ML20150A679
| ML20150A679 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 02/26/1988 |
| From: | Brady J, Mccoy F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20150A667 | List: |
| References | |
| 50-327-88-06, 50-327-88-6, 50-328-88-06, 50-328-88-6, NUDOCS 8803150380 | |
| Download: ML20150A679 (22) | |
See also: IR 05000327/1988006
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UNITED STAT ES
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NUCLEAR REGULATORY COMMISSION
REGloN 11
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101 MARIETTA SThE ET, N.W.
ATL ANT A, GEORGI A 30323
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Report Nos.:
50-327/88-06 and 50-328/88-06
Licensee:
Tennessee Valley Authority
6N38 A Lookout Place
1101 Market Street
Chattanooga, TN 37402-2801
Docket Nos.:
50-527 and 50-328
License Nos.:
Facility Name:
Sequoyah 1 and 2
Inspection Conducted: January 4-8, 1988 and January 19, 1988
8l. /Y 80t/b-
z/zz/sn
Team Leader:
B.Brady,yojectEngineer
Date' Signed
Sequoyah Inspection Programs,
Division of TVA Projects
Team Members:
M. Good
G. Hunegs
A. Long
P. Moore
W. Poertner
T. Powell
R. Schin
Approved by / /
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4
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rFr R, Mjtoy~ ~CFief, Sequoyah Inspection
/ Dat'5' Signed
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Programs Section
Division of TVA Projects
SUMMARY
Scope: This special, announced inspection was conducted in the area of system
alignment verification for Unit 2 heatup. The inspection consisted of review of
administrative procedures and personnel qualifications, observation of the
licensee's accomplishment of the System Operating Instruction (501) checklists,
and independent verification of system alignment.
Conclusions:
The team determined that the licensee's configuration control
program (completed S0I checklists combined with configuration control log
entries) was adequate to support heatup.
8803150300 880301
ADOCK 05000327
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Violations identified during this inspection include:
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Violation.327,328/88-06-01, which is a violation of, Technical Specification
(TS) 6.S.1 for failure to adequately establish, implement, and maintain
written procedures for configuration control.
Examples' include:
1)
. Failure to. specify in'AI-58 the qualification' criteria for.
indiv.iduals performing independent verification of S0I checklists
(paragraph 4.a),
2)
Failure to record the position changes in the configuration log for
Post Accident Sampling System (PASS) valve breakers and instrument
. root valve 1-268A (paragraphs 6.b.3 and 6.a).
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Violation 327,328/88-06-02, which is a violation of 10 CFR 50, Appendix B,
Criterion XVI for failure of the system alignment corrective action
program to eliminate SOI checklist inadequacies prior to restarting the
system alignment process (paragraph 6.b.4).
Violation 327,328/88-06-03. which is 4 violation of 10 CFR 50, Appendix B,
Criterion V for fatiure to establish and implement adequate procedures
and/or practices to prevent storage of loose conductive material in
safety-related electrical boards (paragraph 6.b.5).
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REPORT DETAILS
1.
Licensee Employees Contacted
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- J. Anthony, Operations Group Manager
- R. Buchholz, Sequoyah Site Representative
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- J. Bynum, Assistant Manager of Nuclear Power
- S. Childers, Procedures
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- W. Gamble, Instrument Maintenance General Foreman
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- T. Howard, Division of Nuclear Quality Assurance
- G. Kirk, Compliance Licensing Manager
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- R. Loverne, Compliance Licensing Engineer
- J.
Patrick, Shift Supervisor
S. Smith, Plant Manager
- H. Tirey, Operations System Alignment Team Leader
J. Walker, Assistant Operations Group Manager
- B. Willis, Operations Plant Superintendent
- G. Wilson, Assistant Operations Group Manager
Other licensee employees contacted included technicians, operators, shift
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enginaers, and engineers.
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- Attended January 8 exit interview
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- Attended January 19 exit interview
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- Attended both exit interviews
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2.
Exit Interview
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The inspection scope and findings were summarized with the Operations
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Superintendent and members of his staff on January 8 and January 19, 1988.
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The licensee acknowledged the inspection findings and did not identify as
proprietary any of the material reviewed by the inspectors during this
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inspection.
During the inspection, frequent discussions were held with
the Plant Manager, Operatior.s Superintendent, and other managers
concerning inspection findings.
3.
Licensee Action on Previous Enforcement Matters (92702)
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(0 pen) VIO 327, 328/87-66-01; Failure to Establish, Implement, and
Maintain Procedures for System Alignment.
The licensee upgraded system
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alignment procedure OSLA-58 to Administrative Instruction AI-58 and
corrected inadequacies in the instruction.
Configuration control was
specifically identified to begin when checklist performance begins. A
form was added to provide the proper method for deviating from SOI
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checklists to conform with TS requirements for procedure changes (Appendix
B). Additional comments on the review of AI-58 are contained in paragraph
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4 below.
This item is considered acceptable for heatup based on the
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licensee's corrective action but remains open pending review of the
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licensee's formal response.
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(0 pen) VIO 327,328/87-66-02; Failure to Have an Adequate S01 for the
Emergency Core Cooling System.
The Emergency Core Cooling System
checklists were reviewed to verify that the equipment identified in the
violation had been added to the S0I checklists.
Prior to restarting the
system alignment program the licensee had considered the generic
significance of this violation and performed a verification per OSLA 107
Appendix B of all system alignment checklists.
The checklists were
verified against the plant and against the drawings to ensure that all
necessary equipment was included on the checklists.
Discrepancies from
the OSLA 107 Appendix B review that required corrections to the SOI
checklists were accomplished by the licensee prior to reperformance of any
checklist.
This item is considered acceptable for heattp based on the
licensee's corrective action, but remains cpen pending review of the
licensee's formal response.
4.
Administrative Controls
The inspectors reviewed the adequacy of the administrative procedures
controlling system alignment verifications.
In response to findings of
NRC Inspection 50-327,328/87-66, the licensee upgraded Operations Section
Letter OSLA-58 to an Administrative Instruction, AI-58, "Maintaining
Cognizance of Operational Status - Configuration Status Control".
The inspectors reviewed the adequacy of Al-58, Revision 0, for controlling
system alignment verifications,
a.
Personnel Qualifications and Certification
The inspectors reviewed the adequacy and the implementation of
procedural
requirements for the qualifications of personnel.
Qualifications for personnel performing valve alignment and power
availability checklists were not adequately specified in plant
procedures. Procedure AI-37, "Independent Verification", requirea in
Section
4.1.8
that each plant section establish a minimum
qualification
level
for
individuals
performing
independent
verification. The previous instruction, OSLA-58, had given specific
requirements
for
the qualifications of personnel
performing
checklists, stating:
Licensed Operations personnel (i.e. , Group Managers, SEs, ASEs,
UOs), non-licensed U0s, AU0s, and C-4 SR0s may perform
verifications on valve checklists or power availability
checklists.
These requirements had been deleted in Revision 0 of Al-58.
The
inspector identified through conversations with licensee
management that the minimum acceptable qualification level for
persons
performing
system alignment verifications was still
considered to be certification as an Auxiliary Unit Operator (AVO)
plus additional training on all relevant procedures.
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The licensee stated that all of the system alignment personnel were
certified AV0s at either Sequoyah, Watts Bar, or Bellefonte. During
NRC inspection 50-327,328/87-66, it was determined that if AU0s from
a plant other than Sequoyah were to perform system alignment
verifications, then a formal certification would be required that
they had received plant-specific training which qualified them to
perform that job. During Inspection 87-66, such certification sheets
were generated by the licensee for each individual. The inspector
determined that additional non-Sequoyah AV0s had joined the system
alignment team subsequent to Inspection 87-66, but the agreed-upon
certification sheets were not available. In addition, the previously
inspected certificaticns could not be located when requested by the
inspector.
Thus there was no written certification that the
alignment personnel were qualified.
The inspector was provided with attendance sheets for a number of
procedure training sessions which had been conducted. All but one of
the persons performing the alignment checklists had attended one or
more training sessions on AI-16, AI-58, AI-37, AI-25, and AI-30.
This procedure training was assumed by the inspector to define the
established minimum training as required by AI-37.
The individual
who did not receive this training was a certified Sequoyah AVO.
Licensee management stated that they believe him to possess
sufficient knowledge to have satisfactorily performed the checklists.
However, the licensee had not waived the procedure training for any
other Sequoyah AVO.
Because not all of the other individuals
attended the same number of sessions or sessions of approximately the
same length, it was difficult for the inspector to assess exactly
what amount of training was considered necessary.
The inspector noted that no formal training was conducted on G01-6,
"Apparatus Operations", which provides guidance for operating and
verifying the position of plant equipment including valves and
alectrical components. The previous certification sheets had stated
that the individuals had been formally trained on G01-6. The licensee
stated that the alignment personnel had been instructed to read
G01-6, and that the requirements of the procedure were frequently
covered in the regular shift briefing sessions.
The inspector
questioned several of the alignment team members and determined that
at least two persons appeared not to be aware of the requirement of
GOI-6 that each person physically verify the position of each
manually operated valve not locked in position.
These individuals
stated that the second verifier must only be in close proximity as
the first person verifies the valve position, and they each quoted
the example from AI-37 that both persons must climb the ladder if
this is required to get to a valve.
The inspector concluded that
training on G01-6 had not been adequate in all cases.
The licensee was informed of the statements made to the inspector
that physical verification of valve positions was not required by
both independent verifiers. It was then learned from the licensee
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that permission had been given to one AVO, due to lack of physical
strength, not to independently physically verify valve positions as
required by G01-6 as long as the partner's verification was closely
witnessed.
This particular AVO was not one of the individuals
questioned earlier by the inspector, so the problem was not limited
to that one special case. Licensee management, when informed, agreed
to question all their alignment personnel and to reverify the
position of any components which had not been physically verified by
two individuals in accordance with the requirements of AI-37 and
G01-6.
The failure to adequately specify the qualifications for personnel
perforniing system alignment verifications, and the resulting failure
to train and formally certify these personnel, are considered a
violation of TS 6.8.1 for failure to establish, implement, and
maintain written procedures for configuration control and is
identified as Violation 327,328/88-06-01,
b.
Configuration Control
The inspector assessed the adequacy of the configuration control
. provisions of AI-58 by interviewing personnel and witnessing how the
procedure was being used.
The licensee showed the inspector how
each of the major procedural requirements were being implemented,
including maintaining the Status Notebooks, Test Awareness Log, and
Configuration Log, processing checklist deviations; and holding
checklists open until all items were cleared.
The inspector also
discussed with licensee personnel the criteria and the process for
making configuration log entries and using drop sheets. Interactions
between the unit operators and the system alignment team were closely
observed to assess the level of effective communication.
The inspector concluded that an adequate awareness of the plant
configuration was being maintained and the checklist performance was
being well controlled. AI-58, as the inspector witnessed it being
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implemented, provided an adequate method for controlling system
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configuration. All personnel interviewed had an adequate and uniform
understanding of the requirements of the procedure.
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Configuration log entries were not required by AI-58 for activities
controlled by approved procedures which provide configuration control
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and return to normal within the procedure.
The lead operator is
responsible for ensuring that these procedures do provide control and
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appropriate return to normal. AI-58 does not provide guidance for
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those occasions when a test is interrupted for long periods of time.
The inspector determined from personnel interviews that the lead
operator might enter an interrupted test into the configuration log
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if he considered it advisable.
It was noted that a provision had been added to Al-58 so that no
configuration log entry was required for out ,f position equipment if
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it was controlled from the control room and had positive position
indication (see paragraph 6.a for PASS valve example).
It appeared
that this provision was added to eliminate some configuration log
entries for sis lacking configuration control and adequate return to
normal within the procedure. Several members of the system alignment
team told the inspector that it was common practice for them to ask
the control room to momentarily reposition valves so that the
checklist entry could be signed off, then the valves were immediately
returned to their off-normal position (see paragraph 6a).
This was
relayed to licensee management, who stressed that it is not the
normal policy.
The inspectors reviewed Al-58 and discussed the following comments
with the licensee:
Section 3.2, Startin'
hecklist Performance, was discussed in
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detail with licens
personnel.
Paragraph (f) specifically
addresses when centiguration control should begin, but was
pointed out by the inspectors to be unclear.
Since ensuring
that configuration control begins when checklist p rformance
starts is essential to having an adequate configuration control
program, the licensee was encouraged to ensure that this
paragraph be clarified. A revision was reviewed at the end of
the inspection which appeared to be much clearer concerning this
subject.
Section 1.4 required clarification to differentiate between
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approvals for checklist deviations and normal configuration log
entries.
Specified approvals for checklist deviations and for normal
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configuration log entries should be expressed consistently
throughout the procedure, and the titles for the approving
individuals should be consistent with Technical Specifications.
Whenever appropriate, it should be specified that the approving
senior reactor operator (SRO) is the shif t supervisor (SS) or
assistant SS (ASS) on shift.
Required approval by an
independent Qualified Review (QR) trained individual should be
specified in each applicable portion of AI-58.
Section 2.2.2(c) stated that both the SS/SR0 and ASS /SRO will
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approve configuration log entries "During initial or update
checklist performance." This contradicted the practice observed
by the inspector for configuration log entries made prior to
checklist completion. Prior to checklist completion, Appendix B
forms were approved only by a single SRO. Approval by both the
SS and ASS was intended by the licensee only for actual
checklist deviations made to close the checklist, not when using
the Appendix B form as a tracking device during checklist
performance. The AI-58 procedure should be revised to reflect
the plant practice.
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Section 3.5(a) states that Appendix B will track the status of
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the deviated item (s) until placed in their norma *i o.:cklist
position (s).
Appendix
B
has
signoffs
for
independeat
verification when returning components to normal; however, the
licensee stated that position changes .will be made only in
accordance with approved procedures. The Appendix B sheets are
only for documentation of the change. AI-58 should explicitly
state that Appendix B sheets should only be used in conjunction
with a procedure for returning equipment to normal.
Other items of an editorial nature were also brought to the
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attention of the licensee.
5.
Observation Of The Licensee's System Alignment Process
a.
Observation of Checklist Performance
To verify the adequacy and the implementation of the licensee's
system alignment program, the inspectors accompanied licensee systems
alignment teams in performing all or portions of the following SOI
checklists:
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SOI Checklist No.
System Title
70.1A-1, Rev. 40
Component Cooling
67.1A-9, Rev. 34
Essential Raw Cooling Water
67.1A-11, Rev. 34
Essential Raw Cooling Water
As the inspectors observed the performance of the licensee teams,
they noted in particular whether they were able to adequately
complete the checklists and whether the checklist adequately
described the items, the item location, and the required position of
the items on the checklist. Overall, the performance of the
licensee's system alignment team appeared to be adequate.
b.
Review of Completed Checklists
The inspectors reviewed selected completed valve alignment checklists
for adherence to procedurai requirements.
Procedure AI-58 allows deviations of items that will not be aligned
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normal and will not impact mode changes, system operability, or
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performance of other instructions.
Licensce personnel told the
inspector that as of the time of the inspection, only four SOI
checklists had been deviated.
Other checklists with outstanding
items were being held open until the items could be completed. The
inspector reviewed these deviations, which were to components in
systems 15, 62, 78, and 82, and concurred with the licensee's
determination that these items met the criteria in AI-58 and could be
deviated.
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When a checklist is deviated, Section 3.5 of AI-58 requires that the
SS/SRO and the ASS /SR0 initial and date the status file checklist in
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the margin beside the deviated item's signoff space. The inspector
determined that deviated items in Valve Checklist 15-1, completed
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December 11, 1987, had not been initialed and dated by the SS/SRO
as required by AI-58.
This finding is similar to example 4 of
Violation 327, 328/87-66-01, and was identified to the licensee as
an additional example of that violation.
Licensee personnel told the inspector that certain out-of position
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components in SOI checklists could not be placed in their normal
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at power positions prior to entering Mode 4 but could not be deviated
per AI-58 because they affected system operability or mode change.
Most of these components were positioned for shutdown per G01-3.
Therefore, the licensee planned to enter Mode 4 with certain
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checklists open, then place the components in their normal position
and close the checklists. The inspector requested that the licensee
provide a list of all the checklist items which were to be cleared
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af ter entering Mode 4.
A number of the items provided to the
inspector were in the containment spray system, which is required by
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Technical Specifications to be operable prior to entering Mode 4.
When this discrepancy was brought to the attention of licensee
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management, it was determined to be a misunderstanding between
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licensee management and operations personnel. Only items that were
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not required for mode change would be held open when changing modes.
The licensee stated that they had always intended to clear all
checklist items necessary for operability of containment spray prior
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to entering Mode 4.
6.
Independent System Alignment Verification (71710)
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The independent inspection was accomplished by comparing applicable
portions of selected as-built reference drawings to the SOI checklists and
the plant configurations. The comparison determined whether all equipment
within a particular system was included on the SOI checklists and whether
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the drawings actually reflected the as-built configuration of the plant.
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After the checklist: were verified, a comparison was made by the
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inspectors with the completed checklists in the main control room status
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files to ensure that any differences could be accrunted for. In addition,
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the inspectors randomly selected various work requests that were observed
on equipment from completed checklists and ensured that these work
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requests did not render the equipment inoperable.
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a.
Valve Checklists
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The inspectors independently verified the alignment of all or
portions of the following SOI valve cher.klists to assess checklist
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adequacy and implementation:
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SOI Checklist
' System Title
15-1
Steam Generator Blowdown
32.2-1
Auxiliary Air System
32.2-2
Auxiliary Air System
61.1A-1
Glycol System
62.4A-3
Chemical & Volume Control
62.4A-4
Chemical & Volume Control
62.2-1
Chemical & Volume Control
62.5-2
Chemical & Volume Control
62.5-4
Chemical & Volume Control
63.1A-1
Emergency Core Cooling
63.1A-3
Emergency Core Cooling
63.1A-4
Emergency Core Cooling
72.1A-1
82.1 F-1
Diesel Generator
The following findings pertain to specific items on the valve
checklists:
(1) On checklist 15-1, pages 42-49, valves that were not in their
proper position were covered under test procedures or
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outstanding S0ls with the exception of valve 1-268A, root valve
to FI-1-152, which was found closed. The inspector reviewed the
main control room status file and the configuration log.
The
valve was neither shown as out of position on the master status
file checklist nor logged in the configuration log. Discussions
with operations personnel did not reveal a reason for the valve
being out of position.
This is considered as an additional
example of Violation 327,328/88-06-01 for failure to establish,
implement, and maintain configuration control procedures.
(2) The inspector noted that the vent and fill valves for the
chemical mixing tank were not on any checklist. These valves
are, however, adequately controlled through SOI 62.3,
SOI
62.381, and S01 62.3C which pertain to chemical addition.
(3) Two valves on checklist 61.1A-1 were found to be named
incorrectly. Valve 61-1186 was named "glycol supply drain" on
the nameplate while the checklist name was "test vent
isolation".
Similarly valve 61-1188 was named "glycol return
drain" on the nameplate while the checklist name was "test vent
isolation".
The nameplate names were found to agree with the
reference drawing >.
The licensee agreed to change the names on
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the checklist to agree with the valve nameplates and the
drawings.
(4) During the walkdown of valve checklists 32.2-1 and 32.2-2 for
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the auxiliary air system, the inspector noted hold order
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- 2-88-050 located on auxiliary air compressor B-B. A semi-annual
PM was in progress on the air compressor to disassemble,
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inspect, and replace rings, gaskets, and oil. A check of ths
clearance log and configuration log revealed that both were
properly documented for this work. In addition, a work reqvest
tag (#B275760) was found on control air header B train B
pressure gauge #PI-32-89. According to the computer thir work
(calibrate
and
install
had been
completed
on
September 25, 1987.
(5) During the walkdown of valve checklists 62.4A-3 and 52.4A-4 on
the chemical and volume control system, two valves were found
out of position from the checklists. Valves62-901 and 62-902,
the mixed bed demineralizer A inlet and outlet isolation valves,
were found in the open position when the checklist identified
their position as closed. A review of the main control room
status file revealed that the checklist had been completed on
December 28, 1987.
There was no configuration log entry for
these valves. Discussions with Unit 2 operators revealed that
one mixed bed demineralizer is normally in service for primary
coolant chemistry control;
however,
tne checklist valve
positions reflect all of these demineralizers in standby with
none in service. Al-58 paragraph 2.2.2.1.b allows an exception
to making configuration log entries if the operation is
controlled by a category A or B SOI and is logged in the
operator's journal at the commencement and completion of the
operation.
50I 62.4A, revision 18, page 18, is the procedure
used for placing mixed bed denineralizer A in service and is
identified as a category A SOI. A review of the daily unit
operation's log for 12/28/87 showed the following entries:
0950 CCS 2A demineralizer removed from service
1007 CCS 2A demineralizer placed in service
Operations personnel told the inspector that the Unit 2 mixed
bed demineralizer A had been removed from service 17 minutes to
accommodate completion of the SOI checklist and was then
returned to service.
Realigning components solely for the
purpose of saying that a checklist is complete, and then
returning the components to their previous position is not the
intent of conducting the checklists. Although AI-58 does not
spe:ifically disallow this type of activity, AI-58 does provide
a method for deviating from or temporarily changing a checklist
(Appendix B form).
In discussions with the licensee's Quality Assurance department
concerning their review of the system alignment process, a QA
inspector described a situation similar to the above.
The QA
inspector observed a situation where an Appendix B form had been
filled out for a particular valve which had a hold order tag on
it.
Because the assistant SS and the SS were not qualified
reviewers, a third individual's signature was required in order
to complete the Appendix B form. The qualified reviewer would
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not sign the Appendix B form. The QA inspector said that'the
assistant SS and SS in the process of clearing the hold order
tag to reposition the valve so that the item could be signed off
on the checklist when he. interrupted them. They had intended to
immediately reposition the valve back to its previous position
and rehang the tag af ter the checklist signoff. He explained
that they would be defeating both the intent and the purpcse of
performing the checklist by continuing down the path that they
had chosen.
Although the activities described above did not appear to have
put equipment in an unsafe condition, these activities are
indicative of a lack of adequate operator training (paragraph
4a) and of checklists that were sent to the field which did not
adequately address the required positions of equipment (see
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paragraph 6b for a further discussion of checklist adequacy),
b.
Power Availability Checklists
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The inspectors independently verified the alignment of all or
portions of the following SOI power availability checklists:
SOI Checklist
System Title
1.1A-1
32.1A-2
Auxiliary Control Air
43.2A
Hydrogen Analyzer and Post
Accident Sampling
62.5-2
Chemical & Volume Control
62.6A-1
Chemical & Volume Control
67.1E-2
Essential Raw Cooling Water
68.3A
82.3J
Diesel Generators
92.1
Nuclear Instrumentation
The following findings pertain to power availability checklist:
(1) Main Steam (System 30)
The inspector verified all of main steam checklist 1.1A1.
Work request B229966 was found on 125V Vital Battery Board III
on breaker 210.
The breaker was closed, which was correct
according to the checklist.
During subsequent investigation,
the licensee reported to inspectors that the work request was
complete and signed off.
The rear section of 125V DC Vital Battery Poard III was dirty
and contained cut tie wrap pieces and wire strip cutoffs.
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The Auxiliary Control Room Control Transfer Switch XS-1-24B for
PORV Loop 3, Train A, PCV-1-23 appeared to be mislabeled on
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Auxiliary Control Room Panel 2-L-11A.
The switch t as labeled
"SG #3 Blowdown Hi.R Press" rather than '"Main STM HDR Press".
The labeling _ was not consistent with the checklist or-
nomenclature in A01-27, Control Room inaccessibility.
A valve position indicator light was burnt out on the 480V
Reactor MOV Board 2A2-A, Compartment 2A (2-FCV-1-17).
A valve position indicator light was burnt out on the 480V
Reactor MOV Board 2B2-B, compartment 2A (2-FCV-1-18).
(2) Auxiliary Cont.rol Air (System 32)
The inspector verified all of power availability checklist
32.1A-2.
The Unit. I and Unit 2 Control Copies of 501-32.1A were missing
page 1
of 3 for Power Availability Checklist 32.1A-2.
Subsequent licensee investigation revealed that the page was
probably missed during
reproduction
and
that no
page
l
.
.
verification was done when the revision was entered into the
I
control room controlled document.
NRC inspectors verified the
status file copy of the completed checklist as having all pages.
Breaker labeling inconsistencies existed between the checklist
and breaker label on 120V AC Vital Boards 1-1 and 1-II for
l
breaker 30. Consistent labeling facilitates equipment isolation
j
in the event of equipment fault, personnel injury, or fire.
(3) Hydrogen Analyzer and Post Accident Sampling (System 43)
The inspector verified all of power availability checklist
43.2A.
The following two breakers were not in the position required by
checklist 43.2A:
Breaker
Required
As Verified
120V AC Vital
Instrument PWR BD
2-III, Breaker 17
Open
Closed
2-IV, Breaker 17
Open
Closed
Power Availability Checklist 43.2A was conducted and signed as
complete on December 19, 1987.
A review of the checklist
indicated both breakers were verified open on that date. The
configuration status log was reviewed by control room operators
- .
12
and contained no entries to indicate a change in status for
Breaker 17 on 120V AC Vital Instrument Boards 2-III and 2-IV.
Subsequent licensee investigation revealed that Surveillance
Instruction (SI) 722 "QMDS Valve Stroking" and SI 166.5., "Full
Stroking of Type A & B Valves", had been conducted.
These
surveillances would have required the breakers to be closed.
The licensee's investigation and discussion with operators
conducting the surveillance indicated that most probably the
breakers wer closed to conduct 51-722 on December 22, 1987, and
were not repositioned af ter the SI. No configuration log entry
was made, contrary to the requirements of Administrative
Instruction AI-58.
The lack of configuration control
had potential
safety
significance because having power supplied to the Post Accident
Sampling Valves would cause the unit te enter Limiting Condition
for Operation (LCO) 3.6.1.1 in Modes 1, 2, 3, 4 and LCO 3.9.4
when in Mode 6.
51-14. "Verification of Containment Integrity",
is conducted every 31 days in Modes 1, 2, 3, 4 and 5 should have
caught and corrected the error. However, had the configuration
error occurred after 51-14 performance, a mode change could have
occurred, causing unknowing entry into an LCO.51-722 and SI-166.1 could also have prevented the occurrence if
they had contained specific instructions concerning realignment
status of the valves / breakers in question.
This
is
- onsidered
as
an
additional
example
of
.
Violatior. e7,328/88-06-01 for failure to establish, implement,
and maint 1n configuration control procedures.
(4) Chemical Volume and Control (System 62)
The inspector verified all of power availability checklists
62.5-2 and 62.6A-1 with the exception of 8 covered fuses in
Panel 0-L-206. No deficiencies were noted on power availability
checklist 62.5-2.
Power Availability Checklist 62.6A-1 had one observed def t-
ciency. The boric acid evaporator package
"B" normal control
power breaker (125-V de Vital Battery 80 IV Breaker 318) did not
have a required position on Checklist 62,6A-1. The status file
checklist had verified the breaker with no annotation on the
completed checklist of breaker position.
The inspectors conducted a table top review of other power
availability checklists to determine the scope of this
problem.
The inspectors identified that breaker positions
were
not
specified
for
several
breakers on
checklist
61.1B-1 and 63.10.
Checklist 61.1A-1 had a column entitled
f
. . .
,
T
'
13
i
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>
"Power fuses
Installed"
and
a column
entitled
"Fuses
Installed".
Under the column "Power Fuses Installed" were
listed 125V Vital Battery Board breakers with no fuse
descriptions.
In addition, checklist 1.1A-2, page 8,
was
I
unclear in that it listed only ore pcwer supply position
.;
while nine valve identification If ne items are listed.
No
'
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1
explanation was given on the checklist as to whether this
one power tupply item applied to all nine valve line items.
During the review the inspector coticed a number of inconsis-
tencies in the description of breaker positions on power
s
,
availability checklists.
The breaker position descriptions
- i
'
included "closed", "connected", "bus energized anc breaker
connected",
"bus
energized and breaker closed", "board
'
energized", "board energized and/or breaker connected", and
"board energized and breaker connected".
It was not clear to
the inspectors what the prerson performing sthe checklist was
supposed to check, or if the position specified for the item was
actually a posttion the equipment could be in. During a telecon
on January 12, 1988 licensee management was asked what the
breaker position "connected" meant.
It was explained that
"connected" referred to a breaker that was racked-in.
The
.
inspector asked if a position in addition to "connected" needed
s
to be tpecified to ensure that the equipment was in the proper
'
position.
Licensee management explained that breakers on the
6.9 KV shutdown bsards and 480 V shutdown boards would have the
-
breaker only connected (racked-in). The licensee explained that
this was acceptable since this equipment is controlled by
proccdure, and repositioning the breaker starts or stops the
s ,
equipment and does not just provide power availability. The
g'
inspector pointed out examples of reactor MOV board breakers
that also had positions described as connected.
The licensee
acknowledged . that these breakers do not rack in or out and
that the pcsitten connected in this case was unclear.
The licensee initiated a review of the power availability
checklists to assess 4hether or not the breaker position
"connected" was appropriately used in all cases. On January 15
a telecon was conducteo tetween the inspectors and licensee
management.
The licensed i evaluation had revealeo that for
various large breakers, "connected" was equivalent to "racked
in" and adequately described the required configuration.
However, for numerous other smaller breakers which do not rack
in, the intended configuration was that tkese breakers be
"closed".
Examples of where "connected" and "closed" had not
been properly used were identified by the licensee to exist in
27 checklists for 14 different 5015. In adhtien, the licensee
,
had reverified the positions for all affected equipment in these
27 checklists and found that none were out of position.
The
licensee stated, based on the above information, that they
strongly believed the system alignment personnel knew based on
their general plant knowledge that in these cases "connected"
me.r.at closed. They stated that none of these smaller b eakers
on the checklists were intended to be in the open position. The
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.
(:
14
1
inspectors noted that the licensee's review also found several
instances where "closed" was the position specified on the
checklist but "connected" should have been the proper position.
The inspectors concluded that this problem was aggravated by the
use of column headings on a checklist that listed the required
position for numerous components on a single page, when the
components listed included a mixture of breakers, fuses, power
available lights, and disconnect switches.
On January 19, a second exit meeting was conducted on this
issue.
The inspectors emphasized to the licensee that the
purpose of performing the checklists is to ensure that all
hardwcre on the checklists are in the proper position for mode
,
change.
The licensee concurred with this statement.
The
licensee was asked, therefore, to ensure that for any other
positions on the checklists which could in any way be misinter-
preted, that they q'isure that the actual hardware is properly
/
positioned for mode change.
The licensee committed to do this
prior to changing modes.
,_
The inspector sampled this review and found it to be adequate.
Positions were reverified for all equipment that had descrip-
'
<
tions which could have in any way been misinterpreted.
Several examples noted during the inspector's review of the
reverification are provided for information.
These examples
i
supplement exanples fcf od by inspectors and further indicate the
extent of the problem and the need for comprehensive review.
On Checklist 3.2A-1, page 3, "connected" was used to mean
racked in.
!
On Checklist 62.1B-1, pages 1-9, "energized" was used to
mean breaker closed, and page 9 had 2 alarm breakers with
no position listed,
i
!
On Checklist 13.1, page 1, "normally closed" was used to
mean closed.
On Checklist 30.5E-1, page 1, three fuses, 0-FU3-30-147-A,
lacked faformation on required position.
On Checki .'st 30.7, page 4 lacked fuse identification for
fuses for FSV-31C-303 and FSV-31C-340.
On Checklist 63.10, page 6 had three breakers with no
required position,
On Checklist 70.1A-2, pages 1, 9, and 14 each had one
breaker with no required position.
On Checklist 77.1Al-1, page 2, RCOT to Sump 1-FCV-77-3,
required breakers on 125 VDC vital battery boards I, II,
'
.
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AI
ly
!) ,
f
- .
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'
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,
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1
15
m
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c
,
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6
.and III were not listed. The s'ame problem was identified-
on page 3 with 1-LCV-77-415.
Jl
'
,
( j ', ,'4
7
.
_'
'
On Checklist 82.2J, page 1, "Jelumn C energized" vas used
i
F
to mean breaker 212 closed
ir
,
On Chect.!d st 82.4J, page 2, three < disconnect switches had
I
no posiVihns listed.
~
..
'<
<
On Checklist 90.1A, page 2, three breakers had no lii,ted
g
f
position.
9
On Checklist 90.1A,' page 3, one breaker had no position
'
listed.
1
action program hor Violation
The failure of the corrective
327,328/87-66-02
to
adequately
eliminate
SOI
checklist
inadequacies
prior to
restarting
the
system alignment
process is considered a violation of,10 CFR 50, Appendix B,
,
Criterion XVI
for failure
to
take adequate
corrective
actionandisejesignatedViolation 327,328/88-06-02.
(5) Diesel Generator (System 82)
v ?f ,
.
verified
all
of diesel
generator
oower
,
,
' fl
The
inspector,
availability eneckli st 82.3J, . Revision 32 "Diesel Generator
[{/
2A'-A",
except for the fuse sizqs on six sets of fuses.
. k.
Verification of those- fuses requiged fuse removal which would
<
have rendered the diesel generator' inoperable. All* breakers and
-()/
fus45 checked were,found to be in accordance with't b checkiftt.4
j
The fo1%irig deficiencies with the electrical board inspeeped
.l
were noted:
[j
(
/
_
<
!
Duri,ng the <verifibation step on checklist page 1, fbr o'iesel
t
gt $ ptor ,2A-A Controls AnnQejat'or,
the diesel' generator
' distribution panel was noted icy dontain debris consisting of
wire cut'nffs, tie-wraps and dipt.
This was considered,?o be a
poor maini.enance practice.
I\\
04 ring thyvdrification step for the Diesel Exhaust Monitor TC
'
'
'
Altrm .?phlys and Diesel Gencrator Electric Governor Rheostat,N.
checklist page S/, a box of fuses was found lying in the lowe
i
area of the pahel near all ' of the fuse clips.
Licensee
operations p,ersonnel stated that these were spare fuses.
The
- '
inspectors had significant concerns that the storage or presence
of conductive material in a panel might invalidate seismic
-
5
qualification.
Equipment or entire electrical boards could
be rendered inoperable during a seismic event due to the
-
i
acceleration of material (conductive or non-conductive 1 >within
!
y
i
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'
.
"
y
,
,
ff
I
y
/' f
I
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-
-
,
w &
, ' ,r!
,
,
- _ _ _ _ _
_
-
,
,
'iy
r
16
e
.! b $7
an electrical board.
The' potential for damage due to shorting
and arcing in the area of fuse clips is high because the spacing
between fuse clips is generally small.
During subsequent investigation by the licensee,. it was
determined that Administrative Instruction AI-3, Revision 37,
"Clearances," Section 5.2.1.3 allowed storage of fuses removed
from tagging for single circuit compartments and non-control
circuits within the compartment.
Non-control circuits were
defined as bus potential transformers, voltage regulator
potential transformers, metering transformers, etc.
Al-3 was
revised to prohibit fuses which were removed due to tagging for
any fused circuit from being stored within a panel. All Shift
Supervisors, Assistant Shift Supervisors, and Unit Operators
received training on the change during shif t turnover briefings.
In addition. the Operations Superintendent issued an instruction
letter to each of the same operators.
The inspector's concern about conductive material within seismic
electrical boards was brought to the immediate attention of
licensee management.
Based on the concern,
the license
J'
commenced a walkdown of all safety-related electrical boards to
.
inspect for cleanliness, stored fuses, or other debris. As a
result of the walkdown inspections, e large amount of conductive
material and miscellaneous debris was discovered in numerous
-
safety-related panels. A summary of the licensee's findings is
presented below for information.
~
480 Volt Shutdown Board 2A2-A:
Five loose fuses in front side ficor in compartment 6
Five loose bolts on back side floor compartr..ent 5
Nine locknuts on back side floor compartment 4
Two unused loose bus tie bars, numerous small screws and
washers on back side of compartment 3
Paper ball, metal ID tag and tiewrap (act removed during
walkJown due to cloe? proximity to hot bus)
Logic Panels:
Numerous small screws, light bulbs, pieces of wire, lead
seals with wire, one 3" metal conduit plug.
480 Volt Shutdown Board 2Al-A:
Six fuses, two metal nameplates, screws, and several pieces
of wire (wire not removed due to close proximity to power)
in front of panel 6
_
)
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T'
.
.
17
Three unused' bus tie bars am! wire in back of panel 1
Washing and 3d bare wire in back of panel 3 (wire not
removed due to close proximity to power)
One large nut in back of panel 5 (left - close to power)-
One. red-head, fastener, large nut, 2 large lockwashers in
back of panel 6
Three unused bus tie bars loose in back of panel 8
480 Volt Shutdown Board 2B1-B:
Fourteen fuses and one metal ID. tag in the_ front of
' panel 6
One large boxes filled with junk (TVA's words) in the front
F
of panel 7
Three unused bus tie bars loose and a metal washer in the -
rear of panel 10
Three unused bus tie bars loose ar.d a piece of large wire
in the back of panel 8 (wire left due to close proximity to
power)
Two rubber gloves and one large metal washer in the back of.
panel 6 (on glove was laying on buswork - now removed)
480 Volt Shutdown Board 2B2-B:
Loose bolts, lockwashers, and nuts in the rear of
compartment 1
Six metal plates and 7 nuts in the rear of compartment B
Three large metal plates, 3 small metal plates, bolts,
nuts, and washers in the rear of compartment 9
480 Volt Reactor MOV Board 2B1-B:
3" piece of copper wire in compartment 1A
Light socket hanging loose in compartment 3E
Loose metal clip in compartment 9F
Loose connector, wire and screws in compartment 11F
Leose connector in compartment 3F
_ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ -
)
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- -
.
,
18
480 Volt Reactor MOV Board 2B2-B:
Various loose screws, wires, and connectors in board-
480 Volt Reactor MOV Board 182-B:
Six pieces of wire in compartment 11A
Two heater coils in compartment 9E
Loose board component below compartment 4E
480 Volt Reactor MOV Board 1B1-B:
Loose unused conduit above compartment 3A
6.9KV Shutdown Board 28-B:
Loose fuse and wire tie in compartment 19
Clamp and Lung in compartment 18
.
Breater dolly in compartment 7
Compartments 1,
3,
5,
6,
8,
10, 11, 13, 20 had a
compartment slide door knob missing (door may fall)
6.9KV Shutdown Board 2A-A:
Loose washers, screws and wire tie in compartment 2
Loose screws, lug and cap in compartment 4
Compartments 1, 6,
10, 13, 15, 16, 18, 21, 22 missing
compartment slide door knobs
In compartment 6, 2-HS-57-46C incorrectly label d as going
to 1A-A diesel generator
Discussions with the licensee indicated that loose material
within the safety-related electrical board most probably
resulted from a combination of maintenance and modification
activities.
The inspectors concluded that the discrepancies
did not appear to be isolated cacas, due to the large number
of
cases in numerous different electrical
boards.
The
discrepancies
indicate
inadequate control
of
electrical
maintenance and modifications on safety-related equipment and
systems.
The storage of
spare
fuses in safety-related
electrical
boards and the additional examples above are
considered a violation of 10 CFR 50, Appendix B, Criterion V,
-
__
J
~.
,
19
for failure to control activitics affecting quality and are
designated violation 327,328/88-06-03.
c.
Alignment of Instrumentation Valves
The inspector reviewed the licensee's control of instrumentation to
ensure operability.
The licensee's calibration program for safety
related instrumentation is controlled by the surveillance instruction
program. The inspector verified for selected TS related instruments
that the instruments were calibrated by the surveillance instruction
program and that the applicable instrument maintenance instructions
(IMI) independently verified the position of the instrument panel
valves.
The inspector reviewed SI-604, "Essential Instrumentation Operability
Verification".
The purpose of this SI is to ensure that the
essential surveillance instrumentation needed to monitor plant
processes during normal operating conditions is verified operable.
The inspector verified that for selected safety related systems, all
essential safety related instruments were included in SI-604. As a
.
result of NRC Inspection Report No. 327,328/87-52, the licensee
. committed to include all instrumentation in SI-604. This action will
be completed sometire after Unit 2 restart.
The inspector also reviewed IMI-134, "Configuration Control of
Instrument Maintenance Attivities".
IMI-134 provides configuration
control during instrument maintenance activities affecting CSSC
equipment. The inspector determined that the IMI provides adequate
configuration control during maintenance activities.
The inspector walked down numerous instrument sense lines in the
plant to verify proper valve position.
The inspector found no
instances where valves appeared to be out of position.
7.
General plant Condition
It was noted that there was a substantial amount of trash collection going
on in the containment.
This resulted in a lot of trash accumulating in
bags or being stacked in the raceway. This is understandable as the unit
is expected to begin heatup soon.
However, inspectors noted a good deal
of trash collecting at work sites in various rooms in containment.
Fan
room 1 demonstrated extremely poor housekeeping practices in the form of
paint can lids, tape rolls, hardhats, tools, and tethers. Of concern to
the inspectors was broken glass that was prevalent in the area,
particularly on scaffolding above cooler A-A.
The broken glass is drawn
attention to for two reasons:
1) It could possibly puncture protective
clothing and skin that could lead to undesirable contamination; and 2) It
indicates that personnel are not observing the minimum housekeeping
requirements.
Equipment is available for cleaning up broken glass, and
equipment and used containers should never be lef t around unless a work
activity is continuous.
Other discrepancies are noted below.
~
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..
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,
20
The pointer was missing from the glycol mixing pump suction gage.
A number of packing leaks were observed.
Component Cooling System pump 1B-B discharge valve, 1-70-505B, was
labeled as 2-70-505B.
Component cooling system piping, welds, and flange bolts were found
with moderately heavy rust on the piping to #1 RCP near check valve
70-628A in Unit 1 containment.
-
A borated water leak was observed in Unit 1 containment which
appeared to have been coming from valve FCV-62-69.
Boron deposits
were visible on beams, hangers, and piping, as well as on the floor.
Seieral areas inside Unf t 1 containment had water standing on the
floor.
In addition, housekeeping inside Unit I containment was
considered in need of improvement (parts, tools, and trash scattered
about).