IR 05000327/1990034

Insp Repts 50-327/90-34 & 50-328/90-34 on 901006-1105.One Violation & One Apparent Violation Noted.Major Areas Inspected:Operational Safety Verification Including Control Room Observations & Sys Lineups

ML20062F570
Person / Time
Site:	Sequoyah
Issue date:	11/16/1990
From:	Harmon P, Little W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20062F551	List: IR 05000327/1990034 ML20062F549 ML20062F554
References
50-327-90-34, 50-328-90-34, NUDOCS 9011280041
Download: ML20062F570 (20)

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u UNITED STATES

[,MClo 'o NUCLEAR REGULATORY COMMissl0N

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? HE GION il j* 101 MAnlETTA STREET, g ATLANT A, GEORGI A 30323

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Report Nos.: 50-327/90-34 and 50-32d/90-34 Licensee: Tennessee Valley Authority 6N 38A Lookout Place 1101 Market Street '

Chattanooga, TN 37402-2801 Docket Nos.: 50-327 and 50-328 License Nos.: DPR.77.and DPR-79 Facility Name: Sequoyah Units 1 and 2 Inspection Conducted: October 6, 1990 - November, 5, 1990 Lead Inspecto [

9. Harrk;fh,Wrfiior Resident Inspector

~Date F1gned d

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Inspectors: Scott Shaeffer, Resident inspector Approved by: shYA W 57 L%K, Dief, Project Section 1

//hf90 Defte ' Signed

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TVA Projects CUMMARY Scope:

This announced inspection involved inspection effort by the Resident inspectors in the area of operational safety verification including control room observations, operations performance, system lineups, rediation protection, safeguards, and conditions adverse to quality. Other areas inspected included surveillance testing observations, maintenance observations, review of previous inspection findings, follow-up of events, review of licensee identified items, and review of inspector follow-up item Results:

One violation and one apparent violation were identified. The violation detailed in Paragraph 2.d., involved the presence of.a large amount of combustible material left stacked in the auxiliary building in violation, of fire protection requirements. The apparent violation, detailed in Paragraph 6, is a repetitive similar violation which involved lack of control of overtime.

l The repetitive similar violation is considered significant in that corrective actions for previous violations have proven inadequate to prevent recurrence, and is under consideration for escalated enforcemen PDR ADOCK 05000327 O PDC

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i One Non-cited violation was identified in Paragraph 2.e., concerning missing contaminated area postiaqs for the auxiliary boile ,

One unresolved item was identified in Paragraph 8.c.,_ concerning a lack of ,

proper selective coordination between fuses and breakers separating vital and non-vital power supplie No deviations, or inspector follow-up items were identified, t

During the inspection period Unit 1 was shut'down to repair check valves-in the

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main steam lines. Three . check valve disks were found separated from the valves' disk posts. An Augmented Inspection Team performed an inspection into the circumstances of the check valve ' failures remedial actions by the licensee, and other details of the even Results of that inspection were .

documented in NRC Inspection Report 50-327/328-90-3 l 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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REPORT DETAILS Persons Contacted Licensee Employees

• J. Bynum, Vice president, Nuclear Power Production

• J. Wilson, Site Vice President W. Byrd, Manager, Project Controls / Financial Officer

• C. Vondra, Plant Manager R. Beecken, Maintenance Manager L. Bryant, Work Control Superintendent

• M. Cooper, Site Licensing Manager J. Gates, Technical Support Manager

• G. Hipp, Licensing Engineer W. Lagergren, Jr., Operations Manager M. Lorek, Operations Superintendent R. Lumpkin, Site Quality Manager

• R. Proffitt, Compliance Licensing Manager

• R. Rogers, Technical Support Program Manager

• M. Sullivan, Radiological Control Manager

• P. Trudel, Project Eigineer R. Thompson, Licensing Engineer C. Whittemore Licensing Engineer l NRC Employees

• S. Little, Chief, Project Section 1

• Attended exit interview Acronyms and initialisms used in this report are listed in the last paragrap . OperationalSafetyVerification(71707) Control Room Observations

, 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 attentiveness was commensurate with the plant configuration and plant activities in progress, and with on-going control room

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operations. The operators were observed adhering - to appropriate, approved procedures, including Emergency Operating Procedure!., for the on-going activities. The inspectors observed upper manage:nent in the control room on a number of occasion . .

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The inspector verified that the licensee was operating the plant in a normal plant configuration as required by T3 and when abnormal conditions existed, that the operators werft complying with the appropriate LC0 action statement',. The inspector verified that RCS leak rate calculations were pe* formed and that leakage rutes were within the TS limit :

The inspectors observed int trumentation and recorder traces for abnormalities and verified the status of selected control room anNnciators to ensure that control room operators understood the ciatus of the plant. 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 operation within TS limit No violations or deviations were identifie b. Control Room Logs The inspectors observed control room operations and reviewed

, applicable logs including the shift logs, operating orders, night '

l order book, clearance hold order book, and configuration log to obtain information concerning operating trends and activities. The l TACF log was reviewed to verify that the use of jumpers and lifted leads causing equipment to be inoperable was clearly noted and l understoo The licensee - is actively pursuing correction to i conditions requiring TACFs. No issues were identified with these specific log Plant secondary chemistry reports were reviewed. The inspector I

verified ti.at primary plant chemistry was within TS limit The implementation of the licensee's sampling program was observe Plant specific monitoring systems including seismic, meteorological and fire detection indications were reviewed for operability. A review of surveillance records and tagout logs was performed to confirm the operability of the RP No violations or deviations were identifie c. ECCS System Alignment The inspectors walked down accessible portions of the Unit 1 Containment Spray System to verify operability, flow path, heat sink, water supply, power supply, and proper valve and breaker alignmen In addition, the inspectors verified that a selected- portion of the containment isolation lineup was correc . . . ,

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The inspectors implemented a system status checklist derived from the Sequoyah Probabilistic Risk Assessment. The checklist provides a method for assuring the proper lineup of the principal systems required to prevent or mitigate the Design Basis Accidents based on the safety significance of the individual component This checklist will be comp %ted by the resident staff on a weekly basi No violaticni or deviations or were identifie d. Plant Tours Tours of the diesel generator, auxiliary, control, and turbine twildings, 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 license The inspector visually inspected the major components for leakage, proper lubrication, cooling water supply, and any general' condition that might prevent fulfilling their functional requirement The inspector observed shift turnovers and determined that necessary information concerning the plant systems status was addresse On October 11, 1990, a tour of the 669 elevation of the. auxiliary building was made by the inspector. A large quantity of what appeared to be untreated wood (non fire rated) was discovered just outside the Unit 1 1AA safety injection pump room. The inspector

questioned a roving fire watch in the area about the wood. The watch

! stated that the wood had been there for some time and wen' on with l his appointed rounds. The wood appeared to be the remnants of a shipping crate and a large mounting skid. The approximate amount of wood was four, five by ten foot sheets of one inch plywood, one five by five foot section of the same material, and a mounting skid consisting of approximately six, four foot sections of eight by ten inch timber No documentation was attached to the wood.

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The inspector informed the SOS in the CR of the situation and then-contacted the Fire Brigade Leader. This individual informed the inspector that he was not aware of any transient fire load permit outstanding en the subject wood and that it should have been remove The wood was identified as the shipping crate and skid for a recently refurbished Unit 2 RHR pump motor. The inspector asked to be informed when the wood was removed from the area. Approximately one hour later the inspector was notified of the remova Physical Security Instruction 13 (PHYSI-13)', revision 55, Fire, attachments E and H detail the controls imposed on transient fire loads in safety-related areas at Sequoya .

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Attachment E provides the written procedures for transient fire loading and Attachment H consists of a transient fire load pemit form required to be used whenever wood of any type is brought into safety-related areas. Attachment E. Section 5.1.4 of PHYSI-13 states that equipment- shipped in untreated combustible containers may be unpacked in safety-related areas only if the containers are immediately removed following unpackin In addition, the containers shall not be left unattended for any period of time before, during, or af ter the ' unpacking process. Contrary to this, the wood '

identified by the inspector was left unattended from October 1 through October 11, 1990. This is a violation of TS 6.8.1 and is identified as 327,328/90-34-01, Failure to Control Transient Fire Loads in a Safety-related Are The inspector's review of the procedure with relation to the event determined that the following did not occur or appeared deficient as defined in the procedure:

- No transient fire load permit was issued for entry of the combustibles into the safety-related area. The work supervisor failed to initiate the required permi The procedure appears to rely on the work supervisor to initiate a permit and lacks any positive control of combustibles entering safety-related area Section 5.1.4 of Attachment E provides a provision for untreated combustible packaging or containers to be unpacked in I

safety-related areas. It appeared to the inspector that when

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this section of the procedure would be referenced!by a work-l supervisor for guidance, it may not be clear whether a transient fire load permit would be required at al The required weekly plant inspections by Fire Operations to determine the adequacies of transient fire load controls did identify the problem on October 5,1990. However, resolution

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of the issue did not occur.

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personnel, during the midnight outage turnover: meeting on October 10, 1990, Operations / Maintenance was made aware of the wood prior to the inspector's identificatio However, appropriate followup on the removal was again not mad No determinations for additional fire protection devices or fire watch coverage were performed.- Per the procedure, a system of fire watch coverage shall be required in critica' areas that-contain medium or high fire load _ _

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5 l The inspectors are concerned with the overall program implementation which allowed the unauthorized entry of the combustibles to occu Of equal concern is the lack of followup in resolving the issue once '

it was identified by Fire Operations, Operations, and Maintenance personne One violation was identifie e. Radiation Protection The inspectors observed HP practices and verified the implementation of radiation protection control On a regular basis, RWPs were reviewed and specific work activities were monitored to ensure the activities were being conducted in accordance with the applicabl RWP Workers were observed for proper frisking upon exiting contaminated areas and the radiologically controlled area. Selected radiation protection instruments were verified operable and calibration frequencies were reviewe The following RWPs were reviewed in detail:

90-2-20019, Remove / Replace Insulation in Support of U-2 Refueling 90-2-20011 U-2 Seal Table Work On October 10, 1990, during a routine tour which included the turbine operating deck, the inspector identified a radiation area posting discrepanc Due to an earlier contamination several years before, the auxiliary boiler manways were posted as a radiation area. It was discovered that two of the four lower manway radiation area signs were not posted as required. The inspector informed the turbine building operator of the discrepancy. The operator stated that the postings had always been on the manways since the earlier ( contamination event, however, he did not notice that the two located

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on tiie B auxiliary boiler were missing. When the inspector returned on October 11, 1990 the radiation area signs were posted as require Per discussions with the Radiological Controls Manager, the area was posted in order to require health physics to survey the inside of the boiler prior to personnel entry. Entry into the area would then be regulated by an RWP if contamination was found. The latest surveys taken indicated approximately 100 counts per minute with no smearable contamination. The licensee attempted to account for any entries into the manways while the radiation postings were down. No RWPs were written for entry into either of the auxilinry boiler manways.

In addition to requiring a radiation survey prior to entering the l manways, a confined space permit was required due to entering of the

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interior of the boiler. Due to the fact that none of these permits I were issued during the time in which the radiation postings were missing, the licensee had reasonable assurance that unauthorized ,

entry to the area did not occur. The licensee also determined that '

the. area postings were attached to the manways with a plastic

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yellow and magenta strip which tended to melt due to the heat of the boiler manwa More permanent mounting of the radiation area 1 requirements was installed before the end of the inspection perio >

The missing postings are a violation of 10CFR 20.203 requirements, however, this.NRC identified violation is not being cited because the criteria specified in section V.A. of the NRC Enforcement Policy were satisfied. This item is identified as NCV 327,328/90-34-02, RWP Area Entry Signs Not Installed on Auxiliary Boiler, f. Safeguards Inspection In the course of the monthly activities, the inspectors included a review of the licensee's physical security program. The performance of various shifts of the security force was observed in the conduct of daily activities including: protected and vital area access controlst searching of personnel and packages; escorting of visitors; -

badge issuance and retrieval; and patrols and compensatory post The inspectors observed protected area lighting, and protected and vital area barrier integrit The inspectors verified interfaces '

between the security organization and both operations and maintenanc The Resident inspectors interviewed individuals with security concerns, visited central alarm stations, verified protection of Safeguards Information, and verified onsite/offsite communication capabilitie No violations or deviations were identifie ,

9 Conditions Adverse to Quality The inspectors reviewed selected items to determine that the licensee's problem identification system as defined in Site Standard Practice SSP-3.2, Problem Reporting, Evaluation, and Corrective Action, was functioning. CAQR's were routinely reviewed for adequacy in addressing a problem or even A sample of the following documents were reviewed for adequate handing:

- Work Requests

- Conditions Adverse to Quality, CAQRs

- Radiological Incident Reports

- Problem Evaluation Reports

- Correct-on-the-Spot Documents

- Licensee Event Reports Of the items reviewed, each was found to have been identified by the licensee with immediate corrective action in place.

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For those issues that required long term corrective action the licensee was making adequate progres No violations or deviations were identifie No adverse trends were identified in the operational' safety verification area. General conditions in the plant were adequat Radiation protection and security are adequate to continue two unit operation . Surveillance Observations and Review (61726)

Licensee activities were directly observed / reviewed to ascertain that surveillance of safety-related systems and components was being conducted in accordance with TS requirement The inspectors verified that testing was performed in accordance with adequate procedures; test instrumentation was calibrated; LCOs were met; test results met acceptance criteria and were reviewed by personnel other than the individual directing the test; deficiencies were identified, as appropriate, and any deficiencies identified during the testing were properly reviewed and resolved by management personnel; and system .

restoration was adequate. For completed tests, the inspector verified that testing frequencies were met and tests were performed by qualified individual SI 137.1, Reactor Coolant System Water Inventory, was observed / reviewed with no deficiencies identifie No adverse trends were identified in the area of surveillance performance

during this inspection period. The area of surveillance scheduling and l

management was observed to be adequate and improving.

l No violations or deviations were identified'. Monthly Maintenance Observations and Review (62703)

Station maintenance activities on safety-related systems and components were observed / reviewed to escertain that they were conducted in accordance

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with approved procedures, regulatory guides, industry codes and standards, and in conformance with T.S.

l The following items were considered during this review: LCOs were met

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while components or systems were removed from service, redundant com)onents were operable, approvals were obtained prior to initiating the wor ( activities were accomplished using approved procedures and were inspected as applicable, procedures used were adequate to control the activity, troubleshooting activities were controlled and the repair j 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

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qualified personnel, parts and materials used were properly certified, radiological controls were implemented QC hold points were established where required and were observed, fire prevention controls were implemented, outside contractor force activities were controlled in i accordance with the approved QA program, and housekeeping was actively pursue Work request WR C001694, Repair Betamax Personnel Contamination Monitor was reviewe No violations or deviations were identifie . Management Activities in Support of Plant Operation TVA management activities were reviewed on a daily basis by the inspector The inspectors observed that planning, scheduling, work control and other management meetings were effective in controlling plant activities, with the exception of management and oversight of overtime discussed in section 6. First line supervisors appear to be knowledgeable and involved in the day to day activities of the plan First line supervisor involvement in the field has been observed and appeared to be adequate. Management response to those plant activities and events that occurred during this inspection period appeared timely and effect1v Examples of this management action were efforts to support the Augmented Inspection Team during the on-site inspection concerning the main steam line check valve failure . Site Quality Assurance Activities in Support of Operations (71707)

The inspector discussed QA involvement in plant activities with the QA personnel and managers. The~ QA surveillance and audit . schedules were reviewed and results were discussed with-QA manager QA Monitoring Report OSQ-R-90-729, 0vertime, was reviewed. This report l detailed the monitoring of compliance with plant overtime requirements

! during the current linit 2 Cycle 4 refueling outage. The report concluded that overtime requirements were still being violated and that management control of overtime was inadequate. The report listed specific instances where overtime limits- imposed by Site Standard Practice SSP 32.53, Administration of Overtime, were exceeded. In addition, : inadequate or missing documentation of- exception requests for exceeding overtime limits l were note In one instance, blanket approval for exceeding overtime-i limits for the entire outage was authorized for the Radiological Support section, contrary to the SSP requirement for specific authorization for each individual. Several instances were cited where justification for L exceeding overtime limits consisted simply of a. reference to the refueling

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outage. The report further states that' conditions leading to a violation issued in NRC Inspection Report IR 90-22 were continuing. In short, the .

corrective actions taken by the licensee to control overtime have not been L effectiv .

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SSP 32.53 was written to ensure compliance with Generic Letter 82-12, and contains intent and limitations that parallel the Generic Lette Both ;

the GL and SSP 32.53- list the objectives and intent of controlling i overtime and the imposed limits listed below: '

Objective: Limit work hours for workers involved in safety-related activities to a standard 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> day, and 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> per week, Limit overtime in excess of the standard to necessary work during unusual circumstances or for extended outages such as refueling _ outage When the circumstances require overtime, the workers' hours should '

not exceed 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> continuous, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period, or 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in a 7 day period. No routine use of overtime is allowed, int very unusual circumstances the limits for overtime may be exceeded with prior approval by the plant manager or his deputy. _That prior approval for exceeding overtime limits requires ' documentation of the -

hours to be worked, the type of work to be accomplished, and - the ;

circumstances which force the limits to be exceede '

The QA Monitoring report identified instances where overtime in excess-of i the limits was huthorized without the required documentation of the !

circumstances dictating the excessive overtime, withoutfrior approval to exceed the limits, without detailing the actual hours to be worked, and, in one case, with blanket approval for an entire section.for the duration of the outage (blanket approval) justified -only by the ' fact that a !

refueling outage was in progress. Management control of the plant's overtime was not evident to meet either the intent or the letter of the

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l program. The requirement to receive prior management approval affords the '

opportunity for management to enforce the program. The Monitoring report '

concluded that the implementation of SSP ~ 32.53 was inadequate, and 1 management attention in this area was ineffectiv The inspectors reviewed the licensee's records of hours worked for the Operations section for weeks 10-08-90 through 10-14-90.- The findings of this review are detailed belo :

Average hours worked by section - 59 hours6.828704e-4 days <br />0.0164 hours <br />9.755291e-5 weeks <br />2.24495e-5 months <br /> Number of workers with overtime in excess of 72-hours in a 7 day period - 22 individuals '

Inadequate documentation for exceeding limits - 2 l

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Number of instances where no documentation existed - Number of instances where authorization- prepared af ter the fact - '

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I The principal contributor to the inadequacies for the 22 authorizations H reviewed was the lack of documentation of the specific work to be-performed during the overtime. SSP 32.53 requires in section 2.1.3 that r the Overtime Limitation Exception Report, which is to be; completed to' a document the rationale and justification for approval of overtime in - !

excess of the limits, must ... " Specify in detail the exact work to; b ,

performe For example, details would include ' a specific ' Work Plan !

number, applicable equipment identifier, type of work to be accomplished, !

and so forth".

The twenty-two employees included four who worked as much as 84,86,88 and 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br />. None of the twenty-two Authorization forms contained the 1 required details and in many cases the form was blank in all respects i other than name of the individual and ' hours to be worked. The authorization forms were signed. and approved by management including '

the Plant Manager. The ' twenty-two included licensed operators working the main control panel of the operating uni A revie'w by the inspector of the overtime records for.the weeks beginning September 10,,17 and 24, 1990, revealed numerous instances of radcon and operations ' personnel exceeding the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> per 7 day limit without the required documentatio In response to the previous similar Violation 327,328/90-22-01, TVA agreed that the violation had occurred, and concluded that Operations ;

management had not exercised sufficient oversight and attention to the requirements of ' Administrative Instruction AI-30 Nuclear Plant Conduct of Operations, which controlled the administration of overtime. The control of overtime by AI-30 was not sufficient and TVA committed to '

incorporating the requirements into a new procedure. The transfer to u new procedure, SSP 32.53, . was accomplished September 15, 199 The inclusion of authorization forms for exceeding overtime limits was intended to provide the proper review and documentation for management to concur in the granting of relief to supervisors requesting such relief for individuals on a case by case basis. In the instances cited above, all ,

levels of plant management demonstrated inadequate oversight of the intent and the letter of the requirements. Violation 50-327,328/90-22-01 concluded that the licensee- had exceeded the overtime requirements of-AI-30 on numerous occasions during the refueling outage for Unit 1, cycle 4 in the November 1989 to- May 27,1990' time frame. The inspection:

performed by the' resident' inspector during the current Unit 2, cycle 4

atage indicates that similar occasions of inadequate or missing 1 authorizations for exceeding overtime- limits have continued to ' occu Repeat or similar violations indicate inadequate corrective action for the previous violation In the Notice of Violation for. IR 327,328/90-22, reference was made 'to the fact that Violation 327,328/90-22-01 was similar to Violation 327,328/87-78-01. NRC decided that since significant-changes to plant management had occurred and the time between- Violations 327,328-87-78-01 and 327,328/90-22-01 was very close. to the two year criteria, escalated enforcement action would not be considered. TVA failed to adequately implement the corrective actions described in

their response ~ to Violation 327,328/90-22-0 As a result of this i

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l inadequate corrective action, overtime in excess' of limits specified in SSP 32.53 was performed by Operations' personnel during the week of October 8,1990 without the required documentation and j authorizatio This is an apparent. Violation 50-327,328/90-34-03, Failure to follow Procedures to Control and Document Overtime, and is ;

under consideration for escalated enforcement, i

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Af ter the inspector discussed the preliminary. findings with the Plant Manager on October 26, 1990 the Plant Manager produced a memo distributed to his supervisors and managers. The memo described the QA monitoring report findings and required the individual managers to equalize overtime in their areas and placed an absolute limit of 88 working hours in a week regardless of the circumstance The memo also acknowledged that the plant had' not been adhering to the intent of SSP 32.53. The memo does not address the amount of overtime being worke ,

The outage began September 7,1990 and plant management recognized the ongoing problems in the area of overtime control on October 17, 1990 th I day of the QA report. The letter detailing the Plant Manager's response is dated October 25, 199 . NRC Inspector Follow-up Items, Unresolved Items, Violations (92701, 92702) .

(Closed) URI 327,328/90-06-02, Ice Condenser Flow Channel Inspection Liscrepancie The issue involved several problems identified by the inspector concerning the performance of SI-106.3, Ice Condenser Bed (Unit 2).

These issues were:

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The technicians performing the inspections were not-- aware of the total geometrical area that defined the flow channe !

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Questiorable change in the acceptance criteria when blockages were at different elevations within the same flow channe The technicians did not appear- to be able to make consistent, conservative calls on the percentage of blockage noted-'in the channel In response to the above, the- licensee reviewed SI-106.3 and instituted -

numerous changes to the procedure which includeo clarification of the criteria used for flow path inspection, clarification of instructions for obtaining basket weights and revised data sheets and sketches fo consistency with the procedural instructions. The updated procedure also incorporated _a detailed sketch of a typical flow path boundary in order to allow more consistent conservative calls' by the test.. technicians on the percentage of blockage in the flow channels. Additionally, the licensee reanalyzed the data collected utilizing the unrevised procedure at the time of the inspector's concer Upon review of the results, numerous.

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believes that the procedure enhancements will allow more conservatism and I consistency with the overall test results and had no further concerns at this time. This item is close I

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(Closed) VIO 327,328/09-25-04, Failure to Properly Classify' Both  !

Unit 2 EDG's Being Inoperable as a Notification of Unusual Even The violation involved the failure of the licensee to identify and enter a !

NOVE based on a condition where both unit-related EDGs were inoperable at the same time as a result of unscheduled maintenance or failure. The cause of the violation was pers9nnel error in that the SOS failed to realize that the NOVE should have been declared. The SOS did not immediately consider entering the Radiological Emergency Plan because he was within a TS action statemen: and incorrectly assumed that the action statement was the only controlling document. Various contributing factors were identified by the licensee's root cause investigation. A review of EPIP-1, Emergency Plan Implementing Procedure, found that the unusual e'.ent classification process relied,'in some cases, on memory of the S0 For example, the loss of both EDGs on the same unit was not-covered by an A01 or an E01 and consequently the SOS was not directed to enter the EPIP >

classification process. In order to improve this. condition, the licensee has incorporated a revised format to EPIP-1, which added a tabular format to improve the method of-emergency classifications and action levels. The incorporation of the tat'ular format was also prompted by the licensee's review of NRC Information Notice 89-072, ' Failure of Licensed Senior :

Reactor Operators to Classify Emergency Events Properly. Also,.with the tabular addition, duplication and ambiguous wording was removed and the wording of events was clarified to allow easier identification and classificatio The licensee also identified a training' deficiency where not all unusual event classifications concerning normal; TS events were l routinely covered during simulator evaluation The tabular ]

classification format has been incorporated into the licensee's simulator ;

training program and based on the inspector's review, should enhance the classification ability of the duty S0S. As a result of the violation, the-licensee was requested to address several items involving the failure to appropriately classify and report events at Sequoya The inspector reviewed the licensee's response, which included corrective '

actions for NRC Violation 327,328/88-33-01, Failure to -Implement The REP In A Timely Manner. No problems with the corrective actions taken were identified. This item is close (Closed) TMI Item II.E.4.2.5.B, Containment Isolation Dependability-Containment High Pressure Setpoint Modification m

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' NRC IR 327,328/80-40, previously reviewed this issu The containment j pressure setpoint that initiates containment isolation was required by NUREG 0737 to be reduced, to the minimum compatible with ' the normal operating conditions. The. inspector _ reviewed the documentation which led to the closure of this issu Per supplement No. 5 to the Safety Evaluation Report issued by the NRC in May of 1981, the.. original >

containment high pressure setpoint of 1,54 psig was adequate. It was determined that the reduction of this setpoint would provide no significant additional safety margin. In addition to this, TVA committed in a letter of May 26', 1981, from L. M. Mills to E. Adensam, to limit the opening of the containment purge valves to a maximum of 50 degrees to meet the requirements of the " Interim Position" of II.E.4.2 of NUREG-073 The inspector verified the completion of the modifications to Units 1 and 2 on March 4, 1982 and June 15, 1981 respectively. This item is close (Closed)TMIItemII.E.4.2.7,ContainmentIsolation Dependability-Radiation Signal on Purge Valve The issue involved NUREG-0737 guidance which required the containment t nge valves to close promptly in order to reduce the amount of radiation-released outside the containment following a release of radioactive materials to the containment. The inspector reviewed Sequoyah T.S. for the requirement for at least one radiation monitor that cutomatically closes the purge valves upon sensing high radiation in the containment be operable in Modes 1 thru 4. The requirement was found already addressed '

by SQN T.S. 3.3.2, functional unit 3.c of table 3.?.3, Engineered Safety-

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Feature Activation Signal Instrumentation.. Ths closure of_this item was also documented previously by TVA's NUREG-0578 responseL to the NRC transmitted by the July 11, 1980, L. M. : Mills to A. Schwencer letter; This item is close (Closed) URI 327,328/89-27-04, Average Thermal Power. This URI involved the licensee's inadvertant. operation of Unit 1 on November 29, 1989, with an eight hour thermal power average of 3411.3 MW, which was 'in excess of its rated thermal power of 3411 MW. This occurrence was identified as a potential repeat condition of a problem described -in Violation 327, 328/89 15-03. The corrective actions for the violation put in place specific procedures for limiting and monitoring of average thermal power by the operator per G01 5. The inspector reviewed the licensee's event repert of the November 29, 1989 event and determined that the operations shift actad appropriately in reducing the turbine power once aware of the minor power oscillations which 1.he inspector had identified. The eight hour average, although in excess of 3411 MW, was judged by the inspector-to be within the bounds of normal fluctuations about a mean ' power level and did not approach the power level swings reached in- the .above referenced violation. This does not preclude the fact, however, that the operators were not readily cognizant of the power oscillations in question and increased attention to detail is warranted to monitor for power oscillations and other important plant parameters during power operatio This item is close _ . . . . . .

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14 Eventfollow-up(93702) On October 8, 1990, at 0721 hours0.00834 days <br />0.2 hours <br />0.00119 weeks <br />2.743405e-4 months <br />, the licensee declared a Notice of Unusual Event (NOVE) due to commencing a forced shutdown of Unit 1 as required by TS. The shutdown was required because one of four main steam system check valves (1-MS-1-624) was found to have its disk separated from the valve per the results of radiographic examination The NOVE was subsequently exited upon entering mode 4 at 1534 hour0.0178 days <br />0.426 hours <br />0.00254 weeks <br />5.83687e-4 months <br /> On October 9, with the unit in mode 4 after the shut-down, it was discovered during visual inspections that three of the four check valve discs had separated from the post / arm assemblies due to post failure The investigatiens into the status of 1-MS-1-624 began during followup investigations into reports of a loud noise being heard in the vicinity of .the east valve vault and main steam piping on September 21, 199 One of the separated disks.was found lodged in the check valve body against the seat. The two remaining separated disks were subsequently found lodged in separate main steam risers off the coinmon mixing tee leading to the main turbine throttle valves in the turbine buildin A special NRC team inspection was conducted due to the check valve failure The results of this inspection and additional review of-the licensee's corrective actions are detailed in NRC Inspection Report 327, 328/90-3 Unit I was restarted on October 21, 1990 after repairs were effected on the check valve The resident inspectors will follow the corrective actions, modifications, and monitoring related to this issue in subsequent inspection reports, On October 27, 1990, a non compliance was identified by the licensee with the requirements of Unit 2 License Condition-2.C.13.c, Appendix i The issue was reported on both units in accordance with Unit 2

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License Condition 2.H.Section III.G.I.a of 10 CFR 50 Appendix R, l

requires that one train of systeins necessary to achieve and maintain '

hot shutdown conditions from either the main control room (MCR) or auxiliary control room (ACR) remain free from fire damage. It was discovered that seven ACR instrument loops required for remote I shutdown capability were powered from a MCR power source.. Therefore, l a MCR fire could disable the affected instrumentation-in both the MCR an ACR. The affected instrumentation loops were the following:

l TI-68-1C Loop 1 Reactor Coolant Hot Leg Temperature <

.TI-68-24C Loop 2 Reactor Coolant Hot Leg Temperature TI-68-43C Loop 3 Reactor Coolant Hot Leg Temperature TI-68-65C Loop 4 Reactor Coolant Hot Leg Temperature F1-62-137C Emergency Boration Flow to Charging Pump Suction TI-74-38C Residual Heat Removal Hx "A" Outlet Temperature TI-74-40C Residual Heat Removal Hx "B" Outlet Temperature

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Due to this condition, Unit 1 (in -Mode 1) rntered the action statement of TS 3.3.3.5 (remote shutdown instrumention) on October 27, when the affected instruments were declared inoperable. The same TS had been entered previously for TI-68-10 on October 24, 199 Unit 2 was in Mode 5 shutdown for the Cycle 5 refueling outage, and was not applicable to the TS action requirements. During the seven day LC0 period allowed by TS 3.3.3.5, the power supplies for the affected instrumentation were modified to receive power from a supply unaffected by a MCR fire. The licensee did identify, as a mitigating circumstance, that.the MCR'was and will continue to be incorporated into the surveillance of hourly, roving fire watch patrols, c. On October 17, 1990, Unit 1 entered L.C.0. 3.0.3 due to'more than one Vital Inverter and one Vital Battery Charger being declared inoperable. The 1-1, 1-III, 2-I, and 2-III Vital Inverters and the 1 and 3 Vital Battery Chargers were declared inoperable due to the lack of selective coordination between the Instrument Power Primary Fuse Isolator (IPPFI) and the 480 volt- feeder breaker that services the vital inverters and battery' chargers. 'The lack of coordination means that a fault on the load side of the fuse 'could cause= the breaker. to open. The fuse provides load to non-1E equipment, while the breaker feeds both the IPPFI fuse and vital, IE equipment including the inverters and chargers. In effect, a fault in the non-vital portion of the circuit could cause a loss of Vital equipmen Selective coordination provides . fuse and breaker sizing to ensure. selective tripping and isolation of faults to minimize these interactions,.

Immediate corrective actions were impicmanted to provide ~ breakers that would properly coordinate with the-IPPFI. The new breakers were installed and tested, and L.C.0. 3.0.3 was exited at 5:30 a.m. on October 1 The licensee is investigating the cause of the lack of selective coordination by- means of an event repor Previous ;

instances of a lack of coordination were reported and corrected and '

documented in LER 87-001,87-045,-and 87-061 and were the result of i various design errors. The investigation for, this instance was not complete at the end of the inspection perio This appears to'be a design deficiency that was not reviewed or corrected as part of <

previous corrective actions . Pending completion of the event report, this item will be tracked as URI' 327, 328/90-34-0 . ExitInterview(30703)

The inspection . scope and findings were summarized on ' November 5,1990, with those persons indicated in paragraph 1. The Senior Resident .

Inspector described the areas inspected and discussed -in detail the inspection findings. listed belo .The ~ licensee acknowledged the inspection findings and did .not identify -as prop.rietary any of. the .

material reviewed by the inspectors during the. inspectio U 1 ,

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Inspection Findings:

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One violation, one apparent violation, one. non-cited violation, and one

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unresolved item were identifie VIO 327,328/90-34-01, Failure to Control Transient Fire Loads in Safety Related Areas NCV 327,328/90-34-02, RWP Area Entry Signs Not Installed on Auxiliary' Boiler Apparent VIO 327,328/90-34-03, Failure to Follow Procedures to Control and Document' Overtime URI 327,328/90-34-04, Selective Coordination Causes T.S. 3. Entry During the' reporting period, frequent discussions were held with the Site Director, Plant Manager ar.d other managers concerning inspection finding . List of Acronyms and Initialisms ABGTS- Auxiliary Building Gas Treatment System ABI - Auxiliary Building Isolation ABSCE- Auxiliary Building Secondary Containment Enclosure AFW - Auxiliary Feedwater

, AI -

Administrative Instruction

! A01 -

Abnormal Operating Instruction AVO - Auxiliary Unit Operator ASOS - Assistant Shift Operating Supervisor ASTM - American Society of Testing and Materials BIT - Boron Injection Tank BFN -

Browns Ferry Nuclear Plant-C&A -

Control a'nd Auxiliary Buildings CAQR - Conditions Adverse to Quality Report CCS -

Component' Cooling Water-System l CCP - Centrifugal Charging Pump CCTS - Corporate Commitment Tracking System CFR - Code of Federal Regulations COPS - Cold Overpressure Protection System CS -

Centainment Spray CSSC - Critical Structures, Systems and Components CVCS - Chemical and Volume Control System-CVI ' ' *Curdeinment Ventilation Isolation DC - Direc; Current DCN -

Design Change Notice DG -

Diesel Generator DNE' - Division of Nuclear Engineering ECN -

Engineering Change Notice ECCS - Emergency Core Cooling System

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EDG - Emergency Diesel Generator-EI -

Emergency Instructions ENS - Emergency Notification System E0P - Emergency Operating Procedure ,

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EO -

Emergency Operating Instruction ERCW - Essential Raw Cooling Water ESF -

Engineered Safety Feature FCV -

Flow Control Valve FSAR - Final Safety Analysis Report GDC - General Design Criteria G01 - General Operating Instruction GL -

Generic Letter HVAC - Heating Ventilation and Air Conditioning HIC - Hand-operated Indicating Controller H0 - Hold Order HP - Health Physics ICF - Instruction Change Form IDI - Independent Design Inspection IN -

NRC Information Notice IFI -

Inspector Followup Item IM -

Instrument Maintenance IMI -

Instrument Maintenance Instruction IR -

Inspection Report

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KVA. - Kilovolt-Amp

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KW -

Kilowatt I

KV -

Kilovolt LER - Licensee Event Report LCO -

Limiting Condition for Operation LIV -

Licensee Identified Violation LOCA - Loss of Coolant Accident MCR -

Main Control Room MI -

Maintenance Instruction MR - Maintenance Report MSIV - Main Steam Isolation Valve NB -

NRC Bulletin

, NOV -

Notice of Violation NQAM - Nuclear Quality Assurance Manual NRC - Nuclear Regulatory Commission OSLA - Operations Section Letter - Administrative OSLT - Operations Section Letter - Training OSP -

Office of Special Projects PLS Precautions, Limitations, and Setpoints PM -

Preventive Maintenance ,

PPM -

Parts ~Per Million PMT - Post Modification Test PORC - Plant Operations Review Committee- l P0RS - Plant Operation Review Staff PRD -

Problem Reporting Document PRO - Potentially Reportable Occurrence QA -

Quality Assuranc . ___

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1 18-I QC -

Quality Control I RCA -

Radiation Control Area RCDT - Reactor Coolant Drain Tank RCP - Reactor Coolant Pump '

RCS - Reactor Coolant System RG - Regulatory Guide j RHR -

Residual Heat Removal i RM -

Radiation Monitor R0 - Reactor Operator RPI -

Rod Position Indication RPM -

Revolutions Per Minute RTD -

Resistivity Temperature Device Detector RWP - Radiation Work Permit RWST - Refueling = Water Storage Tank SER -

Safety Evaluation Report SG -

Steam Generator '

SI -

Surveillance Instruction SMI - Special Maintenance Instruction 501 -

System Operating Instructions SOS -

Shift Operating Supervisor l SQM -

Sequoyah Standard Practice Maintenance '

SQRT - Seismic Qualification Review Team SR -

Surveillance Requirements SR0 -

Senior Reactor Operator SS0MI- Safety Systems Outage Modification Inspection SSQE - Safety System Quality Evaluation SSPS - Solid State Protection System L STA -

Shift Technical Advisor STI -

Special Test Instruction TACF - Temporary Alteration Control Form TAVE - Average Reactor Coolant Temperature TDAFW- Turune Driven Auxiliary Feedwater TI -

Technicu' Instruction i TREF - Reference Nmoerature I TROI - Tracking Open items TS -

Technical Specifications TVA -

Tennessee Valley Authority  !

UHI - Upper Head Injection U0 -

Unit Operator i URI - Unresolved Item-USQD - Unreviewed Safety Question Determination VDC -

Volts Direct Current VAC -

Volts Alternating Current WCG -

Work Control Group WP -

Work Plan WR -

Work Request