IR 05000327/1993201

Insp Repts 50-327/93-201 & 50-328/93-201 on 930823-930902. Several Deficiencies Noted.Major Areas Inspected:Plant Operations,Maint,Engineering & Quality Programs

ML20058P676
Person / Time
Site:	Sequoyah
Issue date:	10/13/1993
From:	Imbro E, Jeffrey Jacobson, Koltay P Office of Nuclear Reactor Regulation
To:
Shared Package
ML20058P653	List: IR 05000327/1993201 ML20058P650
References
50-327-93-201, 50-328-93-201, NUDOCS 9310250147
Download: ML20058P676 (50)

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,f U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION NRC Inspection Report: 50-327/93-201 License Nos.: DPR-77 and DPR-79

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and 50-328/93-201 Docket Nos.: 50-327/328

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Licensee: Tennessee Valley Authority facility Name: Sequoyah Nuclear Plant, Units 1 and 2 Inspection at: Sequoyah Nuclear Plant, Soddy Daisy, Tennessee Inspection Conducted: August 23 through September 2, 1993 Inspection Team: Jeffrey B. Jacobson, Team Leader, NRR John D. Wilcox, NRR Serita Sanders, NRR Roy Mathew, NRR Richard Barkley, Region I Greg Galletti, NRR Jack Gadzala, Region III Terrance Reis, Region IV Donald Beckman, Consultant Prepared by: /%/ h /0 [M!N JeffrfyB ~ J obson, Team Leader Date Team Ins e ion Development Section B Special Inspection Branch Division of Reactor Inspection and Licensee Performance Office of Nuclear Reactor Regulation Reviewed by: -

W I Peter S. Koltay, Section Chief Date ,

Team Inspection Development Section B Special Inspection Branch Division of Reactor Inspection i and Licensee Performance  !

Office of Nuclear Reactor Regulation

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Approved by: /#[/3!G

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Eugene V. Imbro, Chief Dat'e Special Inspection Branch

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Division of Reactor Inspection and Licensee Performance ,

Office of Nuclear Reactor Regulation  !

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t SUMMARY OF DEFICIENCIES

DEFICIENCY 93-201-01 (Paragraph 4.5.1)

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DEFICIENCY TITLE: Operations Personnel Operated Red HOLD Tagged Valve DESCRIPTION OF CONDITIONS: S During the conduct of valve lineups, the inspection team observed two licensee personnel operate valves that were labeled with a HOLD tag. Procedure SSP [.

12.3, (Revision 3), " Equipment Clearance Procedure", directs that equipment

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tagged with a HOLD tag must not be operated under any condition. The team observed the two operators check open the two manual valves by partially shutting, then reopening the valves. The licensee responded to this situation by stopping the valve lineup and counseling the individuals involved. A standing order was issued emphasizing that components with a HOLD tag are not to be operated except when performing the audit required by Procedure SSP 12.3. The licensee initiated an evaluation of the valve lineup procedure to -

determine clarifications necessary to better correlate this with the equipment clearance procedur REGULATORY REQUIREMENTS:

Criterion V of Appendix B to 10 CFR Part 50 states in part that " activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings."

REFERENCES: SSP 12.3, " Equipment Clearance Procedure", Revision 3 -

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DEFICIENCY 93-201-02 (Paragraph 4.7.1)

DEFICIENCY TITLE: Inadequate Functional Recovery Procedure ,

DESCRIPTION OF CONDITION:

During review of the Emergency Operating Instructions, a deficiency was identified in the Functional Recovery Status Tree Procedure FRP F-0.4. The procedure required the operator to refer to a series of Pressurized Thermal Shock curves, provided as attachments to the procedure, to evaluate certain decision steps within the status tree. The procedure did not provide adequate referencing guidance to ensure the proper curve would be used when required.

REGULATORY REQUIREMENTS:

Criterion V of Appendix B to 10 CFR Part 50 states in part that " activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings."

REFERENCES:

FRP F-0.4, " Functional Restoration Guidelines Status Trees for Pressurized Thermal Shock," Revision i e

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DEFICIENCY 93-201-03 (Paragraph 4.7.3)

DEFICIENCY TITLE: Lack of 50.59 Evaluation Regarding FSAR Design Deviations in the Main Control Room (MCR) Habitability System and Main Control Room Emergency Ventilation System

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DESCRIPTION OF CONDITION:

On June 23, 1989, TVA identified a deficiency regarding the functionality of smoke detectors installed in the MCR HVAC syste The detectors are designed to detect smoke in the control building fresh air intake and provide automatic-isolation of the MCR and initiation of the Main Control Room Emergency Ventilation System (MCREVS) as defined in the FSAR. The functionality of the detectors was questioned because the smoke detectors installed in the fresh air intake duct system were designed for low flow open-air applications and not for high velocity duct-type applications that exist for this applicatio As part of the Condition Adverse to Quality Review (CAQR) evaluation, the licensee reviewed the Technical Specification bases, Section 3/4.7.7, " Control Room Emergency Ventilation System," and determined that operability of the system was not challenged even though the smoke detectors might not function since their potential inoperability would not effect the ability of the system to actuate on a safety injection or high radiation signal. A safety evaluation pursuant to 10 CFR 50.59(b)(1) was not performed as part of the CAQR evaluatio As justification for continued operation the licensee identified several contingencies including requiring manual operator action to isolate the MCR, and relying on fire watch patrols to provide early warning capability of smoke or fir The licensee issued a standing order on September 28, 1989, which required operators to take manual action to isolate the MCR if smoke was detected. The standing order did not delineate the specific methods for performing the isolation function and no additional procedural guidance was provided to operators. The standing order was removed after 90 days per SSP-12.1, " Conduct of Operations," prior to completing the corrective actions described in the CAQ When an operator was questioned on the initiation of the MCR isolation given a smoke condition in the MCR, there appeared to be some confusion as to the desired method for performing manual isolation of system. Additionally, procedures related to use of the system, A01-30, " Plant Fires," and 50-30-2,

" Control Room Ventilation System," did not adequately describe the preferred method for performing this manual function (e.g., isolating the control room via handswitches on the main control boards).

On August 27, 1993, the licensee initiated WAR #C082818 to survey existing flow characteristics within the HVAC duct work. The survey indicated that

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flowrates in the vicinity of the detectors were approximately 240 feet per minut The licensee contacted the vendor of the detectors to determine if A-3

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the detectors would function under those flow conditions. The vendor could '

not provide any technical documentation to substantiate that the installed detectors would functio As a result of the team's concerns related to the engineering evaluation .

performed and the weaknesses in the implementation of compensatory measures outlined in the Justification for continued operation (JCO), the licensee performed a 10 CFR 50.59 evaluation and initiated PERs SQ930451 and SQ930463 .

to: (1) change the FSAR to recognize operator action on the detection of smoke in the control room as the licensing basis for the actuation of the control room isolation; (2) provide additional procedural guidance on manual isolation of the MCR and automatic initiation of the MCREVS in A01-30; (3) revise SSP-12.1 to enhance the controls on issuance and cancellation of standing orders; and (4) issue a new standing order describing operator actions required to mitigate such an event. The team evaluated the licensee's corrective actions and found them to be adequat REGULATORY REQUIREMENTS:

10 CFR 50.59(b)(1) states, in part, that "the licensee shall maintain records of changes in the facility and changes in procedures made pursuant to this section, to the extent that these changes constitute changes in the facility '

as described in the safety analysis report or to the extent that they constitute changes in procedures as described in the safety analysis repor These records must include a written safety evaluation which provides the bases for the determination that the change, test, or experiment does not involve an unreviewed safety question."

REFERENCES:

SQN Technical Specifications, Section 3/4. SQN FSAR Chapters 9.4, 6.4, and SSP-12.1, " Conduct of Operations", Revision 6

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A01-30, " Plant Fires", Revision 10 l

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DEFICIENCY 93-201-04 (Paragraph 5.3.1)

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DEFICIENCY TITLE: Inadequate Diesel Generator Test Procedure DESCRIPTION OF CONDITION:

Section 6.8, steps 5 through 7, of Test Procedure 2-SI-0PS-082-026.A directs

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that the diesel be loaded to greater than or equal 4840 kW, but within the two ,

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hour rating contained in an attached appendix. The diesel generators manufacture's specified two hour rating is 4840 kW. Taken together, these two requirements result in loading the diesel generators to 4840 kW with no tolerance band. During the most recent performance of this test on each of L the four diesels, operators inadvertently neglected the two hour manufacturer's rating and operated the 1A, IB, and 2A diesels for two hours at 4900 kW and the 2B diesel at 5000 k Running a diesel under such high loads places additional stresses upon it and normally necessitates an inspection for any damage and to verify that it remains acceptable for continued operation. Technical specification 4.8.1.1.2.d requires that the diesel be inspected in accordance with the vendor's recommendations. However, the test procedure did not address this inspection requirement and past performances of this surveillance were not followed by the required inspection. Therefore, operability of the diesel during subsequent reactor operation was not assured following performance of these surveillance test Inspections of the 2A and 28 diesels were performed by the licensee in July and June 1993 respectively. These were the first inspections following the March and April 1993 tests of these diesels. The only notable finding was on the 2B diesel where a copper air gap ring exhibited hot blow by. The licensee found no other unexpected conditions. No inspections were performed on the 1A and IB diesels since their last surveillance tests in March 1993. Following i discussions with the team, the licensee contacted the diesel vendor to discuss this issue. The vendor stated that 4900 kW is within the diesels' design margin and no additional inspection would be require The licensee initiated a change to their diesel surveillance procedures to reduce the potential for operators to overload the diesels during testin The procedure will further be changed to incorporate the lower diesel loading guidelines stated in of Regulatory Guide 1.9 (Revision 3). Additionally, a ;

technical specification change request was initiated to incorporate the new guidelines into the plant's technical specification REGULATORY REQUIREMENTS:

Criterion V of Appendix B to 10 CFR Part 50 states in part that " activities

affecting quality shall be prescribed by documented instructions, procedures, l or drawings, of a type appropriate to the circumstances and shall be

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accomplished in accordance with these instructions, procedures, or drawings."

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t REFERENCES:

2-SI-0PS-082-026.A (Revision 4), " Loss of Offsite Power With Safety Injection '.!

- D/G 2A-A Containment Isolation Test" .

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DEFICIENCY 93-201-05 (Paragraph 6.6)

DEFICIENCY TITLE: Inadequate Procedure To Control Borrowed Equipment

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DESCRIPTION OF CONDITION:

4 During the week of August 23, 1993 the licensee experienced problems with the 2A-A Emergency Diesel Generator and obtained a replacement governor from the installed and abandoned 5th emergency diesel generator. The licensee had in place a process by which parts and materials could be borrowed from other installed components, abandoned components, or from installed components at other facilities within the TVA system. The licensee followed its procedures for obtaining the component and procurement engineering determined the component to be adequate in form, fit and function. However, personnel performing the replacement questioned the acceptability of the component due to corrosion. At that time the governor was deemed unacceptable for us When queried by the team, the licensee assessed its procedures and found that the applicable procedure SP-6.22, Section 3.7.3, " Requirements for Materials Borrowed from Installed Plant Equipment," did not ensure that components obtained from installed plant components or abandoned equipment were inspected from a functional standpoint prior to being placed in a " Ready for Issue" statu REQUIREMENT:

Criterion V of Appendix B to 10 CFR Part 50 states in part that " activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings."

REFERENCE:

SSP-6.22, " Planning Work Orders," Revision 12 I

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DEFICIENCY 93-201-06 (Paragraph 6.6)

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DEFICIENCY TITLE: Inadequate Engineering Evaluation of Replacement Material .

DESCRIPTION OF CONDITION:

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On August 22, 1993, the licensee identified a deficiency in which Appendix R h emergency lighting had been replaced with battery packs with higher wattage bulbs resulting in a condition where the battery packs would not conform to the 8-hour illumination criteria established in Appendix R, Subsection J.

The team evaluated the licensee's Previous Procurement Substantiation Process, which is a process for verification that replacement items meet or exceed the original design basis of the host component or structure. The team found that the evaluation focused on the dimensional and seismic suitability of the replacement component and did not adequately address the difference in wattage rating.

Further investigation by the team found that the procurement engineer had used an outdated Technical ~ Instruction, TI-104, " Replacement Items Verification for Critical Structures, Systems, and Components," Revision 4. The team found that a updated, more detailed procedure SSP 10.5, " Technical Evaluation for Procurement of Materials and Services," had not been used. No procedural guidance existed directing procurement engineering personnel to utilize the updated, more prescriptive procedure. The team considered that had the updated procedure been used, the difference in wattage might have been recognized.

The licensee agreed that TI-104 was obsolete and that improved instructions for the Previously Procured Substantiation Process were contained in SSP 10.5.

TI-104 was deleted and SSP 10.5 was revised to improve the PPSP process.

REQUIREMENT:

Criterion V, Appendix B, 10CFR 50 states, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these-instructions.

REFERENCES:

Technical Instruction, TI-1-4, " Replacement Items Verification for Critical Structures, Systems, and Components," Revision SSP 10.5, " Technical Evaluation for Procurement of Materials and Services,"

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DEFICIENCY 93-201-07 (Paragraph 6.7)

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DEFICIENCY TITLE: Inadequate Emergency Lighting

'e DESCRIPTION OF CONDITION:

' The team examined Maintenance Instruction M1-10.6, " Emergency Lighting (Appendix R)," Revision 3, dtd February 15, 1993. The team member noted that each lantern assembly is tested quarterly by performing a 30 minute discharge

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test and verifying no significant reduction in illumination. The licensee I

employs battery assemblies from two different vendors. One type is commercially rated for a five year life at ambient temperature and the other type is rated for a fifteen year life at ambient temperature. The latter type is what is predominantly installed. The licensee's program calls for .

replacing the assemblies on three and eight year periods respectively or as l warranted by the quarterly testing.

l The team member noted that some assemblies were applied in the steam and

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feedwater penetration areas. The team requested temperature profiles of these areas and found that at operation, ambient temperature in these areas can exceed 120 degrees Fahrenheit. Electric Power Research Institute (EPRI)

guidance indicates that in general, lead-acid battery life is halved for every 16 to 18 degrees above 77 degrees Fahrenhei The licensee promptly analyzed all temperature profiles where Appendix R s

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emergency lighting was applied and found six battery assembly units in Rooms l 706-Al and 706-All that would not maintair an 8-hour discharge capacity given their installation in an elevated temperature environment and their replacement interval. The licensee initiated Problem Evaluation Report SQ930474 to replace the affected assemblies and revise the maintenance instruction to shorten the replacement interval of the newly installed assembl ie REQUIREMENT:

Appendix R, Subjection J, of 10CFR 50, states, in part, that emergency lighting units with at least 8-hour battery power supply shall be provided in all areas needed for operation of safe shutdown equipmen REFERENCES:

Maintenance Instruction MI-10.6, "rmergency Lighting (Appendix R)," Revision .

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DEFICIENCY 93-201-08 (Paragraph 6.9) ,

DEFICIENCY TITLE: Failure To Perform 18 Month Channel Calibration

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DESCRIPTION OF CONDITION:

Work Order 0050206 identified that the RHR pump room 2 post accident area i radiation local indicator was not working during the implementation of work package S1 P0965 dated 4-9-91. Since all other components in the radiation monitoring loop 2-RM-90-290 were functional, the licensee determined that the radiation monitoring loop was operable and the work package (51 P0965) was signed off with an outstanding work request written to replace the faulty indicator. Work Order C050206 remained open until the replacement of the faulty indicator was completed. The team noted that a channel calibration had to be completed every 18 month in accordance with procedure SI 685.2, " Channel Calibration for Low Range Accident Monitors 18 months," Revision 10 and FSAR i Section 11.4.4 " Calibration and maintenance." The next channel calibration which was due on 1-15-93 was deferred due to the outstanding work order against the local indicator. This calibration should not have been deferred ,

as the instrument was considered operable and had not been taken out of service. As a result of the team's questions, the licensee wrote PER No.

SQ93458 to address the missed channel calibration. Du.ing the inspection, the licensee took the radiation monitor channel out of service and was preparing for channel calibration.

REQUIREMENTS:

10 CFR 50 App. 8, Criterion V requires that activities affecting quality shall be prescribed by documented instructions, procedures or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with '

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DEFICIENCY 93-201-09 (Paragraph 9.2)

DEFICIENCY TITLE: Inadequate Storage of Compressed Gas Cylinders DESCRIPTION OF CONDITION: j

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During the system walkdown, the team members noted several examples of improper storage of compressed gas cylinders. One argon cylinder in emergency B diesel generator bay lAl, a nitrogen cylinder in the mechanical chiller room, 669' level and several refrigerant cylinders adjacent to safety-related chillers in the auxiliary building were improperly secured. Procedure SSP-12.7, " Housekeeping / Temporary Equipment Control," Revision 10, dated August 6, a 1993 requires that cylinders be secured such that if the bottom portion of the cylinder is moved horizontally, the top will not slip its tie. None of the cylinders identified met this criteria. The inadequate storage of compressed air cylinders is considered a deficiency. The licensee initiated PER SQ930477 to address the improper storage and agreed to evaluate mechanisms other utilities had employed to solve this proble REQUIREMENT:

Technical Specification 6.8.1 requires that written procedures shall be established, implemented and maintained covering the applicable procedures recommendcd in Appendix A of Regulatory Guide 1.33, Revision 2, February 197 Appendix A of Regulatory Guide 1.33, Section 1 requires administrative procedures for equipment control. Licensee Procedure SSP-12.7, Appendix A implements this requirement for the temporary storage of compressed gas cylinders within plant space REFERENCES:

SSP-12.7, " Housekeeping / Temporary Equipment Control", Revision 1 l l

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N APPENDIX B

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LIST OF 3BSERVATIONS

• = Inadequate Documentation of Technical Evaluations, 93-201-01 (paragraphs ;

3.1.2, 7.3, and 8.4.1) }.

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= Excessive Operations Department Overtime, 93-201-02 (paragraph 4.4)

- Weaknesses In Control Room Abandonment Drill, 93-201-03 (paragraph 4.5.2)

• Lack of Guidance for Abnormal Operating Procedures, 93-201-04 (paragraph {

4.7.2)

• Inadequate Evaluation of Foreign Language Equipment Instructions, 93-201-05 (paragraph 4.7.4)

• Backlog of Safely Related Vendor Manual Updates, 93-201-06 (paragraph 6.11)

• Weak Review of Industry Information (i.g., information Notices),

93-201-07 (paragraph 7.4)

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... Distribution:

Docket Files 50-327/328 RSIB R/F u DRIL R/F TEMurley, NRR FJMiraglia, NRR WTRussell, NRR JGPartlow, NR CERossi, NRR RPZimmerman, NRR EVImbro, NRR PSKoltay, NRR '

JBJacobson, NRR RLSpessard, AEOD SAVarga, NRR FJHebdon, NRR DElaBarge, NRR MHSanders, NRR WEHolland, SRI Regional Administrators Regional Division Directors Inspection Team LPDR PDR ACRS (3)

OGC (3)

IS Distribution i

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