ML20213D178

Insp Repts 50-327/86-46 & 50-328/86-46 on 860806-0905. Violations Noted:Failure to Maintain High Radiation Area Barricade & Posting,Failure to Report Steam Generator Tube Plugging Activities & Failure to Wear Protective Clothing

ML20213D178
Person / Time
Site:	Sequoyah
Issue date:	10/28/1986
From:	Debs B, Harmon P, Jennison K, David Loveless, Nejfelt G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20213D154	List: ML20213D152 ML20213D169 ML20213D178
References
50-327-86-46, 50-328-86-46, IEB-80-12, IEIN-85-042, IEIN-85-046, IEIN-85-055, IEIN-85-057, IEIN-85-42, IEIN-85-46, IEIN-85-55, IEIN-85-57, NUDOCS 8611100454
Download: ML20213D178 (17)

See also: IR 05000327/1986046

Text

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UNITED STATES

[pKtc o "

NUCLEAR REGULATORY COMMISSION

p" -

n REGION ll

y' j 101 MARIETTA STREET, N.W.

• . g ATLANTA, GEORGI A 30323

\*..+/

Report Nos.: 50-327/86-46, 50-328/86-46

Lice'nsee: Tennessee Valley Authority

500A Chestnut Street .

Chattanooga, TN 37401

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 .

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Inspection Conducted: August 6, 1986 thru September'5, 1986

Inspectors y M'!

K. M. Jenison, Senior JTsidf/t Ins 7ector

8/28N[3

Date Signed

fr AV_4 -

P. E. Harmon, Resident IEspe Kor -

Me/st.

Date Signed

WAY &

D. P. Loveless, Residen ns

/r

tor

lo/28/8(.

Date Signed

%= .I &

G. Nejfelt, Resident Ins *pec r Hatch

/%sM

Date Signed

Approved by: "% SkM

Date Signed

E T. Debs, Chief, SectigK 1 7

Division of Reactor Projects

Sumary

Scope: This routine, announced inspection involved inspection onsite by the

Resident Inspectors in the areas of: operational safety verification (including

operations pe-formance, system lineups, radiation protection, safeguards and

housekeeping inspections); maintenance observations; review of previous inspec-

l tion findings; followup of events; review of licensee identified items; review of

IE Information Notices; and review of Inspector Followup Items.

Results: Five violations were identified:

1. Violation 86-46-01, failure to maintain a high radiation area barricade and

i posting (paragraph 5.c.(2)).

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2. Violation 86-46-03, failure to report steam generator tube plugging activi-

ties (paragraph 8.c).

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3. Violation 86-46-07,

6.5.1, PORC activitiesfailure to comply)

(paragraph 14.a with Technical ' Specification (TS)

4. Violation 86-46-08, failure to comply with TS 6.8.5, preventive maintenance

and visual inspection program requirements (paragraph 15).

5. Violation 86-46-09, failure to wear protective clothing as specified in a

radiat_ ion work permit'(paragraph 5.c.(2)).

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REPORT DETAILS

1. Licensee Employees Contacted

H. L. Abercrombie, Site Director

• P. R. Wallace, Plant Manager

• L. M. Nobles, Operations and Engineering Superintendent

• B. M. Patterson, Maintenance Superintendent

J. M. Anthony, Operations Group Supervisor

~*R. V. Pierce, Mechanical Maintenance Supervisor

• L. S. Bryant, Mechanical Maintenance Engineering Supervisor

R. W. Olson, Modifications Branch Manager.

M. R. Sedlacik, Electrical Section Manager, Modifications Branch

• H. D. Elkins, Instrument Maintenance Group Manager

C. W. LaFever, Instrument Engineering Supervisor

M. A. Scarzinski, Electrical Maintenance Supervisor

• M. R. Harding, Licencing Group Manager

• R. W. Fortenberry, Technical Support Supervisor

• D. C. Craven, Quality Assurance Staff Supervisor

• D. E. Crawley, Radiological Field Operations Supervisor

• G. B. Kirk, Compliance Supervisor

• H. R. Rogers, Plant Operations Review Staff

• R. C. Burchell, Compliance Engineer

• J. H. Sullivan, Regulatory Engineering Supervisor

• W. E. Andrews, Site Quality Manager

• J. L. Hamilton, Quality Engineering Manager

• D. L. Cowart, Quality Engineering Supervisor

• R. H. Buchholz, Sequoyah Site Representative

• W. S. Wilburn, Assistant to the Maintenance Superintendent

• J. Robinson, Assistant to the Mod.ifications Manager

• R. M. Mooney, Supervisor, Systems Engineering Section

• B. B. Wilson, Mechanical Engineering, Systems Engineering Section

• M. J. Blankenship, Manager Information Services

• L. D. Alexander, Mechanical Modifications Section Supervisor

• R. K. Gladney, Instrument Maintenance Engineering Supervisor

Other licensee employees contacted included technicians, operators, shift

engineers, security force members, engineers and maintenance personnel.

• Attended exit interview

2. Exit Interview

The inspection scope and findings were summarized with the Plant Manager and

members of his staff on September 5,1936. Five violations described in

this report's Sununary paragraph were discussed. No deviations were discus-

sed. The' licensee acknowledged the inspection findings. The licensee did-

not. identify as proprietary any of the material reviewed by the inspectors

during this inspection. During the reporting period, frequent discussions

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were; held -with the-Site Director, Plant Manager and other managers con-

cerning inspection findings.. At no time- during the inspection was written -

material provided to the ' licensee by the inspectors.

3. -LicenseeActiononPreviousInspectionFindings(92702)

This area was not inspected during the reporting period.

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. Two unresolved items were identified during this inspection, and

are. identified in paragraphs ~9 and 12..

5. . Operational-SafetyVerification(71707) '

a. Plant Tours

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The ~ inspectors- observed control room operations, reviewed applicable

logs,: conducted discussions with control room operators, observed shift

turnovers,-and confirmed operability of instrumentation. The inspec-

tors verified the operability of selected emergency systems, -and

verified compliance with TS- Limiting Conditions for Operation (LCO).

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 Lobserve plant equipment

conditions, including potential ~ fire hazards, fluid leaks, and exces-

sive vibrations and plant housekeeping / cleanliness conditions.

Housekeeping is in better condition .on Unit 2 than on Unit 1, parti- '

-cularly in the respective containments. Readily accessible areas ~ are

maintained clean and free of obstacles and debris. Areas which are

.less accessible and less frequently visited.are not being maintained or

cleaned at a similar level and are receiving less management attention.

Several areas of containment were visited by the inspectors, and while

! the general areas showed great improvement over the past few months,

the accumulator rooms in particular were dirty and cluttered. While

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touring the number 4 accumulator room in Unit 2 containment, the

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inspectors observed two valves, FCV'74-2 and FCV 63-172 with extensive,

long term buildup of boric acid crystals from ' stem leakage. Valve

! 74-2, which is one of the two Residual Heat Removal (RHR)' hot leg

,- suction' isolation valves, was leaking along the valve stem at the time

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and had developed rust around'the valve body and on the threads of the

i body bolts. Water leaking from this 14 inch valve was spraying past

the stem packing, pooling at the valve body flange, and spilling onto

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the floor. The flow path of-the leakage to a floor, drain was marked by

large amounts of rust stains. Debris, discarded parts and trash were

evidence of a lack of attention in these areas. The leaking valves and

the general cleanliness of the area were reported to licensee manage-

ment.

The inspectors walk'ed down accessible portions of the RHR System and

the Chemical and Volume Control System (CVCS) on Unit 2 to verify

. operability and proper valve alignment.

' During the inspection of the CVCS, the inspector changed into the

required protective clothing, left his " street" clothes at the 669

elevation dress-out area and proceeded into the 2A-A Charging Pump

room. When he returned, the inspector found that his clothing had been

wrapped in masking tape with obscenities written on the. tape. Plant

management and NRC Region II management were informed of the incident.

The TVA Inspector General's office is currently investigating the

circumstances of the incident.

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 shifts of the security force was observed in the conduct of

daily activities including protected and vital area access controls;

searching of personnel and packages; badge issuance and retrieval;

patrols and compensatory posts; and escorting of visitors.

In addition, the inspectors observed protected area lighting and

barrier integrity of protected and vital areas. The inspectors visited

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the central alarm station and interviewed security personnel regarding

their respective duties.

The inspectors toured the protected area perimeter during evening shift

to observe continuity of the fence, the cognizance of the public safety

response team and the visibility of the fence perimeter from the

response' positions. The inspector visited each of the response-towers

and interviewed each of the officers on duty.

One possible discrepancy was noted and was discussed with the NRC

Regional -Safeguards inspection personnel. This involved Safeguards

information and will be addressed in an NRC Region 11 specialist

inspection report.

No violations or deviations were identified.

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c. Radiation Protection

(1) 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 activities 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.

(2) On a plant tour conducted on September 3, 1986, two persons from

Mechanical Modifications and one from Plant. Maintenance were found

not to be completely dressed in accordance with Radiation Work

Permit (RWP) 86-2-216-117. All three people failed to completely

apply a protective hood as required by the RWP. Plant procedure

Radiological Controls Instruction (RCI) RCI-1, Radiological

Hygiene Program, implements the requirements of TS 6.8.1 and

requires that protective clothing requirements be specified on an

RWP time sheet and that the protective clothing shall be worn as

required. Failure to war protective clothing as required by the

RWP is a Violation 327,328/86-46-09.

In addition, the above mentioned maintenance person entered a

high radiation area with another maintenance person and failed to

return either of the two available entry barriers to a position

which barricaded access to the high radiation area. TS 6.12

states that each high radiation area in which the intensity of

radiation is greater than 100 mrem /hr but'less than 1000 mrem /hr

shall be barricaded and conspicuously posted as a high radiation

area and entrance thereto shall be controlled by requiring

issuance of a RWP. This requirement is also implemented by RCI-1.

Failure to comply with the requirements of TS 6.12 and RCI-1 is

a Violation 327,328/86-46-01.

(3) During the month of August, two separate incidents' involving

personnel contamination occurred. Both incidents involved pro-

tective clothing that was not adequately cleaned in the on-site

dry cleaning facilities. In both cases a small particle was left

in the processed laundry. This issue and the licensee's actions

with respect to the applicable NRC IE Notices were discussed with

NRC Region II Health Physics Specialists and will be followed as

. Inspector Followup Item (IFI) 327,328/86-46-02.

(4) On September 4, 1986, the inspectors observed an individual

frisking out before exiting the restricted area. He detected a

4000- 5000 - dpm source on his foot. HP' personnel determined that

the contamination was on his foot and not on his shoe or sock.

His foot was decontaminated using soap and water. The inspector

reviewed Health Physics Section Instruction Letter HPSIL-10 and

determined that the event was handled in accordance with this

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procedure. An appropriate Personnel Contamination Report was

issued.

6. Monthly Surveillance Observations (61726)

a. The inspectors reviewed TS required surveillance testing and verified

that testing was performed in accordance with adequate procedures; that

test' instrumentation was calibrated; that LCOs were met; that test

results met' acceptance criteria and were reviewed by personnel other

than the individual directing the test; that deficiencies-were iden-

tified, 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 following surveillanc'se were

reviewed:

SI-632.0 Revision 0 - Auxiliary Building Combined System External .

Leakage

SI-632.1 Revision 7 - Auxiliary Building Containment Spray System

External Leakage

SI-632.2 Revision 2 - Auxiliary Building Safety Injection System

. External Leakage

SI-632.3 Revision 0 - Auxiliary Building Residual Heat Removal

System External Leakage

SI-632.4 Revision 0 - Auxiliary Building Chemical and Volume

Control System External Leakage

SI-632.5 Revision 0 - Auxiliary Building Reactor Coolant Sample

System External Leakage

No violations or deviations were identified 'in the area of Surveil-

lance. However, the above listed surveillances were associated with a

violation in paragraph 15 of this report.

8. Monthly Maintenance Observations (62703)

a. Station maintenance activities of safety-related systems and components

were 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 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

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control' led and the repair record accurately reflected what actually

took p1 ace; 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

materialssused properly certified; radiological controls implemented;

-QC' hold points established where required and observed; fire prevention

controls implemented; and housekeeping actively pursued.

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b. -The ' inspector observed maintenance and troubleshooting activities

involving a main . steam isolation valve .(MSIV 2-29) which was found -

' inoperable following Environmental Qualification modifications. The

work . plan- for the modification required post-modification testing.

. Post-modification testing was the discovery method. When the valve

control switch was positioned to open, -the valve did not move.

Troubleshooting revealed that two of the.four air solenoids controlling

the valve.had been reversed during the modification. The inspector had'

'no further questions on this. item.

c. During this . inspection period the licensee plugged tubes in Unit 2

steam generators. A memorandum addressing this was prepared by the :

Steam Generator Program Manager and submitted to the Resident

Inspectors.on-site. The licensee was informed' that this was not an

- acceptable method of. reporting to the NRC. An appropriate letter was

prepared and sent -to NRC Headquarters within the specified TS. time

frame.

= The inspectors reviewed previous tube . plugging for proper reporting.

With the exception of Unit 1 Cycle 3 refueling outage, the required

reports were made. Licensee . personnel informed the inspectors that

they did not believe the report was required because.the pluggings had

been made. as a preventive measure and were not required by TS 4.4.5.4.a.6 and Table 4.4-2. They stated that the pluggings had been

discussed with NRR personnel by telephone.

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TS 4.4.5.5.a,. states that following each inservice inspection of steam

generator tubes, the number of tubes. plugged in each steam generator

shall be reported to the Commission within 15 days.

Contrary to the.above on October 12, 1985, the licensee completed tube

plugging activities on Unit 1 and failed to submit 'the required report.

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This is a Violation 327,328/86-46-03.

L d. The inspectors observed work in Unit 2 that was in progress on the

- number 4 Reactor ' Coolant Pump (RCP) (2-PMP-68-73) . Maintenance was

performed to replace the seal package 0-ring. The following documents

-were reviewed:

Work . Request B-127664

. MI-2.1, Removal, Inspection and Replacement of Reactor Coolant Pump

Seals) Units 1 & 2

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Instruction Change Form (ICF) 86-1037(8/15/86)-

ICF 86-1041 (8/16/86)

As Low As Reasonably Achievable'(ALARA) planning log 86021

Maintenance personnel had the appropriate procedure available and were

following it in a step-by-step manner. The procedure was very pre-

scriptive. HP personnel were present. and the RWP requirements were

being followed.

e. The inspectors observed maintenance performed on the fire protection

system for the Unit 2 RCP number 3.- The work involved the replacement

of fire protection conduit and heat detectors above the RCP. Two

technicians and a Quality Control (QC) inspector were observed. The

following documents were reviewed:

. Work Request B116759

Drawing 45W1699-24

M&AI-7, Cable Terminations, Splicing, and Repairing of Damaged

Cables

Appendix E of SQM 2, Maintenance Management System

MI-6.20 Configuration Control During Maintenance Activities,

Unit 0

The NRC inspector questioned the QC inspector about the adequacy of a

crushed wire in the power supply to the heat detector. After some

discussion with the mechanics work was stopped to re-plan the job to

i'clude repairing the wire. The crushed portion of the wire was la.ter

removed and a new terminal connector attached.

The~ inspector noted that housekeeping in the area was poor. Articles

included wood, nails, a protective clothing hood, a syringe and chewing

gum.

f. Maintenance on the Post Accident Effluent Monitor 2-RM-90-450 was

observed / reviewed-including the following documents:

Work Request B128793

IMI-134, Configuration Control of Instrument Maintenance Activi-

ties

SI /80, Channel Calibrations for the Eberline Accident Radiation

Monitoring Systems

Drawing 45N2651-8

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g. Maintenance on the Emergency Fire Protection System was oberseved/

reviewed including the following documents:

Work Request B127705

MI-6.20, Configuration Control During Maintenance Activities

Special handwritten functional test instructions

9. Licensee Event Report (LER) Followup (92700)

The following LERs were 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 no violations of regulations or TS

conditions had been identified.

LERs Unit 1

50-327/85016, Shutdown Activities

50-327/86009, Auxilliary Building Isolation

50-327/86010, Emergency Diesel Generator Start

.LERs Unit 2

(0 pen) 50-328/83101 and 50-327/85040 reported and described instances of

loss of both trains of shutdown cooling in the form of air bound RHR pumps.

Both occurred with the reactor vessel head removed and the Reactor Coolant

System (RCS) partially drained for maintenance activities. The air binding

of the pumps was a direct result of water level in the RCS being below the

minimum level necessary to keep the RHR suction line covered.' The LERs

describing the events failed to address several points; these are:

a. Air binding of the RHR pinps blocked all flow in the RHR/RCS shutdown

cooling flow path. In the case of the event described in 50-328/83101,

77 minutes elapsed before the operators were able to vent the air from

the pumps and restore flow. RCS loop temperatures rose from 103

degrees F to 195 degrees F during this period, close to the point where

boiling in the core would have begun. During the event described by

50-327/85040, 50 minutes elapsed before flow was restored.

b. The RHR pumps were vented by different means in each instance, neither

of which is prescribed in Abnormal Operating Instruction A01-14, " Loss

of RHR Shutdown Cooling." During the 50-328/83101 event, venting was

accomplished by opening a valve in the RHR pump suction drain line, a

3/4-inch pipe connection on the bottom of the 14-inch inlet pipe. This

connection is 40 inches below the pump casing, where the air binding

would occur.

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During the 50-327/85040 event, operators opened a valve on instrument-

tubing used '.o drain a local pressure indicator. The instrument tubing

was on the pump discharge line. This vent path is approximately

1/4-inch in diameter. The sizes of the vent paths and the locations of

the vents were major contributors to 'the length of time required to

vent the RHR pump in each instance. If steam binding had occurred in

either case, the pumps would have experienced even more problems

because these two vent paths are inadequate to remove the heat

generated by a running, vapor bound pump.- Neither LER addressed why

the ventir.g procedure used in each instance was not the- prescribed

procedure or vent path specified by A01-14.

c. The vent paths used during the two events were inadequate in both

location and size, contributing to a prolonged loss of shutdown

cooling. The vent path that is installed specifically for pump venting

also has apparent design deficiencies. The vent line is a 3/4-inch

line connecting to the 8-inch pump discharge pipe at a point just

before the pu'mp discharge isolation valve. This location-is on a

vertical run approximately three feet above the pump casing. In order

for this vent path to be effective, the pump discharge isolation valve

must be closed. This also necessitates stopping the pump prior to

venting. This vent path appears to be adequate for venting the air-

bound pump casing events as they were described in the LERs.

d. The air-bound pump during open RCS conditions may not be the most

demanding event on the efficiency of the pump vent. During post-LOCA

swapover of the RHR pumps to the containment recirculation sump the

pumps are especially vulnerable to loss of pump suction due to air or

steam binding. A prolonged loss of the RHR pumps at this crucial time

would leave the core susceptible to a loss of core cooling, since the

normal source of Emergency Core Cooling System (ECCS) water is depleted

at this point in the postulated LOCA event. This may constitute an

unanalyzed event. An engineering evaluation should be made to deter-

mine whether the pump vent, as installed, could adequately vent the

pump in a steam binding situation. Heavy flow rate is necessary to

remove both steam / gas combinations and heat generated by the bound pump

prior to its shutdown. The adequacy of the present pump vent arrange-

ment will be followed as IFI 327,328/86-46-04.

The adequacy of the licensee's corrective actions in the events

described by the two identified LERs, particularly the venting pro-

cesses used and their contribution to the prolonged loss of decay heat

removal capability will be reviewed as Unresolved Item (URI) 327,328/

86-46-05.

10. Event Followup (93702, 62703)

On August 26, the plant experienced a loss of power to the 2B Shutdown Board

causing the Emergency Diesel Generators (EDGs) to start and the 2B-B EDG to

tie onto the shutdown board. The event was caused by personnel error during

relay trip checks on the 6.9KV 2D Unit Board. Just prior to the event, the

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2B Shutdown Board was being powered from the 2C Unit Board and the 2D Unit

Board was powered with all of the loads removed. The Division of Power

Systems Operation (DPS0) technician conducting the test made-up the dif-

ferential relay on the 2C Unit Board instead of on the 2D Unit Board. This

caused a loss of power to the 2B Shutdown Board and the subsequent starting

of the EDGs.

The. error was apparently caused by misleading labeling on the non-safety-

related Unit Boards. These boards are physically connected and the labeling

for the 2D board ("6900 V Unit Board 2D") is- on the panel adjacent to the

Unit Board 2C Differential Relay panel. The labeling problems and the lack

of procedures for the non-safety-related work are the major contributors to

the event.

The licensee is currently planning to draw a dividing line.between the

boards and label the boards in more appropriate locations.

No violations or deviations were identified.

11. IE Information Notices (92701)

The following -IE Information Notices 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 I

questions were involved; and that violations 'of regulations or TS conditions

did not appear to occur.

85-42, Loose Phosphor in Panasonic Thermoluminescent Dosimeter Elements

85-46, Removable Radioactive Surface Contamination Limits

85-57, Lost Iridium Source

85-55, Revised Emergency Exercise Frequency Rule

12. IE Bulletins (92701)

The inspectors reviewad the licensee's response to IE Bulletin 80-12 Decay

Heat Removal System Operability. The Bulletin, of which Sequoyah Unit 1 was

an addressee, required 6 reviews to be completed and to report to the

Commission certain actions to be taken. The inspectors questioned licensee

personnel about the required reviews; however, the documentation of these

reviews has not yet been produced. Pending the review of this documentation

this item will be considered unresolved and will be tracked as URI 327,

328/86-46-06.

13. Temporary Alterations

An inspection of the Sequoyah temporary altcration program was conducted

including a review of the outstanding safety related Temporary Alteration

Change Forms (TACFs). This review encompassed IFI 327,328/85-46-08 and

327,328/86-20-01.

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During this inspection the.following documents were reviewed:

AI-9,- Control of Temporary Alterations

Independent Evaluation of the TACF Program by Stone and Webster

TVA Task Force Report - Startup Impact of Open TACFs

Sequoyah Monthly TACF status report

A review of ccmpleted safety related TACFs was conducted. This review was

discussed with senior managers of the Design Baseline and Verification

Program and the following issues were established:

At the time this inspection was conducted, there were no systems 100%

complete within the Design -Baseline and Verification Program, and no

systems in which the TACFs were evaluated.

No consideration had been given by the Design Baseline and Verification

Program to an engineering evaluation of closed safety related TACFs to

resolve whether or not post modification testing was required to close

out a TACF that was different from the testing conducted for the

permanent modification.

No consideration had been given by the Design Baseline amd Verification

Program to an engineering evaluation of. whether the Unresolved ' Safety

Question Determination evaluation conducted for the TACFs was satisfied

by the implementation of the permanent modification.

Completed safety related Engineering Change Notices which apply to the

systems addressed in the Design Baseline and Verification Program also

share the same considerations mentioned above.

A review of open safety related TACFs was conducted and a sample of out-

standing TACFs was discussed with Sequoyah management on a line item basis.

Those outstanding TACFs in the electrical modifications area were chosen for

the line item review. The following observations were made:

Approximately 150 TACFs are outstanding including both safety- related

and non-safety-related items. Approximately 100 of the outstanding

TACFs fall into three work areas; Mechanical Modifications, Electrical

Mcdifications, and Instrument Maintenance. This was an expected

finding because these three groups are responsible for the bulk of

plant modifications.

Approximately half of the outstanding TACFs were written prior to

January _1984.

Approximately half of the outstanding TACFs are safety-related.

During the review of the open safety-related TACFs it was determined

that the licensee had an_ outstanding Institute of Nuclear Power Opera-

tions (INP0) commitment to reduce outstanding pre-1984 'TACFs, and had

established a goal of .approximately 175 total outstanding TACFs by

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October 1986. This internal goal was reached in January-1986 and there

has been little . apparent progress towards the reduction in the total

number of outstanding TACFs since that date (January - 160, August -

150).

As a result of the review of outstanding safety related TACFs the following

observations were made:

Many of the TACFs appeared to be outstanding as a result of a lack of

work plan preparation and design . support needed to replace the TACF

with a permanent change.

Some of the TACFs appeared to be outstanding as a result of manpower

considerations. The same groups responsible for the majority of the

outstanding TACFs were also responsible for some of the major startup

related programs (e.g., cable, environmental qualification, and fire

protection ).

A review of the report entitled " Independent Evaluation of the TACF Program

by Stone and Webster" was conducted. The report concluded that the program

was adequate. In addition it concluded that there were several weaknesses

that could cause problems. Some of these weaknesses were:

Non-uniform issuance and control of as-constructed drawings.

More than one organization presently has responsibility for the imple-

mentation of the TACF program.

AI-9 was not concise and did not refer to other applicable instruc-

tions.

The inspector found no new issues identified in the Stone and Webster

report. IFIs 327,328/85-46-08 and 327,328/86-20-01 remain open.

14. Plant Operations Review Committee (PORC) (40700)

Inspection Report 327,328/86-20 conducted a review of the PORC Standard

Practice SQA 21, Onsite Independent Review. In this previous inspection, it

was found that: alternate members assigned to the PORC met ANSI 18.1 -

1971; quorum requirements described in SQA 21 met the requirements in TS 6.5.1; responsibilities were adequately defir.ed; and completed QA records

were adequate. These areas we re reviewed during this inspection and similar

conclusions were reached with the exception of the quorum requirements.

Inspection Report violation 327,328/86-20-10 identified that two additional

'

members beyond the TS required composition could legally function as

alternates, but were recognized by the licensee as regular r=mbers. The two

extra members resulted in the quorum requirements being violated with

respect to PORC members present during meetings. In response to this

violation the licensee submitted a letter dated May 23, 1986. The

licensee's corrective action appeared to be specifically directed towards

the two examples identified in Inspection Report 327,328/86-20. The two

-- - -

_

.. - . _ . . - .

.

13

specific actions identified in the licensee's response were reviewed by the

inspectors, and rev.ision 11 to SQA 21 was found to be completed. In

addition the response was reviewed for accuracy and found to be consistent

with a resonable interpretation.

During the review of the above mentioned violation, the following issues

.

were identified:

a. PORC members routinely delegated their independent review responsibi-

lities to their subordinate staffs. The delegation process was not

formally documented. Although a routing cover sheet was used for the

informal PORC delegation process, the delegation process was not

controlled and varied among PORC members. For example, a PORC member

may delegate their review down several organization levels within their

staff. This resulted in safety reviews that were completed by indivi-

duals .with unknown experience and technical qualifications. Each

member employed a different means of being briefed by their subordinate

staff and the amount and depth of review conducted by the individual

,

PORC members could not be verified.

,

'

During the PORC meetings a specific issue is presented and the chairman

generally asks if there are any questions or objections to approving

the issue. Discussion of the issue is generally limited and brief. If

. there are objections by a-PORC member, the issue is usually returned to

the originator with comments for resolution. A telephone conference

was held between NRC Region II and NRC NRR offices to determine if the

licensee's actions met the intent of TS 6.5.1. Because of the format

that is used~during the PORC meetings and the review proces's used by

the PORC members, the intent of TS 6.5.1 is not being met. The intent

of TS 6.5.1 was to gather a knowledgeable group of senior individuals

,

together in order to interact and then advise the Plant Manager on all

matters related to nuclear safety.

! TS 6.5.1.6 requires that PORC shall be responsible for review of'those

. items listed in sub-paragraphs 6.5.1.6.a through m. The review of the

items addressed in sub-paragraphs 6.5.1.6.a through m has been infor -

mally delegated to subordinates by the permanent PORC members over the

t last two years. The permanent members subsequently base their decision

! for approval on memoranda from the subordinates and/or their initials

on the informal PORC document routing sheets. Consequently, due to the

limited discussion format of the PORC meetings and the informal routing

process, the members do not achieve full personal knowledge of the

i issues being addressed. Additionally, temporary PORC members are

further removed from the review process. This is a Violation 327,328/

86-46-07.

b. Alternate PORC members are designated permanently by job position in

SQA 21, Section 5.5, rather than temporarily appointed in writing by

the PORC Chairman, as required by TS 6.5.1.3. This issue was addressed

in Violation 327,328/86-20-10. As a result of this violation, the

,

licensee is in the process of submitting a TS change to incorporata the

.

14

qualified reviewer concept. This item shall remain open until the TS

change has been sutmitted and approved.

.c. The typed PORC meeting minutes from June 2 to August 27, 1986, have not

been signed or reviewed by the PORC Chairman. Also, the QA approval

and review for these documents is not completed nor were these docu-

ments distributed as stated in SQA 21, Section 7.2.

d. SQA 21, Section 5.3, allows alternative means of establishing a quorum

after consultation with the licensee's appropriate central office

supervisor. This is contrary to TS 6.5.1.5 for establishing a quorum,

and is a second example of violation 327,328/86-46-07,

e. SQA 21, Section 5.2, allows a PORC member to be considered present at a

PORC meeting, if he is in telephone communications. A telephone

conference is allowed by the approved Quality Assurance Manual.

However, the licensee has not prescribed its implementation in plant

procedures .other_ than to stipulate that telephone attendance is

acceptable. This does not appear to satisfy the intent of the ANSI

N18.7-1976. Acceptable preparation and review needed to assess the

safety significance of.some safety questions may not be afforded when

PORC members use the allowed telephone communications.

f. TS 6.5.1.1 describes the permanent staffing of the PORC. The intent of

the listing was to identify individuals and not to identify . job cate-

gories. .For example, Maintenance Supervisor was intended to describe a

unique individual and not a job category which may be filled with three

or more people. The licensee took the opposite position and assigned

three Maintenance Supervisors and two Assistant Plant Superintendents

as permanent members of PORC. This changed the possible composition of

PORC and affected the quorum requirements. Only one case where the

actual attendence of more than one Maintenance Supervisor as a per-

manent member was identified during recent PORC meetings. The meeting

occurred in May 1986 and was identified by the licensee. This issue

~

was also addressed in Violation 327,328/86-20-10. This item shall

remain open until the change to TS discussed in b. above has been

submitted and approved.

15. TS 6.8.5 - Primary Coolant Sources Outside Containment

During the review of TS 6.8.5 the following documents were reviewed:

Safety Evaluation Reports (SERs) 2 and 5

NRC inspection Report 327/81-42, 328/81-52

Surveillance Instruction (SI)-632 series - Auxiliary Building External

Leakage

NUREG 1212

_ - - - - .

.-. . - -

i. .

15

Both SERs and the referenced NRC inspection report addressed initial leak

testing on systems that carry radioactive fluid outside containment and the

requirements to submit a report of completed leak testing results to the

NRC. The timeliness of the required licensee report was addressed in the

referenced NRC inspection report. Neither of the SERs nor the NRC inspec-

tion report refer to or evaluate the routine program requirements of TS 6.8.5 a.(i) which states that a program to reduce leakage from those por-

tions of systems outside containment shall include preventive maintenance

and periodic visual inspection requirements.

A review of the program that is in place at Sequoyah indicated that a

program of visual inspections had been established and implemented. As a

result of this visual inspection program corrective maintenance was perfor-

med to correct leakage that exceeded TVA administrative acceptance criteria.

The acceptance criteria is not clear in all. cases. It was the licensee's

position that the visual inspection and corrective maintenance met the

requirement to have a preventive maintenance and periodic visual inspection

program.

Several t.elephone conferences were held between NRC Region II and the

appropriate branch of NRC NRR'to determine the intent of TS 6.8.5. During

the ' conferences, NUREG 1212, Institute of Nuclear Power Operations, and

other industry maintenance standards were discussed. .In each standard,

preventive maintenance was determined to include internal and external

inspections among many othar regularly scheduled actions. The term

regularly scheduled refers to a time based action dependent 'on operating

hours or calendar time.

The licensee's program intended to meet TS 6.8.5 is composed only of the

SI-632

pumps. series visual inspections

The maintenance and random

performed vibration

as a result analy(sis

of a SI-632 of specific

series) visual

in::pection is viewed by the NRC to be corrective maintenance. The licensee

has failed to meet the intent of TS 6.8.5 and is considered a violation

327,328/86-46-08.

In addition, the licensee does not have any program for two systems listed

in the Unit 1 TS 6.8.5 (Hydrogen Recombiner and Iodine Cleanup System). The

reason for this appears to be that the TS are incorrect. As part of the

corrective actions to violation 327,328/86-46-08, the licensee should

resolve whether or not the two systems are listed in the TS incorrectly.