ML20202J797
| ML20202J797 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry, Sequoyah, 05000000 |
| Issue date: | 03/31/1986 |
| From: | Brock L, Harrison M, Knightly J TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML082340316 | List: |
| References | |
| I-86-132-SQN, NUDOCS 8604160189 | |
| Download: ML20202J797 (8) | |
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TENNESSEE VALLEY AUTHORITY 4
NUCLEAR SAFETY REVIEW STAFF NSRS INVESTIGATION REPORT NO. I-86-132-SQN EMPLOYEE CONCERN:
XX-85-116-014
SUBJECT:
SQN SECONDARY WATER CHEMISTRY DATES OF INVESTICATION:
MARCH 10-12 and 19-20, 1986 3
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INVESTICATOR:
I DATE' J. J. KNIGHTLY 3[3/[fr(s REVIEWED BY:
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L. E. BROCK DATE APPROVED BY:
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I.
BACKGROUND A Nuclear Safety Review Staff (NSRS) investigation was conducted to determine the validity of an expressed employee concern received by the Quality Technology Company (QTC)/ Employee Response Team (ERT). The concern of record, as summarized on the Employee Concern Assignment Request Form from QTC and identified as KK-85-116-014, stated:
Sequoyah - Management (known) has signed off secondary water chemistry conditions that were in violation of the technical specifications without having an ensi-neering evaluation performed in violation of site pro-cedures. Time period of 1985. Nuclear Power concern.
Details known to QTC, withheld due to confidentiality.
No further information may be released. CI requests that QTC perform this investigation.
Clarifying information was requested from the ERT follow-up group to
)
identify specific conditions referred to in the statement of concern.
No additional information was available.
i II.
SCOPE A.
The scope of the investigation was determined from the stated concern of record to include the following issue for investigation:
Are the Sequoyah Nuclear Plant (SQN) secondary water chemistry conditions appropriately evaluated / reviewed by cognizant engineering personnel.
B.
To accomplish this investigation, NSRS reviewed applicable require-ments, instructions, previous audit reports, laboratory los sheets, recommendation sheets, daily reports, laboratory journals, and daily c'homistry trend reports. Additionally, responsible chemistry laboratory and engineering personnel were contacted to discuss the,
employee's concern.
III.
SUMMARY
OF FINDINGS A.
Requirements and Commitments 1.
Sequoyah Nuclear Plant Unit 1 and Unit 2 Technical Specifica-tions: Bases for Safety Limits Steam Cenerators, "The plant is expected to be operated in a manner.such that the secondary coolant will be maintained within those chemistry limits found to result in negligible corrosion of the steam generator tubes."
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1 2.
Sequoyah Nuclear Plant Technical Instruction TI-37, " Chemical Laboratory Log System Units 1 and 2," "When a value has been logged, it should be compared to the limit associated with each parameter.
If a parameter is out-of-limits, the analyst is responsible for circling the parameter and immediately informing i
the shift supervisor of the out-of-limits condition. The shift supervisor is responsible for taking action to return the parameter to acceptable conditions."
3.
Sequoyah Nuclear Plant Engineering Section Instruction Letter ES SIL C10. " Laboratory Actions for Out-of-Limit Conditions,"
" Attachment B contains a generalized recommendation sheet to be filled out when making recommendations to Operations documenting out-of-limit chemistry parameters involving Technical Specifica-tion limits or Secondary Chemistry Action Limits."
4.
Audits, reviews, and reports as follows:
a.
Meeting minutes for the February 13, 1986 NRC meeting at SQN on Chemistry (L44 860218 808), ".
. SQN Chemistry proco-dures.
. strongly endorsed. The quality control.
had improved.
. section staffing was judged to be adequate and stable.
A caution was put forward concerning ' hideout.'
High amounts of residue left in steam generators over long terms seemed to be showing up 7 or 8 fuel cycles later as tube degradation."
b.
INPO Evaluation of Sequoyah Nuclear Plant, April 1985, l
" Stringent secondary chemistry guidelines and action levels j
are closely followed."
c.
Division of Quality Assurance Audit. Report No. SQ-8400-14 Sequoyah Chemistry Program, dated November 2, 1984,
" Engineering Section Instruction Letter (ES SIL C10)
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Attachment F requires the completion of a Chemical Labora-tory Plant Recommendations sheet when making recommendationg to operations concerning primary, secondary, and auxiliary l
systems. This form is not always used..
j Additionally, this audit identified three occasions when
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specified power reduction was not accomplished within allowed timeframes to minimize corrosive effects following l
identification of secondary water action levels for steam generator blowdown cation conductivity and steam generator blowdown sodium. Follow-up audit documentation and inter-view statements during this NSRS investigation indicated that there were no delays or failures in reporting or evaluating the chemistry laboratory data. Other factors outside the laboratory controlled the timing of the power i
reductions.
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B.
Findings i
1.
Technical Instruction TI-37, " Chemical Laboratory Log System,"
provides the los sheets to be used for recording data by chemical laboratory personnel. When a value has been logged, it is to be compared to the limit associated with each parameter; if out-of-limits, the analyst is responsible for circling it and inmediately informing the, shift supervisor who is responsible for taking action to return the parar.ater to acceptable
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conditions.
Several p'ractices, as follows, are utilized by the laboratory to achieve traceability / accountability and cognizant review for the laboratory actions related to out-of-limits conditions:
(a) the analyst is to enter and initial a notation on the los sheet that the shift supervisor was notified of the I
out-of-limits condition. (b) the shift supervisor is to note the action taken to being the parameter within limits and to enter j
initials indicating disposition of the out-of-limits condition, 1
(c) the responsible engineer is to initial in the left margin j
signifying review and cognizance of icg sheet ent. ries.
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Traceability is also achieved through the daily laboratory journal which receives entries describing key activities of each l
shif t, and the Chemical Laboratory plant Recotunendation Sheets i
(SIL-CIO Attachment B) which provide out-of-limits notifications 3
and proposed corrective actions for approval by tha,' shift engineer whenever secondary chemistry actions levels are I
exceeded or an out-of-limit 2' condition exists which affects-Technical Specifications.s (Action levels are specified in TI-37
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and describe required acti'vii.ies and plant processes to be followed at each, level in the event that progressively more i
severe out-of-limits levels are identified.)
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I 2.
AnNSRSNamplingreviewofdocumentationforSQNsecondarywater j
chemistry indicated that traceability of out-of-limits condi-tions from the point 'of identification to subsequent evaluation, j
corrective action, and review was as follows:
i s.
Los Sheets. Unit 2 Steam Generator No. 1, Blowdown 5-100%
I power (Moi 41):
l 3
Los' sheets.huly26-August 22, 1985, identified three j
j instanece' of parameters out-of-limits.
In all instances l
corrective actions ware recorded / explained, signed off by J
the shift supervisor, and initialed as reviewed by the cognizant engineer.
It was stated by SQN personnel that'the mode 1 chemistry conditions receive careful scrutiny.
j Additionally,'the mode 1 chemistry paramaters were found to j
be chieted and trended'in a monthly trend report for manage-i ment ceview..
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b.
Log Sheets Feedwater Unit 2 Log sheets March 21 - August 21, 1985, identified 41 instances of parameters out-of-limits with supervisory notification documented in 22 of these instances and corrective action or explanation documented in 19 instances. Log sheets were initialed indicating cognizant engineer review. There was no evidence that parameters remained out-of-limits; that is, parameters were recorded as being back within limits in subsequent samples, l
c.
Log Sheets Feedwater Unit 1:
Log Sheets August 4 - August 21, 1985, identified 13 instances of parameters out-of-limits with supervisory notification documented in 9 of these instances and corrective action or explanation documented in 4 of the instances. Log sheets were initialed indicating cognizant engineer review.
d.
Log Sheets Unit 1. Steam Generator No. 2. " Blowdown for Startup (!: odes 2-5):
Los sheets April 13 - August 28, 1985, for times other than power operation identified numerous instances of parameters out-of-limits, with supervisory notification and corrective action or explanation documented in two-thirds of the instances. Los sheets were initialed indicating cognizant engineer review.
4.
Cognizant personnel stated the following observations regarding tho above data on traceability of out-of-limits conditions:
Monitoring of data to assure that subsequent samples come a.
back into range is a fully adequate response in given circumstances. No other action is needed and specific documentation of the monitoring would not necessarily be recorded.
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b.
Certain out-of-limits parameters are understandab'le and unavoidable on a temporary basis because of activities /
conditions known to be occurring in the plant.
Full documentation for traceability with each laboratory sample l
would serve no purpose.
I Conditions are discussed with engineering personnel in some c.
instances by telept.one without full documentation on the log sheets.
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d.
Laboratory los sheet data is circulated for review daily to the laboratory supervisor, cognizant chemical engineer, and Chemical Unit Supervisor.
Eighteen copies of the daily chemistry reports are distributed daily to the shift engineer, operations supervisor, plant manager, and others.
Mistakes are visible and any persistent pattern of errors would be widely recognized.
During power operations the SQN daily chemistry parameters trend reporting system also provides a visible and objective record of the effectiveness of the chemistry program. Overall, SQN chemistry receives high visibility and extensive review.
IV.
CONCLUSIONS AND RECOMMENDATIONS A.
Conclusion The administrative system for monitoring and reviewing SQN secondsry water chemistry conditions was found to be functioning adequately, based on a sample review of the 1985 secondary water chemistry documentation and discussions with cognizant plant personnel.
The sampling did not identify an error of the type described in the employee's statement of concern. Laboratory personnel acknowledged that such an error could occur; however. NSRS found a sa'tisfactory system of supervisory and engineering review by several different l
individuals was in place to identify repetitive or continuing problems either of a chemistry or administrative nature. A general concern in this area is not substantiated.
B.
Recommendations None o
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DOCUMENTS REVIEWED IN INVESTIGATION I-86-132-SQN AND REFERENCES 1.
Sequoyah Nuclear Plant Unit 1 and Unit 2 Technical Specifications 2.
Sequoyah Nuclear Plant Technical Instruction TI-37, " Chemical Laboratory Log System Units 1 and 2." Revision 32 3.
Sequoyah Nuclear Plant Engineering Section Instruction Letter ES SIL C10
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" Laboratory Actions for Out-of-Limit Conditions," Revision 35 4.
Los Sheets SQN Clerical Laboratory:
I Feedwater Unit 1 August 4-21, 1985 Feedwater Unit 2 March 21 - August 21, 1985 l
Steam Generator No. 2. Unit 1, Blowdown for Startup (Modes 2-5),
April 13 - August 28, 1985 Steam Generator No. 1. Unit 1, Blowdown for Startup 5-100% Power (Mode 1)," July 26 - August 22, 1985 5.
Sequoyah Nuclear Plant Technical Instruction TI-27, " Chemistry qpecifica-tions Units 1 and 2," Revision 25 j
l 6.
Sequoyah Nuclear Plant Technical Instruction TI-16. " Chemistry Specifica-tions Units 1 and 2 " Revision 25 7.
DPM N79E2,Section I, " Water Quality Specifications" 8.
Sequoyah Nuclear Plant General Operating Instruction GOI-2, " Plant Startup from Hot Standby to Minimum Load," Revision 42 9.
Sequoyah Nuclear Plant General Operating Instruction GOI-01 " Plant S,tartup from Cold Shutdown to Hot Standby," Revision 56 I
10.
Daily Chemistry Trends / Chemical Parameter Reports, Units 1 and 2 June-July-August 1985 11.
Meeting minutes for the February 13, 1986 NRC meeting at SQN on Chemistry (L44 860218 808) l 12.
INFO Evaluation of Sequoyah Nuclear Plant, April 1985 13.
Division of Quality Assurance Audit Report No. SQ-8400-14 Sequoyah Chemistry dated November 2, 1984 14.
CAR 84-03-009 dated March 21, 1984 CAR 84-06-014 dated June 11, 1984 6
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- TVA 61 cds+esi cor-wr4-as UNITED STATES GOVERN 31ENT Memorandum TENNESSEE VALLEY AUTHORITY TO W. C. Bibb, Site Director, Browns Ferry Nuclear Plant FROM K. W. Whitt, Director of Nuclear Safety Review Staff, E3A8 C-K DATE
- March 31, 1986
SUBJECT:
NUCLEAR SAFETY REVIEW STAFF INVESTIGATION REPORT TRANSMITTAL Transmitted herein is NSRS Report No.
I-85-773-BFN Subject THERMAL OVERLOAD BYPASS AND INDICATION PROBLEMS Concern No.
IX-85-122-026 and associated recommendations for your action / disposition.
It is requested that you respond to this report and the attached recommendations by May 1, 1986.
Should you have any questions [ h #
please contact W. D. Stevens at extension 6231-K.
..nsa.
NUllEM Pt*T Recommend Reportability Determination: Yes No [
lid O i 'Oti 4
'. W. Whitt l
f WDS:BRP 7ff Attachment g*
cc (Attachment):
n H. L. Abercrombi
, SQN M. L. Martin, WBN W. T. Cottle. WB D. R. Nichols, E10A Y
J. P. Darling, BLN QTC/ERT, CONST-WBN R. P. Denise LP6N40A-C E. K. Sliger, LP6N40
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--Copy and Return--
To :
K. W. Whitt, Director of Nuclear Safety Review Staff, E3A8 C-K From:
Date:
I hereby acknowledge receipt of NSRS Report No.
i Subject for action / disposition.
Signature Date r
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Rouse II C Coeses'se nt Enn oit Ron,rinriv nn the Pavrall etarn*nos Plan
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