ML20133C406

Insp Repts 50-327/85-27 & 50-328/85-28 on 850806-0905. Violations Noted:Failure to Follow Procedure During Surveillance Testing of Emergency Diesel Generator & Failure to Adequately Perform NDE

ML20133C406
Person / Time
Site:	Sequoyah
Issue date:	09/27/1985
From:	Ignatonis A, Jenison K, Linda Watson, Weise S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20133C354	List: IR 05000806/2009005 ML20133C351 ML20133C406
References
50-327-85-27, 50-328-85-28, NUDOCS 8510070343
Download: ML20133C406 (18)

See also: IR 05000327/1985027

Text

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UNITED STATES

[ W Ero o NUCLEAR REGULATORY COMMISSION

-[" " ,$ REGloN 11

< j 101 MARIETTA STREET.N.W.

• 2 ATLANTA, GEORGI A 30323

%...../

Report Nos.: 50-327/85-27, 50-328/85-28

Licensee: Tennessee Valley Authority

500A Chestnut Street

Chattanooga, TN 37401

Docket Nos.: 50-327 and 50-328 License Nos.: DPR-77 and DPR-79

Facility Name: Sequoyah Units 1 and 2

Inspection Conducted: August 6 - September 5, 1985

Inspectors: 0 A < 6!-,Tm ~

f/2 7/B5

K.M.Je(1 son,',5en'iorResidentInspector Dat6 Sigiled

GA n/L Jza,

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9h7/Bs'

L. J. Wat(icn,'R4sfdent Inspector Dat6 Sig/ied

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9h7/45

pA.Ignatoni(s',PrpctInspector

,

Dafs Signed

Approved by: .  ! '

M

S. P. Weise, S'6ction Chief Date Signed

Division of Reactor Projects

SUMMARY

Scope: This routine, announced inspection involved 286 resident inspector-hours

onsite in the areas of operational safety verification including operations

performance, system lineups, radiation protection, securit/ and housekeeping

inspections; surveillance and maintenance observations; review of previous

inspection findings; followup of reportable events; review of inspector followup

items and licensee identified items; and followup of licensee's response to NRC

Order EA 85-49.

Results: In the areas inspected, three violations were identified:

'1) Failure to follow procedure during surveillance testing of an Emergency

Diesel Generator (EDG). This applies to both units.

~(paragraph 6a).

2) Failure to adequately perform a non-destructive examination. This

applies to Unit 1 only. (paragraph 10a).

3) Failure to comply with Technical Specification Limiting Condition for

Operation (LCO) 3.5.1.1. This applies to Unit 2 only. (paragraph 10c)

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REPORT DETAILS

1. Licensee Employees

Persons Contacted

H. L. Abercrombie, Site Director

• P. R. Wallace, Plant Manager

• L. M. Nobles, Operations and Engineering Superintendent

• B. M. Patterson, Maintenance Superintendent

J. A. Domer, Chief, Nuclear Licensing Branch

G. Brantley, Nuclear Safety Review Staff

• M. A. Skarzinski, Electcical Maintenance Supervisor

• M. R. Harding, Engineering Group Supervisor

• J. M. Anthony, Operations Group Supervisor

• D. C. Craven, Quality Assurance Supervisor

D. E. Crawley, Health Physics Supervisor

J. L. Hamilton, Quality Engineering Supervisor

• G. B. Kirk, Compl'iance Supervisor

• W. L. Williams, Chemical Unit Supervisor

• D. F. Goetches, Codes and Standards Supervisor

• R. C. Burchell, Compliance Engineer

• R. L. Moore, SQN Plant Evaluation Group Manager, Division of QA

• C. Wilson, Nuclear Engineer, NSS

Other licensee employees contacted included technicians, operators, shift

engineers, security force members, engineers and maintenance personnel.

• Attended exit interview

2. Exit Interview

The inspection scope and findings were summarized with the Plant Manager and

members of his staff on September 6, 1985. Violations described in

paragraphs 6 and 10 were discussed. The licensee acknowledged the

inspection findings. The licensee did not identify as proprietary any

material reviewed by the inspectors during this inspection. During the

reporting period, frequent discussions were held with the Site Director,

Plant Manager and his assistants concerning inspection findings. The

licensee committed to require technicians to place their initials in signoff

spaces in Maintenance Instruction MI-10.1, Diesel Generator Inspection,

rather than allow the use of checks or other marks. At no time during the

inspection was written material provided to the licensee by the inspector.

3. Licensee Action on Previous Inspection Findings (92702, 61726, 62703)

(Closed) Violation (327/83-31-02). The licensee's response of March 15, 1984

was reviewed, and the indicated corrective actions were audited. The

corrective actions stipulated were to remove the licensed operator from

licensed duties and evaluate his performance, and to retrain all Operations

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personnel in adninistrative controls associated with system alignment and

operation. These licensee actions are considered complete and adequate.

(Closed) Violation (327,328/84-27-01). The licensee's response of

December 13, 1984 was reviewed, and the indicated corrective actions were

audited. The corrective actions stipulated were to repair the damaged

conduit associated with the Upper Head Injection system, to cancel all

drilling permits that were outstanding and to revise Administrative

Instruction AI-17, Drilling, Cutting, Chipping and Excavation. In addition,

three conductance type power interruption devices were purchased and

prescribed for use when applicable drawings are not clear about the location

of embedded electrical conduit. The licensee's actions are considered

complete in this instance; however, the inspector noted that AI-17 does not

require the use of the power interruption devices in all cases.

(Closed) Violation (327/84-24-01). This violation concerned several

examples of failure to establish or implement adequate procedures. The

licensee responded to the violation in letters dated June 6 and July 22,

1985. The inspector reviewed the responses and the following procedures and

held discussions with cognizant licensee personnel:

Maintenance Instruction MI-1.9, Revision 6, Bottom Mounted Instrument

Thimble Tube Retraction and Reinsertion. ,

Administrative Instruction AI-8, Revision 14, Access to Containment

Quality Assurance Section Instruction Letter 5.3, Revision 11 Radiation

Work Permit 02-1-85-110

The licensee has cancelled the original maintenance procedures, MI-0-94-1

and -2. A review of MI-1.9 identified several deficiencies with respect to

unincorporated vendor recommendations for inspection and measurement of

components during high pressure seal reassembly. Licensee personnel

provided a draft revision which was awaiting approval . This revision

incorporated the vendor recommendations. These revisions are to be in place

prior to thimble cleaning activities during the Unit 1 refueling outage.

Other revisions to procedures appeared adequate. The inspector reviewed the

list. of quality assurance reviewers authorized to review maintenance

requests and the documented training held. No discrepancies were

identified. A sample of active hold orders was also reviewed to determine

if hold orders were being issued to personnel responsible for maintenance

activities. No discrepancies were identified, and licensee corrective

actions were complete with the exception of the revisions to MI 1.9. These

are being tracked under IFI 327/84-24-04.

(Closed) Violation (327/84-24-02). This violation concerned onsite review

committee reviews. The inspector reviewed licensee responses dated June 6

and July 22, 1985 and onsite review committee meeting minutes 3415-3429.

Licensee management reviewed the requirements for onsite reviews as

delineated in Technical Specifications and procedure SQA-21. No

discrepancies were identified, and licensee corrective actions appeared

complete.

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(Closed) Violation (327/84-24-03). This violation concerned use of a

modified cleaning tool and lack of appropriate controls. The inspector

reviewed licensee responses dated June 6 and July 22, 1985. The licensee

has implemented a new cleaning method which is to be used only in Modes 5 or

6. The inspector reviewed procedure SQM-63, Special or Modified Tooling,

Revision 0 and two in progress tool evaluations. Licensee corrective

actions appeared adequate.

4. Unresolved Items

Unresolved items were not identified during this inspection.

5. Operational Safety Verification (71707)

a. Plant Tours

The inspectors observed control room operations, reviewed applicable

logs, conducted discussions with control room operators, observed shift

turnovers, and confirmed operability of instrumentation. The

inspectors verit v:d the operability of selected emergency systems,

reviewed tagout records, verified compliance with Technical Specifi-

cation (TS) Limiting Conditions for Operation (LCO) and verified return

to service of affected components. The inspe,ctor verified that

maintenance work orders had been submitted as required and that

followup activities and prioritization of work was accomplished by the

licensee.

Tours of the diesel genepator, auxiliary, control, and turbine

buildings were conducted to observe plant equipment conditions,

including potential fire hazards, fluid leaks, and excessive vibrations

and plant housekeeping / cleanliness conditions.

The inspectors walked down accessible portions of the following

safety-related systems on Units 1 and 2 to verify operability and

proper valve alignment:

Control Room Ventilation (Units 1 and 2)

Diesel Generators (Units 1 and 2)

Auxiliary Air Compressors (Units 1 and 2)

Safety Injection (Units 1 and 2)

No violations or deviations were identified.

-b. Security

During the course.of the inspection, observations relative to protected

and vital area security were made, including access controls, boundary

integrity, search, escort, and badging. No violations or deviations

were identified.

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c. Radiation Protection

The inspectors observed Health Physics (HP) practices and verified

implementation of radiation protection control. On a regular basis,

radiation work permits (RWPs) were reviewed and specific work

activities were monitored to assure the activities were being conducted

in accordance with applicable RWPs. Selected radiation protection

instruments were verified operable and calibration frequencies were

reviewed.

On September 5, 1985, the Sequoyah Nuclear Plant Health Physics

Supervisor notified the Resident Inspectors that an employee, who was a

member of the security force, had reported that he had radiation

sickness. The employee had previously been admitted to a local

hospital for an undisclosed illness and had reported back to work with

a doctor's- release for full duty. The employee was interviewed by the

licensee and returned to work. The inspectors reviewed his exposure

records and determined that his quarterly dose was 190 millirem based

on pocket chamber readings. The most recent reading of his assigned

TLD indicate'd that his exposure during the quarter had been zero. The

TLD reading, which is more accurate, is utilized as the official

exposure record. The individual's lifetime dose was also zero. NRC

Health Physics personnel were notified of this issue.

6. Monthly Surveillance Observation (61726)

The inspectors observed Technical Specification (TS) required surveillance

testing and verified that testing was performed in accordance with adequate

procedures; that test instrumentation was calibrated; that Limiting

Conditions for Operation (LCO) were met; that' test results met acceptance

criteria requirements and were reviewed by personnel other that the

individual directing the test; that any deficiencies were identified,

properly reviewed, and resolved by management personnel; and that system

restoration was adequate. For completed tests, the inspector verified that

testing frequencies were met and tests were performed by qualified

individuals.

The inspector witnessed / reviewed portions of the following surveillance test

activities:

a. Portions of the five year surveillance of the 2A-A Diesel Generator

(DG) were observed on August 14, 1985. In order to ensure that the

remaining three DGs were operable, the licensee conducted Surveillanct

Instruction SI-7, Electrical Power System Diesel Generators, on

August 13, 1985 for DGs 1A-A, IB-B, and 2B-B. The following

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Maintenance Instructions (MI), Maintenance Requests (MR), Surveillance

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Instructions (SI), and Instrument Maintenance Instructions (IMI) were

reviewed / observed in conjunction with this periodic surveillance

activity:

MI-10.1 Diesel Generator Inspection

MI-ll.4 Maintenance of CSSC Valves

MI-6.20 Configuration Control During Maintenance Activities

SI-1 Surveillance Program Units 1 and 2

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SI-7 Electrical Power System: Diesel Generators

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SI-102 Inspection of Diesel Generators

SI-170.3 Periodic Calibration of the Standby Diesel Generator

IMI-82 Standby Diesel Generator System, Appendix C

MR A525959

MR A284291

Hold Order 1529

Drawing 47W839-1

, Temporary Change 85-0828

During the performance of MI-10.1, three instances of failure to follow

procedures w'ere identified:

(1) In order to clean and visually inspect the generator, Electrical

Maintenance technicians are directed in Step 5.4.1.1 of MI-10.1 to

use low pressure air to remove dust from collector rings and

stator. There is a corresponding space on Inspection Sheet 5.4 of

Appendix A to MI-10.1 that is used to indicate completion of this

step. The inspector observed a technician, who was performing

MI-10.1, mark step 5.4.1.1 as complete without using low pressure

air to remove dust from the generator collector rings and stator.

When questioned the technician. stated that in his opinion there

was not sufficient dust on the collector rings and stator to

require the use of the air; therefore, he checked the step as

complete.

(2) Step 5.4.1.2 directs the technician to remove oil, grease, or

accumulation of dirt from the collector with clean, bound end,

lintless wiping cloths. The cloths that were used to complete

this step were of a knit material rather than bound end, lintless

wiping cloths.

(3) Step 5.4.1.8 states that frame hold down and foundation bo:ts are

to be checked to see that they are tight. This step also requires

the technician to record results and any unusual findings on

Inspection Sheet 5.4. This action was not completed by the

Electrical Maintenance technician because he stated that he felt

that the activity was a Mechanical Maintenance Section function.

Mechanical Maintenance technicians did not perform this section of

MI-10.1 and were unaware of the requirements of this step. As a

result Step 5.4.1.8 was not implemented.

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The above examples constitute a violation for failure to follow

procedure (317/85-27-01, 328/85-28-01). While the safety

significance is low, these activities indicate a disregard for

procedural compliance during the performance of a safety related

surveillance.

b. Two steps in MI-10.1 direct the technician to perform tasks and do not

give sufficient guidance to the technician in order to ensure quality.

(1) Step 5.4.1.7 requires the technician to verify that the generator

space heaters were functioning properly by raising the heater's

setpoint and checking heater operation. Additionally, Step

5.4.1.7 directs the technician to return the setpoint to its

original value upon completion. What was actually performed by

the technician was a full scale rotation of the control knob from

a starting point to zero and then to a point where the rheostatic

relay energized. After the relay energized, the knob was returned

to what was thought to be its initial starting point. The

original starting point was not prescribed in the procedure,

recorded on Inspection Sheet 5.4 as an "as found condition", or

indicated on the control knob dial face.

(2) Step 5.4.1.8 directs the technician to chegk frame hold down and

foundation bolts to see that they are tight and to record results

and any unusual findings on Inspection Sheet 5.4. The procedure

did not provide acceptance criteria with reference to bolt

tightness and did not provide a space in Inspection Sheet 5.4 on

which to note the results of the inspection conducted by the

technician.

During the performance of the above surveillance, assigned technicians

were independently conducting separate portions of.SI-102 and MI-10.1.

After the completion of each step, indications were placed on the

appropriate check sheets to validate the completion of that step. The

indications used included check marks and the statement "ok". Initials

were not used in this case and the cover sheet had not been signed

because at the time of inspection, the procedure was not fully

completed. The licensee's policy is to have the individuals who

performed the procedure to initial only the cover sheet rather than

initial each procedural step. These documents are designated as

quality records by the licensee's quality assurance program and as such

require traceability with respect to the technician that performed the

quality function. Since the procedure is performed over some time by

several technicians, there may be a problem in determining who

performed the steps. As a result, the licensee has committed to

incorporate the requirement that technicians initial steps performed in

MI-10.1 rather than use a check or some other indication. This will be

reviewed as Inspector Followup Item (327/85-27-02, 328/85-28-02). The

-licensee did not commit to require the use of initials on all MI's.

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c. The calibration of the Unit I reactor ccolant system (RCS) loop

resistance temperature detectors (RTD) by Instrument Maintenance was

observed by the inspector. The following Surveillance Instructions

were observed / reviewed:

SI-478, Response Time Testing Reactor Coolant System Narrow

Range RTD's Units 1 and 2

SI-483, Procedures for Removing a Reactor Protection Channel

from Service

The calibration of Measuring and Test Equipment (M&TE) used to perform

the calibration of RCS RTD was reviewed. Current bridges TEC LCSR

numbers USTVA 393132 and 432675 were found to be uncalibrated. These

pieces of M&TE equipment are used to generate a step function into a

second piece of calibrated M&TE which disregards the actual amplitude

of the input signal and requires only input of a step function. The

TEC LCSR equipment is functionally tested in step 5.1.2 of SI-478

against a standard decade resistance box which itself is calibrated to

National Bureau of Standards criteria. The current rating of the RTD

is well below that generated by the current bridges, and the current

output of the bridges were checked with a mirltimeter prior to

commencing the RTD calibration.

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7. Monthly Maintenance Observations (62703)

Station maintenance activities on safety-related systems and components were

observed / reviewed to ascertain that tney were conducted in accordance with

approved procedures, regulatory guides, industry codes and standards, and in

conformance with TS.

The following items were considered during this review: LCOs met while

components or systems were removed from service; redundant components

operable; approvals obtained prior to initiating the work; activities

accomplished using approved procedures and inspected as applicable;

procedures used adequate to control the activity; troubleshooting activities

controlled and the repair record accurately reflected activities functional

testing and/or calibrations performed prior to returning components or

systems to service; quality control records maintained; activities

accomplished by qualified personnel; parts and materials used properly

certified; radiological controls implemented; QC hold points established

where required and observed; fire prevention controls implemented; outside

contractor force activities controlled in accordance with the approved

Quality Assurance (QA) program; and housekeeping actively pursued.

a. Maintenance on the 28-B Centrifugal Charging Pump was reviewed and

partially observed. This maintenance involved the addition of ST0-2

oil (serial number 2-MTRA-62-108A) to the pump. Maintenance Request

(MR) A526894 was reviewed and the participating Mechanical Maintenance

Section (MM) technicians were interviewed. The MR stated only that oil

was needed and gave no further guidance.

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The two technicians involved in the maintenance stated that they had

never added oil to this pump and were not familiar with the process.

As a result of the MM technicians lack of familiarity with the process,

a Radiation Work Permit (RWP) (RWP 02-2-85734) was written which

prescribed the use of lab coats and did not authorize disassembly of

the pump. The two assigned technicians consulted a maintenance foreman

and determined that a second MR was needed for partial disassembly of

the pump in order to add oil . This action resulted in rewriting the

RWP and performance of a radiological survey of the area.

A technician, accompanied by a Quality Assurance technician, went to an

oil storage room in the turbine building to draw the oil. When the

technician attempted to transfer oil from the drum to a can, he did not

inspect the internal condition of the can for debris or other oil. The

QA inspector stated that his only function was to ensure that the MM

technician drew the correct oil. Both the technician and the QA

inspector stated that the can should be rinsed with ST0-2 oil prior to

filling it.

The licensee' considered these MM technicians to be qualified and the MR

process to be adequate despite the demonstrated difficulty with this

relatively simple process. The technicians later determined that there

was not any of the correct oil in the storage room. The inspector will

continue to evaluate the appropriateness of the licensee's position on

skill of the craft credit.

b. On August 11, 1985, the Unit 1 letdown orifices 1-62-72, 73 and 74 were

determined to be leaking. The leakage was discovered when relief valve

62-662 lifted after the -letdown orifices were isolated. Manual

isolation valves62-723 and 62-714 were closed and containment

isolation valve 62-77 was closed, tagged and the power removed.

The letdown orifice valves are Masoneillen valves with removable seats.

It was discovered that all three valves had flow induced cuts on the

seats and required repair. The following material was reviewed:

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Maintenance Request (MR) A297129, A297130, A297130

Drawing 47W809

Drawing A8424, Revision 901, Contract 68C60-91934

Maintenance Instruction MI-10.1, Diesel Generator Inspection,

Units 1 and 2

In order to ensure proper valve seating, the surface of the

corresponding disc had to be angle cut. The technicians stated that

they matched the previous angle on the disc and shaved its surface.

The angle used was thirty degrees. MI 10.1 was amended to include the

authorization for milling these valves. No technical manual was

available to the technicians, and the angle used to mill the disk had

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not been verified to be correct. This is an Inspector Followup Item

(327/85-27-03, 328/85-28-03) to evaluate the acceptability of the

milled disk.

9. Review of Licensee Event Reports (LERs), Deficiency Reports, and Special

Reports (92700)

a. The following LER's were reviewed and closed. The inspector verified

that: reporting requirements had been met; causes had been identified;

corrective actions appeared appropriate; generic applicability had been

. considered; the LER forms were complete; the licensee had reviewed the

event; no unreviewed safety questions were involved; and, violations of

regulations or Technical Speci,fication conditions had been identified.

LER's Unit 1

82024 Inoperability of the Turbine Building Sump

Monitor and Condensate Deminineralizer

,

Effluent Monitor

Subsequent LER 83058 identified the same

problem which was blocking of flow switches

due to buildup of crud and debris. Flow

switches were replaced per Work Plan No. 11068

with a new design, having a sight glass for

inspection of crud buildup and a low flow

alarm.

83018 Containment Internal Differential Pressure

Exceeded 0.3 psig Relative to Annulus Pressure

Although similar events occurred afterwards,

the causes were different. In this case the

EGTS suction damper failed to open due to a

failed latching relay. The relay was replaced

per MR No. A-106214.

83038 Potential Inoperability of~ Diesel Generators

Due to High Environmental (Outside) Temper-

ature.

83045 Steam Generator Wide Range Level Channel

Inoperable.

83094 Steam Generator No. 4 Steam Flow Indicated

Zero; Redundant Loop Indicated 106 lbs/hr.

This was reoccurrence of a previous event

described in LER 83037. Air entrainment in

sensing line was suspected. The sensing line

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was backfilled and output verified per MR

No. A-082218. No recurrence was identified.

83164 Turbine Building Liquid Effluent Line

Radiation Monitor Not Able to Clear a False

Hi-Rad Alarm Due to Arcing Contacts in Power

Relay.

83168 1A-A D/G Failed to Start.

83183 Steam Supply Valve Failed to Meet Surveillance

Requirements; Limitorque Switch Failure

84030 and Revision 1 Incore Detector Thimble Tube. Failure at High

Pressure. Connection.

LER's Unit 2

83060 Inoperable Auxiliary Feedwater (AFW) Automatic

Control Valve

Control Valve 2-LCV-3-156 failed to fully open

due to incorrectly sized metering orifice in

the pneumatic relay. There were previous

similar occurrences. A subsequent occur-

rence was reported in LER 328/03133. For

corrective action, valves on both units were

inspected and another control valve,

1-LCV-3-164, was .found to have an incorrectly

sized orifice. A safety evaluation was made

by EN DES, USQD-83-8, Rev. O, which reported

that the valve would stroke properly with

input air pressure reduced to as low as 48

psig. The 35 psig metering orifices were

replaced with the correct 60 psig orifices

ones. Also, permanent tags were mounted on

the actuators stating that a 60 psig metering

orifice should be used for replacement, and

Surveillance Instruction SI-75 was revised to

verify proper metering orifice replacement and

ensure a 60 psig supply pressure. The inspec-

tor verified implementation of the above cor-

rective actions.

83051- Steam Generator (SG) No. 2 Pressure Indicator

Failed Low

83064 AFW Automatic Valve Failed to Close on Demand

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Cause was due to a faulty circuit board in

Beckman Controller; it was replaced per

MR A-105946.

83072 SG No. 1 Remote Shutdown Pressure Indicator '

Failed High

83133 AFW Automatic Control Valve Failed to Open on

Demand

Cause was due to an incorrect air pressure

supply regulator setting. Per MR A-110425 the

air supply was adjusted to 59 psig and proper

valve operation was verified.

83003 Failure to Seal Electrical Conduit Penetrating

a Fire Barrier.

85004 Two Reactor Trips Due to Low-Low Steam

Generator Water Level

b. The following items (18 months and older) were reviewed by the

inspector and are considered closed. The corr,ective actions were

reviewed and appeared to be appropriat.e. These items were:

Unit 1

Special Report 83-03 which pertained to breached penetration fire

barriers in the auxiliary building.

Unit 2

CDR 81-05, Retrievable Information from Valve Tag Numbers

The subject deficiency involved lack of manufacturers valve data in the

li'censee's documentation systems, thereby impeding the retrieval of

pertinent engineering data used in piping analyses and other design

calculations. For corrective action the licensee revised all drawings

in series 47A365, 57A366, and 47B601 to cross reference the manu-

facturer's valve information. This was a long-term corrective action

to be completed by June 30, 1984. The' inspector reviewed the licen-

see's corrective action under Work Plan Number 10809. The inspector

reviewed a sample of revised drawings and verified implementation of

the corrective action.

CDR 81-24, Waiving Source Inspection Without Proper Authority

~ The subject deficiencies was in the control of procurement activities

program and was generically applicable to other TVA facilities. This

item wts inspected and closed for the Bellefonte and Watts Bar facilities;

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The corrective action also applies to Sequoyah facility and the item is

closed.

10. Event Followup (93702, 62703, 61726)

a. On August 11, 1985, a leak in a Chemical and Volume Control System

(CVCS)' sample line was identified by an Auxiliary Unit Operator (AV0)

during a routine walk through. A crack was discovered in the weld area

of the 3/4-inch sample line which runs off the Unit I reactor coolant

system letdown line. The unit was operating at 100% power at the time

of the discovery and continued to operate at this power level. The AVO

reported the situation to the Assistant Shift Engineer (ASE) who

directed the operators to isolate normal letdown. The leakage rate was

approximately 0.4 gallons per minute (gpm) and there was no detectable

airborne radioactivity. This event was similar to an event which

occurred on July 29, 1985 on Unit 2. The Unit 2 occurrence resulted

in a declaration of an Unusual Event by the licensee as a result of

exceeding RCS leakage limits. The Unit 2 event .is discussed in

Inspection Report 327,328/85-26.

The licensee completed weld repairs on the affected sarole lines on

both units, and pipe supports were designed and installed to prevent

recurrence of the cracking. Neither line had begn originally supported

by a pipe brace or support. As partial corrective action, the licensee

performed a structural walkdown in the accessible areas of the CVCS

on each unit to determine if there were additional unsupported lines.

Welds on these smaller lines were not examined during this walkdown.

The licensee also used low frequency accelerometers to test the main

CVCS lines for vibrations. No vibrations were identified, and no root

cause for either line's failure has been identified by the licensee.

The licensee intends to monitor this system during system operation

configuration changes in an attempt to identify a source of the

vibrations. This is Inspector Followup Item (327/85-27-05,

328/85-28-04).

The licensee shipped both failed sample lines to a ve.. dor for

metallurgical analysis. The analysis included, in part, an examination

with a standard electron microscope. The Unit 1 failure was similar to

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the previous failure on Unit 2. Both failures were gen' ated by

high-cycle, low stress fatigue originating on the outer diam er of the

schedule 40 stainless steel line in the heat affected zone of the weld.

The following material was reviewed by the inspector for Units 1

and 2. In addition, this material was reviewed by an NRC metallurgical

inspector as documented in NRC Inspection Report 327/85-29, 328/85-29.

Drawing 47B001 series

Drawing 47W609

Drawing 47W809

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Drawing 47W625

Support Variance Sheet 84080Z0111

Support Variance Sheet 84090Z0057

Prior to the crack on Unit 1 and immediately following the crack on

Unit 2, the licensee wrote a Maintenance Request (MR 123140) to conduct

a liquid penetrant test of the Unit I weld area in accordance with

Technical Instruction TI-51, Liquid Penetrant Examination Using the

Color-Contrast Solvent-Removable Method for Elevated Temperature

Examinations. This procedure was completed for the entire surface area

on the Unit 1 CVCS letdown sample line between the main three inch line

and valve 62-674. The technicians who performed the examination,

reported that a full outside diameter test was conducted with no

discrepancies noted.

When the second failure was evaluated by the vendor, liquid penetrant

. and developer were identified inside the crack. The depth of

penetration attained by the dye penetrant and developer were

approximately one third and two thirds of the distance from the

exterior waT1 towards the inner diameter wall, respectively. This

indicated that the crack was present when the dye penetrant and

developer were applied to the pipe section being tested. The presence

of the dye and developer was verified through both X-ray isotopic

analysis and electron microscope examination.

Failure to adequately implement TI-51 dye penetrant testing on July 31,

1985 is a violation (327/85-27-04). Proper performance of the TI

should have identified the crack in the CVCS letdown sample line prior

to leakage.

The licensee action plan to determine the root cause of the letdown

sample line cracks and corrective actions were specified in the

August 28, 1985 letter from Mr. H. G. Parris of TVA to Dr. J. N. Grace

of NRC Region II. The resolution of the failed branch line joints

consisted of two parallel efforts: 1) to determine the root cause of

the two cracked lines and 2) to ensure that other similar lines are not

cracked or going to crack. For the root cause evaluation, the licensee

had. metallurgical examinations performed by Combustion - Engineering,

Inc., on the failed pipes and committed to obtain vibration data for

various system flow rates and alignments and to investigate the main-

tenance history of the branch line, including preoperational history

and history at other Westinghouse plants having similar configuration.

For the second parallel effort, the licensee committed to inspect the

remaining positions of the letdown system and review the mainteriance

history of snubbers / hangers on other selected systems for indication of

vibration problems. The licensee submitted a status report of findings

on September 15, 1985.

c. -. -

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b. On August- 16, 1985, the licensee declared pressure transmitters in the

Emergency Gas Treatment System (EGTS) inoperable due to environmental

qualification issues. The qualification was questioned when it was

determined that a Containment Spray (CS) line which would carry

potentially highly radioactive water during an accident was located in

close proximity to the transmitters. This line had not previously been

considered in the environmental map of area. The transmitters were

declared operable after setpoint readjustments were evaluated and made.

During an unrelated independent contractor audit of 10CFR50.49

compliance at Sequoyah Nuclear Plant, a review of a sample of the

documentation packages and supporting technical material for the

environmental qualification of safety-related equipment at the plant

was conducted. This re /iew identified the following documentation

deficiencies:

1. Documentation was not available to support the determination that

certain equipment was environmentally qualified.

2. Technic'al criterion were not available to support certain

- engineering evaluations.

3. Manufacturer's recommended maintenance / surveillance actions were

not taken or were not validated on all Qualified Maintenance Data

Sheets.

After examination of the audit findings the licensee identified three

main areas of concern:

1. .

Inadequacy of the justifications of environmental qualification of

equipment based on similarity to other equipment.

2. Inadeau,acy of equipment aging analyses.

3. Establishment of qualified equipment life.

Due to these discrepancies and potential for unqualified equipment, the

licensee commenced shutdown of Unit 2 on August 21, 1985 and of Unit 1

on August 22. Both units were in cold shutdown on August 23. The

licensee is conducting a comprehensive review of the environmental

qualification of safety related equipment for both units. This

shutdown was confirmed by 50.54(f) letter from the NRC on September 17,

1985.

c. On August 9, 1985, while operating at 100% power, a routine boric acid

sample was taken on Unit 2 loop 3 cold leg injection accumulator.

.

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The events that followed lead to a violation of the TS 3.5.1.1 LCO.

The chronology of the events follows:

August 9

'

Time Event Boric Acid Concentration

1440 Number 3 loop accumulator sampled 1907 ppm

1440 Boric Acid Add Recommendation 1907 ppm

Sheet completed

1740 Number 3 loop accumulator was

drained in preparation to add

borated water. LCO 3.5.1.1 was

entered due to low level in

loop 3 accumulator.

1830 Loop 3 accumulator sampled. TS

'

1891

minimum value is 1900 ppm boric acid.

2115 Stopped draining loop 3 accumulator.

-2120' Started 2BB safety injection pump

to fill loop 3 accumulator with

borated water.

2212 Reactor Operator exited LC0 3.5.1.1

based on restoration of level in the

loop 3 accumulator. The out-of-

specification low boric acid

concentration from 1830 sample was

not considered.

2350 Loop 3 accumulator sampled, and 1839 ppm

second sample ordered.

August 10

0002 LC0 3.5.1.1. is entered by Reactor

Operator

,

0100 Loop 3 accumulator resampled. 1831

0120 Loop 3 accumulator resampled and 1961

within the TS allowed limits.

-0200 LCO 3.5.1.1 was exited by the Reactor

Operator

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.

The above sequence of events indicates that LC0 3.5.1.1 was entered as

a result of accumulator level at 1740 on August 9,1985. The licensee

met the LC0 at 0120 on August 10, 1985. The plant actually remained in

the LCO, however, because boric acid concentration was determined to be

out of tolerance low prior to the accumulator level being restored to

the TS required limit. The total time that elapsed from the initial

entry into LCO 3.5.1.1 to its exit at 0120 on August 10,1985 was seven

hours and forty minutes. The licensee did not comply with the LCO 3.5.1.1 action. statement which requires the plant to be placed in hot

shutdown condition within seven hours after initial entry into the LCO.

This is a violation (328/85-28-05). The safety significance of this

event was low since there is reasonable assurance that sufficient boron

concentration existed in the accumulator after the level was restored,

and the boron injection tank and other three cold leg injection

accumulators were available to satisfy the safety analyses.

11. Inspector Followup Items (IFI) (92701)

(Closed) IFI (327,328/83-31-05). The licensee was in the process of writing

a single, comprehensive statement regarding all aspects of independent

verification at the time this IFI was opened. The licensee presently has an

Administrative Instruction (AI-37), Independent Verification, Revision 1,

which addresses independent verification in all cases,with the exception of

temporary alterations. The control of independent verification during the

performance of a temporary alteration is addressed in AI-9, Control of

Temporary Alterations. This IFI is closed.

(Closed) IFI (327,328/83-31-06). The licensee was reviewing a number of

procedures that had been identified by the NRC resident inspectors as

procedures that required independent verification when this IFI was opened.

The licensee developed AI-37 following this review. The inspectors will,

during the course of normal system and p'rocedure inspections, evaluate the

adequacy of independent verification in site procedures. This IFI is closed.

(0 pen) IFI (327/84-24-04). The inspector reviewed the following documents

pertinent to seal table fitting maintenance:

MI-1.9, Revision 6

MI-1.10, Revision 2

Crawford Fitting Company letters dated August 13 and November 16, 1984

TVA NSRS Report R-85-02-SQN/WBN dated March 25, 1985

Westinghouse Technical Bulletin 84-09 Revision 1 dated April 24, 1985

Issues identified by Crawford, with respect to the use of their fittings on

the thimble and guide tubing, were resolved as not being of safety concern

as documented in their November letter. Crawford still does not recommend

mixing their fittings with fittings of other vendors. Westinghouse also

does not recommend use of fittings of different vendors, although certain

mixed fitting combinations have been tested by TVA and Westinghouse and

determined to be adequate high pressure seals.

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The inspector reviewed the licensee maintenance procedures listed above to

determine if vendor recommendations were incorporated. The review of MI 1.9

identified several recommendations which had not been incorporated. When

brought to the licensee's attention, licensee maintenance personnel provided

a draft revision to the procedure which was awaiting review. These

revisions are to be in place prior to thimble tube cleaning activities

during the Unit I refueling outage. Additionally, Sequoyah maintenance

personnel plan to review the Unit 1 seal table fittings to determine the

desirability of making all fitting combinations uniform. While no immediate

safety concerns have been identified in this area, this followup item will

remain open until the licensee has revised MI 1.9 and evaluated current high

pressure seal fitting adequacy.

With respect to the thimble tube blockage problem, TVA has established a

policy of cleaning and lubricating all thimble tubes during refueling

outages. During tSe Unit 1 ice weighing outage, 8 to 10 blocked tubes

were. cleaned. Currently, Unit 2 has two plugged tubes. The licensee has

also determined that detector cables undergo less corrosion when detectors

are kept in their storage position when not in use.

12. NRC Order EA 85-49 Followup

The inspector reviewed the licensee's response dated July 26, 1985, to NRC

Order EA 85-49. The inspector reviewed enclosure 2 of the submittal and

held discussions with TVA licensing staff personnel. Enclosure'2 provided a

summary of the employee survey, and TVA personnel provided position title

information for a sampling of employees. The inspector identified eight

employees having early knowledge of the issue (A0100, A0102, A0121, A0132,

A0136,A0138,A0165,A0168). Based on TVA input, these individuals did not

hold positions that would have brought them into the pressure transmitter

issue. The inspector concluded their surveys were inaccurate or did not

reflect an understanding of the issue. The inspector also questioned a

Nuclear Safety Review Staff member involved in TVA's review of this issue.

This individual stated that none of the eight were interviewed since their

names were not mentioned as associated with the issue during interviews with

cognizant TVA personnel.

[ The inspector identified one management level individual not included in the

'

survey. TVA personnel stated this was an oversight due to the transfer of

the individual to Bellcfonte. TVA provided the survey information on the

individual in a supplemental response dated August 30, 1985.

The inspector identified no violations or deviations.

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