ML20205P021
| ML20205P021 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 05/06/1986 |
| From: | Debs B, Harmon P, Jenison K, David Loveless, Linda Watson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20205P007 | List: |
| References | |
| 50-327-86-19, 50-328-86-19, IEIN-85-069, IEIN-85-69, IEIN-86-017, IEIN-86-17, NUDOCS 8605210078 | |
| Download: ML20205P021 (22) | |
See also: IR 05000327/1986019
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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REGloN 11
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101 MARIETTA STREET, N.W.
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ATLANTA, GEORGI A 30323
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Report Nos.:
50-327/86-19 and 50-328/86-19
Licensee:
Tennessee Valley Authority
6N38 A Lookout Place
1101 Market Street
Chattanooga, TN 37402-2801
Docket Nos.:
50-327 and 50-328
License Nos.: DPR-77 and DPR-79
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Facility Name:
Sequoyah Units 1 and 2
Inspection Conducted:
March 6 - April 5, 1986
/[8d
Inspectors:
s
K. M. Jenison, denior Resid p I6s
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Date Signed
f M ~ d f l. A
SNet
L. J. Watson, Kesident EnsqpG or [ ~
Date Signed
P f* / & - A A
J e t.
S//Jos
P. E. Harmoa, <esident Ins fctor y
Date Signed
rf*f%M
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D. P.
]vtn e s s , Kesident Wfspectorf
Date Signed
Approved by:
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B. T. Debs, Section Chief.
Date' Signed
Division of Reactor Projects
Summary
Scope:
This routine, announced inspection involved 451 resident inspector-hours
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onsite in the areas of:
operational safety verification (including operations
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performance, system lineups, radiation protection, safeguards and housekeeping
inspections); surveillance and maintenance observations; review of previous
inspection findings; followup of events; review of licensee identified items;
review of IE Information Notices; review of Part 21 implementation; and review of
inspector followup items.
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Results: Three violations were identified:
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8605210078 860513
ADOCK 05000327
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1.
Failure'to establish adequate procedures as required by Technical Specifica-
tion (TS) 6.8.1 for verification of valve positions critical to the
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operation of ~ the auxiliary building gas treatment system, emergency gas
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treatment system and upper head injection system (paragraph 3).
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2.
Failure to implement procedures as required by 10CFR 50 Appendix B,
Criterion V, for the following activities (paragraphs 6 and 10):
a.
Control of fuses in en Energency Diesel Generator support system.
b.
Review of Unreviewed Safety Question Determination for a field change
request (FCR) to the Unit 2 Train A hydrogen analyzer.
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c.
Review of system drawings and independent review of system design prior
to approval of a FCR.
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d. ' Provisions for auditabl'e record of design reviews which support plant
,modjfications.
e.
Plant Operations Review Committee review of modifications.
3.
Failure to meet the Limiting Gondition for Operation for TS 3.6.4.1 which
requires the two trains of hydrogen analyzers to be operable in Modes 1 and
2 (paragraph 10).
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REPORT DETAILS
1.
Licensee Employees Contacted
H. L. Abercrombie, Site Director
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- P. R. Wallace, Plant Manager
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- L. M. Nobles, Operations and Engineering Superintendent
- B. M. Patterson, Maintenance Superintendent
- J. M. Anthony, Operations Group Supervisor
- R. W. Olson, Modifications Branch Manager
M. R. Sedlacik, Electrical Section Manager, Modifications Branch
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- H. D. Elkins, Instrument Maintenance Group Manager
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C. W. LaFever, Instrument Engineering Supervisor
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M. A. Scarzinski, Electrical Maintenance Supervisor
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- M. R. Harding, Engineering Group Manager
- D. C. Craven, Quality Assurance Staff Supervisor
D. L. Cowart, Quality Surveillance Supervisor
- D. E. Crawley, Health Physics Supervisor
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- G. B. Kirk, Compliance Supervisor
M. L. Frye, Compliance Engineer
H. R. Rogers, Compliance Engineer
- R. C. Burchell, Compliance Engineer
D. H. Tullis, Mechanical Maintenance Group Supervisor
J. H. Sullivan, Regulatory Engineering Supervisor
- P. R. Hitchcock, Mechanical Engineer, Mechanical Maintenance
- L. S. Bryant, Engineering Supervisor, Mechanical Maintenance
- W. E. Andrews,' Site Quality Manager, QA
- T. A. Kontovich, Electrical Maintenance Engineering Supervisor
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- M. J. Blankenship, Manager, Information Services
J. S. Steigleman, Unit Supervisor, Fealth Physics
C. L. Lagasse, Instrument Maintenance Foreman
Other. licensee employees contacted included technicians, operators, shift
engineers, security force members, engineers and maintenance personnel.
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Other:
- R. W. Bass, BETA
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- Attended exit interview
2.
Exit Interview
The inspection scope and findings were summarized with the Plant Manager and
members of his staff on April 15, 1985.
Three violations, two of which
involved multiple examples, were discussed. The violations are described in
paragraphs 3, 6, and 10. ~ Three unresolved items, described in paragraphs 5
and 7, were also discussed.
The licensee acknowledged the inspection
findings.
The licensee did identify material reviewed by the inspectors
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during this inspection as proprietary. However, no proprietary information
was included in this inspection report.
During the reporting period,
frequent discussions were held with the Site Director, Plant Manager and
other managers concerning inspection findings.
At no time during the
inspection was written material provided to the licensee by the inspector.
3.
Licensee Action on Previous Inspection Findings (92702)
(Closed) Violation 327/85-17-04 and 328/85-17-03.
This violation involved
examples of inadequate written procedures in three separate areas: (1)
surveillance testing, (2) maintenance activities, and (3) post-modification
testing.
The inspector reviewed the licensee's corrective actions for the
procedures involved and the documentation of the procedural changes.
The
licensee's corrective actions appear to be adequate. This item is closed.
(Closed) Unresolved Item 327,328/85-43-02.
This unresolved item was
identified when the inspectors determined, during a walkdown of the
auxiliary building gas treatment system (ABGTS), that valves in the air
supply to all air operated dampers in the ABGTS were not included in the
valve checklist for system operability.
Isolation of these valves could
result in loss of the capability to automatically open dampers required for
system operability.
The inspector reviewed additional examples of licensee controls for position
verification of other valves critical to the operation of safety-related
dampers and valves.
The inspector determined that the system lineup
checklist for the emergency gas treatment system (EGTS) did not include air
supply valves, which if isolated could result in the inoperability of
dampers required to open for use of the EGTS.
The inspector also reviewed
the control of the hydraulic lock release valves which must be in a
throttled open position to assure the closure of the UHI isolation valves on
low UHI water accumulator level.
The inspector determined that the valves
were not locked in position and the position was not verified during system
operability walkdowns.
TS 6.8.1 requires that procedures be established as recommended in Appendix
A to Regulatory Guide 1.33, Revision 2.
RG 1.33 requires that procedures
address startup of safety-related equipment.
The licensee utilizes System
Operating Instructions to meet this requirement.
Failure to adequately
establish procedures for the control of valves critical to the operation of
safety-related equipment is a violation (327,328/86-19-01). Unresolved item
327,328/85-43-02 on this issue is closed.
(Closed) Unresolved 327,328/86-06-06. The inspectors reviewed modifications
to the hydrogen analyzers which resulted in failure to provide a safety-
related air supply to the analyzers.
Two violations as discussed in
paragraph 10 of this report were cited. This unresolved item is closed.
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(0 pen) . Violation 327, 328/85-45-06.
The licensee's response to the
violation dated March 20, 1986, was reviewed. The inspector noted that the
response to the violation did not address corrective action in regard to
trending calibration data for safety-related systems to assure that
out-of-calibration conditions are identified and evaluated. The licensee's
Nuclear Performance Plan does address this trending program.
Followup on
these licensee actions on trending will. be reviewed as part of the inspec-
~ tion of the Nuclear Performance Plan commitments.
The inspectors observed installation and testing of the Upper Head Injection
level switches.
One inspector followup item and one unresolved item were
identified as described in paragraphs 7 and 8.
The installation of the
level switches is considered complete; therefore, part b, of the violation
is. closed.
The violation will be held open until inspection of corrective
action for part a. is completed.
4.
Unresolved Items
Unresolved items are matters about which more information is required to
determine whether they are acceptable or may involve violations or devia-
tions.
Three unresolved items were identified during this inspection as
discussed in paragraphs 5 and 7.
5.
Operational Safety Verification (71707)
a.
Plant Tours
The inspectors observed control room operations, reviewed applicable
logs, conducted discussions with control room operators, observed shift
turnovers, and confirmed operability of instrumentation.
The
inspectors verified the operability of selected emergency systems,
reviewed tagout records, verified compliance with Technical Specifica-
tion (TS) Limiting Conditions for Operation (LC0) and verified return
to service of affected components.
The inspectors verified that
maintenance work orders had been submitted as required and that
followup activities and prioritization of work was accomplished by the
licensee.
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
excessive vibrations 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 operability and
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proper valve alignment:
Residual Heat Removal System (Units 1 and 2)
Diesel Generdtor 1A-A and IB-B Air Start System, ERCW Supply
and Fuel Oil System (Units 1 and 2)
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Auxiliary Control Air (Units 1 and 2)
Auxiliary Building Gas Treatment System (Units 1 and 2
One violation discovered during the walkdown of the Emergency Diesel
Generator is discussed in paragraph 6.
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 shifts of the security force was observed in the conduct of
daily activities including protected and vital area access controls;
searching of personnel, packages and vehicles; escorting of visitors;
badge issuance and retrieval; and patrols and compensatory posts.
In addition, the inspectors observed protected area lighting, protected
and vital area barrier integrity and verified the interface between the
security organization and operation and maintenance.
The inspectors
visited the secondary alarm station and interviewed security personnel
regarding response to security events.
A concern was identified
related to the update of procedures.
The licensee corrected the
concerns prior to the end of the inspection period.
No violations or deviations were identified.
c.
Radiation Protection
The inspectors observed Health Physics (HP) practices and verified
implementation of radiation protection control.
On a regular basis,
radiation work permits' (RWPs) were reviewed and specific work activi-
ties were monitored to assure the activities were being conducted in
accordance with applicable RWPs.
Selected radiation protection
instruments were verified operable and calibration frequencies were
reviewed.
(1) On January 15, 1986, the licensee determined that cracks in the
walls of the Condensate Demineralizer Waste Evaporator Building
(CDWEB) were allowing seepage of radioactive water into a
non-regulated area.
An NRC specialist reviewed this event and
the results of the inspection were provided in NRC Inspection
Report 327,328/86-04.
In addition to the radiological aspects
of the inspection, several concerns were raised regarding main-
tenance of the evaporator recirculation pumps and CDWE venti-
lation.
Areas of concern identified by subtitle below were
reviewed.
(a) t4aintenance Activities
The inspector reviewed the licensee actions concerning the
maintenance of radwaste systems in the CDWEB.
The
licensee has experienced problems with drainage from steam
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traps in the moisture and steam wash drain system, blocked
floor drains and failure of recirculation pump seals
resulting from loss of seal water.
The floor around the
pumps and other areas subject to leakage slopes toward the
outside wall of the CDWEB and away from the drain
resulting in standing water in these areas.
The licensee has initiated modifications to reslope the
floor toward the drains and provide a backup supply of
seal water to the pump seals. The licensee has unclogged
floor drains and routed drains from the steam traps and
moisture separator to the floor drains.
The licensee
stated that the repair of the cracks in the building wall
has been completed and the floor will be recoated
following work to reslope the floor.
However, due to
other work loads, the licensee has delayed implementation
of some of these work plans.
(b) Review of Major Changes to the Liquid Radwaste System In
Accordance With TS 6.15
In 1982, the licensee changed the permanent lineup of the
radwaste system to allow the CDWE to process all radwaste
produced by the plant.
The licensee removed the original
waste and auxiliary waste evaporators from service.
Previously, the CDWE only processed waste from the
condensate demineralizer system and the floor drain
collector tank.
The new configuration allows the CDWE to
process the contents of the tritiated drain tanks.
In
addition, the licensee installed and utilized mobile
radwaste procsssing equipment with temporary connections
to the radwaste system.
The licensee stated that
permanent piping changes were not made to accomplish these
functions.
These changes in the permanent lineup involved a major
change to the liquid radwaste system and thus should have
been reviewed in accordance with TS 6.15.
The licensee
provided the inspector with a safety evaluation dated
April 26, 1985.
The inspector reviewed the safety
evaluation and although it discusses the 10 CFR 50.59 evaluation, the inspector determined that it
did not meet all the requirements for the review
required by TS 6.15.
The licensee also provided an
FSAR update on April 11, 1985.
The FSAR update does
not appear to meet the requirements of TS 6.15.
Also, the licensee was not able to provide evidence
of a PORC review of the radwaste system change.
Determination of the licensee's compliance with TS 6.15 is identified as Unresolved Item 327,328/86-19-02.
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.(c)' CDWEB Ventilation-
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,The inspector reviewed the ventilation to the CDWEB and -
determined that' the CDWEB ventilation is supplied by the
' Auxiliary Building general ventilation system.
The
exhaust. is routed to' the Fuel Handling area ventilation
system and to the Auxiliary Building stack.
Radiacion
monitors in -the Auxiliary Building stack cause an
isolation of any radi_oactive release to the environment
during normal operation on receipt of a high radiation
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signal.
However,- the -CDWEB is isolated from the Auxiliary
Building during an Auxiliary Building Isolation (ABI).
The' CDWE is continuously manned during operation of the
processing system.
During extended periods of Auxiliary
Building isolation or indications of high radiation levels
in the CDWEB, the system is manually shutdown and the CDWEB
is evacuated.
The building remains evacuated until deter-
s
-minations are made that radiation levels in the 'ouilding .
are acceptable for reentry.
.The evacuation is controlled
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administratively.
Review of the licensee's administrative
controls for evacuation and cleanup of the CDWEB -is identi-
fied as IFI'327,328/86-19-04
~ The CDWEB is a Seismic Category 'I building with ~one
entrance through double doors from the yard and one
entrance from the Auxiliary Building.
The FSAR . states
that the CDWEB will be maintained at a slight negative
pressure by the normal ventilation system.
This is not
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accomplished during an ABI.
The inspector expressed a
concern that the building could contain airborne radiation
and be' isolated from cleanup systems.
The licensee is
evaluating the CDWEB _for potential release paths.
This
issue
is
the
first example of Unresolved
Item
327,328/86-19-03.
(d) HVAC
The inspectors reviewed documentation related to the HVAC
for the CDWEB.
The CDWEB has two HVAC units which are
described in the FSAR and are designed to maintain the
building temperature below 105 degrees F.
One of these
units has been inoperable for approximately two years.
The second unit does not operate at optimal performance
and has : at times been inoperable during summer months.
There is no method to assure that the FSAR temperature has
been maintained.
This issue is the second example of
Unresolved Item 327,328/86-19-03.
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(e) Preventive Maintenance and ALARA
Working conditions and -ALARA implementation in this
building, which is continuously manned when the CDWE is in
operation, have been a continuing problem.
Additional
cleanup time for spills was expended because of the
chronic problems with the floor drains stopping up and the
floor sloping away from the drain in many areas.
Contamination under control panels in the control area
have resulted from the spills.
Plans for permanent
improvements were initiated by DCR 1513 in February,1982.
To date only a few of the modifications have been made.
These modifications were made in August, 1985.
FSAR Section 11.2.4 states that all equipment installed to
reduce radioactive effluents to the minimum practical
level is maintained in good operating order.
In addition,
the section states. that in order to assure that these
conditions are met, administrative controls. are exercised
on overall operation of the system, preventive maintenance
is utilized to maintain equipment in peak condition and
experience available from similar plants is used in
planning for operation.
In light of the problems
discussed above, many of which have existed since the
original design of the CDWEB and were not corrected for a
number of years after increasing the volume of radwaste
processed by the CDWE, adherence to licensee commitments
in regard to maintaining the liquid radwaste system in
good operating condition is questionable.
The inspector discussed the preventive maintenance program
with the licensee.
The FSAR states that preventive
maintenance will
be
implemented based on vendor
recommendations.
The licensee stated that the only
preventive maintenance was walkdowns of the liquid
radwaste system and correction of problems affecting
operation.
The inspector will review implementation of
vendor recommendations.
This review is identified as the
third example of Unresolved Item 327,328/86-19-03.
(2) On March 26, 1986, during an observation of work being done under
MR A-529943, the inspector reviewed RQP 02-0-86668 associated with
the job.
It was noted that workers were wearing the appropriate
protective clothing.
Also, the RWP log showed that the indivi-
duals were not exceeding their stay limits.
The inspector
observed that a condition on the RWP required "HP to provide Job
Coverage."
An HP trainee had signed off on March 25, 1986, for
this coverage.
The workers told the inspector on March 26, 1986,
that the HP had pulled an air sample prior to work commencing the
day befora. When questioned, the workers stated that they had not
seen any HP coverage on the job that day.
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Licensee personnel indicated to the inspector that there was no
problem with the situation.
They indicated that the RWP was
unclear, in that coverage was only required when breaching the
system or when performing special processes on potentially
contaminated components. The licensee further indicated that only
clean piping was being worked on during the time of the inspector's
observations. The inspector reviewed the surveys for the zone and
found the piping to be within acceptable limits for the welding
and grinding being done.
The apparent poor ALARA practice of
fitting and welding clean pipe in a contaminated area was brought
to the attention of the licensee.
The inspector discussed with the licensee the procedures for use
of HP trainees in day-to-day activities. Trainees are required to
complete each section of a Health Physics training program and
complete an oral examination on that section before they are
allowed to perform tasks covered under that section.
The
inspectors reviewed the qualifications of the trainees involved
with the surveys under RWP-0-86668 and determined that they had
completed the appropriate sections of their qualifications.
No violations or deviations were identified.
d.
Inspection of Licensee's Performance of Primary Calorimetries
The inspectors evaluated the licensee's performance of primary
calorimetries to ascertain secondary electrical power generation.
Sequoyah Unit 1 electrical output decreased beginning in the third fuel
cycle in June 1984.
TVA employed a vendor to investigate the problem,
confirm the cause of the reduction in electrical output and identify a
course of actinn to recover the loss in output.
Preliminary determinations were that the reduction in electrical output
was being caused by fouling of the venturi nozzles used for feedwater
flow measurement.
The fouling of the venturi nozzles caused a change
in the ratio of actual flow through the nozzle to the differential
pressure across it.
This ratio of flow rate to differential pressure
was used by the P-250 process computer to calculate reactor power.
A special test was written to incorporate the use of ASME nozzles on
the condensate side of Unit 1.
Calorimetries were performed using the
condensate flow nozzles, the P-250 and a third set of specialized
instruments (Rosemonts).
In 1983 corrections were made to the P-250
calorimetric based on the difference between the condensate and
feedwater calorimetries.
This correction was applied directly to the
flow conversion constant.
In 1984 the licensee determined that the
condensate flow nozzles were also starting to foul.
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The licensee contracted with a vendor to develop a calorimetric
comparison process. The comparison method was approved by the licensee
for use in 1985.
This calorimetric comparison was incorporated into a
Technical Instruction (TI-2).
After each performance of TI-2, a
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correction was made to the feedwater flow conversion constant such that
the P-250 and Rosemont generated calorimetrics remained within 1% of
each other.
The inspector found the calorimetric comparison process to be repea-
table and the conversion constants appeared to be conservative with
respect to.the setting of primary instrumentation.
No violations or deviations were identified.
c.
The inspectors reviewed documentation concerning an Auxiliary Building
Isolation event that occurred on April 4,1986 at 0740 CST. The event
was caused by an electrician stepping on the disconnect switch for the
" Instrument Power Distribution Panel 1A" transformer, causing the
switch to open.
The inspectors reviewed the event to verify that the
event was caused tar personnel error and not by some underlying cause.
The electrician involved was working overhead on fire protection
modifications, and was climbing down from the scaffolding at the time
of the occurrence. The licensee reported this event within four hours.
No violations or deviations were identified.
6.
Engineered Safety Features Walkdown (71710)
a.
The inspector verified operability of the Emergency Diesel Generators
(EDGs) on Units 1 and 2 by completing a walkdown of the EDGs.
The
following specifics were reviewed and/or observed as appropriate:
1.
that the licensee's system lineup procedures matched plant
drawings and the as-built configuration;
2.
that equipment conditions were satisfactory and items that might
degrade performance were identified and evaluated (e.g. hangers
and supports were operable, housekeep0 g etc, was adequate);
3.
with assistance from licensee personnel, the interior of the
breakers and electrical or instrumentation cabinets were inspected
for debris, loose material, jumpers, evidence of rodents, etc;
4.
that instrumentation was properly valved in and functioning and
calibration dates were appropriate;
5.
that valves were in proper position, breaker alignment wac
correct, power was available, and valves were locked as required;
and
6.
local and remote instrumentation was compared, and remote
instrumentation was functional.
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b.
During the walkdown, the inspector was accompanied by several Auxiliary
Unit Operators (AU0s) over several days who assisted in locating and
verifying breakers, fuses, switches, and other electrical components
listed in the Power Availability Checklists.
The checklists are part
of System Operating Instructions S0I-82.1,
.2,
.3, and .4 which verify
status and availability of the four EDGs.
Using the S01s and the attendant checklists to perform the safety
system walkdown, the inspector discovered that 10-ampere fuses were
installed for the AC auxiliary lube oil pumps for EDG 2A-A.
This is
a departure from the checklist in that the checklist specifies that
1-ampere fuses are to be installed.
10 CFR 50 Appendix B, Criterion V, requires that activities affecting
quality be prescribed by documented instructions, procedures, or
drawings, of a type appropriate to the circumstances and that these
activities be accomplished in accordance with these instructions,
procedures, or drawings.
The licensee failed to accomplish activities
affecting quality in accordance with the established procedure in that
incorrect fuses had been installed in EDG safety-related support
systems.
This is identified as the first example of Violation
327,328/86-19-06.
Additional examples of this violation are discussed
in paragraph 10 of this report.
Procedure checklist
82.3J, which covered operability of EDG 2A-A
electrical components, was very difficult for the inspector and the
experienced AU0s to follow and complete.
In several instances, the
AVO, who had been using the checklists for some time, could not readily
find and/or identify the components on the checklist. Some fuses were
so difficult to read that it was not possible to verify the type and
size without pulling the fuses out of the bayonet clips.
In several
cases, pulling fuses starts an EDG.
Notes are included in the
checklists to alert the operators to this possibility.
Nevertheless,
on April 6, 1986, an inadvertent start of the EDGs occurred when an AU0
tried to rotate a fuse in a clip and the fuse popped out.
The event
took place while the AVO was performing an EDG electrical component
verification using S01 82.3.
This inadvertent start of the EDGs while
checking fuses is not an isolated event. The problems evidenced by the
difficulty of the AU0s performing fuse checks required by the check-
lists appears to be due to both inadequate training of the AU0s and
poorly written procedures.
This issue will be followed as IFI 327,-
328/86-19-05.
The checklists have cross-references listed in some cases that have no
meaning for the operators. These cross-references are inserted to help
identify the fuses and switches by both type and/or location.
In some
cases these cross-references are useful in locating and identifying
equipment that an individual operator may see only once a year.
However, the inspector encountered enough instances of the operators
not being able to find or identify equipment (especially fuses) to make
the checklist less than an ideal document.
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When the operators were questioned as to why they had not revised the
checklists to make them easier to use, they indicated that the proce-
dure to initiate changes was both cumbersome and rigid in its imple-
mentation.
As a result, procedura changes to correct and modify the
checklists were not made when areas for enhancement were identified by
the operators.
The fuses identified in the violation as being the
wrong size were apparently installed at the time the modification that
originally installed the auxiliary lube oil pumps was implemented in
1982.
Another violation involving fuses was issued to the licensee in
December 1985, as violation 327,328/85-46-04.
The corrective actions
for this violation included correcting the procedure that specified the
wrong size fuses in the Auxiliary Building Gas Treatment System, and
changing the administrative procedures which cover the reviews of
modifications.
The inspector learned during discussions with licensee personnel that a
program to verify correct fuse size and type is presently in effect.
The fuse verification program was initiated by the licensee in January
1986.
In addition to the fuses identified by the inspector, the
licensee has discovered other discrepancies involving fuses of the
wrong size or type during this inspection period.
These licensee
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identified items involved improper fuses installed in two vital battery
chargers and in the EDG emergency start circuits.
The program as
described appears similar to the one that was implemented in 1982 in
response to violation 327,328/82-18-01.
This 1982 program, was com-
pleted in August 1984.
Further inspection of the fuse verification
program will be included in the followup inspection of corrective
action for Violation 327,328/86-19-06.
c.
In addition to the violation detailed above, two separate followup
items were identified by the inspector as a result of the safety
system walkdown of the EDGs.
Additionally, several minor errors in
the procedure were identified to the licensee for correction.
The inspector observed an Auxiliary Unit Operator (AU0) perform a
walkdown to place a diesel generator back in service.
The AU0 dis-
covered that the cooling water throttle valves were improperly set.
The 501 calls for the throttle valves to be adjusted a selected number
of turns from full open, but the as found setting for three of the
eight valves indicated that the valves had been adjusted from the full
-
closed position.
In each case, the as found position was conservative
with respect to cooling water flow.
The base cause of the misposi-
tioned valve and the cooling system design will be reviewed as IFI
327,328/86-19-07.
The inspector also observed trash and debris in control and power
cabinets.
Housekeeping concerns identified during the walkdown will
be followed as IFI 327,328/86-19-08.
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.
12
1
1
d.
During a review of the licensee's disposition of Significant Condition
Reports (SCRs) related to the EDGs, an app (arent programmatic problem
was identified. The Office of Engineering 0E) reviewer of an SCR from
the Browns Ferry plant made what appears to be an incorrect determina-
tion of non-applicability to the Sequoyah units.
The reviewer based
part of his determination of non-applicability on a questionable -
interpretation of the term " generic".
Inspection of licensee controls
on the review of SCRs for generic applicability is identified as IFI
327/328 86-19-09.
7.
Monthly Surveillance Observations (56700, 61700, 61726)
The inspectors observed TS required surveillance testing and verified that
testing was performed in accordance with adequate procedures; that test
instrumentation was calibrated; that Limiting Conditions for Operation were
met; that test results met acceptance criteria and were reviewed by
personnel other than the individual directing the test; that deficiencies
were identified, as appropriate; that any deficiencies identified during the
testing were properly reviewed and resolved by management personnel; and
that system restoration was adequate.
For complete tests, the inspector
verified that testing frequencies were met and tests were performed by
qualified individuals.
The inspector witnessed / reviewed portions of the following surveillance test
activities:
PMT 74
Post Modification Testing of the Shunt Trip Modification
to the Reactor Trip Breakers
PMT-10
Emergency Control Room Lighting
WP 11907 Post Modification Testing of Upper Head Injection (UHI)
Level Switches
During the inspection of the post modification testing of the UHI level
switches, which was conducted after the replacement of the Barton Model 28St.
UHI level switches by Static 0 Ring (SOR) level switches, the inspector
observed instrument maintenance technicians set the stroke time for UHI
valve 2-FCV-87-22.
The inspector reviewed Work Plan 11907 including the
post modification test requirements.
The valve stroke time requirements
were provided by Westinghouse based on the preoperational test of the UHI
system.
The stroke time requirement was 3.5 seconds plus or minus 0.05
seconds.
During a subsequent control room tour, the inspector observed that the alarm
setting for the charge on the hydraulic accumulators, which are bled down to
close the UHI valve, was at approximately 2800 psig.
The stroke time had
been set for the valve with the accumulator fully charged. A fully charged
accumulator can be over 3000 psig.
However, this value was not recorded
during the post modification test.
Two of the control room readings
indicated up to 3025 psig. The inspector questioned licensee concerning the
discrepancy and the effect on valve stroke time.
'
.
13
The licensee retested one valve utilizing an accumulator charged to 2800
psig.
The stroke time was 3.57 seconds or 0.02 seconds over the required
stroke time. The licensee indicated that the stroke time for the valve with
-
a fully charged accumulator had been 3.52 seconds. This indicates that the
difference in the accumulator charge results in a 0.05 second slower stroke
time.
The licensee has requested Westinghouse to determine if the stringent stroke
time is necessary to meet TS 4.5.1.2.c which requires the valve to close
automatically at a prescribed water level.
Review of the Westinghouse
analysis and determination of compliance with the TS is identified as
Unresolved Item 327,328/86-19-10.
8.
Moi.hly Maintenance Observations (62703)
a.
Station maintenance activities of safety-related systems and components
were observed / reviewed to ascertain that they were conducted in accor-
dance with approved procedures, regulatory guides, industry codes
and standards, and in conformance with TS.
The following items were considered during this review: LCOs met while
components or systems were removed from service; redundant components
operable; approvals obtained prior to initiating the work; activities
accomplished using approved procedures and inspected as applicable;
procedures adequate to control the activity; troubleshooting activities
controlled and the repair record accurately reflected what actually
took place; functional testing and/or calibrations performed prior to
returning components or systems to service; quality control records
maintained; activities accomplished by qualified personnel; parts and
materials used properly certified; radiological controls implemented;
QC hold points established where required and observed; fire prevention
controls implemented; outside contractor force activities controlled in
accordance with the approved Quality Assurance (QA) progran; and
housekeeping actively pursued,
b.
The inspector observed work being done on the repiping of the boric
acid system between the boric acid mixing tanks and the boric acid
transfer pumps.
The work was being performed under MR A-529943. The
I
inspector reviewed four procedures associated with this work:
M&AI-1
Control of Weld Documentation and Heat Treatment
MI-6.15
General Procedures, Tightening Mechanical Bolted
Joints
"
M&AI-11
Fabrication, Installation, and Documen:ation of
Seismic Supports and Supports Attacher to Seismic
Category I Structures
MI-6.21
Repairs and Replacements of ASME Section XI Components
The above procedures were all PORC approved and controlled copies were
being utilized. The inspector observed that the work was being done in
accordance with procedures and that appropriate QC hold points were
being signed off.
It was noted that a current welding permit was in
effect and that a fire watch was posted.
.
_
_ _ _ .
_ _ _ .
_
-_
_ _ _ . .___-_ _ ___ _ _
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14
c.
The inspector observed special maintenance being performed on EDG 1A-A
under Special Maintenance Instruction SMI 0.82.2, Repair and Replace-
ment of Diesel Generator Power Assemblies. -This special maintenance
was initiated by a periodic test of oil samples that indicated the
presence of excess lead in the oil of the 1A-A diesel.
Inspection of the bearings and power assemblies (piston and connecting
rods), revealed one cracked connecting rod bearing and several wrist
pin bearings with excessive wear.
In addition, two connecting rods had
metal burr development on the top half of the bearing basket at the
basket to rod blade interface.
Both connecting rods and all damaged or
worn bearings were replaced.
The cracked bearing is being investigated by the licensee to determine
the failure cause and mechanism.
The burr development is a recurring
problem on this model (EMD) engine.
The problem is caused by a loose
fit of the bearing basket.
Work on the diesel was performed by the Mechanical Maintenance Section
in accordance with Surveillance Instruction SI-7.1, Diesel Generator AC
Electrical Power Source Operability Verification (Diesel Generator /
Offsite Source), and Post Modification Test PMT-10.1. During mainten-
ance, Maintenance Instruction MI-6.20, " Configuration Control During
Maintenance Activities " was followed.
d.
The inspector witnessed the installation of the UHI water accumulator
level switches for Unit 2.
The new level switches, manufactured by
Static 0-Ring (SOR) were installed to replace the Barton 288A model.
The functional test performed after the new switches were installed
involved the introduction of a " dummy" signal which simulates an
accumulator low water level.
The low level signal generated by the
level switches should cause the accumulator isolation valves to shut,
thereby preventing the introduction of nitrogen into the upper head of
the reactor vessel following a LOCA.
Instead of causing the isolation
valves to shut on low level in the accumulator, the switches as
installed worked in reverse, shutting the valves when the simulated
level was raised above setpoint, and allowing the valves to be opened
when the level was lowered below setpoint.
Review of the work plan, WP 11907, verified that the switches were
installed as specified by the work plan. When the instrument mainten-
ance technicians determined that the work plan was in error, the test
was stopped and the Office of Engineering (0E) was contacted to
determine the source of the error.
OE reviewed the print supplied to implement the work plan and deter-
mined that the print was in error.
The licensee also determined that
the Unit 1 level switches, which had been installed under a similar
work plan, had been installed backwards. Post modification testing had
a
.
15
not been conducted for the Unit 1 switches at the time of discovery of
the error. The error was corrected by OE and the switches subsequently
reinstalled correctly on both units.
Inspection of the modification review performed by 0E for the print
issued to implement the original work plan is identified as IFI
327,328/86-19-11.
No violations or deviations were identified.
9.
Licensee Event Report (LER) Followup (92700)
The following LER was reviewed and closed.
The inspector verified that:
reporting requirements had been met; causes had been identified; corrective
actions appeared appropriate; generic applicability had been considered; the
LER forms were complete; the licensee had reviewed the event; no unreviewed
safety questions were involved; and violations of regulations or TS condi-
tions had been identified.
328/85-12
Containment Hydrogen Analyzer Air Supply
10. Event Followup (93702, 62703)
On December 11, 1985 the licensee identified, as a result of a Quality
Control Division system walkdown, that the reagent air supply for the Unit 2
A train containment hydrogen analyzer was connected to a nonessential air
system, i .e. , control air.
The A train containment hydrogen analyzer was
declared to be inoperable and the licensee issued Licensee Event Report
328/85-12.
Unresolved Item 327,328/86-06-06 was identified to followup on
the error. Based on the discussion below, the Unresolved Item is closed.
LER 328/85-12 and the following additional documents were reviewed:
NCR EEB 8014
Non-Conformance Report - Electrical Engineering
Branch
DCR 972
Design Change Request
FCR 2468
Field Change Request
FCR 3275
Field Change Request
EN DES-EP 3.10
Office of Engineering Procedure - Design
Verification Methods and Performance of Design
Verification
EN DES-EP 4.06
Office of Engineering Procedure - Field Change
Requests Initiated by NUC PR
AI-19 Pt. IV
Office of Nuclear Power Administrative Instruction
- Plant Modifications After Licensing
In addition, interviews and meetings were held with licensee personnel in
order to evaluate the root cause of the incident and the licensee's cor-
rective actions. The following issues were identified:
a.
NCR 8014 was written to identify a significant condition adverse to
quality.
It specified that certain portions of the hydrogen monitors
j
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16
were to be relocated to an accessible mild environment.
In conjunction
with NCR 8014, DCR 972 was issued to facilitate the environmental
qualification to NUREG 0588 requirements of safety related components.
One of the approximately one hundred ECNs generated by DCR 972 was ECN
6023 for relocation of hydrogen analyzer panels.
When ECN 6023 was implemented, the cognizant modifications engineer
determined that nonessential air was available in the area where Units
1 and 2 train A hydrogen analyzer monitors were to be relocated and
essential air would have to be piped into the area.
FCR 2468 was
written by the site cognizant engineer to exchange a non-essential
reagent air supply for the originally designed essential air supply.
The cognizant engineer discussed the change, by telephone, with the
appropriate Office of Engineering (0E) review engineer, and together
they erroneously determined that the reagent air supply was only needed
for calibration and therefore did not have to be safety related. This
personnel error was presented in LER 328/85-12 as the root cause of the
event.
The inspector determined that personnel error was a contributing
factor; however, it was not the root cause of the event.
The site
cognizant engineer, the OE review engineer and the engineer who
performed the OE independent check failed to comply with AI-19 and EP
4.06 which require determination of FCR category based on the
Unresolved Safety Question Determination (USQD) evaluation prior to FCR
approval.
When questioned, all three engineers stated that the USQD
was not reviewed prior to the erroneous determination that FCR 2468 was
within the ECN 6032 USQD.
10CFR50 Appendix'B Criteria V, states that activities affecting quality
shall be prescribed by documented instructions, procedures, or
drawings, of a type appropriate to the circumstances and shall be
accomplished in accordance with these instructions, procedures, or
drawings.
1.
The cognizant engineer, OE review engineer, and the OE independent
checker engineer failed to accomplish activities affecting quality
in accordance with procedures in that procedures AI-19 and EP-4.06
which required a review of the appropriate USQD prior to FCR
categorization and approval were not implemented. As a result, an
inappropriate category was chosen and the FCR was approved in
error. This is the second example of Violation 327,328/86-19-06.
2.
Reviews conducted by the OE review and independent checker
engineers were not conducted in accordance with EP 3.10 which
requires design drawings to be carefully reviewed by experienced
design engineers.
At the time that FCR 2468 was approved by the
OE review engineer and OE independent checker engineer, no
drawings were reviewed by either party.
In addition the indepen-
dent checker engineer did not perform an independent review but
instead, based his decision on a conversation with the OE review
engineer. This is a third example of Violation 327,328/86-19-06.
,--
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17
3.
EP 3.10 requires that measures be applied to assure the adequacy
of design documents.
The procedure states that a minimum of one
established, identifiable verification method will be used to
assure design adequacy and that suitable documentation will be
provided to show the method used, by whom, and when the verifica-
tion was made.
EP 3.10 further requires the form of verification
to be auditable.
Neither the OE review engineer nor the OE
independent checker engineer established an auditable record to
validate that a review took place.
This is a fourth example of
Violation 327,328/86-19-06.
b.
The Plant Operations Review Committee (PORC) reviewed and approved FCR
2468 on July 19, 1984 and failed to identify that nonsafety-related air
was being substituted for safety-related air. The " red marked" prints
that accompanied the FCR when it was presented to PORC did identify the
change in air supplies.
The change description section on FCR 2468
failed to adequately identify the work to be performed and the category
chosen was in error because the FCR differed from the assumptions that
were made in the original USQD.
The USQD incorporated in ECN 6032
refers to both DCR 972 and NCR SQN EEB 8014.
NCR SON EEB 8014 refers
to the reagent gas as instrument air which is safety-related air.
TS 6.5.1.6 requires the PORC to be responsible for review of all
proposed changes or modifications to unit systems or equipment that
affect nuclear safety.
Administrative Instruction AI-19, Part IV
implements this requirement.
AI-19 requires the PORC to review and
verify USQD special requirements to ensure that the workplan implements
them as necessary. Although a review was conducted by PORC as required
by TS 6.5.1.6, AI-19 was not implemented in that the PORC failed to
perform an adequate review of USQD requirements for a design change to
a safety-related system.
10 CFR 50 Appendix B, Criterion V requires that activities affecting
quality be accomplished in accordance with prescribed procedures.
Failure to implement AI-19 requirements as discussed above is a fifth
example of Violation 327,328/86-19-06.
c.
The root cause of the modification error was not personnel error.
It
was an OE practice of conducting Category A field change design
approval and review by engineers over the telephone without supporting
documentation and in violation of existing OE procedures for design
review.
In addition, the technical supervisory review consisted of a
signature check and encompassed no technical evaluation of the FCR.
A review of ten additional FCRs was conducted. Design change approval
and review was inadequate in all but three cases which were in the
civil engineering area.
The NRC encourages licensee initiative for self-identification and
correction of problems.
Therefore, the NRC may not issue a Notice of
Violation for a violation that meets all of the following tests:
It was identified by the licensee
-
_
_
.
18
It fits a Severity Level IV or V
-
- It was reported, if required
-
It was or will be corrected, including measures to prevent
recurrence, within a reasonable time
It was not a violation that could reasonably be expected to have
-
been prevented by the licensee's corrective action for a previous
violation. Because the licensee failed to identify and correct the
programmatic root cause of this event, Violation 327,328/86-19-06
is not considered licensee identified,
d.
Unit 2 was operated from approximately December 26, 1984 to Aug(ust 21,
1985, in a mode that required both hydrogen analyzer trains
also
referred to as hydrogen monitors) to be operable in accordance with
During this period, the A train hydrogen analyzer did not
have a seismically qualified air supply and therefore was not operable.
In addition, there were three one week periods and one three day period
during this time in which the B train hydrogen analyzer on Unit 2 was
out of service and TS 3.0.3 applied. This is a violation (328/86-19-12).
As a result of the inspector's review it was determined that two
factors existed which justified the mitigation of the safety signifi-
cance and thus the severity of Violation 328/86-19-12.
The first
mitigating factor was that during the period when TS Limiting Condition
for Operation 3.6.4.1 was violated, there was an operable hydrogen
mitigation (igniter) system which did not depend on data from the
hydrogen analyzer system to be initiated.
The hydrogen mitigation
system is required to be energized by procedure during implementation
of the Abnormal Operating Instruction for reactor coolant system
leakage.
The second mitigating factor was that there were two means
of obtaining a hydrogen sample.
One of the means utilizes the post
accident sampling system and the hot-lab gas chromatograph.
11.
IE Information Notices (92701)
The following IE Information Notices (IEN) were reviewed and closed.
The
inspector verified that:
corrective actions appeared appropriate; generic
applicability had been considered;
the licensee had reviewed the event and
that appropriate plant personnel were knowledgeable; no unreviewed safety
questions were involved; and that violations of regulations or TS conditions
did not appear to occur.
(Closed) IEN 86-17
Update of Failure of Automatic Sprinkler System Valves
to Operate.
The inspectors reviewed the licensee's action to close IEN
86-17.
It was determined through discussions with licensee personnel that
they do not currently have Automatic Sprinkler Corporation of America
(ASC0A) deluge and pre-action valves installed at Sequoyah.
Furthermore,
no mechanical latching valves of any kind are used in the fire protection
system.
This information is sufficient to close this item.
(Closed)IEN85-69 Cheating on License Examinations
'
.
19
12.
Inspector Followup Items (92701)
Inspector Followup Items (IFI) are matters of concern to the inspector which
are documented and tracked in inspection reports to allow further review and
evaluation by the inspector.
The following IFIs have been reviewed and
evaluated by the inspector.
The inspector has either resolved the concern
identified, determined that the licensee has performed adequately in the
area, and/or determined that actions taken by the licensee have resolved the
Concern.
327,328/85-26-06
Control of Root Valves by S0Is
327,328/85-45-02
Replacement of UHI Level Switches
13.
10 CFR PART 21 EVALUATION (36100)
The inspectors reviewed the licensee's program for meeting the requirements
of 10CFR21. During this inspection the following procedures were reviewed:
SQA-94 10CFR21 Evaluation and Reporting Requirements -
Procedure No. - 1200R05
SQA-84 Reportable Occurrence
SQA-45 Quality Control of Materials and Parts and Service
AI-18
Plant Reporting Requirements
Part 21 requires directors and responsible officers of organizations which
construct, operate, or own NRC licensed facilities to:
(1) report any defects in basic components,
(2) report any failures to comply with NRC requirements that could
result in a substantial safety hazard,
(3) post 10CFR21 regulations, Section 206 of the Energy Reorganization
Act of 1974, and procedures adopted pursuant to Part 21 regula-
tions,
(4) specify in procurement documents Part 21 applicability; and
(5) maintain records to show compliance with Part 21.
The inspectors verified that licensee procedures included provisions for
evaluating deviations and informing the Site Director of deviations
evaluated to be a defect or determined to be a failure to comply with
requirements related to a substantial safety hazard.
The inspectors noted that AI-18, Plant Reporting Requirements, File Package
18, Notification and Licensee Event Reports (LER), addressed reporting Part
~
.
20
21 requirements in LER format. The 30 day reporting requirements of the LER
are substantially different from the two day requirement for Part 21.
However, this difference is not proceduralized. It should be noted that the
Site Director is required to notify the Commission of Part 21 safety hazards
within two days following the receipt of the information. This discrepancy
will be followed as IFI 327,328/85-19-13.
The inspectors reviewed three records of evaluated deviations of conditions
that did not result in a report to the Commission.
The items were handled
in accordance with procedure, appeared to be factual and complete, and the
inspectors agreed that the findings were a logical conclusion of the review.
Three records of deviations that were identified as Part 21 reportable were
reviewed.
The inspectors verified the proper handling of these records. It
was noted that the Commission reports were issued within the time frames of
the Part 21 requirements.
The inspectors verified the appropriate posting of requisite documents. The
locations were considered adequate and the postings met the requirements of
Licensee procedures were reviewed to ensure that controls were appropriate
to assure that each procurement document for a facility or basic component,
when applicable, specifies that provisions of 10 CFR Part 21 apply.
The inspectors ascertained that licensee procedures assured licensee
maintenance of records.
It was found that the preparation and disposition
of records were appropriate and met the requirements of Part 21.
No violations or deviations were identified.