ML20151W078
| ML20151W078 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 04/25/1988 |
| From: | Branch M, Jenison K, Long A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20151V938 | List: |
| References | |
| 50-327-88-20, 50-328-88-20, NUDOCS 8805030290 | |
| Download: ML20151W078 (36) | |
See also: IR 05000327/1988020
Text
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s UNITED ST ATES i
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NUCLEAR REGULATORY COMMISSION
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5 t 101 MARIETTA STREET. N.W., SUITE 2000
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ATLANTA, OEoRQlA 30323
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Report Nos.: 50-327/88-20, 50-328/88-20
Licenses: Tennessee Valley Authority
6N 38A Lookout Place
1101 Market Square
j Chattanooga, TN 37402-2801 ;
Docket Nos.: 50-327 and 50-328 License Nos.: DPR-77 and DPR-79 [
Facility Name: Sequoyah Units 1 and 2
Inspection Conducted: February 27, 1988 thru March 18, 1988
Project Engineers: O R . b my Vf2Sf?8
J. Brady, Project' Engineer D5te' Signed
G. Hunegs, Project Engineer
A. Long, Project Engineer
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Shift Inspectors: P. Harmon, Shift Inspector
F D. Loveless, Shift Inspector
[ W. Poertner, Shift Inspector ,
i G. Humphrey, Shift Inspector i
W. Bearden, Shift Inspector
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K. Ivey, Shift Inspector j
Shift Manager Approval: I 8 88
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V4 J'e nis on Shift Manager ' Date Signed
- hf O d 36 TT
M. ~ Branch, Shift Manager Date Signed
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8805030290 880427
PDR ADOCK 05000327
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Summary
Scog:- This announced inspection involved onshift and onsite inspections
by the NaC Restart Task Force. The majority of exponded inspection
e2 fort was in the areas of extended contrcl room observation and opera-
tional safety verification including operations performance, system
lineups, radiation protection, and safeguards and housekeeping inspec-
tions. Other areas inspected included maintenance observations, review
of previous inspection findings, follow-up of events, review of licensee
identified items, and review of inspector follow-up items. During this
period there was extensive control room and plant activity coverage by
NRC inspectors and managers.
Results: Four violations were identified:
327,328/88-20-01, Three Examples: Failures to develop or
implement procedures (paragraphs 10 and 11).
327,328/88-20-02: Missed surveillance test for the #3 cold leg
accumulator (paragraph 10). l
327,328/88-10-03: Failure to comply with Technical Specifica-
tion Limi+'.ng Condition for Operations (paragraph ll.b.6).
327,328/88-20-04: Failure to ensure timely notification of the
NRC of a loss of safety functions (paragraph ll.b.10).
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rep 0RT DETAILS
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1. Persons Contacted
Licensee Employees
- *H. Abercrombie, Site Director
J. Anthony, Operations Uroup Supervisor
- T. Arney, Quality Assurance Manager
- R. Beecken, Maintenance Superintendent
- R. Buchholz, Sequoyah Site Representative
- J. Bynum, Assistant Manager of Nuclear Power
M. Cooper, Licensing Supervisor
H. Elkins, Instrument Maintenance Group Manager
R. Fortenberry, Technical Support Supervisor
J. Hamilton, Quality Engineering Manager
- M. Harding, Licensing Group Manager
- G. Kirk, Compliance Supervisor
- J. La point, Deputy Site Director
- L. Martin, Site Quality Manager
R. Olson, Hodifications
R. Pierce, . Mechanical Maintenance Supervisor
R. Prince, Radiological Control Superintendent
- R. Rogers, Plant Operations Review Staff
M. Skarzinski, Electrical Maintenance Supervisor
E. Sliger, Manager of Projects
- S. Smith, Plant Manager
- S. Spenser. Nuclear Engineer, Compliance
- J. Sullivaa, Plant Operations Review Staff Supervisor
- B. Willis, Operations and Engineering Superintendent
NRC Employees
- S. Ebneter, Director, Office of Special Projectu
- F. McCoy, Startup Manager
- K. Jenison, Shift Manager
- M. Branch, Shift Manager
- P. Skinner, Shift Manager
- Attended exit interview
2. Exit Interview
The inspection scope and findinge were summarized on March 23, 1988,
with those persons indicated in paragraph 1. The Startup Manager
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described the areas inspected and discussed in detail the inspection
findings listed below. The licensee acknowledged the inspection
findings and did not identify as proprietary any of the material
reviewed by the inspectors during the inspection.
The f ollowing new items were identified:
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Violation (VIO) 327,328/88-20-01: Failure to develop or implement
procedures.
Example 1: Inadequate TS interpretation related to the
turbine driven auxiliary feedwater pump (AFW)
(paragraph 10).
Example 2: Inadequate TS interpretation related to the 2A-A
centrifugal charging pump (CCP) control switch
position (paragraph 11.b.2).
Example 3: Improper performance of the AI-5 Lead operator
Checklist, resulting in an improper verification
of centrifugal charging pump switch position
(paragraph 11.b.7).
Violation (VIO) 327,328/88-20-02: Missed surveillance test for the
- 3 cold leg accumulator (paragraph 10).
Violation (VIO) 327,328/88-20-03: Failure to comply with technical
specification 3.0.3 involving the loss of safety functions (para-
graph 11.b.6).
Violation (VIO) 327,328/88-20-04: Failure ensure timely notifica-
tion of notify the NRC of a loss of safety functions as required by
10 CFR 50.72.b.2.ili and AI-18, Plant Reporting Requirements (para-
graph 11.b.10).
An enforcement conference was held on March 17, 1988 and is dis-
cussed in paragraph 11.d of this report.
NOTE: A list of abbreviations used in this report is contained in
paragraph 13.
3. Sustained Control Room Observation (71715)
The inspectors observed control room activities and those plant
activities directed from the control room on a continuous basis for
the entire period of this report. The observation consisted of one
shift inspector per shift supported by one shift manager per shift
and other OSp management,
a. Control Room Actjvitics Including Conduct of Operations
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The inspectors reviewed control room activities and determined
that in some instances operators were not attentive and respon-
sive to plant parameters and conditions. These issues were
discussed at an enforcement conference held March 17, 1988 (see
paragraph 11.d). Operators were observed to employ communica-
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tion, terminology and nomenclature that was clear and f ormal.
In one instance operators were observed to perform an improper
relief prior to being discharged from their watch standing
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duties and were not attentive to plant operations (see viola- l
tion 327,328/88-20-01, discussed in paragraph 11).
b. Control Room Manning
The inspectors reviewed control room manning an6 determined
that TS requirements were met and a profeosional atmosphere was
maintained in the control room. The inspectcIs found the :4oise
level and working conditions to be acceptable. The inspectors
observed no horseplay and no radios or other non-job related
material in the control room. Operator compliance with regula-
tory and TVA administrative guidelines were reviewed. No
deficiencies were identified.
In addition, the control room appeared to be clean, unclut- r
tered, and well organized. Special controls were established
to limit personnel both in the control room inner area and in
the control room areas behind the back panels,
c. Routine plant Activities Conducted In or Near the Control Roem
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The inspectors observed activities which require the attention
and direction of control room personnel. The inspectors *
observed that necessary plant administrative and technical '
activities conducted in or near the control room were conducted
in a manner that did not compromise the attentiveness of the
operators at the controls. The licensee has established a SS '
office in the control room area in which the bulk of the
administrative activities, including the authorized issuance of
keys, take place. In addition the licensee has established HO,
WR, SI, and modification matrix functions to release the
licensed operators from the bulk of the technical activities
that could impact the per f ormance of their duties. These
matrixed activities were transf ormed into the WCC which is ,
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located in the TSC spaces.
d. Control Room Alarms and Operator Response to Alarms
In one instance, the inspectors observed that control room e
evaluations were not performed correctly utilizing approved
plant procedures (see paragraph 11). Control room alarms were ;
responded to promptly with adequate attention by the operators
l to the alarm indications. Control room operators appeared to
i believe the alarm indications. None were identified by the r
l inspectors that were either ignored by the operators or
timed-out,
e. Fire Brigade
i The inspectors reviewed fire brigade manning and qualifications !
Both manning and qualifications were found i
on a routine basis.
j to meet TS requirements.
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i f. Shift Briefing / Shift Turnover and Relief
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The inspectors observed that, in general, ROs completed turn-
over checklists, conducted control panel and significant alarm
walkdown reviews, and significant maintenance and surveillance
reviews priot to relief. The inspectors observed that, in
general, sufficient information was transferred on plant
status, operating status and/or events and abnornal system
alignments to ensure the safe operation of the unit. However,
the inspectors l'entified one instance where an insufficient
turnover occurred (see paragraph 11). Assistant SS relief was
conducted in the control room and sufficient inf or ma t ion
appeared to be transferred on plant status, operating status
and/or events, and abnormal system alignments to ensure the
safe operation of the unit. The inspectors identified one
instance when an Assistant SS failed to adequately brief the SS
(see paragraph 11). Assistant SS were observed reviewing shift
logbooks prior to relief.
Shift briefings were cenducted by the offgoing SS. personnel
assignments were made clear to oncoming operations personnel.
Significant time and effort were expended discussing plant
events, plant statua, expected shift activities, shift train-
ing, significant surveillance testing or maintenance activi-
ties, and unusual plant conditions,
g. Shift Logs, Records, and Turnover Status Lists
The inspectors reviewed the SS, STA, aad RO logs and determined
that in most cases, the logs were completed in accordance with
administrative requirements. In one case, however, the STA and
RO logs were concidered inadequate (see paragraph 11). In
addition, some improvement 18 needed in the timeliness of
, coz.ple'.on of the SS log. This was discussed with the licensee
at an e..forcement conference held on March 17, 1988.
The following logs were also reviewed:
Night Order Log
System Status Log
Configuration Control Log
Key Log
Temporarf Alteration Log
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h. Control Room Recorder / Strip Charts and Log Sheets
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! The inspector observed operators check, install, mark, file,
and route for review, recorder and strip charts in accordance
with the established plant processes. There were no events
j that caused the immediate control room review of recorder / strip
- chart peaks during this inspection period. Control room and
plant equipment logsheets were found to be complete and legi-
ble; parameter limits were specified; and out-of-specification
parameters were marked and reviewed during the approval pro-
Cess.
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4. Manacement Activities
TVA management activities were reviewed on a daily basis by the NRC
shift inspectors, shift managers, and Startup Manager,
a. Daily Control of Plant Activities (War Room Activities)
The licensee conducted a series of plant activities throughout
each day to control plant routines. These activities were re-
ferred to by the !?.censee os War Room activities. War Room
activities were observed by the shift manager on a daily basis
and were found to be an adequate method to involve upper level
management in the day-to-day activities affecting the operation
of the units.
b. Observation of First Line Supervisor Activities
An increase in first line supervisor involvement in plant
activities was observed. First line supervisor response to
issues and events that occurred during the inspector period was
adequate,
c Management Response To Plant Activities and Events
Management response to the events that occurred during this
inspection period was conservative, well organized, and based
on a Sound technical grasp of the issues.
5. Site Quality Assurance Activities in Suncort of Operations
The inspectors reviewed the activities of the WCC which includes QA
oversight. No discrepancies were noted.
6. Chronoloav of Unit 2 Plant Onerations
At the beginning of the NRC Restart Task Force shift coverage, Unit
2 was in Cold shutdown (Mode 5) with tnree RCgs operating and the
2A-A RHR pump in service. The RCS was at 180 F and 370 psig.
i Pressurizer level was at 26 inches. All SGs were filled to the
operatir49 range, the condensate system was on long cycle recir-
culatisn, and there was a vacuun in the main condenser.
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On February 4, 1988, the NRC approved entry into Mode 4/3 (Hot Shut-
down/ Hot Standby). The plant was heated up using RCPs and entered
Mode 4 on February 6, 1988.
On February 10, 1988, RHR cooling was returned to service and the
licensee suspended all non-essential testing and maintenance for
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about 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. This was done following a series of events which
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included generation of a reactor trip signal, inadvertent MSIV
, closures and feedwater isolations, and a loss of the VCT level due
! to maintenance activities. During this period of licensee
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evaluation and corrective action, the MSIVs remained closed and the
unit was maintained in Hot Shutdown (Mode 4) using RCPs and RHR.
Prior to Mode 3 entry, approximately nine personnel errors had oc- !
curred. None of the events resulting from those personnel errors r
represented significant safety concerns of their own accord and i
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collectively appeared to be typical of what one would expect at a
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Near Term Operating License Plant going through the same evolution.
During this inspection period the unit entered Mode 3 (Hot Standby)
on February 27 and was maintained in Hodg 3 with four RCPs opgrat- '
ing. The RCS was maintained between 350 F/1600 psig and 546
F/2250 psig. A number of events occurred during this inspection !
period and are listed below:
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February 28: Two inoperable steam flow channels, in conjunc-
tion with the existing low-low Tave, resulted in the closure of ;
all four MSIVs.
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February 29: During perf ormance of SI-137.2, RCS Water Inven-
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tory, 2 gpm leakage was identified. The leakage was later
, deterr01ned to be due to RCS temperature variation. SI-137.2
was reperformed satisfactorily. ,
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March 1: A Unit 1 CVI occurrci due to spiking on the lower
- compartment RMs.
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March 5: Val:<e 2-LCV-3-175 failed to stroke but the TDAFP was
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not declared inoperable. This resulted in violation
! 327,328/88-20-01, example 1 (see paragraph 10).
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March 6: Cumulative RCS leakage into the #3 CLA exceeded it of
- the tank volume without boron concentration being verified as ,
j required by TS. This resulted in violation 327,328/88-20-02
(see paragraph 10).
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March 9: The control switch for the 2A-A CCP was in the PTL
! position while 2B-B CCP was also inoperable due to testing.
This resulted in two violations (327,328/88-20-03 and -04)
which are being evaluated for escalated enforcement (see
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! paragraph 11) and resulted in two of the three examples of
violation 327,328/88-20-01. ,
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March 10: Boron concentrations in the RWST and in the #3 cold
l leg accumulator were found to exceed TS limits. Both problems ;
) were corrected within the time limits of the TS Action State-
! ments.
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March 16: The group M* mand step counter in the control room
failed to meve as control bank b was being inserted.
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l Detailed discussions of these events are contained in paragraphs 10
l and 11.
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7. Ooerational Safety verification (71707) Units 1 and 2
a. Plant Tours
The inspectors observed control room oporations; monitored
conduct of testing evolutions; reviewed applicable logs,
including the shift logs, night order book, clearance hold
order book, configuration log, and TACF log; conducted discus-
sions with control room operators; observed shift turnovers;
and confirmed the operability of instrumentation. The inspec-
tors reviewed the operability of selected emergency systems and
compliance with TS LCOs. The inspectors verified that mainte-
nance W0s had been submitted as required and that follow-up
activities and prioritization of work was accomplished by the
licensee.
Tours of the diesel generator, auxiliary, control, and turbine
buildings were conducted to observe plant equipment conditions,
including potential fire hazards, fluid leaks, excessive vibra-
tions, and plant housekeeping / cleanliness conditions.
The inspectors walked down accessible portions of the following
safety-related systems on Unit 1 and Unit 2 to verify operabil-
ity and proper valve alignment:
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Auxiliary Feedwater System
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Chemical Volume Control System
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Upper Head Injection System.
With the exceptions of the violations described in paragraphs
10 and 11, no problems were identified.
b. Safeguards Inspection
NRC inspection activities included a review of the licensee's
physical security program. The performance of various shif ts
of the security force was observed in the conduct of daily
activities, including protectec and vital area access controls;
searching of personnel and packages; escorting of visitors;
wadge issuance and retrieval; patrols; and compensatory posts.
In uidition, the inspectors observed protected area lighting,
and protected and vital area barrier integrity. The inspectors
verified interfaces between the security organization and both
operations and maintenance. Specifically, the shift inspectors
inspected security dur'ng the outage period and reviewed
licensee security event reports.
No violations or deviations were identified,
c. Radiation Protection
The inspectors observed HP practices and verified the implemen-
tation of radiation protection controls. On a regular basis,
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RWPs were reviewed and specific work activities were monitored t
to ensure the activities were being conducted in accordance
with applicable RWPs. Selected radiation protection instru- l
ments were verified operable and within calibration frequency. j
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The following RWPs were reviewed:
RWp 88-0-24: Minor Work.
RWP 88-1-29: Component Cooling Water System pump Repair. [
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No violations or deviations were identified.
8. Shift Surveillance Observations and Review (61726[ !
The inspectors observed or reviewed TS required surveillance testing
and verified that testing was performed in accordance with adequate !
procedures; test instrumentation was calibrated; LCOs were met; test
results met acceptance criteria requirements and were reviewed by
personnel other thar the individual directing the test; deficiencies
were identified, as appropriate, and any deficiencies identified
during the testing were properly reviewed and resolved by management
personnel; and system restoration was adequate. For completed
tests, the inspector verified that testing frequencies were met and
tests were performed by qualified individuals.
The following activities were observed or reviewed:
SI-2: Shift Log. The inspector verified that the requirements of TS i
4.5.2a for valvec 2-FCV-63-1 and 2-FCV-63-22 are being adequately l
implemented by this SI. The inspector verified that the SI has been ;
accomplished at the required frequency and no deficiencies were
noted. ;
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SI-7.1: Diesel Generator AC Electrical Power Source Operability
Verification. This SI was observed by the inspector and no defi- i
ciencies were identified. i
SI-7.2: Diesel Generator Surveillance Frequency. This SI was
observed by the inspector and no deficiencies were identified.
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SI-11: Reactivity Control Systems Moveable Control Assemblies. The
- inspectors observed portions of this SI. A review of problems '
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associated with this SI is contained in the events section (para-
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graph 10).
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- SI-43: Rod Drop Time Measurement. The inspectors observed the
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performance of the SI, which was interrupted due to problems with
i the rod position step counter. A review of the problems is con- ,
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tained in paragraph 10.
I SI-90.82: Monthly Functional Test of Reactor Trip Instrumentation.
l This SI was observed by the inspector and no deficiencies were ,
identified. ,
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SI-111: Testing and Setting of Main Steam Safety Valves. This SI $
was observed by the inspector. No deficiencies were identifjed. -
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SI-127: RCS and pressur !zer Temperature and Pressure Limits. The
inspector observed portions of this SI during increase of tempera-
ture and pressure to ti e normal operating range. The purpose of
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this SI is to document compliance with surveillance requirements in i
order to provide reasonable assurance that unacceptable stresses ,
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af fecting system integrity will not occur and that operation in
excess of the limits is analyzed. No deficiencies were identified.
SI-130.1: Turbine Driven Auxiliary Feedvater Pumps. This SI tas ,
observed by the inspector. During the pump run, smoke came from the
outboard packing of the pump. The TDAFP was tripped and a WR ,'
written. Af ter packing repairs a second reperf ormance of this S'
was observed and no deficiencies were identified. 7
SI-137.1: Reactor Coolant Systems-Unidentified Leakage Measurement. l
This SI was observed by the inspector and no deficiencies were !
identified. l
SI-137.2: RCS Water Inventory. This SI was observed by the inspec-
tor, and failed to meet the acceptance criterion that leakage be
less than than 1 gpm. It was determined that the failure to meet ,
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the acceptance criterion was due to not maintaining the RCS tempera-
ture constant (see paragraph 10). The 3I was rerun holding RCS i
temperature constant and the acceptance criterion was then met. No !
further discrepancies were noted.
SI-166: Summary of Valve Tests for ASME Section XI. This SI was l
observed by the inspector and no deficiencies were identified.
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SI-166.6: post Maintenance Testing of Category A and B valves. The r
SI was observed being performed on valves 2-LCV-3-164 and I
2-FCV-1-15. In both cases the SI was satisfactorily completed and
no deficiencies were identified. i
SI-166.8: Increased Frequency Testing of Category "A" and "B" I
Valves. This SI was observed by the inspector. During the perfor-
mance of this test, valve 2-LCV-3-175 would not stroke. The details T
of this issue are discussed in paragraph 10.
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SI-166.32: AFW Check Valve Opening Test. This SI was observed and
the inspector noted that the TDAFP turbine sometimes oversped. The
cause of these overspeed trips was ir.vestigated by the licensee and i
resolved. Procedural changes to the TDAF Tests were reviewed. The ;
test was changed to implement steam supply swapover in the automatic l
mode rather than manually. Auto swapover allows reset of the !
trip / throttle valve (manual swapover does not reset) such that [
overspeed does not occur. The test was rerun successfully with no [
! overspeed. The licensee has determined that the overspeed was >
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caused by the manual swapover and the procedure change has corrected i
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the overspeed deficiencies. Review of the corrective actions by the
inspector performed on 1/3/88 revealed no discrepancies. No further
discrepancies were noted.
SI-196: periodic Calibration of UHI System Instrumentation. The
inspector observed this SI and noted that the hydraulic pressure
used to cycle the valve in this SI was 3130125 psig, although in
SI-744 hydraulic pressure is allowed to drop to the alarm setpoint
of 2970 psig. The inspector noted that a lower pressure would
increase the closing time of the valve. A follow-up inspection
performed subsequent to the inspector's initial observation deter-
mined that SI-196 is the test utilized by the licensee to satisfy
ASME Section XI valve timing test. ASME Section XI does not require
worst case testing (i.e. bleed to lowest expected pressure).
ST-228.2: Functional Test of RCP Undervoltage Relays. This SI was
coserved by the inspectors and no deficiencies were identified.
SI-230.2: Functional Test of RCP Underfrequency Relays. No defi-
ciencies were identified.
SI-276: Auxiliary Feedwater Automatic Control Valve Operability.
The inspectors reviewed this SI and no deficiencies were identified.
SI-298.2: Calibration and Functional Test of Condensate Storage Tank
Suction Header Pressure Switches to Auxiliary Feedwater System.
This SI was observed being performed on the 2B-D AFW pump r.4'ction
pressure switches. No deficiencies were identified.
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SI-488: RCS RfD Sensor Verification of Calibration. This SI was ob-
served at 525 F and at 447 F. No deficiencies were identified.
SI-720: Calibration of AFW Terry Turbine Controls. This SI was ob-
served by the inspector and the acceptance criterion was met, but
the inspector noted that the t:rbine tripped on overspeed. The
cause of the overspeed trips is discussed under SI-166.32 above.
SI-744: Monitoring of UHI Isolation Valves Accumulator Pressure.
The inspector observed performance of this SI and no deficiencies
were identified.
9. Shift Maintenance Observations and Review (62703)
a. Station maintenance activities of saf ety-related systems and
components were observed or reviewed to ascertain that they
were conducted in accordance with approved procedures, regula-
tory guides, industry codes and standards, and in conf ormance
with TS.
The following i te ms ve r e considered during this review: LCOs
were met while components or systems were removed from service;
redundant components were operable; approvals were obtained
prior to initiating the work; activities were accomplished
using approved procedures and inspected as applicable;
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procedures used were adequate to control the activity; trouble-
shooting activities were controlled and the repair record
accurately reflected what actually took place; functional
testing and/or calibrations were performed prior to returning
components or systems to service; QC records were maintained; ,
activities were accomplished by qualified personnel; parts and
materials used were properly certified; radiological controls l
were implemented; QC hold points were established where re-
quired and were observed; fire prevention controls were imple-
mented; outside contractor activities were controlled in -
accordance with the approved QA program; and housekeeping was
actively pursued.
b. Temporary Alterations :
The following TACFs were reviewed: L
2-87-2001-30: Thermocouples in East and West Valve Vaults t
2-88-2005-68: Switching RCP RTDs from 2-TE-68-2A to
2-TE-68-2B (spare)
2-84-2039-03: Automatic Main Feedwater Bypass Valve.
No violations or deviations were identified.
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c. Work Requests [
The following WRs were reviewed: l
WR B257703 was initiated for inspection of 2D-B CCP gland bolt.
No deficiencies were identified.
WR 262113 was initiated for troubleshooting of steam flow i
indicator 1-3A. No deficiencies were identified.
<
WR B262118 was initiated for troubleshooting on valve
2-LCV-3-164. Tb2 inspector observed the work in progress and .
no deficiencies were identified. During the troubleshooting,
it was determined that the problem was in the valve controller
rather than in the valve. ,
WR B262457 was initiated for electrical ground troubleshooting, ,
No deficiencies were identified.
WR B264214 was initiated for repairs to CCS pump 1-PHP-70-46.
The inspector observed the pump impeller being set up in one of
the machine shop lathes. An RA had been established around the
- lathe, and RWp-1-29 was controlling work within this RA. The
inspector questioned the following practices:
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The lathe operator wiped his nose with the sleeve of his
j anti-contamination clothing (Anti-Cs). '
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- An assistant was outside the RA boundary ropes instead of
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- at the R A access area (i.e. the step-off pad).
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The assistant was smoking as he handed tools across the RA
boundary.
The inspector discussed these issues with HP supervision, who
said they would ensure the lathe operator had not contaminated
his face. The Hp supervisor and the inspector reviewed CRI-1,
Radiological Control Program; RCI-14, Radiation Work permit
Program; SQA-205, Contamination Control; and RCI-15, Establish-
ing and Updating Radiological Signposting. None of these
documents gave guidance about where tools could enter the RA or
about sm3 king at the boundary of the RA.
The inspector also observed the condition of the RA around the
pump in the auxiliary building. There were no personnel ir. the
RA. At the time of the observation the RA had oily dirt on the
floor, numerous tools adrift, and several copies of procedures
lying around. Maintaining ras orderly helps prevent the
unnecessary spread of contamination. The inspector discussed
these issues with HP supervision, who agreed they were poor
work practices and directed that the work area be cleaned up.
WR B267164 was initiated to adjust the limit switches on valve
2-LCV-3-164. The inspectors reviewed work in progress and did
not note any discrepancies.
WR B267403 was initiated to repair valve 2-LCV-3-164, which had
been permitting approximately 100 gpm of flow when the valve
indicated closed in the auto position. The inspectors reviewed
work in progress and no deficiencies were identified.
WR B267451 was initiated to repair and calibrate 2-LCV-3-173.
The inspector observed work in progress and partial performance
of SI-75, the post maintenance test. No discrepancies were
noted.
WR B267767 was initiated to repair bearing leakage on the 23-B
AFW pump. No deficiencies were identified.
WR B26770 was initiated to repair a hydraulic leak on
2-FCV-87-23. No deficiencies were identified.
WR B271864 was initiated on the draindown pressure on
2-FCV-87-22. No deficiencies were identified.
WR B271886 was initiated on the draindown pressure on
2-FCV-87-24. No deficiencies were identified.
WR B275198 and WR 267353 were initiated to remove plugging from
the 2" line off the boric acid tank. The inspectors reviewed
work in progress and did not note any di60IepaneleS.
WR B275996 was initiated for repairs and testing of AFW SG
level contrc'. valve 2-LCV- 3-0156 A. No deficiencies were
identified.
14
__ _ _ _ _ _ _ _ _ _ _ _ _ _________ _ _ __.
WR B293849 was initiated to repair the governor valve on the
TDAFW. The inspector observed work in progress and no defi-
ciencies were identified.
] WR B296429 was initiated to replace the lockout relay on the ,
- 2A-A 6.9 KV shutdown board normal supply breaker. The inspec- ,
tor monitored a portion of the work activities. No discrepan-
cies were noted. ;
!
,
No violations or deviations were identified during the inspec-
tions of work requests,
d. Hold Orders
The inspectors reviewed various Hos to verify compliance with
AI-3, Clearance Procedure, Revision 38, and to verify that the
H0s contained adequate information to properly isolate the
affected portions of the system being tagged. Additionally,
the inspectors inspected the affected equipment to verify that -
the required tags were installed on the equipment as stated on
the H0s. The following H0s were reviewed:
Hold Order E2uioment ;
'
2-88-52 2-FCV-67-68 Motor Replacement
1-88-429 Boric Acid System ,
1-88-438 1A-A Motor Driven AFW pump ,
i
No violations or deviations were identified. ;
10. Event Follow-un (93702, 62703)
On February 28, at approximately 8:00 p.m., steam flow channel #1 on
,
'
the #1 SG and steam flow channel #1 on the #3 SG were declared i
inoperable as a result of improper indication (i.e. indication of ['
steam flow when there was no steam flow) . TS 3.3.2.1 allows opera-
tion to continue if the inoperable channel is tripped. Accordingly,
to allow continued operation, the inoperable channels were tripped ;
as prescribed in TS 3.3.2.1. This caused high steam flow indication
in two steam lines, which in conjunction with the existing low-low
Tave (less than 540 F), resulted in the closure of all four MSIVs.
The MSIVs were subsequently reopened, and the unit remained in Mode
3. The human f actors error will be evaluated as part of the LER
closure process.
'
,
On February 29, at approximately 2:00 a.m., during the perf ormance
! of SI-137.2, Reactor Coolant System Water Inventory, 2 gpm unclas-
sified leakage was identified. Until classification can be estab-
11shed, the leakage is considered unidentified. The licensee
- declared an unusual event in accordance with their radiological ,
- emergency plan. The high leakage rate was later determined to be
,
due to variation in RCS temperature during the leak rate test. The
test was reperformed at a constant RCS temperature and the retest ,
]
, .
.
15
,
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
!
i
data reflected a leakage rate well within TS acceptance criteria.
The unusual event was exited at 1:10 p.m. on February 29, 1988.
On M6rch 1, at 2:43 a.m., a Unit 1 CVI occurred due to spiking on
the lower compartment RM 1-RM-90-106 A&B. When the CVI occurred,
the RO blocked the RM signal. Troubleshooting determined the RM
signal to be the result of a clogged filter which caused relay
chattering and EMP spikes in the RM circuits. Containment venti-
lation and RMs were returned to service. At 3:45 p.m., the RMs
caused another CVI. Troubleshooting led to the same root cause as
before. The licensee is now changing the filters every four hours.
Permanent corrective action still needs to be developed.
On March 5, at approximately 10:30 p.m., TDAFP LCV 2-LCV-3-175 would
not stroke. TS 3.7.1.2 requires at least three independent SG AFW
pumps and associated flow paths be operable in Modes 1,2, and 3. ?S
3.0.5 states:
Whea a system, subsystem train, component or device is deter-
mined to be inoperable solely because its emergency power
source is inoperable, or solely because its normal power source
is inoperabic it may be considered operable for the purpose of
satisfying the requirements of its applicable LCO provided: (1)
its corresponding normal or emergency power source is operable;
and (2) all of its redundant system (s)........are operable, or
likewise satisfy the requirements of this specification.
TVA had interpreted TS 3.7.1.2 and had issued in 1984 a written
corporate position as TS Interpretation #8. Based on the interpre-
tation the TDAFP pump was agi declared inoperable. The 1984 TS
interpretation states that:
A recent incident involved the removal of a train B-B EDG from
service for maintenance and using LCO 3.0.5 to declare various
Llant equipment to be operable in relation to power supplies,
later that same day the TDAFP was declared inoperable. Howev-
er, confusion arose as to the operability of train B MDAFP,
since it was unclear if it still met the definition of 3.0.5
for ensuring all its redundant equipment was operabic. . . If
train B EDG is inoperable, then train "A" MDAFP must be opera-
ble and at least 3 SG's capable of being supplied from the
The inspector questioned the validity of TS Interpretation 88 and
the decision not to call the TDAFP inoperable based upon the the
interpretation.
Further review by the inspector determined the following:
1) The failure of valve 2-LCV-3-175 to stroke during the
performance of SI 166.8, Increased Frequency Testing of
Category A and B Valves, was not entered in the RO,
Assistant SS or SS logs prior to shift relief. A log
16
t. .
{
entry was subsequently made after the inspecto: expressed
his concerns to the oncoming SS.
2) The failure of valve 2-LCV-3-175 was not entered in the SI
166.8 test director's chronological test log. The failure
of valve 2-LCV-3-175 to stroke was also not identified as
a deficiency in the SI 166.8 data package.
Valve 2-LCV-3-175 was successfully stroked at approximately 0120.
Therefore, although the TDAFp was not declared inoperable, the time
limit of the TS Action Statement was not exceeded and no violation
of TS occurred. The licensee has removed the TS interpretation book
from the control room until all the interpretations can be reviewed
for adequacy. The specific example of inadequate TS interpretations
is a violation of TS 6.8.1, which requires adequate procedures be
developed and implemented. This is violation 327,328/88-20-01,
example 1.
On March 6, at 8:00 p.m., the inspector determined that the licensee
had been routinely draining the #3 CLA due to inleakage from the RCS
and that RCS boron concentration was 2177 ppm. Review of TS 3.5.1.1
indicated that the upper limit for boron concentration in the CLAs
is 2100 ppm and that TS surveillance requirement 4.5.1.1.1.b re-
quires boron concentration to be verified within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> after each
solution volume increase of greater than or equal to 1% of tank
volume. The inspector expressed concern to the SS that cumula-
tively, a 1% volume increase may have occurred as a result of the
RCS inleakage into #3 CLA. The SS immediately took action to
determine if a 1% volume increase had occurred as a result of RCS
inleakage and to obtain a boron sample. The boron sample analysis
was completed at 9:49 p.m. and indicated a boron concentration of
2085 ppm. The licensee determined that cumulatively the RCS
inleakage had increased the CLA #3 volume by greater than 1%. This
issue is identified as violation 327,328/88-20-02, Missed Surveil-
lance Test.
On March 9 it was determined that both CCps were inoperable for a 1
hour and 24 minute period. This event and the follow-up are de-
scribed in detail in paragraph 11 of this report.
On March 10, at 3:45 p.m. the Unit 2 RWST was declared inoperable
when its boron concentration was sampled and determined to be 2111
j ppm. This exceeded the TS 3.1.2.5.b.2 maximum of 2100 ppm. The
j licensee fed and bled the RWST to lower the boron concentration and
exited the LCO on March 11, at 12:12 a.m..
! On March 10, at 4:54 p.m. an Unusual Event was reported. A boron
- sample on #3 CLA was 2101 ppm which exceeded the TS maximum boron
concentration of 2100 ppm. TS 3.5.1.1 requires the concentration to
,
be corrected within one hour or be in mode 4 within the next 5
i hours. The licensee commenced feed and bleed operations on the CLA.
1 At 8:25 p.m. the licensee began cooling down to enter mode 4 within
- 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. This initiation of cooldown necessitated a declaration of
'
an unusual event. At 9:40 p.m., a sample on 83 CLA indicated a
17
. .
i
!
!
l
boron concentration of 2079 ppm and a backup sample indicated 2080 l
ppm. At 10:10 p.m. the Unusual Event was terminated and the plant i
began a heatup to return to_527 F. !
!
- On March 15, at 12:36 a.m., the licensee was conducting rod exercis- ;
l es per SI-11, which requires stepping rod banks out 10 steps and i
'
j then back in. When attempting to step rod control bank D back in,
.
the licensee discovered that the rods had stepped in but the indi- )
cated position on the control room step counters had not changed. l
The licensee manually opened the RTBs as required by TS 3.1.3.3. !
All equipment functioned and gperator actions were as expected. The '
reactor was stabilized at 535 F. Previous SI-11 rod exercises of '
- shutdown banks A through D and rod control banks A through c had
i been completed without similar indication problems.
"
On March 17, at 6:69 a.m., the reactor was again tripped manually to i
'
comply with TS 3.1.3.3 when the step counters on bank B were ob- *
served to be inoperable while performing rod drop testing. Early
troubleshooting indicated a bad step counter, j
!
i
on March 18, at 2:30 p.m., control rod E-3 in shutdown bank C i
, appeared to be stuck on the bottom. The individual position indica-
tor appeared to stick, then responded. When bank C was reinserted
j and then withdrawn, rod E-3 stepped out with the bank. When the
j bank stopped at 10 steps withdrawn, rod E-3 appeared to f all slowly
! back to zero. The test was performed again, and rod E-3 appeared to ,
) fall as soon as the stepping out sequence was stopped. The problem
was later identified as a problem in the signal conditioning module
for the rod's position indicator. Repairs were effected and no ;
further problems were observed.
i
- 11. Centrifugal Charging Pump 2A-A in Pull-to-Lock ,
I
'
a. Description of Event
! At 7:30 p.m. on March 9, 1988, during a walkdown of the Unit 2 L
- control room panels, the inspector noted that the control
'
switch (HS-62-108A) for the 2A-A CCP was in the PTL position.
- The inspector brought this condition to the attention of the
! control room operator and after brief discussion the operator
i put the switch back into the A-Auto position. During the above l
'
l discussion with the two operators in the control area the
i inspector considered that it was not common knowledge among the ;
i operators that the pump was not OPERABLE for Mode 3 while in t
! the PTL position (i.e. not capable of automatically starting on
I an accident signal). In fact, the operators indicated they r
! thought that the TS interpretation book allowed this switch '
j position while in Mode 3. The inspector indicated that he did
j not agree with the TVA interpretation and that the TS action :
I
3
should have been entered while the pump was an PTL.
I
! i
'
Following the above discussion with the control room operators,
the inspector monitored the licensee follow-up actions for the
, l
! !
18 l
[
'
L
.
event. Specifically, after resolving the initial safety
concern regarding the switch position, the inspector observed
the actions of the Ros, Assistant SS, STA and SS. The inspec-
tor was attempting to evaluate the effectiveness of communi-
cations among the above individuals in order to determine that
the proper level of- management was involved in the f ollow-up
actions. Af ter waiting approximately 30 minutes, at 8:00 p.m.,
the inspector asked the SS if he was aware of the problem
involving the 2A-A CCP being in PTL and determined that he had
not been informed of the problem.
The inspector requested the following information from the duty
SS:
-
When the 2A-A CCP was put in Pull-to-Lock
-
Whether the 2B-B CCP was OPERABLE during the period the
-
If the 2A-A CCP was in PTL during shift turnover, and if
so, why the problem didn't get identified by the turnover
checklist
-
Why it took so long to notify the SS of the problem
-
If there was a TS interpretation that allowed the pump to
be considered OPERABLE in mode 3 with the switch in PTL
-
If there was a training problem on CCP OPERABILITY
After discussing the above event with the NRC Startup Manager
the inspector reviewed the Unit 2 operator log and determined
that:
1) At 1:11 p.m. on March 9, 1988 the ?B-B CCP was started for
engineering test associated with the speed increaser oil
system;
2) At 1:16 p.m. the 2A-A CCP was shutdown (although not
reflected by the log, this is the time the licensee later
determined the switch was put in PTL;
3) At 2:40 p.m. the 2B-B CCP was declared OPERABLE after post
maintenance testing. This review indicated that for a 1
hour and 24 minute period, between 1:16 p.m. and 2:40
p.m., both the 2A-A and 2B-B CCPs were inoperable and the
action of TS 3.0.3 was not followed.
A follow-up review of the March 9, 1988 Lead Operator System
Status checklist for Modes 1-4 (required by AI-5) was conducted
by the inspector. This review and follow-up conversation with
the SS revealed that during the 3:00 p.m. perf ormance of the
checklist the lead RO failed to recognize that the hand switch
(HS-62-108A) for the 2A-A CCP was in the PTL position. This
was demonstrated by a checkmark in the 3:00 p.m. entry space
next to the switch on the checklist. Later, after the inspec-
tor had identified the problem, the operator wrote over the
j checkmark with the inscription PTL and initialed the entry 'see
- paragraph ll.B 6). Additionally, a review of the event
1
I
i 19
!
- ._-.
_ _ _ _ - _ - _ - _ _ _ _ __
.
description in the STA log indicated that the SS was immediate-
ly notified of the event by the operator. This was incorrect,
as the inspector had previously observed that the SS was not
promptly notified. (See the evaluation of concerns in section
11.B.9 of this report).
The SS requested that the PORS group perform a Root Cause
Evaluation of the event and the inspector provided a statement
to the PORS investigator. The inspector requested that the NRC
be provided with a copy of the investigation.
One additional issue arose when the reporting to the NRC (via
Red Phone) of the fact that both CCPs were inoperable for a 1
hour and 24 minute period was delayed until 10:08 a.m. on March
10, 1988. The inspector has concern that TVA may not have "Red
Phoned" the event at all if the site NRC personnel had not
intervened. This is based on the fact that the initial PRO
(2-88-74) did not address that the action of TS 3.0.3 was
exceeded. The PRO only indicated that LCO 3.0.3 "may" have
been entered without being recognized.
b. Evaluation of Concerns
1. Concern 01: Hand switch (HS-62-108A) for the 2A-A CCP
being in Pull-to-Lock not entered in LCO action log.
With the switch in PTL, the 2A-A CCP was inoperable (see
violatten 327,328/88-20-03, discussed in paragraph 11.B.6)
but the LCO of TS 3.5.2 was not indicated in the TS LCO
action log as required by AI-6, Log Entry and Review.
This failure to log a condition that was not recognized by
the operator as an entry into an LCO is not considered a
violation of procedural requirements since the condition
was not recognized by the operators as constituting
inoperability.
2. Concern #2: Several control room operators not aware that
in Mode 3 with the control switch in the PTL position the
2A-A CCP was inoperable, as defined by the TS.
The discussion between the control room operators and the
inspector indicated that the operators actually believed
that TVA has a TS interpretation that would allow the
switch to be in PTL. The inspector believes that the
operators, who were used to Cold Shutdown operations (i.e.
Mode 5), were relying on past knowledge and a TS interpre-
tation that allowed a charging pump to be in PTL and still
be considered operable for the boron injection flow path
while in Mode 5 or 4 only. Additionally, the operators
were not properly trained on the use of this TS interpre-
tation and were not referring to the control room proce-
dures or unit TS for their information. When the inspec-
tor questioned the switch position, the first place the
20
. .
.
operator went for the information was the TS interpreta-
tion book and not the NRC approved TS.
A subsequent review by the licensee of several interpreta-
tions in the TS interpretation book indicated that these
interpretations were in fact wrong and conflicted with the
current unit TS. The inspector requested that the
licensee pull the TS interpretation books from the control
room and training center until the interpretations had
been validated by the licensee.
Sequoyah Operating Licensee NO. DPR-79 requires the plant
to be operated in accordance with the TS. The use of TS
interpretations which conflict with the NRC - approved TS
constitutes a violation of TS 6.8.1 which requires ade-
quate plant procedures be established, linplemented and
maintained. This is violation 327,328/88-20-01, example 2.
s. Concern #3: Failure of the on duty RO, at the time of the
discovery of improper switch position, to promptly commu-
nicate the problem to the SS.
The NRC requires that the holder of a SRO license be on
duty in the control room during all nodes of plant opera-
tion. This SRO must be knowledgeable of the technical
aspects of the plant as well as being f amiliar with the
administrative requirements (including TS) required for
control of day-to-day operations. The technical knowledge
requirements of the SRO position are ensured by the
operator licensing process. Additionally, ANSI
N10.7-1976, which the licensee is committed to through
their QA Topical Report TVA-TR75-1A, requires the above
command function be established.
In order for the command function to be effective, commu-
nication of problems encountered by the RO must be timely
and effectively communicated to the SRO level so that
effective corrective and follow-up actions can be imple-
mented. AI-30, Nuclear Plant Conduct of Operations,
implies, but does not specifically state, that timely and
effective communication is essential. The inspector
consideres that this procedure (AI-30) should more specif-
ically address timely and effective communication of
problems up the operations chain.
4. Concern #4: Log entry made at the time the 2A-A CCP was
shutdown (i..e. 1:16 pm on March 9, 1988) did not reflect
tnat the control switch was put in PTL.
AI-6 requires that inf ornation pertaining to major equip-
ment operation be documented in the RO daily log. Howev-
er, the procedure does not specify the needed detail that
should be recorded. The event that occurred regarding the
2A-A CCP being placed in the PTL was not described in any
21
.
8 4
detail. In fact, only a simple statement that the "A CCP
shutdown IM notified to swap flukes to 2BB CCP" was
recorded in the log. Had the fact that the pump was
placed in PTL been recorded the review of the RO daily log
required by AI-5 may have discovered the inoperable
equipment.
5. Concern #5: Placing control switch in the PTL position
when the pump was secured.
SOI 62.1, Chemical and Volume Control System, which is the
operating instruction used to operate the 2A-A CCP, does
not state to put switch in PTL when stopping the running
pump. It is unclear whether or not the operator who
secured the 2A-A CCP on March 9 actually consulted the
procedure to operate this equipment or was sufficiently
knowledgeable of this requirements of this procedure.
This may have contributed to Violation 327,328/88-20-03.
6. Concern 06: Both CCP being inoperable for a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and 24 I
minute period and the action of TS 3.0.3. not followed.
At the time the 2A-A CCP was placed in the PTL position '
(i.e. made inoperable) the 28-B CCP was also inoperable,
in that its perf ormance had not been established subsc- .
'
quent to maintenance on its speed changer. With both
pumps simultaneously inoperable the action required by TS , 3.0.3 should have been followed. This required that ;
within one hour, action be initiated to place the unit in i
a mode that did not require two operable centrifugal [
charging pumps. l
>
The failure to comply with the requirement of TS 3.0.3 (
resulted in a violation of TS requirements and involved !
the loss of a safety function (i.e. high head injection i
and rapid boron injaction needed f or a LOCA and Main Steam l
Line Break Accident). This is violation 327,328/88-20-03. l
!
7. Concern 07: Failure to identify improper switch position ;
for the 2A CCP during accomplishment of the March 9, 1988,
3:00 p.m. turnover checklist.
A review of the checklist wnich is required by AI-5 to be l
performed prior to shift turnover by the lead RO, indicat- l
ed that the control room handswitch for the 2A-A CCP
(HS-62-108A) was checkea as being in the proper position
(i.e. A-Auto). This constituted an improper performance
of the checklist, in that the actual position at the time
of the 3:00 p.m. verification was later verified to have ;
been the PTL position. This is violation
327,328/88-20-01, example 3.
8. Concern 58: Improper Correction of the AI-5 checklist ;
completed on March 9, 1988, i
l
i
22 i
-_ . , - -
_ _ - _ _ - __ _. _ __ . _ _ ._ _ _ _ _ _ _ _. .___
. .
On the March 9, 1988, AI-5 lead operator checklist, the
3:00 p.m. check mark entry for handswitch (HS-62-108A) had
been written over with the inscription PTL and initialed
by the operator. This method of correction of a OA record
is improper in that corrections should be made by drawing
a single black ink line through errors in the record so
that the incorrect information is still legible and the
person making the correction should initial and date the
correction. This improper record correction was promptly
corrected by the licensee.
9. Concern 19: STA log incorrectly indicating that the SS was
immediately notified of the event by the operator.
This was an incorrect statement in that the NRC inspector
notified the SS of the event after waiting approximately
30 minutes. Discussion with the STA involved indicated
that he had assumed that the SS was notified by the
Assistant SS. This incorrect STA log entry was discovered
and promptly corrected by the licensee.
10. Concern 510: Failure to ensure timely notification of the
NRC of a loss of safety functions (via ENS Red Phone) as
required by 10 CFR 50.72.b.2.111 and AI-18, Plant Report-
ing Requirements.
The event described in this report associated with having
both CCPs simultaneously inoperable meets the NRC thresh-
old of requiring a 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> "Red Phone" report after identi-
fication of the problem. However, it took approximately
13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> to report the event after suspecting that both
pumps had been simultaneously inoperable. This is vi;la-
tion 327,328/88-20-04.
c. Concle tons
concerns 2, and 7, above constitute failures to either properly
develop or implement procedures as required by TS 6.8.1, and
were identified as examples of violation 327,328/88-20-01.
Concern 6, involving both CCPs being inoperable for a period in
excess of one hour and not complying with the Action Statement
required by TS 3.0.3, was identified as violation
327,328/88-20-03 and is being considered for escalated enforce-
ment.
Concern 10, regarding a failure to timely notify the NRC (via
ENS Red Phone) as required by 10 CFR 50.72.b.2.111 and AI-18
within four hours of the occurrence, was identified as viola-
tion 327,328/88-20-04 and is also being considered for escalat-
ed enforcement.
d. Enforcement Conference
23
.
On March 17, 1988 the NRC held an enforcement conference with
TVA to discuss concerns related to the apparent failure to ,
comply with TS 3.0.3 action requirements when both CCPs were [
INOPERADLE for a period of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and 24 minutes on March 9, i
'
1988. The meeting was opened by S. Ebneter, Director, office
of Special Projects, who along with F. McCoy discussed the NRC l
concerns with this specific event. TVA was requested to i
address their own investigation of this event along with other l
recent operational events that had occurred since approximately !
January 14, 1988. TVA presented the requested information and .
I
provided a list of planned corrective actions to be implemented
both prior to and subsequent to plant startup. A copy of the t
material presented at the conference by TVA has been included I
as Appendix A of this inspection report. I
!
The NRC agreed with most of the TVA evaluation of the CCP ;
event. However, there was a disagreement as to when TVA became l
aware that the 2A-A CCP was put in the PTL position when it was i
secured at 1:16 p.m. on March 9, 1988. TVA indicated that the
reason they took approximately 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> to report the violation i
of TS 3.0.3 was that they did not know for sure that the 2A !
pump was inoperable at the same time that the 2B-B pump was i
inoperable. The inspector who discovered the problem consid- i
~
ered that the pump was put in eTL when it was secured at 1:16
p.m. This was based on discussicns with control room opera- -
tions personnel along with the pORS member who investigated the !
event. Additionally, the PRO which was written approximately i
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> before the event was reported indleated that a viola- ;
l tion of 3.0.3 may have occurred. The licensee agreed to ,
conduct further follow-up to evaluate the inspector's position. !
The following prior-to-restart commitments were nade by the
l licensee: l
1
-
Controls will be established to limit interchanging
' operators from a cold shutdown unit to an operating unit.
-
AI-6, for operator log entries, is being revised to f
a delineate the level of detail for log entries such as
,
specifying switch positions. l
i
!
! -
AI-30, for operator communication, will be revised to
i specify required interface of operators during control ;
- board manipulations while switch positions are changed or i
j major equipment is taken out of service. f
I
!
i
- AI-5 will be revised to require a checklist completion ,
) (Appendix D1) for nonscheduled shift relief. !
- i
l -
A PORC review of f or mal TS interpretations is being I
i performed for technical adequacy and clarity. The TS i
l interpretation book has been removed from direct accesu to
- operators until this review is complete. Additionally, i
.
!
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J !
24
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_ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ __ _
- * ?
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the iteensee committed to have p0RC approval of any TS
interpretation prior to allowing its use by operators. !
!
-
AI-5 will be revised to require the Assistant SS to
observe the main control board status f or abnormal condi- l
tions prior to assuming the shift. This observation will i
be documented in the Assistant SS log. (
- Senior Office of Nuclear power management are addressing i
operations personnel on the causes, conclusions, and i
corrective actions for the event. !
l
-
Signs emphasizing plant operating mode will be placed in
the main control room and the auxiliary instrument room. ;
'
,
!
-
The STA log entry at 8:20 p.m. and the AI-5, 3:00 p.m.
time entry will be corrected in accordance with plant [
procedures.
- Evaluate the duties of the Assistant SS and make necessary
changes to minimize his absence from the control room for ;
administrative matters.
On March 24 the inspector verified that the prior-to-restart I
commitments made by the licensee in the enforcement conference j
were implemented. t
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25
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_ _ _ _ __ _ _ _ _ _ _ _ _
, _ _
. .
.
13. Shift Inspector Follow-un Issues
Issue Number Descriotion Status / Resolution
1/23/88-2-2 SI 166.12 needs to be Resolved. The licensee has
revised to reflect the implemented instruction changG
proper position of 88-0649 to require return to
valves HCV-74-36 and 31 service component positions.
2/15/88-2-1 Verify method of returning Resolved. SI-118 was
switches to service in appropriately revised.
SI-118,
2/16/88-2-1 Control room in- ~ tion Resolved. This item is con-
items : key con' shift tinuing to be monitored and
turnover check' 3 . and specific issues will be
SS log keeping .cices. addressed on a case-by-case
basis in subaequent reports.
2/16/88-2-2 Follow-up on discussion Resolved. Discussions and
items including key independent reviews indicated
control, shift turnover licensee ogrcms were
checklists, and logkeeping hdequate 69C will continue
to monit!
2/26/88-2-1 Evaluate new Work Control Currently under NRC review.
Group's effectiveness
regarding recognizing LCO
conditions
2/27/88-2-1 Review of improper Currently under NRC review.
operations of the COPS
2/28/88-1-1 SIS check valve leakage Currently under NRC review.
2/28/88-1-2 Main steam isolation ESF Resolved. Review ccmplete
actuation review and item to be reviewed
in depth in LER.
2/29/88-1-1 Review operator license Resolved. Review indicated
of an operator that the operator in question
was properly licensed.
2/29/C8-2-1 Repair TDAFP so it Resolved. The trips had been
does not inadvertently caused by inappropriate
trip on overspeed procedure steps. The pro-
cedure was changed and the
test rerun with satisfactory
results.
3/5/88-2-1 TVA to review the Resolved. This review is
validity of all TS complete. Twenty-seven out
interpretations prior to of ninety items were removed
Mode 2. from the control room.
26
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_ _ - - - _ _ - __ -- - _ . . . _ . -- _ _ _ . - _ - _ _ _ _ - _ ___
- - _ _ _ - ____
. .
t
- 3/,7/88-2-1 Review PRO Report Resolved. The issue was
2-88 ' disposition discussed programatically
at 3/17/88 enforcement
conference.
.3/.7/88-2-2 . Follow events relating to. Resolved. _ Review is com-
2A-A MDAFP LCO :plete, and-an in-depth-
' review will be conducted
.on the LER.
3/7/88-2-3- Operability requirements Resolved. AFW instru-
of AFW instrumentation mentation'is considered
attendant-equipment.
- 3/8/88-1-l' Review the drawing Currently under NRC review.
control process in
SOEP 30 and SQEP 42 for
compliance with 10 CFR 50
Appendix B, Criterion VI
3/9/88-1-1 2A CCP in Pull-to-Lock Resolved. This item will
be tracked through vio-
lation 327,328/88-20-03
3/12/88-1-1 RCP #1 upper thrust Currently under NRC review.
- bearing temperature alarm
problem
3/12/88-2-1- Determine that appropriate This is a non-restart item
measures for protection of and is currently under NRC
power block personnel for review.
radiography
3/12/88-2-2 Determine source of Resolved. Leak from
reddish fluid dripping snubber was repaired,
'
from overhead between #2 fluid cleaned up, the
and #3 SGs licensee is monitoring.
!
'
3/12/88-2-3 Evaluate PRO 2-88-81 Currently under NRC review,
dealing with no PMT after
[ work on 2-FCV-67-67
c.
.
'
3/14/88-2-1 Determine acceptability of Resolved. The test
pressure associated with pressure listed in SI-196
i. UHI valve testing was to ensure that valve
> accumulators were charged
to normal pressure after
other tests that reduced
accumulator pressure were
completed.
.
27
.
13. List of Abbreviations
AFW -
AI -
Administrative Instruction
ANSI - American National Standards Institute
AOI -
Abnormal Operating Instruction
ASME - American Society of Mechanical Engineers
CAQR - Conditions Adverse to Quality Reports
CCP -
Centrifugal Charging Pump
CCS -
Component Cooling System
CLA -
Cold Leg Accumulator
COPS - Cold Overpressure Protection System
CVI -
Containment Ventilation Isolation
EDG -
ENS -
Emergency Notification System
ESF -
Engineered Safety Feature
F -
Farenheit
HO -
Hold Order
HP -
Health Physics
IM -
Instrument Maintenance
LCO -
Limiting Condition for Operation
LCV -
Level Control Valve
LOCA - Loss of Coolant Accident
MDAFP- Motor Driven Auxiliary Feedwater Pump
MSIV - Main Steam Isolation Valve
NRC -
Nuclear Regulatory Commission
OSP -
Office of Special Projects
PMT -
Post Modification Test
PORS - Plant Operation Review Staff
PSIG - Pounds per Square Inch Gauge
PTL -
Pull-to-Lock
PRO -
Potentially Reportable Occurrence
QA -
Quality Assurance
QC -
Quality Control
RA -
Regulated Area
RCS -
RCP -
Reactor Coolant Pump
RHR -
RM -
Radiation Monitor
RO -
Reactor Operator
RTB -
Reactor Trip Breaker
RTD -
Resistance Thermal Devices
RTI -
Restart Test Instruction
RWP -
Radiation Work Permit
RWST - Reactor Water Storage Tank
SG -
SI -
Surveillance Instruction
SS -
Shift Supervisor
SIS -
Safety Injection System
SOI -
System Operating Instructions
SRO -
Senior Reactor Operator
STA -
Shift Technical Advisor
TACF - Temporary Alteration Control Form
TAVE - Average Reactor Coolant
28
_ _ __ __., - _ . _ . _
. .,
.
-
.
TDAFP - Turbine Driven Auxiliary Feedwater Pump
TS -
Technical Specifications
TSC -
TVA -
Tennessee Valley Authority
UHI -
Upper Head Injection
VCT -
Volume Control Tank
WCC -
Work Control Center
WR -
Work Request
i
29
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APPENDIX A
SUMMARY OF EVENTS
+ -
,
DATE TIME ACTION
- 3/8/88 2154 28-B CCP WAS DECLARED INOPERABLE FOR REPAIRS.
'
ENTERED LCOs 3.1.2.4 AND 3.5.2.
3/9/88 0945 SHIFT REllEF OCCURRED. INCOMING OPERATOR HAD
5
SPENT TEN DAYS ON UNIT 1 BEFORE RETURNING TO UNIT 2.
. 3/9/88 1311 2B-B CCP STARTED FOR POST MAINTENANCE TEST.
3/9/88 1316 2A-A CCP WAS STOPPED AND PLACED IN PULL-TO-LOCK
BY OPERATOR.
3/9/88 1440 TEST ON 28-B CCP WAS COMPLETE AND PUMP DECLARED
.
OPERABLE. LCOs 3.1.2.4 AND ~3.5.2 WERE EXITED.
'; 3/9/88 1630 SHIFT REllEF TOOK PLACE. ONCOMING OPERATOR
ASKED ABOUT OPERABILITY OF THE 2A-A CCP IN
PULL-TO-LOCK POSITION. WAS TOLD PUMP OPERABLE.
3/9/88 1930 SECOND SHIFT RELIEF TOOK PLACE. 2A-A CCP WAS
FOUND IN THE PULL-TO-LOCK POSITION BY AN NRC
INSPECTOR. OPERATOR ENTERED LCO 3.5.2 AND
RETURNED 2A-A CCP TO A-AUTO MAKING PUMP
3 ~
3/9/88 2000 SHIFT SUPERVISOR WAS NOTIFIED OF EVENT BY NRC ,
INSPECTOR
I
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I.
If
t
L.. CONCLUSIONS
d
.-
- OPERATOR DID NOT RECOGNIZE THAT PUTTING
l THE CCP HANDSWITCH IN PULL-TO-LOCK RENDERED
L THE PUMP INOPERABLE
L * TWO SUBSEQUENT SHIFT TURNOVERS DID NOT
L IDENTIFY THAT THE PUMP WAS INOPERABLE
s BECAUSE OF THE HANDSWITCH BEING IN
Tl PULL-TO-LOCK
- HANDSWITCH POSITION WAS INCORRECTLY LOGGED
IN Al-5
L
..
h * INOPERABLE CONDITION OF 2A-A CCP WAS NOT
. IMMEDIATELY REPORTED TO SHIFT SUPERVISOR
- STA LOG ENTRY FOR MARCH 9,1988, AT 2020 EST,
WAS IN ERROR
i * WRITE 0VER IN Al-5 BY OPERATOR IS CONTRADICTORY
TO THE REQUIREMENTS OF Al-7 FOR A OA DOCUMENT
i:
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ROOT CAUSES !
l
,' o MANAGEMENT DID NOT ADEQUATELY CONSIDER THE POTENTIAL
AFFECTS OF TEMPORARILY ASSIGNING OPERATORS TO A COLD
'
'
SHUTDOWN UNIT AND BACK TO THE OPERATING UNIT (MODE 3).
- MANAGEMENT DIRECTION REGARDING DETAIL OF OPERATOR
g LOG ENTRIES AND OPERATOR COMMUNICATION WAS NOT
j A0EQUATELY DESCRIBED.
- Al-5 DOES NOT ADEQUATELY ADDRESS NONSCHEDULED
L SHIFT TURNOVERS.
I
1
- THE INTERPRETATION CONCERNING OPERABILITY OF A
4 PULL-TO-LOCK CCP IS NOT CONSISTENT WITH PLANT
-
MANAGEMENT PHILOSOPHY. i
- DISCREPANCY EXISTS BETWEEN G01-3 AND TECHNICAL
SPECIFICATION 3.1.2.4 FOR CCPs NEEDED FOR REACTIVITY
CONTROL.
d
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_. CORRECTIVE ACTIONS '
'
(SLIDE 10F 2)
- CONTROLS WILL BE ESTABLISHED TO LIMIT INTERCHANGING
OPERATORS FROM A COLD SHUTDOWN UNIT TO AN OPERATING
UNIT.
- Al-6, FOR OPERATOR LOG ENTRIES IS BEING REVISED
TO DELINEATE THE LEVEL OF DETAll FOR LOG ENTRIES
SUCH AS SPECIFYING SWITCH POSITIONS.
.
( * Al-30, FOR OPERATOR COMMUNICATION WILL BE REVISED
- TO SPECIFY REQUIRED INTERFACE OF OPERATORS DURING
3 CONTROL BOARD MANIPULATIONS WHILE SWITCH POSITIONS
ARE CHANGED OR TAKING MAJOR EQUIPMENT OUT OF SERVICE.
l * Al-5 WILL BE REVISED TO REQUIRE A CHECKLIST
i
COMPLETION (APPENDIX B1) FOR NONSCHEDULED SHIFT
REllEF.
,
- A REVIEW OF FORMAL TECHNICAL SPECIFICATION
!
,
INTERPRETATIONS (TSI) IS BEING PERFORMED FOR
! TECHNICAL ADECUiCY AND CLARITY. TSI MANUAL HAS
BEEN REMOVED FROM DIRECT ACCESS TO OPERATORS UNTIL
THIS REVIEW IS COMPLETE.
- Al-5 WILL BE REVISED TO REQUIRE THE UNIT SUPERVISOR
(SRO) TO OBSERVE THE MAIN CONTROL BOARD STATUS FOR
l
-
ABNORMAL CONDITIONS PRIOR TO ASSUMING SHIFT. THIS
OBSERVATION WILL BE DOCUMENTED IN THE UNIT SUPERVISOR LOG.
!
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_ CORRECTIVE ACTIONS
(SLIDE 2 0F 2)
T
- EVALUATE G01-3 REQUIREMENT TO PUT A CCP IN PULL TO
LOCK BELOW 350 DEGREES F FOR COLD OVERPRESSURIZATION
PROTECTION.
- SENIOR OFFICE OF NUCLEAR POWER MANAGEMENT
ADDRESSING OPERATIONS PERSONNEL ON THE CAUSES,
CONCLUSIONS, AND CORRECTIVE ACTIONS FOR THIS EVENT.
.
- SIGNS EMPHASIZING PLANT OPERATING MODE WILL BE
PLACED IN MCR AND AUXILIARY INSTRUMENT ROOM.
l * TECHNICAL SPECIFICATIONS 3.5.3 (MODE 4) AND 3.1.2.4
I (MODES 1-4 REACTIVITY CONTROL) WILL BE EVALUATED
TO DETERMINE IF A CHANGE IS NEEDED TO CLARIFY
THE OPERABILITY REQUIREMENTS OF CCPS FOR MODE 4.
- * TRAINING WILL BE GIVEN ON PROCEDURE CHANGES
AND TECHNICAL SPECIFICATION INTERPRETATION
CHANGES.
- SCENARIOS EMPHASIZING THE USE OF TECHNICAL
SPECIFICATIONS WILL BE INCORPORATED INTO OPERATOR
'
L SIMULATOR TRAINING.
- THE STA LOG ENTRY AT 2020 EST AND THE Al-5,
! 1500 TIME ENTRY WILL BE CORRECTED IN ACCORDANCE
WITH PLANT PROCEDURES.
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OPERATIONAL EVENT SUMMARY
-
-
, s
1. INADVERTENT ABI: (1-14-88)
.
2. PERSONNEL ERROR IN RETURNING TB SUMP RM TO SERVICE: (1-16-88)
"
3. INADVERTENT START OF (4) D/Gs: (1-27-88)
4. UNIT 1 CVI - WRONG UNIT / WRONG EQUIPMENT: (1-27-88)
5. FAILURE TO COMPLETE PMT ON ERCW RM: (1-30-88)
6. RX TRIP: (2-7-88)
..
7. TURBINE TRIP /FWl: (2-7-88)
8. FAILURE TO MEET SR RCS LEAKRATE: (2-8-8 8)
P 9. RCS LOSS OF INVENTORY - FCV-62-118 MISPOSITION: (2-9-88)
,
~ '
10. MAIN STEAM ISOLATION: (2-10-88)
11. LOSS OF NON-ESSENTIAL AIR IN CONTAINMENT UNIT 1: ' (2-10-88)
4
12. 1 A-A D/G TAGGED W/"B" CREVS INOP: (2-15-88)
L
l 13. COPS ACTUATION: (2-17-88)
l
14. MISINTERPRETATION OF CCS INDEPENDENT LOOPS: (2-26-88)
15. MSIV ACTUATION: (2-28-88) .
L 16. (2) UNIT 1 CVI: DUE TO EMI NOISE: (3-1-88)
l
17. TDAFW LCV NOT DECLARED INOP UPON SI-166.8 FAILURE: (3-5-88)
e
18. FAILURE TO DECLARE TDAFW VALVE (LCV) IHOP DUE TO COMMON
l SENSE LINE: (3-6-88)
19. NRC FOUND 2A-A CCP IN PULL TO LOCK: (3-9-88)
,
, , _ . . _ . , , . _ . . _ _ _ . . _ . _ _ , , . . . , . _ _ . , _ , - - . . . - - - - - - - - -
.
4 ,
EVENT CLASSIFICATION
PROCEDURAL INADVERTENT INADVERTENT
. DESCRIPTION NONCOMPLIANCE ESF ACTUATIONS LCO ENTRY
1 INADVERTENT ABI (1-14-88) X
3 D/G START (1-27-88) y
4 UNIT 1 CVI (1-27-88) X X
.
6 RX TRIP (2-7-88)
X X
,
7 TURBINE TRIP /FWI (2-7-88) X X
,' 8 RCS LEAKRATE (2-8-88) X X
,
FCV-62-118 POSITION (2-9-88)
-
10 MAIN STEAM ISOLATION (2-10-88) y y
11 LOSS OF AIR (2-10-88) X
. 12 CREVS INOP (2-15-88) X
,
13 COPS ACTUATION (2-17-88)
[ X
,
_
14 CCS LOOPS (2-26-88) y
i
15 MSIV ACTUATION (2-28-88) y
,
16 (2) UNIT 1 CVis (3-1-88) X
17 TDAFW LCV STROKE TIME (3-5-88) y y
(
,
TDAFW LCV SENSE LINE (3-6-88) x X
19 CCP IN PULL-TO-LOCK (3-9-88) X X