ML20133P360
| ML20133P360 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 08/01/1985 |
| From: | Jenison K, Linda Watson, Weise S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20133P252 | List: |
| References | |
| 50-327-85-23, 50-328-85-23, NUDOCS 8508140274 | |
| Download: ML20133P360 (17) | |
See also: IR 05000327/1985023
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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101 MARlETTA STHEET,N.W.
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ATLANTA, GEORGI A 30323
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Report Nos.:
50-327/85-23 and 50-328/85-23
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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 1 and 2
Inspection Conducted: June 6 - July 5, 1985
Inspectors:
/7 d _ //w ,, D ,
8/o//65
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K. M. Jbnipn,' Sbqfo'r ~ Resident Inspector
Dat6 Si@ned
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8 /ci/ss
L. J. WatsoW, Re fd t Inspector
Date Sidned
Approved by:
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S. P. Weise, Section Chief
Date Signed
Division of Reactor Projects
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SUMMARY
Scope: This routine, announced inspection involved 349 resident inspector-hours
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onsite in the areas of operational safety verification including operations
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performance, system lineups, radiation protection, security and housekeeping
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inspections; surveillance and maintenance observations; review of previous
inspection findings; followup of events; review of inspector followup items; and
review of licensee identified items.
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Results:
In the areas inspected, three violations were identified:
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1.
Failure to properly store stainless steel piping (paragraph 3).
2.
Failure to follow a site security procedure (paragraph 5).
3.
Failure to take corrective actions in response to a previous
violation (paragraph 3).
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8508140274 850802
ADOCK 05000327
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REPORT DETAILS
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1.
Licensee Employees Contacted
H. L. Abercrombie, Site Director
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- P. R. Wallace, Plant Manager
- L. M. Nobles, Operations and Engineering Superintendent
- B. M. Patterson, Maintenance Supervisor
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M. R. Harding, Engineering Group Supervisor
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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, Compliance Supervisor
- D. L. Cowart, Quality Section Supervisor
Other licensee employees contacted included technicians, operators, shift
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engineers, security force members, engineers and maintenance personnel.
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- Attended exit interview
2.
Exit Interview
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The inspection scope and findings were summarized with the Plant Manage r and
members of his staff on July 8, 1985. Violations described in paragraphs 3
1
and 5 were discussed.
The licensee acknowledged the inspection findings.
In addition, the licensee committed to frisk Beta-contaminated smears as
discussed in paragraph 5 of this report. The licensee did not identify as
proprietary any material reviewed by the inspectors during this inspection.
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During the reporting period, frequent discussions were held with the Site
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Director, Plant Manager and his assistants concerning inspection findings.
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At no time during the inspection was written material provided to the
licensee by the inspector.
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3.
Licensee Action on Previous Inspection Findings (92702, 61726, 62703)
(Closed) Violation (327/83-16-01).
The licensee's response of October 7,
1983, was reviewed and the indicated corrective action was audited. The
corrective action stipulated was to revise instruction S0I 30.5D, Auxiliary
Building Heating and Ventilating Systems and Room Coolers, to include all
operations necessary to recover from auxiliary building isolations including
the placement of Auxiliary Building Gas Treatment System (ABGTS) fan control
switches back to the "A-Auto" position after shutting down the fans.
The
current revision of SOI 30.5D was verified to return the ABGTS to normal
("A-Auto") after shutting down the fans.
The licensee's actions are
considered complete.
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(Closed)
Violation
(327,328/83-18-01).
The
licensee's response of
November 1,1983, was reviewed and the corrective action was audited.
The
corrective action stipulated was to revise instruction IMI-3, Main and
Auxiliary Feedwater System, to include independent verification of lifting
and terminating electrical leads.
The current revision of IMI-3 was
verified to require that lifted and terminated leads be independently
verified. The licensee's actions are considered complete.
(Closed)
Violation
(327,328/83-01-01).
The
licensee's response of
February 25, 1983, was reviewed and the indicated corrective actions were
audited.
The corrective actions stipulated were to adjust the alarm
setpoint of the Essential Raw Cooling Water (ERCW) system effluent monitors
to account for the background radiation resulting from a nearby Refueling
'
Water Storage Tank pipe, and to amend instruction SI-3, Daily, Weekly, and
Monthly Logs, to require that monitor alarms be promptly cleared or the
monitor be declared inoperable and the action statement implemented. The
current revision of SI-3 has been revised to include the clearance of
monitor alarms and the ERCW effluent monitors were observed to be operable
and not in the alarm state.
The licensee's corrective actions are
considered complete.
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(Closed)
Violation
(327,328/83-12-01).
The licensee's response of
September 23, 1983, was reviewed and the indicated corrective actions
were audited. The corrective actions stipulated were to insure that all
stainless steel pipe was stored in accordance with ANSI-45.2.2, Packaging,
Shipping, Receiving, Storage, and Handling of Items for Nuclear Power
plants, and to write a section instruction letter to Power Stores personnel
in order to reinforce instruction AI-11. This corrective action appeared to
have been adequate within the Power Stores and the Shop Stores areas of
responsibility. However, a similar situation was identified in a stainless
steel storage area on the 690 level within the Auxiliary Building. TI-70,
Cleaning and Decontamination of Plant Equipment, implements in part the
licensee's commitments to the aforementioned ANSI standard. TI-70 requires
stainless steel material to be stored with the ends capped or taped.
Contrary the above, the licensee failed to store several lengths of stain-
less steel pipe, including elbows and flanges, in the proper manner.
The section responsible for this storage area reports to the Office of
Engineering. Violation (327,328/83-12-01) is considered closed; however,
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the failure to properly store stainless steel pipe on the 690 level of the
Auxiliary Building is a violation (327,328/85-23-01).
(0 pen) Violation (328/83-26-01). The licensee's responses of December 21,
.
1983, July 20, 1984, and September 21, 1984, were reviewed and the indicated
corrective actions were audited. The corrective actions stipulated were to
submit a Technical Specification (TS) change to TS 3.3.3.7 and to issue
formal interpretations to the Operations Department staff concerning the
requirement for acoustic monitor operability.
The formal interpretation
issued to the Operations Department staff was added to the TS interpre-
tations manual, which identified the acoustic monitors as one of two
required indications of flow from the power operated relief valves. The TS
amendment is still under review by the NRC.
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(Closed) Violation (327/83-26-01). The licensee's response of December 21,
1983, was reviewed and the indicated corrective actions were audited.
The
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corrective actions stipulated in the response were to change a computer
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program which incorrectly calculated Overtemperature Delta Temperature
(0 TDT) and to revise Technical Instruction TI-36, Incore-Excore Calibration,
.
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to include TS values.
These items are considered to be complete.
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(Closed) Violation (327,
328/83-26-02).
The licensee's response of
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December 21, 1983, was reviewed and the indicated corrective actions were
audited. The corrective actions stipulated in the response were to complete
an engineering evaluation comparing the as-built plant, Surveillance
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Instruction SI-162.1, and TS to determine if required snubbers appeared in
all three documents.
A TS change was submitted to account for design
changes in snubber location and number.
Additionally,
Surveillance
Instruction 162.1 was revised. A TS amendment has been issued by the NRC to
delete tables related to hydraulic snubbers from the TS. A list of snubbers
will be maintained by the licensee and revisions to the list will be made in
accordance with 10 CFR 50.59. The licensee's actions are considered to be
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complete.
(Closed) Violation (327,
328/83-29-01).
The licensee's response of
January 10, 1984, was reviewed and the indicated corrective actions were
audited.
The corrective actions stipulated in the response were to
discipline and retrain the involved personnel that failed to follow an
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established radioactive waste effluent discharge procedure.
In addition,
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procedure S01-14.3, Condensate Demineralizer Waste Disposal, was revised to
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include independent verification of valve alignment.
These actions are
considered to be complete.
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(Closed) Violation (327,
328/83-29-02).
The licensee's response of
January 10, 1984, was reviewed and the indicated corrective actions were
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audited.
The corrective actions stipulated in the response were to
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reemphasize to the engineering staff that identification of Critical
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Systems, Structures and Components (CSSC) is required prior to the execution
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of a work plan.
In addition, the subject work plan (WP10260) was reworked
as a CSSC job. These actions are considered to be complete.
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(Closed) Violation (328/83-29-03). The licensee's response of January 10,
1984, was reviewed and the indicated corrective actions were audited. The
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corrective actions stipulated in the response were to reemphasize to the
Operations Department staff that procedures were to be followed and that
plant parameters were to be observed.
These actions are considered to be
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complete.
(Closed) Violation (327,328/83-31-01). The licensee's response of March 15,
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1984, was reviewed and the indicated corrective actions were audited. The
corrective actions stipulated in, the response were to reemphasize to all
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personnel the importance of following radiation work permit (RWP)
requirements, to . review RWP postings for accuracy and to compare key card
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entry data with RWP data on a periodic basis.
The corrective actions
involved with a periodic RWP/ key card comparison were not completed as
committed to in the licensee's response.
This failure to conduct the
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periodic RWP/ key card comparisons is an instance of not taking prompt
corrective actions to insure quality operations and is a violation
(327,328/85-23-02).
(Closed) Violation (328/83-31-02).
The licensee's response of March 15,
1984, was reviewed and the indicated corrective actions were audited.
The
corrective actions stipulated in the response were to revise procedure
SOI-63.1 and complete and document training in the areas of following
procedures, reduction of personnel errors and several other areas.
The
revision to SOI 67.1 was reviewed and initial and scheduled retraining in
the Operations Department was verified.
(Closed) Violation (327/84-11-01).
The licensee's response of July 16,
1984, was reviewed and the indicated corrective actions were audited.
The
corrective action included revision of a procedure for mode change and
modification of an RCS sample line.
The inspector reviewed: Technical
Instruction, TI-59,
Listing of Technical
Specification Instruments;
Surveillance Instruction SI-90.6, Reactor Trip Instrumentation Quarterly
Functional Tests; and General Operating Instruction GOI-1, Plant Startup
from Cold Shutdown to Hot Standby.
The inspector verified that the
procedures required operability of steam generator level transmitter
1-LT-3-38 prior to entry into Mode 3.
The inspector also audited Workplan
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10721, Rev. 1, which implemented a modification to assure operability of a
pressurizer level transmitter.
The licensee actions in this area are
considered to be complete.
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4.
Unresolved Items
Unresolved items 'are matters about which more information is required to
determine whether they are acceptable or may involve violations or devia-
tions.
One unresolved item was identified during this inspection regarding per-
formance of maintenance on a safety-related transducer is discussed in
paragraph 7.
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5.
Operational Safety Verification (71707)
a.
Plant Tours
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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 verified 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 inspector verified that
maintenance work orders had been submitted as required and that
followup activities and prioritization of work was accomplished by the
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licensee.
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Tours of the Diesel Generator, Auxiliary, Control, Turbine Buildings,
and Reactor Containment were conducted to observe plant equipment
conditions, including potential fire hazards, fluid leaks, and
excessive vibrations and plant housekeeping / cleanliness conditions.
During one routine tour of the Auxiliary building,
ice A-57 was
identified to have what appeared to be cracks in its vertical and
horizontal ribs, and in its hinges. This door is an auxiliary building
secondary containment isolation door and is required to be shut and
capable of withstanding a force of one-half psid pressure.
The
licensee evaluated these apparent cracks by removing the existing paint
and visually examining the welds. All apparent cracks were determined
to be the result of cracked paint material.
The inspector had no
further questions.
The inspectors walked down accessible portions of the following
safety-related systems on Unit I and Unit 2 to verify operability and
proper valve alignment:
Safety Injection System (Units 1 and 2)
Turbine Driven Auxiliary Feedwater System (Units 1 and 2)
Motor Driven Auxiliary Feedwater System (Units 1 and 2)
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Upper Head Injection System (Units 1 and 2)
125V DC Vital Batteries
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Diesel Generators (Units 1 and 2)
Ice Condenser (Unit 1)
b.
Security
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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.
During a routine tour on
June 12, 1985, in an assembled group of approximately twelve workmen,
the inspector observed one permanently badged individual who did not
have his badge in his possession and one temporarily badged individual
who was not displaying his badge correctly. These workers were inside
the protected area. This constitutes a violation (327,328/85-23-03) of
licensee procedures for display of security identification badges.
c.
Radiation Protection
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(1) The inspectors observed Health Physics (HP) practices and verified
implementation of radiation protection control.
On a regular
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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
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protection instruments were verified operable and calibration
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frequencies were reviewed. A review of RWP data indicated minor
clerical errors in the protective dress requirements of five RWPs:
02-085867
02-085902
02-085611
02-085638
02-085732
The resolution of the above errors and the nonrecurrence of this
type of minor inadequacy will be reviewed as Inspector Followup
Item (327,328/85-23-04).
(2) The inspectors routinely evaluated the transfer of material out of
and into the regulated area.
Health Physics (HP) technicians
routinely smear materials leaving the regulated area at a stand
situated at one of the regulated area boundaries.
In addition,
some general area smears are also evaluated by HP technicians at
this same stand. During the nonitoring of contaminated smears,
taken from an area with a relatively high level of Beta
contamination, an HP technician was observed covering the smears
with a tissue prior to the frisking process. The technician then
placed the frisker probe in contact with the tissue paper and read
the smear.
The HP supervisor was asked to determine if the shielding provided
by the paper was significant and to account for this shielding in
the Radiation Work Permit (RWP) process.
The HP supervisor
provided the inspector with an evaluation of the frisking process
which indicated that, when the probe was held one quarter inch
above a' series of control smear samples, the tissue reduced the
Beta reading by approximately twelve percent. When the probe was
placed in contact with the tissue, however, the reading that
resulted was approximately eight percent higher than the reading
taken at one quarter inch above the same smear sample when not
covered.
Therefore,
the
frisking
method
observed
was
conservative. The licensee committed to use the contact method of
frisking of covered smears.
(3) A review of TVA Health Physics form 17195 (DOH&SI-80), Request For
Estimate of Current Radiation Dose Total, was conducted.
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10 CFR 19.13(e) requires that licensees, if requested, provide
workers
terminating
employment or ending
temporary work
assignments involving radiation dose in the licensee's facility
with a written report or estimate of the radiation dose received
by that worker from operations of the licensee.
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The inspector determined that on two separate occasions, indivi-
duals who requested dose records upon terminating assignments
involving radiation dose at the licensee's facility were given
incorrect written estimates in that the estimates did not repre-
sent the radiation dose received by the worker from operations of
the licensee during the specifically identified time period. One
individual had dose from another facility included in the Sequoyah
Nuclear Facility dose estimate and one individual had the dose
estimate calculated incorrectly.
In both cases, the estimates
indicated a dose higher than that received and were therefore
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conservative. This is identified as an Inspector Followup Item
pending NRC Region II review of additional licensee dose records
(327,328/85-23-05).
(4) During a tour of the Auxiliary Building on June 11, 1985, the
inspector observed a worker placing tools inside a yellow bag.
The worker subsequently placed the bag inside a desk door on
Elevation 690 of the Auxiliary Building.
The inspector inter-
viewed the worker concerning the control of contaminated tools.
The worker stated that the tools were not contaminated; however,
the worker stored the material in the yellow wrapping without a
survey or marking of the material as required by RCI-1, " Radio-
.
logical Control Instruction."
The worker stated that he was
aware he had not followed the procedure.
The licensee was cited in IE Inspection Report 327,328/85-20 for
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several examples of failure to survey and mark contaminated items.
Improper use of yellow wrappings can contribute to this problem.
The licensee has a program in progress, as part of the corrective
,
action to the violation, to monitor the controlled area and worker
activities in the controlled area to assure the proper use of
yellow wrappings and appropriate labeling and storage of con-
taminated materials.
The licensee is taking disciplinary action
against employees who fail to adhere to radiological control
procedures.
The inspector will continue to monitor corrective
action in response to the violation to assure that the program is
effective. This is identified as Inspector Followup Item (327,
328/85-23-06).
d.
Operational Verification of Ice Condenser Doors
In conjunction with the operational verification of the ice condenser
on Unit 1, an evaluation of +he licensee's control of ice condenser
parameters, ice condenser doors and associated appurtenances was con-
ducted by the inspectors.
It was determined that Technical Specification 4.6.5.3.2 may be routinely violated by the licensee and that there is a
chronic ice buildup problem on the intermediate doors.
This ice
buildup has resulted in almost daily entries into the Unit 1 contain-
ment building in order to remove ice from the intermediate door sur-
faces (between 40 and 60 pounds of ice a day).
This issue will be
discussed in inspection report (327,328/85-24).
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In addition to the review of ice buildup on certain ice condenser
doors, a review of the use of lower inlet door blocking devices was
conducted.
The licensee presently uses a blocking device which is
pressed between the lower inlet doors and the downward air flow vanes.
Proper administrative control of blocking devices is mandatory since
the blocking devices, if not removed prior to plant operation, could
make the ice condenser inoperable.
The blocking devices are normally
used during ice weighing outages and other sufficiently long outages.
The devices are installed and removed using the routine maintenance
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request (MR) process. The unused blocking devices are stored in a shop
area when not in use, and there is no numerical accountability for the
devices. During ice weighing and/or servicing, Maintenance Instruction
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(MI) 5.3, Ice Servicing, is used in conjunction with the MR process to
install and remove the devices.
Several existing procedures control observations of the intermediate
and/or the lower ice condenser doors to assure operability of the
doors. These procedures are:
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Maintenance
Instruction
MI-5.3,
Ice
Servicing,
requires
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independent verification of both installation and removal when the
blocking devices are installed during an ice servicing outage.
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During other outages the MR process is used alone.
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General Operating Instruction, GOI-1, Plant Startup From Cold
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Shutdown to Hot Standby, requires that prior to entering mode 4
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the ice condenser door blocks be removed and temporary rubber
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drain covers be replaced with dissolvable paper.
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Surveillance Instruction, SI-3, Daily, Weekly and Monthly Logs,
requires instep 4.6.3.2.a, that the ice condenser intermediate
deck doo' rs to be visually inspected once every seven days to be
free from frost accumulation and verified closed.
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Operations Section Letter Administrative, OSLA-99,- Assistant Unit
Operator Duty Locations and Responsibilities, addresses the visual
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inspection of the ice condenser doors a: part of the routine
inspection activities during normal Assistant Unit Operator tours.
Surveillance Instruction, SI-108, Ice Condenser Doors, requires
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that the opening torque of the lower and intermediate deck doors
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be checked once a year and the upper deck doors be inspected once
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every 90 days. This surveillance is normally conducted after ice
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basket servicing and would verify the removal of the blocking
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devices used during the servicing period.
One deficiency noted was that these procedures do not control removal
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of blocking devices individually.
Each blocking device used is not
identified, and no signoff is required for each device.
Instead, a
signoff is made that all devices have been removed. This also reduces
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the effectiveness of independent verification since the verifier does
not know on which doors the blocks were installed. This deficiency was
discussed with the licensee and a commitment obtained from the licensee
to justify the practice or revise administrative controls.
6.
Monthly Surveillance Observation (61726)
The inspectors observed Technical Specification (TS) required surveillance
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testing and verified that testing was performed in accordance with adequate
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procedures; that test instrumentation was calibrated; that limiting
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conditions for operation were met; that test results met acceptance criteria
requirements and were reviewed by personnel other that the individual direc-
ting the test; that deficiencies were identifiej, as appropriate, and that
any deficiencies identified during the testing were properly reviewed and
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resolved by management personnel; and that system restoration was adequate.
For complete 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:
SI-90.6,
" Reactor Trip Instrumentation Quarterly Functional
Tests"
SI-7S
Monitoring
Instrumentation
Steam
Generator Level (Refueling Cycle)"
SI-166.6
" Post Maintenance Testing of Category
"A"
and
"B"
Valves"
SI-90.6
" Reactor Trip Quarterly Functional Tests"
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SI-170.2,
" Periodic Calibration of the Standby Diesel Generator
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1B-B (Annual Inspection) (Unit 1)"
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The inspector reviewed documentation to assure completion of the following
surveillance activities:
SI-13,
" Verification of ECCS Valves with Power Removed"
SI-3,
" Daily, Weekly and Monthly Logs"
SI-33.1,
"ERCW and Auxiliary ERCW Valves Servicing Safety Related
Equipment'
SI-12,
"ECCS Valve Alignment Verification"
No violations or deviations were identified in this area.
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7.
Monthly Maintenance Observations (62703)
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a.
Station maintenance activities of safety-related systems and components
were observed / reviewed to ascertain that they were conducted in
accordance with approved procedures, regulatory guides, industry codes
and standards, and in conformance with TS.
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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 if applicable;
procedures adequate to control the activity; troubleshooting activities
controlled and the repair records accurately reflect work 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 and observed; fire prevention controls implemented;
and housekeeping maintained.
b.
During the Unit I return to power on June 21, 1985, the inspector
observed trouble shooting on the local speed controller for the turbine
driven auxiliary feedwater pump (TDAFP). The defective controller was
replaced when it was determined that the controller would drop the pump
speed back to idle when output flow on the pump reached 880 gpm.
The inspector reviewed maintenance request (MR) A528966 and identified
the following concerns. The MR stated that the equipment was not CSSC
equipment; however, the instrument technician interviewed stated that
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the defective controller (in automatic) could have prevented the TDAFP
from maintaining operating speed. This indicates that the controller
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should be designated as safety related equipment,
i.e., CSSC equipment,
in accordance with Appendix B of 10 CFR 50.
Since the work was on
equipment designated as non-CSSC, the work was done with a drawing that
was not controlled, although two individuals independently stated that
the circuitry in question on the drawing used was verified against a
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controlled print.
Additionally, configuration control sheets in
procedure IMI-1324 were attached to the MR and used to control the
configuration changes. The equipment is designated as Class IE.
The inspector discussed these concerns with the licensee. The licensee
stated that an onsite CSSC Review Committee (formed under Administra-
tive Instruction AI-39, " Critical Structures, Systems and Components -
CSSC)," which was issued March 19, 1985) had identified components in
the Auxiliary Feedwater Terry Turbine control system including the
subject controller which should be included in the CSSC list.
On
May 20 and 21, the licensee had held meetings to instruct planners to
handle
future workplans
involving
the
subject
equipment
as
safety-related.
A revision to include this equipment in SQA-134,
" Critical Structures, Systems and Components (CSSC) List," was under
review.
Appendix B of 10 CFR 50 requires the licensee to identi fy the
structures, systems, and components to be covered by the quality
assurance program.
Failure to identify CSSC equipment and supply
appropriate quality control measures to equipment that is safety-
related is a violation; however, this violation meets the requirements
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for a licensee identified violation.
The failure to identify the
,
controller as CSSC equipment was identified by the licensee, is a
Severity Level IV violation, was not required to be reported, will be
corrected with appropriate interim measures and measures to prevent
recurrence, and was not a violation that could have been prevented by
corrective action for a previous violation. Corrective action includes
revision of SQA-134 by July 12, 1985, to include the equipment
determined to be safety-related by the CSSC Review Committee.
In the
interim, the licensee stated that the equipment will be handled as
safety-related equipment.
c.
The inspector observed maintenance on the incore probes on June 25,
1985.
The maintenance consisted of removal of one incore detector,
which was stored in a storage location in the incore instrument room,
and replacement with a new detector.
d.
The inspector observed maintenance on the B train evaporator vent
condenser water trap and vent valve which are CSSC equipment.
The
inspector reviewed the maintenance requests and procedures for the
work. The following documents were reviewed:
MR A545723
MI 6.20 Configuration Control During Maintenance Activities
MI 6.15 General Procedure, Tightening Bolted Joints
MI 11.4 Maintenance of CSSC Valves
e.
Corrective maintenance on
a
Masoneilan 8005 electropneumatic
.
transducer, current to pneumatic (I/P) converter, for a Unit 1
,
Auxiliary Feedwater system level control valve (1-LCV-3-148A) was
observed on June 23, 1985.
The following documents were reviewed:
MR A528972
Instrument Maintenance Instruction (IMI-134) Configuration Control
!
of Instrument Maintenance Activities
Surveillance Instruction (SI-75) Remote Shutdown Monitoring
,
Instrumentation Steam Generator Level
Drawings 47W610-3-3, 47W600-124, 45N603-4, 45N1630-56, and
i
Quality Assurance Form 575-558-85-0136
Sequoyah Nuclear Plant Standard Practice (SQM-1) Sequoyah Nuclear
Plant Maintenance Program
Surveillance Instruction (SI-166.6) Post Maintenance Testing of
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Category A and B Valves
Nuclear Quality Assurance Manual (NQAM)
Masoneilan Technical Instruction 2035E
l
The inspector observed technicians performing the maintenance under MR
A528972. The MR required the work to be performed in accordance with
l
IMI-134.
One purpose of IMI-134 is to provide explicit work
instructions
for
the
performance of maintenance
activities.
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Instructions on the IMI-134 maintenance work sheet used by the
technicians stated (in the " Performance of Work" section), " verify
proper operation and repair if required per vendors manual using as
constructed drawings".
No explicit work instructions or any other
procedures were used to perform the maintenance.
In addition, the
vendor's manual did not provide instructions for replacement of the I/P
converter.
TVA's Nuclear Quality Assurance Program (NQAM) states in section
3.3.1.2 that maintenance instructions shall contain enough detail to
permit the task to be performed safety and expeditiously. The NQAM is
implemented in part by SQM-1, which states that maintenance
instructions shall be prepared to include a description of what work is
to be done, in enough detail that further instructions are minimized.
SQM-1 further states that this description should give a step-by-step
sequence of events such that the job will be performed correctly,
safety, and expeditiously, and shall include references to such
documents as vendor drawings, TVA drawings, maintenance manuals, and
other maintenance instructions.
The NQAM is also implemented in part by IMI-134. IMI-134 states that
its purpose is to provide explicit precautions, prerequisites, work
instructions, and pertinent information for the performance of
maintenance activities. IMI-134 also states that work instructions are
to clearly direct the work of the craf tsman and/or refer to pre-written
instrument maintenance instructions or manuals.
SQM-1 and IMI-134 were not adequately implemented in this case in that
the " Performance of Work" section of the IMI-134 maintenance work sheet
did not sufficiently describe the work to be performed on the level
control valve; contained no details of the work to be performed; and,
contained no' reference to other procedures describing the activities to
be performed. This is an unresolved item pending review of additional
maintenance performances (327, 328/85-23-07).
The NQAM also states, in section 3.3.1.1, that the " Preparations for
Maintenance" section of a maintenance instruction shall reflect special
equipment requirements such as Measuring and Test Equipment (M&TE).
SQM-1 states in the " Preparations for Work" section that maintenance
procedures should state what special tools are needed. SQM-1 specifies
that M&TE are special tools.
M&TE used during the maintenance, a
Heise gauge and digital volt meter, were not included in the "Special
.
Equipment Section".
While these procedural requirements were not
implemented as stated, the IMI-134 maintenance work sheet did reference
SI-75 in the " Performance of Work" section. Therefore, information on
the special equipment needed was available by referencing SI-75 but not
listed in the right section of the IMI-134 work sheet.
The further
review of proper inclusion of M&TE in the Special Equipment Section of
IMI-134 is identified as
an
Inspector
Followup
Item (327,
328/35-23-08).
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8.
Licensee Event Report (LER) Followup (92700)
a.
The following LERs 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 Specification conditions had been identified.
LERs Unit 1
85006
Frozen Sense Lines
85020
Inadvertent Isolation of Unit 1 Residual Heat
Removal While in Mode 5
84038
DNB Design Basis
84041
Pressurizer Indicator in ACR Inoperable
84043
Thermal Fire Detector Inoperable
84045
BB Compressor Out of Service
84066
Circuit Breaker Operating Error
84071
Surveillance Requirement Not Met
83003
Inoperability of Effluent Radiation Monitor
83016
Inoperability
of
Ice
Condenser
Temperature
'
Monitoring System Recorder in the Main Control Room
83029
Two Ice Condenser Door Limit Switches Out of
Adjustment
83031
Control Rod Position Indication Inoperable
83036
Train B Auxiliary Building Gas Treatment System
83039
Inoperable Turbine Building Sump Liquid Effluent
Radiation Monitor
83042
Opening of the Ice Condenser Lower Inlet Doors
83053
Blowdown Isolation Valve Failed Shut
83058
Inoperable Liquid Effluent Radiation Monitor
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83076
Inoperable Liquid Effluent Radiation Monitor
83083
Inoperable Shield Building Stack Flow Rate Monitor
>
83096
Inoperable Gaseous Effluent Radiation Monitor for
the Auxiliary Building Exhaust
83102
Waste Gas Decay Tank 0xygen Concentration Greater
Than 2%
83103
Automatic Control Valve Failed Open
83106
Condenser
Vacuum Exhaust
Flow Rate Monitor
83113
Inoperable Steam Generator Blowdown Radiation
Monitor
83115
Auxiliary Building Gas Treatment System Discharge
Damper Operator Found Disconnected
83123
Train
of Auxiliary Building Gas
Treatment System
83125
Inoperable Condenser Vacuum Exhaust Effluent
Monitor
83128
Inoperable Lower Containment Ventilation Isolation
Radiation Monitor
83136
125 Volt DC Battery Bank Cell 2B Inoperable
83159
'D' WGOT High Oxygen Concentration
LERs Unit 2
83032
Opening of the Ice Condenser Inlet Doors
83049
Ice Condenser Intermediate Deck Door Frozen Closed
l
83073
Inoperable Gaseous Effluent Radiation Monitor
83078
Inoperable Steam Generator Blowdown Monitor
83107
Average Ice Weight Below Minimum
83132
Inoperable Steam Generator Blowdown Radiation
Monitors
85008
Missed One Hour Fire Watch Tour
s
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85009
Unit 2 Reactor Trip
9.
Event Followup (93702, 62703, 61726)
a.
Pressurizer Heatup and Cooldown
On June 15, 1985, the licensee determined during review of SI-127, "RCS
Temperature and Pressure Limits," that the pressurizer cooldown and
heatup rates as indicated by the change in pressurizer liquid
temperature over one hour had been exceeded during cooldown of Unit 1
on the morning of June 15th.
The inspector reviewed Surveillance
Instruction SI-127, RCS Temperature and Pressure Limits, performed on
June 14 and 15, 1985, Potentially Reportable Occurrence Report
1-85-196, and operator logs for June 14 and 15, 1985.
Concerns were
identified in that the departure from the Limiting Condition for
Operation occurred three times with no entry into the Technical
Specification action statement iridicated by the operator logs.
The
inspectors are interviewing operators on the sequence of events. This
is identified as Inspector Followup Item (327, 328/85-23-09).
b.
Inadvertent Engineered Safeguards Feature (ESF) Actuation
On June 25, 1985, while Unit I was operating in Mode 3, an ESF
actuation occurred.
At the time the ESF actuation occurred
intermediate head safety injection was blocked in accordance with
routine operating procedures. Therefore, no safety injection resulted.
Other automatic actions responded normally including the isolation of
the main steam isolation valves.
Prior to the ESF actuation, Solid
State Protection System (SSPS) steam flow channel 2, switch FS-1-28A,
had been tripped to perform a troubleshooting procedures. A spurious
steam flow signal tripped a second channel, resulting in the ESF
actuation.
Spurious steam flow signals have resulted in SSPS channel
actuations on April 13, 1985, June 22, 1985, June 23, 1985, and
June 25, 1985.
The troubleshooting process was observed by the
inspector, along with the recalibration of steam flow channel module
1-RC-1-73.
The following documents were reviewed:
SI-483, Procedures for Removing a Reactor Protection Channel From
Service
MR 528984
MR 530537
MR 543754
.
IMI-99 Section C.10.3, Offline Channel Calibration of Turbine
Impulse Pressure Channel
Foxboro Technical Manual, Volume 2
No violations or' deviations were 4Centified during the troubleshooting or
calibration of steam flow chann , '.
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10.
Inspector Followup Items (92701)
(Closed) Inspector Followup Item (327/79-45-03).
This item concerned
10 CFR 21 evaluation worksheets that did not provide evidence that vendors
or contractors had been informed of TVA identified noncompliances or
defects.
The licensee committed to change the reporting procus by
October 15, 1979.
The current Significant Condition Report Processing
Record Sheet (Revision SCRPRS 9/82) was reviewed and was found to require
vendor notification if a condition required a Part 21 report. The licensee
actions are considered complete.
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