IR 05000327/1993045

Insp Repts 50-327/93-45 & 50-328/93-45 on 930913-17.No Violations or Deviations Noted.Major Areas Inspected:Balance of Plan Activities & Followup on Previously Identified Insp Findings

ML20059G466
Person / Time
Site:	Sequoyah
Issue date:	10/08/1993
From:	Casto C, Matt Thomas NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20059G463	List: IR 05000327/1993045 ML20059G461
References
50-327-93-45, 50-328-93-45, NUDOCS 9311080163
Download: ML20059G466 (6)

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U?dlTED STATES

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Report Nos.: 50-327/93-45 and 50-328/93-45 i 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 I and 2 Inspection Conducted: September 13-17, 1993 Inspector: bhkh *,

M. Thoma's O Mww /C - 5- 93 Date Signed

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Approved by: m C. Casto, Chief

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d [e/P'/9 7 D' ate ' Signed Test Programs Section Engineering Branch Division of Reactor Safety SUMMARY Scope:

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This special, announced inspection was conducted in the areas of balance of plant (BOP) activities and followup on previously identified inspection finding .

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Results:

In the areas inspected, violations or deviations were not identifie Corrective actions were ongoing to complete items identified as being required - '

for Unit 2 restart. After restart, system engineers will continue to be actively involved in reviewing work requests to determine the appropriate prioritizatio For the open NRC items reviewed, appropriate corrective  ;

actions have been taken to address aspects of the items that were considered 1 to be restar However, for one inspector followup item (IFI) reviewed, 'l corrective actions were slow in being developed to address the broader 'l question of whether design change notice (DCN) requirements were being I adequately translated to work instruction )

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REPORT DETAILS .

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i'. asee Employees e

B. Ahmrdi, Modifications Field Electrical Engineering Manager j!

• R. Alsup, Site Quality Audit Manager

• L. Bryant, Maintenance Manager E. Burke, Modifications Field Mechanical Engineering Manager R. Clift, Modifications Field Engineering Manager

• R. Driscoll, Site Quality Manager .

• R. Fenech, Sequoyah Site Vice President ',

E. Hudgins, Modifications Procedures and Training Supervisor ,

• Kent, Radiological Control and Chemistry Manager l

• Lundy, Technical Support Manager t

• Meade, Licensing Engineering

• Powers, Plant Manager

• Rogers, Technical Support Program Manager

• Shell, Site Licensing Manager

• Thompson, Compliance Licensing Manager I A. Varner, Quality Assessment Supervisor

• J. Ward, Engineering and Modifications Manager '

• C. Whittemore, Licensing Engineer Other licensee employees contacted included engineers, operators, QA/QC personnel, craftsmen, and other plant personne :

NRC Employees

• Holland, Senior Resident Inspector

• A. Long, Resident Inspector

S. Shaeffer, Resident Inspector

• J. Stohr, Director, Division of Radiation Safety and Safeguards, RII

• Attended exit meeting f

Acronyms and initialisms used throughout this report are listed in the !

last paragrap . Plant Status .

Unit I was in the refueling condition (Mode 6) to support a refueling i outage and Unit 2 was in the cold shutdown condition (Mode 5) for a !

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forced outag . B0P Activities  ;

The inspectors reviewed ongoing B0P activities as the licensee completed actions for items that were determined to be restart. This included various maintenance and modification activities as well as changes to applicable procedure i

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One activity reviewed by the inspector concerned involvement of the system engineers in reviewing emergent issues for their assigned systems ;

to determine if the issues were appropriately prioritized and scheduled for restart. The inspector had determined during previous inspections that the licensee's actions in this area were satisfactory for emergent :

issues identified during this shutdow ,

During an earlier inspection, the inspector had questioned whether t '

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system engineers would continue to review the prioritization and scheduling of items after restart. The inspector followed up on this ,

question during this inspection. During discussions with system engineers and management personnel, the inspector found that there was an increased level of awareness and sensitivity to B0P material condition deficiencies which translated to problems being addressed in a more timely manner. However, the inspector noted that some licensee-personnel were not clear as to whether this level of involvement by the system engineers would continue after restart. During further discussions, licensee management indicated that this level of attention will continue after restar ,

The inspector reviewed Revision 0 of the Sequoyah Post Restart Plan, dated August 20, 1993, and found further indications of the increased management attention and system engineering involvement in the ,

prioritizing of work for ensuring the timely completion of activitie Item DD8-534 of the Sequoyah Site Improvement Plan (which is part of the Post Restart Plan) is as;igned for action to the Technical Support Manager to revise "SP 8.50 by October 1993 to reflect the system engineers' role in Issue and WR/WO prioritization. Technical Support management indicated that until SSP 8.50 is revised, a memorandum will be issued to the Technical Support staff (which includes Systems Engineering) to clearly state the involvement of system engineers in the work prioritization proces f The inspector determined that the licensee's actions adequately address the question of the system engineers' involvement in work prioritization after restart. The revision to SSP 8.50 will be reviewed during a future inspectio Violations or deviations were not identified in the areas inspecte . Followup on Previous Inspection Findings (92701, 92702) (Closed) IFI 50-327,328/92-34-02, Lack of Air System Component Filters This item involved a concern over the licensee's conclusion and justification that six safety related control air end user components supplied by non-essential air did not need filter l The concern was based on the fact that the non-essential air system had experienced water intrusion resulting in potential -

corrosion product particulate formation in the headers. The ,'

licensee understood this concern and implemented modification DCN

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M09151A which installed filters for each of the Unit-1 MSIVs. The '

inspectors' concern, as discussed in Inspection Report (IR)

50-327,328/92-34, originally encompassed two additional control <

air end users (two 5th vital battery room dampers) that were later !

determined had been provided with air filters. Installation of the filters for the MSIVs was verified by the inspectors during 1 inspection 50-327,328/93-3 '

Initially, the installation of the four MSIV filters was considered acceptable to address the inspectors' concerns over the lack of individual filters for safety-related components. A total of 24 safety-related components had been identified in IR 92-34 as not having individual filters,18 of which were considered to be adequately protected due to their air being provided from the more reliable and safety-related ACA system. The four MSIVs and the two battery room dampers made up the balance of the original 2 However, as discussed in IR 93-32, the ACA system had not passed an air quality test for particulate since the water intrusion :

event in October 1992. That fact coupled with the historic problems of the control air system overall, caused the inspectors i to question the 18 components which were previously considered acceptable without filters because they were supplied by the ACA system. This item was left open in IR 93-32 pending the licensee's resolution of the air quality problems and a reassessment of the need to install filters in the remaining 18 ACA system supplied component During followup of this item, the inspectors reviewed air quality test results for the ACA and SCSA systems and verified that the data met the test acceptance criteria for particulates. The licensee again concluded that the remaining components supplied by ,

the ACA system did not need local filters. The justification was based on the licensee's contact with the vendor for the associated components who recommended that the air system should include a filter to limit the particulate size to 50 microns. All of the end components were supplied by the same vendor. The ACA system has 0.9 micron afterfilters installed. Also, the ACA system has stainless steel piping installed between the afterfilters and the remaining end components to further reduce the likelihood of particulate greater than 50 microns reaching the component The inspectors concluded that the licensee's controls and '

justification for not Mtalling filters in the remaining end components was adequate. This IFI is considered close <

b. (0 pen) Violation 50-327,328/93-32-01, Failure to Follow Procedures for Failed ACA and SCSA Air Quality Tests This NOV was written because of the licensee's failure to initiate a problem evaluation report (PER) or other corrective action program document to identify the problem of the failed air quality tests. No corrective actions were initiated after the air quality I

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l test performed in January 1993, failed the acceptance criteria.for particulate size on the safety related portion of the' Control Air t Syste '

Subsequent to the violation, the licensee wrote PER SQPER930282 after the June 1993, air quality tests results did not meet the acceptance criteria either. The PER was evaluated against the ,

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restart criteria and was determined to be a restart PER. The PER also documented a corrective action plan for the Control Air ,

System. The inspector reviewed the corrective actions required for restart and verified that the actions completed adequately addressed the concerns of the NOV. This included satisfactory air quality test results, as discussed in paragraph 4.a. of this I The licensee's response to the NOV was due September 20, 1993, and the response had not been received at the conclusion of this inspection. This violation will remain open pending review of the ;

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licensee's response and corrective actions to the NO .

c. (0 pen) IFI 50-327,328/93-32-02, Resolution of Main Feedwater '

Modification Discrepancies This IFI was initiated to follow up on the licensee's resolution of weaknesses identified during implementation of the Main feedwater (MFW) System portion of DCN G8937 During review of this item the inspector noted that the licensee had taken adequate corrective actions to address the specific !

weaknesses identified in the IFI. Site Engineering performed an .

evaluation for the individual sections of stainless steel pipe ,

that were used as replacement for carbon steel pipe. These sections were not installed in accordance with the DCN requirements. It was determined that the thermal growth stress criteria was not exceeded and the piping was acceptable as ,

installed. Also, the inspector verified that work request (WR) i C173812 had been revised to incorporate all of the post .

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modification test requirements specified by Site Engineerin During further review of this IFI, the inspector noted that the ,

licensee was slow in developing actions to address the broader ;

question concerning DCN requirements not being effectively l translated to work documents. One of the contributors to the slowness in addressing the broader question appeared to be ;

modifications personnel not recognizing that there was a proble '

The inspector discussed this item with Modifications Department personnel who indicated that only minor discrepancies had been idertified and there was not a problem with work documents that were written to implement DCNs. The inspector questioned this ,

conclusion in light of the inspector's IFI findings and the results from two Site Quality Assurance performance based assessments of the Maintenance and Modifications departments

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during 1993. The latest assessment was a followup conducted June-July 1993. Both assessments rated the Modifications Department as

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" Unsatisfactory-requires corrective action" in the area of planning work orders for modification activities. This included Site Quality reviewing work packages and determining that some of the packages did not provide specific directions nor clearly-define the work to be performe During further discussions, licensee management indicated that findings identified in the Site Quality. as;essments and the IF were being reviewed by the Modifications Improvement Committee to address both the specific findings and the broader questions concerning the adequacy of work instructions for modification This IFI remains open and will be reviewed during future inspections to review any additional corrective actions taken by the licensee to address this weaknes ; Exit Interview  :

The inspection scope and results were summarized on September 17, 1993, with those persons indicated in paragraph I. The inspectors described ;

the areas inspected and discussed in detail the inspection finding '

Proprietary information is not contained in this report. Dissenting comments were not received from the license . Acronyms and Initialisms ,

ACA Auxiliary Control Air 1 B0P Balance of Plant -

DCN Design Change Notice IFI Inspector followup Item  ;

IR Inspection Report i MFW Main Feedwater MSIV Main Steam Isolation Valve  !

NOV Notice of Violation PER Problem Evaluation Report t QA Quality Assurance QC Quality Control ,

SCSA Station Control and Service Air  !

SSP Site Standard Practice .

WO Work Order i WR Work Request

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