yet to be performed prior. to-
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final closure of this bulletin. These actions, and their implementation
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dates,.are as follows:
- Differential pressure testing of two turbine-driven auxiliary
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feedwater (TDAFW) pump turbine steam supply valves. (During Unit 2 i
restart testing of TOAFW pump.)
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- 47A940 series drawings are to be issued to control torque switch q
set points for 21 MOVs listed in the licensee's initial response.
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(By Unit 2 restart, but not later than 11-15-87.)
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- Revise plant procedures to incorporate the requirement's contained i
in the above 47A940 series of drawings. (By Unit 2 restart, but '
not later than 11-15-87.)
- Issue final report to NRC. (Sixty days after completion of above items.)
i References:
- NRC IEB 85-03, 11-15-85
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- TVA Letter from Shell to Grace, 5-12-86 (L44 860512 803)
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- TVA Letter from Gridley to Grace, 9-11-86 (L44 860911800)
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- TVA Letter from Gridley to Grace, 10-31-86 (L44 861031 810)
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- TVA Memo from Skarzinski to Kirk, 11-28-86 (S10 861208 898)
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- TVA Memo from Wilson to Kirk, 9-17-86 (B25 860917 048)
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- TVA Memo from Wilson to Abercrombie, 10-27-86 (B25 861027 004)
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- Safety Evaluation of BIT Valve Testing, 3-17-87 (S10 870327 842)
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9.
Inspector Followup Items
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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 j
review and evaluation by the inspector.
The following IFIs have been i
reviewed and evaluated by the inspector.
The inspector has either
resolved the concern identified, determined that the licensee has performed adequately in the area, and/or determined that actions taken by the licensee have resolved the concern.
(Closed) IFI 327,328/86-60-03; Class A.and B Piping Traceability. The
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inspector discussed this issue with the site team leader in charge of inspection 327,328/87-44 and determined that his inspection covered the traceability issue and the TVA employee concern element. report. This item is closed and the above issues will be resolved as a part of inspection report 327,328/87-44.
(Closed) IFI 327,328/86-71-01; HP Organization and Standing RWP.
The resident inspectors questioned the adequacy of the new HP organization and the ALARA program.
The programs were reviewed for adequacy by region based inspectors and documented in inspection report 327,328/87-03.
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Subsequent to this inspection the resident inspectors have reviewed the -
implementation of this program. The inspectors have no further questions.
This item is closed.
(Closed) IFI 327,328/86-28-04; Operational Configuration Control.
This
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issue addressed the use and uniform application. of the control room I
configuration log in maintenance and operations activities.
This issue was addressed in enforcement / inspection activities 'and will be followed under violation 327,328/87-30-01. This item is closed.
(Closed) IFI 327,328/86-37-08; HP Training and Practices.
Training practices and programs were reviewed by the resident inspectors in the areas mentioned in inspection report 86-37.. In addition, regional based inspectors made - additional observations and interviews during their Inspection 327,328/87-56.
With respect to these two inspection-activities no further deficiencies were noted' with HP training and practices as related to this item.
This item is closed.
(Closed) IFI 327,328/86-37-01; Drawing Discrepancies. The inspector noted several minor drawing discrepancies in drawings 47W811-2,(Unit 2) and j
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47W811-1 (Unit 1) on the Safety Injection System and the Upper Head
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Injection System.
These deficiencies were reviewed by the licensee and corrected.
This item is closed.
(Closed) IFI 327,328/85-35-02, Review of Negative Rate Trip.
The inspector reviewed the licensee's TS change submittal of October 22, 1985, and determined that the appropriate change was included.
This item is closed.
(0 pen) IFI 327,328/86-31-04, Review of an Inadvertent Control Room Isolation Following Completion of Licensee Investigation.
This IFI was
opened to track the licensee's program to resolve problems associated with l
Electromagnetic Interference (EMI) generated voltage spikes which activate
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Engineered Safety Features (ESF) when. radiation monitors trip due to EMI spikes. LER 328/86-002 describes one such event but. listed the. root cause as a personnel error in that an inadequate instruction did not caution the technician against decreasing the air flow to the monitor being tested to
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the low flow alarm point.
The LER did not identify previous events
associated with EMI spikes when the detectors' alarm circuits are activated. Instead, the LER stated that-this was the first occurrence of a Control Room Ventilation Isolation (CVI) caused by testing of the control air check valves. Two days later, another CVI' occurred and was i
properij described in LER 327/86-022 as caused by an EMI, and that there
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were 24 previous occurrences caused by EMI spikes.
This LER. detailed
planned ' corrective actions to initiate a design change request (DCR) to add capacitors to the alarm circuits of the radiation monitor circuits to suppress and filter the induced EMI spikes. This IFI remains pending NRC review of corrective action implementation.
(Closed) IFI 327,328/86-20-02; Plant Walkdowns of E0Is. The documentation of a plant walkthrough for procedure / hardware compatibility, committed to in the Procedures Generation Package, was not available at the time of the 1986 inspection. _ TVA draf ted a walkdown instruction and an 'SRO conducted
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the walkdown in March 1986.
This inspector reviewed the walkdown documentation, discussed the written remarks made by the walkdown SR0 and reviewed plant E0Is.
Although the walkdown - procedure and documentation was very informal, pertinent steps of E01s had been addressed and instruc-j tions had been upgraded as a result of the SRO's comments.
Additionally'
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inspection module-T/I-2515/79 is currently being accomplished by NRC. team
inspection to assess the adequacy of E0Is.
This item is therefore closed.
j (Closed) IFI 327,328/86-19-09; Review of Generic Sig'nificant Condition-Reports (SCRs).
During a review of the licensee's disposition of SCRs related to the EDGs, ar apparent programmatic' problem was identified. The Office of Engineering (OE) reviewer' of an SCR from the Browns Ferry plant.
made what appears to be an incorrect determination of nonapplicablity on a questionable interpretation of the ~ term " generic" A review of the licensee revised program was conducted to determine if the revised program l
adequately adoi;rsed the above programmatic concern. The revised program, Administrative Instruction (AI) -12, Part I was implemented at Sequoyah, February 23, 1987.
'Section 10.0 of AI-12, Part 1 provides for-determination of generic implications and_ details the procedure review / determination process. AI-12, Part 1 adequately address the above inspector concern.
This item is closed.
(Closed) IFI 328/86-62-10; Need to Establish 30 Minute Activation Requirement for H2 Analyzer. As previously stated in IR 327, 328/86-62, the licensee had indicated that the task analysis for the use_of Emergency Operating Procedures (EOP) has verified that current procedures would
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drive the operator to activate the Hz analyzer system within 30 minutes l
following a true Safety Injection (SI). Subsequent to the. -initial i
inspection TVA provided the inspector additional information from the TVA I
Style Writer's Guide which was. established to implement the Westinghouse Owners Group (WOG) E0Ps.
Thic writer's guide cautions against using specific times to initiate operator actions and indicates that operator l
actions should be related primarily to plant parameters. Additionally, the
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licensee has determined that E0P steps which require Emergency Core Cooling Systems (ECCS) be swapped over to the containment sump, which is a time monitored action, are preceeded by the requirement to activate the H2 analyzer system. The inspector has monitored the use of the procedures at the simulator and during exercises and agrees that if the procedures are properly followed there is reasonable assurance that the H2 -analyzer system will be activated within 30 minutes following a true SI. This item is closed.
(0 pen) IFI 50-327,328/86-11-01; Followup of the Licensee's. Response to NRR for Post Trip Review. TVA's licensing staff stated that TVA is preparing a response to address NRC concerns which resulted from a review of TVA's
response to the Technical Evaluation Report on generic letter 83-28-action. NRC concerns were discussed with TVA during a July 9,1986, tele-l con (NRC/J. Holonich - TVA/M. Burzynski).
TVA's licensing staff stated the response would be submitted by August 31, 1987.
This-item is not a startup item and will remain open pending NRC review of TVA's submission.
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10.
Surveillance Instruction Program (61700, 61726)
l Inspection 327, 328/87-36 was conducted to determine the adequacy of the.
SI review program implementation. In a continuing review of the licensee's surveillance instruction review program the inspectors reviewed the following LERs and URI:
(Closed) LER 327/87-014; Baron Injection Tank (BIT) Heaters Not' Verified
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Operable Every 31 Days.
As a result of the licensee's surveillance instruction review process it was determined that SI-16, BIT Heat Tracing, s
was not fully implementing TSs in that the redundant. tank heaters were not verified operable every 31 days by energizing each heat tracing channel.
The inspector reviewed the licensee's corrective action and determined i
that it was adequate.
This LER is closed.
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(Closed) LER 327/87-017; Failure to Meet Minimum' Boron Concentrations due'
to Analytical Technique. 'As a result of the licensee's surveillance l
instruction review process it was determined that SI-51, Weekly Chemistry i
Requirements, had errors in its supporting Technical Instructions (TI)
which calculated boron concentrations based on the volume of the solution as opposed to the weight of the solution. The inspector reviewed the J
licensee's corrective action and determined that it was adequate This LER is closed.
(Closed) LER 327/87-008; ERCW surveillance requirement not met. As a result of the licensee's surveillance instruction review process it was determined that SI-33, ERCW Valves Servicing Safety Related Equipment, did not completely comply with TS surveillance requirement 4.7.4.a.
The inspector reviewed the licensee's corrective action and determined that it was adequate. This LER is closed.
(Closed) LER 327/87-009; Ice Condenser PH Surveillance Requirement not i
Met.
As a result of the licensee's surveillance instruction review process it was determined that Technical Instruction TI-11, Chemical
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Analytical Methods did not ensure compliance with TS surveillance requirement 4.6.5.1.b.1.
The inspector reviewed the licensee's corrective action and determined that it was adequate. This LER is closed.
(Closed) LER 327/87-031; Emergency Gas Treatment System Bypass Flow. As a result of the licensee's surveillance instruction review process it was determined that 51-142, Emergency Gas Treatment System, Filter Train Test, and TI-9, Test Methods for Nuclear Air Cleaning System, did'not ensure compliance with TS 3.6.1.8.
The inspector reviewed the licensee's corrective action and determired that it was adequate.
This. LER is closed.
(0 pen) URI 327,328/87-36-02; Surveillance Program Inspection Technical Questions. The inspector reviewed the licensee response associated with SI-166.40.
The licensee has received confirmation from Target Rock Corporation that the valve should open in less than or. equal to two seconds at any pressure from zero to 2500 psig.
This portion of the
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unresolved item-is considered closed.
URI 327,328/87-36-02 will remain open pending review of the licensee's response to the other two technical questions identified in URI 327,328/87-36-02.
In addition, one other issue was identified. with the adequacy of surveillance instruction SI-275.1, Inspection of Non Class.1E Load Circuit Breakers Fed From Class 1E Busses.
It was determined that certain SI-1 appendix F, attachment II administrative items existed which did not appear to affect the-technical adequacy of the surveillance.
The issues were addressed in the change form for revision 13 (draft). However, there did appear to be a significant issue with respect'to the maintenance of seismic qualification of components which are disassembled. The adequacy of the licensee's seismic qualification program is unresolved item URI 327,328/87-54-02.
11.
Condensate Demineralized Waste Evaporator Operabili - Review (71707)
The Condensate Demineralized Waste Evaporator (CDWE) is currently the only operable permanently installed liquid radioactive waste ( radwa ste).
processing system at Sequoyah Nuclear Pl ar,t.
In 1982, the licensee realigned certain liquid radwaste crossconnect valves in order to process plant liquid radwaste in the CDWE.
This action was followed by the l
removal from service of both the liquid radwaste evaporator package and
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the auxiliary radwaste evaporator package from service.
Prior to this action the CDWE had only been used to process. waste from the condensate demineralized :ystem and the floor drain collector tank.
The new
configuration allowed the processing of the tritiated drain tank.
In
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addition, the licensee installed and utilized mobile radwaste processing
'i equipment with temporary connections.
This issue was identified in NRC Inspection Report (IR) 327,328/86-19, and the following items were opened:
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URI 327,328/86-19-02; Radwaste Systen Changes.
This URI addressed the failure of the licensee to perform an adequate.
50.59 review, the failure of an FSAR update to meet the requirements of TSs, and the inability of the licensee to document that CDWE changes were reviewed by the Plant Operations Review Committee. URI 327,328/86-19-02 was closed in NRC IR 327,328/86-28 and replaced with violation 327,328/86-28-01.
References:
Licensee safety evaluation dated April 26, 1985 FSAR revision dated April 11, 1985 Licensee responset to violation 327, 328/86-28-01 dated July 15, 1986 and June 12, 1987 Licensee safety evaluation dated February 6,1987 Licensee Radiological Effluent Release Report' 1986 URI 327,328/86-19-03; FSAR commitments on Radwaste Systems.
This URI addresses the ventilation requirements within the COWE enclosure.
The CDWE building is a seismic category I structure with two entrances (one internal connecting to the auxiliary building and one external connecting to the yard).
The FSAR
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states that the CDWE building will be maintained at a slight negative pressure by the normal auxiliary building ventilation system.
This negative pressure requirement is not maintained during an auxiliary building ventilation. system isolation (ABI).
Following an ABI there would be a potential release path which would not be aligned to the emergency ventilation cleanup system (auxiliary' building gas treatment system, ABGTS).
In addition
the CDWE has two installed heating ventilation and air conditioning units. When this URI was written one of the units had been inoperable for approximately two years and one unit was not capable of maintaining FSAR CDWE building temperature requirements without extended out-of-service periods. This URI l
was closed in NRC IR 327,328/87-08 and deviation 327, i
328/87-08-02 was issued.
References:
Licensee response to deviation 327, 328-87-08-02,-
l dated May 15, 1987 NRC letter (Zech/ White) dated July 22, 1987 Two CDWE liquid radwaste spills have occurred. The first spill occurred in 1986 (PRO 1-86-006).
The second spill occurred in June 1987.
The spills have resulted from a. leakage path between 'the CDWE building walls and floor.
The licensee has an outage currently scheduled to repair the CDWE building walls and floors.
A current health physics inspection 327,328/87-55 has ' identified further modifications made to the lineup of the CDWE system to accept the drains i
from the laundry area. These lineup modifications caused soap impurities to be present in a radwaste drum that was being solidified with i
proprietary chemicals prior to disposal.
As a result of the soap i
impurities being present in the drum an exothermic reaction took place which contaminated one worker.
These issues are further addressed ' in IR 327,328/87-56.
In light of the information/ situations presented above, OSP-HQ has been i
requested to assess the adequacy of' the CDWE system as the. only operable permanently installed liquid radwaste processing system at Sequoyah.
12.
SAFETY SYSTEM OUTAGE MODIFICATION INSPECTION (SSOMI) ITEMS The following tabulation of items identified in Inspection Report 86-68 is provided below to indication TVA and NRC assessments for the specified criteria.
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Violations
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Report Sample /
TVA Admit / NRC Followup
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De fi cency Deny Accept / Deny Restart 86-68-01 a
2.1.1.3 32-2 Admit Accept Yes 42.1 Admit Accept No b
2.1.1.2 2-1 Deny Accept Yes c
2.1.1.1 30-1 Deny Accept Yes L'
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Para No.
Report Sample /
TVA Admit / NRC Followup
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Number Number Section #
Deficency Deny Accept / Deny Restart 86-68-02 a
2.1.3.1 17-1.
Admit Accept No l
b 2.1.3.1 44-1 Admit Accept No
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45-1 Admit Accept No 46-1 Admit Accept No c
2.1.3.1 45-2 Admit Accept No
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11.5 Deny Accept Ne
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12.1 Deny Accept No 13.1 Deny Accept No
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6.2 Deny Accept No l
10.3 Deny.
Accept No l
5.2 Deny Accept No j
1-2 Deny Deny No l
l 3-1 Deny Accept No
3-3 Deny Accept No
2.1.3.2 7.1 Deny Accept No j
13.3 Deny Accept No
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19.1 Deny Accept No 19.3 Deny Accept No 20.5 Admit Accept-No 21-1 Admit Accept No 40-1 Deny Accept No
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19-5 Deny Accept No d
2.4.9 D-2.4-10 Deny Accept No 86-68-03 a
2.1.4.1 W30 Admit Accept No
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b 2.1.4.2 4-3 Deny Accept No 8-1 Deny Accept No 9-3 Deny Accept No 10.6 Deny Accept No
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32-2 Deny Accept-No l
41-1 Deny Accept No l
11-2 Deny Accept No 22-2 Deny Accept No
c 2.1.2.2 WS Admit Accept No
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W8 Deny Accept No W9 Deny Accept No W11 Admit Accept No
)
W13 Admit Accept No
86-68-04 2.1.2.1 D-2.1-4 Deny Accept No j
86-68-05 a
2.4.10 0-2.4-11 Deny Accept Yes D-2.4-12 Admit Accept Yes D-2.4-13 Deny Deny Yes D-2.4-14 Deny Accept Yes b
2.4.1 D-2.4-1 Admit Accept Yes
D-2.4-2 Deny Deny -
No c
2.4.2 D-2.4-3 Admit Accept Yes 2.4.3 D-2,4-4 Admit Deny Yes 2.4.4 D-2.4-5 Admit Deny Yes b
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1 Para No.
Report Sample /
TVA Admit /
NRC Followup Number Number Section #
Deficency Deny Accept / Deny Restart
]
2.4.5 D-2.4-6 Admit-Accept Yes 2.4.6 D-2.4-7 Admit Accept No j
2.4.8 D-2.4-9 Admit Accept Yes 2.5.5 D-2.5-1 Admit Accept Yes d
2.3.9 D-2.3-9 Deny Accept.
Yes 2.4.7 D-2.4-8 Deny Accept Yes 2.4.13 D-2.4-15 Admit Accept No 2.4.14 D-2.4-16 Admit Accept Yes I
2.4.15 D-2.4-17 Admit Accept Yes
2.4.17 D-2.4-18-Admit-Accept Yes 2.4.18 D-2.4-19 Admit Accept Yes
86-68-06 a
2.1.2.5 W18,W15 Admit Accept No b'
2.1.2.5 W12 Deny Accept No c
c 2.1.2.5 W21 Admit-Accept No
W22 Admit Accept No
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d 2.1.2.5 W10 Admit Accept No 86-68-07 a
2.3.1 D-2.3-1 Admit Accept Yes 2.3.3 D-2.3-3 Deny Accept Yes 2.3.4 0-2.3-4 Admit Accept Yes 2.3.6 D-2.3-6 Admit Accept Yes 2.3.7 D-2.3-7 Admit Accept Yes 2.3.11 D-2.3-10 Admit Accept No b
2.3.2 D-2.3-2 Admit Accept No 2.3.8 D.2.3-8 Admit Accept No UNRESOLVED ITEMS
Item Number Section Number SSOMI Followup Restart J
U-2.1-1 2.1.2.3 Not Reviewed Yes U-2.1-2 2.1.2.4 Not Reviewed Yes U-2.1-4 2.1.3.1 Not Reviewed Yes U-2.1-5 2.1.3.1 Not Reviewed No U-2.2-1 2.2.1 Not Reviewed No U-2.3-1 2.3.1 Not Reviewed No i
U-2.4-1 2.4.1 Not Reviewed No U-2.4-2 2.4.11 Not Reviewed Yes U-2.4-3 2.4.12 Not Reviewed Yes l
U-2.4-4 2.4.14 Not Reviewed No U-2.5-1 2.5.4 Not Reviewed No DEFICIENCIES NOT INCLUDED ABOVE Item Number Report Section SSOMI Followup Restart
,
D-2.3-5 2.3.5 Not Reviewed-No t -
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Restart Test Program (RTP) Review During this inspection period the inspectors continued their independent review of the RTP implementation as it related to System 67 (Emergency Raw Cooling Water (ERCW)), and System 72 (Containment Spray (CS))..In addition to reviewing these two system packages the inspectors also. attended several Joint Test Group (JTG)' meetings where the inspectors actively
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participated in the review of System 31 (Ventilation), System 1 (Main Steam), System 70 (Component' Cooling), and System 15 '(Steam Generator'
j Blowdown). Numerous comments were provided and factored into the final
_j functional anaijsis report package. In addition to analyzing the above system pacr, ages the inspector reviewed the following Special Test J
Instructions (STIs) for technical adequacy:
J STI-72, Diesel Generator 1A-A Restart Test STI-73, Diesel Generator 1B-B Restart Test STI-74, Diesel Generator 2A-A Restart Test
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STI-75, Diesel Generator 2B-B Restart Test STI-81, Hydrogen Analyzer 2A and 28 Valves Fail-Safe Position Test STI-65, Containment Spray Pump Performance Test The inspector determined, that after the licensee incorporated the JTG and inspector's comments, tests STI-72, STI-73, STI-74, STI-75 and STI-81 were technically adequate. However, STI-65 required additional revisions af ter the inspector identified that the ERCW system and RWST required i
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temperature monitoring to ensure that heat added by the CS pump does not cause damage to equipment in the systems.
The licensee is currently a
modifying the test procedure and the inspector will ensure that his
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comments are properly dispositioned.
The inspectors witnessed the performance of STI-73 and STI-75 on the
"B" train diesel generators (DGs). The two tests were conducted concurrently and performed with no major problems.
However, testing was stopped on a few occasions due to procedural problems requiring nonintent changes (modifying the step sequence).
The testing was satisfactorily performed to close several Function Analysis Report (FAR) punchlist items for the D/G system.
The testing verified the following functions:
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High jacket water temperature (HJWT), low lube oil pressure ( LOP), and high crankcase pressure (CP) trips will trip the diesel.
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HJWT, LOP, and CP trips are blocked when an emergency start is present.
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The overspeed trip is not blocked by emergency' start signal.
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The D/G manual control is blocked during emergency operations.
SI reset timers will reset the sequence timer on initiation of
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SI following a blackout.
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Whenever a D/G is idling and an emergency start occurs, that'
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The air tanks for the 0/G air start subsystem can be pumped up to 300 psig in equal to'or less than 30 minutes after 5 starts.
Component Cooling Water Pump 2B-B will not start.on low header-
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pressure until approximately 20 seconds after a blackout.'
14.
Stone and Webster Engineering Corporation (SWEC) Element Report i
A review of the Sequoyah Final Element reports was conducted to determine J
l if restart issues had been adequately. identified.
The SWEC element reports were derived from a report prepared for TVA by Stone and Webster Engineering Corporation (SWEC).
The SWEC report attempted to determine all outstanding issues and concerns at Sequoyah Nuclear Plant.
TVA's Employee Concerns Task Group (ECTG) grouped the SWEC issues and concerns into 59 elements.
Each element consisted of an introduction that identified the issues in that element, a verification of-the SWEC issues, corrective action taken, a verification analysis and completion status.
ECTG then determined from the report those items that required completion and closure prior to. startup of Unit 2, Items identified for startup were verified to be tracked by a Startup Activities List (SAL) number or other
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tracking system.
The inspector concluded that the methodology used to determine startup items adequately identified the startup items.in the SWEC report, and that these items are being tracked via the SAL or-NRC open items list.
No unique issues were discovered during this limited review of the SWEC element report.
The inspector had no further questions.
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