ML20133P360

Insp Repts 50-327/85-23 & 50-328/85-23 on 850606-0705. Violations Noted:Failure to Properly Store Stainless Steel Piping,To Follow Site Security Procedure & to Take Corrective Actions from Previous Insp Violation

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: IR 05000606/2007005 ML20133P249 ML20133P360
References
50-327-85-23, 50-328-85-23, NUDOCS 8508140274
Download: ML20133P360 (17)

See also: IR 05000327/1985023

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og UNITED STATES

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[km Mo NUCLEAR REGULATORY COMMISSION

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g j 101 MARlETTA STHEET,N.W.

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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

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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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C n. JL, .2;n

L. J. WatsoW, Re fd t Inspector

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Date Sidned

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Approved by: ,

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S. P. Weise, Section Chief Date Signed

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Division of Reactor Projects

SUMMARY

Scope: This routine, announced inspection involved 349 resident inspector-hours

. onsite in the areas of operational safety verification including operations

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performance, system lineups, radiation protection, security and housekeeping

inspections; surveillance and maintenance observations; review of previous

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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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REPORT DETAILS

I 1. Licensee Employees Contacted

i H. L. Abercrombie, Site Director

• P. R. Wallace, Plant Manager

• L. M. Nobles, Operations and Engineering Superintendent

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• B. M. Patterson, Maintenance Supervisor

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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, Compliance Supervisor

• D. L. Cowart, Quality Section Supervisor

Other licensee employees contacted included technicians, operators, shift

j engineers, security force members, engineers and maintenance personnel.

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• Attended exit interview

2. Exit Interview

! 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

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proprietary any material reviewed by the inspectors during this inspection.

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

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Director, Plant Manager and his assistants concerning inspection findings.

At no time during the inspection was written material provided to the

licensee by the inspector.

i 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

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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

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considered complete.

(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,

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

l corrective actions stipulated in the response were to change a computer '

program which incorrectly calculated Overtemperature Delta Temperature

. (0 TDT) and to revise Technical Instruction TI-36, Incore-Excore Calibration,

l to include TS values. These items are considered to be complete.

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i (Closed) Violation (327, 328/83-26-02). The licensee's response of

December 21, 1983, was reviewed and the indicated corrective actions were

audited. The corrective actions stipulated in the response were to complete

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an engineering evaluation comparing the as-built plant, Surveillance

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

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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,

procedure S01-14.3, Condensate Demineralizer Waste Disposal, was revised to

j include independent verification of valve alignment. These actions are

considered to be complete.

! (Closed) Violation (327, 328/83-29-02). The licensee's response of

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January 10, 1984, was reviewed and the indicated corrective actions were

audited. The corrective actions stipulated in the response were to

i reemphasize to the engineering staff that identification of Critical ,

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Systems, Structures and Components (CSSC) is required prior to the execution '

of a work plan. In addition, the subject work plan (WP10260) was reworked

as a CSSC job. These actions are considered to be complete.

l (Closed) Violation (328/83-29-03). The licensee's response of January 10,

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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 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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(Closed) Violation (327,328/83-31-01). The licensee's response of March 15,

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 all

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

{ 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

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1-LT-3-38 prior to entry into Mode 3. The inspector also audited Workplan

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.

l 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

j 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)

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l Motor Driven Auxiliary Feedwater System (Units 1 and 2)

Upper Head Injection System (Units 1 and 2)

125V DC Vital Batteries

i Diesel Generators (Units 1 and 2)

Ice Condenser (Unit 1)

b. Security

l 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

! 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

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.

4 The devices are installed and removed using the routine maintenance

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

j (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

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doors. These procedures are:

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Maintenance Instruction MI-5.3, Ice Servicing, requires

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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i Shutdown to Hot Standby, requires that prior to entering mode 4

the ice condenser door blocks be removed and temporary rubber

j 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.

! Operations Section Letter Administrative, OSLA-99,- Assistant Unit

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Operator Duty Locations and Responsibilities, addresses the visual

inspection of the ice condenser doors a: part of the routine

inspection activities during normal Assistant Unit Operator tours.

i Surveillance Instruction, SI-108, Ice Condenser Doors, requires

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that the opening torque of the lower and intermediate deck doors

be checked once a year and the upper deck doors be inspected once

' . every 90 days. This surveillance is normally conducted after ice

basket servicing and would verify the removal of the blocking

l devices used during the servicing period.

, One deficiency noted was that these procedures do not control removal

l 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)

2 The inspectors observed Technical Specification (TS) required surveillance

! testing and verified that testing was performed in accordance with adequate

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procedures; that test instrumentation was calibrated; that limiting

j 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

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 " Remote Shutdown Monitoring Instrumentation Steam

Generator Level (Refueling Cycle)"

SI-166.6 " Post Maintenance Testing of Category "A" and "B"

Valves"

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SI-90.6 " Reactor Trip Quarterly Functional Tests"

, SI-170.2, " Periodic Calibration of the Standby Diesel Generator

} 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.

I . 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

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from maintaining operating speed. This indicates that the controller

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

i 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

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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

45N2630-56

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Quality Assurance Form 575-558-85-0136

Sequoyah Nuclear Plant Standard Practice (SQM-1) Sequoyah Nuclear

Plant Maintenance Program

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Surveillance Instruction (SI-166.6) Post Maintenance Testing of

Category A and B Valves

Nuclear Quality Assurance Manual (NQAM)

Masoneilan Technical Instruction 2035E

l

The inspector observed technicians performing the maintenance under MR l

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 l

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

Inoperable

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

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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

Inoperable

83113 Inoperable Steam Generator Blowdown Radiation

Monitor

83115 Auxiliary Building Gas Treatment System Discharge

Damper Operator Found Disconnected

83123 Inoperable 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

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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 , '. i

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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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