ML20215C112

Insp Repts 50-327/86-42 & 50-328/86-42 on 860706-0805. Violations Noted:Failure to Process Adequate Variance & Implement Temporary Alteration Change Form Requirement

ML20215C112
Person / Time
Site:	Sequoyah
Issue date:	09/22/1986
From:	Debs B, Harmon P, Jenison K, David Loveless, Linda Watson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20215C092	List: ML20215C088 ML20215C100 ML20215C112
References
50-327-86-42, 50-328-86-42, NUDOCS 8610100097
Download: ML20215C112 (16)

See also: IR 05000327/1986042

Text

UNITED STATES

'

/gm It!cq'o NUCLEAR REGIJLATORY COMMISSION

[" ', Rd360N 11

g ,j 101 MARIETTA STREET, N.W.

• I t ATLANTA, GEORGI A 30323

.. Nos.:/

\Report ..

50-327/86-42,50-328/86-42

Licensee: Tennessee Valley Authority

500A Chestnut Street

Chattanooga, TN 37401

Docket Nos.: 50-327 and 50-328 License Nos.: DPR-77 and DPR-79

Facility Name: Sequoyah Units 1 and 2

Inspection Conducted: July 6,1986 - August 5,1986

Inspectors e M! , _ /9/M~

Date Signed

K.M.Jenison,SeniorRep6entIp'spector

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" $ $h? b

L. J. Watson, Resident JMpepbr Gate ~ Signed

(Yn W l W e9d*

P.E.Harmon,1esidensInsptor ' Date' Si gned

W W e z-t-s h

D. P. LoveTeW, Resided Inspector

W/WRC

' Gate'Signe

Approved by:~ p M Y#

B. T. Debs, Chief, Section JA //Jate _ Signed

Division of Reactor Projects

SUMMARY

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

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

operations performance, system lineups, radiation protection, safeguards and

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

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

IE Information Notices; and review of Inspector Followup Items.

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Results:

Two violations were identified:

1. 86-42-01 failure to process an adequate variance paragraph 3

2. 86-42-06 failure to implement a Temporary Alteration Change Form

requirement paragraph 7

Two unresolved items (URIs) were identified:

1. 86-42-02 vendor manual requirements paragraph 3

2. 86-42-05 Raychem splice applications paragraph 7

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8610100097 860926

PDR ADOCK 05000327

G PDR

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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

• G. Wilson, Assistant Operations 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

• R. V. Pierce, Mechanical Maintenance Supervisor

• D. Tullis, Special Projects Maintenance

• M. R. Harding, Engineering Group Manager

D. C. Craven, Quality Assurance Staff Supervisor

D. E. Crawley, Health Physics Supervisor

• G. B. Kirk, Compliance Licensing Supervisor

H. R. Rogers, Supervisor, Plant Reporting Section

• R. C. Burchell, Licensing Engineer

• M. A. Purcell, Licensing Engineer

J. H. Sullivan, Manager, Plant Operating Review Staff

• W. E. Andrews, Site Quality Manager

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

J. Robinson, Assistant to the Modifications Manager

R. M. Mooney, Supervisor, Systems Engineering Section

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

• L. D. Alexander, Mechanical Modifications Section Supervisor

R. W. Fortenberry, Technical Support Supervisor

• R. K. Gladney, Instrument Maintenance Engineering Supervisor

, *T. L. Howard, Quality Surveillance Supervisor

• J. A. Dunlap, DPS0 Supervisor

Other licensee employees contacted included technicians, operators, shift

engineers, security force members, engineers and maintenance personnel.

• Attended exit interview

2. Exit Interview

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The inspection scope and findings were summarized with the Plant Manager

and members of his staff on August 11, 1986. One violation described in

paragraphs 3.a. and 3. b. , and another described in paragraph 7 were

discussed. No deviations were discussed. The licensee acknowledged the

inspection findings. The licensee did not identify as proprietary any of

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the material reviewed by the inspectors during this inspection. 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

inspectors. A management meeting was held at Sequoyah on August 1,1986, to

discuss license conditions. A summary of this meeting is discussed in

paragraph 10.

3. Licensee Action on Previous Inspection Findings (92702)

a. (Closed) URI 327,328/85-45-11, Seismic Qualification Verification of

Specific ASCO Solenoid Valves. The subject item was identified during

a tour of the facility. The specific flow solenoid valves (FSVs)

inspected were 1-FSV-63-64,1-FSV-63-42,1-FSV-68-305, and 1-FSV-77-20

which are located in the Unit 1 pipe chase, elevation 690. The inspec-

tor learned through discussions with the licensee that these solenoids

had been replaced in 1985 with environmentally qualified ASCO solenoids

as part of the 10 CFR 50.49 program. These valves were provided from

the vendor with mounting brackets installed on each end of the valve.

This configuration was seismically and environmentally qualified by the

vendor. However, the valves inspected had mounting configurations that

differed from that provided by the vendor. The inspector found that

valves 1-FSV-63-64 and 1-FSV-63-42 had only one bracket attached and

that valves 1-FSV-68-305 and 1-FSV-77-20 were not mounted with brackets

at all, but instead by the 1/2-inch tubing connected to the inlet and

outlet ports of the solenoid. The tubing was supported by a unistrut

hanger. These 10 CFR 50.49 qualified valves had been reconfigured

to match the original, non-10 CFR 50.49 qualified solenoid mounting

method.

The inspector held discussions with the licensee to determine whether

the mounting configurations for the valves in question were seismically

analyzed and approved. During these discussions, information was

provided which led the inspector to the following conclusions:

Valves 1-FSV-68-305 and 1-FSV-77-20 were attached per typical

drawing 47A054-33 and 47A054-33A. This mounting method is

acceptable since the typical drawing represents a qualified

mounting method.

l Valve 1-FSV-63-64 was supplied from the vendor and was attached

to its respective flow control valve (FCV) as shown on drawing

CP1-18-55, Rev. 901. The solenoid and FCV were seismically

qualified by the vendor as a unit.

Valve 1-FSV-63-42, with one end bracket, was installed by bolting

the end bracket to a unistrut hanger. The unistrut in turn was

supported between two flow control valves along with the associ-

ated pressure regulator. The mounting for this valve did not

conform to the typical drawing, and a Support Variance Sheet was

not used.

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Sequoyah Nuclear Plant Construction Procedure P-30, Rev.1, "Fabrica-

tion and Installation of Seismic Supports", specifies that the 47A054

series Typical drawings are to be used to install instrument air lines.

Section 6.0.E.1 of this procedure specifies that a variance sheet shall

be used to alter an existing typical support drawing and shall be

applicable to one specific support at a specific location. Failure to

process a variance in accordance with procedure P-30, Rev.1, is

identified as a violation (327,328/86-42-01). As a result, this ASCO '

solenoid valve was installed without proper seismic evaluation and

approval of the mounting method. In addition, when the new 10 CFR

50.49 solenoid valve was installed in 1985, it was reconfigured to

match the original unanalyzed mounting configuration, and the seismic

qualification of this new valve was again compromised.

b. (Closed) URI 327,328/85-45-12, Environmental Qualification of Specific

ASCO Solenoid Valves. The inspector found that valves 1-FSV-63-64,

1-FSV-63-42, 1-FSV-68-305, and 1-FSV-77-20 had been replaced in 1985,

as outlined in paragraph a., above, with 10 CFR 50.49 qualified valves.

The inspector reviewed engineering change notice (ECN) -6487 which was

issued September 10, 1985, and work plan (WP) -11806 which was prepared

September 17, 1985. The purpose of this ECN was to replace the exist-

ing solenoid valves with valves which met 10 CFR 50.49 requirements.

The WP gave detailed instructions to implement the actions required by

the ECN for Unit 1. The inspector noted that neither the ECN nor the

WP denoted any special requirements for disassembly or reassembly of

the new valves to allow for installation. The WP did indicate that the

modification did not violate the internal integrity of the valves. In

these cases, one or both of the mounting brackets were removed in order

for the valves to be installed to conform to the existing configura-

tion. This required removal and replacement of two of the four screws

at the end of each valve body. Removing the screws breaks the 10 CFR

50.49 boundary. However, no torque values or tightening patterns were

specified in the ECN or the WP to re-establish the pressure boundary.

i Discussions with the licensee verified that no special torquing of the

l screws was performed. The inspector reviewed vendor manuals and

l bulletins applicable to the valves in question and found that torque

values and a criss-cross tightening pattern were required to maintain

the 10 CFR 50.49 boundary.

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Administrative Instruction 19, Rev. 12, Plant Modifications After

! Licensing, was established to provide that work instructions shall

give a step-by-step sequence of events required to perform the work

correctly and that the procedure identify the results of improper

action. This procedure was not implemented in that work plan WP 11806

did not give adequate instructions for craft personnel to reconfigure

10 CFR 50.49 qualified valves for proper installation and did not give

the results of improper actions associated with modifying the valves.

This is a further example of violation 327,328/86-42-01.

The Environmental Qualification program must remain current by

, incorporating vendor requirements into any replacement or

l reconfiguration activities. How vendor supplied requirements and

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recommendations are implemented into the EQ program will be followed

l as URI 327,328/86-42-02.

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c. (Closed) Inspector Followup Item 327,328/85-46-10. This item involved

the adequacy of the licensee's centralized corporate commitment track-

ing system. Additional review / followup on this item was completed and

documented in Inspection Report 327,328/86-31, and is considered

closed.

4. Unresolved Items

Unresolved items are matters about which more information is required

to determine whether they are acceptable or may involve violations or

deviations. Two unresolved items identified during this inspection are

discussed in paragraph 3.b, 7.b, and 7.e.

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,

and verified compliance with Technical Specification (TS) Limiting

Conditions for Operation (LCOs). The inspectors verified that main-

tenance 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 build-

ings, the essential raw cooling water (ERCW) pump house and containment

were conducted to observe plant equipment conditions (including poten-

tial fire hazards, fluid leaks, and excessive vibrations) and plant

housekeeping / cleanliness conditions.

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 con-

trols; searching of personnel and packages; badge issuance and retriev-

al; patrols and compensatory posts; and escorting of visitors.

In addition, the inspectors observed protected area lighting and

protected and vital area barrier integrity. The inspectors visited

the central alarm station and interviewed security personnel regarding

their respective duties.

(1) During the inspection period the site area received the record

high temperatures experienced throughout the Tennessee Valley.

During the week beginning on July 20, 1986, two public safety

officers were transported from the site to local hospitals for

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heat related maladies. Several other officers reported to the

site nurse complaining of heat trauma. The inspectors discussed

with licensee personnel the heat related problems and how the

Security Plan was being met during this period.

Licensee personnel discussed the steps that they were taking to

mitigate the potential heat problems. Surveillance vehicles

on site are not air-conditioned (A/C) because of the slow speeds

at which they generally travel. During this heat wave two new

vehicles were temporarily acquired that had A/C. One other

vehicle patrol remains without A/C. This vehicle patrols the

entire perirr.eter and therefore can patrol fast enough to get air

circulation. In addition, this patrol is relieved at an increased

frequency.

The walking patrols and response officers are rotated with the

air conditioned tower posts on a four hour interval. Also these

officers are allowed time indoors for the intake of fluids and

shelter from the sun.

(2) During the inspection period the inspector found an IE inspection

report containing 2.790 safeguards proprietary information in an

unsecured file. The inspector discussed this issue with public

safety personnel and personnel in control of the file. The

material was expeditiously removed from the file and replaced with

a sanitized version. Licensee personnel are currently reviewing

the files of all plant offices that have access to 2.790

information. Three additional reports were identified in the same

office as the originally discovered file.

(3) 'Two security related incidents occurred during this report period '

and will be investigated by an NRC Region II specialist. The

first event involved a threatening phone call and the second

involved an officer that was less than fully alert.

l Those security related items listed in the paragraphs 5.b.(1) through

(3) will be tracked by Inspector Followup Item (IFI) 327,328/86-42-03

l and will be reviewed / investigated by an NRC Region II security

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specialist.

No violations or deviations were identified.

c. Radiation Protection

The inspectors observed Health Physics (HP) practices and verified

i 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 instru-

ments were verified operable and calibration frequencies were reviewed.

I No violations or deviations were identified

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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

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.

b. The inspectors observed the calibration of auxiliary feedwater level

controllers 1-LIC-3-174 and 1-LIC-3-173. The following documents were

reviewed:

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Instrument Maintenance Instruction IMI-121, Bench Alignment and

Calibration of Beckman 8800 Controllers, Rev. 2, 6/24/86

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Beckman Vendors Manual 820498 ID# 835, Series 8800 Indicating

Deviation Controllers, Validated Manual #4, 8/19/83

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Beckman Vendors Manual, Series 8800 Indicating Deviation

Controllers, Validated Manual 76-820498, 9/8/76

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Beckman PID Test Procedure, Factory Calibration Procedure for 8800

Controllers, Drawing Number 001-644338, 9/30/83

During observation of the bench calibration, the inspectors noted that

step 6.3.4 of IMI-121 required the technician to adjust a potentiometer

(pot) labeled R3 on the adjustable limits board. As the technician was

beginning to perform the step on controller 1-LIC-3-173, the inspectors

asked how the technician was identifying the pot. The inspectors and

technicians then noted that the pot was labeled R5. The inspectors

compared the adjustable limits board on controller 1-LIC-3-173 to the

adjustable limits board on 1-LIC-3-174 and determined that they were of

a different configuration. The Hi pot on the adjustable limits board

on 1-LIC-3-174 was labeled R3 and the Lo pot R4. The Hi pot on

1-LIC-3-173 was R5 and the lo pot R6.

After reviewing the vendors manual, it was determined that IMI-121 had

been written to address the configuration covered under the 1983

vendors manual. However, controllers having different configurations

covered under a 1976 vendors manual were in use at the plant.

Controller 1-LIC-3-174 was one of the 1976 controllers. IMI-121 was

being used to calibrate both types of controllers.

The licensee stated that 6 controllers were covered by the 1983 manual

and 12 controllers were covered by the 1976 manual. IMI-121 was

written to address the 1983 manual utilizing the 1983 Beckman factory

calibration procedure as a base document. The engineer who wrote the

procedure was not aware that controllers of different configurations

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existed. The procedure was field run by the engineer and a technician.

However, by chance, the controller. used in the field test was of the

1983 configuration.

When questioned about the historical records documenting changes in

equipment design, the licensee produced a February 6, 1978 letter

indicating that Beckman had informed the licensee of the change in

circuit boards. The licensee stated that in the past the knowledge and

personal files of the cognizant engineer had been relied on to track

these differences. The engineer who wrote IMI-121 was not aware of the

letter or the equipment differences.

The licensee has reviewed the procedure and determined that although

the pots were labeled incorrectly, i.e. , R3 and R4 vs. R5 and R6,

these were the only two pots on the adjustable limits board; the

procedure further specified that the technician was to adjust the Hi

pot in step 6.3.4 and the Lo pot in step 6.3.5; and, the pots were also

labeled Hi and Lo. The licensee concluded that there was no safety

significance since the probability of adjusting the wrong pot was low

and the controller would not have responded as desired if the incorrect

pot had been adjusted.

The inspector asked why the technicians had not changed the procedure

when it had been used previously. The licensee stated that the R3 and

R4 lettering on the board was difficult to read and the technicians

were using the Hi and Lo imprints to perform the step.

The inspector requested the licensee to address the problem of assuring

that the correct vendor manuals are being utilized to write procedures

for calibration and operation of equipment in the plant. The licensee

stated that this problem had been identified previously and that a

program to revalidate all plant "endors manuals had been established.

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This program will also establish . c oss reference list between each

l component, not just classes of crmptnents, and the correct vendors

I manual. The implementation of this program to ensure that correct

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vendor manuals are used and incorporated into plant procedures will be

followed under Inspector Followup Item IFI 327,328/86-42-04.

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c. The inspector observed air flow measurements for Train B of the

Auxiliary Building Gas Treatment System (ABGTS) conducted in accordance

with Technical Instruction (TI)-50, Air Flow Measurements Methods, and

l Surveillance Instruction (SI)-149, Auxiliary Building Gas Treatment

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System Vacuum Test, Unit 0. The air flow measurements are conducted to

meet the surveillance requirements of TS 4.7.8.d.3. The test was

conducted by the Engineering Test group. The engineer and technicians

performed the test in accordance with the instructions. The results

l met the acceptance criteria. No violations or deviations were

identified.

d. On July 17, 1986, the inspectors observed two electrical maintenance

technicians preparing to perform SI-238, Diesel Generator Battery

System Inspection Units 1 and 2. Precaution 4.1 of the procedure

states that, " Approved goggles and face shield, acid resistant aprons

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and gloves shall be worn while working on batteries in any activity

which could involve the splashing of acid." The inspector questioned

the workers as to the whereabouts of this safety equipment. They

responded that this equipment was not necessary if they were careful.

The inspector questioned the workers about. the need to follow .

procedures. The workers then proceeded to find the required safety

gear.

e. On July 21, 1986, the inspector witnessed portions of SI-45.1.b, "ERCW

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Pumps" being performed on Pump R-A. This portion of the procedure is

used to redefine the pump curves per ASME Section XI. The procedure

! was out and being followed by personnel in the Control Room. Addi-

l tional personnel were in direct contact with the Control Room and were

under the direction of the Test Engineer. SI-45.1 is a Plant Opera-

tional Review Committee (PORC) approved Surveillance Instruction and

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had Temporary Change 86-1002 in effect.

j No violations or deviations were identified.

! 7. Monthly Maintenance Observations (62703)

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

were reviewed to ascertain that they were conducted in accordance with

i' approved procedures, regulatory guides, industry codes and standards,

and in conformance with TS.

I The following items were considered during this review: LCOs met while

i componcnts or systems were removed from service; redundant components

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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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controlled and the repair record accurately reflected what actually

. took place; functional testing and/or calibrations performed prior to

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returning components or systems to service; quality control records

maintained; activities accomplished by qualified personnel; parts and

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materials. used properly certified; radiological controls implemented;

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Quality Control (QC) hold points established where required and

i observed; fire prevention controls implemented; and housekeeping

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actively pursued. '

b. The inspector observed the replacement of valve 2-FSV-30-046B, a ,

solenoid valve for containment vacuum relief valve 2-FCV-30-046. The

solenoid valve had been leaking such that the relief valve would not

close. The following documents were reviewed:

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Work Request B130837

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Modifications and Additions Instruction (M&AI)-7, Cable

Terminations, Splicing and Repairing of Damaged Cables

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Maintenance Instruction (MI)-6.20, Configuration Control During

Maintenance Activities

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Valve 2-FCV-30-046 was originally worked on Maintenance Report (MR)

8561828 on November 17, 1985, to correct a seat leakage problem. The

soft seat was replaced and SI-158.1 was performed. The SI failed a

second time and the MR was returned for troubleshooting.

The MR was then sent to Electrical Maintenance to correct problems with-

the limit switch. The valve was worked and once again failed to pass  !

SI-158.1.

- After a troubleshooting procedure, the maintenance crew replaced the

soft seat a second time. Following this work the valve failed to

stroke at all. At this time, it was determined that 2-FSV-30-46B

was exhausting continuously. MR B130837 was written to correct the

problem. The replacement parts were not available to 'fix the broken

solenoid, so a new valve was procured from Watts Bar.

The inspector observed electrical ' and mechanical maintenance crews

remove the old valve and install a new valve qualified to 10 CFR 50.49

requirements. The EQ binder SQNEQSOL.006 indicates that this model

NP 831654V valve-is to be mounted per ASCO manual V5967 R1. It also

discusses that the pipe sealant / lubrication for the airline should not

be petroleum based and should not come in contact with the valve

internals.

The technicians in the field followed the requirements of the work

1- request and utilized MI-6.20 to control the configuration during the

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valve installation. During the installation, it was noted by the

inspector that although the valve was 50.49 equipment, the work request

had not been preplanned to address the requirements of M&AI-7. These

new EQ criteria require that as equipment is changed out the new

installation must meet specific requirements for cable splicing,

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including application of Raychem and minimum cable bend radius.

The technicians determined in the field that in order to meet these

requirements, additional material would be needed. The technicians

first returned the work request to procure QA bolts for the splice.

The work request was replanned at that time to include the bolts, the

materials for the Raychem application and a new conduit to meet the

minimum bend requirements. During the second entry, the QC inspector

observing the work determined that the Raychem packages were not the

correct size. The QC inspector issued a rejection on this problem and

on a failure to list the conduit to be inspected. The technicians

- returned to the shop to have the foreman correct these errors.

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The inspector reviewed M&AI-7 and determined that the procedure could

be the source of many errors of this type. The procedure excerpts

sheets from complicated Raychem instructions specifying the sizes and

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configurations of the application. These sheets have been reduced to

almost illegible size print to fit on an 8 by 11 sheet. Proper

preplanning of the job by individuals intimately familiar with these

instructions appears to be the key to correct installation. However,

it is not evident from observation of this maintenance and other

maintenance that this is being accomplished. The inspector will review

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other QC rejections to see if Raychem splices represent a generic

problem that TVA should have addressed. This review will include an

evaluation of the adequacy of the current procedure and any corrective

action taken to prevent recurrence of similar problems. This item will

be tracked as URI 327,328/86-42-05

In addition, the inspector noted that housekeeping in the area was

poor. The platform for the relief valve was littered with nails,

wires, cigarette butts and other materials. It should be noted that

this area is a regulated area and no smoking is allowed. The

technicians performing this work cleaned the area prior to leaving.

The inspector noted several other areas on EL 823 of the annulus where

the housekeeping was poor.

c. The inspector inspected an application of heat trace tape to a safety

related portion of the Chemical Volume Control System (CVCS), system

number 62. A change in the type of heat tracing applied to the system

had been accomplished through the use of a Temporary Alteration Change

Form (TACF). The inspector also discussed the application of the heat

tracing with an onsite Quality Assurance (QA) inspector who had also

inspected the application of heat tracing. The QA inspector had

written a draft Corrective Action Report (CAR). The following day the

inspector discussed the onsite QA inspector's findings with licensee

management and reviewed the progress of the draft CAR. The draft CAR

reviewed by the inspector is now identified as CAR 86-07-038. In

addition the inspector reviewed the following documents:

M&AI-18, Installation and Repair of Heat Trace

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

Cables

MI-6.20, Configuration Control During Maintenance Activities

TACF 0-85-097-234

TACF 1-85-060-234

Drawing 47K 406-54 R7

Drawing 86 004 74-90A, sheet 6

Work Request A-529926

- Work Request A-529943

Work Request B-115658

Work Request B-115659

Work Request A-534406

Work Request A-518212

Work Request A-539170

TACF 0-85-097-234 stated that the existing series heat trace (Thermon)

was to be replaced with non-QA Raychem Chemelex semiconducting, self-

regulating, parallel heat trace for safety-related applications

involved with system 62. It further stated that the original Thermon-

heat trace applied 260 watts of heat per heat trace circuit by wrapping

26 feet with 10 watts per foot on the pump and the pipe. The TACF went

on to state that the pump would have the same wattage of heat trace

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after the Thermon was replaced. The Unreviewed Safety Question Deter-

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mination Section- of the TACF also stated that the parallel heat trace

tape (Chemelex) would have the same total wattage as the original heat

trace.

, TACF 1-85-060-234 stated that heat tracing circuits-being replaced with

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non-QA Raychem Chemelex would maintain the process temperature of the

Boric Acid transfer Pump with an equivalent total wattage of Chemelex.

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TACF 0-85-097-234 stated that there would be a required verification

that the temperature would be maintained between 170 degrees and 180

degrees F.

TS 6.8.1 states that written procedures shall be established,

implemented and maintained covering the maintenance of safety related

equipment. Standard Practice SQA-119 establishes the procedure to

, implement a PORC approved temporary alteration to a safety-related

system. Standards established by TACF 0-85-097-234 and approved by the

, PORC, for the total amount of wattage to be applied to the system 62

'

pumps and piping, were not implemented by the above stated Work

, Requests. This lack of TACF standard implementat:on was a result of a

i failure to adequately control the configuration, and hence, the wattage

. output, of the replacement heat trace tape (Chemelex). This is identi-

l fied as Violation 327,328/86-42-06.

,

In addition to the violation 327,328/86-42-06, several other procedural

violations were identified which meet the criteria to be identified as

a Licensee Identified Violation. These issues included the use of work

instructions -which did not apply to the replacement heat trace tape

(Chemelex); the lack of post maintenance testing to verify system

y temperatures were within those identified by the TACFs; inadequate

splicing of the replacement heat trace tape; and inadequate work

instructions. The corrective actions for these issues . will be

inspected as anciliary issues to Violation 327,328/86-42-06.

! d. The inspector witnessed the reinstallation of the 1B-B Emergency Diesel

. Generator governor / actuator. The actuator is the hydraulic component

which moves the injector racks to regulate fuel supply in response to

the. governor's demands. The actuator is mounted directly below the

.

governor. The actuators from the 1B-B and 28-B generators had been

i shipped to the manufacturer (Woodward) for refurbishing and realignment.

I

c During the reinstallation of the 1B-B engine 2 actuator, the maintenance

crew discovered that the actuator-to-rack link did not have a locator

groove in its spline arrangement. This locator is necessary to ensure

that the link is replaced onto the actuator's shaft in the same relative

position as it was when removed. A spare link with the proper locator

groove was obtained from stores to replace the original.

'

After reinstallatica of the actuators on the 2B-B unit, operation of i

, the actuators was found to be erratic. Field adjustments to both l

actuators by a vendor representative corrected the problem. Similar

field adjustments are expected to be necessary for the other units

when their actuators are adjusted and replaced.

!

!

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Documentation for the work described above included the following:

WR 132489

WR 132490

MI-6.20, Configuration Control

SI-7, Diesel Generator Surveillance Instruction

SI-102, Diesel Generator Inspection

M&AI-7, Modifications and Additions Instructions, " Cable

Terminations, Splicing, and Repairing of Damaged Cables"

Manual 92652, Validated Tech Manual, "EMD Diesel Generators"

Manual 82340, Woodward Governor / Actuator

No violations or deviations from procedures were identified during

observation of the diesel generator repair work.

e. The inspector reviewed WR B115764 which was work complete June 2, 1986.

The WR was written to install new packing and 0-rings on the Essential

Raw Cooling Water (ERCW) pump R-A. The WR and MR supplement was PORC

approved on March 20, 1986. The workmen removed the stuffing box and

found that the sleeve was damaged. The parts were not available at the

time. Therefore, only the packing and 0-rings were replaced per the WR

and the pump was reassembled. The WR called for a functional test per

SMI-0-67-5. This was not performed and the WR was not closed.

Subsequently, the pump was used in performance of SI-26.2A, Loss of

Offsite Power with Safety Injection D/G 2A-A Containment Isolation

Test, Unit 2. Licensed operators stated that there was not a problem

>

with using an inoperable pump for loading the D/G in SI-26.2A. The

question of using an inoperable ERCW pump to load the Emergency Diesel

Generator (EDG) during an SI will be further addressed by the inspector

and will be tracked as URI 327,328/86-42-07.

8. 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 2

50-328/86002

50-328/86003

(0 pen) LER 50-327,328/86011. In April 1986 LER 86-11 was issued discussing

i an error in the Containment sump level setpoint. The TS stated the set

i point to be 30 inches above elevation 680 feet. The set point was actually

being calculated 30" above the containment floor (elevation 679 feet 9

inches). The error was found to have existed since the initial issuance of

the TS and is believed to have been caused by an error in the instrument

mounting drawing for the sump level channels. The drawing error was

corrected in 1983, but the error in the setpoint was not detected.

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i The inspector requested that the discrepancy be evaluated to determine if

the discrepancy in the containment floor elevation impacted on the

Containment Free Volume input to the design basis calculations. The

licensee determined that the error was not in the plant architectural

drawings, but only in the instrument mounting drawings. Licensee design

personnel also stated that an error of 3 inches in the floor of the

containment would result in a maximum error of 0.25% in the Containment

Free Volume (1.19 million Cubic Feet). This error is well within the

calculational error band of the original design number.

.I As discussed in Inspection Report 86-37, the containment sump level is not

l a limiting signal for Residual Heat Removal (RHR) swap-over to the sump.

Therefore, this three-inch difference in setpoint did not significantly

'

4

effect the response of the plant to a design basis accident. The licensee

has also recalibrated these instruments to the TS setpoint. The question

. about control of drawings was identified and discussed in previous inspection

reports and is under continuing NRC review. This LER will remain open

pending regional review of the licensee's findings in their TS surveillance .

r

t

task force.

9. -Event Followup (93702, 62703) '

a. On July 11, 1986, at 11:00 a.m. (EDT), the plant declared a Notification

i of an Unusual Event (NOVE) when they were informed by the load dispatcher

that an earthquake of approximately 3.7 on the Richter scale had occurred

near Dalton, GA (approximately 25 miles South of the plant). There were

l' no seismic monitor alarms received at the Sequoyah site, and no apparent

damage occurred. The NOUE was terminated at 11:05 a.m. Subsequently,

I

the licensee checked the Remote Seismic Monitoring Instrumentation and

found that one of the Triaxial Time-History Accelerographs in the

Diesel Generator (EDG) Building had tripped. This instrument has been

. documented in the past as tripping during EDG starts. An SI on the

!

1B-B EDG was being conducted at the time of the incident. Therefore,

the plant attributed the accelerograph trip to the EDG start rather

than to the seismic event. This was corroborated by the lack of

! indication on the Triaxial Response-Spectrum Recorder located in the

i same general vicinity.

b. On July 15,1986, at 9:04 a.m. , an inadvertent start of three EDGs

occurred during the performance of a Fuse Identification Check per ECN

58-80. During verification of fuses in the control circuit for breaker

1822 (the 2C 6.9 KV Unit Board Normal Feeder Breaker to the 28-B

Shutdown Board), the D.C. power fuses were removed. Upon replacing the

fuses, the Neutral Overcurrent Relay picked up and sent a gate pulse to

the breaker's trip relay, which opened the breaker. This caused an

undervoltage condition to occur on the 28-B Shutdown Board. This

resulted in the automatic start of EDGs 1A-A, 28-B and 2A-A and a rapid

transfer of. the 2B-B Shutdown Board to its alternate source of power.

,

EDG 1B-B did not start since it was out of service at the time.

!

l The licensee conducted an investigation into the event and determined

( that the trouble was caused by a faulty Neutral Overcurrent Relay

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14

picking up when it sensed the D.C. control power surge as the trip

fuses were replaced.

During the recovery from this event, an operator switching error caused

a loss of alternate power to Shutdown Board 2B-B. The respective EDG

tied in to the board and loaded. The inspectors will review the

switching problems following the event and the associated corrective

action following the issuance of the licensee's 30-day report.

c. During a performance of Special Maintenance Instruction (SMI)-0-317-30

on July 24, 1986, an inadvertent ESF actuation occurred at 9:04 a.m.

The instruction was being used to verify nameplate data on certain

plant circuit breakers. An Auxiliary Unit Operator (AV0) was removing

the cover panel on the first row of breakers on the Vital Battery

Board 1, Panel 2. During this evolution the panel cover slipped and

tripped open breakers 210 and 212. Breaker 212 feeds column C in

Panel 4 of the Vital Battery Board 1. Column C, circuit 42, is the

feeder to the Remote Emergency Start Circuit for EDG 1A-A. This

circuit is normally energized and is "de-energized to actuate."

Therefore, the loss of power to this circuit gave the effect of a

Remote Emergency Start signal to all EDGs. The "B" train was

tagged-out for repair to the Woodward Governors and did not start.

EDGs 1A-A and 2A-A started as expected. The EDGs were secured and

the licensee investigation showed no complications.

10. Summary of Management Meeting

A meeting was held with the licensee on August 1,1986, which was attended

by:

J. Wills, TVA Licensing Staff

M. Harding, TVA Site Licensing and Compliance Supervisor

G. Kirk, TVA Compliance Supervisor

B. Debs, NRC DRP Section Chief

K. Jenison, NRC Resident Inspector

The meeting lasted approximately six hours, during which all license

conditions listed in the front of each Unit's TS were discussed. The

participants were able to evaluate all of the license conditions and

determine that they were applicable to one of three categories.

1. License Condition met by the licensee, inspected by the NRC and closed.

2. Additional information required to establish if the license condition

was met.

3. Submittal to NRC made by the licensee and no NRC response could be

identified.

Those license conditions which were met by the licensee and were inspected

by the NRC require no further action.

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15

Those license conditions, for which additional information is required

to establish if the license condition was met, 'were communicated to the

licensee. The licensee agreed to gather the required information and-

provide it to the resident inspector prior to a meeting which is tentatively

scheduled for the month of September.

Those conditions where a submittal to the NRC was made and no response has

been received by the licensee are listed below. (NOTE The license

condition numbers do not agree between units):

UNIT 1 UNIT 2

2.C (5) 2.C (5)

2.C (6) 2.C (15)

2.C (8) 2.C (16) j.

2.C (9) (c) 2.C (16) n.

2.C (13) 2.F

2.C (14)

2.C (16)

2.C (17)

2.C (18) (b)

2.C (21)

2.C (22) E

It is expected that most issues will be resolved to an extent that a status

can be given for each license condition in the resident inspector inspection

report that covers the period September 6 through October 5, 1986.

_ _ . . _--