IR 05000327/1996011

From kanterella
Jump to navigation Jump to search
Insp Repts 50-327/96-11 & 50-328/96-11 on 960915-1026. Violations Noted.Major Areas Inspected:Licensee Operations, Maint,Engineering,Plant Support, & Effectiveness of Licensee Controls in Identifying,Resolving & Preventing Problems
ML20134Q330
Person / Time
Site: Sequoyah  Tennessee Valley Authority icon.png
Issue date: 11/19/1996
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20134Q321 List:
References
50-327-96-11, 50-328-96-11, NUDOCS 9612020233
Preceding documents:
Download: ML20134Q330 (17)


Text

- . - - . - - - . . . - . ._- =_ -..= - - . .--

. .

., .

i

!

,

U.S. NUCLEAR REGULATORY COMISSION r

REGION II

l Docket Nos: 50 327, 50 328 License Nos: DPR 77, DPR 79

,

Report Nos: 50-327/96-11, 50-328/96-11

'

i Licensee: Tennessee Valley Authority

l Facility: Sequoyah Nuclear Plant, Units 1 & 2 '

,

Location: Sequoyah Access Road '

Hamilton County, TN 37379 l Dates: September 15 through October 26. 1996 Inspectors: M. Shannon, Senior Resident Inspector l D. Starkey, Resident Inspector l C. Rapp, Reactor Inspector (Sections E8.1 through E8.7) 1

,

W. Sartor, Reactor Inspector (Section Pl.2) l l S. Sparks, Project Engineer-

!  !

Approved by: M. Lesser, Chief Reactor Projects Branch 6 Division of Reactor Projects

l

!

f'

I

'

Enclosure 2 9612O20233 961119 PDR ADOCK 05000327 i PDR ._

. - .

_ _ . _ _ _ _ . - _ - _ . . . _ _ _ - . _ _ _ _ . _ . _ . _ - . _ _ . _

i

- ~

l

j-

i 1 j'

EXECUTIVE StM MRY 3 -

Sequoyah Nuclear Plant. Units 1 & 2 i NRC Inspection Report 50 327/ % 11, 50 328/96 11 l

This. integrated inspection included aspects of licensee operations, i maintenance, engineering, plant support, and effectiveness of licensee I

controls in identifying, resolving, and preventing problems. The report l covers a six week period of' resident inspection. -In addition,'it includes th '

[ -results of an announced inspection by.an engineering inspecto '

-Operations j e Operations management initiated a positive program to discuss, y during shift turnovers. recent configuration control issues in an L effort to reduce the' number of configuration control problems i j (Section 01.1). j A non cited violation (!JCV) was identifed for failure to use a i procedure when performing a main control room switch manipulation

-

(Section 01.2).

, e Operators were not aware that a radiation monitor with " low

! counts" would not perform its-designed Auxiliary Building .;

[ - Isolation (ABI) function (Section 02.1). 1

[ l

! Maintenance 1 i

! -

. .

o - A weakness was identified in the licensee's corrective action ]

' program for closing.a problem report on previously identified AFW bearing oil problems without substantial evaluation (Section M2.1).

! .

.

l e A positive observation was noted when Nuclear Assurance identified l four previous Problem Evaluation Reports (PER) related to i

! Auxiliary Feedwater (AFW) bearing oil problems (Section M2.1).

J '

l e - A weakness was identified regarding the licensee's switchyard i

_ preventive. maintenance program (Section M2.2).  !

o A violation was-identified for failure to install a temporary i

,f missile shield during excavation in the area of Essential Raw-l- Cooling Water (ERCW) underground piping (Section M2.3).

-

g

.;

}

i

.

,

s

, , r w ---c.- w--. r , , -4. -- , - -- , - -, y -

.. - . - . . - - . ~ - . . . - - . - -. . . ~ . _ - . - . . - - . . - . _ - - .

,

!  !

. .

-

.

2 .

Enaineerina

,

o A violation was identified in that the DG starting air system i relief valves were set above the design condition limit (Section

! E2.1).

e An NCV was identified for failure to incorporate procedural l guidance when an Abnormal Operating Instruction .(A0I) was upgraded l to an Abnormal Operating Procedure (A0P) (Section E8.4).

!

l Plant Sucoort

!

e The licensee conducted a challenging. Radiological Emergency Plan (REP) drill scenario in preparation for the November 6, 1996, i

graded REP exercise. During the drill critique, the licensee was

'

quick to identify drill deficiencies and ways to make improvements in the 2EP program (Section Pl.1).

e The emergency program was observed to be well managed and l- receiving management support. Effective corrective actions taken

'

to previous open items permitted the closure of two violations and -

two IFIs.- (Section Pl.2)

l l- I

!

I i

'

'

>

)

!

'

t

. . .- .. - . _

l

. .

l l

l

. Reoort Details Summary of Plant Status Unit 1 began the inspection period in power operation. The unit )

operated at power for the duration of the inspection perio Unit 2 began the inspection period in power operation. On October 11, l the unit began a controlled shutdown from 100% power because of a suspected failure of a reactor coolant pump seal and later that day operators manually tripped the Unit due to equipment problems and entered Mode 3. (See Inspectioc, Report 50 327,328/96 13). The unit entered Mode 5 and commenced a forced outage to replace two reactor coolant pump seal packages and one reactor coolant pump motor. On ,

October 24, 1996, when the repairs to the reactor coolant pumps had been

'

completed, the unit entered Mode 4. When the report period ended, the unit was in Mode 4 awaiting completion of repairs to the motor driven auxiliary feedwater pump I. Operations 01 Conduct of Operations l 01.1 General Comments (71707)

Using Inspection Procedure 71707, the inspectors conducted frequent reviews of ongoing plant operations. In general, the conduct of I operations was good. Particularly noteworthy were the thoroughness and 3rofessionalism of operations shift turnover briefings. Operations has

)egun discussing, during shift turnover briefings, recent instances of configuration control problems. This is considered a positive !

initiative by operations management to increase operator awareness of i such issues in an effort to reduce the number of configuration control problems. Additional operational events and observat%ns are detailed .

in the sections belo .2 Inaoorooriate Ooerator Action On September 24, 1996, a licensed operator assigned to Unit 1 ;

repositioned a Unit 2 Emergency Gas Treatment System (EGTS) Fan A suction damper control switch from the "A-Auto" position to the "Close" position and immediately returned the switch to "A-Auto." The damper was in the closed position both before and after the switch operation and no damper movement actually occurred. The operator performed this switch movement to verify the switch spring-return to-auto feature of the switch. However, the operator did not request the unit supervisor's permission prior to the test nor did he use Procedure 0-50 65 1 Emergency Gas Treatment System Air Cleanup and Annulus Vacuum, Revision 0, which gives direction on system alignment and operatio __ _ _ _ __ - _ _

' -

,

Operations management took appropriate disciplinary action and stressed I to all operators that unapproved testing activities do not meet management expectations. The ins)ectors concluded that no realignment of the EGTS occurred because of t1e unauthorized switch test and that o)erations management took immediate actions to emphasize to operators t1eir expectations regarding such activitie The failure to implement the EGTS system operating procedure when operating the EGTS system is considered a violation of TS 6.8. This ;

licensee identified and corrected violation is being treated as a Non- I Cited Violation, consistent with Section VII.B.1 of the NRC Enforcement Policy (NCV 50-327, 328/96 11-01).

02 Operational Status of Facilities and Equipment 02.1 Radiation Monitor Inoperable Due to Low Counts

a. Insoection Scope (71707)

The inspectors reviewed the deficiency related to " low counts" associated with radiation monitor 0-RM 90101C, Auxiliary Building Vent Monitor-Iodine, and the operability requirements for the monito )

i l

b. Observations and Findinas On September 18, 1996, during a routine tour of the main control room (MCR), the inspectors noted a Work Request (WR) sticker, WR C280035, dated April 12, 1996, attached to radiation monitor 0-RM-90-101C which indicated that the monitor had ' low counts." The inspectors questioned operators regarding the operability of the monitor and were informed, and subsequently verified, that the iodine channel monitor, channel C of i 0-RM 90101, was not required by either the Offsite Dose Calculation Manual (0DCM) or TS. However, the 00CM does require the iodine sampler, a cartridge in the radiation monitor flow path which is analyzed weekly )

by Chemistry, to be operable. The ODCH also requires the channel A particulate sampler and the channel B noble gas activity monitor be operable. The inspectors verified with Chemistry that the iodine sampler was, in fact, operable and that weekly samples were being take Discussions with the radiation monitor system engineer indicated that a condition of low counts renders channel C inoperable. The inspectors l also learned that repairs to the monitor were awaiting parts and that l the repairs were scheduled for the week of November 4,1996. The work '

order (WO) associated with the monitor repair stated that the reason for the low counts was a bad "HV" power supply or a bad detecto Further review by the inspectors of the operability requirements for I monitor 0-RM 90 101C revealed that the Updated Final Safety Analysis )

Report (UFSAR), Section 11.4.2.2.4 states that either of the three channels of 0 RM 90101 (A B, or C) automatically initiates an Auxiliary Building Isolation (ABI). On September 26, following a '

discussion with the Shift Manager regarding the loss of Auxiliary Building Isolation (ABI) function for 0 RM-90-101C. the MCR monitor was

= - - . - - . - - - - - _. _ . - . - _ .- . - . . . - . . _ . - . . -

o

.

. i

-

.

i 3  !

'

i ~

tagged with an "IN0P" tag. On September 28.- Problem Evaluation Report t (PER) No. SQ%2511PER was written by operations to address the validity 1 of the ABI initiation'since the monitor was not required by either TS or i the ODCM. The PER also questioned the time frame during which the- i monitor would not have performed the ABI function. On October 3, 199 maintenance personnel replaced the detector on 0-RM 90-101 successfully completed the_ post maintenance test (PMT), and returned the monitor to servic Conclusions The-inspectors concluded that operators were not aware that 0 RM 90101C would not perform its designed ABI function with a condition of " low counts" and. therefore, did not consider the monitor for 0 RM 90 101C to be inoperable. ~ However, once the question of operability was raised by the inspectors, operations took appropriate action to identify the monitor as inoperable and to write a PER. The inspectors will-follow up on the resolution of PER No. SQ962511PER regarding the ABI function of 0 RM 90 101C. This item is identified as Inspector Followup Item (IFI)

50 327, 328/96-11 02. Review Corrective Action of PER No. SQ962511PER

.Related to ABI Function of Radiation Monitor 0 RM 90 101 II. MainteGanCR M1 Conduct of Maintenance M1.1 GeneralComtg.niiE2707) Insoection Scoce (61726 & 62707)

-The inspectors observed and/or reviewed all or portions of the following ,

work activities and/or surveillances:  ;

o e WO9629423 Change inboard and outboard bearing oil,and perform section XI test e WO9304301 Replace flex conduit to MFIV 2 MV0P 003 0033A e WO9407044 Replace flex conduit to MFIV 2 HV0P-003 00478 l e' W09302957

-

Replace EDG starting air-system relief valve e WO9302971 Replace EDG starting air system relief valve e WO9628678 Replace failed primary water pump seal  :

. - . . _ - . . - . - . - - . . - . - - - - - . -- - - - -

, .

-

.

1 4 i- Observations and Findinos

'

The inspectors noted that the work activities and the performance of surveillance activities were adequately performe M2 . Maintenance and Material Condition of Facilities and Equipment i M2.1 Auxiliary Feedwater Pumo (AFW) 1B B Bearina Oil Discoloration Insoection Scoce (62707)

,

The inspector observed a scheduled preventive maintenance activity on (. the 1B B AFW pump which included changing the. oil on the inboard and t

outboard pump bearings.

i Observations and Findinas F .

.

i On September 30,19%, the inspector observed preventive maintenance

being performed on the 1B B AFW pump. The maintenance was performed

'

under WO 9629432 and included changing the oil in the inboard and outboard pump bearings. The oil wnich was drained had a noticeable dark discoloration and the subsequent oil sample results indicated a high level of iron and copper. . Also, while inspecting the bearing housing, the licensee discovered two metal fragments which were believed to have come from the threads of the oil drain plug when it was over tightened during its last installation. The licensee performed a visual inspection of the bearings and did not identify any abnormalitie New oil was added, an American Society of Mechanical Engineers (ASME)

Section XI test was performed on the pump, and the oil was flushed and replaced again following the Section XI tes i The licensee documented the discovery of. the discolored oil in PER N SQ962516PER and discussed their oil sample findings with the pump i

'

vendor. In a letter from the vendor to the licensee dated October 2, 1996, the vendor stated that both the pump and bearing vendor were aware of instances (throughout the industry) of " black oil" but had not been l able to determine.the exact source of the oil discoloration. The vendor l further stated that they were not aware that this condition and/or the resulting " black oil" caused failure or accelerated failure of the bearing, and subsequently the ) ump. The vendor recommended that the licensee continue to monitor t1e condition and quality of the oil and to change it periodically. The licensee informed the inspector that they !

intend to drain and sample the oil after each quarterly run of the pum On October 7, 1996, the vendor stated in another letter to the licensee, that the pum) should )erform satisfactorily until the next refueling outage and tlat TVA s1ould follow the recommendations concerning the ,

'

monitoring and changing of-the oil. The vendor further stated that they

.had not established any specific allowable percentages of elements found in the oil as indicators to change the oi !

. . . - -- -- . _ _ - . --

, .

.

'

As a result of this most recent problem with AFW bearings / oil, the licensee's Nuclear Assurance organization initiated PER No. SQ962542PER, dated October 2,1996, which referenced four previous PER's related to AFW bearing oil problems, and classified these four PERs as examples of inadequate recurrence control. One of those four PERs, No. SQ951743PER, dated October 5,1995, had also identified high metal content in the 1B-B AFW bearing oil. That PER was closed in April 1996 without a root cause analysis, without an extent of condition review, without a review of 3revious similar events, or without interim actions addressing the :

, hig1 metal conten ' Conclusions

.

) A positive observation was noted when Nuclear Assurance identified four i

-

previous PERs related to AFW bearing oil problem l

A weakness was identified in the licensee's corrective action program i

for failure to adequately address previously identified AFW bearing oil problem '

l M2.2 Exolosion of Potential Transformer in 500 KV Switchyard  :

  • Insoection Scooe (62707)

-

On October 5,1996, a potential transformer (PT) in the 500 KV a switchyard exploded. The inspector reported to the site to assess the

'

damage to the switchyard and to verify that neither unit was affected by the explosion.

Observations and Findinas

,

The explosion of the PT caused the loss of Bus 1 in the 500 KV switchyard. Switchyard relays sensed the electrical fault, as designed, and power circuit breakers o)ened to clear the differential fault.

'

During the event, oil from t1e failed PT sprayed onto the gravel in the switchyard and ignited. The fire was extinguished in approximately 16

'

minutes. Additionally, shrapnel from the ex)losion damaged the 500 KV to 161 KV intertie transformer as well as otler switchyard components such as insulators. Both units experienced various control room alarms but no plant equipment was affected and both units continued to operate at full power. There were no personnel injuries during the even Approximately one hour after the initiation of the event, the licensee simultaneously declared, then exited, a Notification of Unusual Event due to an ex)1osion within the protected area. The licensee also determined tlat the loss of the intertie transformer did not affect the reliability of the required off site power source The licensee subsequently replaced three pts, including the one which

. exploded, and returned the 500 KV Bus 1 to service on October 12, 199 However, when the inspection period ended, the intertie transformer

remained out of service for repairs and other PM activitie .

The inspector reviewed the PM history related to the type of PT which failed and learned that preventive maintenance had never been performed on these particular pts since they were purchased in 1972. The recommended PM interval was noted to be six year Due to increased attention which the licensee has recently placed on switchyard maintenance, these particular pts had been scheduled to be inspected during the next outage in 199 Conclusions The inspector concluded that the licensee's failure, over a period of years, to ensure that the 500 KV switchyard pts were routinely inspected, contributed to the eventual failure of the PT. This is considered a weakness of the switchyard PM progra M2.3 Yard Fire Hydrant Reoair/Reclacement Inspection Scope (62707)

The inspectors reviewed the activities related to repair / replacement of ,

a yard fire hydrant adjacent to the ERCW underground pipin ! Observations and Findings During tours of the facility the inspectors noted excavation in the j area of the ERCW underground piping missile shield. Excavation was i directly adjacent to the missile shiel The inspector requested the licensee to provide information regarding requirements for excavation near safety related equipment. The inspector learned that Site Standard Practice (SSP)-7.4. Work Permits. Revision 7. required that Site Engineering shall be notified by the cognizant engineer prior to any I excavations within 10 feet of Category 1 structures (buildings, manholes, conduit banks, etc.).

On June 18, 1996, excavation permit No. 94 09292-00 was signed and issued by Site Engineering to remove earth from around a fire hydrant adjacent to an ERCW concrete missile shield in order to replace the hydrant. The permit required temporary missile protection if the excavation was within six feet from the edge of the ERCW permanent missile protection. The inspector verified that the fire hydrant was less than two feet from the ERCW permanent missile protection and therefore personnel should have contacted Site Engineering for specific guidance on installing temporary missile protection. The actual excavation to replace the fire hydrant was started on October 4.199 The inspector reviewed WO 9409292 and noted that, in step 5.1. the work supervisor initialed the step acknowledging that the excavation would be performed per the SSP-7.4 excavation permit which was part of the work package. However, the work supervisor did not contact Site Engineering for specific instructions nor did he install any temporary missile protection as required by the excavation permit, even though the hydrant was less than the required six feet from the permanent ERCW missile

.

. ._ _. _ _ _ - _ _ . _ _ _ _ _ _ . . _ _ . _ _ . _ _ _ _ _ . ._

. .

A

. protection. The failure to install temporary missile protection for ERCW piping as required by SSP 7.4 is considered to be a violation (VIO 50 327.328/96-11 03).

Following discussions with the licensee, PER No. SQN962668PER was i initiated to document that temporary missile protection.was not in place j and that the excavation was immediately adjacent to the ERCW permanent l missile protection concrete sla !

c. Conclusions

'

The failure to follow a procedure, which required a temporary missile shield, while excavating in the area of ERCW missile shield, is l considered to be a violatio l

j III. Encineerina l

!

El Conduct of Engineering 1

-

E1.1 General Comments (37551)

An inspection was' conducted on September 23 27..1996, in the areas of service water system operational performance in accordance with NRC Temporary Instruction (TI) 2515/118. This inspection concentrated on resolution of existing open items associated with the Service Water System inspection. The NRC review concluded the licensee had adequately i addressed the technical issues associated with the service water systems. Section E8 discusses items related to this service water followup inspectio E2 Engineering Support of Facilities and Equipment l E2.1 Diesel Generator (DG) Startina Air system Relief Valves Insoection Scooe (37551)

During the previous inspection period, the inspector observed an emergency diesel generator (DG) starting air system relief valve lifting due to overpressure. The inspector reviewed the documentation associated with the relief valve PM program and the relief valve corrective maintenance history, Observations and Findinas Due to problems being experienced with the DG starting air system pressure control switches, the system relief valves had been documented as lifting on several occasions. During tours with an assistant unit operator (AU0) the inspector observed a lifting DG starting air system relief valve. The inspector had noted that the relief valve was lifting with a pressure of 345 psig on the starting air system receiver tan This observation was discussed in detail in IR 96 09 and included a

.. _ __ . _ - . _ . _ . . . _ . _ _ _ _ ,

. .

.

violation for inadequate corrective action associated with the repair >

and replacement of the starting air compressor pressure control  ;

'

switche In order to determine proper operation of the relief valve, the inspector reviewed the lift setpoints for the system relief valves. The system control drawing. CCD No.l.2 47W839 2. NOTE 3. listed the design

' pressure as 250 psig. This drawing information was incorrect. The i inspector noted that normal system pressure is controlled between 250-300 psi l The design basis document, SQN-DC-V-11.8. documented the maximum I operating condition as 300 psig and the design condition for the system !

at 330 psig. The work history noted that the relief valves were set in l a range of 340 to 360 psig. The licensee is committed to the 1986 Edition of the ASME Pressure Vessel Code. The 1986 Edition of the ASME Code,Section VIII UG 125 (c), states that all aressure vessels shall be ,

protected by a pressure relieving device that s1all prevent pressure l from rising more than 10% above the maximum allowable working pressure 1 (operating condition) of the system. Contrary to the ASME code, the DG starting air system relief valves were set above the allowable limit of 330 psig and this is considered to be a violation (VIO 50 327 328/96-11- 1 04). I Conclusions The failure to properly adjust the DG starting air system relief valve (8) setpoints is considered to be a violatio E8 Miscellaneous Engineering Issues (92902. TI 2515/118)

E8.1 (CLOSED) IFI 95 03-01: Generic Letter (GL) 89 13 Actions on Dead Leg Flushing, Chemical Treatment. High Pressure Fire Protection (HPFP)

System and Airside Cooler Testing i This IFI identified that the licensee's GL 8913 committed actions were !

not fully implemented. Neither the licensee's actions nor the docketed !

GL 89-13 response fully encompassed the HPFP system. Also, the licensee's docketed GL 89-13 response omitted discussion of room cooler air side testin l

The inspector toured the ERCW intake pumping station and inspected the ERCW pumps, strainers, traveling screens, and flood mode sump pump Additionally, the inspector noted the chemical chlorination injection line was being replace '

Regarding room cooler air side testing. the licensee's GL 89 13

'

response, dated September 22, 1995, discussed that periodic air flow testing was performed on the air side of the Emergency Safeguards Features (ESF) room / area coolers and lower containment vent coolers to confirm minimum air flow recuirements. The inspector determined that this periodic testing was acequat . - - - - - ~ - - - - . - . - - - - - . - - - - - - .

,

i

. . l

)- *

i- ,

'

! 9 Regarding the.HPFP system, the licensee's position was that the HPFP system was not a safety-related system and the HPFP system was not included as a service water system as defined by GL 8913 because it did !

not add heat to the ultimate heat sink. The inspector concurred with :

the: licensee's position that the HPFP was not a service water system as l defined by GL 8913. However, based on Technical-Specification requirements, the licensee was maintaining the HPFP comparable to the GL 89 13 requirement .

E8.2 (CLOSED) VIO 95-03 02: Inadequate Design Control Measures for ERCW, HPFP, and DG Batteries This was a four part' violation that identified numerous deficiencies in I design control measures associated with ERCW strainer plugging, use of the HPFP system for flood mitigation, acceptability of replacement DG batteries, and the setpoint calculation for turbine building isolatio The inspectors reviewed the corrective actions contained in the licensee's response dated May 22, 1995. Based on the inspectors review, these corrective actions had been implemented and adequately addressed the deficiencies. Accordingly, this violation is close E8.3 (CLOSED) URI 95 03-03: Interpretation of Design Basis Flood This Unresolved Item (URI) questioned whether the licensee's categorization of the design basis for two 100% capacity ERCW upper deck sump pumps as an " event" versus an " accident" was consistent with NRC regulations. Due'to the licensee's classification that the upper deck sump pumps were required to mitigate certain " events" but not the consequences of an accident, the sump pumps had-not been included in any pump testing or maintenance progra The inspectors concluded that the upper deck sump pumps would not be considered safety-related by any existing regulation. However, occurrences such as fires, floods, missiles, storms, or earthquakes were considered." events" and any event can lead to or cause an accident that requires analysis under Chapter 15 of the UFSAR. Since the sump pumps have some importance to safety, the licensee should have a testing program to comply with General Design Criteria (GDC) I. GDC I requires ,

components important to safety be tested to quality standards commensurate with the im)ortance of the safety function to be performe The inspector verified tie licensee had placed the ERCW sump pumps in-the second ten-year inspection interval:for ASME Section XI. Since ASME Section XI testing clearly meets the requirements of GDC I, this URI is close E8.4 (CLOSED) VIO 95-03 04: Inadequate Procedures or Improper Procedure Implementation This violation identified five examples of deficiencies with either procedure quality or adherence. The examples cited were inadequate review of procedure Abnormal Operating Instruction (A0I) 7. Probable Maximum Flood,' failure to post a transient fire load permit, failure to

. . - . -

-- _ . .

-

,

' 10 place a work request sticker on inoperable control room instrumentation, and inadequate performance of an equalivanency evaluation. The inspectors reviewed the corrective actions contained in the licensee's response dated May 22, 1995. Based on the inspectors review, these corrective actions had been implemented and adequately addressed the i deficiencies. Accordingly, this violation is close '

During the review of corrective actions for inadequate review of procedure A01-7, the inspectors noted that a licensee Quality Assurance ,

(QA) audit had identified procedure Abnormal Operating Procedure (A0P)- '

N.03, Flooding, Revision 0, contained references to procedure 0 FP-MXX-000 003 and did not contain actions that were in A0I 7. The licensee had canceled procedure 0-FP-MXX-000-003. Flood Preparation - Parts, !

Tools, and Equipment to be Moved Above Elevation 723.1, and included a )

list of supplies and equipment that were to be moved above the flood level in procedure A0P N.03. The licensee had issued PER N SQ962256PER dated August 2.1996 to document these QA audit finding ,

The licensee issued A0P N.03 revision 1 effective September 6,1996 to I address the QA audit findings, j 10 CFR 50, Appendix B, Criterion III, " Design Control " states in part ,

that " Measures shall be established to assure that applicable regulatory )'

requirements and the design basis . . . are correctly translated into s)ecifications, drawings, procedures, and instructions." Contrary to t1e above, the licensee failed to ensure the procedural guidance provided in A0I-7 was pro)erly translated to A0P-N.03. However, the ,

licensee had identified tie problem and taken prompt corrective actio '

This licensee-identified and corrected violation is being treated as a Non Cited Violation, consistent with Section VII.B.1 of the NRC

,

Enforcement Policy. This is item is identified as NCV 50 327. 328/96- 4 11-05. Inadequate Translation of Procedural Guidance During AOP Upgrade Progra E8.5 (Closed) VIO 95 03 05: Failure to Identify Conditions Adverse to Quality This violation identified three examples for failing to initiate a problem evaluation report of conditions adverse to quality. The examples cited were multiple calculations that were not adequately documented for stand alone review, multi)le deficiencies with plant service water system identified during tie licensee's self assessments in 1993 and 1994, and failure to comply with TS 6.2.3.4. The inspectors reviewed the corrective actions contained in the licensee's response dated May 22, 1995. Based on the inspectors review, these corrective actions had been implemented and adequately addressed the deficiencie Accordingly, this violation is close E8.6 (CLOSED) IFI 95-03 08: LC0 Considerations for Select Room Coolers The licensee had issued a memorandum to Operations personnel providing guidance on entry into LCOs when room coolers were removed from servic The memorandum contained a matrix that related room coolers to the

.- ---

. .

11 a)plicable LC0 and the unit or units affected. The inspectors concluded t1e memorandum provided sufficient guidance to the operator E8.7 (CLOSED) IFI 95 03-10: Implementation of New Ultrasonic Testing Methodology This IFI identified the licensee's ultrasonic testing (UT) of piping had i not been o)timized. The UT was a pass / fail test without attempting to quantify t1e corrosion rate or predict through-wall failures. Within the past year, the licensee began to gather data to determine corrosion rate or predict through wall failure. The program had not been in effect long enough to produce quantifiable result i The inspector held discussions with the engineering personnel involved in the wall thickness inspections and reviewed the test data for two areas inspected using UT identified as 1-67 D G057 and 1-67 W-G02 Licensee trending of UT data indicated that base material thickness for ,

piping area 1-67 W-G024 was ap3 roaching minimum wall thickness and was I recently replaced. Based on t1e inspectors evaluation, this program was found to be adequat IV. Plant Support i P1 Conduct of EP Activities )

Pl.1 Observation of Radioloaical Emeraency Preoaredness (REP) Drill a. Insoection Scoce (82301) l l

l On October 2, 1996, the inspector observed portions of an REP drill which the licensee conducted in pre)aration for the November 6 full scale REP Graded Exercise. On Octo)er 4, 1996, the inspector attended the licensee's formal critique of the October 2 dril b. Findinas and Observations The inspector observed the activation of the Technical Support Center I (TSC) during this total loss of all offsite AC electrical power drill scenario. To give a realistic effect the TSC normal lighting was disabled and the TSC was illuminated only by installed emergency lighting and hand carried flashlights. The TSC was staffed expeditiously and appeared to function smoothly even with limited lighting. The inspector observed that the licensee experienced problems with the Integrated Computer System (ICS), an initial shortage of phone headsets, and telecommunication problems with the corporate emergency ,

response center. These deficiencies were discussed by the licensee at i the formal critique following the dril l I

. - - - . - _ - .- .

.

. .

-

.

. Conclusions The inspector concluded that the licensee conducted a challenging REP drill scenario in preparation for the November 6,1996, graded REP exercise. During the drill critique, the licensee was quick to identify drill deficiencies and discussed ways to make improvements in the EP program.

.

Pl.2 Followuo  !

, I InsDeCtion SCODe (82701)

l

-

The inspection focused on program initiatives to correct program I deficiencies that were identified in an emergency preparedness l inspection conducted in April 1996 and documented in Inspection Report i 50 327, 50-328/96 04.

'

< Observations and Findinas Since the April inspection the licensee had conducted a self assessment of the emergency preparedness program and completed the 50.54(q) review 1 of the program. The reviews resulted in some minor inconsistencies !

being corrected but both the self assessment and 50.54(q) review

'

validated an effective program. The inspector's review of 1)

documentation addressing the maintenance of the emergency preparedness

program, 2) equipment and facilities, and 3) review of training i
documents and training was accomplished with no safety-significant

>

issues identifie The focus of inspection observations was on the open items from the April inspection. The inspector reviewed the radiological monitoring i instrumentation in the Control Room against the instrumentation ranges

and nomenclature identified in the EALs. No issues were identified, which closed IFI 50 327, 328/96-04 05. The inspector reviewed selected copies of the Emergency Plan and Implementing Procedures to verify that controlled copies were being properly maintained. No discrepancies were

,

noted, thus closing VIO 50 327, 50 328/96 04-06. The inspector reviewed the status of the batteries for the OSC radios. The batteries were fully charged, with 11 spares available. The licensee had implemented a program for maintaining the batteries. This closed VIO 50-327, 50 328/96 04-07. The inspector reviewed the licensee's implementation of its tracking and closing of items identified as issues during drill The inspector found the licensee to be extremely aggressive in tracking items and assigning responsibility for corrective action. This closed IFI 50 327, 50 328/96-04 0 Conclusions The inspector's observations verified that the program was being managed effectively, and that good corrective actions had been taken to previously identified issues. Two open violations (50 327, 50 328/96 04 08 and 50-327, 328/96 04 10) were not reviewed because

-

. -_- - . - -

.

.

.

i additional information had been provided to NRC and a reply had yet to J

be provided.

'

The emergency program was obstrved to be well managed and receiving management suppor Effectivo corrective actions taken to previous open

items permitted the closure of two violations and two IFI V. Manaarment Meetinas i

X1 Exit Meeting Summary The inspectors ) resented the 11spection results to members of licensee

,

management at t1e conclusion of the inspection on November 5,1996.

i

.

The licensee acknowledged the findings presented.

! The inspectors asked the licer see whether any materials would be considered proprietary. No p'oprietary information was identified.

.

! PARTIAL LIS1 0F PERSONS CONTACTED Licensee

  • Adney, R., Site Vice President
  • Beasley, J., Acting Site Quality Manager
  • Bryant, L., Outage Manager
  • Burzynski, M., Engineering & Materials Manager Driscoll, D., Training Marager
  • Fecht, M., Nuclear. Assurar.ce & Licensing Manager Fink F., Business and Wo"k Performance Manager
  • Flippo, T., Site Support 11anager
  • Harrington, W., Acting Ma'ntenance Manager
  • Herron, J. , Plant Manager Kent, C. 'Radcon/Chemistr) Manager Lagergren, B., Operations ianager Rausch, R. Maintenance and Modifications Manager Reynolds, J., Operations Superintendent
  • Rupert, J., Engineering and Support Services Manager
  • Shell, R., Manager of Licensing and Industry Affairs Skarzinski, M., Technical Support Manager
  • Smith, J., Licensing Supervisor Summy, J., Assistant Plant Manager Symonds, J. Modifications Manager
  • Attended exit interview INSPECTION PROCEDURES USED IP 37551: Onsite Engineering IP 40500: Effectiveness of Licensee Controls In Identifying, Resolving, & Preventing Problems IP 61726: Surveillance Observations

- . --

' '

'

.

.

14 IP 62707: Maintenance Observations IP 71707: Plant Operations IP 71750: Plant' Support Activities IP 82301: Evaluation of Exercises for Power Reactors IP 92902: Followup Maintenance TI 2515/118: Service Water System Operational Performance Inspection

<

IO 82701: Operational Status of the Emergency Preparedness Program

IHMS OPENED. CLOSED. AIO DISCUSSED Ooened TyRg Item Number

_ Status Descriotion and Reference NCV 50 327, 328/96-11 01 Open/ Failure to Implement EGTS System Closed Operating Procedure When Operating EGTS (Section 01.2).

IFI 50-327, 328/96 11-02 Open Review corrective Action of PER N i SQ962511PER Related to ABI Function of Radiation Monitor 0 RM-90-101C (Section 02.1).

VIO 50 327. 328/96-11-03 Open Failure to Install Temporary Missile Protection for ERCW Piping as Required by SSP-7.4 (Section M2.3).

VIO 50-327, 328/96 11-04 Open Failure to Set DG Starting Air )

System Relief Valves with the ASME l Code Limit (Section E2.1). NCV 50 327, 328/96 11 05 Open/ Inadequate Translation of Procedural Closed Guidance During A0P Upgrade Progra (Section E8.4) ,

Closed Typf Item Number Status Descriotion and Reference IFI 95 03 01 CLOSED GL Actions on Deadleg Flushing Chemical Treatment. HPFP System & Airside Cooler Testing (Section E8.1)

VIO 95 03 02 CLOSED Inadequate Design Control Measures for ERC HPFP and EDG Batteries (Section E8.2)

URI 95 03 03 CLOSED Interpretation of Design Basis Flood (Section E8.3)

_

. . .

. -

l

VIO 95 03 04 CLOSED Inadequate Procedures or Improp: Procedure Implementation (Section E8.4) ,

VIO 95 03-05 CLOSED Failure to Identify Conditions Adverse to l Quality (Section E8.5) l IFI 95 03 08 CLOSED LC0 Considerations for Select Room Coolers (Section E8.6)

IFI 95 03-10 CLOSED Implementation of New Ultrasonic Testing Methodology (Section E8.7)

IFI 96 04 05 CLOSED Inconsistency between Numenclature in the EALs and Control Room, and Proper Terminology in the EALs (Section Pl.2)

VIO 96 04 06 CLOSED Failure to Maintain Controlled Volumes of the I EPIPs up to date (Section Pl.2) l

VIO 96 04-07 CLOSED Failure to Maintain Operational Readiness of the i Batteries for the Emergency Two way Radios in l the OSC (Section Pl.2)

IFI 96-04-09 CLOSED Verify the Tracking and Resolution of Corrective Action Items and Items Needing Improvement Identified in Drill Reports (Section 1.2)

LIST OF ACRONYMS USED ABI -

Auxiliary Building Isolation l AC - Alternating Current AFW -

Auxiliary Feedwater A0I -

Abnormal Operating Instruction A0P -

Abnormal Operating Procedure ASME -

American Society of Mechanical Engineers AU0 -

Assistant Unit Operator CCP -

Centrifugal Charging Pump CFR -

Code of Federal Regulations CLA -

Cold Leg Accumulator DG -

Diesel Generator DRP - Division of Reactor Projects ECCS -

Emergency Core Cooling Systems EDG -

Emergency Diesel Generator EGTS - Emergency Gas Treatment System EHC -

Electro Hydraulic Control EP -

Emergency Preparedness ERCW - Essential Raw Cooling Water ESF -

Engineered Safeguard Features GDC -

General Design Criteria GL -

Generic Letter gph -

Gallons per hour

. - _- . _ . - -- . _ - _ . __ -

, ,

.. .

.

,

HV - High Voltage

,

ICS -

Integrated Computer System

.

IFI -

Inspector Followup Item IR -

Inspection Report

KV -

Kilo Volt LC0 -

Limiting Condition for Operation LER -

Licensee Event Report MI -

Maintenance Instruction MSIV - Main Steam Isolation Valve MCR -

Main Control Room NIS -

Nuclear Instrumentation System NOUE -

Notification of Unusual Event

NCV -

Non cited Violation NRC -

Nuclear Regulatory Commission

NRR -

Nuclear Reactor Regulation j ODCM -

Offsite Dose Calculation Manual PCF -

Procedure Change Form PER -

Problem Evaluation Report PM -

Preventive Maintenance PMT -

Post Maintenance Test P00 -

Plan of the Day PT -

Potential Transformer

. psig -

pounds per square inch gage

. QA -

Quality Assurance

! QC - Quality Control

! RCS -

Reactor Coolant System i REP - Radiological Emergency Plan RHR -

Residual Heat Removal RM -

Radiation Monitor

rpm -

Revolutions per Minute RVLIS - Reactor Vessel Level Indication System SALP - Systematic Assessment of Licensee Performance SFP -

Spent Fuel Pit / Pool

-

SI -

Surveillance Instruction SR0 -

Senior Reactor Operator

. SSP -

Site Standard Practice Solid State Protection System

'

SSPS -

TI -

Tem)orary Instruction l TS -

Tec1nical Specifications

TSC -

Technical Support Center l TVA -

Tennessee Valley Authority

'

.

UFSAR - Updated Final Safety Analysis Report UT -

Ultrasonic Testing URI -

Unresolved Item VCT -

Volume Control Tank VDC -

Volts Direct Current Violation

'

VIO -

WO -

Work Order WR -

Work Request j

.

I