ML18030A822
| ML18030A822 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 10/23/1985 |
| From: | Brooks C, Cantrell F, Patterson C, Paulk G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18030A820 | List: |
| References | |
| 50-259-85-45, 50-260-85-45, 50-296-85-45, NUDOCS 8511040331 | |
| Download: ML18030A822 (28) | |
See also: IR 05000259/1985045
Text
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UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323
Report Nos.:
50-259/85-45,
50-260/85-45,
and 50-296/85-45
Licensee:
Valley Authority
500A Chestnut Street
Tower II
Chattanooga,
37401
. Docket Nos.:
50-259, 50-260,
and 50-296
License Nos.:
and
Facility Name:
Browns Ferry Nuclear Plant
Inspection
Conducted:
August
20 - September
30,
1985
Inspectors:
au
,
en1
e
ent
n
atterson,
s
t
roo s,
es
nt
Approved by:
F.
. Cantre
, Section
se
,
Division of Reactor Project
r
>2 ~$
ate
1gne
z3 z~
a e
sgne
gag gW
ate
igne
zing)
ate Signed
SUMMARY
Scope:
This routine inspection
involved
240 resident
inspector-hours
in
the
areas
of operational
safety,
maintenance
observation,
reportable
occurrences,
previous
enforcement
matters,
surveillance
testing,
regulatory
performance
improvement
program,
and refueling activities.
Results:
FOUR VIOLATIONS-
10 CFR 50, Appendix B, Criterion
XVI for failure to take corrective
action fer a diesel
generator false start.
2.
10 CFR 50, Appendix B, Criterion
V for multiple examples:
a.
Failure to maintain Reactor Protection
System circuitry per plant
drawing.
b.
Failure
to maintain
record of
a diesel
generator
surveillance
instruction.
851i0403~i
8/025'DR
ADOCK OM
@DR
c.
Failure to use
a
PORC approved
maintenance
request.
d.
Failure
to
have
an
adequate
operating
instruction for'he
containment
purge-system
charcoal
heaters'.
3.
10 CFR 50, Appendix B, Criterion VI for failure to maintain drawings of
the vacuum breaking system.
4.
Appendix
B, Criterion
XVI, for failure to
preclude
repetition of violation
on failure to perform
vendor
recommended
maintenance
items.
REPORT DETAILS
Licensee
Employees
Persons
Contacted:
J.
A. Coffey, Site Director
R. L. Lewis, Plant Manager (Acting)
J.
E. Swindell, Superintendent
- Operations/Engineering
T.
D. Cosby, Superintendent
- Maintenance
(Acting)
J.
H. Rinne, Modifications Manager
J.
D. Garison, guality Engineering Supervisor
D.
C. Mims, Engineering
Group Supervt'sor
R. McKeon, Operations
Group Supervisor
C.
G.
Wages,
Mechanical
Maintenance
Supervisor
J.
C. Crowell, Electrical Maintenance
Supervisor
(Acting)
R.
E. Burns, Instrument Maintenance Supervisor
A. W. Sorrell, Health Physics
Supervisor
R.
E. Jackson,
Chief Public Safety
T. L. Chinn, Senior Shift Manager
T. F. Ziegler, Site Services
Manager
J.
R. Clark, Chemical Unit Supervisor
B. C. Morris, Plant Compliance Supervisor
A. L. Burnette, Assistant Operations
Group Supervisor
R.
R. Smallwood, Assistant Operations
Group Supervisor
S.
R. Maehr, Planning/Scheduling
Supervisor
G.
R. Hall, Design Services
Manager
W. C. Thomison, Engineering Section Supervisor
C.
E. Burke,
Radwaste
Group Controller
Other
licensee
employees
contacted
included
licensed
reactor
operators,
auxiliary operators,
craftsmen,
technicians,
public safety officers, quality
assurance,
design
and engineering
personnel.
Exit Interview
(30703)
The
inspection
scope
and
findings
were
summarized
September
20,
and
October I, 1985 with the Plant Manager and/or Assistant Plant Managers
and
other members of his staff.
The licensee
acknowledged
the findings and took no exceptions.
The licensee
did not identify as proprietary any of the materials
provided to or reviewed
by the inspectors
during this inspection.
Licensee Action on Previous
Enforcement Matters
(92702)
(Closed)
Unresolved
Item (259/83-27-05).
The licensee
has
established
a
program to certify hydrometers.
The hydrometers
in the tool
room were
inspected
and
each
contained
a current certification sticker.
This item is
closed.
(Closed) Violation (259,260,296/83-19-01).
The Pressure
Suppression
Chamber
(PSC)
System
has
been returned to an operable status.
Operating Instruction
OI-74,
Residual
Heat
Removal,
has
been
revised
to provide
a
method of
alignment of the
keep fill system
using
the
system or the condensate
transfer
system.
This item is closed.
(Closed) Violation (259,260,296/83-33-06).
Instrument Tabulation
Drawings
and 47B607-64-8R were reviewed
and found to have
been correctly
revised.
This item is closed.
(Closed)
Open
Item (259/83-33-07).
This item has
been
inspected
during
other routine
inspections
since
Report
83-33
and
Unit
3 drywell
leak
detection
equipment is discussed
in paragraph five.
This item is closed.
(Closed)
Open
Item (259/83-33-08).
The licensee
has
completed
detailed
procedures
for the control
room panels 9-3 and 9-4.
This item
is closed.
(Closed)
Open Item (259/83-52-01)..
The licensee
has
done
a detailed'review
of the control
and filing of temporary alterations.
Discussions
with
personnel
involved in the review indicated
the process
was sufficient to
correct deficiencies identified in the past.
This item'is closed.
(Closed)
Open
Item (259/83-33-05).
Technical
Instruction
38 has
undergone
a major revision to upgrade
the procedure.
This item is closed.
(Closed)
Violation (259/83-60-02).
Plant procedures
have
been
revised
in
this
area
to require notification of the chemistry
section
upon unit
startup.
This item is closed.
(Closed)
Unresolved
(260/81-09-01).
The
Pressure
Suppression
Chamber
System
has
been returned to an operating status.
This item is closed.
(Closed)
Open
Item (260/82-06-02).
Procedure
revisions
have
been
made to
designate
high worth control
rods
on the rod pull sheet.
This item is
closed.
(Closed)
Violation (260/82-15-06).
The response
to this violation was
reviewed
and the inspector
has
no further questions.
This item is closed.
(Closed)
Violation (260/82-12-03).
Procedure
revisions
to Surveillance
Instruction 4.6.H. 1, Visual Examination of Hydraulic and Mechanical
were reviewed
and found adequate.
This item is closed.
(Closed)
Violation (260/82-19-03).
The licensee
response
and corrective
action were reviewed.
The inspector
has
no further questions
in this area.
This item is closed.
(Closed)
Violation (260/82-24-01).
The licensee's
corrective action in
this
area
was
reviewed
and
recent
inspections
have
found
no
equipment
problems in this area.
This item is closed.
4.
5.
(Closed)
Open Item (260,296/82-34-04).
This item was previously closed for
Unit
1 and closed
now for the other units.
(Closed)
Violation (260/83-33-06).
The inspector
reviewed
the licensee
response
to this violation and the present
method of adjusting the
R factor.
This item is closed.
(Closed)
Violation (260/83-43-02).
The response
and corrective
steps
to
this violation were
reviewed
and the inspector
has
no further questions.
This item is closed.
(Remain
Open)
Open Item (259,260,296/81-35-05)
Licensee
Event Report 85-04
discusses
the
problems
with the
low pressure
coolant injection
(LPCI)
motor-generator
(MG) sets
and
the repair
program in process.
All Unit 2
MG sets
have
been returned to the vendor for permanent repair.
Units
1
and
3 will be repaired after the return of Unit 2.
The
MG sets
continue to
be plagued with problems.
(Closed)
Violation (296/82-34-03).
Mechanical
Maintenance
Instruction
MMI-28 was
reviewed for post-maintenance
test requirements.
This item is
closed.
(Closed)
Violation (259/260/296/84-23=02).
Further tracking in this area-
concerning
diesel
generator will be under the deviation addressed
in this
report.
Unresolved
Items* (92701)
In paragraph
five there is
an unresolved
item about the
vacuum
breaking
system,
in paragraph
six there is
an unresolved
item concerning
fuses,
and
in paragraph
ten there is
an unresolved
item concerning reactor protection
system
panel discrepancies.
Operational
Safety
(71707,
71710)
The
inspectors
were kept informed
on
a daily basis
of the overall plant
status
and
any significant safety matters
related
to plant operations.
Daily discussions
were held
each
morning with plant management
and various
members of the plant operating staff.
The inspectors
made frequent visits to the'ontrol
rooms
such that each
was
visited at least daily when
an inspector
was
on site. Observations
included
instrument readings,
setpoints
and recordings;
status of operating
systems;
status
and
alignments
of emergency
standby
systems;
onsite
and offsite
emergency
power
sources
available for automatic
operation;
purpose
of
temporary tags
on equipment controls
and switches;
alarm
t
n unreso
ve
tern
ss
a matter
a out w ich more information is required to
determine whether it is acceptable
or may involve a violation or deviation.
status;
adherence
to
procedures;
adherence
to limiting conditions for
operations;
nuclear
instruments
temporary alterations
in effect;
daily journals
and logs;
stack monitor recorder
traces;
and control
room
manning.
This
inspection
activity also
included
numerous
informal
discussions
with operators
and their supervisors.
General
plant tours
were conducted
on at least
a weekly basis.
Portions of
the turbine building, each reactor building and outside
areas
were visited.
Observations
included valve positions
and
system
alignment;
and
hanger
conditions;
containment
isolation alignments;
instrument
readings;
housekeeping;
proper
power supply
and
breaker
alignments;
radiation
area
controls;
tag controls
on equipment;
work activities in progress;
radiation
protection
controls
adequate;
vitaR
area controls;
personnel
search
and
escort;
and vehicle search
and escort.
Informal discussions
were held with
selected
plant
personnel
in their functional
areas
during these
tours.
Weekly verifications of system status
which included major flow path valve
alignment,
instrument
alignment,
and
switch
position
alignments
were
performed
on the primary containment
purge
system
and the circulating water
vacuum breaking
system.
A complete
walkdown of the accessible
portions of the primary containment
purge
system
and circulating water
vacuum breaking
system
was conducted
to
verify system operability.
Typical of- the items checked during the walkdown-
were: lineup procedures
match plant drawings
and the as-built configuration,
hangars
and
supports
housekeeping
adequate,
electrical
panel
interior conditions, calibration
dates
appropriate,
system
instrumentation
on-l.ine, valve position alignment correct,
valves locked
as appropriate
and
system indicators functioning properly.
a ~
Drywell Leak Detection
System
During
a routine tour of the unit three control
room on September
4,
1985, the inspector questioned
why both the drywell equipment
and floor
drain
sump level
abnormal
were illuminated.
The system is
setup with high-high, high, low, and
low-low trip points.
The
pumps cycle
between
the high
and
low points,
and the annunciator
is
actuated
by the high-high or low-low.
If the
system is operating
normal,
the annunciator
should not
be received
unless
a
problem
has
occurred with the
sump level.
The operator stated
the
sump levels were low which had been verified by
local
level transmitters.
Proper
operation
of the
pumps
and
was
understood.
One possible, explanation
for why the
drywell equipment drain
sump level abnormal
had alarmed
was
that the
pump had been manually cycled to try to stop
a continuous
upward drift of the
flow integrator.
Three
maintenance
request
stickers
were attached
to the integrator.
Although the integrator
was
providing
a meaningless
reading,
log readings
were still being taken
and
an average
value of greater
than
10 gallons per minute leakage
had
been
logged for several
days.
No leakage
was
suspected
for the plant
condition of cold shutdown.
The operator stated
the log readings
were
still being taken in hopes that
some action would be taken to correct
the equipment
problems.
The plant superintendent
for operations
was
informed of the inspector
concerns
in this area.
Purge
System
During
a
walkdown of the
primary
containment
purge
system
on
September
12, 1985, the following deficiencies
were noted:
(1)
The charcoal
bed
heaters
on
each unit were
turned off for no
apparent
reason.
(2)
The high efficiency particulate filters were apparently installed
in the wrong units.
Each filter has
a manufacturer identification
label
which includes
the unit designation.
The unit designated
for unit one
was
found in unit three, unit two in unit one,
and
unit three in unit two.
(3)
The cover for unit two charcoal
bed temperature
sensor
(TI-64-125)
was missing.
(4)
The foundation bolts for unit two were found not secured.
These
concerns
were discussed
with plant
management
in
a meeting
on
September
12,
1985.
A review of the training departments
lesson
plan
(Lesson
Plan
16,
Primary
and
Seconda+
Containment
Systems)
found
little information concerning
the system.
The plan merely stated
the
system's
purpose
and
referenced
the plant operating
instructions.
Further review found that the charcoal
heaters
were not addressed
in
any plant operating instruction.
The charcoal
bed heaters
remove
any
accumulation of moisture to prevent degradation
of the system's
iodide
removal capability.
The iodide removal. efficiency for the charcoal
bed
is addressed
in Technical Specification 3.7.F.2.6.
Failure to have
a
procedure for operation of the containment
purge
system
charcoal
bed
heaters
is
a violation of 10 CFR 50 Appendix B, Criterion 5. (259, 260,
296/85-45-01).
This violation is similar to
a violation in last
month's report concerning
the standby
gas treatment
system charcoal
bed
heaters
(85-39).
The violation was
discussed
in an exit meeting
on
September
20, 1985, with plant management.
Vacuum Breaking System
The inspectors
performed
a walkdown
on the accessible
portions of the
Vacuum Breaking
System
(VBS) associated
with the Condenser Circulating
Mater System.
The
VBS is described
in Section 11.6.4 of the
FSAR as
a
redundant,
seismic
Class
I engineered
safeguard.
The
VBS pipe building
is located
outside
the protected
area.
The building is below grade
with an earth backfill over the top of the building.
Access is through
an unsecured
manhole.
The material condition was found to be generally
poor with an excessive
amount of dirt and cobwebs.
Rags,
old pressure
and various
other
loose
equipment
were laying about.
Three
(1-27-886,
2-27-886,
and 3-27-886)
were found removed
from
the
system
and
blank flanges
were installed in their place.
These
valves
were
removed
as part of
ECN L2002 performed in July 1978.
As
constructed
plant drawings
Rev.
A) had not been
updated to
show the
removal
of the valves.
This work was closed
out without
proper verification of drawing revision.
This is
a violation of
Appendix
B, Criterion VI.
(259,260,296/85-45-02).
The
following additional
concerns
were identified and will be tracked
as
an
unresolved
item
pending
evaluation
by
the
licensee.
(259,260,
296/85-45-03):
(1)
Critical System
and
Components List (CSSC).
(2)
Installed
instrumentation
is
not
on
a
program for periodic
functional
and calibration testing.
(3)
The operator
training
plan
does
not identify the
as
an
engineered
safeguard
and treats
the
basis for the
system
in
a
superficial
manner.
(4)
Radiological
Emergency
Procedures
(REP)
Implementing
Procedure,
IP-24,
Emergency
Procedure
identifies the location of
Breaker
1427
(power supply for the vacuum breaker valves)
as being
panel
14 of Battery Board 2.
Breaker
1427 is actually located
on
the Plant Non-Preferred
AC Panel
Board.
(5)
Although OI-27C, Condenser
refers to the
Radiological
Emergency
Plan Implementing Procedures
for actions in
the event of
a breach of Wheeler
Dam,
no Implementing
Procedure
exists for'this situation.
6.
Maintenance
Observation
(62703)
Plant
maintenance
activities
of selected
safety-related
systems
and
components
were observed/reviewed
to ascertain
that they were conducted
in
accordance
with requirements.
The following items were considered
during
this review:
the limiting conditions for operations
were met; activities
were
accomplished
using
approved
procedures;
functional
testing
and/or
calibrations
were
performed prior to returning
components
or system
to
service;
quality
control
records
were
maintained;
activities
were
accomplished
by qualified personnel;
parts
and materials
used
were properly
certified; proper
tagout
clearance
procedures
were
adhered
to; Technical
Specification
adherence;
and radiological
controls
were
implemented
as
required.
Maintenance
requests
were reviewed to determine
status
of outstanding
jobs
and
to
assure
that priority was
assigned
to safety-related
equipment
maintenance
which might affect plant safety.
The inspectors
observed
the
below listed maintenance activities during this report period:
a.
MMI-29, RHRSW
Pump Maintenance
b.
Vacuum breaking
system
and off-gas building inspections
c.
Refuel floor activities
d.
MG Set Maintenance
Requests
e.
Fuse
Problems
During
a review of recent
maintenance
requests
related to the
MG sets,
numerous
requests
were written concerning
incorrect
fuse installations.
Further
inspections
in this
area
revealed
that
a
program for fuse
identification resulting
from
a previous violation (260/83-27-08),
where
several
control circuit
fuses
were
found incorrectly installed,
had
identified significant problems
in this area.
The inspector
thought that
all the fuse problems
had
been corrected
and the fuse identification program
was
a program consisting of operator training and labeling. of fuse holders.
Upon learning of the
magnitude
of the
problem the inspector told plant
management
on September
17,
1985 these
problems
needed
to be evaluated for
reportability.
Although all three units have not been operating since March
1985,
some of these
problems
were identified by the licensee while the units
were operating.
The following Table lists the
number of problems
found
during the labeling program:
Common
S stem
Unit
I
Unit
Ij
Unit
rrr
Fuse
Sets
Labeled
1340
No Fuse 'Block Found
12
Breaker Installed - No Fuse Block
0
Panel
Not Installed
9
Fuse Block Size - Incorrect
21
1970
5
2
6
5
2922
3411
13
33
6
2
12
4
8
6
Total
Number
Fuse
Sets
Percent
Complete
Requires
Maintenance
Request
Written
1382
44
688
1988
65
372
2961
3456
99
100
757
237
Requires
Design
Change
Request
Correction
42
25
38
154
Fifty percent
of the
maintenance
requests
written were
estimated
for
enhancement
items
and were not actual
problems.
The problems
were varied
and in all types of systems.
This area will remain unresolved for further
evaluation
(259,260,296/85-45-04).
a ~
Failure of a Diesel
Generator to Start
On August 27,
1985,
the licensee
made
a 4-hour report regarding
the
failure of the Units
1 and
2 (shared)
B Diesel
Generator
(hereinafter
referred to as the
1
B D/G) to start when required.
The residents
were
kept informed in
a general
way
on the status
of the troubleshooting
efforts
on
a daily basis.
Following return of the
1
B
D/G to an
status,
the inspector weviewed the documentation
to determine
the initial failure indications,
root cause,
corrective action,
and
post-maintenance
testing.
The documentation
was inadequate
to support
the root cause
determination,
troubleshooting efforts,
and corrective
action
taken.
Interviews with operations
and maintenance
personnel
were initiated
to
supplement
the
documentation.
The following
Chronology
describes
the maintenance
efforts
from various
logs'nd'nterviews:
Aug. 27,
1985
1430
Commenced
SI 4.9.A.1.a,
Diesel
Generator
Monthly"Test,
on
1
B Diesel
Generator.
It is=
- not
known if this was
a routine surveillance
or done,
due to
a problem noted during per-
formance
of
SI 4.9.A.3.a,
Common
Accident
Signal Logic Test (fuel pressure
problems).
1545
Licensee
Reportable
Event Determination
(LRED)
gives this
as
the
Event
Time
and Discovery
Time.
1
B D/G failed to start
when given
an
auto start signal during the performance of Sl
4.9.A.l.a.
NOTE:,
A copy of this SI 4.9.A.l.a cannot
be located;
no more details
on the failure of
1
B D/G are
known.
1600
1930
2030
1
B
D/G declared
in
operators'ogs.
4-hour
ENS call-in made at 1744.
Running
1
B D/G, fuel filters appear
to need
changing - MR'd.
After running
1
B D/G which started
OK on slow
start, fuel oil system
8
1 pressure
was 0 when
diesel
was at idle speed; will try to change
filters.
Aug. 28,
1985
0105
SI 4.9.A.l.a in progress
on
1
B D/G.
0140
Stopped
1
B D/6 due to leak in fuel filter.
0145
SI 4.9.A.l.a
in progress
on
1
B
D/G blew
on fuel oil strainer.
DG shutdown.
NOTE:
A copy of this
SI 4.9.A. l.a cannot
be located;
interviews
indicated that the fuel filters were
changed
(although
no
MR has
been
located)
and that an "0" ring on the fuel filter cap retaining bolt was
either not reinstalled
or pinched
during assembly
since this
was the
source of the fuel leak.
0500
1
B D/G still inoperable,
will not idle at
450
RPM,
appears
not to
be getting
enough
fuel.
Starts to shutdown.
0820
1140
Started
SI 4.9.A.l.a on
1
B D/G.
SI 4.9.A. l.a
on
1
B D/G complete but D/G will
not start
on ¹
1 air start motor.
NOTE:
The
SI cover
sheet
indicates
that
the
reason
this
was
performed
was that it was required
by the routine schedule
(a monthly
surveillance)
and
that
the
acceptance
criteria
was satisfied.
Remarks
section
indicates
that the
D/G did not start
on the ¹
1 air
start motor and that
MR A 571512
was written to investigate.
An entry
was
made
on September
3,
1985 in the
remarks
section that
MR A 588874
was generated for additional work.
MR A 571512 - Work instructions
were to change
governor oil, replace
fuel filter retaining
nut gasket
and
inspect
the
engine air box.
Sample of old governor oil to be submitted to chemistry laboratory
(This
MR written
on August 28,
1985
and
completed
on September
29,
1985).
MR A 588874 - Work instructions
were to remove starting air motors to
be cleaned.
Replace after cleaning.
(This
MR written on August 29,
1985 and completed
on August 29, 1985).
NOTE:
Neither
MR satisfactorily documents
what conditions
were found
but interviews indicate that
no abnormal
conditions
were found and
no
cause for the previous
problems
could be determined.
Aug. 29,
1985
0735
Approved
MR to work
1
B D/G to change
out
governor oil.
1200
1458
Started
SI 4.9.A. l.a on
1
B D/G.
Completed
SI 4.9.A. l.a on
1
B D/G.
10
1500
1
8 D/G declared
This
breakdown
in corrective
action is
a violation of
Appendix 8, Criterion XVI which requires strict control, documentation
and
reporting
of significant
conditions
adverse
to
quality
(259,260,296/85-45-05).
Browns
Ferry
Standard
Practice
1.3,
Definitions, describes
a significant condition adverse
to guality as
(in part)
any condition which is reportable
to the
NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />
or within 30 days.
This condition
was
reported
as required
by the
4-hour reporting requirement of 10 CFR 50.72
on August 27,
1985.
The lost Surveillance Instruction test
data for SI 4.9.A. l.a which was
performed at
1430
on August 27; 1985
and again at 0105
on August 28,
1985 is
a violation for failure to adhere
to Standard
Practice
17.9,
Surveillance
Requirement
Program (259,260,296/85-45-01).
This Standard
Practice
requires
surveillance
instruction test data to be maintained
as
a quality assurance
record with a lifetime retention period.
RHRSW Relay Wiring
While observing
the
Suction pit cleaning
in progress
on
September
5,
1985,
the inspector
noted
the clearance
tag for the
B2
pump local control switch
was not attached
to the control switch"-
but was laying on
a workbench nearby.
Plant operations
personnel
were
informed of this discrepancy.
On September.10,
1985,
the inspector
once again toured the
RHRSW building and discovered that clearance
tags
for both
the
Cl and
C3
pump local control
switches
were not
attached
but were
found
on the
ground- in the vicinity of the
pump
motors.
The plant
manager
was
informed of the continuing lack of
control of clearance
tags
on control switches.
This deficiency will be
tracked
as
an inspector follow-up item for control of clearance
tags
on
local control switches
(259,260,296/85-45-06).
,1
Diesel
Generator
Maintenance
The licensee identified as part of their system operational
readiness
review that procedures
had not
been
prepared
for the standby
diesel
generators
scheduled
maintenance
as
recommended
by the manufacturer for
the six and twelve year intervals.
Procedures
were in place for the
annual
arRf three year inspections.
Technical Specification 4.9.A. l.d
requires
that
each
diesel, generator
be given
an annual
inspection in
accordance
with instructions
based
on the manufacturer's
recommen-
dations.
The manufacturer's
recommendations
of scheduled
maintenance
is given in Electro-Motive Division Maintenance
Instruction
(M.I. 1742)
for 999 system generating
plants.
The li'censee
performs Surveillance
Instruction'SI)
4.9.A. l.d
which
is
implemented
by
Mechanical
Maintenance
Instruction
MMI-6 and Electrical
Maintenance
Instruction
EMI-3 to comply with technical specifications.
11
The inspector
asked
to review. the licensee
event report
(LER) for this
discovery which occurred
on August 14, 1985,
on September
19,
1985, but
was told the
LER was still in draft form.
The
LER was being generated
for "informational purposes
only" and the 30 day reporting requirement
was not applicable.
This was questioned
as
a previous violation had
been
issued
concerning
diesel
maintenance
(259,260,296/84-23-02)
and
the inspections
were required
by technical specifications.
A review of the
licensee's
response
to
the
previous
violation
(84-23-02)
found that the licensee
stated that MMI-6 would be revised
to
include
the
maintenance
recommendations
made
Division's
M.I. 1742,
Revision
E.
Full compliance
was to be achieved
October
5,
1984
when
MMI-6 was- revised to include the manufacturer's
recommendations.
A review of MMI-6 found that the
procedure
was
revised
not
on October 5,
but
on October 23,
1984,
to include the
recommendations.
The procedure
only included revisions
to the annual
and three year requirements.
Once the procedure
was
implemented
the
three year inspection
was not performed
and
has not been
performed for
any unit as of the date of this inspection.
The inspector
reviewed the package for preparation of the
LER and found
the following statement:
"Sequoyah
and Watts
Bar do not follow EMD's recommendations
word
for word,
but
have
used their judgement
to either eliminate,
reschedule
or modify EMD's program."
Not following the manufacturer's
recommendations
may be
a potentially
generic
problem at all
TVA sites.
According to the evaluation in the
LER package
by the cognizant
engineer
there
was
no justification for
deviation
from the
maintenance
schedule
for
some
items
based
on
conversations
with the vendor.
Listed as
most important
was the six
year replacement
of cylinder head
grommets, inlet and outlet seals
and
lower line seals.
The diesel
cooling water is maintained
heated for an
automatic start
and water continually flows by 'the seals
by natural
circulation.
A failure of the seals
could result in cooling water
entering
the piston cylinder area or the lubricating oil resulting in
failure of the engine.
Sufficient replacement
parts
were not available
to work even
one diesel.
Starting in 1972 for the units
one
and
two
diesels,
<he six year
items
are
over
seven
years
past
due
and since
1976
the
items
are
three
years
past
due
on unit three.
Other
maintenance
requirements
were additionally not completed
and are being
evaluated
by the licensee.
Additionally, some items
on the scheduled
maintenance
would normally be
performed
by the electrical
maintenance
section but a review found none
of the six year
items
were
being
performed.
Also, the electrical
section did not have the current revision of the vendor's
recommended
maintenance.
They
had
M.I.
1742 (original issue)
dated
August
1970.
12
This was part of the root cause for the previous violation 84-23-02
and
resulted
in the licensee
establishing
a vendor
manual
control
system.
A review of the vendor
manual
control
system
found that the diesel
manual
was not controlled
as yet but was
on
a priority list for later
control.
The
manual
assembled
to be established
as the control
copy
contained
not only M.I.
1742 dated
August
1970,
but also
M.I.'742,
revision
D dated April 1975.
The Mechanical
Maintenance
section
was
the only one which possessed
revision
E dated
June
1976.
Although the
vendor
manual
was not controlled
as yet, it is reasonable
to expect
that all sections
would be using revision
E since this was mentioned in
the licensee's
response
to violation 84-23-02 nearly
a year
ago.
The
root
cause
and corrective
action
to violation 84-23-02
were only
superficially
corrected.
This
is
in violation of
Appendix 8, Criterion
XVI which requires
that
measures
shall
be
established
to assure
that conditions
adverse
to quality
such
as
failures,
malfunctions
and deficiencies
are
promptly identified
and
corrected.
In the .case of significant conditions
adverse
to quality,
the measures
shall
assure
that the cause of the condition is determined
and corrective
action
taken
to preclude repetition.
The licensee
failed
to
take
corrective
action
to
preclude
repetition
of
a
significant condition
adverse
to quality.
This is identified
as
Violation Item (259,260,296/85-45-08).
Also,
a review of the Final Safety Analysis Report
(FSAR) section 8.5,
Standby
A-C Power
Supply
and Distribution, found that section 8.5.5,
Inspection
and Testing,
addressed
the maintenance
on the diesels.
page 8.5-19 states
that scheduled
maintenance
on the diesel
generators
is conducted
in accordance
with the manufacturer's
recommendations.
The licensee
reported
on September
24,
1985 that all the diesels
were
technically inoperable
since
the vendor required
inspections
for the
three,
six,
and
twelve year intervals
had not
been
performed.
The
diesels
would, however,
be maintained
in a standby
readiness
condition.
Simultaneously,
the diesels
were reported
because
the diesel
battery
racks
were determined
to
be not seismically qualified.
This
was the subject of a previous violation (259,260,296/85-28-05)
in April
1985.
During correction of the April problem four studs
broke which
were welded to an
embedded
metal plate in the concrete
foundation.
The
battery
racks
are
secured
to the floor using
the studs.
The stud
material
was given
a metallurgical
evaluation
and found not acceptable
for welding.
The steel
contained
too high
a carbon content
and
upon
welding would
become brittle.
The studs
have
been installed for a
number of years
and the source of the error was
unknown.
The licensee
plans to systematically
repair
the diesel
battery rack
as quickly as
possible.
The inspector questioned
the timing of the information.
The
plant manager
reviewed the
sequence
of events with the inspector.
It
was stated
the first time the evaluation information was discussed
with
the plant
was
on September
20,
1985.
However, this
was
done
on the
13
telephone
and the information not understood fully.
The metallurgical
evaluation
was transmitted to the plant on September
24,
1985.
This is
the
second
example of violation 259,260,296/85-45-08
above,
in that
this condition was not promptly identified and corrected.
As
a result of the diesel
generators
being inoperable the licensee
was
unable
to meet three technical
specification
requirements.
These
are
summarized
as follows:
(1)
T.S.
3.9.C.1
requires
that
whenever
the
reactor
is in cold
shutdown with irradiated fuel in the reactor,
at least
two diesel
generators
shall
be operable.
This was not met for Units
1 and 3.
(2)
T.S.
3.5.A.4 requires
core
spray
pumps
and associated
diesel
generators.
This
was
not
met for Unit three
with
irradiated fuel in the vessel
and the vessel
head installed.
(3)
T.S.
3.5.8.9
requires
residual
heat
removal
pumps
and
associated
diesel
generators.
This
was not met for Unit three
with irradiated fuel in the vessel
and the vessel
head installed.
The licensee
initiated
a safety evaluation
to analyze
the unanalyzed
condition of the plant.
As a compensatory
measure
primary containmen't
was reestablished
on Unit three.
Additionally, all fuel
movement
was
suspended
due to timing problems
with some ventilation dampers.
FSAR section 5.3.4.2
discusses
a time
requirement of 2 seconds for the dampers.
The licensee
discovered that
some solenoid operated ventilation dampers
had not been given
a post maintenance
timing test after installation of
new solenoids for environmental
qualification purposes.
The timing in
question related to a fuel handling accident.
7.
Surveillance Testing Observation
(61726)
The
inspectors
observed
and/or
reviewed
the
below listed surveillance
procedures.
The inspection
consisted
of
a review of the
procedures
for
technical
adequacy,
conformance
to technical
specifications,
verification
of test
instrament
calibration,
observation
on the conduct of the test,
removal
from service
and return to service of the system,
a review of test
data,
limiting condition for operation
met,
testing
accomplished
by
qualified personnel,
and that the surveillance
was completed at the required
frequency.
a.
S. I. 4.9.A.3.A,
Common Accident Signal
Logic Test.
b.
S.I. 4.9.A.1.D, Diesel
Generator
Annual Inspection.
14
,
8
On August 28,
1985, while performing SI 4.9.A.3.A,
Common Accident Signal
Logic Test
on Unit 3, the licensee
discovered
that the Bl
RHRSW pump
was
for
EECW service
since it failed to start
upon
an automatic
starting signal.
Subsequent
troubleshooting
by the licensee
discovered
a
wiring error associated
with time delay relay
TD2C in the Bl pump starting
circuitry.
This condition 'is believed to have
been in existence
since the
last surveillance test
was
performed
on the
RHRSW timers
on April 26,
1985.
A review of documentation
associated
with this event
indicated
that
a
similar time delay relay had failed in April 1985
on Unit 1 and was replaced
on April 26,
1985.
Maintenance
Request
(MR) A-170596 was written to verify
proper operation of the relay following the replacement.
This
MR contains
detailed step-by-step
work instructions with a temporary jumper installation
and independent verification sign-off steps.
Normally, MRs should refer to
reviewed
instructions
to assure
procedural
controls
are maintained.
Standard
Practice 7.6, Maintenance
Request
and Tracking, requires that
CSSC
MRs that
have
no
PORC reviewed instruction
and are
beyond the skill of the
craft shall
be sent to
PORC for review and to the plant superintendent
for
approval.
MR A-170596 was not reviewed
and approved
as required.
This is
a
violation for failure to adhere
to written instructions.
(259,260,296/85-45-01).
Reportable
Occurrences
(90712,
92700)
The below listed licensee
events
reports
(LERs) were reviewed to determine
if the
information
provided
met
NRC requirements.
The
determination
included:
adequacy
of event description, verification of compliance with
technical
specifications
and regulatory
requirements,
corrective
action
taken,
existence
of potential
generic
problems,
reporting
requirements
satisfied,
and
the relative safety significance of each
event.
Additional
in-plant reviews
and discussion
with plant personnel,
as appropriate,
were
conducted
for those reports indicated
by an asterisk.
The following licensee
event reports
are closed:
LER No.
- 260/85-05
- 260/85-06
Date
June
11,
1985
June
20,
1985
Event
Reactor Water Cleanup Isolation.
Secondary
Containment Isolation
Initiated from Refuel
Zone Radiation
Detector
- 260/85-09
- 260/85-08
- 259/85-10
July 12,
1985
July ll, 1985
April 03,
1985
Containment Isolation
Because of
Improper Transfer
Reactor Water Cleanup Isolation
Because of Improper Transfer
Discontinuance of CAM Hourly
Sampling
Due to Personnel
Error.
Regulatory
Performance
Improvement
Program
(RPIP)
The responsible
section chief reviewed the status of RPIP and actions
taken
by TVA to implement specific items
as required
by
NRC Confirmatory Order
84-34
dated
July
13,
1984.
TVA has
assigned
a senior
manager
as
RPIP
Coordinator at the site.
His responsibilities
include verifying that each
task
has
been
implemented
as described,
has
met objectives,
and that the
necessary
programs
are in place to insure that objectives will continue to
be met.
Host of the short term items
have
been indicated
as complete,
but
have
not
been
signed off as
completed
by the
RPIP Coordinator.
The
inspectors
,reviewed
implementation
of Short
Term Action
Item 4.11,
Establishment
of the Independent
Safety Engineering
Group
( ISEG)
and found
that contrary to the indicated status
on the RPIP, the
ISEG did not exist.
Follow-up discussions
with licensee
representative
led to a concern that the
proposed
ISEG functions
and responsibilities
did not satisfy the discussion
in NUREG-0737 regarding
ISEG.
Although the plant is not committed to this
THI action item, it was
expected
that the guidance
contained
in NUREG-0737
would be followed in the implementation of this
RPIP action item.
This item
will continue to be tracked
under the
RPIP program.
Long
Term
Item 9.7, Utilize outside
contractor
to evaluate
Technical
Specifications
was
reviewed.
The contractor's
report dated
September
27,
1984
was
reviewed
and
actions
initiated
by the
licensee
to resolve
identified technical
specification discrepancies
were followed up to verify
initiation of necessary
corrective action.
Refueling Activities (60710)
The inspector
observed activities associated
with fuel off-loading on Unit I
and
verified
that
technical
specification
requirements
related
to
containment
integrity,
neutron
monitoring instrumentation,
control
rods,
refueling interlocks,
and staffing were being satisfied.
An inspection of the Reactor
Protection
System Trip Panels
(panels 9-15 and
9-17)
was
performed to verify removal of SRH Shorting links per GOI-100-3,
Refueling Operations,
Step
B. l.p.
The inspector verified that the. links
were
removed
as required;
however,
several
apparent
discrepancies
regarding
the internal wiring of the
panels
prompted
a detailed
inspection.
The
as-constructed
drawing for panel 9-17
was obtained
(Drawing 791E247-2A)
and
the following problems
were identified on the Unit I panels:
a ~
The metallic jumper link connecting
terminals
79
and
80 of terminal
board
CC on panel 9-17
was not secured with terminal
screws.
The link
was merely resting
on the terminals
and the integrity of the electrical
connection
could
not
be
determined.
Plant
personnel
immediately
installed
appropriate
screws
when
informed.
This link was
in the
control rod timing test circuitry and was believed to have
no effect on
the
Reactor
Protection
System
(RPS)
should it have fallen off the
terminals.
16
b.
The insulation
on several
wires adjacent
to fuses '22, 23,
and
24
on
terminal
board
BB of panel 9-17 was discolored
from a previous overload
condition.
c.
On panels 9-15
and
9-17
diodes
CR2B
and
CR2O
were
observed
to
be
supported
only by the attached
wires
and were dangling, loose,
from the
plastic wire ways from which the wires emerged.
d.
The main
power supply wire from terminal
2 of the
NG set breaker
(CBIB) to terminal
1 of the hot bus
(CR) which supplies
power to all of
the
components
shows
evidence
of an overloaded
condition.
The jacket is cracked,
discolored
and
sections
of the jacket
are
missing.
The cable insulation is also cracked in several
locations.
e.
The fire proof metallic enclosures
which house
fuses
F12,
F13, F16,
and
F17 in panel 9-17
had lost their fire proof integrity.
The hinged
enclosure
cover
plate
was
not
secured
to the
enclosure
with the
required
wing nuts
and
as
a result
a one-half inch opening to.the
enclosure
was observed.
e
f.
The one-half inch flex conduit from the fire proof metallic enclosures
housing fuses
F12,
F13,
F16,
and
F17 in panel 9-17 terminated
about
one
inch from the enclosure
and the w'ires emerged into an adjacent wire was
for a distance
up to 3 feet before the wires exited the bundle
and were
terminated
on terminal
block
CC.
Orawing
791E247-2A requires
the
conduit carrying these
wires to be'terminated
as close
as possible to
the terminal block.
g.
The wires
shown
on Orawing 791E247-2A from terminal
3 of fuse
F13 to
terminal
3 of fuse
F27 and from terminal
3 of fuse
F17 to terminal
3 of
fuse
F25 were not installed in panel 9-17.
Items a,
e, f and
g are
examples
of a violation for failure to have
equipment installed
per approved
plant drawings.
(259,
260, 296/85-
45-01).
Items b, c,
and
d will be further evaluated
by the licensee
and left as
an unresolved
item until evaluation
completion.
(259,
260, 296/85-45-07).
~
~