ML20133C406
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: |
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
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NUCLEAR REGULATORY COMMISSION
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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:
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K.M.Je(1 son,',5en'iorResidentInspector
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L. J. Wat(icn,'R4sfdent Inspector
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Dafs Signed
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Approved by:
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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)
8510070343 85
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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
- 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.
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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
IB-B, and 2B-B.
The following
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
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
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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
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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
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
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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
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with a standard electron microscope. The Unit 1 failure was similar to
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.
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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:
Inadequacy of the justifications of environmental qualification of
1.
.
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
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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' ocedure inspections, evaluate the
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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
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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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