ML20154N512
| ML20154N512 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 09/15/1988 |
| From: | Harmon P, Jenison K NRC OFFICE OF SPECIAL PROJECTS |
| To: | |
| Shared Package | |
| ML20154N502 | List: |
| References | |
| 50-327-88-36, 50-328-88-36, NUDOCS 8809290327 | |
| Download: ML20154N512 (19) | |
See also: IR 05000327/1988036
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UNITED STATES
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NUCLEAR .9EGULATORY COMMISSION
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REGION ll
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101 MARIETTA ST
N.W.
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ATLANTA. GEORGIA 30323
Report Nos.:
50-327/88-36 and 50-328/88-36
Licensee:
Tennessee Valley Authority
6N38 A Lookout Place
1101 Market Street
Chattanooga, TN 37402-2801
Docket Nos.:
50-327 and 50-328
License Nos.:
OpR-77 and OPR-79
Facility Name:
Sequoyah 1 and 2
Inspection Conducted: July 12 - August 5, 1988
Inspector:
t A /$u d jen
'7/M/RP,
P. Ef Harmon, SepYop' Resident Inspector
Date Signed
Resident Inspectors:
D. P. Loveless
W. K. Poertner
P. G. Humphrey
'7!/Cff
Approved by: Y/h1
de
K. A' Jehisfn Acting Chief,
/)ateAi~ghed
ProjectsSectIon1
Div1sion of TVA Projects
SUMMARY
Scope:
This routine, announced inspection involved inspection onsite by the
Resident Inspectors in the areas of operational safety verification
protection, perationssafeguards and housekeeping inspections; maintenanc
including o
performance,
system lineups,
radiation
observations * surveillitnce testing observations; review of previous
inspectionfIndings;andreviewoflicenseeidentifieditems.
Results: One violation was identified.
Paragraph 6. - Failure to test Containment Spray check valves per
(327,328/88-36-01)
- 0ne unresolved item was identified.
Paragraph 2.a - Auxiliary Feedwater valve out of alignment per
(327,328/88-36-02)
No deviations were identified.
"Unresolved items are matters about which more information is required to
determine whether they are acceptable or may involve violations or deviations,
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Closures: LER's:
(0 pen) LER 327/88-07, Opening of Unit 1 containment results in
secondary containment envelope outside the boundary set for
surveillance testing of auxiliary building gas treatment system
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(Closed) LER 327/88-21, Improper RHR valve alignment resulting in
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loss of RCS inventory.
(Closed) LER 327/88-16, Rev.1
Inadvertent main steam isolation
caused by an inadequate review o,f a work package.
(Closed) LER 327/87-03
Potential for loss of containment air return
fanduetoadesignandconstructiondeficiency.
(0 pen) LER 327/88-14, LER 327/88-17, LER 327/88-23, Spurious
containment ventilation isolations due to iMI-induced radiation
monitor actuations.
(Closed) LER 327/87-61
Rev.1, Associated circuits that share a
common power sup)1y wIth appendix R circuits lacked selective
coordination due ;o inadequate design calculations.
(0 pen) LER 328/88-20, Check valves used as containment isolation
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valves in a raw water system did not pass leak rate test due to
improper application of valve usage.
(Closed) LER 328/88-24, Reactor trip resulting from low reactor
coolant system flow signal caused by a procedure noncompliance.
(Closed) LER 328/88-25, Failure to comply with a TS action statement
for diesel generator operability verification.
Violations:
(0 pen) VIO 327,328/87-66-02
Failure to establish, implement, and
maintain system operating Instruction procedures for system 63
(safety injection),
(Closed) VIO 327,328/87-76-02, failure to follow procedure.
(0 pen) VIO 327,328/88-02-01, failure to comply with procedural
requirements.
(Closed) VIO 327 328/88-06-02, Failure to adequately identify and
correct 50I checkiists for system aligreent.
(Closed) VIO 327,328/88-06-01 failure to specify qualifications and
train individuals performing system alignments.
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(Closed) VIO 327,328/88-20-01, Failure to develop or implement
procedures.
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(Closed)VIO 327,328/88-20-02, Missed surveillance test.
(0 pen) VIO 327 328/88-20-03, Failure to compl
specification ilmiting condition for operations.y with technical
(0 pen)VIO 327,328/88-20-04, Failure to ensure timely notification of
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the NRC of a loss of safety functions.
Unresolved items:
(Closed) URI 327,328/88-29-05, Adequacy of testing of check valves
72-547 and 72-548.
(Closed)URI 327,328/88-22-01, AFW valve out of position.
Conclusions:
In the area of Operational Safety Verification one URI was identified
concerning a mispositioned valve in the AFW system.
The remainder of the
items inspected in this area a)) eared to be adequate.
In the areas of
surveillance and maintenance all
items reviewed appeared to be adequate.
Additionally the licensee's corporate commitment tracking system was
reviewed, and on a limited scope of review, it appeared to be adequate.
Those items listed above were reviewed for closure during the inspection
period.
In those items designated as "closed" the licensee's actions
appeared to be adequate.
The items designated as "open" required further
review by the inspector or further action by the licensee as identified in
the body of the report.
Four items remain open from this re] ort which
recuire resolution prior to Unit I restart.
They are Viola; ion 327
32E/88-36-01, LER 327/88-07, LER 328/88-20 and Violation 327,328/88-20'03.
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REPORI DETAILS
1.
Licensee Employees Contacted
J. Anthony, Operations Group Supervisor
R. Beecken, Maintenance Superintendent
J. 83
- H. Co/num, Vice President, Nuclear Power Production
oper, Compliance L'icensing Manager
D. Craven
H. Elkins,, Plant Support SuperintendentInstrument Maintenance Group Mana
R. Fortenberr , Technical Support Supervisor
J. Hamilton,
uality Engineering Manager
- J. La Point
eting Site Director
L. Martin $iteQualityManager
R. Olson,, Modifications Manager
J. Patrick, Mechanical Maintenance Supervisor
Operations Group Manager
R. Pierce
M. Ray,SIteLicensingStaffManager
R. Rogers Plant Reporting Section
- B. Schofie,ld, Licensing Engineer
- S. Smith, Plant Mana er
S. Spencer, Licensin Engineer
M. Sullivan, Radiolo ical Controls Superintendent
C. Whittemore, Licensing Engineer
NRC Employees
- Attended exit interview
NOTE: Acronyms and initialisms used in this report are listed in the last
paragraph.
2.
OperationalSafetyVerification(71707)
a.
Plant Tours
The inspectors observed control room operations; reviewed applicable
logs including the shift logs, night order book, clearance hold order
configuration log and TACF log; conducted discussions with
book, l room operators; verified that proper control room staffing
contro
was maintained; observed shift turnovers
and confirmed operability
of instrumentation.
The inspectors verlfied the operability of
selected emergency systems, and verified compliance with TS LCOs.
The inspectors verified that maintenance work orders had been
submitted as required and that followup activities and prioritization
of work were accomplished by the licensee.
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Tours of the diesel generator, auxiliary, control, and turbine
buildings, and containment were conducted to observe plant equipment
conditions, including potential fire hazards, fluid leaks
and
excessivevibrationsandplanthousekeeping/cleanlinessconditions.
During an inspection tour of the unit #1 containment on August 1, a
large number of scaffolds, equipment, and other items were visible
which were being utilized for work efforts necessary to support work
required for restart of the unit.
The ice condenser was included in
the tour and the flow passages between the ice baskets in the areas
that had been cleaned appeared acceptable.
However the ice condenser
floor and turning vanes had not yet been cleaned and a large amount
of ice build-up existed there.
Work was continuing and close-out
cleanliness inspections had not been performed pertaining to these
two areas.
The inspectors walked down accessible portions of the following
safety related systems on Unit 1 and Unit 2 to verify operability and
proper valve alignment:
ResidualHeatRemoval(Unit 1)
Diesel Generator Starting Air (Units 1 and 2)
Auxiliary Feedwater (Unit 2)
During the walkdown of the AFW system the inspector identified that
valve 2-FCV-3-824, isolation valve to a sample sink, was open as
opposed to its 50! required configuration of closed.
This was
reported immediately to the U0 who placed the valve in the
configuration 100 as out of position.
The valve was later placed in
the proper posit'on.
This item will be reviewed further during the
next inspection period and is identified as URI 327,328/88-36-02.
No violations or deviations were identified.
b.
Safeguards Inspection
In the course of the monthly activities, the inspectors 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: protected and vital area access
controls; searching of personnel and packages; escorting of visitors;
and badge issuance and retrieval; patrols and compensatory posts.
In addition, the inspectors observed protected area lighting, ied
protected and vital area barrier integrity.
The inspectors verif
interfaces between the security organization and both operations or
maintenance.
Specifically, the Resident Inspectors:
(1) interviewed individuals with security concerns
(2)
inspected security during outages
(3) reviewed licensee security event report
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visited central or secondary alarn station
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verified protection of Safeguards Information
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verified ansite/offsite communication capabilities
No violations or deviations were identified.
c.
Radiation Protection
The inspectors observed HP practices and verified the implementation
of radiation protection controls.
On a regular basis, RWPs were
reviewed and specific work activities were monitored to ensure the
activities were being conducted in accordance with the applicable
RWPs.
Selected radiation protection instruments were verified
operable and calibration frequencies were reviewed.
The inspectors reviewed RWP #88-18-00 Rev. I during this reporting
aeriod.
The work location was for all areas of the auxiliary
auilding, except containment, and pertained to the inspection of pipe
supports for SMI-0-317-69 and associated work.
Protective clothing
was referenced and respirator protection was specified for specific
areas within the building.
Dose rate meters or dose warning devices
were required for various areas identified within the auxiliary
building per the special instructions.
In addition, HP coverage,
housekeep'ng, and the use of tools were specified with reference to
ALARA considerations.
The briefing attendance record was reviewed.
No deficiencies were noted.
The inspector reviewed RWP 1-88-19, unit 1 containment, upper and
lower.
No deficiencies were noted.
No violations or deviations were identified.
3.
Monthly Surveillance Observations (61726)
Licensee activities were directly observed to ascertain that surveillance
of safety-related systems and components was being conducted in accordance
with TS requirements.
The inspectors 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 than the individual directing the test; deficiencies were
identified, as appropriate, and any deficiencies identiffed 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.
Work activities in progress associated with the performance of SI-260.2.1,
Rev.3: BIT Cold Leg Injection Flow Balance, Pump Performance and Check
Valve Test, were reviewed during this reporting period.
This activity
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provided detailed steps to determine that the CCPs injection line flow
rates into tha reactor coolant system and total flow rates were within
technical specification limits.
It further provided that the check valves
in the flow path were fully stroked open during plant cold shutdown.
No
deficiencies or violations were noted.
The inspector monitored activities in progress associated with the
performance of SI-109, Channel Calibration for RHR Flow Rate.
No
deficiencies were noted.
The inspector reviewed the latest performance of SI-5, Auxiliary Feedwater
Valves Position Verification, and 50!-3.2, Auxiliary Feedwater System.
The procedures appeared to be adequate and the instruction correctly
performed.
No violations or deviations were identified.
4.
Monthly Maintenance Observations (62703)
Station maintenance activities of safety-related systems and components
were observed / reviewed to ascertain that they were conducted in accordance
with approved procedures, regulatory guides, industry codes and standards,
and in conformance with TS.
The following items were considered during this review:
LCOs were met
while components or systems were removed from service; redundant
components were operable
approvals were obtained arior to initiating the
work; activities were ac;complished using approvec
procedures and were
inspected as applicable; procedures used were adequate to control the
activity; troubleshooting activities were controlled and the repair
records 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;
sarts and materials used were
properly certified; radiological contro's were implemented; QC hold points
were established where required and were observed; fire prevention
controls were implemented; outside contractor force activities were
controlled in accordance with the approved QA program; and housekeeping
was actively pursued.
The inspector reviewed work activities in progress during the serformance
of WR #B751026.
This activity consisted of troubleshooting anc the repair
of the reactor building floor and equipment drain sump pump.
The problem
referenced was that the pump would not automatically start as required
when a high water level condition existed in the sump.
A second problem
existed in that the pump would not trip upon a low level condition.
The
work and documentation reviewed appeared satisfactory.
The inspector reviewed activities associated with WR #8281268 for the
repair of the 2A condensate booster pump.
These activities were essential
to correct lubrication and cooling water seal problems.
The suspected
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cause of the lubrication problem was that the oil pressure was actually
greater than normal.
This was caused by the auxiliary oil pump not
operating correctly; not starting when required; failing to stop when the
pressure reached the predetermined set-point, and therefore, contributing
to a higher oil pressure in the system.
No deficiencies were noted.
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The inspector monitored work activities in progress associated with WR
B789963.
The purpose of this work request was to replace the outboard
packing on component cooling water pump 1A.
No deficiencies were noted.
No violations or deviations were identified.
5.
Licensee Event Report Followup (92700)
The following LERs were reviewed and evaluated for closure.
The inspector
verified that: reporting requirements had been met; causes had been
identified; corrective actions appeared appropriate; generic applicability
had been considered; the LER forms were complete; the licensee had
reviewed the event; and no unreviewed safety questions were involved.
LER's Unit 1
(0 pen) LER 327/88-07, Opening of unit 1 containment results in secondary
containment envelope outside the boundary set for surveillance testing of
auxiliary building gas treatment system.
The inspector reviewed this event and the licensee's short and long term
commitments. The short term commitments were found acceptable for the
restart of Unit 2.
However, the corrective actions required for the
restart of Unit I have not been implemented and the licensee has committed
in the LER to revising the response by September 1,1988.
Pending the
review and acceptance of this response, this item will remain an open
restart item for Unit 1.
(Closed) LER 327/88-21, Improper RHR valve alignment resulting in loss
of RCS inventory.
This incident was reviewed by the shif t inspector and documented in
IR 327,328/88-28.
The LER was later reviewed and it was determined that
the licensee's short and long term corrective actions were appropriate.
The immediate actions were to correct the valve alignment and restore the
RCS inventory to the required volume.
The long term actions were to
revise the applicable procedures to prevent reoccurrence.
This included
a revision to AI-30, Rev. 19, Nuclear Plant Conduct of Operation, that
implemented the requirement to use cards to record information when
verbally directed to change the status of plant equipment and then
verbally repeat back the information to the supervisor prior to
performing the manipulation.
Additionally, the procedure required
the AUO's to realign the equipment to the original position in the
event that other than the desired results are encountered.
A further
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commitment in the LER involved the revision (Rev. 48) of SOI 68.1, Reactor
Coolant System, to add a H0 on valve, HCV-74-34, during RCS drain-down to
a specified level to prevent an inadvertent loss of suction to the RHR
system.
The requirement to place the H0 was also implemented in 50I 74.1,
Rev. 45, Residual Heat Removal System.
Based on the review of the event and the corrective actions taken by the
Licensee, this LER is closed.
(Closed) LER 327/88015, Rev. 1, Inadvertent main steam isolation caused by
an inadequate review of a work package.
This event resulted in an inadvertent main steam line isolation signal
being generated while replacing the flexible sense lines on steam flow
transmitter 1-FS-1-108.
At the time of this event bistable 1-FS-1-21A had
already been placed in the tripped condition by maintenance personnel.
Wnen bistable 1-FS-1-108 was accidentally tripped during the maintenance
activity, this completed the two out of three logic and generated a main
steam isolation signal.
The main steam isolation valves were closed at
the time the signal was generated so an actual isolation did not occur.
The inspector reviewed the licensee's submittal and proposed corrective
actions and found them acceptable.
This item is closed.
(Closed) LER 327/87-03, Potential for loss of containment air return fan
due to a design and construction deficiency.
During design reviews at Sequoyah, the licensee determined that the
potential existed for damage to and possible loss of one of the two
containment air return fans installed in each unit's containment.
The
potential damage mechanism was water accumulation from the containment
spray system that could enter the fan housing and impinge directly on the
fan blades after a design basis accident requiring containment spray.
The
fan housing is located flush with the upper containment floor.
The
previously installed kick plate style curbing had been removed as it
interfered with opening the nearby personnel hatch.
With no curbing
around the fan, water from the containment spray system could accumulate
on the floor, enter the fan, and disable it.
Only the train A fan for
each unit was affected, because the other fan is mounted above the floor
level.
Curbing was redesigned and installed for the Unit 2 fan prior to plant
startup.
The work for the Unit 1 fan was completed August 2,1988.
In
addition to the modifications to each fan, Revision 11 to SI-19,
Containment Systems Divider Barriers, Removable Curbs, Personnel Access
Doors and Equipment Access Hatches
3rovides a means of ensuring the
curbing around the A train fans is 'nstalled prior to closecut of the
containrent after an outage.
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This item is closed.
(0 pen) LER 327/88-014
LER 327/88-017, LER 327/88-023,
Spurious
Containment Ventilation Isolations due to EMI-Induced Radiation Monitor
Actuations.
The first of these three events occurred on March 14, 1988, and was caused
by IM's working on the containment purae radiation monitor,1-RM-90-130
without first having the operations staff place the monitor in "Block".
The IM personnel returned the radiation monitor's local sample pump switch
to the normal (run) position and the pump switch actuation caused an
electromagnetic interference spike to be induced into the monitor.
The
EMI spike caused the tripping of the high radiation bistable, and the
subsequent CVI.
The corrective action for this event was the issuance of
a memorandum to IM personnel, requiring them to contact operations so that
the RM trip signal could be blocked before performing any work on RMs
capable of actuating ESF equipment.
The second event, described in LER 327/88-017, occurred March 31, 1988.
This CVI was initiated when an AVO noticed that the abnormal flow alarm
light for 1-RM-90-130
was illuminated on the local RM panel.
In
attempting to clear tne alarm, the AVO jogged the RM sainple aump switch
off and then back on.
The pump switch actuation caused an Ell spike to
trip the high radiation bistable, and a CVI occurred,
The LER identified
the root cause of this event as improperly controlling the operation of
the sample pump switch af ter it had been identified as the cause of the
March 14 CVI described above.
The corrective action prescribed for this
event included the issuance of a memorandum to operations personnel
- imilar to the one previously issued to the IMs.
In addition, a H0 was
placed on the local sample pump switch to prevent operation until switch
replacement could be accomplished.
The third event, described in LER 327/88-023, occurred June 7, 1988, when
two CVIs occurred within 30 minutes of each other.
These CVIs were
initiated by EM personnel working on 1-RM-90-130.
The work, performed
under WR 8262490, was to replace the local sample pump switch on the RM
which had caused the previous two CVIs.
This WR was reviewed by the Unit
1 A505 prior to its im31ementation.
Power to the pump had been removed
before the work was initiated, and the A505 and the work planners assumed
that no EMI spike could be generated when the pump switc1 was actuated.
While the pump itself is powered from 480-volt power, an auxiliary set of
contacts to indicate pump status opens and closes in parallel with the
pump power supply.
These auxiliary contacts are electrically isolated
from the 480-volt power supply, but are common to the 120-volt power that
actuates the radiation analyzer for the RM.
TVA has theorized that the
status circuitry and the auxiliary contacts are the components causing the
Since the 480-volt pump power supply was
thought to be the source of the EMI spikes, (and that power was isolated),
the RM's handswitch was not placed in the "Block" position, which would
have prevented the CVIs described by this LER.
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These three LERs will remain open pending the completion of the licensee's
corrective actions to preclude recurrence of CVIs associated with
operation of the RM prior to placing the handswitch in "Block".
(Closed) LER 327/87061, Rev.1, Associated circuits that share a common
power supply with appendix R circuits lacked selective coordination due to
inadequate design calculations.
During calculation reviews the licensee identified several cases where a
fault on appendix R associated circuits could cause interruption of a
required circuit.
The cause of this deficiency was due to use of design
cable lengths for fuse / breaker sizing.
This LER was reviewed in inspection report 327,328/88-19 and was left open
pending review of revision 1 of the LER.
The inspector reviewed the
revision and found the description and corrective actions adequate.
This item is closed.
LER's Unit 2
(0 pen) LER 328/88-20, Check valves used as containment isolation valves in
a raw water system did not pass leak rate test due to improper application
of valve usage.
The licensee's proposed corrective action was to replace the unit one
valves prior to entering mude 4 operation.
The inspectors reviewed the
status of the work and determined that most of the field work had been
completed.
However, the associated work packages, WP 7378-01 and WP
7378-02, had not been closed.
This item will remain open and require a
disposition prior to unit 1 entering mode 4.
(Closed) LER 328/88-24, Reactor trip resulting from low reactor coolant
system flow signal caused by a procedure noncompliance.
The on-shif t inspectors reviewed the licensee's analysis of the events
associated with this reactor trip and the determination that the trip was
a result of a failure to follow procedure when removing and returning the
RCS flow transmitter to service during the calibration process.
This was
identified as violation, VIO 327,328/88-28-01.
The corrective actions
taken by the licensee includes determining the cause of the trip and a
review of the event with the instrument maintenance personnel to ensure
lessons learned from this event were identified and to re-emphasize the
necessity of procedural compliance.
A further commitment was cocitained in the LER to review previous reactor
trips for a similar occurrence of common equipment interactions causing
reactor trips and is being carried in the licensee's CCTS, Control No.
NCOSS013001.
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This issue will be reviewed under Violation 327,328/8.8-28-01.
The LER is
closed.
(Closed) LER 328/88-25, Failure to comply with a TS action statement for
diesel generator operability verification.
This issue involves the failure to meet the requirements of TS 3.8.1.1
action A when diesel
voltage relay testing. generator 1A-A was removed from service for degraded
This event was reviewed in Inspection Report 327,328/88-34 and resulted in
a violation being issued.
The inspector reviewed the LER and found the
licensee's corrective actions adequate.
This item is closed.
No violations or deviations were identified.
6.
Licensee Action on Previous Inspection Findings (92702)
(0 pen) VIO 327,328/87-66-02, Failure to establish, implement, and maintain
systemoperatinginstructionproceduresforsystem63(safetyinjection).
The inspector reviewed 501-63.1
Emergency Core Cooling System, and
determined that the corrections , identified in this violation had been
completed and documented in Inspection Report 327,328/87-76.
This item
has been determined adequate for the restart of Unit 1.
However, the
commitment to implement a phase 2 procedures enhancement program to ensure
human factors and consistency and clarity in all 501s has not been fully
implemented. This issue will remain open.
(Closed)VIO 327,328/87-76-02, Failure to follow procedure.
This event involved two examples of failure to follow procedure. The first
example resulted in an improper inspection of the 2A-A Hydrogen recombiner
and failure to identify anc remove an obstruction from the recombiner
orifice.
The second example involved the failure to properly drain and
depressurize a section of AFW piping prior to issuing a clearance on the
system.
Immediate actions were taken to correct the conditions and
long-term commitments were to revise SI-153.4, Test Requirements for the
Electric Hydrogen Recombiner System, to enhance the instruction and to
implement training to insure procedural compliance.
The inspectors reviewed the training documentation and found this effort
to be satisfactory.
The SI-153.4 revision has not been completed but has
been entered into the licensee's CCTS, Control No NC0880105001.
The
srocedures for Unit 1, SI-153.3.1, Test Requirements for the Electric
iydrogen Recombiner 1A-A, and 51-153.3.2, Test Requirements for the
Electric Hydrogen Recombiner 18-B, have been issued.
Based on these corrective actions, this item is closed.
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(0 pen) VIO 327,328/88-02-01, Failure to comply with procedural
requirements.
The inspectors reviewed actions taken by the licensee as a result of the
four examples identified in the subject violation cited.
The first
example cited the opening of the MSIVs with the reactor coolant system
temperature below that required by the procedure and resulted in a reactor
trip.
The second example involved opening only the #4 steam generator
MSIV which was in conflict with the system operating instruction, 501-1,1,
Main Steam Supply, which required all four MSIVs to be opened simulta-
neously.
The licensee's corrective actions associated with the two
exam)les above included upgrading of 501-1.1 to a category "A" procedure
whici requires the operator to have the procedure present and referred to
during the performance of the activity.
Further actions included a
maximum pressure difference limitation prior to opening the MSIVs and the
installation of temporary gauges for monitoring the pressures.
Example #3
cited the use of an "information only" drawing utilized to perform
troubleshooting / work in the plant on the containment spray system.
The
response to this issue is currently being revised.
Example #4 involved
poor housekeeping practices and the failure to properly perform SI-187,
Containment Ins)ection.
The corrective actions involved satisfactorily
re-serforming tie SI and active participation by
slant management to
emplasize the importance of maintaining a high stancard of work ethics.
Based on the above, this item has been determined technically adequate for
Unit I restart but will remain open until the licensee's revised response
has been received and evaluated.
(Closed) VIO 50-327,328/88-06-02, Failure to adequately identify and
correct 50! checklist; for system alignment.
The inspector reviewed a random sample of the 50!'s and verified that
revisions had been incorporated to correct the discrepancies identified.
Further, it was verified that G01-6, Rev. 34, Apparatus Operations
implemented the commitment for adding a definition ser. tion for electrical
devices.
The licensee's response tc IR 327,328/88-06
received on
March 30, 1988, which stated that all power availability checklists
contained in AI-58, Maintaining Cognizance of Operational Status - Con-
figuration Status Control, Appendix A, were reviewed to identify any
devices whose required position could be misinterpreted.
In addition, the
correct position for each com)onent was identified and correctiens to the
checklists were made as needec.
Valve alignments were then fielt) verified
and documented by utilizing the corrected checklists and no discrepancies
were discovered.
The above licensee efforts appear satisfactory and
therefore this violation is closed.
(Closed)VIO 327,328/88 06-01, Failure to specify qualifications and train
individuals performing system alignments.
.e
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The inspectors reviewed the revised method for independent verification
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implemented in Rev. 42 of G01-6.
This revision specified the method for
independently verifying e
Independent Verification, quipment status.In adc ition, AI-37, Rev. 5,
was revised to implement the requirement for
,
,
separation of independent verification.
The methods utilized for
'
verification, and the qualifications were specified for those persons
performing the verifications.
The licensee s corrective actions were
!
)
appropriate to correct the identified issue.
This violation is closed.
,
(Closed) VIO 327,328/88-20-01, Failure to develop or implement procedures.
f
.
A review of the corrective actions completed by the licensee appear
.
adequate.
Those actions completed included a revision to Al-6, Log
I
Entries and Review, which addressed the level of detail for log entries
,
a review of formal SQN TS interpretations for technical adequacy
and clarity; ining program; and entries made into the operation logs to
l
implementing the use of TSs into the licensed operator
!
simulator tra
reflect the findings of the valve non-actuation by the previous shifts.
t
'
However, the licensee committed to training the Unit 1 operators on
,
procedure changes and TS interpretation changes before Unit 1 enters mode
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2 operation.
This commitment must be satisfied prior to Unit 1 entering
t
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mode 2.
The commitment is identical to that made for corrective action
to VIO 327,328/88-20-03 below and will be tracked under that item.
1
Therefore, VIO 327,328/88-20-01 is closed.
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(Closed) VIO 327,328/88-20-02, Missed surveillance test.
The ins
i
actions.pector reviewed the licensee's long term and short term corrective
1
The short term action involved immediate sampling of the #3 cold
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leg accumulator which identified that the boron concentration was above
j
that allowed by TS.
The inleakage from the RCS causing this problem was
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corrected.
The long term corrective actions involved a revision of SOI
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63.1, Emergency Core Cooling System, and SI-2, Shif t Log.
Based on this
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review, corrective actions taken by the licensee were determined to be
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technically adequate.
This issue is closed.
l
(0 pen)imiting condition for operations. Failure to comply with technical specifi
.
VIO 327,328/88-20-03,
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tion l
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1
This violation arose from operators having the 2A-A CCP hand switch in the
!
pull-to-lock position when the pump was required to be operable.
Per
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- ,
conversations with the operators, they were relying on a TS interpretation
>
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that they believed existed which determined the pump to be opera)le with
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the hand switch in this position. Since this event, the licensee has
,
!
reviewed the TS interpretations because some were found in disagreement
with the TS and is requiring the operators to rely more on the TS.
In
f
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addition, the licensee committed to perform additional TS training of the
,
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Unit 1 operators.
This item will remain open and
should be resolved
[
]
prior to Unit 1 entry into Mode 2.
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(0 pen) VIO 327,328/88-20-04, Failure to ensure timely notification of the
NRC of a loss of safety functions.
The licensee's management became involved in the issue and has directed
the 50S's to be conservative in evaluations of events involving TSs and to
initiate a notification when situations indicate this action could be
required.
Based on these corrective actions, this item is closed as it
pertains to the unit I restart but will remain open until a formal NRC
acknowledgement to the licensee's response has been issued.
(Closed) URI 327,328/88-29-05, Adequacy of testing of check valves 72-547
and 72-548.
The inspector reviewed the adequacy"C" leak rate tested per 10 CFR 50
of the testing of valves 72-547 and
72-548 in that they are not type
Appendix J.
The adequacy of the containment isolation design with respect
to GDC-56 was reviewed by the staff during the review of the nuclear
performance plan and is documented in the May 1988 SER.
The SER ap
to address only the outboard isolation valves stating the following:peared
Isolation designs which are adequate on "some other defined basis"
are described in the standard review plan (SRP) Section 6.2.4,
"Containment Isolation System," and ANSI Standard N271-1976,
"Containment Isolation Provision; for Fluid Systems." For contain-
ment Spray line penetrations, as well as for other essential systems,
the SRP and the ANSI standard identify the use of remote manual
valves in lieu of automatic valves as acceptable.
TVA, on the other
hand, has traditionally relied on the closed system outside contain-
ment rather than identify an outboard remote manual valve as an
isolation valve.
Therefore, the staff conclusion that the testing of penetrations X-48A and
X-488 was acceptable, may not have taken into consideration the testing of
the check valves.
The inspector reviewed the testing of valves 72-548 and 72-547 as well as
valves 72-555 and 72-556, the RHR spray isolation valves, which are similar
in function.
These valves are not in a configuration to be type "C" tested
aer Appendix J.
There is no isolation between the valves and the spray
leaders making it impossible to individually test these valves.
On June 8,1988, NRC management notified the licensee that they were in
violation of Aspendix J.
The licensee declared the containment isolation
system inoperable at 2:10 p.m. and entered the Action Statement for
LCO 3. 6.1.1.
The licensee exited the LC0 upon determining that the
containment isolation system remained operable as defined by the TS.
This
decision was based on the fact that the containment spray isolation
configuration was similar to that of the UHI system and that an NRC
approved exeeption from Appendix J type "C" testing existed on the UHI
system.
This JC0 was documented on ICF 88-0935 to SI-14.2, Verification
of Containment Integrity, under the provisions of 10 CFR 50.59.
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10 CFR 50 Appendix J states that:
II.H.3
Type C testing is required for those valves that, " Are
required to operate intermittently under postaccident conditions..."
III.C.1
"Type C tests shall be performed by local pressurization.
The pressure shall be applied in the same direction as that
when the valve would be required to perform its safety
function..."
III.C.2
"Valves, which are sealed with fluid from a seal system
shall be pressurized with that fluid to a pressure not less
that 1.10 Pa."
Contrary to the above, the containment spray and RHR spray inboard
containment isolation valves have not been type C tested for the If fe of
the plant.
This is a violation and shall be identified as VIO
327,328/88-36-01.
The licensee discussed this issue with the inspector and stated that they
believe that they were always in compliance with the re
This
was based on a statement from Appendix J III.C.3 stating:gulations.
Leakage from containment isolation valves that are sealed with fluid
from a seal system may be excluded when determining the combined
leakage rate: provided , that;
(a) Such valves have been demonstrated to have fluid leakage rates
that do not exceed those s
associated bases, and (b)pecified in the technical specifications or
The installed isolation valve seal-water
system fluid inventory is sufficient to assure the sealing function
for at least 30 days at a pressure of 1.10 Pa.
This statement discusses only the combined type B and C leakage rate
calculations from a water sealed system.
The inspector does not take
issue with the exclusion of the penetration from the combined leakage rate
calculation per III.C.3.
The inspector also recognizes that Type C testing
for the outboard containment spray and RHR spray isolation valves pursuant
to III.C.2. is acceptable.
However, this does not exemat the licensee
from performing a type C test under the provisions of TII.C.1 for the
inboard containment spray and RHR spray isolation valves.
The issues of Appendix J requirements and testing /88-36-01;
of these check valves
for both units is addressed as Violation 327,328
therefore,
URI 327,328/88-29-05 is closed.
(Closed)URI 50-327,328/88-22-01, AFW valve out of position.
The inspectors reviewed the corrective actions committed to by the
licensee to prevent exiting an LCO when the system has not been properly
realigned.
This included a review of Rev.16 to Al-6, Log Entries and
Review, and associated log forms which frplemented the requirement for
documenting all specific actions /equipeent which could affect the
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14
operability of a system.
This documentation was intended to insure that
equipment that had been repositioned was reviewed and properly re-aligned
prior to declaring the system operable.
Based on these procedural changes
incorporated by the licensee, this item is closed.
7.
Commitment Tracking Review
The inspector reviewed the licensee's CCTS and TROI systems for timeliness
in meeting commitments, coordination between the two systems and the
licensee's implementation.
Over 100 items from the CCTS were reviewed for
timeliness.
Two items were identified as having missed the commitment
date.
Both items were discussed with NRC/OSP management prior to becoming
late.
These tracking and trending systems will be reviewed further during the
operational readiness inspection to be conducted prior to the unit one
restart.
No violations or deviations were identified during this review.
8.
Exit Interview (30703)
The inspection scope and findings were summarized on August 9, 1988, with
those persons indicated in paragraph 1.
The Senior Resident Inspector
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.
Inspection Findings:
One violation was identified in paragraph 6.
One unresolved item was identified in paragraph 2.a.
No deviations or inspector follow-up items were identified.
The licensee expressed at the exit interview that the plant was always in
compliance with Appendix J as it relates to the violation discussed in
paragraph 6 of this report.
The resident inspectors explained that the
licensee's position did not agree with the NRC staff's interpretation of
the regulations.
The licensee was also informed that they may further
address this issue in their response to the Notice of Violation.
During the reporting period, frequent discussions were held with the Site
Director, Plant Manager and other managers concerning inspection findings.
9.
List of Abbreviations
-
Administrative Instruction
AI
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ALARA -
As Low As is Reasonably Achievable
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ANSI
American Nuclear Standards Institute
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AVO
Auxiliary Unit Operator
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A505
Assistant Shift Operating Supervisor
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81T
Boron Injection Tank
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C&A
Control and Auxiliary Buildings
-
Centrifugal Charging Pump
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CCTS
Corporate Commitment Tracking System
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COPS
Cold Overpressure Protection System
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Containment Ventilation Isolation
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Direct Current
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EH
Electrical Maintenance Technician
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Electromagnetic Interference
-
Engineered Safety Feature
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Flow Control Valve
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FS
Flow Switch
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GDC
General Design Criteria
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GOI
General Operating Instruction
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Hand Control Valve
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H0
Hold Order
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Health Physics
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ICF
Instruction Change Form
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IN
NRC Information Notice
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IM
Instrument Maintenance
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IR
Inspection Report
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JC0
Justification for Continued Operations
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LER
Licensee Event Report
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LC0
Limiting Condition for Operation
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MI
Maintenance Instruction
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NRC
Nuclear Regulatory Commission
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Office of Special Projects
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PRO
Potentially Reportable Occurrence
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Quality Assurance
-
Quality Control
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-
Radiation Monitor
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-
Radiation Work Permit
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Safety Evaluation Report
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Surveillance Instruction
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SMI
Special Maintenance Instruction
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501
System Operating Instructions
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505
Shift Operating Supervisor
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Standard Review Plan
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TACF
Temporary Alteration Control Room
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TROI
Tracking Open Items
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TS
Technical Specifications
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Tennessee Valley Authority
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00
Unit Operator
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Unresolved Item
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Violation
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WP
Work Plan
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Work Request
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