IR 05000327/1990006
| ML20033G840 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 03/29/1990 |
| From: | Jenison K, Linda Watson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20033G839 | List: |
| References | |
| 50-327-90-06, 50-328-90-06, NUDOCS 9004120200 | |
| Download: ML20033G840 (39) | |
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- o NUCLEAR REGULATORY COMMISSION
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101 MARIETTA STREET,N.W.
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t ATLANT A, otoRGI A 30323
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Report Nos.:
50-327/90-06 and 50-328/90-06'
Licensee:
Tennessee Valley Authority 6N38 A Lookout Place i
1101 Market Street Chattanooga, TN 37402-2801 Docket Nos.:
50-327 and 50-328 License Nos.:
DPR-77 and UPR-79 Facility Name:
Sequoyah 1 and 2-Inspection Conducted: February 6 - March 5, 1989 Inspector: /.A A m,A M 347/7o K1 Jenison~ 5picfr Resident Inspector Date Signed
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Inspectors:
P. Harmon, Senior Resident Inspector D.' Loveless, Resident Inspector F. Pau11tz, Reactor Inspector Approved by: kW (44I4L da/7#
L.~JV Watson, Chief D#te*5igned Project Section 1 TVA Projects Division Office of Nuclear Reactor Regulation
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SUMMARY a
Scope:
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'This announced inspection involved inspection effort by the Resident Inspectors
'in the area of operational safety verification including control ' room observa_tions, operations performance, system lineups, radiation protection,
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safeguards, and housekeeping inspections.
Other areas inspected included'
maintenance observations, surveillance testing observations, review.of previous' inspection findings, follow-up of events, review of licensee identified items, and review of inspector follow-up items.
Results:
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Three strengths were noted during this inspection period.
One strength was
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noted with respect to prompt operator actions during a rod withdrawal event I
that occurred on February 28, 1990.
A second strength was noted in the maintenance area with respect to the cleanup of the condensate demineralizer bay.
A third strength was noted in the area of QA and Site Licensing with j
respect to the verification of NRC commitment closures.
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900412O200 900329 PDR ADOCK 05000327
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The areas of Operations, Maintenance, and Surveillance were adequate and fully capable to support current plant operations.
The observed activities of the control room operators were professional and well executed.
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No violations were identified.
Two noncited violations (NCV) were identified:
J NCV 327,328/90-06-03, Motor Lubrication, paragraph 7 NCV 327,328/90-06-04, UHI Valve Operability, paragraph 7 One unresolved item (URI)* was identified:
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URI 327,328/90-06-02, Ice Condenser Flow Channel Inspection Discrepancies, paragraphs 3 and 12 Two inspector followup items (IFI) were identified:
IFI 327,328/90-06-01, Security Issues, paragraph 2.e IFI 327,328/90-06-05, Resolution of SSOMI Issues, paragraph 14 No deviations were identified.
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- Unresolved items are matters for which more information is required to determine whether they are acceptable or may involve violations or deviations.
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REPORT DETAILS
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1.
Persons Contacted h
Licensee Employees J. Bynum, Vice President, Nuclear Power Production
- W. Byrd, Acting Site Director
- C..Vondra, Plant Manager T. Arney, Quality Control Manager
- R. Beecken, Maintenance Manager
- M. Burzynski, Site Licensing Manager
- M. Cooper, Compliance Licensing Manager
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D. Craven, Supervisor Instrumentation and Control
- J. Gates, Technical Support Manager
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J. Holland, Corrective Action Program Manager
- W. Lagergren, Jr., Operations Manager M. Lorek, Operations Superintendent
- R. Lumpkin, Site Quality Manager R. Pierce, Mechanical Maintenance Group Supervisor R. Proffitt, Licensing Engineer R. Rogers, Supervisor Engineering Support Section M. Sullivan, Radiological Controls Manager S. Spencer, Licensing Engineer
- C Whittemore, Licensing Engineer NRC Employees
- B. A. Wilson, Assistant Director TVA Projects i
- L. J. Watson, Chief, Project Section 1
- Attended exit interview
Acronyms and initialisms used in this report are listed in the last paragraph.
2.
Operational Safety Verification (71707)
a.
Control Room Observations l
The inspectors conducted discussions with control room operators, verified that proper control room staffing was maintained, verified that access to the control room was properly controlled, and that operator behavior was commensurate with the plant configuration and
l plant activities in progress, and with on going control room operations.
The operators were observed adhering to appropriate, approved procedures, including Emergency Operating Procedures, for the on going activities.
Additionally, the frequency of visits to
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The inspector also verified that the licensee was operating the plant in a normal plant configuration e.s required by TS and when abnormal conditions existed, that the operators were complying with the appropriate LCO action statements.
The inspector verified that leak
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rate calculations were performed and that leakage rates were within the TS limits.
l The inspectors observed instrumentation and recorder traces for abnormalities and verified the status of selected control room
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annunciators to ensure that control room operators understood the
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Panel indications were reviewed for the nuclear instruments, the emergency power sources, the safety parameter
display system and the radiation monitors to ensure operability and
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operation within TS limits.
The inspectors reviewed the activities related to an automatic rod withdrawal that occurred on February 28, 1990.
The indication of auctioneered average RCS temperature (TAVE auctioneered) failed low in its scale causing the control rods to step out at 72 steps per minute.
The transient was terminated after 4 steps by operators taking manual rod control.
The operators responded in less than four seconds with adequate actions.
This was viewed as a strength in the area of Operations.
No violations or deviations were observed.
b.
Control Room Logs The inspectors observed control room operations and reviewed applicable logs including the shift logs, operating orders, night order book, clearance hold order book, and configuration log to obtain information concerning operating trends and activities.
The TACF log was reviewed to verify that the use of jumpers and lifted
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leads causing equipment to be inoperable was clearly noted and understood.
The licensee is actively pursuing correction to conditions requiring TACFs.
No issues were identified with these specific logs.
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Plant chemistry reports were reviewed to confirm steam generator tube integrity in the secondary and to verify that primary plant chemistry was within TS limits.
In addition, the implementation of the licensee's sampling program was observed.
Plant specific monitoring systems, including seismic, meteorological and fire detection indications, were reviewed for operability.
A review of surveillance records and tagout logs was performed to confirm the operability of the RPS.
No violations or deviations were observed.
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c.
ECCS System Alignment The inspectors walked down accessible portions of the following safety-related systems on Units 1 and 2 to verify operability, flow
)ath, heat sink, water supply, power supply, and proper valve and
)reaker alignment:
Unit I and Unit 2 MDAFWP Unit 1 CS No deviations or violations were identified, d.
Plant Tours Tours of the diesel generator, auxiliary, control, and turbine buildings, and exterior areas were conducted to observe plant equipment conditions, potential fire hazards, control of ignition sources, fluid leaks, excessive vibrations, missile hazards and plant housekeeping and cleanliness conditions.
The plant was observed to be clean and in adequate condition.
The inspectors verified that maintenance work orders had been submitted as required and that followup activities and prioritization of work was accomplished by the licensee.
Pre-outage staging and preparation were in evidence throughout the plant.
Consequently, items such as work boxes, temporary scaffolding, welding machines and work related :lutter were increasing throughout the plant.
Although the number of minor housekeeping and maintenance items was increasing because of outage related activities, cooler leaks, and minor spills; the licensee was aggressively addressing these housekeeping and maintenance items during this inspection period.
The inspector observed shift turnovers and determined that necessary information concerning the plant system status was addressed.
During one control room tour, the inspector identified two flashing annunciators inside the operating horseshoe area. Each of these I
annunciators had WRs attached that had been outstanding for several
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days.
When the flashing annunciators were identified to the Operations Manager they were fixed within one day. The inspector had no further questions.
No violations or deviations were observed.
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Safeguards Inspection l
l In the course of the monthly activities, the inspectors included a
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I review of the licensee's physical security program, i
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The performance of variour. sh!f ts of the security force was observed in the conduct of daily activities including:
protected and vital
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area access controls; searching of personnel and packages; escorting
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of visitors; badge issuance and retrieval; and patrols and l
compensatory posts.
In addition, the inspectors observed protected area lighting, and protected and vital area barrier integrity.
The inspectorc verified interfaces between the security organization and both operations and
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maintenance.
Specifically, the Resident Inspectors:
r (1) visited the central and secondary alhem station (2) verified protection of Safeguards Information Two security related events were reviewed by the inspector.
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first event was described in PRO 1-90-042.
This event involved
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compensatory measures put in place because of maintenance related hardware problems on the microwave system.
The second event involved a public safety officer who was suspended for dereliction of duty for failing to take action when informed of a potential security violation.
These issues will be reviewed by an NRC Region 11 security specialist under IFI 327, 328/90-06-01, Security Issues.
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No violations or deviations were identified.
No trends were identified in the operational safety verification area.
General conditions in the plant were adequate.
The number of control room maintenance and modification items is decreasing.
However, the rate at which control room annunciator related issues are being resolved is also slowing.
Radiation protection at;d security are adequato to continue two unit operations.
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3.
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 requirements.
The inspectors verified that: testing was performed in accordance with adequate 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
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identified, as appropriate, and any deficiencies identified during the testing were properly reviewed and resolved by management personnel; and system restoration was adequate.
For completed tests, the inspector verified that testing frequencies were met and tests were performed by qualified individual.
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The following activities were observed / reviewed with no deficiencies identified except as noted:
51-106.3, Ice Condenser Bed During the performance of the ice condenser flow channel inspections, the inspector noted threa problems:
(a) The technicians performing the inspections were not aware of the total geometrical area that defined the flow channel.
(b) The inspector questioned a change in the acceptance criteria when blockages were at different elevations within the same flow channel.
(c) The technicians did not appear to be able to make consistent conservative calls on the percentage of blockage noted in the channels.
These task performance errors were identified and immediately discussed with the licensee.
This issue will be further reviewed at the completion of SI-106.2 and SI-106.3 (surveillances for both units), and will be tracked as URI 327,328/90-06-02, Ice Condenser Flow Channel Inspection Discrepancies.
SI-305.2, Hydrogen Mitigation System Operability
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SI-34, Containment Spray
51-7.1, Diesel Generator AC Electrical Power SI-666, River Temperature Limits l
During recent inspection periods, the trends observed in the area of
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surveillance performance were that the technical content and adequacy of direction were good.
However, task performance errors were noted during the performance of SI-106.3.
In addition, those surveillance related i
events or problems identified by the licensee, QA and in previous inspection periods by the NRC, appeared to be related to task performance The area of surveillance scheduling and management was observed errors.
to be adequate.
The management of the TS surveillance program appears to have progressed from a reactive type process to a routinely scheduled,
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adequately managed plant operation support activity.
4.
Monthly Maintenance Observations and Review (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,
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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
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work; activities were accomplished using approved procedures and were
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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 I
where required and were observed; fire prevention controls were implemented; outside contractor force activities were controlled in accordance with the approved QA program; and hounkeeping was actively pursued.
The following maintenance activities were reviewed:
WR B792984, Group B 480 Volt Distribution Panel WR B283296, Letdown Orifice WR B283625 Upper Compartment Cooler WR B758864, Nuclear Instrument Power Range WR B773415, Full Length Rods WR B283529, Head Vent
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WR B762049, RHR pump Mechanical Seal WP 1419A-0-1 EGTS Room Hangers DCN F-2523-A, EGTS Room Hangers WR B290786,UHI Level Transmitter l
During review of WR B290786, the inspector determined that the QC hold point for installation of instrument tubing was not completed, l
i The inspector reviewed this issue with the Maintenance Superintendent who initiated CAQR SQP 900003. The configuration of the sense line r
was immediately reviewed and the licensee determined that it did not affect the operability of the instrument. The QC hold point was performed with no deviations noted.
The failure to perform the QC hold point was a condition adverse to quality but there was no affect on operability of the system. The inspector had no further questions.
No violations or deviations were identified in the area of Maintenance.
5.
Management Activities in Support of Plant Operations TVA management activities were reviewed on a daily basis by the NRC insSectors.
The Resident Inspectors observed that planning, scheduling, worc control and other management meetings were effective in controlling plant activities.
First line supervisors appear to be knowledgeable and involved in the day to day activities of the plant.
First line supervisor involvement in the field has been observed and was determined to be adequate.
Management response to those plant activities and events that occurred during this inspection period appeared timely and effective. An example of management activities that have had a positive impact on the plant is the concerted effort initiated by maintenance management in cleaning, painting and general restoration of the condensate demineralizer building. This is viewed as a strength in the area of maintenanc >
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Site Quality Assurance Activities in Support of Operations (71707)
The following QA surveillances were reviewed *
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QSQ-M-90-0082 Electrical Raceway
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QSQ-M-90-0108 CDWE QSQ-M-90-0091, TACF 89-69-063 Safety Evaluation QSQ-M-90-0022, SQN-VD-VAC-019 Calculation i
The inspector reviewed recent efforts on the part of QA and site licensing
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to ensure that NRC comitments were met and accurately described.
The issues were identified by the licensee, dispositioned through the licensee's corrective action process and the corrective actions appear to be adequate.
This is viewed as a strength in the areas of QA and site licensing. The inspector had no further questions.
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NRC Inspector Follow-up Items, Unresolved Items Violations (92701, 92702)
(Closed) VIO 327, 328/89-21-01, Failure to Adequately Prescribe Work Activities This violation addressed the failure to adequately prescribe work
l activities in two instances - soldering safety related circuit boards and
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the repair of a Grinnel valve.
The inspector reviewed the licensee's corrective actions as stated in letter (Medford/NRC) dated November 6, 1989. The licensee's corrective actions appear to be adequate.
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VIO 327, 328/89-21-01 is closed.
(Closed)IFI 327, 328/89-21-02, Controlled Reassembly l
This IFI was opened to track and review the programs that the licensee
used to control post maintenance testing, independent verification, and QC
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hold points.
The inspector reviewed these programs and determined that, despite the redundancy, adequate programmatic control of component reassembly existed. The inspector had no further questions.
IFI 327, 328/89-21-02 is closed.
(Closed).IFI 327, 328/88-4'4-03, Long Term Corrective Action Related Items, With Two Examples Example 1 This item involved the implementation of the licensee's corrective actions relative to CAQR SQN 871457.
This CAQR addressed NRC identified problems
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with the licensee's method of maintaining the seismic qualifications of l
Class 1E equipment at Sequoyah.
The following specific items were
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addressed in the CAQR:
i Issuance of a procedure for maintaining seismic qualifications of I
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electrical components
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Development of PMs for inspection of seismically qualified electrical
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components.
Closure of WRs B234582, B257858, B226340 and B247913.
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i The inspector reviewed MI-1.3.2, Electrical Equipment Fastener Tightening i
and Replacement.
This instruction covered tightening and replacement of -
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fasteners for electrical. installations applications.
The inspector determined the procedure to be adequate to answer the above listed questions.
The licensee developed an extensive PM program for the maintenance of.the Class 1E seismic qualifications.
The inspector reviewed the following PMs and their most recent performances:
PMs on 6.9 KV shutdown boards 24052000 24061000 24071000 22592000 PMs on 480 V shutdown boards.
24002000 24082000 24121000 24131000 24141000 29172000 PMs on 120 VAC Vital Inverter 56720000 55210000 - Scheduled for VIC4 outage
125 VOC Vital Battery Boards inspections are included under SI-100.3, Annual 125-Volt Vital Battery System Inspection.
The following
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performances were reviewed:
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i System I 2/16/89
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System 11 1/27/89 System III 2/3/89 System IV 2/7/89 System V 3/14/89 Additionally, the licensee performed certain seismic review activities
under the following WRs:
B 775621 B 775622 B 775623 B 775624 i
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B 775625 B 775626 B 775627 B 775628 B 252501 B 252502 The inspector reviewed the above listed WRs and determined them to be closed.
WRs B234582, B226340 and 8247913 were closed by the licensee and the items were handled under the PMs addressed above.
WR B257858, which was completed, was reviewed by the inspector and found to be satisfactory.
This example is closed.
Example 2 VIO 327, 328/87-52-01, example B. vas reviewed in IR 327,328/88-19 and closed by the NRC, with certain aspects involving long term reviews remaining open and being tracked by the licensee s corrective action system.
Unit I cables were to be addressed by a long term licensee cable managementprogram(NC0-87-0324-035). TVA committed to complete this item by March 1,1991 by letter dated January 18, 1990.
This area will be reviewed during the next performance of IP 37700, Design, Design Changes, and Modifications. This example is administratively closed.
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IFI 327, 328/88-44-03 is closed.
(Closed) VIO 327, 328/89-15-02, Configuration Control of Maintenance Activities This issue involved maintenance performed on radiation monitor RM-90-404.
During this maintenance the licensee failed to control repair part material and did not comply with Sequoyah maintenance procedures.
The licensee responded to this violation in a letter (Medford/NRC) dated October 23,1989, RIMS S10 891023 806.
In its response the licensee stated that:
An improved incident investigation process and augmented trending of events and incidents attributed to among other things personnel performance have been implemented.
The inspector reviewed the licensee's immediate corrective actions and determined that programmatic controls put in place to administer vendor access to safety related components appeared to be adequate.
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VIO 327, 328/89-15-02 is closed.
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(Closed)IFI 327, 328/90-03-04, Fire Pump Test Deviation The inspector reviewed WR 797822 under which pressure control valves
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PCV-26-109 and 110 were repaired.
A Bourdon tube was replaced on
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PCV-26-109, the valve stroke tested and the lift point verified at 130
psig.
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WR 797822 was written to trouble shoot and repair PCV valves 109 and 110 after en operator realized that they were not maintaining system pressure below 130 psig during a tagging operation. During this tagging operation system pressure was allowec to rise to approximately 190 psig.
The licensee determined that the system overpressure did not affect its operability and generated ICF 90-0049 to Instrument Maintenance Instruction 26 to ensure that lift setpoints and test acceptance criteria were adequately established. The inspector had no further questions.
(Closed) VIO 327, 328/86-68-02, Example a.
Sample 17-1 Material Certification was not Received From Bruce GM Diesel for 144 Anchor Bolts Drawing A950D12006 required the anchor bolts to be either A307 or A325 which have significantly different material strengths.
In a response dated July 9,1987, TVA stated that Condition Adverse to Quality Report (CAQR) SQP870937 was initiated to document resolution of the D/G anchor bolt deficiency by verification that the installed anchor bolt material was acceptable for use by metallurgical evaluation.
The evaluation was to be completed by September 1,1987.
In Inspection Report 327,328/87-40 the inspector reviewed the proposed corrective action for this item and identified no problems.
The item was left open pending verification of corrective action completion.
TVA's technical disposition was based on a report from Central
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Laboratories. This disposition, dated August 29, 1987, indicated that the material was a standard resulfurized carbon steel that meets the specifications for AISI 1144.
Tensile properties extrapolated from the hardness values, which concur with those properties found in the literature in Table 2, indicated that AISI 1144 exceeds the tensile strength of AISI 1141, which qualified this material as acceptable for use for the intended service. The inspector had no further questions.
Example a, Sample 17-1 is closed.
l (Closed) VIO 327, 328/86-68-02, Example b, Samples 44-1 and 46-1, Fasteners Installed in the Vital Battery Rooms Number I and 11 Did Not Have Vendor or Grade Markings as Required by ASTM A307
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l TVA admitted the violations and stated that this deficiency resulted from a misinterpretation by both TVA and the bolting material suppliers of the standard for marking of bolting materials.
QIR NEB 87066 was generated February 18, 1987, to evaluate and document the disposition of unmarked bolting at Sequoyah, in Inspection Report 327, 328/87-40 the inspector stated that they had reviewed the corrective action for these items and identified no problems.
The items were left open pending verification of corrective action completion.
The inspector reviewed the results of a Singleton Materials Engineering Laboratories report issued as a result of the QIR.
The results of testing 645 unmarked bolts showed that 98.9 percent of the bolts met the
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mechanical property requirements of ASTM A307, Grade A material.
The probability of an unmarked bolt meeting the mechanical property requirements of ASTM A307, Grade A was P=0.9842 in this test. Therefore, TVA determined that unmarked bolting material installed in the field at Sequoyah is considered to meet ASTM A307 material properties and can be used as is in applicatior.s where ASTM A307 is required. The inspector had no further questions.
Example b, Samples 44-1 and 46-1 are closed.
(Closed) VIO 327, 328/86-68-02, Example c. D ' 1-8, Semple 20-3; Motor Operator Studs and Nuts for Valve 2-FCV-3-87
- re of Varying Grades and Were Not Fully Engaged in a response dated July 9,1987, TVA admitted the violation stating that the cause was indeterminate.
The response stated that the inadequate thread engagement was corrected, and that three of the eight bolts were determined to be of varying grades.
Procedural requirements had already been in place to require proper thread engagement when assembling bolted connections.
Additionally, TVA stated that shop spares would be removed from the shop and the material control in the Replacement Item Parts program should prevent recurrence of this deficiency.
In NRC Inspection Report 327,328/87-40 the inspectors stated that they had reviewed the corrective action for sample 20-3 and were able to verify that the bolt thread engagement problem was corrected, but the material grade problem had not been corrected.
However, the inspectors' review of the planned corrective action for the material grade problem of sample 20-3 identified no concerns, and this item was left open pending verification of corrective action completion during a future inspection.
The inspector reviewed the closure of WRs B240501 and B240502 and the licensee's CCTS item NCO 870204026, and found the items to be completed.
The inspector had no further questions.
Example c, D-2,1-8, Sample 20-3 is closed.
(Closed) VIO 327, 328/86-68-02, Cases in Which Nonconforming Materials Were Issued and Installed in Plant Safety-related Applications This item was closed in part by Inspection Reports 327, 328/87-40 and 327, 328/87-76 and this report as addressed above.
The closure of specific parts is tabulated in paragraph 11 of this report.
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VIO 327, 328/86-68-02 is closed in its entirety.
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(Closed) 327,328/86-68-06, Example a. D-2,1-6. Samples W15 and W18, Certified Material Test Reports Involving Specific Types of Weld Electrodes Furnished by ARCOS Failed to Include Mechanical Test Data as Required
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In a response dated July 9,1987, TVA admitted the violation and stated that the material was receipt-inspected in 1976 and 1979 by a Power Stores clerk who was not a nuclear-power-certified receipt inspector and did not have the training or knowledge to detect these discrepancies,
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TVA stated that none of the ARCOS weld rod material had been issued for use and that CAQRs 871081 and 871082 were written to disposition the material.
Additionally. TVA stated that only qualified QC inspectors are now doing receipt inspections, and that appropriate training has been given to permit them to identify problems such as those identified.
Inspection Report 327, 328/87-40 stated that TVA admitted the following examples of deficiency D-2.1-6: samples W-10. W 15, W-21 and W-22.
While TVA did not formally respond to sample W-18 in the inspection response, discussion between TVA and the NRC inspectors established that TVA's position regarding sample W-18 was the same as for W-15, which also i
pertained to ARCOS weld electrodes.
The NRC inspectors' evaluation of corrective action for the admitted violation examples, including sample W-18 determined that the action was adequate. Verification of completion of the corrective action for all examples was to be performed during a future NRC inspection.
The inspector reviewed the closure of CAQRs SQP 871081 and 871082 and determined that the licensee had initially placed "STOP, Do Not Use This Item" tags on all the weld material involved.
Secondly, completed property clearance requests were issued to sell the electrodes "where is, as is" for non safety related applications only. The material was sold and removed from the premises.
Example a. D-2.1-6, Samples W15 and W18 are closed.
(Closed) 327, 328/86-68-06, Example d D-2.1-6, Sample W10, Physically Different Gaskets For a Three Inch Masoneillan Valve Were Accepted Under the Same Part Number In a response dated July 9,1987 TVA admitted the violation and stated that it was an additional example of the violation in 327, 328/86-61 on piece / parts procurement deficiencies.
The licensee committed to prepare an engineering evaluation by August 3,1987, to ascertain the suitability for use of the gaskets, and disposition this item.
Inspection Report 327, 328/87-40 stated that the NRC inspectors determined that the corrective action for the admitted violation examples was adequate and that verification of completion of the corrective action for all examples would be performed during future NRC inspection.
The inspector reviewed the engineering evaluation dated October 24, 1987.
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The evaluation stated that based on contract information the gaskets were non-CSSC type and hence non-safety related.
Furthermore the gaskets were not governed by any code requirements other than the fact that it is subjected to QC receipt inspection.
The coating on the gaskets was
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determined to be acceptable and the gaskets of differing thicknesses were disposed of as documented in the licensee's CAQR SQP 871078.
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Example d. D-2,1-6, Sample W10 is closed, f
(Closed) 327,328/86-68-06, Instances in Which items That Did Not Meet the Purchase Order Specifications Had Been Signed-off as Acceptable During
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Receipt Inspection This item was closed in part by Inspection Reports 327, 328/87-40 and 327,
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328/87-54 and this report as addressed above.
The closure of specific parts is tabulated in paragraph 11 of this report.
VIO 327, 328/86-68-06 is closed.
(Closed) 327, 328/86-68-07 Example a. D-2.3-10, Drawings ERCW-4 and ERCW-5 Failed to Detail Weld Joints at the Interface of the Two Drawings The inspectors determined that the drawings were reversed relative to the connecting drawings and that consequently, weld records including NDE results and materials traceability documents could not be located.
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In a response dated July 9, 1987, TVA admitted the violation. They stated that the drawing discrepancies were probably caused by inadvertent deletion during construction after physical work was complete and inadequate final document review.
CAQR SQP 870926 was initiated to review records associated with the discrepant portions of drawings ERCW-4 and ERCW-5.
This review was to reconstruct the construction sequence and to identify the welds.
In Inspection Report 327,328/87-40 the inspectors reviewed the proposed corrective actions and determined them to be acceptable.
However, verification of corrective action completion was not performed at that time.
The inspector reviewed CAQR SQP 870926 and determined that the licensee had identified and recovered records for one of the nine welds discussed.
The other eight were inspected and NDE performed and documented. New weld joint histories were prepared including:
results from visual and magnetic particle inspections; the estimated dates and construction practices; and the probable welder of the eight welds as deduced from the weld maps. The inspector had no further questions.
Example a, D-2.3-10 is closed.
(Closed) 327, 328/86-68-07, Inadequate Implementation of Document Control Procedures This item was closed in part by Inspection Reports 327, 328/87-40, 327, 328/87-54 and 327, 328/87-60 and this report as addressed above. The closure of specific parts is tabulated in paragraph 11 of this report.
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VIO 327, 328/86-68-07 is closed.
(Closed) URI 327, 328/89-09-01, Motor Lubrication On March 7,1989, the licensee determined that 13 fan motors from ECCS room coolers had not been lubricated in accordance with the licensee's Qualified Maintenance Program approved for meeting the requirements of 10 CFR 50.49.
The program required lubrication for the motors to be performed at various dates on or prior to August 19, 1988.
On August 19, 1988, ONE issued a memorandum to plant maintenance allowing an extension of the lubrication date for all the motors to December 16, 1988.
On March 10, 1989 DNE issued a second memorandum extending the due date for all motors to April 15, 1989.
This memo and the associated review met the requirements of Generic Letter 88-07 and constituted adequate corrective action for the problem.
The period from the end of the original extension until March 10 constituted a violation of 10 CFR 50.49 for the coolers.
Based on the low safety significance of this particular situation, that it was licensee identified, and that the licensee took prompt corrective action, this item will not be cited because the criteria specified in Section V.G.1 of the Enforcement Policy were satisfied.
This.
item is identified as NCV 327, 328/90-06-03.
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The inspector reviewed the license's CAQR and determined that the lubrications had been performed within the specified extension time.
The licensee also reviewed other QMDS items to look for similar extension problems, implemented a tracking system to track all periodic QMDS required activitics and performed EQ training for site personnel ' involved with the program.
Therefore, NCV 327, 328/90-06-03 is considered closed.
URI 327, 328/89-09-01, Motor Lubrication, is closed.
(Closed) URI 327, 328/89-09-02, UHI Valve Operability with Scaffolding Interference In March 1989, the licensee erected a scaffold through the yoke of UHI
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isolation valve 1-FCV-87-24, obstructing valve travel.
After discovering
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the interfering scaffold, the licensee removed the scaffold, and later determined that the valve was operable and could still have performed its intended function.
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i On July 18, 1989, as documented in IR 327,328/89-19, the NRC staff l
concluded that the valve was indeed inoperable and that its ability to perform its intended function was questionable during the time the
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scaffold was in place.
On August 14, 1989, by internal memorandum, the effect of the inoperable l
UHI valve was evaluated and documented by the NRC staf f.
The staff concluded that during a large break LOCA, very little of the nitrogen injected would actually pass through the core and that the additional water injected was desirable.
The staf f also concluded that it would be
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unlikely that in the event of a small break LOCA that the ECCS acceptance
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criteria would be violated as a result of failure to isolate the UHI
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l system.
Therefore, based on the low safety significance of this particular situation, that it was licensee identified, and that the licensee took prompt corrective action, this item will not be cited because the criteria specified in Section V.G.1 of the NRC Enforcement Policy were satisfied.
This item is identified as NCV 327, 328/90-06-04.
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Corrective actions by the licensee are already in place, and no additional
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review is necessary.
Therefore, NCV 327, 328/90-06-04 is considered closed.
URI 327, 328/89-09-02, UHI Valve Operability with Scaffolding Interference, is closed.
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(Closed) VIO 327, 328/89-25-02, Failure to Inform the SOS of an Out-of-Tolerance Analysis for Unit 2 RWST Boron Concentration
On October 20,1989, by 8:15 a.m., the licensee had drawn and analyzed 2 samples from the Unit 2 RWST and determined the Boron concentration to be l
l below 2000 ppm and did not inform the SOS of this fact as required by l
TI-37 and SI-51,
The licensee determined that the reason for the violation was a failure by the Chemistry shif t supervisor to make clear in the 8:19 a.m. report to the SOS that the analytical results were based on two separate samples.
Had this been made clear, LCO 3.5.5 would have been entered. The cause of the unacceptable boron concentration results was that the range of standards used to bracket the expected sample boron concentration was too wide and the 100 ppm standard had too wide an acceptance criterion.
The changes to the chemistry analytical procedure had been made without adequate validation.
The licensee counseled the chemistry personnel on the importance of complete and timely notification of the SOS with information needed to make plant operational decisions.
The preparer and reviewers of the
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procedural change were given disciplinary action.
In addition SQE-22,
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l Sequoyah Nuclear Plant Chemistry Program, was revised to clarify that the SOS should be notified after the results of the first sample shows adverse results, even though there may be open issues relative to the sample or analysis quality.
The inspector had no further questions.
This violation is closed.
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(Closed) 327,328/89-25-01, Failure to follow SI-137.2, Reactor Coolant
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System Water Inventory
$1-137.2, ICF 89-0758 section 4.9 and the associated flow chart, requires
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that if unidentified leakage is calculated to be negative, then the i
calculations will be reperformed using a minimum of one hour of additional
data. On October 18, 1989, the Unit 2 operators completed the performance of SI-137.2 at 7:26 a.m. and determined that the unidentified leak rate was negative.
However, they did not take additional data as required by i
section 4.9 in ICF 89-0758.
i The licensee stated that the reason for the violation was inattention to i
detail by the personnel performing the SI in that the additional hour of l
data collection stipulated in the procedure was not performed.
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contributing cause for the violation may have been that the procedure being used to perform this surveillance was not clear.
At the time this l
violation occurred, four ICFs had accrued in SI-137.2, which resulted in a
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patchwork procedure that no longer provided clear, step-by-step instructions to the performer of the surveillance.
As corrective action, the licensee disciplined the individuals involved and reperformed the surveillance activity.
Additionally, SI-137.2 was revised to incorporate the ICFs into a more clearly understandable text.
The licensee evaluated the AI-4, Preparation, Review, Approval and Use of I
Site Procedures / Instructions, guidelines to determine if there is adequate guidance to prevent a procedure from becoming a patchwork that may be
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difficult to understand when multiple ICFs accrue. The review found that the ICF process delineated in AI-4 adequately addressed the concerns mentioned above and that the particular problem with SI-137.2 was an isolated event. The inspector had no further questions.
VIO 327, 328/89-25-01 is closed.
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(Closed) VIO 327, 328/89-07-01, Failure to Establish Implement or Maintain i
Procedures for Safety Related Activities (examples A through F)
Example A. Wedged Fuel Assembly as a Result of an Inadequate Procedure.
This violation example addressed the failure to provide adequate procedural and/or QC controls over a refueling operation.
During the refueling operation, a fuel handling operator was required to verify that the fuel handling cart was fully inserted before upending the fuel assembly.
The inspector reviewed the licensee's response
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(Ray /NRC) dated May 18, 1989, RIMS L44 890518 802, and determined that the licensee's initial corrective actions were adequate.
The actions included repair of a defective load cell and upender torque switch.
In addition the applicable fuel handling instruction was amended to require QC independent verification of fuel assembly
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Finally, the licensee initiated CAQR SQP 890083 which includes in its long term corrective actions'
t Before the next refueling, do a thorough checkout of the system using vendor support and Sequoyah engineering support.
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Before the next refueling, provide a reliable method to give
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interlocks to prevent upending of a bundle unless the cart is
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in the proper position, j
l The licensee's corrective actions appeared to be adequate.
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Example 3, Handwritten Procedure for UHI Venting
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This violation example addressed the failure to provide adequate work instructions to vent the UHI nitrogen accumulator.
The inspector
reviewed the licensee's corrective actions documented in TVA letter r
(Ray /NRC) dated May 18, 1989 RIMS L44 890518 802.
In addition the
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inspector reviewed Revision 15 to administrative instruction Al-58, Maintaining Cognizance of Operation Status - Configuration Status l
Control, and CAQR SQN 890143.
The licensee's corrective actions l
appeared to be adequate.
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Example C, Seismic Qualification of Unit 2 Bailey Meters This violation example addressed the failure to provide an adequate
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safety evaluation and temporary alteration.
The inspector reviewed the licensee's corrective actions documented in TVA letter (Ray /NRC)
dated May 18, 1989, RIMS L44 890518 802.
In addition, the inspector
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reviewed revised TACF 2-88-2019 and 1-88-22-500.
The licensee's I
corrective actions appeared to be adequate.
Example D, Failure to Adequately Lithiate and Borate a Resin Bed This violation example addressed the failure to follow System Operating Instruction S0I 62.4, Chemical and Volume Control System, while placing a resin bed in service. As a result of this inadequate
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system control, the licensee placed an untreated resin bed in service which resulted in a mild power transient and required emergency boration of the RCS.
The inspector reviewed the licensee's corrective actions documented in TVA letter (Ray /NRC) dated May 18, 1989, RIMS L44 890518 802.
In addition, the inspector also reviewed CAQR 890016 which documented the issue. The licensee's corrective actions appeared to be adequate.
Example E, Failure to Follow Abnormal Operating Instruction A01-3, Malfunction of Reactor Makeup Control This violation example addressed the failure to follow A01-3 following a mild power transient requiring emergency boration of the RCS due to placement of an untreated resin bed in service.
The inspector reviewed the licensee's corrective actions documented in TVA letter (Ray /NRC) dated May 18,1989, RIMS L44 890518 802.
In addition, the inspector reviewed Operations Night Order #72, and
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Revision 8 to A01-3.
The licensee's corrective actions appeared to be adequate.
Example F.
Tailure to Provide Adequate Instructions for Maintenance Activities This violation example addressed the failure to provide adequate work instructions for WR 328429, Condensate Dump back Flow Recorder.
The wirk activities performed under this WR caused a reactor trip. The inspector reviewed the licensee's corrective actions documented in TVA letter (Ray /NRC) dated May 18,1989, RIMS L44 890518 802. In addition, the inspector reviewed LER 327/89-05, and preventive maintenance activities SQN-PMSP 6.2.1 and SQN-PMSP 6.2.3.
The licensee's corrective actions appeared to be adequate.
The licensee's corrective actions for violation 327,328/89-07-01 examples A through F appeared to be adequate.
This violation is closed.
(Closed) URI 327, 328/89-25-03, Boric Acid Sampling Analysis The Resident Inspector staff requested assistance from the Region II Radiological Effluents and Chemistry Section in evaluating Unresolved Item 327, 328/89-25-03 concerning inaccuracies in boron concentration determination.
In response to this request inspection 327, 328/89-28 was performed.
The inspection activities performed under inspection 327, 328/89-28 included a review of Event Report 11-89-076, and a review of the events surrounding an RWST analysis performed on October 20, 1989.
The inspector concluded that activities and records used during the analysis in question were appropriate and that no violations of NRC regulations were identified.
The inspector had no further questions.
URI 327, 328/89-25-03 is closed.
8.
Electrical Inspection (92700, 92702)
The inspectors reviewed a number of electrical system and distribution related issues, a.
(Closed) LER 327/89-03, Brief Interruption of Control Power This LER addressed the failure of feeder breaker 1718, on the 6.9 KV shutdown Board 1A-A to open on demand and the auto start of the motor driven auxiliary feedwater pump A. The failure of the breaker was caused by the failure of relay 05.
The LER did not identify the relay type nor the manufacturer.
The inspector's review of the work request WR B79753 determined that the relay was a Telemecanique, P/W J13PA6012, 10 second time delay relay.
The LER stated that the relay f ailure was considered random.
During the investigation of the DS relay f ailure a positive ground was observed on the 125 VDC vital battery III.
The licensee thought the battery ground and the DS relay f ailure may have been related.
It was during this search for the battery ground that the blackout BOY relay and other under
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voltage UVY relays caused the MDAFWP to start.
The inspector's i
review of work request B797602 for the determination of the battery j
ground determined that the DS relay was not involved. However, there r
i was a 24 volt negative ground on breaker 303 circuit and a 120 volt positive ground on valve 2 FSV 30 135 circuit.
As part of the corrective action the licensee placed permanent caution tags near selected 125 VDC breakers to alert Operations
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personnel that operation of these breakers could cause ESF r
actuations. Further, procedures were issued to specify the method to t
t search and isolate bettery grounded circuits without causing an ESF actuation and n,ethods to accomplish transfer of the alternate control bus back to its normal feeder without causing an ESF actuation.
The
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inspector reviewed General Operating Instruction G01-9.1, 6900V and
480V Shutdown Board Ground Location and Isolation Procedure Revision
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O, and System Operating Instruction 501-203.1, 6900V and 480V
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Shutdown Board DC Control Bus Transfer Procedure, Revision 0.
The
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inspector discussed with TVA a caution note in 501-?03.1.
The
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caution note stated:
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The AC electrical boards will not be transferred tn their AC l
alternate supply source to support this instruction.
Many l
alternate feeders have not yet been determined operable.
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TVA's response was that operable meant that all of the alternate
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supplies have not been evaluated by Nuclear Engineering regarding
adequate ampacity and trip setpoints. These evaluations were done for l
the normal supplies prior to restart of Unit 2.
TVA identified the
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correct root causes and provided adequate corrective action.
LER 327/89-03 is closed.
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b.
(Closed)LER 328/88-34, four Operational Events and Subsequent Stcrt
of All Diesel Generators l
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One of the events resulted in a TS violation because the offsite
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Transmission Operating Group (TOG) was not aware of the TS i
requirement.
During inspection 50 327, 328/89-14 for overvoltage conditions, the corrective action in this LER to improve
comunication between the plant and the offsite Transmission l
Operating Group was reviewed.
The training included a review of the i
guidelines implemented by the TOG to maintain the offsite power system for Sequoyah.
The inspector found this corrective action to
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be adequate.
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One condition resulted due to a phase to ground fault of 6.9KV start bus 2A from the phase c bus bar to the cabinet wall which caused an arc burn and damage.
This electrical fault was due to dust and moisture in the compartment. Inspection on other nearby breaker compartments revealed a thick layer of dust on insulators, cts, etc and indications of water droplets. The corrective action to prevent
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recurrence was to review and implement preventive maintenance instructions.
During a walkdown, the inspector observed the bus housing modification which would prevent moisture from entering the bus housing, The inspector reviewed the preventive maintenance detailed work instructions (PM) 1310, 1311, 3312, 1313, 1314, 1315 and 1316 for cleaning and assuring that moisture does not enter the bus housing.
The present PM content and frequency is the same as the PM prior to this LER event.
The 6.9 KV bus IB which is outside and
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along the turbine building south wall was due to be inspected on October 31, 1989, but was rescheduled to February 21, 1990.
TVA identified the correct root causes of this event and provided adequate corrective action.
LER 50-328/88-34 is closed.
c.
Battery Inspection The inspector walked down the 125 volt DC vital batteries I, II III,and IV, and the standby maintenance battery V.
The inspector observed that there was slight corrosion on cable leads between the terminal lug and where the insulation pulled off the terminal lug.
This exposure of the conductor to the battery electrolyte was caused by the bend from the upper rack to the lower rack.
The inspector reviewed the vital battery V pilot cell data trend from January 18, 1988 through January 29, 1990 during which time vital battery V was used only for replacement of other vital batteries for maintenance activities.
The electrolyte specific gravity lowest value was 1.191 on March 14, 1988 and the highest was 1.216 on December 4, 1989.
The specific gravity was 1.204 on January 29,
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1990.
The licensee informed the inspector that battery acid was added to the pilot cell because of the electrolyte loss during the repeated specific gravity testing.
The lowest pilot cell voltage was 2.04 volts an January 18, 1988 and February 1, 1988.
The pilot cell voltage was 2.17 volts on January 29, 1990.
Technical Specification.
Table 4.8.2, Battery Surveillance Requirements, indicates that the limits for the pilot cell specific gravity should be equal to 1.200 or additional surveillance is required, and the float voltage is greater than 2.13 volts. The minimum acceptable value for each of the connected cells is a specific gravity equal to or greater than 1.195 and a float voltage greater than 2.07 volts.
The inspector reviewed a sample of battery $1-100 performances for battery V, and determined that with one exception, the average specific gravity was 1.201 which was below the average specific gravity criteria of 1.205.
The inspector reviewed the capacity discharge surveillance tests, SI-105.5, and determined that this battery may be used for a temporary replacement for the other 125 volt safety-related l
batteries.
The inspector reviewed the use of vital battery V and l
determined that in the cases reviewed the vital battery replaced was considered out-of-service and TS requirements were met.
The inspector had no further questions.
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d.
(Closed) URI 327, 328/88-34-01, inadequate Review of GO!-2 Change for SG Level During Startup This URI involved the inadequate review and implementation of a change to G01 2 Plant Startup From Hot Standby, which allowed SG 1evels to be maintained at a higher value than specified by plant design documents.
The G01 2 change allowed the operators to maintain levels at 48 percent rather than 33 percent. After discussions with the inspectors and with Westinghouse, the licensee rescinded this change without actually implementing it.
Because the change was not actually implemented, the safety significance was determined to be low.
Problems with the review process for procedure changes have been the subject of several recent violations.
These include the escalated enforcement violation issued in IR 327, 328/89 15 concerning the licensee's safety evaluation program. The licensee's response to violation 327, 328/89-15-04 is considered adequate to prevent inappropriate procedure changes such as the example in this URI from recurring.
URI 327, 328/88-34-01 is closed.
9.
AdministrativeReviewofNRCInspectorfollowupItems(92701)
The following Inspector Followup Items (IFI) were reviewed by a special NRC team and in parallel by a licensee management committee prior to the restart of Unit 2 and/or the restart of Unit 1.
These items were reviewed to determine whether any of the items met the criteria of having safety significance.
The safety significance criteria (restart criteria) had been submitted by the licensee and approved by the NRC, None of the below listed items met the safety significance criteria.
In addition, these items were discussed by memo in 1987 and/or 1988 with NRC Region !!
management and none of the items were identified as having any safety or regulatory significance.
Finally, the inspector administrative 1y reviewed these issues and determined that licensee management was aware of the issues, had taken what it felt was appropriate corrective actions, and that no safety or regulatory issues were identified.
Therefore, the following inspector followup items are administrative 1y closed.
327,328/86-11-02 327,328/86-18-05 327,328/86-18-06 327,328/87-61-09 327,328/88-14-01 327,328/88-57-04 327,328/88-32-01 328/85-21-03
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The majority of the following Unresolved items (URI) and NRC violations were reviewed by a special NRC team and in parallel by a licensee management committee, prior to the restart of Unit 2, the restart of Unit 1, and/or by the resident inspector staff.
These reviews were performed in accordance with licensee submitted and NRC accepted safety significance criteria (restart criteria),
in addition these items were discussed by memo in 1987 and/or 1988 with NRC Region 11 management and none of the items were identified as having any safety or regulatory impact on the continued operation of the units.
Finally, the inspector administratively reviewed all of the below listed issues and determined that licensee management was aware of the issues, had taken appropriate corrective actions, and that no safety or regulatory issues were currently identified. Therefore, the following issues are administrativel) closed:
327,328/87 68 01 327,328/88-50-04 327,328/88-50-05 327,328/88-50-07 327,328/88 09-01 327,328/88 09-02 327,328/88-40-02 328/85-24-03 11. LicenseeEventReportfollowup(92700)
The following LERs were reviewed and closed. The inspector verified that:
reporting requirements had been met; causes had been identified; corrective actions appeared appropriate; generic applicability had been considered; the LER forms were completed; no unreviewed safety questions were involved; and violations of regulations or Technical Specification conditions had been identified. Unless otherwise indicated, the inspector had no further questions and the LERs are closed.
UNIT 1 327/88-46 and 327/85-23, Seismic Qualification of Molded Plugs.
These LERs were reopened in inspection report 327,328/89-27, in order to review the licensee's programmatic and generic corrective actions.
The inspector reviewed these corrective actions and determined that the last of the corrective actions that apply to these specific cases is currently scheduled, tracked, and planned by the licensee. The inspector had no further questions.
327/89-04, R1 Seismic Monitor Annunciator Switches were Outside Acceptable Limits Due to an inadequate Instructio r l
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327/89 09 C0 Syftem Protecting Computer Room Was Discovered Inoperable Due To Personnel Error.
327/89 10 6900 Y Shutdown Board 28-B Auxiliary Relays DS and DV Exceeded the NRC Surveillance Frequency Due. to an inadequate Determination.
327/89-17 Failure to Properly Calibrate the Pressurizer Level Control Transmitters.
327/89 21 Diesel Generator Board Room 1A-A Operability When Fire Door Failed to Close During Performance of Surveillance Instruction 237.2.
327/89 22 An Event Where LCO 3.0.3 Was Entered as a Result of Exceeding the Time Limit of Action 2.d of LCO 3.3.1.1 Following the Loss of One Excore Detector.
This issue resulted in a separate violation.
327/89-25 Inoperability of All Four Diesel Generators.
327/89 26 Entry into LCO 3.0.3 as a Result of More Than One RPI Per Bank Being Inoperable Because of a Lack Of Preventive Maintenance to CRDM Cooling System Dampers.
327/89-27 Failure to Demonstrate Operability of Spray and/or Sprinkler Systems as Required by Technical Specifications as a Result of an inadequate Procedure.
327/89-29 Control Room Isolation During Maintenance Activities Due to Accidental Bumping of Control Room Isolation Relays.
327/89-30 Fire Suppression System Yalve Isolated for More Than One Hour Without Required Continuous Fire Watch Being Established as a Result of Personnel Communication Breakdown.
327/89-33 Refueling Water Storage Tank Level Transmitters Failed Because of Freezing During Cold Weather.
This issue resulted in a violation issued in IR 90-01.
327/89-34 Increased Airborne Activity in the Auxiliary Building Resulted in the Suspension of Fire Watch Patrols ard Subsequent Noncompliance With Technical Specifications 3.7.12, i
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UNIT 2 328/89 02 Two Reactor Trips Occurred While Unit 2 was in Cold Shutdown During Performance of Response Time Testing Because of Deficient Procedure.
328/89-04 Operational Mode Change Made Without Exception to Limiting Condition for Operation 3.0.4 Due to a Misinterpretation.
328/89-06 N!S Intermediate Range Reactor Trip Setpoints Were Nonconservative When the Detectors were Placed in the Withdrawn Position Without Rescaling. This issue resulted in a separate violation and several meetings with the licensee.
328/89-09 Failure to Perform Ice Bed Temperature Monitoring as Specified in Technical Specification Limiting Condition for Operation 3.6.5.2.a.
12.
Event follow-up (93702)
a.
On February 26, 1990, Sequoyah Unit 1 experienced a containment ventilation isolation.
This ESF actuation was the result of a failure to adequately perform a surveillance instruction and will be reviewed by the inspector following the issuance of the licensee's LER.
b.
Ole February 22, 1990, Sequoyah Unit 2 entered LCO 3.6.5.1 for an inoperable ice condenser.
The LCO entry was in response to NRC resident inspector questions about the adequacy of channel flow inspections.
Upon completion of the Unit 2 ice condenser inspection and completion of a special surveillance inspection on five bays in Unit 1, the inspector will review the test results.
This issue was discussed in paragraph 3 as URI 327, 328/90-06-02.
c.
On February 28, 1990, an inadvertent rod withdrawal was caused by failure of Tave auctioneering unit.
The inspectors reviewed the circumstances of this event and concluded that licensed operators acted promptly tn terminate the event.
Later investigation by the licensee of the auctioneering unit failure revealed the power supply breaker to the auctioneering unit had tripped.
The licensee has been unable to determine the cause of the breaker trip.
13.
10 CFR 21 and Other Technical Issues (93702)
a.
GTE Sylvania Contactors On January 4,1990, another utility identified a problem with Type TM GTE Sylvania manufactured contactors for electrical circuit breakers.
On January 16, 1990, an inspection of eight safety related motor
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control centers was performed and six contactors were found to have loose screws on the contact carriers.
An industry advisory Significant Event Notification (SEN) was issued on January 17, 1990.
The TVA Nuclear Experience Review (NER)
received the issue on January 30, 1990.
On February 2.1990, the licensee preliminar11y determined that there were no GTE Sylvania contactors of this type installed at Sequoyah.
No action was identified and the issue was routed to site Engineering. Technical Support, Maintenance, cnd Procurement.
The licensee's corrective actions appeared to be adequate and the inspector had no further questions.
b.
Agastat Relays On November 16, 1989, another utility identified a problem with Agastat relay models E7000 and 7000, which were used to sequence emergency loads on to both offsite power and the emergency diesel generators.
The other utility determined that an unanalyzed condition existed related to sequencing electrical loads onto offsite power due to degraded grid voltages.
The resulting condition could cause shedding of emergency busses from offsite power,ical loads. starting the emergency diesel generators, and resequencing electr An industry advisory Significant Event Notification (SEN) was issued on November 17, 1989.
TVA Nuclear Experience Review (NER) received the issue on November 21, 1989.
On November 21, 1989, the licensee determined that loads were not sequenced onto offsite power.
The issue was routed to Operations and Maintenance for information because the licensee has done extension studies and calculations and determined that no diesel generator voltage degradation exists at Sec uoyah.
The licensee's corrective action appeared to be adequate anc the inspector had no further questions.
c.
P2189-12 - SMB 000 and SMB-00 Torque Switches On September 29, 1989 the Limitorque Corporation submitted a letter to the NRC pursuant to the requirements of 10 CFR 21 and simultaneously provided the same information to its customers.
This letter described a common failure of SMB-000 and SMB-00 cam type torque switches installed in motor operators supplied prior to 1981 and 1976 respectively.
The potential failure was related to the loosening of stationary contact screws on the side of the torque switch which have fiber spacers.
The manufacturer recommended that actuators with the cam-type torque switch and fiber spacer be replaced during the next available maintenance period.
TVA received the letter on October 6,1989 and Sequoyah NER received the information on October 10, 1989, and a CAQR (890560) was issued on October 12, 1989.
The CAQR determined the issue to be an operability issue with no immediate required
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corrective actions.
The basis for not perfoming immediate corrective actions was that:
No immediate operability concern exists as a result of this notice.
The manufacturer recomends corrective action to be completed during the next available maintenance period due to the small number of reported failures (i.e., three occurrences, the first in 1980).
Additionally, substantial maintenance (i.e., refurbishment, M0 VATS test, etc.) has been performed on safety related actuators as a result of EQ and Generic Letter 85-03 which would have identified problems such as described in the notice.
The inspector reviewed the outage schedule to determine if the subject components were scheduled for examination and determined that the licensee had established Unit 1, cycle 4 (March 1990) and Unit 2, cycle 4 (October 1990) action dates.
The inspector reviewed maintenance history on safety related SMB-000 and SMB-00 actuators and determined that no history of similar failures existed at Sequoyah. The inspector had no further questions, d.
P2189-11. EMD 645E4 Tandem Air Start Control System On August 4, 1989 TVA issued Watts Bar CA0R 890376 and determined it to be generic to Sequoyah. This issue had been previously identified on Nonconforming Condition Report W-314-P on November 29, 1985. On September 25, 1989 TVA issued Sequoyah CAQR SQP 89 0523 addressing the redundant diesel generator equipment such as air compressors, accumulators, starting air motors and accessories.
The licensee discovered that loss of starting air to one engine of the tandem diesel generator would result in energizing the recycle network which would only allow the redundant air starting motors to engage for 0.5 seconds to the other engine thus preventing a diesel generator start.
On September 29, 1989, Sequoyah prepared a JC0 in accordance with Al-12, part 111, Corrective Actions. The JC0 determined that:
No operability problem exists.
No TS requirements have been violated.
Each diesel generator has an independent air start system.
If one DG should be inoperable due to air start failure, three DG will remain operable.
This is within the requirements of TSs.
The DG air start systems are tested periodically by the SI 166.36 series and SI 102 electrical monthly.
These sis verify operability of the DG air start system.
The inspector reviewed Surveillance Instructions (SI)
SI-170.2 Periodic Calibration of the Standby Diesel Generator IB B, and $1-102 E/SA, Diesel Generator Semi-annual Electrical Inspection.
In addition, the inspector determined that an alarm in the control room i
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P2189-14, Foxboro NEll and NE13 Transmitters Containing 10-50 ma Type Amplifier On October 6,1989 the Foxboro Company issued a letter to TVA (S. White) informing them that certain transmitters had deficient B0142EC amplifiers requiring replacement of all amplifiers manufactured from January 1,1988 through September 1,1989.
The letter further stated that the transmitter operation could be affected in the form of current output oscillations which may suddenly occur because of bridging and/or contact resistance changes from improper connections.
Sequoyah conducted a physical walkdown of Foxboro transmitters in the plant and power stores on October 15 through 17, 1989.
No deficient transmitters were identified.
The issue was technically addressed in EQ binder SQNEQ-IPT-002. The inspector had no further questions.
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P2189-01 Brown Boveri Circuit Breakers This 10 CFR 21 report discussed a K-line circuit breaker configuration that resulted when there was no rebound spring installed to the slow close bar.
This rebound spring prevents the slow close bar from vibrating to an undesired position.
The manufacturer detennined that users of K-line K-225 through K-2000 circuit breakers, which were delivered prior to July 1974, should add the rebound spring to the slow close pin in accordance with the instructions included in installation bulletin 8901.
This issue was also discussed in NRC Information Notice 89-029 and industry notice SEN 89-058.
In addition, TVA NER program addressed this issue under RIMS L33 890418 810. L33 890222 804, and L33 890418 809.
The licensee determined that the components identified in this Part 21 report were not utilized at Sequoyah.
The inspector had no further questions, g.
P2188-09, X0M0X Assembled Limitorque Actuators This 10 CFR 21 report identified manufacturing flaws in certain butterfly and plug valves assembled by X0M0X corporation.
Sequoyah identified that 24 of the subject valves were in power stores. The defective valves were quarantined and CAQR SQP880079 was issued for corrective actions.
One of the possible corrective actions is the use of an upgrade kit supplied by the manufacturer.
The inspector had no further question,
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P2188-03, Gamma-metrics Cable Assemblies This 10 CFR 21 report identified a potential manufacturing defect in the cable assemblies for neutron flux monitors which could be installed in the post-accident monitoring system.
The defect involved a solder joint on a power supply.
TVA determined that the only purchase made for this type of equipment was on a contract for Bellefonte.
The equipment was later shipped to Sequoyah for installation.
Based on a November 30, 1987 letter from Gamma-metrics, TVA determined that the equipment to be installed at Sequoyah did not use the problem power supply.
TVA reviewed and closed this item under NER 870897.
The inspector had no further questions.
1.
P2188-01, Worm Shaft Gear Failures in Limitorque Actuators The issue discussed in the 10 CFR 21 report was a Limitorque valve actuator failure mechanism associated with the transfer of the actuator clutch mechanism from the manual to the motor drive mode when certain critical speeds were combined with repetitive transfers.
The vendor recommended two alternate corrective actions one of which involved the removal of the clutch trippers.
The vendor further stated that if the removal of the clutch trippers was completed, the performance of the existing actuators was not affected.
TVA removed the clutch trippers from the valves identified b Several long term actions are still outstanding.y the manufacturer.The inspector had no further questions, j.
P2189-18, Melamine Torque Switches in Limitorque Actuators The issue discussed in this 10 CFR 21 report was a defect in SMB-000 and SMB-00 actuators associated with the post mold shrinkage of the Melamine torque switches.
The licensee responded to the issue in NER 890070 and a resulting CAQR SQP 890032.
In the CAQR, the licensee documented a justification for continued operations (JCO) and established a schedule for switch replacement.
The JC0 identified two f ailure situations - torque switch / cam binding and locked rotor.
The JC0 further discussed that these two situations could be identified with a current signature of the valve and that:
TVA's MOVATS program at SQN develops a motor current signature which would identify either of the above situations.
M0 VATS testing was completed for all safety related active actuators prior to restart of both units (refer to the Nuclear Performance Plan section 4.3.3).
The inspector had no further questions.
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CAQRs Invalidated Improperly The inspector reviewed an issue involving CAQRs that had been invalidated without proper administrative controls as specified by the licensee's corrective action program.
The specific CAQR reviewed was written to document a condition of nonconformance by the plant in implementing a corporate standard Safety Evaluation program on the required date.
The standard, NP STD 6.1.3 was required to be implemented by September 8,1989.
The Site Director at Sequoyah decided to delay implementation of the standard until certain revisions were made to the program.
TVA corporate had agreed to make the revisions, but no agreement was reached regarding an extension date for the implementation.
A CAQR was written detailing the fact that the plant was in nonconformance with a commitment to the NRC to implement a revised Safety Evaluation program by September 8,1989.
This CAQR, SQP 890531. met the criteria described in Al 12 Corrective Action, for a CAQR.
The CAQR was, however, declared invalid by the Site Director, without proper justification for that invalidation.
The justification given was merely that the condition described was not a condition adverse to quality.
A revised version of STD 6.1.3 was subsequently implemented on November 7, 1989.
The new program and its implementation were the subject of IR 327, 328/90-01.
Other CA0Rs have been invalidated which were later determined to be valid.
This issue is discussed in IR 327. 328/90 03, paragraph 8.
In addition, an audit conducted by site QA, Audit 89001, determined that 5 CAQRs dispositioned as invalid in 1989 were in fact valid.
The individual CAQRs were corrected and the audit concluded that further corrective actions were not required.
The inspector had no further questions.
SSOMI Close-out The following is a tabulation of the close-out outage modification associated with the items as listed in the original Safety Systems Outage ModificationsInspection(SSOMI) Report 327, 328/86-68.
The inspectors review of the SSOMI items identified several items that were not completely closed, as noted in the tabulation.
Several additional issues were also identifie,
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SSONI Inspection Items Violation Report Deficiency Sample Close Out Number Example Section Number Number Action 86-68-01 a.
2.1.1. 3 D-2.1-3 32-2 87-60 Closed 41-1 87-60 Closed b.
2.1.1.2 0-2,1-2
87-40 Closed c.
2.1.1.1 0-2.1-1 30-1 87-40 Closed Closed in its entirety in IR 327, 328/87-76.
86-68-02 a.
2.1. 3.1 17-1 90-06 Closed b.
2.1.3.1 44 1 90-06 Closed 4b-1 87-76 Closed 46-1 90-06 Closed c.
2.1.3.1 D-2.1-7 45-2 87-76 Closed 11-5 87-40 Closed 12-1 87 40 Closed 13 1 87-40 Closed-6-2 87-40 Closed 10-3 87-40 Closed
87-40 Closed 1-2 87-76 Closed 3-1 87-40 Closed
87-40 Closed 2.1. 3. 2 0-2.1-8 7-1 87-40 Closed 13-3 87-40 Closed 19-1 87-40 Closed 19-3 87-40 Closed 20-3 90-06 Closed 21-1 87-40 Closed 40 1 87-40 Closed 19-5 87-40 Closed d.
2.4.9 D-2.4-10 87-40 Closed Closed in its entirety in IR 327, 328/90-06.
86-68-03 a.
2.1.4.1 0-2.1-9 W 30 87-40 Closed b.
2.1. 4. 2 D-2.1-10 4-3 87-40 Closed 8-1 87-40 Closed 9-3 87-40 Closed 10-6 87-40 Closed 41-1 87-40 Closed 11-2 87-40 Closed 22-2 87-40 Closed
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2.1.2.2 0 2.1-5 W5 87 40 Closed W8 87 40 Closed W9 87-40 Closed W 11 87-40 Closed W 13 87-40 Closed Closed in its entirety in IR 327, 328/87-76.
86-68-04 2.1. 2.1 0-2.1-4 87-40 Closed Closed in its entirety in IR 327, 328/87-40.
86-68-05 a.
2.4.10 0-2.4 11 87-40 Closed D 2.4 12 87-76 Closed D 2,4-13 87-76 Closed D-2.4-14 87 40 Closed b.
2.4.1 D-2,4-1 86 60 Closed D-2.4-2 87 40 Open c.
2.4.2 0-2.4-3 87 60 Closed 2.4.3 D-2.4-4 87 60 Closed 2.4.4 0-2.4-5 87 65 Closed 2.4.5 0-2.4-6 87-65 Closed 2.4.6 D-2,4-7 87 40 Open 2.4.8 D-2.4-9 87-40 Closed 2.5.5 D-2.5-1 87-76 Closed d.
2.3.9 D-2.3-9 87-40 Closed 2.4.7 D-2.4-8 87-40 Closed 2.4.13 0-2.4-15 87-40 Open 2.4.14 D-2.4-16 87-65 Closed 2.4.15 0-2.4-17 87-60 Closed 2.4.17 D-2.4-18 87-60 Closed 2.4.18 D-2.4-19 87-60 Closed 86-68-06 a.
2.1.2.5 0 '.1-6 W 15 90-06 Closed W 18 90-06 Closed b.
2.1. 2. 5 W 12 87-40 Closed c.
2.1.2.5 W 21 87-54 Closed W 22 87-54 Closed 42-1 87-54 Closed d.
2.1. 2. 5 W 10 90-06 Closed Closed in its entirety in IR 327, 328/90-06.
86-68-07 a.
2.3.1 0-2.3-1 87-60 Closed 2.3.3 D-2.3-3 87-40 Closed 2.3.4 0-2.3-4 87-60 Closed 2.3.6 0-2.3-6 88-19 Closed 2.3.7 D-2.3-7 87-40 Closed 2.3.11 D-2.3-10 90-06 Closed
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2.3.2 D-2.3-2 87-60 Closed 2.3.4 D-2.3-4 87-60 Closed 2.3.8.1 0-2.3-8 9966 87 40 Closed 11313 87 40 Closed 11580 87 40 Closed 2.3.8.2 87-40 Closed 2.3.8.3 87-40 Closed 2.3.8.4 87-40 Closed 2.3.8.5 87 40 Closed 2.3.8.6 87-54, 87 40 Closed 2.3,8.7 87 40 Closed 2.3.8.8 87-40 Closed Closed in its entirety in IR 327, 328/90-06.
The following item numbers were assigned for tracking purposes by the inspector and do not appear in Inspection Report 327, 328/86-68.-
S6 68-08 2.1.2.3 U-2.1-1 87 54 Closed 86-68-09 2.1.2.4 U-2.1-2 87-54 Closed 86 68-10 2.1. 3.1 U-2,1-4
'87-54 Closed 86 68-11 2.1.3.1 U-2.1-5 86-68-12 2.2.1 U-2.2-1 87-76 Closed 86-68-13 2.3.1 U-2.3-1 87-40 Open 86-68-14 2.4.1 U-2,4-1 86-68-15 2.4.11 U-2.4-2 87-71 Closed 86-68-16 2.4.12 U-2.4-3 87-76 Closed 86-68-17 2.4.14 U-2.4-4 86-68-18 2.5.4 U-2.5-1 The following items are not associated with violations but were addressed as deficiencies in the report.
2.3.5 D-2.3-5 87-40 Open 2.3.12 None 87-40 Closed
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The following items were designated as Open items and have not been addressed in any inspection report since that time:
2.1.2.5 0-2.1-1 2.5.1 0-2.5-1 2.5.2 0-2.5-2 2.5.3 0-2.5-3 2.5.6 0-2.5-4 2.6 0-2.6-1 2.6 0-2.6-2 The above listed items were reviewed and tabulated by the inspectors with some closures in paragraph 7 of this report and as noted on the table.
Those items remaining were reviewed by a special NRC team and in parallel by a licensee management comittee prior to the restart of Unit 2 and/or the restart of Unit 1.
These items were reviewed to determine whether any of the items met the criteria of having ) safety significance.
The safety significance criteria (restart criteria had been submitted by the licensee and approved by the NRC.
None of the above listed items met the safety significance criteria.
Finally, NRC inspectors have reviewed these issues and determined that licensee management was aware of the issues, was taking what it felt was appropriate corrective actions.
Therefore, these items are administratively closed, and the final licensee corrective action and closure of those items identified as open will be tracked under IFI 327,328/90-06-05, Resolution of SSOMI Issues.
15.
LicenseeSelfAssessmentOrganizations(40500)
The inspector reviewed the periodic reports and activities associated with the licensee's self assessment organizations.
In addition, the inspector interviewed the new heads of the self assessment organizations, and attended a sample of self assessment organization meetings.
The site Quality Assurance (QA) organization, Independent Safety
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Engineering Group (ISEG), Nuclear Safety Review Board (NSRB), Nuclear
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Manager's Review Group Nuclear Experience Review (NER) Staff, Management l
Review Committee (MRC) and Plant Operation Review Committee (PORC), were
reorganized during this assessment period.
Following their reorganization and assignment of new managers, the PORC, QA, ISEG, and NSRB each took a
more aggressive role in the identification and resolution of safety and
l regulatory issues.
The NSRB and ISEG increased their site contact and visibility. The ISEG and its functions were combined with the NMRG.
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l The combination of Independent Qualified Review (1QR) and the new PORC
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organization increased the effectiveness of PORC.
The number of issues addressed by PORC dropped, allowing PORC to spend additional time on the
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more safety significant issues.
One weak review performed by PORC was identified, concerning the removal of heat trace on several Refueling i
Water Storage Tank level transmitters.
The removal of the heat trace i
resulted in frozen level transmitters, two LCO entries, and a request by the licensee for TS relief.
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The MRC was established by the if censee to evaluate and ensure the
resolution of potential conditions adverse to quality.
The MRC has been
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very exacting and insightful during the evaluation and operability
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determination processes afforded potential conditions adverse to quality.
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During a special inspection the NFlC determined the decisions made by the i
MRC to be adequate and conservativo.
In general, the NER process implenentation, which is based on a TVA THI action item commitment, was adequate.
Although some items were " hand
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carried" to the responsible group, the NER site function appeared to be limited to distributing NER items for information.
The NER engineer did i
not initiate CAQRs instead the receiving organizations made these
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determinations.
One specific NER case, involving NRC Bulletin 88-04,
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resulted in a condition adverse to quality with respect to dead headed RHR
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pump discharge pressures.
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Following its reorganizatiun and t$e assignment of a new site QA manager, the site QA organization consisted of three main functions: Quality Surveillance (QS) which performed surveillance and audit activities,
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Quality Control (QC) which performed work release and inspection l
functions, and Quality Engineering (QE) which performed Division of Nuclear Engineering (DNE) activity reviews, i
i QC activities at the site are adequate and consistent with QA program
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requirements.
QS and QE activities were aggressive and supported quality plant operations as evidenced by the number, technical or programmatic orientation, and significance of their findings.
Site line management response has been positive and cooperative f n the resolution of the identified issues, and routinely requests assistance f rom these groups.
Finally, QS and QE have taken an assertive and visible role in incident investigations, MRC activities, PORC activities and site action plans resulting in effective quality program improvements.
The inspector had no further questions.
16.
Exit Interview (30703)
The inspection scope and findings were summarized on March 6,1989, with those persons indicated in paragraph 1.
The Senior Resident Inspector described the areas inspected and discussed in detail the inspection findings listed below.
The licensee acknowledged the inspection findings and did not identify as proprietary any of the material reviewed by the inspectors during the inspection.
Inspection findings:
No violations were identified.
Two noncited violations (NCV) were identified:
NCV 327,328/90-06-03, Motor Lubrication, paragraph 7.
NCV 327,328/90-06-04, UHI Valve Operability, paragraph 7.
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One unresolved item (URI) was identified:
URI 327,328/90-06-02, Ice Condenser Flow Channel Inspection Discrepancies, paragraphs 3 and 12.
Two inspector followup items (ITI) were identified:
IFI 321.328/90-06-01, Security Issues, paragraph 2.e.
IFI 327,328/90-06-05, Resolution of SSOMI !ssues, paragraph 14.
No deviations were identified.
During the reporting period, freque,nt discussions were held with the Site Director, Plant Manager and other managers concerning inspection findings.
16.
List of Acronyms and Initialisms ABGTS -
Auxiliary Building Gas Treatment System ABI Auxiliary Building Isolation
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ABSCE -
Auxiliary Building Secondary Containment Enclosure AFW Auxiliary Feedwater
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AI Administrative Instruction
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AOI Abnormal Operating Instruction
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AVO Auxiliary Unit Operator
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ASOS Assistant Shift Operating Supervisor
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ASTM American Society of Testing and Materials
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BIT BoronInjectionTank
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BFN Browns Ferry Nuclear Plant
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C&A Control and Auxiliary Buildings
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CAQR Conditions Adverse to Quality Report
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CCS Component Cooling Water System
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CCP Centrifugal Charging Pump
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CCTS Corporate Commitment Tracking System
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CFR Code of Federal Regulations
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COPS Cold Overpressure Protection System
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CSSC Critical Structures, Systems and Components
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CVCS Chemical and Volume Control System
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CVI Containment Ventilation Isolation
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DC Direct Current
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DCN Design Change Notice
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DG Diesel Generator
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DNE Division of Nuclear Engineering
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ECN Engineering Change Notice
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ECCS Emergency Core Cooling System
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EDG Emergency Diesel Generator
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EI Emergency Instructions
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ENS Emergency Notification System
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E0P Emergency Operating Procedure
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EO Emergency Operating Instruction
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ERCW Essential Raw Cooling Water
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Engineered Safety Feature ESF
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Flow Control Valve FCV
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Final Safety Analysis Report FSAR
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General Design Criteria GDC
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General Operating Instruction G01
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Generic Letter GL
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Heating Ventilation and Air Conditioning HVAC
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Hand operated Indicating Controller HIC
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Hold Order H0
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Health Physics HP
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Instruction Change Form ICF
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Independent Design Inspection IDI
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NRC Information Notice IN
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Inspector Followup Item IFI
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IM Instrument Maintenance
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Instrument Maintenance Instruction IMI
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Inspection Report
IR
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Justification for Continued Operation
JC0
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Kilovolt Amp
KVA
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Kilowatt
KW
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Kilovolt
KV
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LER
Licensee Event Report
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LCO
Limiting Condition for Operation
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LIV
Licensee Identified Violation
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Loss of Coolant Accident
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Main Control Room
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Maintenance Instruction
MI
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Maintenance Report
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NRC Bulletin
NB
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NQAM
Nuclear Quality Assurance Manual
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Nuclear Regulatory Commission
NRC
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OSLA
Operations Section Letter - Administrative
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Operations Section Letter - Training
OSLT
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Office of Special Projects
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Precautions, limitations, and Setpoints
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Preventive Maintenance
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Parts Per Million
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Post Modification Test
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Plant Operations Review Committee
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Plant Operation Review Staff
PORS
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Problem Reporting Document
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PRO
Potentially Reportable Occurrence
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Quality Assurance
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QlR
Quality Information Request
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Quality Control
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Radiation Control Area
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Reactor Coolant Drain Tank
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Reactor Coolant Pump
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Regulatory Guide
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Radiation Monitor
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Reactor Operator
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Rod Position Indication
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Revolutions Per Minute
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Resistivity Temperature Device Detector
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Radiation Work Permit
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Refueling Water Storage Tank
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Safety Evaluation Report
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Surveillance Instruction
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SMI
Special Maintenance Instruction
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501
System Operating Instructions
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505
Shift Operating Supervisor
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SQM
Sequoyah Standard Practice Maintenance
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SQRT
Seismic Qualification Review Team
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SR
Survelliance Requirements
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Senior Reactor Operator
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$50MI -
Safety Systems Outage Modification Inspection
S$QE
Safety fysten Quality Evaluation
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SSPS
Solid State Protection System
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Special Test Instruction
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TACF
Temporary Alteration Control form
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TAVE
Average Reactor Coolant Temperature
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TDAFW -
Turbine Driven Auxiliary feedwater
TI
Technical Instruction
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TREF
Reference Temperature
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TROI
Tracking Open Items
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TS
Technical Specifications
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Tennessee Valley Authority
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UHI
UpperHeadInjection
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VO
Unit Operator
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Unresolved Item
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USQD
Unreviewed Safety Question Determination
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VDC
Volts Direct Current
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VAC
Volts Alternating Current
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WCG
Work Control Group
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WP
Work Plan
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Work Request
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