IR 05000327/1988042

From kanterella
Jump to navigation Jump to search
Insp Repts 50-327/88-42 & 50-328/88-42 on 880829-0902.No Violations or Deviations Noted.Major Areas Inspected: Operational Staffing,Review Committee Activities,Maint Status & Status of Testing
ML20205R045
Person / Time
Site: Sequoyah  Tennessee Valley Authority icon.png
Issue date: 10/25/1988
From: Jenison K, Linda Watson
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20205R030 List:
References
TASK-3.D.3.4, TASK-TM 50-327-88-42, 50-328-88-42, IEIN-86-076, IEIN-86-76, NUDOCS 8811090431
Download: ML20205R045 (41)


Text

. __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ . _ - - _ _ _ - _ _ _ _ _ _ _ _ _ _

s

~*

. ei .

d muy%

O' 't / ' UNITED STATEf, '

]o J NUCLEAR REGULATORY COMMISSION

'

- ,  !. REGION 11

[# ' S g 8 '101 MARIETTA ST e,,,, ATLANTA. GEORGIA 30323 '

,

,

Report Nos.: 50-327 and 50-328-

'

(

Licensee: TennesseeLValley Authority 6N 38A Lookout Place 1101 Market Street Chattanooga, TN 37402-2901 Docket Nos.: 50-327 and 50-328 License Nos.: DPR-77, DPR-79 Facility Name: Sequoyah Units 1 and 2 Inspections Conducted: August 29, 1988 thru' September 2, 1988 Inspector: $ /$ 8 & ]st /o/2)/88 Date Signed K.f enison, Sen p Kesident Inspector, Team Leader Team Members: J. Brady M. Branch'

M. Fields

-

G. Humphrey D. Loveless P. Moore B. Singh A. Szczepaniec C. Hosey

'

Approved.by: f/C)d#dirn~ h/J5/99 L" J/ Watson, Chief, Project Section 1 Date Sfgned TVA Projects Division

SUMMARY Scope: This special announced inspection was conducted to partially assess TVA's readiness to support Sequoyah Unit I heatup and startup. The areas reviewed included operational staffing, review committee activities, maintenance ststus, status of testing, scatus of NRC OIL '

items and TVA's operational readiness assessment items associated with heatup and startup. In addition, as documented in paragraph 4, e a functional evaluation of the Unit i Ventilation System was conducte t Results: Sequoyah Unit I was found to be. ready to c(mmence heatup and startup activities when those necessary startup punch list items are complet In addition, the site management, support facilities, and physical plant equipment ws.re found ready to support two unit Mode 1 operatio No violations or deviations were identifie I 8811090431 seio3g ,

hDR ADOCK 05000327 PDC

_ _ . _ . . , _ _ _ _ _

o

. .

REPORT DETAILS 1 Persons Contacted Licensee Employees

  • S. White, Senior Vice President of Nuclear Group
  • B. Charleston, Advisor Office of Nuclear Power
  • W.Hannum, Chairman,N$RB Aslinger, Maintenance SuperintendentAssistant Site Representative R. Beecken, J. Boyles Employee Concerns Site Representative

"J. Bynum,,Vice President Nuclear Power M. Cooper, Compliance Licensing Supervisor D. Craven, Plant Support Superintendent W. Elliott Coordina+or Engineer G.Fiser,EhemistryManager R. Fortenberry Technical Support Superintendent M. Frye, P0RS $ection Supervisor G. Gault, Reactor Engineer W. Hannum, Chairman, Nuclear Safety Review Board (NSRB)

0. Hickman, Manager Radiation Protection T. Howard Operations Surveillance Support J. Klein , Maintenance Engineer W. Lagerg,ren Staff Manager

  • J.LaPoint,dctingSiteDirector D. Lester, Restart Testing Manager J. Maddox, Lead Engineering Assurance Engineer
  • ISEG Mashburn, G. Putt lead Group Work Control Reviewer,/ Outage Superintendent M. Ray,, Site Licensing Manager A. Ritter Engineering Assurance Engineer ,

Assistant Modification Engineer J.Robinso,n$upervisorPlantReporting H. Rogers H. Skarzin, ski, System Engineer Supervisor

  • S. Smith P.Trudel,PlantManagerProjectEngineer J. Walker, Manager, Operations Support Group Other licensee employees contacted included technicians, operators, shift engineers, security force members, engineers and maintenance personne Other NRO Representatives i
  • McCoy, Assistant Director for Inspection Programs, Office of Special l Projects.

<

l * Attended Exit Interview Note: Acronyms and initialisms used in this report are listed in the l last paragraph.

l

_ _ _ _ _ _ _ _ _ _ _ _ _ .

O o .

2. Licensee Actions on Previously Identified Inspection Findings (92701)

l (0 pen) URI 327,328/87-73-04 involved minimum operating shift staffing )

required for performance of compensatory measure The concern was that the licensee did not have staffing plans that would maintain enough personnel in the Control Room in the event of a LOCA and station blackout i requiring the shutdown of both Units. There was a discussion of placing a i fourth SR0 in the control room, but this was not pursued. Instead, the l licensee is plenning to revise their E0Ps to place the step for evaluating i plant status earlier in the procedure. This item remains open until the i licensee has finalized and implemented their plan for Unit 1 startu I

3. Readiness For Heatup and Startup Inspection This inspection was performed to provide, in part, the basis for determining the readiness of Sequoyah Unit 1 to commence plant heatup and startup activitie Since the issuance of the Sequoyah Nuclear Performance Plan (SNPP), the NRC has performed program improvement and implementation inspections which are documented in numerous inspection report Operational Staffing (36301, 41301, 36700)

(1) Qualification and Staffing Level of Operators and STAS Licensed operator qualification and staffing levels were evaluated and 28 andinfound NRCtoinspections 327,328/88-02, be adequate 08,116, to support Mode 17, 20 26, operation,s for Unit 2 and Mode 5 operations for Unit 1. The intent of this inspection was to review the implementation in this area and to evaluate any changes or differences from the programs or implementation which was previously evaluate The inspector investigated the concern that the licensee may not have an adequate number of o)erators to support two unit operation. This concern arose cue to a licensee request to have licenses granted to three R0 candidates whose completion of the R0 licensee prerequisite for significant reactivity l manipulations was being questioned by the Region II operator l license section. The inspector determined that there were enougli qualified operators available to support two unit opera-tion in accordance with the TS and NUREG-0737; but, in order to meet their planned staffing of six gr,oups and not use the three R0 candidates discussed above, the licensee would have had to

, remove some SRO candidates from training to stand R0 watch

or exceed their administrative overtime requirements. The inspector was later informed that the NRC had granted the licenses to the three R0 candidate The inspector also reviewed the staffing and qualifications of the STAS. There are presently eight personnel that can fulfill the STA positions. Six of them are assigned to the shifts and two others are available should the need for replacement aris mm im

__

- _ _ _ _ _ _

.

-

..

The to providelicensee is actively,bility further flexi in the staffing area and topursuing the hiring o enable them to maintain an ongoing training and up, grade p,rogram for the STAS. The inspector also reviewed the training files of the STAS and found the licensee to be actively involved in an ongoing STA training program thus meeting the requirements of NUREG-073 (2) Training on Recent Modifications for Operators and STAS on recent modifications was evaluated Operator in NRC inspectionsand STA training /88-02, 08,16,17 26 and 28 and 327,328 found to be adequate. Inspection 327 328/851620, dealt prin,ci-pally with those Unit 2 and common modifications that affected the startup of Unit 2. The other inspections evaluated the shift briefing and training that took place for recent modifi-cations of both units and common equipmen The intent of this inspection was to review the implementation

'

of Unit 1 specific training that was not included in the shift briefing and training activities, and to determine if the two areas of training together provided adequate update training to

.

Unit 1 operators to support two unit Mode 1 operations, t

!

The inspector reviewed the implementation of Unit 1 specific I training with particular attention paid to recent plant modifications since Unit 2 startup. The licensee has been issuin training letters to operations ersonnel to inform f themofanyimportantmodificationsandtkeirpossibleimpacton the operation of the plant from the operator standpoint. The

'

most recent training letter was issued May 10, 1988 and the inspector reviewed this training letter as well as the training letters issued over the past two years. . Interviews with responsible trainin department personnel indicated that the training department lans to issue one final letter right before startup covering al im)ortant plant modifications that had occurred since the May :.0,1988 training letter. The licensee stated that training on the final letter would be conducted for shift personnel prior to restar The inspector found th0 training that was being performed on recent plant modificatins to be adequate to support Unit 1 startup effort (3) QualificationandStaffingofP0RS The qualification and staffing of P0RS were evaluated in NRC inspection 327,328/88-16 and found to be adequate for those activities that were necessary with Unit 2 in Mode 1 and Unit 1 in Mode __ _ ___

- - - - - - . - - - - - - - - - - - . - - - - - - - - - - - - _ - - - - - _ - - _ - - _ _ - - - - -

.

.

The intent of this inspection was to review the qualification and staffing of P0RS personnel for plant operation with two units in Mode 1 operatio The ins 3ector interviewed the P0RS group manager responsible for OPERABILITY determinations to detertaine whether staffing levels would be adequate for two unit operation. The P0RS group respon-sible for making operability determinations has not changed significantly since NRC inspection 327,328/88-16 when the group was found to be acceptable for Unit 2 restar The number of members have decreased from eight to six; however the six remaining members have not change The P0RS members have received additional training in investigation techniques (MOR1)

and root cause analysis. In addition, two members have success-fully completed the STA training program. The justification for the reduction in staff was that the work load had decreased since Unit 2 started up (8-9 LERs/ month to 4 LERs/ month). In addition, the number of days required for the group to complete an LER has been reduced by about five days. The grou) 1s anticipating a spike in work load during the Unit 1 s;artup Jeriod; however, they appear to be adequately staffed to handle Jnit 1 startup and to support two unit operatio (4) New Managers The impact of possible manpower reductions because of the TVA reduction in force activities was reviewe The licensee is reducing their management staff by approximately 15%. Many of these reductions are at the "assistant to" managerial position The intent behind the majority of the changes is to reduce the levels of mana Some programs such as the CAOR, LER, gement from seven to five.and Employee Concern to a ' evel just below the Site Programs Manager. These reductions are being performed in an effort to streamline the organization as the site progresses from its extended outage posture towards a more normal operating status. There are no further reductions planned. The inspector determined that this management reorganization would in no way affect the safe operation of the olants or preclude the startup of Unit b. ReviewCommitteeActivities(40700,40701)

The Sequoyah Plant Operations Review Committee (PORC), Nuclear Safety and Independent Safety Engineering Group ISEG)

Review were Board in reviewed (NSRB),

or der to verify compliance with applicabl(e requirements in NRC inspection 327 328/83-16. In each case the committee or group was evaluated in terms of TS requiremen,ts, previous enforcement and industry standard Each group was found to meet TS requirement _ __ _ _ _-____ _ _-_ _ __ _- .

..

.. .

,.

-(1) Review PORC Staffing and Functionality The activities and the composition of the Sequoyah PORC was reviewed to verify regulatory compliance, as defined in the Sequoyah TSs.

,

The PORC charter was reviewed to verify incorporation of:

-

Purpose

-

Scope

-

References

-

Organization

-

Authority

-

Method of Operation The PORC is a committee composed of plant management and su)ervisory personnel with diverse technical backgrounds. The PORC meets at least once per calendar month to review matters required by the TS and related to safe plant operatio A special PORC meeting may be convened, as requested by managemen In the event that committee business must be transacted on an expedited basis during non-work hours, a member may be considered present if he is in telephone communication with the committee. No more than four members, including the chairman,ittee.may the comra be offsittvote A majority and inifcommunication by telephone with taken) by the members present is required for the commi(ttee to approve recommended action to be taken on agenda matters. The Sequoyah PORC normally operates on a consensus basis and a formal vote is normally not performed or recorded. Dissenting opinion will be recorded in the PORC minutes. If a member or alternate in telephone contact with PORC voices a dissenting opinion, PORC will not recommend that item for approva The PORC is required to maintain written minutes of each PORC meeting that, at a minimum, document the results of all PORC activities performed under the responsibility and authority provisions of the T A review of the PORC was conducted by the NRC inspector The finding; indicated that items were presented to the committee on a timely basis. Minutes of each meeting were issued and committee reviews and approvals were conducted within the timeframe allowed by AI-48. It was further determined that there was limited use of subcommittees to review issue As a result of a PORC meeting witnessed by the inspectors on September 1, 1988 it was determined that the issues presented had been pruiously reviewed by the committee members and each J

_

. _ _ _ _ . _ _ _ - _ _ _ _ _ _

_ _ _ - _ -

L' .

'

. .

6 issue was given careful consideration prior to making a decision. Issues presented with inadequate information or those requiring corrections were returned to the responsible personnel for making the specified corrections and then tracked on an open items listin The inspector reviewed the results of the Sequoyah inscection conducted by American Nuclear Insurers (ANI) on July 5-5,198 The Jurpose of the ANI review was to assess the nuclear liability of the insurance pools in the areas of root cause assessment and safety review. The inspection had focused primarily on. reviewing previous ANI safety recommendations and reviewing a PORC meeting. Thirteen of the ANI's sixteen outstanding pending, ' T he three remaining consisted of: (1)recommendations the pTant were manager or assistant . manager, ONP, should chair all PORC meetings;(2)allPORCmembersshouldberequiredtoattendPORC meetings 1 the use of alternates should cease; and (3)an action plan.e.shouldbedevelopedandimplementedforestablishing corrective actions for PORC deficiencies noted by outside organization The results of the recent ANI inspection were favorable and only enhancement recommendations were made. There were no further requirements initiate SQN-I, was also reviewed by the NRC ISEG Report, This report referenced areas reviewed during an inspector inspection of PORC conducted in the later part of 1987. The report was issued on June 1,1988 and the areas of concern have been satisfactorily addresse The above reviews were conducted to determine if new issues or Unit 1 saecific issues have occurred since the startup of Unit 2 and whet'1er the startup of Unit 1 would introduce any additional aspects requiring corrective action. The inspector found no new issues,which would effect Unit 1 startup or prevent two unit operatio The PORC appears adequate to support a two-unit plant operation based on the above inspections and review (2) Review liSRB Staffing and Functionality The Sequoyah NSRB was reviewed to verify that the NSRB charter,

"Office of Nuclear Power Organization Description Number 13.5, Rev.1," implements the TS and entails the following:

-

The function of the NSRB

-

The responsibilities of the NSRB members

_

-

.

-

. .

-

The organization of the NSRB

-

Personnel qualification requirements of the NSRB member

-

A)pointment mechanism of NSRB members

-

Tie training received by the NSRB member

-

The NSRB review process

-

NSRB meeting requirements o Agenda o Quorum o Conduct of Meetings

-

NSRB records requirements Inspection 327,328/88-16 found through interview a review of the charter and a review of meeting minutes tliat TVA had satisfactori,ly addressed the circumstances that led to Violation 327,328/87-30-02 and that the NSRB was functioning properl The NSRB was reviewed to determine if new issues or Unit 1 saecific issues have occurred since the startup of Unit 2 and w1 ether the startup of Unit 1 would introduce any additional aspects requiring corrective actio The inspector reviewed the NSRB charter and compared it with TS 6. The charter appears to comply with the TS in all aspects. The inspector sampled the qualifications of NSRB board members to ensure they met the TS and NSRB charter requirement All members sampled met the the requirement NSRB meeting minutes for June, July, and August were reviewed by the inspector. The quorum requirements were met for each of the minutes reviewed. The meeting frequency complied with the requirements in the TS als The inspector interviewed the NSRB Chairman and one other member of the NSRB. The Chairman stated that the NSRB has formed subcommittees to better address each of the TS required major areas of activity. These subcommittees are chaired by NSRB members and may include other TVA em)loyees. The subcommittees provide written reports to the boarc concerning activities in the specific area assigned. The use of subcommittees appears to allow board members to concentrate their time outside of the actual board meetings on a specific area which provides greater depth of review. Written reports are provided to the NSRB and discussed durinc the regularly scheduled meetings. The written reports are inc' uded as an attachment to the meeting minute The inspector determined that the use of subcommittees was an enhancement to the NSRB proces _ _ _ _ _ _ _ _ _ . . _ - _ _ _

.

. .

The inspector also discussed with the Chairman the term

"advisors" used in the meeting minutes. The TS allows for non-TVA personnel to be members of the NSRB; however, TVA has chosen to use them as advisors to the board and not as actual board members. They provide the same broad view input to the board even though they are not voting members. The inspector found this to be acceptabl This area is considered acceptable for the restart of Unit (3) Review ISEG Staffing and Functionality The Sequoyah ISEG was reviewed to verify, among other things, that the piogram has been prepared and contains the following:

-

The responsibilities of the ISEG members

-

Description of the ISEG function

-

The organization and authority of the ISEG members

-

The qualifications of ISEG members

-

lhe training of ISEG members

-

A description of the ISEG process

-

A description of the ISEG escalation process

-

A description of the record retention requirements for ISEG documents The current ISEG program was also compared to TS 6.2.3 to verify program compliance in terms of function, composition, responsibilities and authorit The inspector found that the ISE6 charter and procedures adeguately implement the requirements of the TS. Three dedicated engineers are assigned at the site while at least two additional engineers are shared among all TVA nuclear sites at the corporate office. The ISEG reports to the Director of Nuclear Licensing and Regulatory Affairs which is in accordar.ce with the TS and complies with the guidance of NUREG-073 The inspector discussed ISEG duties with the lead site ISEG reviewer and the corporate ISEG manager. Duties are s) lit between the site croup and the corporate group such tlat incoming corres correspondence, poncence from outside sources such as NRCindust correspondence are received first at the corporate ISEG gro They evaluate the correspondence for plant applicability and then route it to the appropriate site ISEG groups for additional review. Onsite ISEG functions include review and surveillance of plant activities such as maintenance, modifications and plant operations (operational analysis and problem evaluations). The

_ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _

-

. .

!

corporate ISEG staff is used to supplement the onsite staff in investigations. The results of these reviews are generally published in a monthly ISEG repert. Additional topics for review which entail single topic investi period of time generally are published ingation special report over a longer The inspector reviewed the qualifications for each ISEG member and determined that all were qualified in accordance with ISEG implementing procedure 0604.05, ISEG Evaluations, Rev. O. The inspector sampled the ISEG monthly reports and special reports for the period beginning July 198, until present. The areas of review satisfied the requirements of the TS and the ISEG

charter. Observations and findings from the ISEG reports appear '

to get adequate and prompt line organization res]onse. The inspector sampled some of the special reports published by the

.

ISEG in the areas of plant / grid interface problems and 10 CFR 50.59 pr,ogram implementatio These two reports reflected that indepth reviews of these subjects were conducted and that the ISEG appears to be getting the proper attention of high level management in order to get problems resolved. In i particular, the plant / grid interface problem report involved

, corrective action coordination between the Department of Nuclear .

Engineering (DNE), Sequoyah Operations, and the Power System ,

Operations Division of the Office of Power. When the 500 - 161 kV Intertie Transformer Bank is out of service communication and coordination between the Sequoyah control ro,om operators and ,

the load dispatchers was found to be required in order to determine whether two independent sources of offsite power are

'

available. Procedure changes shown to the inspector indicate that ISEG is making si this problem, however,gnificant coordinating progress the required in actions the resolution with of ,

t,'e dispatcher has yet to be teste l During this inspection, the following documents were reviewed: I i -

ISEG Implementation Charter

-

ISEG Implementing Procedures o 0604.05, ISEG Evaluations, Rev. O  !

l o 6.1-1, Selection of ISEG Review Topics, Rev. 0 l g .

! o 6.1-2, Conduct of ISEG Reviews, Rev. 0

.

i o 6.1-3, Reporting of ISEG Reviews, Rev. 0 l 1 o 6.1-4, Tracking of ISEG Findings, Rev 0 ,

o 6.1-5, ISEG Surveillance Activities, Rev. O g

j o 6.1-6, ISEG Personnel Training, Rev.0 l ,

L

_a

_ _ - _ _ _ . ________

-

.

,

This area appears to be adequate for restart of Unit c. MaintenanceandModificationStatus(71707,72701,62703)

(1) General Material Condition of Plant The inspector performed walkdowns in the Auxiliary Building and various other areas a?d found the material condition of the plant and general housekeeping to be outstanding with the following exceptions:

Unit 1 Elevation 714 heating and ventilation room had excessive water leaki,ng through the bottom of the walls onto a substantial area of the floor and into floor drain:.

Unit 1 Pipe gallery, a black Unit 1, Elevation 669, ibly oil) was found on the floo slipperysubstance(poss Unit 1, Elevation 619, near laundry and hot shower tanks, a ladder was wired to conduit and brackets in a permanent fashion with no scaffolding permit attache In general, plant conditions were acceptable for Unit I restar (2) Annunciator Alarm Status The inspector walked down the Unit 1 annunciator panels and noted a total of 77 annunciators tagged out for maintenance. A review performed on the outstanding maintenance work requests that were in effect in the Control Room revealed no major maintenance activity necessary for startup that could not be completed before the planned startup date. Some Work Requests could not be completed until the plant enters a different Mode because the PMT could not be performed to close out the Work Request. No items were identified in this section that would negatively impact Unit 1 startup effort (3) Post Maintenance Testing Complete or Scheduled The inspector reviewed the licensee's printouts for post maintenance testing that has been completed or scheduled. A 1988, listed only seven PMTs that printout needed todated August pr be completed 26,ior to entering Mode 4.The remainder of the testing could not be performed until the proper Mode had been entered to allow the plant personnel to perform the requisite testing. There were no apparent problems encountered in this area that would prevent the licensee from proceeding with the startup. The information on the printouts indicated that the licensee had a good g, rasp of what needed to be done in order to commence each successive Mode chang .

.. .

11 i

!

!

'

(4) Maintenance Backlog and TVA Lowest Mode Determination

.

The inspector reviewed the liceasse's trecking and trending of i equipment failures for the ventilation systems. The licensee i had not made any identification of repetitive failures that i would have presented a potential deficiency or operability nuestion on any of the ventilation systems with the exception of t a few failures of some Foxboro transmitters which have been known to be troublesome in the past. The licensee currently has a corrective action plan for Foxboro transmitters. Overall the '

inspector fond no 'ndications of any significant problems, in .

this are i The inspector reviewed the backlog of primary and se:ondary work requests determined that the ~ maintenance backlog was not excessive, and was well managed and that plant heatup could be ,

supporte Further review will be performed prior to Mode 2 entr (5) Work Control Center Activities  !

During the course of the inspection, several inspectors had to l interface with the licensee's Work Control Groups. These Groups :

have been set up separately for Unit 1 and Unit 2. The grouas are cocposed of individuals with a good deal of experience in either operations or maintenance. System drawings used by these groups were very clear and easy to use. All questions directed towards the individuals assigned to the given systems were e adequately addressed and all individuals contacted demonstrated a good understanding of the maintenance activities in progress or planned for their systems. Overall the activities of the WoraControlGroupindicatedastronglIcenseecommitmenttothe ,

accomplishment of all necessary maintenance activities required i to support both the startup and eventual full power operatio The maintenance activities appeared to be adequately reviewed and controlle l (6) Modifications Backlog and TVA Lowest Mode Determination i

The inspector reviewed the licensee's mod lfications listing of

'

items required for restart. The majority of the items on the -

list were already completed. Approximately 100 items were '

still outstanding with no estimated completion date beyond j September 9, 1988 for Mode 4 required items. Discussions with c licensee personnel indicated that there were not any forseeable i difficulties in completing all of the planned restart modifi-cations in time to support the planned Unit 1 startup. A printout is generated daily providing an up-to-date listing of

.

-

. .

all the modifications activities that are in process and their status. This printout and discussions with modifications personnel demonstrated that tha plar,t had a gecd grasp of the modifications activities that needed to be completed to support Mode 4 operation No items were identified which would prevent the startup of Unit (7) Outstanding Clearances The ins)ector reviewed the outstanding clearances on the Unit 1 ventila". ion system Clearances, Hold Orders and Tagouts were investigated for their completeness and accountability. The following Hold Orders were reviewed: 1-88-240, 1-88-588 1-88-1108 1-88-1219, 1-88-883, and 1-88-121 Recordsrevlewed in the dontrol Room were complete and accurat No discrepancies were identified in this are (8) Temporary Alterations Outstanding for the Ventilation System The following temporary alterations on the ventilation systems were reviewed: 1-87-007-31, 1-85-070-31, 1-87-001-31 1-84-039-31, and 1-88-02-3 Temporar 1-88-02-30 was associated with clearance .1.-88-240,y alterationand involved m a vacuum in the auxiliary buildin compartment access door was opened.g while the Unit 1 upperThere temporary alterations on the ventilation system that would pose a problem to the Unit 1 startup and 1-88-02-30 will be closed when work is completed on Unit 1 and the upper compartment access door is close HealthPhysicsProgram(84523,84524,83526,83524)

An onsite inspection, was conducted durinc the January 11-15, 1988, using the follow 327, 328/88-03,ing ures: period procec inspection Licuid cnd Liquid Wastes (84723 , Gaseous Waste S anc Radiological Environmental M)onitoring (80721).ystem (84724),

Inspection 327,328/88-16 determined that these portions of the program were adequate to support the startup of Sequoyah The purpose of this inspection was to review the implementation of the radiological environmental monitoring program and the liquid and gaseous radioactive waste management programs to determine if there had been any chances or developments in the licensee's programs which nfluence Unit 1 restart. In addition, recent would personnel changes 'in upper management level. were evaluate adversely

.

. .

i In addition NRC inspection 327,328/88-31 determined that, with the '

exceptionofoneidentifiedviolation,theHPsystemswerecapableof supporting two unit operatien. Management personnel in the Region II Health Physics Section determined that the corrective actions taken by the licensee to prevent reoccurrence of the violation were adequate to support restart of Unit 1. The corrective actions for the examples identified in the violation consisted of: (1) termina-tion of an employee for improper placement of the radiation instru-ment for required monitoring of a contaminated work area; and, (2) a commitment to implement control measures for beta exposure during future steam generator work by October,1988. These issues were the subject of a telephone call between the Region II HP Section Chief and the inspector, the week of August 29, 198 Based on the results of inspections identified above and disposition i of the items critical to the restart of Unit 1, the health physics program has been determined acceptable to support two unit operatio SecurityandEmergencyPlanning(81070,81172,81052,81054)

NRC inspection 327,328/88-41 determined that the security systems on site were adequate. This inspection did not cover the security area in depth based on the satisfactory results of the referenced inspection. Discussions with NRC Region II security management revealed that there were no reported deficiencies that would indicate plant security was unable to support two unit operatio The emergency plar ning area was inspected in NRC inspections

.'

327,328/88-16 and 18-33 (emercency exercice) and determined to be

'

adequate to support two unit Fode 1 operation. The purpose of this inspection was to d(termine if programmatic changes or 1mplementation changes had occurrec since the last NRC evaluation. The inspectors determined that emergency planning was acceptable to support two

,

unit operation based on a review of the resul'.s of the inspections referenced abov SustainedControlRoomandPlantObservation(71715)

This inspection area covered control room conduct, control room operator action, shift turnover and relief, shift logs and records, event response, surveillance testing, and accomplishment of

, maintenance.

I

  • I i

e .

This area was moaitored by NRC shift inspectors and is documented in inspections 327 328/88-02, 88-17, 88-20, 88-22, 88-26, and 88-2 There are no ou,t?tanding issues from these inspections which could affect the startup of Sequoyah Unit ImplementationofCAQRProcess(36700,90714)

Inspection report 327,328/88-19 stated that the licensee had devoted a significant amount of managerial attention in order to affect changes necessary to make the CA0R process adequate and in order to maintain these identified improvements, increased managerial attention maj have to be directed long term. The implementation of the CAQR system was determined to be adequate to support Mode 1 operation of Unit 2 and it recommer.ded the removal of order EA 85-49 from Sequoya Since the above review was completed, the licensee has made changes to the QA Topical Nuclear Quality Assurance Manual, and procedure AI-12, Corrective , Action. The inspector attended a working session with discusse the licensee on August These changes were 24, implemented at Sequoyah during the1 week that this inspection was conducte Therefore the following observations documents andreference not the most revision recent3change of Al-12to and AI-12supp(orting, revision 4),for upper tier which there was no body of implementation data to revie (1) The CAQR process was audited by evaluating several issues to ensure that program processing requirements with respect to sensitivity and timing were still being satisfie ,

-

CAQRSQN 880394, Dimensional Error Found in Piping Analysis for Containment Spray Syste ;

The licensee determined that the calculation had been issued prior to receipt of a walkdown package. This was not in accordance with standard practice and resulted in an inadeguatecalculatio In addition, piping The calculation was revised and .ssue the design organization implemented a program for tracking preliminary information and for clearly noting the status of design informatio The inspector determined that the licensee's corrective action appeared to be adequat CAQRSQP 880386, Inservice Testing of Relief Valves  ;

The relief valves (72-612 and 72-513) were identified as  !

not being in the ASME Section XI test program. The f licensee determined tha! the valves were post-modification

i i

I

. , - - _ _ _ . ._ . . _ _ _ _ _ , _ . _ . . _ , _ . ._ _ _____._ _ __ ... __.-_______.. . _

. 4

'

.; .

tested using a procedure equivalent to the ASME Section XI requirements, rhe valves were subsequently added to the '

'

Inservice Testing progra The ir.spector determined that the licensee's corre..ive ;

actinn appeared to be adequat CAQRSQP 880366, QC Receipt Inspector Did Not Verify'All !

,

the Requirements of Purchase Requisition 74610A l The rectifiers satisfactorily )assed the required testi !

'

and were released for wor hanagementcounseledtheQY l inspector regarding the verification of purchase :

requisitian requirements. TVA considers this to be an L isolated oc:urrence and no further corrective action war

- taken, t The inspector had no further question !

-

i CAQR SQP the Test Was Com880354'pleted.ICF 88-0797 to SI-146 Was Approve l The licensee determined that the change was only to add additional documentation to the test package and not to

'

change the test data, t s , The inspector had no further questions.

-

CAQRSQP 880388, Failure to follow TI-9 i ABGTS filters were tested under ASTd 03803-1979 by vendor contract as opposed to ROT M16-1T per TI-9. The licensee corporate headquarters issued a new contract for the testing to be performed. The new conteact specified the new testing requirements and SQN personnel were not

, notified that change ICF 88-0909 was initiated to reverse j TI-9 to include the new testing standard. Tne li:.ensee determined that the new testing requirements met the intent

'

and the letter of their T The inspector detLmined that the licensee's corrective action appeared to be adequat (2) The CAQR backlog and screening procedure were reviewed to ensure that important issues were receiving the proper amount of attention.

$.

i l

.

L

-.,-.----,,,,,,w -

-.,-w.- - , .g,.- - - - - - . - - - . . - . -m-

_ _ _ _ _ _ _ _ _

O

'

.

The inspector reviewed the status of the CAQR program and found the following data as of August 28, 1988:

Old Program AI-12, revision 3 program Remaining Open 315 519 Open 6 Months N/A 160 Open 2 Years 125 N/A Open Unit 1 Restart 39 58 Closed Over Last 13 Weeks 84 193 Opened Over Last 13 Weeks N/A 86 The number of significant CAQRs outstanding continues at about 70 items but the total number of CAQRs continues to drop. The inspector had no further question (3) HanagementInvolvementwithNewCAQRProcess The inspector interviewed members of the site management team which dispositions the actions and urgency of CAQRs specific to Sequ ab. This interview included a discussion and review of the A audit program of the management overview arocess. In addi ion, the inspector interviewed the Site Quality Manace Based on these interviews and the documents that support The committee's activities, management involvement in the daily execution of the CAQR process appears to be adequat The AI-12 revision 4 process appears to be closely related to the previous process except for the formal acceptance of ten feeder processes which may be used to handle administrative problems. These processes existed under the AI-12, revision 3 process but there was a very large emphasis to arocess issues as CAQRs. Therevision4processseems4.;maketieprocessmore flexible and has the potential to allow hsues which would have been processed as CAQRs under the revision 3 process to be handled as administrative issues under the revision 4 proces In conclusion, the CAQR process under the AI-12, revision 3 process was determined to be adequately implemente The AI-12 revision 4processwasnotinspectedforimplemcntationandwili

.

requite inspeci.:on when a body of data is available to support

an inspection. No issues were identified which would prevent the startup of Sequoyah Unit 1.

l

-. -

. _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

.

. .

17 Evaluation of Specific Testing (61728, 61702, 61705, 61707, 61726, 72701)

The purpose of this inspection was to determine if changes or modifications to the plant or procedures could affect Unit 1 startu The inspector reviewed the startup and estimated critical condition

-

data for the Unit 2 startup to determint f any "lessons learned"

!

were applicable to the Unit 1 startu The documents reviewed included:

-

- SI-120, SI-139 Rev, Rev. 5,6,"Overall Reactivity

"Determination Balance" of Moderator Temperature Coeffic,ient"

-

TI-7, Rev. 10, "Heasurement of At-Povar Moderate Temperature Coefficient"

-

TI-4, Rev. 8, "Reactivity Anomaly Analysis" The inspector reviewed the above procedures and reviewed the last performance of SI-13 No discrepancies or deviations were noted, ReviewofOutstandingEmployeeIssues(TI 2515/74)

(1) Open NRC Allegations and Employee Concerns

! The inspector communicated with OSP allegation coordination personnel to determine if any open issues existed which would affect the heatup and startup of Unit 1 cr two unit Mode 1 operatio Several issues exist which will be completed arior to the startup of Unit Resolution of these issues i.e 3eing formally tracked by the NRC as a startep ite (2) Outstanding Issues in the Sequoyah New Employee Concern Program (ECP)

The inspector interviewed the ECP Site Manager and reviewed a

, list of the outstanding concerns. In addition, several Jpecific concerns were discussed in detail. The inspector also revb wad i a listing of those ECP concerns that were closed in orca tc

evaluate whether certain corrective actions (outstandino w complete) could affect Unit I heatup and startup or two bit Mode 1 operatio No restart related issues were identiti9d

that were not on a restart punch list, ReviewStatusofNRCIdentifiedIssues(92700,92701,92703,92703)
A review was conducted of NRC outstanding items to determine if any

!

would effect the restart of Unit 1 or two unit Mode 1 operatio The i outstanding issues were reviewed against the Sequoyah startup criteria.

1

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ - _ ____ _ _

_ _ _ -

.

'

. .

Reports through ins)ection report 327,328/88-27 have been reviewed for restart requirec item Twenty-six LERs and eighteen open items have been identified and discussed with the licensee which require resolution for restart of Unit 1. Resolution of these issues is being formally tracked by the NRC as a startup item, Review of Licensee Operational Readiness Assessment Effor;.s The inspectors reviewed tne efforts that the licensee has expended to establish the operational readiness of Unit 1 for restar These efforts included TVA NMRG/NSRB ORR dated August 23, 1988 and the INP0 inspection conducted Spring 198 No restart issues were identified that were not on a restart punch list for corrective action . Functional Evaluation of the Unit 1 Ventilation System Including the Following Subsystems: Emergency Gas Treatment System (EGTS), Auxiliary Building Gas Treatment System (ABGTS) Control Room Emergency Ventilation (CREV)andContainmentVentilation(CV The following design and functional attributes were inspected, utilizing licensee prepared packages, in order to determine if there was sufficient assurance that the ventilation subsystems identified could fulfill these attributes. Each attribute had been reviewed by the Division of Nuclear Engineerin and verified by either Engineerinc Assurance or Quality Assurance.g,Ap3roximately 10 deficiencies were icentified by the licensee, including one ':AQR, during the licensee's document retrievas proces ABGTS (1) The ABGTS will actuate either manually from the main control locall room (MCR),ignals:y, following s or automatically upon receipt of any of the

-

Phase A containment isolation signal from either reactor unit,

-

High radiation signal from the fuel handling area radiation moniters,

-

High radiation signal from the auxiliary building exhaust vent monitor, or

-

High temperature from the auxiliary building air intak All isolation dampers close automaticall No issues were identifie (2) The handswitches which control the fans from the Main Control Room are supplied with position-indicating lights in the MC No issues were identifie .

-

.

,

' '

. .

. .

r (3) An alarm sounds in the MCR upon increa3ing Auxiliary Building Secondary Containment Enclosure (ABSCE) pressur No issues were identifie (4) Pressure differential indicators are alaced across individual components (except the relative humidtty heater) in the filter housing to locally display the pressure drop across each {

-

componen No issues were identifie ;

(5) A high temperature cutout is provided for the humidity control i heate No issues were identifie l

.

(6) A low flow condition in either train is annunciated in the HC i No issues were identifie l

. (7) All isolation dampers are automatically closed on all auto start ;

! signal No issues were identifie (8) The single failure criterion is me The system has redundant s components such that a single failure will not render the system l inoperabl !

While the ABGTS is designed to meet the single failure criteria [

the licensee has f 1 by use of that identified separate 100% capacity documentation trains,ilable to support is not ava  ;

i consideration of common mode failure The licensee has issued i

. a PRO to resolve this issu !

.

!

i mechanical :

'

(9) The total allowable penetrations ABSCE inleakage through doors,is not to and electrical '

exceed 7000 cfm at - 1/4" w.g.Nopenetrations, etc. ,

issues a re identifie L

,

(10) A vacuum relief flow rate capacity of 2000 cfm is provided to i

.

limit the vacuum in the ABSCE. No issues were identifie l i (11)ThetotalsystemflowrateforeachtrainofABGTSis9000cfm+ '-

!

10%. No issues vere identifie !

,

i (12) Two 100 percent capacity trains consisting of the following !

i components listed in order exist: Relative humidity heater, ;

'

prefilter, HEPA filter, charcoal bed and an exhaust fan. No ,

issues were identifie (13)Adequateisolationoftheauxiliarybuildingduringaccidentsis provide This is accomplished by using low leakage dampers and i door Leakage across the boundary is into the ABSCE from !

surrounding areas. No issues were identifie !

(14) All air is exhausted through the shield building exhaust ven and none is recirculated. No issues were identifie _ - _ _ _ _ _ _ _ _

.

'

. .

(15) Mcdulating dampers are utilized to vary the vacuum relief flow rate such that a pressure of - 0.25 water gau,ge with resoect to outside is mainta'ined. An isolation dwper in series with the modulating damper shall be utilized. No issues were identifie (16)RelativeHumidit, Heater e The first element in each filter train is an electric heater to reduce relative humidit elements of the train. The y of heater the influent controltois protect other interlocked with the fan. A high air temperature cutout to prevent overheating is provided. The heater operates continuously when the system is in operation (unless high temperature exists). No issues were identifie (17)Prefilter The second element in each filter train is a bank of prefilter cells whi:h serves to protect the absolute filters from dust loading that would normally shorten their life. Prefilters have an NBS dust spot efficiency rating of 40 to 50 percent using atmospher:c dus No issues were identifie (18)HEPAFilter The third element in each filter train is a bank of HEPA filter cells designed for service in temperatures up to 250*F. Each >

cell is the formed module type having a minimum efficiency of 99.97 percent for removal of particulates 2.3 micron and larger when tested with 00P. No issues were identifie (19)ExhaustFans Each 100 percent capacity ABGTS exhaust fan is a belt driven centrifugal type designed to exhaust 9,000 cfm i 10% of air. No issues were identifie (20)Loopsealsindrainsfromeachfilterassemblyareprovide No issues were identifie positive-acting type (21) designed Isolationtodampers are of over prevent leakage a tight-closing, the requ ired range of pressure differentials. Dampers fail in the safe position, are engineered safety features and are seismic category No issues were identifie UL-aaproved t (22) by Firefusible dampers link are heavy-duty, dioxice trips.ype, or carbon- No issuesand are actuated were identified.

.

. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

-

. .

(23) The capability for manually stopping one train (and placing it in standby building i) solation is no longer required is provided bothor s locally and in the MC No issues were identifie (24) Low flow detection by a flow sensing device automatically starts the standby train. No issues were identifie (25) The fans have the capability to be controlled from the MCR and locally. No issues were identifie (26)FlowanddifferentialpressureinstrumentscontrolABSCEat-1/4 '

water gauge with respect to the outside. No 'ssues were identifie (27) The humidity control lagic for the heaters is designed to energize the heater whenever the fan start No issues were identifie (28)AllboundarydoorsintheABSCEarekeptclosedandareprovided with interlocking and annunciation features. The licensee has identified six boundary doors that do not have both the interlocking and annunciation feature The licensee has issued a PRO to resolve this issu ,

'

REFERENCES

- SI-3 Weekly, and Monthly Logs Units 1 and 2

- SI-21, AuxDaily}iary 1 Building Gas Treatment System - Unit 0

- SI-26.1A, Loss of Offsite Power with Safety Inj,ection - D/G 1A-A Containment Isolation Test, - Unit 1

'

- SI-83, Channel Calibration for Radiation Monitoring System

- Units 0 and 1

- SI-132, Auxiliary Building Gas Treatment System Filter Train Test - Unit 0-SI-141,ResultsfroaTestLaboratoryonCharcoalTestSample, '

- Units 1 and 2

- SI-149, Auxiliary Building Gas Treatment System Vacuum Test, -

Unit 0

- TVA drawing 47W866-8

- TVA drawing 47W866-3 1

- TVA drawing 47W865-8  !

- TVA drawing 47W866-3 6

- TVA drawing 47W865-6

- SQN-DC-V-3.2, General Design Criteria for the Classification i of HVAC System SQN-DC-V-21.0, General Design Criteria for Enviro.wental Design

-

.

.

- SQN-DC-V-13.8, Detailed Design Criteria for Seismic Qualification of Round and Rectangular Duct-SQN-DC-V-24.0,CapabilityGeneral Safe Shutdown Design Criteria for Fire Protectio

- SQN-DC-V-7.4, Desi n Criteria for ERCW system

- SCN-DC-V-7.5, Desi n Criteria for Fire Protection System

- S(N-DC-V-7.6, Desi n Criteria for Proprietary Protection Signaling System f r Fire Alarm and Supervisory Service

- SQN-DC-V-26.2, Environmental Qualification ta 10CFR50.49 Single Failure Criteria

-- SON-DC-V-1 SQN-DC-V-2.16,1, 125V Fifth Vital Battery System

- ANSI N18.2-1970 Nuclear Safety Criteria for the Design of Stationary Pressurized Water Reactor Plants

- Regulatory Guide 1.29, Seismic Design Classification, August 1973

- IEEE Standard 279 Criteria for Protection Systems for Nuclear PowerGenerating$tations(1971 issue

- IEEE Standard 323 IEEE Standard for ualifying Class 1E Equipment for Nuclear Power Generatin Stations

- TVA Drawing 47E235 - Series Environm?ntal Data

- 10CFR50 Appendix A GDC No. 13 - Instrument and Control

- 10CFR50 Appendix A GDC No. 4 - Environmental and Missile Design Basis 4

- 10CFR50 Appendix R, Section III.G cnd II r

"

- TVA Drawing 47E493, Fire Hazard Analysis Tables

- TVA Drawing 47W494, Fire Protection Compartmentation Reactor Site Criteria i

-- TVA 10CFR Part Letter 100, J. A. Domer to J. P. O'Reilly dated from December 21, 1984 L44851221804)

-SQN-DC-V-12.2, Des (ignCriteriaforSeparationofElectric Equipment and Wiring b. Control Building Environmental Control System (CREV)  ;

(1) the The MCRboardair conditioning system air conditioning air conditunits,ioning

,

electrical room air conditioning system *

units the control building emergency air cleanup system fans,  ;

'

and the battery room exhaust system fans have the capability of being controlled from the MCR and locally. The handswitches which control this eculpment from the MCR are equipped with position indicating 'ights in the MC No is, sues were identifie (2) The standby train will start automatically when the operating train fails. No issues were identifie (3) Pressure differential indicators are placed across the filter of each air conditioning unit for the MCR and electrical board rocm air conditioninc) systems to locally display the pressure dro No issues were identifie ._ _ - _ ___ _ __ _ _____ _ _____________ ____ _ ____ __ _ _ _ _ _ ____ -_

.

. .

(4) Pressure differential indicators to lecally display the pressure drop are installed across the prefilter/HEPA filter assembly and across the charcoal absorber of each air cleanup unit of the MCR emergency air cleanup system. No issues were identifie (5) A flow alarm will sound in the MCR when air flow for a system drops below the set point value and the redundant system will automatically start. No issues were identifie (6) Each of two MCR air-conditioning units are belt-driven, .

centrifugal, and 100 percent capacity. No issues were identifie (7) Each of two electrical board room air conditioning units are i belt-driven centrifugal, and 100 percent capacity. No issues were identifie (8) Each of the two control buildine emergency pressurization air ,

supply fans are direct-driven, vaneaxial, and 100 percent capacit Each one is capable of delivering a maximum capacity of 1000 cfm of ai No issues were identifie (9) Each of the two control building emergency air cleanup fans is direct-driven vaneaxial , and 100 percent capacity and is capable of de'livering a m,inimum capacity of 4,000 cfm of ai No issues u re identifie '

(10) Each of two control building emergency air cleanup units contains a bank of HEPA filters and a bank of carbon absorber Type II unit trays, fabricated in accordance with reference 8.3.0, contain impregnated charcoal for use in the carbon ,

. absoroer bank. The face velocity across the bank of unit trays '

is less than 45 feet per minute and the residence time is in 1 excess of 0.25 seconds to assure a high reroval efficiency. No f issues were identified, t'

(11) Each of the three battery room exhaust fans is belt-driven, centrifugal, and 100 percent capacity and is capable of delivering a minimum capacity of 2,200 cfm of ai j DCNX001298 was written to change the air flow of these exhaust fans from 2200 cfm each to 1915 cfm but the FSAR and Design Criteria SQN-DC-V-13.96 were not revised to reflect this change  !

at the time of DCN issue. The licensee has issued a PRD to

'

resolve this situation. No issues were identifie (1?) The MCR air-conditioning system and the electrical board room air-conditioning system automatically controls room temperature i by a room thermostat. The standby unit automatically starts if  ;

.

l l

I l

_.- - _

. _ _ _ _ _ . . _ _ , - - _ _ _ . _- _ _ _ . - _ _ . __

_ _ _ _ _ _ _

l -

. .

a flow sensor pressure in the detects freon low airflow,line. An alarm sounds in thehigh air temperature, o refrigerant l

MCR when any of these conditions occu The licensee has issued two drawing deviations to make minor changes to Drawings Nos. 45N657-12 (RG) and 47W867-4 (RG).

(13) Both fans of the control building emergency pressurization system automatically start upon receipt of a control room

'

isolation signal. One fan is to be manually shut down and placed on standb Low airflow is alarmed in the MCR causing the standby fan to automatically star No issues were identifie (14) Both trains of the control building emergency air cleanup and habitability zone isolation system automatically start upon receipt of a control room isolation signal. Low airflow is be alarmed in the MCR and the standby train automatically start No issues were identifie (15) One of the three 100 percent capacity battery exhaust fans is maintained in continuous operation (except for the time period duringatornadoevent). A standby fan automatically starts and alarms in the MCR if a flow sensor detects low airflow. No issues were identifie (16)Isolationdampersandvalvescloseautomaticallyuponreceiptof a control room isolation signal. No issues were identifie REFERENCES

- SI-2, Shift Log - Units 1 and 2

- SI-3 Weekly and Monthly Logs Units 1 and 2-SI-21,DailyliaryBulldingGasTreatmentSystem,it0 Auxi - Unit 0

- SI-24, Control Room Air Cleanup Subsystem, - Un

- SI-26.1A, Loss of Offsite Power with Safety Injection - 0/G 1A-A Containment Isolation Test - Unit 1-SI-132,AuxiliaryBuildingGasTreatment$ystemFilterTrain

<

Test - Unit 0

- 51-141, Units 1 and 2ResultsfromTestLaboratoryonCharcoalTestSamp

- - 51-143, Control Building Emergency Air Cleanup System Filter Train Test - Unit 0

- 51-144.1, Control Room Emergency Ventilation Automatic Actuation, - Unit 0

- 51-144.2, Control Room Emergency Ventilation Test - Unit 0

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __~

~

.

.

- TVA Drawing series - 47W494 - Fire Protection Compartmentation

- TVA Drawing series - 47E235 - Environmental Data-10CFR50(JulAp Plants endix A, General Design Criteria for Nuclear Power

- IEEE 279-19 1 1971)teriaforProtectionSystemsforNuclear Cri PowerGeneratIngStations

- IEEE Nuclear323-1974, Power Generating StationsQualifying Class IE Electrical

- 10CFR50 Appendix B Quality Assurance Criteria for Nuclear PowerPlantsandFue,lReprocessingPlant(September 1971)

- ANSI N18.2 - 1970 (draft), Nuclear Safety Criteria for the Design of Stationary Pressurized Water Reactor Plants (Augtst 1970 draft)

-RegulatoryGuide1.29,SeismicDesignClassification(August 1973)

and Maintenance

- Regulatory Guide 1.52, Criteria for Atmosphere Design, Cleanup Testing, Air Filtration and System Adsorption Units of Light Water-Cooled Nuclear Power Plants

- Regulatory Guide 1.78 Assumptions for Evaluating the HabitabilityofaNuclearPowerPlantControlRoomDuringa Postulated Hazardous Chemical Release Protection of Nuclear Power Plant

- Regulatory Control Room Guide 1.95, Against An Accidental Chlorine Release Operators Fire Protection Pro

- 10CFR50, Ap]endix R, Prior to January Facilities Operating 19791, gram for Nuclear Power

- TVA Construction Heating, Ventilatin Specification and Air-Condit G-37,ioning SystemsTesting and

- TVA Calculation TI gEdS-27 Main Control Room Habitability During Hazardous Chemical, Releases At or Near the Plant

- 10CFR100, Ap Reactor Site Criteria

- SQN-DC-V-11.pendix 2, 125-Vo A,lt Vital Battery System

- SON-DC-V-11.2.1 125-Volt Fif th ' ital Battery System

-- SSON-DC-V-11.6,1, N-DC-V-1 Normal and Emergency AC Auxiliary P 5 stem

- T A Mechanical Design Standard DS-M18.6.1, Identification of Mechanical Safety-Related Systems and Components

- SQN DC-V-21.0, Ceneral Design Criteria for Environmental Design

- SQN-DC-V-3.2, General Design Criteria for the Classification of Heatin and Air Conditioning Systems-SN-DC-Vg ,Ventilating,iteriaforSeparationofElectric Design Cr E aiament and Wiring

- S N- )C-V-2.16 Single Failure Criteria for Fluid and EectricalSafety-RelatedSystems

- SQN-DC-V-26.2, Environmental Qualification of 10CFR50.49 Equipment

__ _ _ _ _ . __ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .

.

'

.

26 EGTS (1) Isolation valves and dampers have MCR indicatio No issues were identifie (2) The fans have the capability to be controlled from the MCR and locally. The hand switches which control the fans from the MCR have position-indicating lights in the MCR. No issues were identifie (3) The redundant train starts automatically when the operating unit fails. No issues were identifie (4) Exhaust flow rate indication is displayed for each train in the MC No issues were identifie (5) Annuius differential pressure is indicated in the MCR. The instruments maintain the annulus at 0.5" w.g. with respect to 1.he shutdown board roo No issues were identifie (6) Pressure differential indicators are placed across individual components (except the relative humidity heater) in the filter housing to locally display the pressure drop across each componen An indicator is placed across the entire filter train to display the total pressure drop across the entire uni This pressure drop indication is dispiayed in the MCR and an alarm sounds in the MCR upon high differential pressure. No issues were identifie (7) A redundant set of dampers is activated automatically upon failure of an opposite set of dampers to maintain the proper annulus presrure accompanied by an alarm in the MC On August failure of t 2, he EdTS damper control system during an accidentth

, could cause excessive vacuum in the annulus resulting in an increased offsite dose. The licensee added a compensatory

'

measure to their emergency instructions to direct the operator, after 30 minutes into any accident, to check the EGTS damper control system and manually change trains if the operating train had the described single failure. A design change was being developedbyTVAandtrackedbytheCAQR. This was evaluated to be a licensee identified item because the failure had never happened and the corrective action was in progres (8) The humidity control logic for the heaters will energize the heater whenever the fan starts. A hi installed. No issues were identified.gh temperature cutoui. is i

i

, _ , _ _ . _ _ _ -- . _ . _ _ _ _ _ - . , _ _ , . . _ _ _ . , _ _ _ _ _ _ , _ _ . _ _ , , . , _ _ , _ _ _ _ _ , _ _ _ _ _ _ _ . _ ,

, _ _ _ _ _ _ _ _ _ _ _ _ _

'

.

s 27 (9) Two 100 percent-capacity trains consisting of the following components listed in order is installed: a moisture separator a l relative humidity heater a prefilter, HEPA filter, two 2-inc,h r and exhaust deep fan. Thecharcoal subsystembeds in se,ies, has redundant an after-HEPA components such t filter, hat a s failure will not render the subsystem inoperabl No issues were identifie (10) Adeguate isolation of the annulus vacuum control subsystem during accidents occurs. During the isolation aeriod the annulus is maintained at a negative pressure by tie air, cleanup subsystem such that leakage across the boundary is into the annulus from the primary containment and areas adjacent to the shield building. No issues were identifie (11) The intakes and ducting used to bring the air to the EGTS are shared with the annulus vacuum control subsyste No issues were identifie (12) Upon start of the air cleanup subsystem, the full flow of the subsystem is exhausted through the stack until pressure in the annulus has stabilized at (-)0.5" water gauge. At this point the flow rate out the stack equals the inleakage into the annulus and the maximum inleakage is 250 scf No issues were identifie (13) The flow dividers utilize butterfly valves ather than dampers to minimize outside air inleakage from the reactor unit vents into the annulu No issues were idesitifie (14) Modulating dampers are utilized to vary che amount of air that is exhausted throu pressure of (-)0.5'gh the gauge water shieldwith building vent respect such to the that a atmosphere is maintaine No issues were identifie (15) Simultaneous adjustment that closes one damper and opens the other, eliminates air flow oscillation problems that could arise from nonsimultaneous operation cf separately actuated damper No issues were identifie (16) The filters and absorbers in an inactive air cleanup unit that is loaded with radioactive material can be cooled with two crossover flow ducts that can draw a small staeam (anroximately 200 cfm) of air from the active air cleanu,p unit (A:J) through the inactive ACU. This air flow is sufficient to keep the temperature rise through a fully loaded inactive ACU to len than 95"F. No issues were identifie (17) The first element in each filter train is a moisture separator having a moisture removal efficiency of 99 percent for all particles 2 microns or larger with moisture entrainment loading up to 4 pounds per 1,000 cfm of ai No issues were identifie , - _ _ _ _ _ _ - - _ _ - _ - _ - _ _ _ _ _ _ _ _ _ - _ _ _ _ _

  • ;

. .

28 ,

i (18)Thesecondelementineachfiltertrainisanelectricheaterto reduce the relative humidity of the influent to 70 percent or less to protect other elements of the train. The heater control circuit is interlocked with flow to heater unless airflow exists, and is < preclude energizing ofnterlocked temperature cutout to prevent overheatin The heater operates ,

continuously when the system is in operation and is sized to '

handle moisture not removed by the separator plus saturated air at 150"F maximum. The heater is protected with UL approved protective devices. The environmental data drawing shows that the worst condition at Sequoyah will be 120"F at 90% RH. No issues were identifie (19) The third element in each filter train is a bank of prefilter L cells which serve to protect the absolute filters from dust r

loading that would normally shorten their life. Prefilters have i an NBS dust spot efficiency rating of 40 to 50 percent using j t

atmospheric dust. No issues were identifie ,

'

(20)ThefourthelementineachfiltertrainisabankofHEPAfilter ,

cells designed for service in temperatures up to 250*F. Each  !

cell is formed module type having a minimum efficiency of 99.95 '

percent for removal of particulates 0.3 micron and larger when tested with 00P. No issues were identifie <

~

t (21) The fifth and sixth elements in each filter train are two banks

of charcoal absorbers arranged in 20-inch deep horizontal bed l The design face velocity to these absorbers is 40 fpm and ,

the ignition temperature is 625"F. The charcoal absorbers have efficiency ratings of 99.9 percent for removal of elemental  :

,

iodine and 95 percent for removal of methyl iodine when 1 operating at 170*F and 70 percent relative humidity. No issues  ;

i

-

were identifie t i

(22) The seventh element in each filter train is a bank of HEPA filter cells for interce the charcoal absorbers. ption of any filter possible i

This HEPA bankparticulate from conforms in all l aspects to the requirements for the upstream HEPA filter bank.

No issues were identifie .

I (23) Two 100installekercent for Unit 2. capacitf are air cleanup subsystem centrifugal exhaust fans are type belt driven I capable of exhausting 4 0 cfm of air against 11 inches of , I water static pressur hese fans meet the separation criteria [

! and designed for seismic category I requirements. No issues  !

i were identifie i

'

f l

l

! t I

[

t

. _ _ _ - -_ -___. _ _ __ _ _ _ _. _ _ __ _ - _ _ _ --_ - _ - _ _ -. _

-- . - _ _ _ _ _ _ _ _ _ _ _ _ _ . _

( ,

. . t i

i (24) Isolation dampers and valves are tight-closing, positive-acting l

- type designed to prevent leakage over the requ: red range of pressure differentials. Dampers and valves fail in the safe position are engineered safety features and seismic Category :

No issues, were identifie '

'

(25) Cutoff dampers for airflow diversion are quick-acting type that will close sufficiently to maintain flow in the proper directio No issues were identifie (26) Balancing dampers are multi)le, opposed-blade types either quadrant or face operated wi".h provisions for locking blades in the balanced position. No issues were identifie (27) type, Fire dampers and to beif actuated installed should be heavy by fusible link or duty, car bon-cioxideUL-a) pro trips. There is no fire damoer presently installed in the EGT No issues were identifie (28) System discharge ducts, located within the shield building annulus are routed from the shield building isolation valves to are constructed to withstand the shield basis the design building exhaust tornado vent, ic atmospher aressure decrease as shown on the environmental data drawing ho issues were identid e (29)Systemexhaustductsareconstructedtowithstandthesystemfan shutoff negative pressure of approximately 15 inches of wate The duct system has not been verified to withstand the 15 inches negative pressure requireroent as stated. TVA has identified this discrepancy and prepared a PRD to resolve it. Redundancy in the system assures that tne safety function of the system is satisfied via automatic transfer to the backup unit on a low diffloW in the affected filter trai REFERENCES:

,

- 10CFR100 Appendix A, Seismic and Geologic Siting Criteria for Nuclearflants

- 10CFR50, Appendix A, General Design Criteria for Nuclear Power Plants

- 10CFR50., Apaendix B, Quality Assurance Criteria for Nuclear Plants and :uel Reprocessing Plants

- 10 CFR 50.49, Environmental ualification of Electric Ecuipment Important to Safet for Nuclear Power Plants

- AhSI N510-1975, Testing of N clear Air-Cleaning Systems

- Regulatory Juide 1.29, Seismic Design Classification (August 1973)

_ _ ,, .. .. .

.i....--. . _ . . . . - - _ _ _ _ _ _ _ . _ . _ _ _ . _ _ _ .

.

.

'

. .

and Maintenance

- Regulatory Guide 1.52,Cleanup Criteria for Atmosphere Design,System Testing, Air Filtration and Adsorption Units of Light Water-Cooled Nuclear Power Plants (June 1973)

- IEEE 279-1971 Criteria for Protection Systems for Nuclear PowerGeneratIng Stations

- IEEE 323-1974, IEEE Standard for Qualifying class 1E Equipment for Nuclear Power Generatin

- TVA Drawing Series-47E235 g Stations Environmental Data

- TVA Drawing Series-47W494 - Fire Protection Compartmentation

- Memorandum form H. B. Rankin to J. P. Vineyard (501850402973-NEBCalculation)

- NCR WBNMEB8504 , TI-ECS-95 (NEB 850115 235)

Nuclear Safety Criteria for the Design of

- ANSI N18.2, Pressurized Water Reactor Plants, (August 1970 Stationary draft)

endix R Fire Protection Pro-10CFR50ApbperatingPriortoJanuary1,gramforNuclearPower Facilities 1979

- 10CFR50, Seismic Class II Mechanical and Electrical EquipmentAppendix F Qualific Testin and Balancing of

- TVA Construction Heating, Ventilatin Specification

, and Air-Condit G-37,ioning ystems

- TVA Mechanical Desi n Standard DS-M18.6.1, dentificatiun of Mechanical Safety-R lated Systems and Components

- SON-DC-V-3.2,ing Afr-Condition SystemsClassification of Heating, Ventilating, and

- SQN-DC-V-21.0, General Design Criteria for Environmental Design

- S(.N-DC-V-12.2 Separation of Electric Equipment and Wiring

- SC N-DC-V-13. Auxiliary Building Ventilation and Cooling

- S( 'N-DC-V-2.16 ElectricalSele$ingleFailureCriteriaforFluidand ty-Related Systems-SQN-DC4-26.2,EnvironmentalQualificationof10CFR50.49 Ecluipment

- 5(N-DC-V-7.6, Sicnaling Systems Design for FireCriteria Alarm and for Probupervisoryrietary Protection

- SC'f-DC-V- S('N-DC-V-19.1,FireProtectionSystemsPostaccident Monitoring Criteria

- S('N-DC-V-11.2, 125 Volt Vital Battery System

- SC'N-DC-V-11.2.1 125 Volt Fifth Vital Battery System

- S('N-DC-V-11.6 120VoltACVitalInstrumentPowerSystem

- S(N-DC-V-11.4.,1, Normal and Emergency AC Auxiliary Power Systems ReactorBuildingEnvironmentalControlSystem(RBECS)

(1) The containment air return fans automatically activate by a phase B containment isolation signal. The capability of manual operation is also provided. No issues were icentifie ._

_ _ _

f'

e

(2) The RBECS air handling unit fans automatically trip off on a phase B containment isolation signal. Automatic diesel loading is not required; however, the capability for manual operation during aostaccident recovery periods exists. No issues were identifi e (3) All primary containment isolation valves are equipped with position indication switches and remote handswitche Exhaust air flow rate in the purge system is monitored. No issues were identifie (4) Both containment air return fans start ten minutes after receipt of a phase B containment isolation signal. In addition each fan has manual control capability from the main control, room (MCR). No issues were identifie (5) RBECS air handling unit fans have remote manual handswitches with indication in the MCR. No issues were identifie (6) Each of the containment air return fans is direct drive vaneaxial, and 100 percent capacity. Each is capable of removing at least 40,000 cfm of air from the upper com against a static pressure of 5 inches water cauge (inpartment wg) in order to keep the non-return dampers and ice conJenser inlet doors open following blowdown. No issues were identifie (7) The main duct associated with each containment air return fan is quipped with a non-return or backdraft damper. These dampers are designed to prevent steam from by passing the ice condenser during the initial blowdown phase of the DBA LOCA or MSLB and can withstand a differential pressure of 12 lb/in29 They shall have a leakage area cf not more than two square Inches at the maximum differential aressure of 12 lb/in2g. The dampers are gravity-loaded such t1at they return to the closed portion upon loss of adequate fan suction pressur The licensee issued a PRD on the containment air return backdraf t dampers because the dampers were specified and received with a 4 in2 maximum leakage area. The inspector acrees with the conclusion reached by the licensee that the aiditional bypass leakage (0.028 ft2) is insignificant compared to the analyzed bypass margin of approximately 45 ft2, (8) Each containment vacuum relief unit consists of a vacuum relief valve, an isolation valve, and the necessary pipe and flange The vacuum relief valve is in series with, but upstream of the isolation valve. The arrangement includes sufficient space between the vacuum relief system and the shield building to prevent contact during seismic motion. Vacuum relief valves are

. . .

_ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ -

. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

.

. .

disc balanced, valve self-actuated, Isolation valves are horizontally-installed, elastomer seat, pneumatica swinginglly-operated butterfly valve No issues were identifie (9) The RBECS provides mechanical ventilation of the primary instrument room, and the shield building annulu containment}1as The system two 50 percent capacity air supply fans, two 50 percent ca)acity exhaust fans and two 50 percent capacity cleanup filter trains andanInstrumentroomsupplyandexhaust fan. NoissueswereIdentifie (10) All RBECS containment isolation valves shall be motor-operated type valves designed to limit leakage to at most 0.06 butterflyinch SCFH per of diameter at 12 lb/in2 differential pressure in their closed position. Similar type valves are mounted in each purge supply and exhaust air opening for the annulus and in eac1 of the systems main supply and exhaust ducts located exterior to the shield building. Each of the above butterfly valves is designed to fail closed and to be normally closed during purge system shutdow The licensee issued a PRD on the RBECS containment isolation valves because they are air-operated rather than motor-operate There is no safety issue involved since the air-operated valves meet the requirements of 10 CFR 50, Appendix (11) Debris screens are provided inboard of each interior isolation valve on both the supply and exhaust to prevent foreign material from restricting isolation valve closure. The screens consist of 10 cauge steel wire on 2-inch mesh backed by reinforcing bars. 7he screens are located at least one valve diameter away from the valve pivo A PRD was issued because three of the screens were Ncated within the one diameter clearance criteria. Since the screens were located further than 1/2 diameter away, na safety concern exists because all the valves in question are butterfl valves that require only 1/2 diameter clearance to open ful . A separate issue included in this PRD was the lack of bris screens en 4 of the RBECS lines (located in tile upper contain-ment). The drawing specified that screens be installed downstream of the valves. Screens downstream of the valves thejustifi-would cation not perform provided byathe screening licenseefunction, therefore,is to not install debr screens on these lines appears to be reasonable. The NRC review is not completed, however, this is not a restart issu (12) Each of the four RBECS air handling unit fans is direct drive, vaneaxial and capable of delivering 65,000 cfm of air against a minimum static pressure of 2.19 in-wg. Three of the four units

_

-

.

,

are required to provide adequate cooling during normal plant operation In addition any two units have the capabilit to deliver 1500 cfm into the pressurizer enclosure and provfde cooling throughout lower containment durin recovery periods. No issues were identified.g post-accident (13) All 3rimary containment isolation valves associated with CVRS and RBPVS are equipped with limit switches to indicate valve position in the NCR. Remote manual handswitches are provided for each isolation valve in the MCR so that they can be manually closed or opened. No issues were identifie (14) The vacuum relief valves associated with CVRS have position indication in the MCR. No issues were identifie (15) R8PVS supply and exhaust fans have remote manual handswitches located in the MCR. RBPVS exhaust air flow rate is monitored '

aid alarmed in the MCR when flow drops below the set point value of 14,000 cfm. No issues were identifie (16) The closing of the isolation valves associated with CVRS U initiated by sicnals from pressure switches independent of all ,

other system io issues were identified, i (17)Oneofthedieselgenerators(OG)roomfansstartsonaDGstart i signal and the standby fan starts on low flow or high tempera-ture signal. The diesel generator and electric panel fan starts when either of the two M room exhaust fans start. The muffler room exhaust fan starts on the DG starts. No issues were identifie REFERENCES

- SI-3 Daily, Weekly, and Monthly Logs Units 1 and 2-SI-256,CummulativeTimeThatContainmentPurgeSupplyand Exhaust Isolation Valves are Open, - Units 1 and 2

- SI-738, Lower Containment Vent Coolers Operability - Units 1 and 2

- SI-739, Lower Containment Vent Coolers Flow Verification Test Units 1 and 2

- 10CFR50.49, Environmental Qualification of Electric Equipment Important to Safety for Nuclear Power Plants

- 10CFR50, Appendix A, General Design Criteria for Nuclear Powerplants (July 1970)

- IEEE-279, Criteria for Protection Systems for Nuclear Power Generatinc (ESB 831213211)(1971)

-

NRC Regulatory Guice 1.52, Design, Testing and Maintenance Criteria for Post Accident Engineered-Safety-Feature Atmos-

)here Cleanup System Air Filtration and Adsorption Units of

.ight-Water-Cooled Nuclear Power Plants I

l

m ,

"

..- .

.

- ,

i

-

IEEE-323, General Trial-Use Guide for Qualifying Class IE l Electric E  :

Stations, (1971).

quipment for Nuclear Power GeneratingSupers:

(1974,thelaterdocumentmaybeusedforprocure-  !

ments after 1980

-

Mechanical Design Standard Identification of DS-M18.6.1, Mechanical Safetyl ti

- SON-DC-V-2.15 Containment Iso a on System Related$ystemsandComponents i

- 5(IN-DC-V-26.1, Combustible Gas Control System i

- S(lN-DC-V-21.0,, General Design Criteria for Environmental t Design (ESB831213211  !

-SQN-DC-V-3.2,GeneralDesignCriteria)fortheClassification t ventilating ofHeating45851008501} and Air-Conditioning

&

Systems (B l-SQN-DC-V-12.2,DesignCriteriaforSearationofElectric i Equ pment and Wiring, B42851030506) -

- S(iN-DC-V- &

-SC'N-DC-V-2.15DesinCriteriaforRadationMonitoringSystem Sin le Failure Criteria

- SC'N-DC-V-26.2, Environmental Qualification to 10CFR50.49  ;

- SC'N-DC-V-11.2, 125-Volt Vital Battery System

- SC'N-DC-V-11. Volt Fifth Vital Batter System  :

SC'N-DC-V-11.6,1, Normal and Emergency AC A!

-- S(!N-DC-V-1 System ,

- S('N-DC-V-1.0 General Civil Design Criteria  !

- S(!N-DC-V-27.$, Containment Spray System i 1 !

A sample of the following areas was reviewed for the ABGTS, l orEGTS,  :

CREV,ience exper review issues exist.and CV subsystems to determine if systemic op

}

(1) Employee Concerns CATO items which are specifically applicable j to the Unit 1 Ventilation Systems

!

The inspector reviewed all identified Emp'loyee Concerns files  !

that related to ventilation systems. The issues a)peared to be r aggressively reviewed and closures appear to be acequat The [

inspector had no further questions, j (2) Condition Adverse to Quality Requests (CAQRs) which were i applicable to Unit 1 or Unit 2 Ventilation Systems (from August t 1985topresent) {

t The following CAQR's were reviewed for adequate licensee  :

closur ;

i S('P 880254 SC'P 871696  ;

SQP870860

,

i

[

- - ,- - -. --

'

_ , - _ - - - . - , -

r--~ ,

.

.

.. .

'

E 35

!

S0P G70890 r

-

.< SCP 871696 SC'P 871656 SC'P 880388 i SC P 880354 l S( P 880366 t S P 880386 ,

S(P 880394 l

!

The inspector had no question (3) Outstanding preoperational test deficiency data which is applicable to Unit 1 or Unit 2 Ventilation Systems

[

The inspector reviewed the one outstanding preoperational test l deficiency remaining on the ventilation system. This deficiency !

dealt with the auxiliary building gas treatment system as it !

relates to the access control system for the 690 elevation !

service door entrance. The deficlency was written against the t outer door (A56) for the frequency with which the door brok The vacuum in the auxiliary building would cause the large door to slam shut causing door failure on a frequent basis. This door i is not part of the auxiliary building secondary containment !

boundary but is the outer air lock door and is interlocked with ;

the inner door A57) which is the boundary. The outer door as :

originally desig(ned did not have a personnel access door built i into it and required opening and closing continually. ECN L5855 i has since installed a smaller personnel access door in the outer i door which has improved the situation considerably. Although !

the ECN is not closed, the inspector considers that the i remaining enhancements do not have any effect on Unit 1 startup or two unit operatio [

,

(4) Industr Nuclear Ex erfence Review (NEk issues eci !

a)plicafle to the Ukit 1 or Unit 2 Ventifation Nefe: SysY

i

fromAugust1985topresent), i

!

-

Information Notice 86-076, Problems Noted In Control Room i Emergency Ventilation Systems i IEN 87-076 discussed common problems noted in control room emergency ventilation systems during NRC industry-wide f reviews of TMI item 111.0.3.4. The licensee revised plant ;

3rocedures to further test control room leakage and to i Setter seal certain system j

.

The inspector found the licensee's response to be adequate.

i

.

!

!

L - - - - -.- - -_ . - - - >

, .-_ - _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ __ _ _ _ .

_

. .

.

36 i i

k

-

SER 85-34, Water leakace into a control room panel due to r the inadvertent actuat'on of the control room heating, I venti!ationandairconditioning(HVAC)delugesyste l No issues were identifie I

-

GE SIL 421 Effects of HVAC Failure f

GE SIL 421 discusses potential problems with control  !

equipment caused by increased temperature environments i should the HVAC fail. TVA revfewed the Sequoyah design and  !

determined that- t

  • I Heat loads in the main control room and the auxiliary instrument room allows time to repair chiller packages ,

should a failure occu i

,

  • Sequoyah has independent trains of HVAC which allows i the redundancy necessary to ensure proper cooling of ,

equipmen !

Therefore, the lice,see determined that no action was require f The inspector determined that this appeared to be adequat [

(5) Potential Reportable Occurrences Applicable to Unit 1  ;

Ventilation Systems  !

[

The inspector reviewed the licensees files for all Potential  ;

EGTS and CREV tystem Reportable Occurrences Particular attention was paidfor the to the ABGTS,PR0s that were determined  !

to be not re ortable. The insoector requested more details on  ;

the followin PR0s: 8751032, 8768556, and 8789612 because the PRO either i entified potential restart items regarding system e flow rates, an outstandin operability determination, g lab report that rendered anor an outstandinI!

that could have impacted restart. The inspector reviewed the j outstanding documentation and found no instance where a i condition existed that would preclude restarting Unit 1 due to  !

an operability deficiency of the ventilation system [

5. Balance of Plant

)

The inspection of Balance of Plant was not intended to be compliance  !

oriented. This is primarily due to the absence of prescriptive i recuirements applicable to B0P syster!.s. Rather the intent was to perform  ;

a 'imited review of actions by the licensee in, response to B0P problems  :

and assess the licensee position concerning BOP systems and equi) men [

This assessment is based on a review of selected events involving 30P, 80P  :

related procedures, reports and interviews with plant personne The

,

. _ _ . _ _ - . _ _ - _ _ ._ _ _ _ _ _ _

.

.

l

review was primarily centered around the maintenance area. In support of an evaluation of the readiness for Unit 1 to startup, a review was also made of the outstanding B0P work request The licensee appears to be satisfactorily addressing the 80P operations at the plant and is placing en increasing emphasis on addressing its problems and im) roving performanc Management recognizes the impact that BOP o)erations can have on overall plant operation, but yet it is still o)vious that safety-related equipment is still of primary concern and obtaining the most attention. Plant performance will indicate whether adequate attention is being given to B0P. One indicator is the number of reactor trips. Since restart of Unit 2 in May 1988 three of the five i

reactor trips are directly attributable to BOP equipm,ent or operatio A review of the events has shown that the root causes are not directly

related. The root cause analyses reviewed were thorough and well prepare A good understanding of the events was evident and the recommendations appeared in depth and satisfactory. It was also noted that the root cause analysis program has also been used on strictly B0P

, events not associated with a reactor trip, specifically the condensate

'

piping water hammer problem.

'

Regardng B0P maintenance activities, SQM-2, Standard Procedure Main-tenance . Management System, establishes the methods and responsibilities for managpq and tracking the implementation,, planning, scheduling and coordination, execution and post work evaluation, control and documento-tion of maintecance work activities. The procedure is written for all plant work, however within the procedure, numerous distinctions and

allowances are made for activities depending whet $er they are safety-1 related or non-safety-related. An example of the implementation of these allowances for B0P work are in work requests B279393, B794724 and B20967 Those work requests involve maintenance on Unit 1 condensate booster pumps and motors.

The work request packages are basically prepared by a planner who s)ecifies the work instructions, materials and post maintenance testing.

l Tie requirements depend upon the jud i for the condensate booster pumpwhich work,gment and knowledge was determined properly to beof the plann

{ non-safety-related, no quality assurance coverage / approval was required, no formal engineering review was provided for no reference was provided

! to the vendor manual, and no material specification was documented.

. Reliance is placed on the planner, the craftsman and the foreman to ensure

the work is adequate and complete. Post saintei.ance testing in the work l package for pump 1A requires verification of proper operability and no l excessive leakage. Pump 1B testing requi;es verification of proper-

! o)erability and no leaks. Although the operations department concurs in

tie testing being complete, a lack of consistent requirements and specific l acceptance criteria is evident.

i

!

I

r ,

,

ss

,

.

l

,

Even though engineering does not get formally involved in the preparation l and review of B0P work packages, the licensee does have assigned system  !

engineers. Even though involvement in the work arocess is not formalized, 1 the system engineers appear to keep abreast of tie work in, and the status l their systems. A work control group, with personnel specifically i of,igned ass to B0P systems, has also been formed and is used to track and .'

coordinate on going wor The work process also inputs information into a maintenance failure trendina program. This program reviews the maintenance data and identifies components as being repetitive failures. This information is then passed on to the planner 3 or systems engineers to act on as appropriat The review of the condensate booster pump work requests indicates that work being performed on B0P is being documented. Besides the craftsmen specifying what work he has accomplished in writing, e configuration control sheet also is used to record all changes in equipment. The an housekeeping at a jobsite is also documentedjobsite did indicate It also appeared that good hous the general condition of the plan", was good during a walkdown of the condensate syste It was also observed that improvements made to one unit were being ap) lied to the other uni For example, changes required as a result of tie investigation into the Unit 2 trips are being incorporated into Unit 1 als Another example is the condensate booster puma repair The need for the repairs were identified during Unit 2 operations and the decision was made to inspect and repair the Unit 1 pu'nps prior to Unit 1 startu The licensee has also performed a review of its backlog of Unit I work recuests to determine which items are needed to be done for the different moces of operations, and which items are not required for startup. A review was made of those B0P work requests which the licensee determined were not needed for startup, and, of those items reviewed, no discrepancies were foun No issues were identified which would prevent the restart of Sequoyah Unit . Exit Interview The ins)ection scope and findings were summarized with the Site Director 198 The licensee acknowledged and mem)ers of the inspection his staff The finding on September licensee d 2,id not identify as of the material reviewed by the inspectors during this ins) proprietary ectio During any the inspection period, frequent discussions were held wit) the licensing manager and other managers concerning inspection finding F .

..

,

, .

39 List of Abbreviations (Units 1 and 2)

AI -

Administrative Instruction ALARA -

As low As Reasonably Achievable Am -

Americium ANI -

American Nuclear Insurers A0V -

Air Operated Valve AVO -

Assistant Unit Operator BFN -

Browns Ferry Nuclear Plant Bachelor of Science Degree CA0R

-

ConditionsAdversetoQuality(Report)

CCTS -

Corporate Commitment Tracking System CS -

ContainmentSpray(System)

CSSC -

Critical Structures, Systems and Components CVCS -

Chemical and Volume Control System DNE -

Division of Nuclear Engineering DNSL -

Division of Nuclear Safety and Licensing DPS0 -

Division of Power Systems Operations DSC -

Design Services Complex ECA -

Emergency Contingency Action ECP -

Engineering Critical Position EDN -

Engineering Change Notice E0P -

Emergency Operating Procedure ESF -

Engineered Safety feature Eu -

Europium FRG -

Functional Restoration Guideline Gd -

Gadolinium GET -

General Employee Training HP -

Health Physics IEB -

NRC Bulletin IFI -

(NRC)InspectorFollow-upItem IN -

NRC Information Notice IR -

Inspet.. ion Report IQR

-

IndependentQualifiedReview(er)

ISEG -

Independent Safety Enginee,ing Group LC0 -

Limiting Condition for Operat:on LER -

Licensee Event Report Maintenance Groups:

Electrical Instrumentation Mechanical MTE -

Measuring & Test Equipment Mode 2 -

Startup(lessthan5% power)

M,de 3 -

Heatup to 350*F or above Mode 4 -

Heatup above 200*F and below 35CSF MR -

Maintenance Request NER -

Nuclear Experience Review NMRG -

Nuclear Managers Review Group N) -

Neptunium NRC -

Nuclear Regulatory Commission

_ .

... .

O *

NSRB -

Nuclear Safety Review Board NSRS

-

Nuclear Safety Review Staff ONP -

Office of Nuclear Power OR -

Operational Review ORR -

Operational Readiness Review PAM -

Post-AccidentMonitoring(equipment,etc.)

-

PCM Percent-milli (0.00001)

Pm -

Promethium PMT -

Post Maintenance Test PORC -

Plant Operations Review Committee P0RS -

Plant Operations Review Staff PORV -

Power Operated Relief Valve PPM -

Part per Million PRD -

Problem Reporting Document PRO -

Potentially Reportable Occurrence Pu -

Plutonium QA

-

ualit Assurance QC

-

ualit Control RARC -

adiol gical Assessment Review Committee RBECS -

Reactor Building Environmental Control System REV -

Revision RHR -

ResidualHeatRemoval(System)

RO -

Reactor Operator RTD -

Resistance Temperature Detector RTP -

Resistance Thermal Power SAL -

Sequoyah Activities List SAR -

Safety Analysis Re) ort SER -

Safety Evaluation Report SIS -

SafetyInjectionSystem Sm -

Samarium SNPP -

Se uoyah Nuclear Performance Plan SOER -

Si nificant Operational Event Report SOA -

Sh ft 0)erating Advisor SPDS -

Safety )arameter Display System S(N -

Sequoyah Nuclear Plant SR0 -

Senior Reactor Operator STA -

Shitt Technical Advisor TACF -

Temporary Alteration Coange Form TROI -

Tracking and Reporting of Open Items (System)

TS -

Technical Specifications TSC -

Technical Support Center TVA -

Tennessee Valley Authority UHI -

Uner Head Injection (System)

URI -

(HC) 'Jnresolved Item VCT -

Volume Control Tank WCG -

Work Control Group

)