IR 05000327/1990002
ML20012C379 | |
Person / Time | |
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Site: | Sequoyah ![]() |
Issue date: | 03/09/1990 |
From: | Jape F, Peebles T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
To: | |
Shared Package | |
ML20012C377 | List: |
References | |
50-327-90-02, 50-327-90-2, 50-328-90-02, 50-328-90-2, NUDOCS 9003210148 | |
Download: ML20012C379 (16) | |
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"i NUCLEA'RE~.'ULATZRY COMMIS$10N
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Report Nos.:
50-327/90-02 and 50-328/90-02-(
y Licensee:' LTennessee Valley Authority
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V 6N38 A Lookout ~ Place'
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1101 Market Street Chattanooga, TN-37402-2801
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Docket Nos.:
50-327 and 50-328 License Nos. :
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L Facility Name:.Sequoyah 1 and 2
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Inspection Conducted: January 22-26, 1990
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Team Leader:
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F. JapV
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Date Signed
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Inspectors:
W.-K. Poertner
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C. F. Smith R. W. Wright i
Censultants: C..J. Crane D. C. Pr atte
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Approved by:-
M
-/m-J.9-90 T. Peebles, Chief
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Date. Signed
' Operations Branch Division of Reactor Safety
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-SUMMARY
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Scope:
This special, announced inspection was conducted in the areas of design changes ' and modifications, procurement, and licensee action on.previously
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identified inspection findings.
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Results:
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= One' violation' was identified - failure to follow procedures (paragraph 2.b).
~ The violation involved the failure to develop the technical justification for adding 8.2' KW of load to-the emergency diesel generators through a documented r
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calculation as required by procedures NEP-3.1, Calculation and NEP-3.2, Design Input.
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Three licensee commitments were identified and discussed at the exit
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The commitments involve: 1) revision of calculation "ETR" ' to
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delete the use of putty on the diesel generator timing relay potentiometers, 2) revision of Electric Design Standard DS-E4.5.2; and 3) requiring that PM20722 and.PM41811 be included in the mandatory PM program.
9003210148 900312 PDR ADOCK 05000327 Q
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Improvements since the previous SALP have been noted in the engineering and technical support areas.
For example the. back log of ECNs and DCNs has been reduced and the documentation of these packages has improved.
Improved cooperation between. DNE and. plant personnel has been observed.
A three element work order process has been implemented which has improved the nuclear engineering program effectiveness.
DNE ' personnel are included as members of the reactor trip assessment team.
Also, the DNE representative on the Plant Operating Review Committee is rotated to enable others within DNE to gain this experience.
The licensee has formed a Radwaste Improvement Task Group which includes. DNE participation.
The licensee has an acceptable program for use of commercial grade items intended for' safety related applications.
Overall performance of engineering and technical ' support provides assurance that technical issues are being resolved in a quality and timely manner.
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REPORT DETAILS
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Persons Contacted Licensee Employees.
- S. Bargerstock, Manager, Procurement Engineering Nuclear Power Production
- J..Bynum, Vice Presidenti
- M. Cooper, Compli& ace Licensing Manager
- H.
Fisch, Modifications
- T. Flippo,: Quality Assurance
- J. Gates, Technical Support R. Lisom, QA Supervisor
- D. Love, Maintenance
- D..Lundy, Lead' Civil Engineer
- M..Medford, Vice President and Nuclear Technical Director D. Michlink,- Manager, Special Projects
- R.
Miles, Modifications C. Moore, Manager, Vendor Manual Program
- F. Moreadith, Vice President, Nuclear Engineering
- J.
Proffitt, Licensing Engineer
- J.-Robinson, Site Programs
- P. Trudel, Sequoyah Project Engineer
- C, Vondra,' Plant Manager J. Wheeler, Manager, Site Materials
- R. Whitthauer, Engineering Other' licensee employees-contacted during this inspection included craftsmen, engineers, technicians, and administrative personnel.
NRC Resident Inspectors
- K. Jenison
- Attended exit interview 2.
Design, Design Changes, and Modifications (37700)
The inspectors reviewed selected modifications to determine the adequacy of the safety evaluations performed to meet 10 CFR 50.59 requirements; verify that the modifications were prepared and installed in accordance
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-with program requirements and applicable industry codes and standards; verify that the modifications were reviewed and approved in accordance with TS and administrative controls; ensure the subject modifications were installed (for those physically inspectable) in accordance with the applicable modification packages; applicable plant operating documents (drawings, plant procedures, FSAR, TS, etc.) were revised to reflect the subject modifications; the modifications were reviewed and incorporated into the operations training program as applicable; and post modification i
test requirements were specified and adequate testing was performe p,
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ECN L7286B'
This modification addressed replacement of diesel generator load sequence timing relays located in logic panels 1A-A, IB-B, 2A-A and 2B-B.
This activity was initiated based on CAQR No. SQP870080.
The CAQR pointed out that compliance with NRC Regulatory Guide 1.9 was indeterminate with respect to load sequencing because Calculation SQN-E3-002, Diesel Generator Load Analysis, is based on an accuracy of 5 percent for the timing relay.
However. - another calculation "DG Timer Relays," referenced on RIMS No.
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B25 880323 302 Revision 3 dated March 22, 1988, indicated that the actual timer accuracies varied between 10.4 and 16.0 percent. of the setting.
Although TVA was able to demonstrate that the existing timer relays (Agastat series 7000 electro-pneumatic relays) were adequate (based on Calculation SQN-E3-015, DG Voltage and Margin Analysis), it was decided to replace the timer relays with Agastat electronic ETR series relays.
Calculation "DG Timer Relays" states that the required accuracy for the diesel generator timing relays is 5 percent (sheet 7 and attachment 8).
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This calculation used technical data from Calculation "ETR" Demonstrated Accuracy, Agastat ETR Timing Relays, to determine the accuracy of the replacement timer relays.
The accuracy was determined to be d6.9 percent of setpoint for all relays.
The inspector noted, however, that TVA did not address or reconcile the original accuracy requirement which was identified as 15 percent for these relays.
Therefore, a discrepancy exists between the required accuracy and the accuracy calculated in calculation "DG Timer Relays" for these relays.
Also, Technical Specification surveillance requirement 4.8.1.1.2.d.10 states that these relays are operable if they are verified to be within d5 percent of their design setpoint at least once per 18 months during shutdown.
Again, a-discrepancy. exists between the calculated accuracy and the surveillance requirement in that the surveillance requirement is more conservative.
The inspectors reviewed the calibration history of the replacement ETR relays and verified that all the relays met the 5 percent requirement as specified in the TS.
Calculation "ETR" was prepared to determine the accuracy of the replacement sequence timing relays-Sheet 10 (item 6) of the calculation states that a requirement of the calculation is that the adjustment potentiometer must be secured (by applying putty, glue or some other positive method); tnus, the " seismic effect" inaccuracy term in the calculation would be negligible.
The inspector noted that this requirement is incorrect because it is not possible (or advisable) to secure the potentiometer adjustment on these relays.
This was pointed out to the licensee. The licensee subsequently conducted a field walkdown and verified that the new relays installed in the plant did not have the adjustment potentiometer secured as required by the calculation.
In addition, this issue may be generic in nature in that it appears to be applicable to other TVA plants (i.e., Browns Ferry Nuclear Plant).
In response to this concern, TVA committed to revise the calculation to delete use of putty on the adjustment scre '
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The seismic qualification of the ETR load sequence timer relays was'
evaluated in. Calculation SQEP-C2-142, Seismic Qualification of Agastat Relays, B25 870917 800, Revision 0 dated September 17,. 1987.
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Design Standard DS-E4.5.2, Mounting Small Components, dated March 12, 1984,
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was used to provide guidance to install 'the timing relays. The inspector found that there is no documented calculation to support the details in
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the Standard with respect to seismic mounting and mounting hardware for J
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Lthe subject relays.
In response to this concern, TVA performed a field walkdown of-the relays
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and:a draf t calculation which demonstrated that the relays are mounted E
correctly.and committed to revise Electric Design Standard DS-E4.5.2.
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Revision of Calculation "ETR" and revision of Electric Design Standard DS-E4.5.2 is identified as Inspector Follow-up Item (IFI)
50-327,328/90-02-01, b.
ECN L7242E
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This modification addressed revised. ERCW flows and - air flow require-ments for safety related room cooling units.
The as-specified flow rates did not provide adequate capacity to handle the heat loads.
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Certain cooler f an motors will now operate at higher loads due to this change; also the maximum ambient room temperature will be increased.
The ECN package stated that ESF equipment could handle the increased
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temperatures, and the increased motor loading is acceptable with respect to the emergency diesel generator (EDG) loading.
To demonstrate that the increased motor loading would have no adverse effect on the' EDG, a memorandum (B25 880804 017)' and attached QIRs (QIR-SQP-SQN-88-436, R0 and -88-652, RO) were included -in the ECN package ~ as a technical justification. Tables 1 and 2 of QIR-SQP-SQN-88-436 showed the worst _ case EDG loads added by several other.ECN package's.
The justification-concluded that the addition ' of 8.2KW, due to ' the operation of the fan motors at higher rating would not reduce the EDG load margin below an acceptable level.
The inspectors determined that the technical justification included in the ECN package was not developed through a - documented calculation as required - by procedures - NEP-3.1, Calculations and NEP-3.2, Design Input. Procedure NEP 3.1, paragraph 2.1, defines a calculation in part as a computation or analysis applied to design input or output for the purpose of developing or providing for the design of structures, systems and components.
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paragraph-4.1 also requires the design process to provide for relating the A
final design back to the source of design input.
Traceability to verify the design basis statement that addition of the 8.2 KW load would not-reduce the EDG load margin was not available in the absence of a calculation.
The inspectors also-determined that the technical justification included in the ECN package was developed based on technical information obtained from a " Revision log only" change contained in the front of calculation SQN-ALS-913.
Calculation SQN-ALS-013 for the most part is a running tabulation of load changes made to the EDG via various design changes.
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T This document' does not provide a summation of the load changes nor their ef fects on ' the - EDG design rating.
Justification for making these load-changes are documented on its attachment, " Revision _ log only"..
A technical -basis for-EDG. load changes supported by a calculation is not provided by'this so-called calculation.~ Overall effects of load changes to,the EDG design rating ano available load margain is given-in. primary calculation SQN-E3-002.
The licensee's failure to meet the procedural requirements o f-NEP-3.1 and NEP-3.2 is ' identified as Violation 50-327,328/90-02-02.
TVA has' not revised primary calculation SQN-E3-002, Diesel Generator-Load-Analysis,=to include various as-designed loads. In order to identify additional-EDG loading due to design changes, the Calculation - Cross.
Reference Information System, (CCRIS) is used.
Eventually,-all_the loads wil1~ be reflected in the primary calculation.
This method provides a capability 1 of tracking. changes, especially since CCRIS is a-QA verified document.
However, the inspectors believe that better design controls would be-implemented if TVA developed and maintained a " current as-designed" EDG Load Calculation.
The presently used method of distributed EDG load values appears to be overly complex, and essential data is not easily retrievable nor auditable.
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DCN X00015B LER 87-028-00,' dated July 10, 1987, documents a design deficiency identified:
in the electrical control logic of the auxiliary air compressors.
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design error could result in the loss of all control air in_ the. event of
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a loss' oft offsite power.
The auxiliary control air compressors were intended to automatically start
from the EDG upon loss of offsite power. However, the original electrical
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control logic required a manual reset of the control circuit. before the compressor motors could be ' restarted when fed from the EDG.
The. time delay caused by manually resetting the control circuits could render the system incapable of providing an adequate control air supply to various plant systems.
Licensee management attributed the design ' deficiency to personnel oversight on the part of the system designer.
Additionally, CAQR No. SQP-870993 was written to initiate corrective action for the design deficiency.
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DCN No, X00015B was developed and installed to correct the above design deficiency.
The design objective was to modify the control logic'such
_that manual reset of the control circuits would not be necessary to facilitate restart of compressor motors when fed from the EDG.
Hardware chan0es to the control circuits involved installing jumpers across the low oil level relays and high air temperature relays seal in contacts
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for auxiliary air compressors A-A and B-B.
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The safety evaluation performed in accordance with the requirements of
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10 CFR 50.59 was reviewed by the inspectors to assess the technical
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adequacy of the evaluation.
No deficiencies were identified during this
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. review.
The following design output documents were reviewed by the inspectors to verify that the hardware changes were consistent with the design scope.
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CCD 1, 2-45N779-22, Wiring Diagram,.480V Shutdown Auxiliary Power Schematic Diagrams, Sheet-22 Drawing No. E-0-X0015A-A-01-27524D, Assembly Wiring, Ingersoll-Rand Company Drawing No. E-0-X0015A-A-0-45N779-22 Wiring Diagrams, 480V Shutdown
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Auxiliary Power Schematic Diagrams, Sheet 22 Review of _ the above electrical schematics verified that the hardware changes shown were within the design scope.
Work - Plan 12587, dated July 29, 1987, used for installation of the modification, was reviewed to verify that post-modification test acceptance criteria had been met, and the design objectives had been achieved.
The inspectors verified by review of calculation SQN-E3-002, Diesel Generator Load Analysis, that the auxiliary air compressor motor loads had been included in the random loads for, train -2A and train 2B diesel generators. Additionally, the requirements of applicable codes and standards were verified as having been imposed during preparation, review, and installation of DCN No. X00015B.
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DCN No. X00227B, and DCN No. M-01230A CAQR SQP-880282, dated September 23, 1988, was written to document a design deficiency identified in the RHR discharge flow instrumentation loops (FI-63-92C and FI-63-91C) used for remote shutdown monitoring, The deficiency concerned a misapplication of Foxboro transmitters, model N-E110M-HIC 2, in that the GMAC instrument power supply and instrument loop impedance did not. meet Foxboro instrument specifications.
This deficiency was identified by Instrument Maintenance personnel on March 30, 1988. It was also noted by the Instrument and Maintenance staff that the af fected loops had a history of calibration drif t.
Proposed corrective actions documented on the CAQR were (1) install a load resistor in Unit I and 2 instrument loops FI63-91C and 92C; (2) perform a review of other instrument loops having GMAC power supplies to ensure that the transmitters, power supplies, and loop components associated with contract 92784 are properly interfaced. The inspectors determined that this was an original design deficiency caused by use of Foxboro transmitters in lieu of GMAC transmitters.
Plant modifications DCN No. X00227B (Unit 2) and DCN No, M-01230A (Unit 1)
were prepared, reviewed, and installed to correct the above design o<
deficiency. Additionally, the licensee upon identifying the deficiency implemented compensatory measures via monthly surveillances to ensure operability of the instruments in accordance with the requirements of TS Section 3/4 3.3.5.
A JC0 was written based on the increased calibration frequency of the instruments performed during the monthly surveillance.
The deficiencies were reviewed for reportability and were also determined to be non-restart items.
Based on review of sampled results of PM No. 41811 (Unit 1) and PM No. 20722 (Unit 2) performed prior to installation of both plant modifications, the inspectors verified that the instrument loops were calibrated per SI-109 if the as-found conditi_on was out of toleranc __
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The safety evaluations for both plant modification packages prepared in accordance with the requirements of 10 CFR 50.59 were reviewed by the inspectors to. verify technical adequacy.
The inspectors determined that instrument loop accuracy calculations had not been prepared for the.
instrument loops in question. The design basis for selection of the 200 ohm load resistor was based on performance curves provided by Foxboro for the installed transmitters.
Additional reviews of the modification packages revealed that the scope of the plant modifications also included installation of a 10 ohm test point resistor. The inspectors verified by review of CCD's that the hardware changes were as described in the safety evaluation.
Post modification tests were also verified has having been completed via review of Work Plan M01230-01 for Unit 1.
Further discussions with licensee engineering personnel revealed that installation of the above plant modifications had not corrected the problem of instrument calibration drif t.
Compensatory measures to ensure operability of the instruments have been increased to biweekly surveil-iances of Unit 2 instruments and continued monthly surveillances of Unit 1 instruments.
CAQRSQP-890566, dated October 18, 1989, was written to document the continued instrument calibration drif ts and' to describe interim corrective actions taken.
The inspectors determined that data obtained for instrument loop 2-FT-63-92C showed an A.C. ripple on the power supply D.C. output. Work Request No. 8757659 was implemented for refurbishing the power supply via replacement of a capacitor.
Additional corrective actions included continued performance of PM20722 and trending of collected data by the System Engineer.
The inspectors reviewed the results of four PMs performed for instrument loop 2-FT-63-92C since refurbishment of the power supply.
The inspectors determined that the instrument was found out of calibration during the PM performed December 12-14, 1989. No instrument drif t was identified during the other three PMs.
Licensee management has not determined the root cause of the RHR discharge flow instrument calibration drif ts.
Additionally, because of
.the nature of the problem, a generic review for applicability to numerous other instrument loops having GMAC power supplies has not been performed.
This situation exists, despite the requirement for performing such a review which is documented on CAQR No. SQP-880282. Review of the results of compensatory measures implemented via PM20722 and PM41811 showed that the surveillances were not always performed on their scheduled dates.
Licensee management committed to make both PMs mandatory, which will ensure their performance in strict compliance with the predetermined schedule.
Upon identification of the root causes of the problem and trending of data to verify effective corrective actions, the PM frequency will be adjusted until calibration of the instrument loops returns to the 18-month frequency specified in the T.S.
Inclusion of PM20722 and PM41811 into the mandatory PM program is identified as IFI 327,328/90-02-03, i
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These modifications replaced ERCW and CCW containment isolation check
valves with motor operated butterfly valves. The modification packages
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were developed to. replace 10 six-inch containment isolation check valves (five in each unit) on the CCW and ERCW systems with motor - operated butterfly valves (ECNi s L-7329 and L-7331 respectively). The check valves being replaced had been found to be a chronic source of leakage when tested-
'in accordance with 10 CFR 50, Appendix J.
The purpose of these modifications was to' provide more positive containment isolation at-these penetrations -
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.Along with each butterfly valve, a half-inch spring loaded check valve was
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installed to provide thermal pressure relief to the piping between' the-
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inboard and outboard isolation valves whenever both valves were closed,
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This valve would relieve back to the piping inside containment' inboard of E
the inboard isolation valve.
Although the environmental qualification of the motor operators for.ther
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valves had clearly been considered in the modification packages,.it was
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not clear that the design operating conditions for the valves themselves had -been adequately considered.
Both the six-inch butterfly valves and the half-inch check valves contained soft seats and packings of
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elastomeric materials which required consideration with respect to their ability to withstand the effects of temperature and radiation for both normal operating and accident conditions.
i-When this apparent oversight was brought to the attention of the licensee
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by ' the inspector, a Condition Adverse to Quality Report was written to document the condition, and a Justification for Continued Operation was generated which showed that the actual capabilities of the materials exceeded the required capabilities.
-Therefore,'this finding hadEno actual plant safety significance. However, it could-have had profound safety significance, and'it did indicate a lack of attention to detail in the design process.
During the review of ECN 7331, the inspectors - determined that the n
modification package did not identify all of the FSAR changes and.the
' Design ~ Criteria Document changes required to be implemented as a result of-this modification.
In discussions with the licensee, the' inspectors determined that the discrepancies had been previously identified by the
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L licensee and a CAQR had been initiated to correct the discrepancies.
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DCN X00238 This nodification replaced an existing Kerotest valve in the component cooling water system with a replacement globe valve.
The Kerotest valve was replaced due to CAQR SQP-871491DI that identified that Kerotest Model 9900 series valves are not suitable for use as throttle valves.
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' test data has shown that the valves could be damaged under certain flow and-throttle positions. The inspector reviewed the DCN package and associated Work Plan 238-01.
No deficiencies were noted, p
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OCN M01200A This modification removed the valve internals for ERCW check valves 2-67-565A, B, C and D; 2-67-568A, B, C and 0; and 2-67-571, A, B, C and D. These check valves are located in the discharge lines of the lower compartment vent coolers, the control rod drive coolers and the reactor coolant pump motor air coolers respectively.
The inspectors reviewed the DCN package and associated work plan 1200-01.
The inspectors also verified that drawing 47W845, Essential Raw Cooling Water, had been revised to reflect - that the valve internals had been removed.
No deficiencies were noted.
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DCN 01204 This modification replaced check valves 2-70-676A and B with suitable replacement check valves. These check valves are located in the component cooling water system in the discharge of the thermal barrier booster pumps. The inspector reviewed the DCN package-and associated work plan 1204-01.
No deficiencies were noted, i.
DCN 01349 This modification was a documentation only modification.
The modification upgraded valve 1-70-737, a half-inch TVA class C valve to TVA class B and revised the documentation to agree with the as-built configuration.
No deficiencies were noted, j.
DCN X00299 This modification installed two ERCW supply isolation valves; two discharge isolation valves; four drain valves; and four vent valves to the ERCW system to allow isolation of ESF coolers and repair on MIC affected welds.
The inspector reviewed the modification package, verified that the valves had been added to the system operating procedure and applicable surveillance instructions and that the system -drawing had been revised to reflect the addition of these valves.
In rev_iewing this package, the inspectors also reviewed the overall program which has been developed by the licensee to address the MIC problem.
The problem was first discovered with leaks in stainless steel piping in the ERCW System at the Watts Bar plant in 1986.
Subsequent to this, similar leaks were discovered at the Sequoyah plant. As a result of these
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discoveries, an aggressive program was initiated which includes continuous biocide treatment of the ERCW System started in January 1989, and alternating 100 percent external visual inspection of one train of ERCW each six months. If indications of MIC damage are discovered, radiography of the af fected welds is performed.
No indications have ceen discovered since the-start of the biocide treatment.
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ECN L7351
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This' modification provided; design ' features to ass'ure 'that containmen_t spray water was routed to the containment. sump.
- This modification was made necessary by -the discovery:that a portion of the containment spray water was likely to be entrained'in the air streams
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of the containment cooler fans and could be carried to a locatien where it could not-drain back to the containment, sump. This could produce an unacceptably. low containment sump water level during the recirculation-phase of an accident.
The modification added curbs-and orificed floor drains' to route this-water in the proper direction.
Additionally strainers were added to the drains to assure that debris which could plug the containment sump suction-if point could not be washed into the sump.
This modification involved
- calculations' to assure that ' the drains and strainers could handle the required drainage rate to prevent overflow of the curbs. No deficiencies
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3.
Engineering Activities on Radiological Waste Systems The 1989 SALP report noted in the Plant Operations section that the licensee..had failed. to " aggressively correct design problems that make
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operations awkward or could create personnel or radiological hazards." 'In the licensee's response, a commitment was made to ' review outstanding and.
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cancelled. design change requests-(DCRs) related to the radiological waste processing systems to reevaluate the need for these modifications, and to j
evaluate the = systems to determine-what, if any, additional modifications-I may be required to ensure they perform adequately.
-The progress to-date on these commitments was' reviewed by the. inspectors, and-it appeared that, irdeed, new emphasis had - been assigned to rauiological waste processing concerns in Engineering.
A Radwaste Improvement Task Group had been established, meetings had been held between Operations, Systems Engineering and Nuclear Engineering. to identify work and assign priorities, and a master schedule of improvement activities had been developed. Additionally, three modification packages j
were being implemented:
ECN 5916. Cask Decontamination Collection Tank
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Pump Replacement; ECN 7328, Spent Resin Storage Tank Underdrain Backflush;
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. and DCN M01278, Waste Gas Compressor Header Drain.
One study was being '
i performed on improvements in the boric acid evaporator, and another study i
was scheduled to begin in May 1990 on the use of permanent demineralizers, j
It appeared that aggressive action was being taken by Engineering to
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resolve radwaste design problems, and that these actions were being taken
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in concert with the other plant organizations.
4.
Commercial Grade Procurement (38703)
The objective of this inspection was to evaluate the licensee's CG procurement activities at Sequoyah since the site's last SALP evaluation
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period which ended February 3,1989, and to ensure that they currently conform to established guidance and requirements, m
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.w l0 In order to establish stronger control on the use of the CGIs, TVA revised the Nuclear QA Manual, Nuclear Engineering procedures, and site procedures to control installation and procurement of items intended for safety-related application. TVA has incorporated into its procedures the methodology that is used to evaluate CGIs for use in safety-related applications.
This - program is consistent with Generic Letter 89-02 guidelines.
The inspector reviewed the licensee's program for the control and preparation of CG procur.ement packages that are developed by the CEG as described in TI-110, Technical Evaluation for Procurement of Materials and Services, Revision 3, dated September 2,1988. _These packages contain a procurement specification including technical and QA requirements, and dedication documentation that incorporates EPRI NP-5652 guidelines.
In addition to the above instruction review, the inspector conducted discussions with Sequoyah's Site Material Manager, Procurement Engineering Manager, Contract Group Engineers, the QA Supervisor, and knowledgeable"QE and QC Receipt Inspectors to inquire about past CG procurement problems; when and how these problems were corrected; and to become-familiar with their duties and responsibilities for implementing the site procurement program.
The inspector verified proper implementation of the CG procurement program by reviewing the following selected procurement packages which were awarded from February 2989 to date:
Requisition Nos. 83446B, 86781A, 86907A, 86953A, 86998A Transfer No. 87056A These packages represent stock reorders, new procurements and a Watts Bar transfer procurement.
The above packages were examined for adequate procurement specifications, technical and QA requirements specified, dedication requirements and documentation enclosed, particularly the CCs specified for the item, the acceptance methods identified and the actual verification implemented.
The inspector found these dedication packages and their implementation to be above average in that they generally specified more than one acceptance method for an item using a combination of tests and inspections with vendor surveys / audits, TVA source inspections, engineering evaluations, or functional testing.
Examination of TVA vendor audits and source inspections performed for the above procurement packages verified the validity of the COCs received from these vendors.
In addition to examining these packages to EPRI NP-5652 guidelines, they were reviewed against previous discrepancies identified -
o in Region II Inspection Report 50-327,328/88-07 and no recurring problems were identified with the packages.
The inspector conducted a walk-through inspection of the main warehouse and warehouse No. 6 to verify that QC inspected material was properly tagged, nonconforming items were properly identified and segregated, that QC receipt inspection test and inspection equipment was in current calibration, and that functional test documentation for conditionally dedicated items was being maintained with the stored ite _ _ -____
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Within these areas, no violations or deviations were identified.
5.
Follow-up on Engineering / Plant Staff Vendor Manual Interface (SALP Response Plan Goal 2B) (92701)
The SALP report noted an interf ace problem between engineering and the plant in relation to vendor manuals having conflicting data which resulted from a lack of' communication between the two organizations.
The inspector examined supporting documentation and conducted discussions with the Manager. Special Projects and Manager, Vendor Manual Program concerning actions taken to date to resolve this interf ace problem.
A major -step was the establishment of a Vendor Manual Use Task Force which is comprised of ten members, five each from the engineering organization and plant-organization who serve as a feedback / communication mechanism between users and producers of vendor manuals at SNP. This Task Force was scheduled to meet on a monthly basis for one year. The Task Force Charter and the Agenda for the opening meeting conducted October 24, 1989, were examined by the inspector.
SNP has upgraded control procedures AI-23, Vendor Manual Control, Revision 31, and SQEP-39, Review and Approval of Vendor Manuals / Revisions, Revision 7.
These changed procedures more-accurately reflect responsibilities,- the flow of vendor manual reviews,- help ensure
_
compliance with NRC Generic Letter 83-28, and establish necessary interfaces.
As of October 1989, contract personnel have been phased out of the Vendor Manual Program and this group is now manned entirely by TVA personnel
.
which is expected to improve internal interfaces. The vendor manual group has completed work on the generic match of manuals and improved vendor manual reviews against plant procedures to rectify any differences have been implemented.
It appears that the above mentioned licensee actions are enhancing the effectiveness and efficiency of the Vendor Manual Program at SNP.
6.-
Action on Previous Inspection Findings (92701, 92702)
(Closed) VIO 50-327, 328/88-09-02, Improper Storage of Quality Records TVA's responses, dated July 1, 1988, and October 20, 1989, to the violation issued on May 17, 1988, were reviewed.
In the initial response, TVA denied the violation based on the fact that the work plan documents in question were not QA records as defined in ANSI N45.2.9 (1974). NRC responded to this matter by letter dated January 18, 1990. The corrective actions stated in the TVA responses were acceptable and were examined during this inspection. TVA recognized the advantage of affording certain documents, which were destined to become QA records, a degree of protection in handling and storage because of the di f ficulty in reconstructing or replacing the p
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p Processing Records' was made to include instructions for in process QA.-
p records. This; revision was-examined and found-to be acceptable.
1f To~ assess implementation -of AI-7, a verification review was completed by '
f 0A on January 17, 1990. Results'of the verification review indicated that;
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_97 percent' ofJ thes.-in process records are. properly stored.
The ' three
-
H percent, improperly stored consisted of four' surveillance-instructions and
,
-
one. work. plan; document. The requirement for proper; storage _was discussed
with-the personne1' involved.
This item is closed.
i(Closed)IFI 50-328/85-21-03, Issue Procedure STI-1-sand Cancel SQA-100.
y This. item involved control for special test,, experiments, or activity
'
requests (STEAR) and is. discussed in Inspection Report.50-327,328/86-41.,
paragraph 8.c.
- SQA-100 was cancelled on March 18, 1989, and STI-1,
,
-originally approved-on July' 31, 1986, is in place : to control STEAR
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activities. ~This: item-is closed.
3 - ;
(Closed) VIO 50-327,328/88-60-01,_ Boron Purchase and Release-for Use.
The licensee's response, dated' April 10, 1989, to the violation issued on
-
March 9, '1989, was acknowledged as acceptable.on May 1, 1989.
The,
-
corrective actions identified in the April 10, 1989 response and revised byEletter, dated November 7,1989, were examined during this inspection and found:to be fully implemented. This item is closed.
,
7.
Exit Interview The inspection scope and results= were summarized on January 26, 1990, with _.those: persons _ indicated in paragraph 1.
The inspectors described the areas. inspected _ and discussed.in detail the-inspection results listed-below.
Proprietary information is not contained in this report.
Dissenting comments were not received from the licensee.
Item Number Description and Reference-327,328/90-02-01 IFI-Revision of Calculation "ETR" and Electric Design Standard DS-E 4.5.2, paragraph 2.a.
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_327,328/90-02-02 Violation-Failure to meet the procedural
requirements of NEP-3.1 and NEP-3.2, paragraph 2.b.
i 327,328/90-02-03 IFI-Inclusion of PM 20722 and y
pM 41811 in the mandatory PM program, paragraph 2.d.
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The following open items were reviewed and closed.
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Violation'50 327,328/88-09-02,: Improper Storage of Quality Records.
.
. Violation 50-327,328/88-60-01, Boron Purchase and. Release For Use.
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.IFI 50-328/85-21-03, Issue Procedure ST1-1 and Cancel SQA-100<
During the ' exit interview. the ~ licensee agreed to provide -additional
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information-concerning the required accuracy-of the Agastat ETR timing:
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relays versus the calculated accuracy discussed in paragraph 2.a.
This
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information was received February 26, 1990. TVA concluded that the accuracy--
'
of the installed. ETR-timers does not affect the design bases.. The calculated-inaccuracies for the most limiting condition is : within.'the safety s limit.
Applicable calculations are scheduled to be revised' to -
M reflect the values on acceptance band, t
8.
Acronyms and Initialisms
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' Alternating Current
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Administrative Instruction-CAQR Condition Adverse.to Quality Report CC
. Critical Characteristic CCD-
-Configuration Control Drawing
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Component Cooling Water i
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. Electrical Power Research Institute
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MIC Microbiologically Induceo Corrosion
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NEP Nuclear Engineering Procedure QA-Quality Assurance
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Quality control QE Quality Engineers QIR
' Quality Information Release
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