IR 05000327/1989018

Insp Repts 50-327/89-18 & 50-328/89-18 on 890606-0705. Violations Noted.Major Areas Inspected:Operational Safety Verification,Control Room Observations,Sys Lineups,Radiation Protection,Safeguards,Operations Performance & Housekeeping

ML20245K438
Person / Time
Site:	Sequoyah
Issue date:	08/10/1989
From:	Jenison K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20245K433	List: IR 05000327/1989018 ML20245K431 ML20245K436
References
50-327-89-18, 50-328-89-18, NUDOCS 8908210021
Download: ML20245K438 (22)

Text

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LReport.Nes.: 50-327/89-18 and 50-328/89-18' .' Licensee: Tennessee Valley' Authority- ,

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6N38 A Lookout Place

.e    1101~ Market Street  .

Chattanooga,.TN 37402-2801 Docket Nos.: .50-327 and 50-328 License Nos.: DPR-77 and DPR-79 4 > Facility Name': ~'Sequoyah 1 'and 2 Inspection Conducted: June 6 ' July 5, 1989- ._

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  -I'n spector: ~

I/ I K. .Jenison, j5enior . Resident Inspector Da e S'igned

Accompanying" Personnel:'P.Harmon,SeniorResidentInspector . j'., LD.' Loveless, Resident' Inspector

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Approved-by:

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8 Me b L. J./Wa~tson, Chief 9 /0 Datre Sitjnea- ~

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TVA Projects Section l'

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SUMMARY Scope: , g,

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  .This' announced inspection involved inspection effort by the Resident Inspectors in the area, of operational safety verification including control _ room l
  ~o observations, operations performance, system lineups, t radiation' protection,
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safeguards, 'and housekeeping Inspections. Other areas inspected included

  . maintenance:. observations,   surveillance' testing observations,    review of previous; inspection Sfindings, follow-up of events, review of licensee 11dentified items, and review of inspector follow u'p item ~
;  Results:

The areasi of.. Operational Safety Verification, Maintenance, and Surveillance ~ Observation . appeared. to' be adequate and the licensee was fully capable of

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supporting" current - plant operations. Operators _ were not aggressive in

,   resolving ' continuously alarmed _ indications. Maintenance activities at the       "
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craft and -first line supervisor level continued to improve. Weaknesses were identified in site ~ security; practice Maintenance Department, Site Licensing, Site 4 Secyrity, and Site Work? Control management were quick to ' ' e . respond and correct! weaknesses which were identified to the Operations management was. slow to respond'to plant conditions-in-two instances related to

, 3  ; ice' condenser temperature monitoring and cold leg accumulator level indication
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  :and in one of theLinstances responded in a nonconservative fashio PDR  ADOCK 05000327-Q    PDC

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Three violations were identifiea: The licensee failed to comply with TS 3.6.5.2.a in that with the ice bed temperature monitoring system not available in the main control room, the licensee did not determine, every 12 hours, the ice bed temperature at the local ice condenser temperature monitoring panel as required by the action statement. This is identified as VIO 327,328/89-18-03 (paragraph 3.a).

The licensee failed to comply with 10 CFR 50, Appendix B, Criterion XVI in that management did not take prompt corrective action when the Unit was not in compliance with TS 3.6.5.2. for ice condeser temperature i monitorin This is identified as VIO 327,328/89-18-04 (paragraph 3.c.). ' The licensee completed temporary plant changes to the ice condenser temperature monitoring system without performing an adequate review pursuant to the requirements of 10 CFR 50.59 as required by AI-9. This is

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identified as VIO 327,328/89-18-10 (paragraph 3.b).

Two non-cited violations were identified: NCV 327,328/89-18-05 for failure to supply licensed operators with updated i TS within an appropriate period of time (paragraph 4.b).

NCV 327,328/89-18-06 for an unattended protected area badge and key card left in the Unit I control room (paragraph 2.f).

Four Unresolved Items were identified: URI 327,328/89-18-01, concerning PMT on Unit 1 Cold Leg Accumulator Level Indications (paragraph 4.b).

URI 327,328/89-18-02, concerning Closures of Engineering Change Notices (paragraph 7).

URI 327,328/89-18-07, concerning Pressurizer Safety Valve Temperature High (paragraph 2.a).

URI 327,328/89-18-09, concerning Personnel and Package Monitoring - Corrective Action (paragraph 2.f).

One Inspector Followup Item was identified: IFI 327,328/89-18-08, concerning an individual chewing gum within the RCA (paragraph 2.e).

No deviations were identified.

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REPORT DETAILS Persons Contacted Licensee. Employees J. Bynum, Vice President, Nuclear Power Production

  *J. LaPoint, Site Director

! *C. Mason, Acting Plant Manager T. Arney, Quality Control Manager

  *R. Beecken, Maintenance Superintendent
  * Cooper, Compliance Licensing Manager D. Craven, Plant Support Superintendent
  *S. Crowe, Site Quality Manager R. Fortenberry, Technical Support Supervisor J. Holland, Corrective Action Program Manager
  *W. Lagergrin, Operations Superintendent R. Pierce, Mechanicai Maintenance Supervisor
  *M.'Burzynski, Site Licensing Staff Manager
  *R. Rogers, Plant Support Superintendent M. Sullivan, Radiological Controls Superintendent S. Spencer, Licensing Engineer
  *C. Whittemore, Licensing Engineer NRC Employees
  *B. Wilson,' Assistant Director for TVA Inspection Programs
  *J. Brady, Acting Sequoyah Section Chief
  * Attended exit interview Acronyms and initialisms used in this report are listed in the last paragrap . Operational Safety Verification (71707)

a., Control Room Observations The inspectors conducted discussions with control room operators and verified that proper control room staffing was maintaine The inspectors also verified that access to the control room was properly controlled, and that operator behavior was commensurate with the plant configuration and plant activities in progress and with on going control room operation The operators were observed adhering to appropriate and approved procedures, including annunciator response procedures for the on going activities. However, two instances of continuously alarmed indications with less than aggressive licensee response were identified and are addressed in

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URI 327,328/89-18-07, (paragraph 2.a) and NCV 327,328/89-18-05 (paragraph 4.b). The frequency of visits to the control room by upper management was observed and determined to be adequat The inspector also verified that the licensee was operating the plant ~ in a normal plant configuration as required by TS. When abnormal conditions existed, operators were generally complying with the appropriate LCO action statements except as discussed in this report j under URI 327,328/89-18-01 (paragraph 4.b) and VIO 327,328/89-18-03 (paragraph 3.c).  ; i The inspector verified that leak-rate calculations were performed and that leakage rates were within the TS limits. Indications regartling safety limits were reviewed and found to be satisfactor Tihe inspectors observed instrumentation and recorder traces for abnormali- i ties and verified the status of selected control room annunciators to ensure that control room operators understood the status of the plant. The Unit I annunciator, Pressurizer Safety Valve Temperature , High, was in continuous alarm for the entire inspection period. The ' licensee stated that this condition is the result of normally high ambient temperatures near the sensor and not an indication of pressurizer safety valve leakage. This is one of the alarms that is l included in the licensee's control room design review. The inspector

 - discussed the operability of an alarm that is in constant alarm status with Sequoyah plant management. The licensee agreed to pursue the issue with DNE in order to ascertain whether the setpoint could ,

be changed. Licensee personnel did not believe that the operability l of the alarm was questionabl The inspector will review this , potential high temperature condition and/or alarm operability issue i under URI 327,328/89-18-07, Pressurizer Safety Valve Temperature Hig Control room panel indications for nuclear instruments, emergency  ; power source, safety parameter display system and radiation monitors I were reviewed to ensure operability and operation within TS limits i and were found to be adequate. Control rod insertion limits were observed as specified in the T Control Room Logs i The inspectors observed control room operations and reviewed l applicable logs including shift logs, operating orders, night order book, clearance hold order book, and configuration log to obtain inform tion concerning operating trends and activities. The night order book has steadily increased in size over the last two month The night order book is not well organized and the sheer number of issues contained in it may become an administrative burden to the operators. This was discussed with the plant management and I operations management during the course of this inspection. The TACF log was also reviewed to verify that the use of jumpers and lifted , leads causing inoperabilities are clearly noted and understood. The !

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clearance hold order book was updated at the beginning of 1989 and new numbers were assigned to existing old hold orders. Though this renumbering resulted in better validation, it did not contribute to the reduction of older hold orders. No other issues were identified with these specific log Plant chemistry reports and daily Operations Department surveillance were reviewed. The chemistry data was reviewed to confirm tnat the licensee's steam generator tube. integrity program was being implemented through the control of secondary chemistr For a selected sample, primary plant chemistry was observed to be within TS limit The implementation of the licensee's sampling program was observe Plant specific monitoring systems including seismic, meteorological and fire detection indications were reviewed for operabilit Performance of daily surveillance was observed / reviewed to ensure compliance with TS. A review of surveillance records and the hold order log was performed to confirm operability of the RP No violations or deviations were observe c. ECCS System Alignment The inspectors walked down accessible portions of the following safety-related systems on Unit I and Unit 2 to verify operability, flow path, heat sink, water supply, power supply, and proper valve and breaker alignment: Intermediate Head Safety Injection (Units 1 & 2) Non-Essential Control Air (Unit 1) In addition, the inspectors verified that a selected portion of the containment isolation lineup was correc No deviations or violations were identifie d. Plant Tours Tours of the diesel generator, auxiliary, control, and turbine buildings, and exterior areas were conducted to observe plant equip-ment conditions, potential fire hazards, control of ignition sources, fluid leaks, excessive vibrations, missile hazards and plant house-keeping and cleanliness conditions. The plant was observed to be in an adequate condition with respect to cleanliness. Several floor areas in the auxiliary building were being chipped and resurfaced, which resulted in large amounts of dust and debri In addition, several lay-down areas were established for radiological waste. The inspectors verified that maintenance work orders had been submitted as required and that followup activities and prioritization of work

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was generally accomplished by the licensee. One instance in which work prioritization was questioned by the inspectors is discussed in URI 327,328/89-18-01 (paragraph 4.b).

The inspector visually inspected the major components for leakage,. proper lubrication, cooling water supply, and any general condition that might prevent fulfillment'of their functional requirements. All discrepancies noted were already being tracked by the license The inspector observed shift turnovers and control room activ4 ties and detercined that all necessary information concerning the plant systems status was addressed. One instance where plant information was addressed but may not have been complete is discussed in URI 327,328/89-18-01 (paragraph 4.b).

No violations or deviations were observe e. Radiation Protection The inspectors observed HP practices and verified the implementation of radiation protection controls. On a regular basis, RWPs were reviewed and specific work activities were monitored to ensure that activities were being conducted in accordance with the applicable RWPs. ~ Workers were observed for proper frisking upon exiting contaminated areas and the radiologically controlled area. Selected radiation protection. instruments were verified operable and calibra-tion frequencies were reviewed. The following RWPs were reviewed in detail: RWP 89-20-431, U2 Upper Containment. Perform SI-28 on dampers 2-30-543 and 2-30-55 The inspectors . reviewed and resolved an incident involving an NRC visitor who performed an excluded practice (chewing gum) within the RCA on June 26, 1989. The licensee properly identified to the visitor that this was a prohibited practice. This item will be tracked as IFI 327,328/89-18-08, HP Practice This issue was discussed with NRC ADSP management, NRC Region II HP specialists and the individual involved. No additional initial corrective actions ' are necessary and this item remains open for NRC HP specialist revie No violations or deviations were identifie f. Safeguards Inspection In the course of the monthly activities, the inspectors included a review of the licensee's physical security program. The performance of various shifts of the security force was observed in the conduct of daily activities including: protected and vital area access _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ -

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controls; searching of personnel and packages; escorting of visitors; badge issuance and-. retrieval; and patrols and compensatory post In addition,-. the inspectors . observed protected area lighting, and protected and vital area barrier integrity. The inspectors verified interfaces between the security. organization and both operations and maintenance. Specifically, the Resident Inspectors:

 (1). : observed emergency drills (2) ' reviewed licensee security degradations (3) ' visited -secondary and central alarm stations (4) verified protection of Safeguards Information On June 13, 1989 the insper. tor found- an unattended protected area badge and key card in the Unit I control room. The ASOS. paged the individual and returned the badge within- approximately two minute The individual had been working behind'the panels of Unit 2'and had not left the control room complex. The inspector reported this event to the Nuclear Safety Services Shift Supervisor. They investigated the incident and wrote security degradation ' report ~ 89-69-06 because the individual had lost control of his badg The event was in violation of the security plan, but will not be cited because the criteria specified in Section V.G. of the Enforcement Policy were satisfied. Treatment of this issue as a non-cited violation is appropriate because: the licensee took immediate corrective action, the. safety ~ significance was low, and this issue appears to ' be a single occurrence without programmatic implications. This item will
 .be tracked as NCV 327,328/89-18-06 and is close During the inspection period the inspector observed personnel and package monitoring going through the protected area entrance' .

Several times the inspector noted questionable search practices. The inspector discussed the specific problems with the site security manager. .He agreed that the issues should be addressed and ensured that corrective actions to improve these security practices were performe The corrective actions were documented in TVA memo Kelly / List SB1, dated June 30, 1989 and discussed with NRC Region II ; security specialists who agreed with the proposed corrective action ! URI 327,328/89-18-09, Personnel and Package Monitoring Corrective i Actions, will be reviewed during a future security inspectio No violations or deviations were identifie Conditions Adverse to Quality The inspectors reviewed selected items to determine that the licensee's problem identification system as defined in AI-12, Corrective Action, was functionin CAQR's were routinely reviewed for adequacy in addressing a problem or even Additionally, a sample of the following documents was reviewed for adequate handling: __

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a (1) Work Requests (2) Potential Reportable Occurrences (3) Radiological' Incident Reports (4). Test Deficiencies (5) Problem Reporting Documents (6) Licensee Event Reports (7) Security Degradation / Incident Reports For the items reviewed, the inspectors determined that the issues were identified and ccrrected in the appropriate manne No violations or deviations were observe Bimonthly' Inspections The licensee's use of overtime was reviewed to verify that it is consistent with the licensee's commitments to the NRC. Overtime use in the Operations Department. averaged approximately 10%, with no indication of evertime abuse. In addition the inspectors determined that required notices to workers were appropriately and conspicuously posted in accordance with 10 CFR 19.1 No violations or deviations were observe No trends were identified in the operational safety verification are Two instances occurred that were resolved in nonconservative manners as discussed in paragraph 3.and 4. General conditions in the plant were-adequate. Radiation protection and security were adequate to continue two unit operation . Surveillance Observations and Review (61726) Licensee activities were directly observed / reviewed to ascertain that surveillance of safety-related systems and components was being conducted in accordance with TS requirement The inspectors verified that in general: testing was performed in accordance with adaquate procedures; test instrumentation was calibrated; LCOs were met; test results met acceptance criteria requirements and were reviewed by personnel other than the individual directing the test; deficiencies were identified, as appropriate, and any deficiencies identified during the testing were properly reviewed and resolved by management personnel; sad system restoration was adequat However, one instance of an incorrectly completed SI is discussed in VIO 327,328/89-18-03 belo For completed tests, the inspector verified that testing frequencies were met and tests were performed by qualified individual The inspector observed the performance of SI-28, Containment Air Return Fans, on June 15, 198 The performance was well planned and was performed in accordance with an approved procedure. No deficiencies were l L

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p L " noted and the equipment was returned to service in an expeditious manne ' The inspector had no further question The inspector. reviewed - the performance of SI-477, Backup Ice Condensor

'Monitorir  and the following documents.were reviewed to gather informa-  ,

ing to ice bed temperature monitorin ~ tion per PRO 2-89-87, Ice Condenser Monitor SI-2, Shift Log  ! WR B265910 Ice Bed Temperature Recorder 2-TR61-138 IMI 134,. Configuration Control . FSAR section 6.2. l Drawing TVA 45N2618-3 i Drawing Westronics D37075  ! Vendor. Manual SQM-VTM-W130-0010  ! AI-47, Conduct of Testing l AI-9, Control of Temporary Alteration !

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On June 24, 1989, the inspector noted that the Unit 2 ice condenser  :, monitoring system temperature recorder (2-TR-61-138) failed to read or

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record points 25 through 27, that WR B265910'had been written to address this problem, and that TS LCO 3.6.5.2 had been entered. The WR addressed  ! acceptable methods of repair for the recorder and stated that' the l technician was to ver'#y the recorder calibration, if required, per j calibration cards; update calibration cards; and, ' perform - SI-477 if  ! necessar As a result of this maintenance activity it' was determined  ; that the recorder was inoperab'e because of: a failed relay - APP 277W - j C205 A16. A replacement rela, was not immediately= available and the WR l was'placed into a material availability hold statu i In addition to the maintenance activity that identified the failed relay, I SI-477 was -partially performe The partial performance of SI-477 by using a portable measuring and test equipment (M 'and TE) Fluke digital monitor indicated that the ice bed temperatures were all less than the TS l required 27 F. The AI-47 chronological test log stated that SI-477_ was ' stopped based on a request from operations to use the Fluke digital monitor as a replacement for recorder 2-TR-61-138. After interruption of SI-477, the SOS /ASOS utilized the Fluke digital indicator as a substitute  ; for the ice bed monitor recorder 2-TR-61-138, and TS LC0 3.6.5.2 was-incorrectly exite The inspector reviewed the following aspects of this plant condition: Ice Bed Temperature Monitoring System Operability in the Control Room /TS LCO 3.6.5.2.a Action Statement Requirements FSAR Section 6.2.1.5 describes temperature monitoring and states that temperature sensors are distributed throughout the ice bed of the ice condenser. These temperatures are monitored and recorded in the instrument room inside containment. Selected channels are displayed on a recorder in the main control room and provide actuation signals

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b 8 for- the' annunciat' ion at preset' deviations from the procribed limits

    ' of the ice bed equilibrium. temperature On June 24,~1989 the inspector determined that the' Fluke digital 1  - indicator which was temporarily installed was incorrectly takenlas an acceptable. temporary substitute for the ice bed monitor recorder. The inspector brought this information -to the attention of the licensee.

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  .At this point'the plant had. operated outside the monitoring require-
  .ments of_LCO action statement 3.6.5.2.a for approximate 1y'49. day Action' statement-3.6.5.2.a requires that with the ice bed' temperature -

indication ~ not available- in the main control room, the ice bed temperature must be determined at the local ice condenser temperature-monitoring panel every 12 hours. Failure to comply with the action

  : statement- of TS 3.6.5.2.a is' a violation and is designated as VIO 327,328/89-19-0 CFR 50.59 Safety Evaluation The FSAR section' referenced above, describes the Ice Condenser Monitoring system and the ice bed temperature indication available in-the control room. 10 CFR 50.59 states that the licensee may make changes in- the facility as described .in the safety analysis report without prior Commission approval unless the proposed change involves an unreviewed-safety' question or a change inthe technical specifica-tions incorporated in the licens 'AI-9'is the site approved process that controls temporary changes to plant equipment. AI-9 is required to bs used for safety related systems ' and ~ provides requirements- for installing,. controlling, returning to normal, and documenting temporary alteration It further states that temporary alterations that are positively identified and controlled in other plant approved ' instructions are excluded from the requirements of AI-9 provided the. instructions meet certain criteri In the case of the control room ice bed temperature monitor / recorder the licensee determined that the installation of the Fluke digital indicator using SI-477 was an acceptable method to temporarily modify the plan However, SI-477 does not meet the timeliness or safety criteria of AI-9. No safety review as required by SQA-119 was
,,  performed-to determine if the replacement of the control room ice bed monitor with tne Fluke digital indicator constituted an unreviewed safety question. AI-9 also states that for temporary - alterations that are installed on equipment that is out of service and normally excluded from the requirements of Al-9; if the instruction is complete or cannot be completed and the temporary alteration must remain installed, the temporary change shall be documented and controlled by Al- SI-477 was not intended to be a vehicle for
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l . controlling a temporary or permanent plant modification and states in section.1.2 that the procedure shall- be performed when the primary-Ice Bed Temperature Monitor, 2-TR-61-138, is inoperable or to verify . operabilit In addition SI-477 acknowledges the need to perform local temperature indications in accordance with TS LC0 action 3.6.5. Failure to control a temporary alteration resulting in failure to perform an adequate review pursuant to the requirements of 10 CFR 50.59 for changes to the Ice Condenser Temperature Monitoring system is a violation and is designated as VIO 327, 328/89-18-1 Adeauate Corrective Action and Line Management Activities Although the ice bed temperatures were not being monitored locally, temperature readings were taken every eight hours using the Fluke digital indicato These readings were consistent with plant conditions and appeared to be within TS 3.6.5.2.a requirements. The inspector discussed the issue with the on-shift SOS /AS0S on June 24, 1989. The SOS determined that he should be in the LC0 and stated that he would enter i On June 25, 1989 the ice bed temperature monitoring system operabii issue was discussed with the Operations Superintendent and the actine Plant Manager. The plant had still not entered the LCO. The Operations Superintendent stated that he believed that the LCO should be entere On' June 26, 1989 the issue was again discussed with the Operations Superintendent, the acting Plant Manager, and the Vice President, Nuclear Power Production. Each of the managers acknowledged that the LC0 had not been artered and took the position that the condition of the plant was acce, .able without entering the LC On June 29, 1989 the issue was discussed with the Site Director, who had not been present at the site during the previous 5 days. The Site Director and the on-shif t SOS took quick corrective action and the LCO was entere On June 30, 1989, a conversation was held with the Site Director, acting Plant Manager, and Operations Superintendent. During this conversation it was confirmed that the licensee had still not performed a safety and/or technical evaluation in accordance with 10 CFR 50.59 nor had the licensee determined if the affected plant system was technically reliable with the temporarily installed equipmen The resident inspector had discussed the need for such an evaluation with the acting Plant Manager and the Operations Superintendent on several occasions throughout the previous wee CFR 50, Appendix B Criterion XVI, states that measures shall be established to assure that conditions adverse te quality such as failures, malfunctions and defective equipment, and nonconformances _ _ _ _ _ - _ - _ _ - _ _ - _ _ _ _ _ - - - _ _ _ -

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are.promptly identified and corrected. Licensee management. failed to take prompt corrective action from June 25 to 29, when presented with the information that the unit was not in compliance with TS 3.6. and failed to promptly perform a 50.59 evaluation as of June 30, 1989. This is a violation and is designated as VIO 327,328/89-18-04, Failure to Take Prompt Corrective Actio Additional weaknesses associated with the above event were: While using the _ digital Fluke monitor to take the place of the installed ice bed temperature monitor 2-TR-61-138, the data sheets .for several performances of SI-2 indicated that temperature readings were taken from 2-TR-61-138, when in fact the temperature readings were taken from the digital Fluke monito Corrective action for the above violations should include resolution of the incorrect entries in these QA record After review of the appropriate electrical drawings, the inspector determined that the digital Fluke differed from the installed control room ice bed temperature monitor in that no alarm or annunciation function was provided by the digital Fluke, no permanent record was produced by the digital Fluke and the process of point selection was a manual process on the Fluke as compared to automatic circuit selection on the installed ice bed temperature monitor. The temporary monitor was electrically similar to the permanent monitor with the above exception During the period May 4,1989 to June 29, 1989, there is no documentation that a local indication was taken at the local ice condenser temperature monitoring panel in accordance with TS 6.5.2.1 action a. The electrical indications received by the digital Fluke were not electrically the same as those that would be measured at the local panel. The local panel reads directly from the RTDs and the digital Fluke reads through a feedback point selection circuit that includes switching diodes, a card selecting resistance network and a reed switch. The indications taken through the use of the digital Fluke meter appeared to have been reliable and indicate that there were no concerns about the operability of the ice condenser itself, with respect to temperatur There is no indication on the IMI-134 configuration control i sheet or the AI-47 chronological log of what trouble shooting or L maintenance activities occurred other than the partial performance of SI-477. This procedural consideration should be included in the response to violation 327,328/89-18-0 SI-477, contains inaccurate instructions in that it refers to a TS LCO action that does not exist (i.e., 3.6.5.2.c). In addition, the licensee failed to follow SI-477 instructions when Appendix A was performed vice Appendix SI-477 requires

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    -11 l  ' Appendix B' be performed when the Ice Bed Monitor system i i noperabl e'. These procedural considerations should be ' included l  in the . response .to violations- 327,328/89-18-03 and 327, 328/89-18-1 No trends-were identified in the area of surveillance performance during
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this inspection period. However,- the practice of 'using sis, which '. are intended 'to support a temporary testing' activity, to perform plant-modifications' was identified as a weakness in the licensee's temporary modification / alteration process implementation. The area of surveillance scheduling-and management was observed to be. adequate and the completion of TS' surveillance requirements was accomplished in an acceptable manne . . Monthly. Maintenance Observations and Revies (62703) Station maintenance activities on safety-related systems and components-

 .were observed / reviewed to ascertain that they were conducted in accordance with approved procedures, regulatory guides, industry codes and standards, and'in conformance with T The following . items were considered during this , review:  LCOs were met while components or systems were removed from service; redundant components were operable; approvals were obtained prior to. initiating the work; activities were accomplished using approved procedures and were inspected as applicable; ' procedures _ used were adequate to control the activity; troubleshooting activities were controlled and the repair records accurately reflected the activities; functional testing and/or calibrations were performed prior to returning components or systems to service; QC records were . maintained; activities were accomplished by qualified personnel; parts and materials used were properly certified; radiological controls were implemented; QC hold points were established where required and were observed; fire prevention controls were implemented; outside contractor force activities were controlled in accordance with the approved QA program; and housekeeping was actively pursue Temporary Alterations (TACFs)

The following TACF was reviewed: 1-88-23-30, Unit 1 Upper Containment Space Heater Thermostat No violations or deviations were identifie Work Requests L The following work requests were reviewed: WR B790747,1-FS62-11, #3 RCP Seal Flo The inspector reviewed and observed portions of site action plan 6-23 designed to reduce the seal flow on the #3 RCP seal. The

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licensee adjusted b pressure, seal injection flow and seal injection temperature in an attempt to reduce excess. saal- flo Lower bearing temperature, standpipe level, and RCDT level were mes,tore The licensee worked closely with the pump manufacturer who had two technical representatives on site during these activitie Seal flow was reduced to acceptable limits and no pump damage is indicated. These activities were well planned, managed and implemente WR B283529 Reactor Head Vents This WR was written to repair an indication of high temperature on the vent line. This plant indication was in continuous alarm. However, no other plant indications support this alarm as a true plant condition and support the licensee's determina-tion that there is an indication proble The inspector discussed the operability of the indication with the ASOS in consideration that it was in continuous alarm. The licensee did not concur with the inspector that there was a question on the operability of the alarm and annunciato On June 25, 1989, while reviewing this alarm, the inspector attempted to review TS 4.11 for the head vent system. TS amendment 116 had not been entered into either copy cf the Technical Specifications located in the control room h t athoe are The amendment was issued by the NRC on June 1, ..:9; received by TVA on June 8,1989, received on site on June 13, 1989; and was in the STA's in-box for review on June 25, 198 The inspector determined that the TS amendments were still outstanding on June 27, 1989, after discussions with the Operations Superintendent on June 26, 1989, and the SOS and STA on June 25, 1989. In response to the inspector's questions, the site licensing manager issued PRD SQP 890391P to resolve both the individual problem with TS amendment 116 and the programmatic aspects of the licensee's TS amendment process (SQA-30, Responsibility for Technical Specification Amendments and Operating License Changes). Failure to supply the licensed operators with updated TS within an appropriate period of time is a viciation of Appendix B, Criterion VI, Document Contro This will be tracked as Noncited-violation 327,328/89-18-05 and will remain open until licensee SQA-30 programmatic reviews are complet This violation is not being cited because the criteria specified in Section V.G. of the Enforcement Policy were satisfied. It is appropriate to categorize this issue as an NCV because of the immediate low safety significance and the long term programmatic corrective action being pursued by the site licensing staf This item remains open.

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WR'B265348, DG 2A1 Immersion Heaters 'i During :the review / observation' of the immersion ' heater . relay ._ maintenance,'the following documents were reviewed:  ! M and AI'9,-Tightening, Inspection _'and Documentation of.- Bolted Connections M and AI 7, Cable Terminations . .

 - MI 6.20, Configuration' Control Duri_ng Maintenance   !
   

Activities . L ' SQM 2.2, Maintenance Management System Troubleshooting Form _575 -.5889020989; i These activities were well planned and implemnte The 1-documents indicated good. communication between.the maintenance technicians _and the planners.when questions arose about what was j an appropriate : post maintenance'_ test. The inspector. had no ' question l WR B252551, 1-FCV38-110, Auxiliary Control Air to Unit 1 l-Isolated Due to Faulty Solenoi ] On June 15,.1989, WR B252551 was written to correct a perceived

. problem with the 1-FCV-38-110 valve drifting closed and causing loss of air to inside containment. . During this event, which required entry into TS LC0 3.6.4.1 and 3.6.1.1,   several j

_ additional problems aros On June 16, 1989_ at approximately 9:50 a.m., Unit 1_ lost' j portions of .non-essential control air as evidenced by six radiation monitor isolation valves going closed and the~other _1 two drifting close A containment ventilation isolation signal was not generate The licensee determined after several hours that .the 1 1-FCV-38-110 valve was actually operating properly in response i to low air pressure in the syste This was caused by an isolation valve being only 1/9 open and a heavy demand on the system at the tim Throughout the event the operators and licensee management responded in an adequate and professional manner. The licensee is still investigating the cause of the throttled isolation valv With respect to this maintenance i activity, the inspector had no further questions. The inspector  ! will review the root cause evaluation when the licensee's investigation is complet I WR 790932 Unit 1 Cold Leg Accumulator Level Indication i i The inspector commenced his review of the work activities concerning Unit 1 CLA level indication 1-LT-63-82 on June 19, 198 On June 22, 1989, the information requested by the I

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inspector concerning ,a PMT was supplied' by a Work Control n supervisor. The PMT had been completed - and the results were unacceptable. The completed PMT indicated that there was a high ,,

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probability that the remaining -CLA lev'el indicator, 1-LT-63-60,

 .was not- accurately indicating CLA level. Indicator 1-LT-53-60 was being used as the sole level' indication and means to' comply y  with TS 3.5.1.1. ~ The inspector discussed this concern with the Site Director and the Operations Superintendent. _ The inspector determined that the below listed sequence of events occurred:

Date Time Discussion 5/7 ---- WR 790932 was written because of the disparity-r between channels 1-LT-63-82 and 1-LT-63-6 The operato_rs had filled the #4 CLA several times during. previous shift Because of plant conditions and the . best - professional judgement ' available to the SOS /ASOS at the time, 1-LT-63-82 was declared inoperabl /22 0000 Work was. commenced on 1-LT-63-8 Despite the

  . fact that this was a control- room WR and the licensee announced its intention to reduce the number of control room WRs, the inspector discovered that this particular WR had been
  ' downgraded from a priority 3 '(work within three days),. rescheduled' and  replanned. . These (   . activities' had resulted in a delay of.' approxi-mately 44 days.

m 6/22 1300 IM technicians. completed transmitter maintenance and PMT activities for 1-LT-63-8 These activities-indicated that channel 1-LT-63-82 was accurately indicating CLA level and that it differed from channel 1-LT-63-60 by 11%. This difference between the channel indicated levels (functional test) resulted in a failed PM /22 1530 The auxiliary instrument room rack' portion of the loop calibration was completed by the IM technicians to ensure that 1-LT-63-82 was accurate. The' discrepant channel information was communicated to the oncoming S0 /22 1600 The SOS discussed with the acting Plant Manager plant conditions and the possibility that entry into the TS LCD for CLA #4 operability may be required. At the time of this discussion it was believed by the SOS that if 1-LT-63-82 was

  ' determined to be operable, a high level condition
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  (in excess of TS) in the CLA would be indicated and entry into LCO 3.5.1.1 would be required.

i 6/22 1749 The SOS, maintenance personnel and the work group reviewed the work package in the control roo Level indicator 1-LT-63-82 was determined to be reading correctly based on a channel calibration completed at 1530, but was. still considered inoperable because the PMT requirements for the channel check could not be me Leve transmitter 1-LT-63-60 was then declared inoperable based on the channel check and confidence in the loop calibration for level transmitter 1-LT-63-8 Because neither transmitter could be determined to be operable, LCO 3.5.1.1. was entered for CLA inoperability due to a lack of all level indicatio This issue will remain open to determine at a minimum the following: The acceptability of not performing the required mainter.ance activities for approximately 44 day * Whether or not there is a reticence on the part of plant management to take conservative technically based actions when plant conditions indicated potential entry into TS action statement Whether the requirements of AI-47, and AI-12, were met during the performance of these activitie In addition, the difference between the information that was available to the SOS at 1:00 p.m., 3:30 p.m., and 5:49 p.m., and when 1-LT-63-60 was declared inoperable will be reviewe Whether the PMT was adequat What process allowed and provided for the loop calibration of the rack and the transmitter portions of the level instrument Whether the CLA exceeded level requirements between May 7 and June 2 This will be tracked as URI 327,328/89-18-0 . _ _-________ -____________-_ ___-_ _ ___--___-_- _

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A y -l u 16 Management' Activities in Support of Plant' Operations TVA< management activities were' reviewed on a' daily basis by the NRC inspectors. Resident Inspectors ' observed that planning, <,.:heduling, work control and other-management meetings were effective .in controlling plant-activities.- First 1.ine supervisors appeared to ~ be - knowledgeable and'

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involved in the day to day activities of the plant. 'First line supervisor involvement in the field was observed. Operations management and plant management response -to two plant events that occurred during this-inspection period was slow cand 'in one instance was nonconservativ These events are discussed in paragraphs 3 and 4 of this report. Finally, the Site . Director's response to the two' plant events was quick and effectiv ; Site Qualit'y Assurance Activities in Support of Operations During the ' inspection period, the site QA staff performed audits, inspections,-and reviews. These issues were reviewed by the inspector and found 'to be adequately . resolved by the licensee. The ,following audits

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were performed: QSQ-M-89-606- Radioactive Waste Solidification Process Control Program QSQ-M-89-682 Plant Material Condition QSQ-M-89-620 Operator Aids QSQ-M-89-612 Special Monitoring - NER 890156 QSQ-M-89-688 Maintenance Performance QSQ-M-89-656 CCTS Verification In addition to the above audits, the inspector discussed several recent issues. with the Site QA Manager and the QA Surveillance Group Manage .The inspector determined that QA involvement in these issues was adequat . ECN Backlog Closure (92701) The inspector reviewed licensee corrective actions intended to reduce a backlog of ECN closure package By letter dated February 3,1987, the licensee committed to close an ECN backlog of " work complete" ECNs j numbering approximately 1150. This work was to be completed on l October 15, 198 i ! The inspector reviewed this closure effort and determined the following: Neither the licensee nor the NRC ransiders the commitment complete as of July 5, 198 Series 2000 ECNs were closed by DNE under a previous design proces Verification did not require that plant actions were complet _ _- - - _ _ . -- ____ x _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ __________________-__-___

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f l Approximately 52 ECNs were substituted for ECNs on the original list l of IJ50 that were difficult to close.

l The licensee had not accounted for approximately 200 additional ECNs from the original 1150 ECNs.

l At least 17 ECNs were cancelled or voided and were not completed or close These issues will be reviewed as URI 327,328/89-18-02, Completion of Old ECN Closure . Exit Interview (30703) The inspection scope and findings were summarized on July 6,1989, with those persons indicated in paragraph The Senior Resident Inspector described the areas inspected and discussed in detail the inspection findings listed belo In addition the strengths and weaknesses identified at the end of each report section were discussed. The licensee acknowledged the inspection findings and did not identify as proprietary any of the material revieved by the inspectors during the inspectio Inspection Findings:

   (0 pen)  URI 327,328/89-18-07, " Pressurizer Safety Valve Temperature High" (0 pen)  IFI 327,328/89-18-08, "HP Practices" (Closed) NCV 327,328/89-18-06, " Unattended Badge and Key Card" (0 pen)  URI 327,328/89-18-09, " Personnel and Package Monitoring Corrective Actions" (0 pen)  .VIO 327,328/89-18-03, " Failure to Comply with TS 3.6.5.2 Action a, Ice Condenser Temperature Monitoring System Operability" (0 pen)  VIO 327,328/89-18-10, " Failure to Perform a Plant Change in Accordance with 10 CFR 50.59" (0 pen)  VIO 327,328/89-18-04, " Failure to Take Prompt Corrective Action" (0 pen)  NCV 327,328/89-18-05, " Document Control for TS Changes" (0 pen)  URI 327,328/89-18-01, " Cold Leg Accumulator Level Indication" (0 pen)  URI 327,328/89-18-02, " Completion of Old ECN Closures" i

During the reporting period, frequent discussions were held with the Site l Director, Plant Manager and other managers concerning inspection finding l

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l' l 1 ' List of Acronyms and Initialisms ABGTS - Auxiliary Building Gas Treatment System ABI- - Auxiliary Building Isclation AESCE - Auxiliary Building Secondary Containment Enclosure AFW - Auxiliary Feedwater AI- - Administrative Instruction A0I - _ Abnormal Operating Instruction AVO - Auxiliary Unit Operator AS05 - Assistant Shift Operating Supervisor ASTM - American Society ofLTesting and Materials BIT - Boron Injection Tank BFN - Browns Ferry Nuclear Plant C&A - Control and Auxiliary Buildings CAQR

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Conditions Adverse to Quality Report CCS - Component Cooling Water System CCP - Centrifugal Churgina Pump

  'CCTS  -

Corporate Commitment Trackino System CFR - Code of Federal Regulations COPS - Cold Overpressure Protection System CS - Containment Spray CSSC - Criticci Structures, Systems and Components CVCS - Chemical and Volume Control System CVI - Containment Ventilation Isolation DC - Direct Current DCN - Design Change Notice DN Division of Nuclear Engineering ECN - Engineering Change Notice ECCS - Emergency Core Cooling System EDG - Emergency Diesel Generator EI - Emergency Instructions ENS - Emergency Notification System E0P - Emergency Operating Procedure EO - Emergency Operating Instruction

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Essential Raw Cooling Water ESF - Engineered-Safety Feature FCV - Flow Control Valve FSAR - Final Safety Analysis Report GDC - General Design Criteria GOI - General Operating Instruction GL - Generic Letter HVAC - Heating Ventilation and Air Conditioning HIC - Hand-operated Indicating Controller H0 - Hold Order HP - Health Physics ICF - Instruction Change Form IDI - Independent Design Inspection IN - NRC Information Notice ____ __-_-_______-____- _ _ -

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IFI - Inspector Followup Item IM - Instrument Maintenance IMI - Instrument Maintenance Instruction IR -

Inspection Report

KVA - Kilovolt-Amp-KW - Kilowatt KV - Kilovolt LER - Licensee Event Report LCO - Limiting Condition for Operation LIV - Licensee Identified Violation LOCA - Loss of Coolant Accident  ! MCR - Main Control Room MI - Maintenance Instruction MR - Maintenance Report MSIV - Main Steam Isolation Valve NB - NRC Bulletin NCV - Non-cited Violation NOV. - Notice of Violation NQAM

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Nuclear Quality Assurance Manual NRC - Nuclear Regulatory Commission OSLA - Operations Section Letter - Administrative DSLT - Operations Section Letter - Training PLS - Precautions, Limitations, and Setpoints PM - Preventiv2 Maintenance PPM - Parts Per Million PMT - Post Modification Test PORC - Plant Operations Review Committee PORS - Plant Operation Review Staff PRD - Problem Reporting Document PRO - Potentially Reportable Occurrence QA - Quality Assurance QC - Quality Control RCA - Radiation Control Area RCDT - Reactor Coolant Drain Tank RCP - Reactor Coolant Pump RCS - Reactor Coolant System RG - Regulatory Guide RHR - Residual Heat Removal RM - Radietion Monitor R0 - Reactor Operator RPI - Rod Position Indication RPM - Revolutions Per Minute RTD - Resistivity Temperature Device Detector RWP - Radiation Work Permit RWST - Refueling Wate Storage Tank SER - Safety Evaluation Report SG - Steam Generator SI - Surveillance Instruction SMI - Special Maintenance Instruction 501 - System Operating Instructions i

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SOS - Shift Operating Supervisor SQM

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Sequoyah Standard Practice Maintenance SQRT

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Seismic Qualification Review Team SR - Surveillance Requirements SRO - Senior Reactor Operator SS0MI - Safety Systems Outage Modification Inspection SSQE

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Safety System Quality Evaluation SSPS - Solid State Protection System STA - Shift Technical Advisor STI - Special Test Instruction TACF - Temp'orary Alteration Control Form TAVE - Average Reactor Coolant Temperature TDAFW - Turbine Driven Auxiliary Feedwater TI - Technical Instruction TREF - Reference Temperature TROI - Tracking Open Items TS - Technical Specifications TVA - Tennessee Valley Authority UHI - Upper Head Injection UO - Unit Operator URI - Unresolved Item USQD

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Unreviewed Safety Question Determination VDC - Volts Direct Current VAC - Volts Alternating Current WCG - Work Control Group WP - Work Plan WR - Work Request I l L- }}