IR 05000327/1993053

Insp Repts 50-327/93-53 & 50-328/93-53 on 931115-19.No Violations Noted.Major Areas Inspected:Meteorological Monitoring,Control Room Emergency Ventilation,Audits & Secondary Water Chemistry

ML20059B945
Person / Time
Site:	Sequoyah
Issue date:	12/17/1993
From:	Decker T, David Jones NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20059B923	List: IR 05000327/1993053 ML20059B918
References
50-327-93-53, 50-328-93-53, NUDOCS 9401040297
Download: ML20059B945 (8)

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UNITED STATES I

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.I Report Nos.: 50-327/93-53 and 50-328/93-53 Licensee: Tennessee Valley Authority 6N 38A Lookout Place 1101 Market Street  ;

. Chattanooga, TN 37402-2801 i Docket Nos.: 50-327 and 50-328 License Nos.: DPR-77 and DPR-79 Facility Name: Sequoyah 1 and 2 l Inspection Conducted: November 15-19, 1993 j Inspector: [(d fw;w M//7/ D.W.(Jon~es Date Signed l

Approved by: A c' /;' ,h 7 s T. R. Decker, Chief Date'51gned *

Radiological Effluents and Chemistry Section Radiological Protection and Emergency Preparedness Branch Division of Radiation Safety and Safeguards ,

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SUMMARY

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This routine, announced inspection was conducted in the areas of l meteorological monitoring, control room emergency ventilation, audits, and t secondary water chemistr !

Results:

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In the areas inspected, no violations or deviations were identifie l The licensee had implemented an effective program for maintaining the

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meteorological monitoring instrumentation in an operable status (Paragraph 2).

The licensee had complied with the operational and surveillance requirements ,

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for the control room emergency ventilation systems (Paragraph 3).

1 The licensee had implemented an effective audit program. The audits were of 4fficient scope and depth to identify potential or existing problems and  :

• Jrrective actions were taken for identified findings (Paragraph 4). -

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9401040297 931217 PDR ADOCK 05000327 i G PDR

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a The calibration and setpoint adjustment for the' secondary chemistry on-line :

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monitoring instrumentation was delinquent but the licensee had made adequate

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progress on development of new proceduras for those surveillances -

(Paragraph 5).  !

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REPORT DETAILS ' Persons Contacted Licensee Employees .

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D. Adams, Program Manager, Chemistry

• R. Alsup, Quality Audit Supervisor, Nuclear Assurance j D. Amos, Nuclear Chemist, Chemistry ,

J. Barker, Secondary Chemist, Chemistry

_ i tJ. Baumstark, Manager, Operations D. Bodine, Manager, Environmental Programs, Radiation Protection R. Campbell, Systems Engineer, Technical Support

• E. Chandrasekaron, Project Manager, Corporate Chemistry l

• J. Dills, Systems Engineer, Technical Support j t*R. Driscoll, Manager, Site Quality {

t*R. Fenech, Site Vice President >

C. Kent, Manager, Radiological Control and Chemistry

• D. Keuter, Vice President, Nuclear Readiness D. Pittman, Meteorologist, Corporate Resource Group -l

• S. Poage, Manager, Audits and Assessment, Nuclear Assurance i

• K. Powers, Plant Manager  ;

t*J. Proffit, Compliance Engineer, Compliance Licensing  !

• G. Rich, Manager, Chemistry j t*G. Sanders, Manager, Operations Support i 1R. Shell, Manager, Site Licensing L. Strickland, Manager, Process Chemistry G. Taylor, Radiochemical Analyst, Chemistry ,

• R. Thompson, Manager, Compliance Licensing

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t*N. Welch, Superintendent, Operations

• C. Whittemore, Licensing Engineer, Compliance Licensing l l

Other licensee employees contacted included engineers, technicians, and I administrative personne j Nuclear Regulatory Commission tW. Holland, Senior Resident Inspector t*S. Shaeffer, Resident Inspector 1 Attended entrance intervie l

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• Attended exit intervie . Meteorological Monitoring Program (84750)

TSs 3/4.3.3.4 for both units described the operational and surveillance requirements for the meteorological monitoring instrumentatio Instrumentation for wind speed, wind direction, and vertical air temperature differences was required to be operable at all times and demonstrated to be operable by the performance of daily channel checks and semiannual channel' calibrations. An Action Statement specified that' .

when one or more of the monitoring channels is inoperable for more than -l 7 days, a Special Report would be submitted to the NRC within 10 days l

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outlining the cause of the malfunction and the plans for restoring the instrumentation to operable statu .

The inspector toured the meteorological monitoring station and discussed its operation with the licensee. The licensee indicated that the _;

meteorological data were accumulated and summarized by a computer located at the monitoring station and the summarized data were ,

transmitted to their corporate office for use in offsite dose -'

calculations. The sensor components of the instrumentation, located on the station tower, were routinely exchanged at six month . intervals. The removed sensors were then calibrated prior to being returned to service during subsequent sensor exchanges. The wind direction sensors were :

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calibrated onsite and the wind speed and air temperature sensors were calibrated by an offsite vendor. The inspector reviewed the following procedures and determined that they included provisions for performing the required surveillances at the required frequenc .26, " Calibration of Air Temperature Sensors - Nuclear" 05-11.27, " Calibration of Wind Speed Sensors - Nuclear"

, DS-61.21, " Calibration of Wind Direction Sensor Climet Model 012-Nuclear"

The inspector reviewed selected records of recent performance of those procedures and determined that the instruments had been calibrated at the required frequenc The licensee also provided the inspector with quarterly summaries of the meteorological monitoring instrumentation's percent availability for the first three quarters of 1993. Those data indicated that the instruments were typically operable more than 90 percent of the tim The inspector reviewed procedure 2-SI-0PS-000-003.D, Rev. 7,

" Surveillance Test Program" and determined that it included provisions ,

for performing the required daily channel checks of the meteorological monitoring instrumentation in the Control Room. The Daily Shift Log records for November 13 and 16, 1993, indicated that the surveillances had been performed on those day Based on the above reviews and observations, it was concluded that the licensee had implemented an effective program for maintaining the meteorological monitoring instrumentation in an operable statu No violations or deviations were identifie l Control Room Emergency Ventilation Systems (84750)

TSs 3/4.7.7 for both units described the operational and surveillance _ i requirements for the control room cmergency ventilation systems. Two independent systems consisting of fans, pre-filters, high efficiency D particulate air (HEPA) filters, and charcoal adsorber filter beds were

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required to be operable during all operational modes. Action statements applicable to various modes were provided for conditions in which one or both of the systems were inoperable. The frequencies for functional testing, filter leak testing, air flow measurements, differential pressure measurements, and charcoal adsorption efficiency testing were specifie The inspector toured the mechanical equipment room in which the control .

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room ventilation systems were located. The licensee's cognizant system engineer located and identified, for the inspector, the major components of the systems. The inspector observed that the components and associated ductwork were well maintained structurally and that there was no physical deterioration of the ductwork sealant .

The inspector reviewed the procedures listed below and determine'1 that they included provisions for performing the above operability and performance tests at the required frequencies. The acceptance criteria -

for the test results specified in those procedures were consistent with ,

the TS requirements. Review of selected records of those tests indicated that they had been performed in accordance with the testing procedures and that the acceptance criteria cad been me '

1-SI-0PS-000-00 " Shift Log" 0-SI-0PS-030-02 " Control Room Air Cleanup Subsystem" 0-SI-SFT-031-143. A (&B) " Control Building Emergency Air Cleanup System Filter Train A (&B) Test" 0-SI-SFT-031-144. A (&B) " Control Room Emergency Ventilation Test Train A (&B)"

0-SI-0PS-030-14 " Control Room Emergency Ventilation Automatic Actuation" 0-SI-SXX-000-14 "Results From Test Laboratory On Charcoal Test Sample" Based on the above reviews and observations, it was concluded that the licensee had complied with the above operational and surveillance requirements for the control room emergency ventilation system No violations or d6/iations were identifie ,

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4. Audits (84750 and 86750)

TSs 6.5.2.8 for both units required the licensee to perform audits of facility activities which encompass, in part, the following: the -

conformance of facility operation to provisions contained within the TSs and applicable license conditions at least once per 12 months; the performance, training, and qualification of the facility staff at least once per 12 months; the Radiological Environmental Monitoring Program f

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and the results thereof at least once per 12 months; the Offsite Dose Calculation Manual and implementing procedures at least once per !

24 months; the Process Control Program and implementing procedures at least once per 24 months; and the performance of activities required by the Quality Assurance Program for effluent and environmental monitoring at least once per 12 months. TS 6.5.2.10.c required that reports for the above audits be forwarded to facility management within 30 days after completion of the audit The inspector reviewed the reports for Audit No. SQA92304 " Radiological Effluent and Environmental Monitoring", Audit No. SSA93301 " Plant Chemistry / Plant Layup and Equipment Preservation", and Audit No. SSA93306 " Radiological Controls and Radioactive Material Management". Those audits were conducted during the periods December 1, 1992 - January 20, 1993, January 4,- February 22, 1993, and February 22 - April 14, 1993, respectively, by the licensee's Site Quality organization. The scope of those audits included, in part, l facility activities in the following areas: liquid and gaseous effluent monitoring program; environmental monitoring program, compliance with the Offsite Dose Calculation Manual; radwaste processing, storage, classification, and shipping; water chemistry control program; implementation of the Chemistry Upgrade Project; and followup on issues identified during previous audits. Substantive issues, minor deficiencies and recommendations for program improvements were identified in those audi*.ed areas. The inspector determined that the audits were of sufficient scope and depth to identify potential or existing problems and that corrective actions were taken for identified findings. The audit results were well documented and promptly reported to facility management. Management response to the audit results and corrective actions were prudent and timel Based on the above review, it was concluded that the licensee had implemented an effective audit progra No violations or deviations were identifie . Secondary Water Chemistry (84750)

TS 6.8.5.c for both units required the licensee to establish, implement and maintain a program for monitoring of secondary water chemistry to I inhibit steam generator tube degradation. The program requirements included: identification of the variables to be monitored, process I sampling points, sampling frequency and control limits for those '

variables; and procedures for measurement of those variables, data recording and management, corrective actions for off-control chemistry 1

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conditions, assignment of responsibility for corrective actions, monitoring of condensate for condenser in-leakage, and corrective action for identified condenser in-leakage within 96 hour0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> The inspector reviewed the licensee's Site Standard Practice SSP-1 " Conduct of Chemistry", which described the overall chemistry program for the facility, and determined that the SSP included provisions for l

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implementing the secondary water chemistry program requirement Appendix E to that SSP delineated, for each primary and secondary plant system, the chemical parameters to be monitored, the operating goals (desired range for the parameter), the monitoring frequency, and action limits for listed parameters. Appendix F prescribed the on-line analyzer setpoints for ensuring that secondary chemistry was controlled within-industry guidelines. Appendix G prescribed the calibration specifications for the secondary chemistry on-line monitoring instrumentatio The inspector requested to review the procedures and records for the current setpoints and calibrations of the secondary chemistry on-line monitoring instrumentation. The licensee indicated that those procedures and records were the subject of a Problem Evaluation Report (PER) and a Significant Corrective Action Report (SCAR) initiated on June 15, 199 Copies of the PER, SCAR No. SQSCA920009, and the licensee's information and data package related to the SCAR were provided to the inspector for review. Those documents indicated that Surveillance Instruction SI-587, for calibration of Sampling and Water Quality System Instrumentation, specified an 18 month calibration frequency for that instrumentation and that those calibrations were last performed on May 10, 1985, and February 21, 1984, for Unit 1 and Unit 2, respectively. The section of the SCAR which addressed the extent of the problem indicated that in addition to SI-587, approximately 30 other non-TS related SI's had been identified as being delinquent. The PER and SCAR also indicated that there were inconsistencies between Technical Instruction TI-41-43 and Instrument Maintenance Instruction IMI-43. TI-41-43 provided the scaling and setpoint information for the sampling and water quality system instrumentation and IMI-43 provided information and instructions'for calibration and setpoint adjustment of the instrumentation. The PER and SCAR further indicated that the alarm setpoints specified in TI-41-43 and IMI-43 were incompatible with the current water chemistry control program requirements. The licensee indicated'that the range within which the various chemical parameters must be controlled was dependent upon the type of water chemistry control program being employed and that the secondary chemistry control program had been changed from an ammonium hydroxide injection based program to a morpholine injection based '

program. Therefore, the change in the water chemistry control program necessitated revision of the instructions for calibration and setpoint adjustment of the secondary on-line monitoring instrumentation. In order to correct these problems an action plan was developed which included monthly progress reports on completion of the delinquent instrument calibrations and revision of the procedures for calibration and set point adjustment of the secondary chemistry on-line monitoring instrumentatio A Notice of Violation (NOV) was issued on April 22, 1993, for failure to perform calibrations of the instruments identified in the SCAR at the required frequency and for failure to document technical justification for deferral of those calibrations in accordance with SSP-8.2 (Reference NRC Inspection Report Nos. 50-327/93-09 and 50-328/93-09). The licensee's reply to that NOV indicated that a list of components with L

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delinquent calibrations had been developed and that those components were being calibrated based on an established priority. It was also ,

indicated that safety related, compliance, and post-accident monitoring l instrument components with' delinquent calibrations would either be :

calibrated or have technical justification for deferral before restart ;

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of the respective units from the current outages. Followup and closure ,

of that issue was documented in NRC Inspection Report Nos. 50-327/93-42 ,

and 50-328/93-42. During this inspection, the technical justification !

for deferring performance of 51-587 was reviewed. The Test Scheduling r Deferral Form indicated that SI-587 was being replaced by approximately i 200 Instrument Data Packages (IDPs), one for each of the secondary ,

chemistry in-line monitoring instrument components. The proposed date i for having all of the IDPs written and performed was June 1,1994. The l inspector informed the licensee that their progress on that project would be reviewed during subsequent inspection Based on the above reviews, it was concluded that the licensee was :

taking adequate corrective actions for the problems identified in SCAR :

No. SQSCA92000 No new violations or deviations were identifie . Exit Interview The inspection scope and results were summarized on November 19, 1993, with those persons indicated in Paragraph 1. The inspector described the 1

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areas inspected and discussed in detail the inspection results listed above. No dissenting comments were received from the license i Proprietary information is not contained in this repor ,

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