ML20212A491
| ML20212A491 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 12/09/1986 |
| From: | Gass K TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20212A474 | List: |
| References | |
| SWEC-SQN-54, SWEC-SQN-54-R, SWEC-SQN-54-R00, NUDOCS 8612240172 | |
| Download: ML20212A491 (11) | |
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. , i TVA EMPLOYEE CONCERNS REPORT NUMBER: SWEC-SQN-54 SPECIAL PROGRAM REPORT TYPE: Sequoyah Nucicar Plant - Element REVISION NUMBER: 0 TITLE: Failure to Update Operating Instruction; Containment Instrumentation; Operator Training REASON FOR REVISION:
N/A l bEC
SUMMARY
STATEMENT: The items in this report were identified by the Nuclear h Regulatory Commission (NRC) and were included in the Stone & Webster Engineering Corportion (SWEC) systematic analysis. All items evaluated within this report were verified to be adequately addressed and SWEC concern A02860117006-003 is now ready for NRC closure. Concerns A02860111006-001, -002 will be ready for NRC closure followinE completion of corrective actions.
PREPARATION PREPARED BY:
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- DATE APPROVED BY:
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- SRP Secretary's signature denotes SRP concurrences are in flies.
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4 TENNESSEE VALLEY AUO10RITY WATTS BAR NUCLEAR PLANT EMPLOYEE CONCERNS TASK GROUP OlHER SITES CEG Element
Title:
Failure to Update Operating Instruction:
Containment Instrumentation: Operator Training SWEC Concerns: A02860117006-OO1 A02860117006-002 A02860117006-003 Source Document: NRC Inspection Report 327, 328/85-43 Report Number: SWEC-SQN-54 a
Evaluator: _Y/ b a__ _ _ _ ff. 9. k (,.
K. R. Gass Date i Reviewed by: ID kb ~
ikd J. J. Knightly' Date Approved by' M_ m /.1,[ g A. G. Dobba(e b_ ate i 1724T l
I
j REPORT SWEC - SQN-54 Failure to Update Operating Instruction; Containment Instrumentation: Operator Training I. INTRODUCTION During a routine, announced inspection of Sequoyah Nuclear Plant (SQN),
November 6 through December 5, 1985 (reference 1) in the areas of operational safety verification, the Nuclear Regulatory Commission (NRC) inspector verified operability of the Auxiliary Building Gas Treatment System (ABGTS) on units 1 and 2 by completing a walkdown of the system.
Two Unresolved Items (URI) and several Inspector Followup Items (IFI) identified during the inspection were included in the Stone & Webster Engineering Corporation (SWEC) systematic analysis:
(1) A02860117006-001 (URI 327, 328/85-43-01) Failure to update System Operation Instruction (SOI)-30.6., and (URI 327, 328/85-43-02) Valves in the air supply to all air operated dampers in ADGTS were not in the valve checklist for system lineup in SOI-30.6.
(2) A02960117006-002, NRC Concerns with Post Accident Monitoring (PAM)
Instrumentation (IFI-327, 328/85-43-07) Noble Gas Monitor, (IFI-327, 328/85-43-08 and 09) Containment High Range Pressure Monitors, (IFI-327, 328/85-43-10) Containment Pressure Monitors, (IFI-327, 328/85-43-11) Containment Water Level Monitors, (IFI-327, 328/85-43-12) Containment Hydrogen Monitors.
(3) A02860117006-003 (IFI-327, 328/85-43-05) Safety Parameter Display System (SPDS), and (IFI-327, 328/85-43-06) Reactor Vessel Head Vent System (RVHVS).
Information on the background, the corrective actions taken, the verification methodology, the verification analysis, the completion status, and any pertinent references for the area of concern is included in this report.
II, VERIFICATION OF SWEC ISSUES A. A02860117006-001, Failure to Update SOI-30.6 System Operating Instruction and to Control Air Supply Valves
- 1. Background (a) During the walkdown of the ADGTS, several concerns were identified. System Operating Instruction, SOI-30.6, Auxiliary Building Gas Treatment System, requires three 45-amp fuses and two 2-amp fuses in the local control panel for the ADGiS humidity, control heaters. Instead, three Page 1 of 9
. r 50-amp fuses and two 1-amp fuses had been installed. In addition, the procedure required that a local disconnect switch for humidity control be closed for manual start of the system. The inspectors determined that this switch had been disconnected at the local control panel. SQN stated that a modification had been made to the system to change the fuses and disconnect the switch in late 1984. Review of this modification and the failure to update the SOI to include these changes is identified as Unresolved Item 327, 328/85-43-01. This URI was later upgraded to violation 327, 328/85-46-04 (reference 2).
(b) The inspectors determined that valves in the air supply to all the air operated dampers in the A8GTS were not included in the valve checklist for system lineup in SOI-30.6.
Isolation of these valves could result in loss of the capability to automatically open dampers required for system operability. Review of system operating procedures to determine the control lineup of air supply valves reauired for operation of safety related air-operated valves and dampers is identified as Unresolved Item 327, 328/85-43-02.
This URI was later upgraded to violation 327, 328/86-19-01 (reference 3).
- 2. Corrective Actions Taken The corrective action for violation 327, 328/85-46-04 and 327, 328/86-19-01 is applicable to this concern. SOI-30.6 was revised to correct the deficiencies. The revision was reviewed by the Plant Operations Review Committee (PORC)
January 28, 1986. This ensures proper documentation of the modified items discussed above in II.A.l.(a).
In response to violation 86-19-01, SQN stated (reference 9):
The need to ensure that an air supply to equipment is properly aligned had been identified in October 1985 by the SQN NRC Residents as a URI, and Operations personnel were in the process of revising the System Operating Instructions (SOI's) to add a note to the valve checklist which states:
For a pneumatically operated Flow Control Valvo (FCV) to be ' aligned and/or operable' it must have control air properly lined up to its controller, air regulator, positioner and operator. It must appear proporly assembled and have no physical barriers or obstructions to its operation.
Two instructions had been revised before October 1985 (non-CSSC systems) and six were revised beforo February 18, 1986. 1here are approximately nine additional instructions requiring revision. This will be completed before startup of unit 2.
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- 3. Verification Methodology The SWEC concern identified for Employeo Concerns Task Group (ECTG) verification was stated as follows:
RIMS NUMBER ISSUE RIMS IJEM A02860117006 Improper use of fuse and RIMS-001 failure to update SOI to include changes for ABGTS system. Inadequato operating procedure for control of air supply valves.
ECTG reviewed the Sequoyah Compliance Licensing Filos for internal and external correspondenco related to this issue and NRC status and closure files. This review of the pertinent '
documentation formed the basis for this verification activity.
- 4. Verification Analvsis The ECTG review of the pertinent documents indicated that the corrective actions for this concern and the violations are being accomplished as described in II.2. The corrective action for each violation is adequate to resolve the cone.orn and violation. At the time of this verification, the NRC violations remain open. lhe corrective action for URI-327, 328/05-43-01 (violation 327, 328/85-46-04) is complete; full compliance for URI-327, 328/85-43-02 (violation 327, 328/86-19-01) will be achieved before startup of unit 2.
- 5. Completion Status Based on SQN actions and evidence of SQN management commitment, correctivo action on the SWEC issues is assessed to be progressing satisfactorily. Upon completion of the planned correctivo actions, these issues will be adequately resolved and thus ready for NRC closure.
D.' A02860117006-002 - NRC Concerns With post Accident Monitoring (pAM)
Instrumentation
1. Background
IFI-327, 328/85-43 The Facility Operating License (FOL) for both units requires that the instrumentation listed below bo installed and operablo by the end of the second refueling outage. Installation of the accident monitoring equipment was accomplished within those requiremonts as documented below.
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(1) Items A&B - Noble Gas Monitor, Iodine / Particulate Sampling An inspection was performed of the installation of the permanent shield building particulate, iodine and noble gas-monitors for units 1 and 2. The monitors were installed during the second refueling outage for both units and are considered operational by the licensee. The inspector reviewed several completed surveillance instructions for channel calibration and functional tests of the monitors.
No concerns were identified. During review of work plans associated with the installation of the monitors, the inspector identified commitments made by TVA in a December 10, 1980 letter to the NRC. This letter appears to contain commitments that exceed NRC requirements for accident monitoring instrumentation; however, the
- commitments did not appear to have been met. Further review of correspondence between TVA and NRC is required to -
resolve the status of these commitments. This is identified as Inspector Followup Item 327, 328/85-43-07.
l (2) IFI-327, 328/85-43-08, 09 - Item C - Containment High Range i Radiation Monitors The inspectors reviewed the work plans for installation of l the containment high range monitors. 1he inspectors were not able to determine from the documentation reviewed whether post-modification testing was conducted after the original installation. This is identified as Inspector Followup Item 327, 328/85-43-08. The containment high range monitors were removed from the units 1 and 2 containments during the shutdown which began in August 1985 to perform calibration using a high range source. The inspector observed a portion of this testing, which appeared adequate. The monitors are to be replaced and source checked in the field prior to startup. Review of the installation and testing of the monitors prior to startup is identified as Inspector Followup Item 327, 328/85-43-09.
(3) IFI-327, 328/85-43 Item D - Containment Pressure Monitors An inspection was conducted of the installation of the containment pressure monitors. 1hese monitors were originally installed in unit 1 July 1980 and unit 2 in November 1980. 1he monitors were upgraded to meet IEEE 323 requirements 1974 in October and November 1984 for units 1 and 2, respectively. The inspector noted that the nameplato data on the pressure transmitters indicated that the monitor had a range of 100 psig, but had a safe pressure of only 12 psig. In general, the safe pressure should be one and one-half times the range. The licensee provided documentation that indicates that the transmitters were tested by the vendor to 150 psig. Further review of the nameplate data discrepancy is identified as Inspector Followup Item 327, 328/85-43-10.
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I (4) IFI-327, 328/85-43 Item E - Containment Water Level Monitors An inspection of the installation of the containment water level monitors was conducted. The monitors have been installed since fuel load. A review of the surveillance documentation indicates that a problem exists with calibration of the monitors. Discussions with the licensee on the calibration of the monitors is identified as Inspector Followup Item 327, 328/85-43-11.
3 (5) IFI-327, 328/85-43 Item F - Containment Ilydrogen Monitors Installation of the monitors was completed prior to fuel r
loading. lhe monitors were subsequently moved outside containment for environmental qualification reasons in -
1984. SQN determined on December 11, 1985, that the unit 2 Train A hydrogen monitor had been tied into a nonessential air supply during these modifications. Followup on this discrepancy is identified as Inspector Followup Item 327, 328/05-43-12.
- 2. Corrective Actions Taken IFI 327, 328/85-43-07:
4 The inspectors reviewed the licensee's installed equipment to verify their compliance with the requirements of a December 10, 1980 letter to the NRC. Further review of I
correspondence between TVA and NRC on this item had been I
identified previously as IFI 327, 328/85-43-07. This
! review indicated that the licensee's response was ambiguous in that the licensee committed to redundant systems in one part of the response and in another part stated that the system would only meet the NUREG-0737 requirements t (reference 9) which do not require redundant systems. The f monitors installed at SQN are not redundant but do meet the
- ' requirements of NUREG-0737. Other corrmitments made in the December 10, 1980 letter have also been verified by the licensee. IFI 327, 328/85-43-07 is closed (reference 5).
) IFI-327, 328/85-43-08:
IFI 327, 328/85-43-08 has been reviewed and evaluated by the inspector. The inspector has either resolved the concern identified, determined that SQN has performed j adequately in the area, and/or determined that actions F taken by SQN have resolved the concern. As a result of this review IFI 327, 328/85-43-08 was closed (reference 4).
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IF1-327, 328/85-43-09, 327, 328/85-43-10, and 327, 328/85-43-12 have been reviewed and evaluated by the
-inspector. The inspector has either resolved the concern identified, determined that SQN has performed adequately in the area, and/or determined that actions taken by SQN have resolved the concern (reference 7).
IFI-327, 328/85-43-11:
During a telephone interview with ECTG, the cognizant instrument engineer stated that SQN has a preventive maintenance (PM) procedure (reference 10) that checks the '
output of the containment water level transmitters on a monthly basis in order to confirm their accuracy. The PM data sheets aro routed through the plant assessment group for evaluation. The cognizant engineer further stated that he had consulted with other nuclear plants and found they had like problems with their transmitters. He also stated +
that one company makes a transmitter that is manufactured for submerged service. He stated that a design change request is being considered-for issuance in the near future to change this system. Although NRC closed the IFI, this item is considered to be unresolved and will be tracked as URI 327, 328/86-28-15 (reference 4).
- 3. Verification Methodology The SWEC concern identified for ECTG verification was stated as follows:
RIMS NUMBER ISSUE RIMS ITEM A02860117006 NRC concerns about compliance, RIMS-OO2 incomplete documentation, calibration problems, incorrect nameplates and improper connections for accident monitoring during instrumentation
, EC1G reviewed the Sequoyah Licensing Files for internal and external correspondence related to this issue, applicable procedures, and NRC status and closure files, lhis review of the pertinent documentation formed the basis for this verification activity.
- 4. Verification Analysis The ECIG review of the pertinent documents indicate that (with the exception of IFI 327, 328/85-43-11 which is unresolved and will be tracked as URI 327, 328/86-28-15), the corrective actions as outlined in II.O.2, above, for this concern and the IFIs have been completed and are adequate to resolve the concern. At the time of this ECTG verification the IFIs are closed, only URI 327, 328/86-28-15 remains open (reference 4).
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- 5. Completion Status The SWLC concern included five NRC items, four of which have been closed by the NRC. Following corrective action on URI 327,328/86-28-15. SQN's corrective actions will be complete and the SWEC concern can be closed.
C. A02860117006-003 - Training on Safety Parameter Display System (SPDS) and Reactor Vessel Head Vent System (RVHVS)
- 1. Background IFI 327, 328/85-43-05 (reference 1):
lhe SPDS was installed by SQN by October 31, 1985, for unit 1 ard November 31, 1985, on unit 2. Additional review of the installation will be conducted by the Operational Readiness Review Team prior to startup of units 1 and 2. -
lhe NRC inspector interviewed operators and Shif t Technical Advisors (STAS) on the use of the SPDS and compared the displays to the Emergency Operating Instructions issued in August, 1985. The inspector noted that the operators displayed difficulty in obtaining the fault tree data. A more detailed review of operator and STA training on the use of the SPDS is an Inspector Followup Item (327, 328/85-43-05).
IFI-327, 328/85-43-06 l The NRC inspector conducted interviews with plant operators l to determine familiarity and training concerning the RVHVS. Additional interviews of training records and verification that training is included in requalification training is identified as Inspector Followup Item 327, 328/85-43-06,
- 2. Corrective Actions Taken l
IFI 327, 328/85-43-05 l
! The NRC Inspector stated (reference 11):
A review of Shift Technical Advisor Safety Parameter Display System (SPDS) training was conducted as a portion of the SQN Performance Plan evaluation. The training appeared to be adequate. The Technical Support Center computer manual established by the licensee to direct the operation of the SPDS appeared to adequately address the operation of the SPDS. IFI 327,328/85-43-05 . . . is closed.
IFI-327, 328/85-43-06 No formal response by SQN was required. SQN considers this item ready for closure. 1he item remained open at the time of this CCTG investigation.
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- 3. Verification Methodology y 7
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.a 3
TheSWECconcernidentifiedforECTGverification[wasstatedas follows: ?
RIMS NUMBER ISSUE. RIMS ITE5 e j!
RIMS-003[
A02860117006 Detail review of operator and additional STA training '
on the use of SPDS. Also training and requalification P training for RVHVS system. l'
,)
ECTG reviewed the Sequoyah Compliance Licensing files for internal and external correspondence related to this isrue' and <
the NRC status and tracking system for the issue. Thisl review -
p of the pertinent documentation formed the basis for thig
- ji verification activity. 'l- 1
- 4. Verification Analysis t g The ECTG review of the pertinent documents indicates that the corrective actions taken for this concern, and the IFIs are ,
adequate to resolve the concern. At the time of this ECTG (3 verification, IFI 327.328/85-43-05 is closed. N IFI 327,328/85-43-06 remains open. However, no action is required by SQN. The issue is considered to be ready for NRC closure.
- 5. Completion Status s
' Based on SQN corrective action and compliance with requirements, this issue is considered complete and ready for NRC closure.
III. REFERENCES l l j .NRC Report 50-327/85-43 and 50-328/85-43 dated January 14, 1986 j David M. Verrelli to H. G. Parris
- 2. NRC Report 50-327/85-46 and 50-328/85-46 dated January 24, 1986 Roger Walker to S. A. White t
- 3. NRC Report 50-327/86-19 and 50-328/86-19 dated May 13, 1986 John A. Olshinski to S. A. White l 4. NRC Report 50-327/86-28 and 50-328/86-28 dated June 13, 1986 Stephen P. Weise to S. A. White
- 5. NRC Report 50-327/06-31 and 50-328/86-31 dated August 12, 1986 Gary G. Zech to S. A. White Page 8 of 9
- 6. 'TVA letter, NUREG-0737 Item II.B.1, Reactor Coolant System Vents, R. L. Gridley to NRC, B. Youngblood dated August 18, 1986 (L44 860818 801)
- 7. NRC Report 50-327/86-15 and 50-328/86-15 dated May 28, 1986 Stephen P. Weise to S. A. White
- 8. NRC, NUREG-0737, Post-accident liigh-Range Noble Gas and Gaseous Effluent Monitoring for radioactive iodines and particulates.
- 9. TVA memorandum, "Sequoyah Nuclear Plant Units 1 and 2 - NRC-OIE Region II Inspection Report 50-327/86-19 and 50-328-/86 '
Response to Violations," dated August 19, 1986 3.A. Domer to J.N. Grace.
- 10. SQN Preventive Maintenance Procedure Nos.1653 (Unit 1) and 1654-063 (Unit 2). .
- 11. NRC Report Nos. 50/327/86-28 and 50-328-86-28 dated June 13, 1986, S. P. Weise to S. A. White.
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