ML20216H784
| ML20216H784 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 04/10/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20216H631 | List: |
| References | |
| 50-327-98-03, 50-327-98-3, 50-328-98-03, 50-328-98-3, NUDOCS 9804210224 | |
| Download: ML20216H784 (30) | |
See also: IR 05000327/1998003
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U.S. NUCLEAR REGULATORY COMMISSION
REGION II
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Docket Nos:
50-327. 50-328
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License Nos:
Report No: 50-327/98-03. 50-328/98-03
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Licensee:
Tennessee Valley Authority (TVA)
Facility:
Sequoyah Nuclear Plant. Units 1 & 2
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Location:
Sequoyah Access Road
Hamilton County. TN 37379
Dates:
February 1 through March 14. 1998
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Inspectors:
M. Shannon. Senior Resident Inspector
R. Starkey Resident Inspector
R. Telson Resident Inspector
C. Smith. Reactor Inspector (Section E2.1)
E. Testa. Reactor Inspector (Sections R1, R2. R7. R8)
Approved by:
H. Christensen. Chief
Reactor Projects Branch 6
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Division of Reactor Projects
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Enclosure 2
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9804210224 980410
ADOCK 05000327
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EXECUTIVE SUMMARY
Sequoyah Nuclear Plant. Units 1 & 2
NRC Inspection Report 50-327/98-03, 50-328/98-03
This integrated inspection included aspects of licensee operations,
maintenance, engineering, plant support. and effectiveness of licensee
controls in identifying. resolving, and preventing problems; in addition, it
includes the results of a radiological control inspection and an engineering
inspection.
Ooerations
A negative finding was identified due to a lack of instructions in
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surveillance procedure 0-SI-SXV-063-266.0 for establishing the necessary
plant conditions prior to valve stroke testing (Section 01.2).
A negative finding was identified for operations management not ensuring
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that operators periodically review the printout from the
annunciator / alarm printer (Section 01.3).
The inspectors noted a potential problem requiring further review for a
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potential failure to enter the action statement of Technical Specification (TS) 3.11.2.5 when chemistry grab samples indicated a high
oxygen concentration in Unit 1 pressurizer relief tank (PRT) (Section
01.4).
The inspectors noted several potential problems during the review of the
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high oxygen concentration in Unit 1 PRT.
Further review will be
necessary for the following items: potential failure to meet the Updated
Final Safety Analysis Report (UFSAR) requirements for having an
automatic gas analyzer. not adequately revising the UFSAR to describe
actual plant configuration for the gas analyzer, inappropriately closing
the design change package and not establishing a periodic
oxygen / hydrogen sampling program for the various waste gas collection
tanks (Section 01.4).
Mair,tenance
In general, the conduct of maintenance and surveillance activities was
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good (Section M1.1).
Enaineerina
The inspectors noted that the licensee's American Society of Mechanical
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Engineers (ASME)Section XI valve testing program may not include all
necessary/ required valve testing and further review will be necessary to
resolve this issue (Section E1.1).
The Corrective Action Program was generally implemented in accordance
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with the requirements of procedure SSP-3.4. Corrective Action. Revision
23. The program follows the guidance of Generic Letter 91-18. Revision
1. for disposition of degraded and non-conforming conditions and fully
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satisfies- the' requirements of 10 CFR 50 Appendix B.' Criterion XVI.
(Section E2.1).
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Plant Sucoort
A violation was identified for' failure to initiate a problem evaluation
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report (PER) afterLchemistry analysis of Unit 1 PRT sample -indicated a
high oxygen concentration. A second example of this' violation was
identified for_ the failure to initiate a work request when chemistry
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personnel could not obtain a PRT sample due;to apparent blockage of the
sample line (Section 01.4).
Radiological facility conditions and housekeeping in radioactive waste
storage areas. health abysics facilities, auxiliary building and
refueling floor were 03 served to be good, material was labeled
appropriately. and areas were properly posted (Section R1.1).
Radiation work activities were planned.. radiation worker doses were
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being maintained well;below regulatory limits and the licensee was
continuing to maintain exposures as low as reasonably achievable
(Section.R1.1).
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' Contamination control was effective (Section R1.1).
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The licensee had effectively implemented a program for shipping and
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receiving radioactive materials as required by NRC and Department of
Transportation (DOT) regulations (Section R1.2).
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The water chemistry control program.for monitoring primary and secondary
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water quality had been implemented._for_those parameters reviewed. in
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accordance with the TS requirements (Section R1.3).
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The meteorological. instrumentation had been adequately maintained and
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the meteorological monitoring program had been effectively implemented
_ Section R2).
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The inspectors' determined the licensee was effectively conducting formal
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radiation protection (RP) audits as required by TS and conducting self-
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assessments. The licensee was effectively developing corrective action
plans and completing corrective actions in a timely. manner (Section R7).
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Report Details
Summary of Plant Status
Unit 1 operated at full power for the entire inspection period.
Unit 2 operated at full power for the entire inspection period.
Review of Updated Final Safety Analysis Reoort (UFSAR) Commitments
While performing inspections discussed in this report, the inspectors reviewed
the applicable portions of the UFSAR that were related to the areas inspected.
The inspectors verified that the UFSAR wording was generally consistent with
the observed plant practices, procedures, and/or parameters.
However, during
the review of the UFSAR for the operation of the waste gas analyzer, the
inspectors noted that the recently installed waste gas analyzer could not
function as stated in the UFSAR.
This issue is discussed in Section 01.4 of
this report.
I. Operations
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Conduct of Operations
01.1 General Comments (71707)
Using Inspection Procedure 71707, the inspectors conducted frequent
reviews of ongoing plant operations.
In general, the conduct of
operations was considered to be good.
01.2 Unit 2 Inadvertent Boration Event
a.
Insoection Scooe (71707)
The inspectors reviewed the circumstances surrounding a Unit 2
inadvertent boration event as a result of an American Society of
Mechanical Engineers (ASME) Code Section XI valve stroke test. The
inspectors reviewed the Problem Evaluation Report (PER) No. SO980188PER:
the Unit 2 control room log: Procedure 0-SI-SXV-063-266.0. "ASME Section
XI Valve Testing." Rev. 3. Data Sheet No. FCV-63-7: the ASME Section XI
Code: Volume Control Tank (VCT) level and pressure trends: charging
system drawings: and engineering calculations.
The inspectors also
interviewed the system engineer, engineering department supervision, and
operations personnel as to their review and investigation into the
event.
b.
Observations and Findinas
On February 25. 1998 at approximately 2:15 a.m.. the licensee was
performing ASME Code Section XI stroke testing of valve 2-FCV-63-7.
" Safety Injection System (SIS) Pump Suction from Residual Heat Removal
(RHR) Pump Discharge." The control room operators noted a power level
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decrease of approximately 34 Mwt.
Subsequently, the operators
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determined the )ower decrease to be from an inadvertent boron addition.
Actions were tacen to enter Abnormal Operating Procedure (AOP) C.02.
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" Dilution and Rod Movements to Maintain Reactor Power." Reactor power
was stabilized and normal operations resumed without further incident.
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The AOP was exited at 5:35 a.m.
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The performance of surveillance )rocedure 0-SI-SXV-063-266.0 stroked 2-
FCV-63-7 established a flowpath Jetween the Refueling Water Storage Tank-
'(RWST) and the charging pump suction.
Normal charging operation
provides suction from the VCT. However, during performance of this test
VCT level was approximately 24% with pressure approximately 20 asig.
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Operating at those conditions established an equivalent static lead
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pressure in both the VCT and RWST.
Therefore due to the flowpath
already established for stroke testing of 2-FCV-63-7 borated water from
the RWST was directly supplied to the charging pump suction.
As a result of this event, the licensee revised the surveillance
procedure to include steps to establish a minimum VCT level and pressure-
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prior to performance of the subject valve stroke testing. The licensee
is also conducting a review of other valve stroke procedures to
determine if'other flowpaths could be established that may cause an
inadvertent dilution or boration event.
c.
Conclusions
A negative. finding was identified due to a lack of instructions in
surveillance procedure 0-SI-SXV-063-266.0 for establishing the necessary
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plant conditions prior to valve stroke testing.
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01.3 Ooerators 00 Not Periodically Review Annunciator-Printer
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a.
.Insoection Scooe (71707)
The inspectors reviewed the circumstances which led to the
identification by the licensee that the main control room annunciator
printer printout was not routinely reviewed by control room operators.
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b.
Observations and Findinas
-On February 24, 1998, the licensee initiated PER No. SO980185PER which
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documented an intermittent (occasionally flickering) " protection set .I
trouble" status light on Unit 2.
The intermittent status light wa's of
such a short duration (approximately one-tenth of a second) that
.o>erators seldom observed the-flickering light. Upon further' review.
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t1e licensee discovered that during the month of February that the
- channel I protection set alarm had been recorded on the annunciator
printer approximately four times and that the channel IV protection set
trouble alarm had been recorded approximately 20 times. The licensee
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subsequently. installed monitoring equipment on the protection set
channels in order to identify the source of the alarms.
On March 17.
1998. the licensee identified and replaced a faulty card in an
instrument rack which a) pears to have corrected the problem with the
intermittent status lig1ts.
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When the licensee identified that the intermittent status lights had
been recording on the alarm printer. they discovered that there was no
procedural requirement or expectation that operators periodically review
the annunciator 3rinter.
The inspectors reviewed SSP-12.1. Conduct of
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Operations and t7e operators' turnover procedures and confirmed that
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neither addressed a requirement for operators to review the annunciator
printer printout.
As an interim corrective action. the licensee initiated Standing Order
98-014. dated March 16, 1998. which stated that operators shall verify
at the beginning and end of their shift that the alarm printout does not
contain any entries indicating an unknown problem, document the review
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in the unit log. and inform the unit supervisor and shift manager of any
abnormal annunciator entries. The long term corrective action will be
to revise the operators' turnover procedures (1-PI-0PS-000--21.1 and 2-
PI-0PS-000.023.1) to include a review of the annunciator printer at the
beginning and end of each shift.
c.
Conclusions
A negative finding was identified for operations management not ensuring
that operators periodically review the printout from the
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annunciator / alarm printer.
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01.4 Potentially Hiah Concentrations of Oxvaen and Hydroaen In the
Pressurizer Relief Tank (PRT)
a.
Insoection Scoce (71707 and 84750)
The inspectors reviewed the licensee's followup and corrective actions
after grab samples indicated high concentrations of oxygen and hydrogen
-were present in the PRT.
b.
Observations and Findinas
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On February 6. 1998. the licensee sampled the Unit 1 PRT. Analysis of
the sample. indicated that the hydrogen concentration was 22.8% and the
oxygen concentration was 12.1%.
This sample indicated that a flammable
or explosive mixture of hydrogen and oxygen was present in the PRT. On
February 7. the licensee resampled the Unit 1 PRT. Analysis of the
sample indicated that the hydrogen concentration was 22.8% and the
oxygen concentration was 12%.
Later on February 7. the issue was
discussed between the shift manager, shift technical advisor. Unit 1
senior reactor operator and plant licensing.
Licensing concluded that
the PRT was not part of the Waste Gas Holdup System as defined in TS , 3.11.2.5 and thus was not a regulatory concern that would ) lace the
plant in a LCO condition.
The shift manager concurred wit 1 this
interpretation. The Unit'l control room logs noted that a caution order
would be placed on the PRT vent isolation valve to the waste gas header
and that chemistry department personnel would investigate and resolve
concerns with the suspect sampling technique / problem.
On February 8.
1998, the licensee obtained another sample of the Unit 1 PRT and the
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analysis again indicated high concentrations of hydrogen at 35% and
oxygen at 9%.
During the last week of February, the inspectors conducted an integrated
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review of the control. room logs and noted the February 7 and February 8
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entries concerning the high concentrations of oxygen and hydrogen in the
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PRT.
The licensee was requested to discuss the issue on March 2 with
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the inspectors.
The licensee stated that the high concentration of
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. Oxygen indicated in the PRT was due to a sampling problem and that the
PRT did not contain a high oxygen concentration.
The licensee also
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indicated that a PER would be initiated to track resolution of this
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issue. The inspectors requested to be informed prior to the next PRT
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vent or sample evolution so that the evolution could be observed.
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On March 12. 1998, further discussions were conducted with operations
and chemistry departments. Based on these discussions, the inspectors
noted that plant startup activities following the last refueling outage
could have introduced oxygen into the PRT: the licensee did not
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continuously monitor or periodically sample the PRT: the licensee could
not sample the PRT without drawing a vacuum on the PRT sample line; a
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work request to troubleshoot the problem with drawing a PRT sample had
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not been written: a PER had not been initiated to address the
potentially high concentrations of hydrogen and oxygen from the February
6. 7 and 8 sample results: and the licensee had not confirmed by sample
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analysis that the PRT did not have a high concentration of oxygen.
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On March 17. 1998, the licensee initiated a procedure revision to'the
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System Operating Instruction 1 S0-68-5. Pressurizer Relief Tank, to
' provide procedural instructions for venting the PRT while in Modes 1. 2.
3 and 4.
On March 18, 1998, the. Unit 2 PRT was sampled, pressurized
with nitrogen and sampled, and vented to the waste gas vent header and
sampled.
Analysis of the sam)les indicated that the oxygen
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concentration in the PRT was Jelow the revised procedure limit of 2%
limit.
On March 19. 1998, the Unit 1 PRT was sampled, pressurized with
nitrogen and sampled, and vented to the waste gas vent header and
sampled.
Analysis of the samples indicated oxygen concentrations of
ap)roximately 5% with hydrogen concentrations of about 25%.
During
su) sequent venting of the PRT to the waste gas vent header, the waste
gas analyzer indicated that the waste gases being processed from the PRT
contained less than a 1% concentration of oxygen. A manual grab sample
-of the waste gas decay tank also indicated that waste gases being
-processed from the PRT contained less than 1% oxygen. The online
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monitor and the additional manual grab sample of the PRT supported the
licensee's conclusion that the previous PRT sampling process had been
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providing erroneous.results.
The inspectors noted various problems during the ongoing reviews and
discussions of the PRT and sample monitor issues.
The following
paragraphs document the inspectors findings.
TS 3.11.2.5. Explosive Gas Mixture, requires that the concentration of
oxygen in the waste gas holdup system shall be limited to less than or
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equal to 2% by volume whenever the hydrogen concentration exceeds 4% by
volume. The surveillance recuirement SR 4.11.2.5 requires that the
concentration of hydrogen anc oxygen in the waste gas holdup system
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shall be determined to be within the above limits by monitoring the
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waste gas additions to the waste gas holdu) system with the hydrogen and
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oxygen monitors. Amendment 12 of the UFSA1. Section 11.3.2. states that
"The automatic gas analyzer determines the quantity of oxygen and
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hydrogen in the volume control tank, pressurizer relief tank, holdup
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tanks, evaporators, gas decay tanks, and spent resin storage tank and
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provides an alarm on high oxygen and hydrogen concentration." Amendment
13 to the UFSAR removed the ~ Automatic" requirement for the gas analyzer
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and stated. "The online gas analyzer determines the quantity of oxygen
and hydrogen in the volume control tank, pressurizer relief tank, holdup
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tanks, gas decay tanks, and spent resin storage tank by monitoring the
waste gas header, or by selecting the individual sample Joint. The
waste gas analyzer provides an alarm on high oxygen and lydrogen
concentration." . Based on the UFSAR statements, it ap) eared that the
" waste gas holdup system" documented in TS 3.11.2.5 s1ould include the
tanks where waste gases were collected (holdup tanks. PRT. etc.).
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associated piping and compressors, and the waste gas decay tanks and
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that TS 3.11.2.5 would be applicable to the entire waste gas collection,
processing and storage system.
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On February 6 and 7, 1998, the licensee sampled the PRT and noted high
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concentrations of hydrogen (23%) and oxygen (12%). however: the
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. licensee may have-inappropriately concluded that the PRT was not a part
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of the waste gas holdup system and therefore did not enter the action
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= statement,for TS 3.11.2.5.
TS 3.11.2.5 b states that "with the
concentration of oxygen in a waste gas holduo tank greater than 4% by
volume and the hydrogen concentration greates than 2% by volume, without
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delay suspend all additions of waste gases to the affected waste gas
holdup tank and reduce the concentration of oxygen to less than or equal
to 2% by volume without delay." Not entering the TS 3.11.2.5 LCO action
statement is being identified as an unresolved item pending 'further
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review.-(URI 50-327/98-03-01).
On February 6 and 7. 1998, when the initial PRT sampling )roblems were
noted, the licensee failed to initiate a PER to resolve t1e issue.
During discussions with the NRC on March 2. 1998, the licensee stated
that a PER would be initiated to address the issue; however on March
12. the ins)ectors noted that a PER still had not been initiated.
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March 13. PER No. SO980240PER was initiated to document the ongoing
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investigation into the PRT sampling and analysis difficulties. The
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licensee's Site Standard Practice procedure SSP-3.4. Corrective Action.
Section 3.0.A. requires personnel to promptly report adverse conditions
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on a work request / work order and/or a PER.
The failure of site
personnel to initiate a PER after the analysis of the PRT sample
indicated a high oxygen concentration is considered to be a failure to
follow the Corrective' Action procedure and is identified as a violation
(VIO 50-327/98-03-02).
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On February 6.1998 the licensee was unable to obtain a sample from the
pressurized (3-6 psig) PRT without using a vacuum ) ump. This adverse
condition was not addressed by initiation of a worc request until after
the March 12 discussion with the NRC. The failure to initiate a work
request is considered to be another example of a failure to follow the
Corrective Action procedure and is identified as a second example of
violation (VIO 50-327/98-03-02).
Amendment 12 of the UFSAR noted that "The automatic gas analyzer
determines the quantity of oxygen and hydrogen in the volume control
tank, pressurizer relief tank holdup tanks evaporators gas decay
tanks, and spent resin storage tank and 3rovides an alarm on high oxygen
and hydrogen concentration." However, t1e licensee stated during
discussions with the inspectors that the system had not been capable of
performing the automatic sampling as specified in the UFSAR. Amendment
13 of the UFSAR noted that. "The online gas analyzer determines the
quantity of oxygen and hydrogen in the volume control tank, pressurizer
relief tank, holdup tanks, gas decay tanks, and spent resin storage tank
by monitoring the waste gas header, or by selecting the individual
sample point." However, the inspectors noted that the system was not
capable of sampling the various tanks by " selecting individual sample
points." Following the installation of a new waste gas analyzer in
October 1997 the waste gas analyzer could no longer be aligned to
sample individual tanks.
The only way to sample the collection tanks
would be to perform a manual grab sample.
In addition, discussions with
the licensee indicated that a program to periodically sample the tanks
following the plant modification to the gas analyzer had not been
established.
During the review, the licensee noted that the October 1997 design
change of the gas analyzer had not been implemented correctly in that
the necessary changes to the UFSAR had not been processed although the
modification package was signed off as complete and was in " closed"
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status. The potential failure to meet the UFSAR requirements for having
a gas analyzer that could sample the individual tanks not adequately
revising the UFSAR to describe actual plant configuration for the gas
analyzer, inappropriately closing the modification package and not
establishing a periodic sampling program for the various waste gas
collection tanks is considered to be an unresolved item pending further
review (URI 50-327, 328/98-03-03).
Further discussions indicated that the licensee's original intent for
sampling the " individual sample points." referenced in the UFSAR.
amendment 13, was to aerform periodic manual grab samples that would
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then be analyzed in t1e chemistry lab.
The licensee indicated that all
necessary changes to the description for the waste gas analyzer would be
incorporated into Amendment 14 of the UFSAR.
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The inspectors reviewed the System Operating Instruction 1-S0-68-5 for
the Pressurizer Relief Tank and noted that the Precauticos and
Limitations section of the procedure provided limits for oxygen and
hydrogen concentrations in~the PRT.
Section 3.0.C stated "The PRT
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oxygen concentration limit is less than 5% by volume and the PRT
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hydrogen concentration limit is less than 4% by volume." Discussions
indicated that the licensee had not evaluated the PRT procedural limits
following the February 6 and 7 sample results because they considered
the sample results to be erroneous.
Based on the way the procedure
limits were written. the February 6, 7 and 8 samples indicated that.both
the hydrogen and oxygen concentrations exceeded the procedural
limitations. This procedural issue was considered to be a part of the
previous violation for failure to initiate a PER, as discussed in
Section 01.4 of this report.
c.
Conclusions
An unresolved item was identified for not entering the action statement
of TS'3.11.2.5 when chemistry grab samples indicated a high oxygen
concentration in the Unit 1 PRT.
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A violation was identified for the failure of site personnel to initiate
a PER after the' chemistry analysis of the Unit l'PRT sample indicated a
high oxygen concentration. A second example of this violation was
identified for the licensee's failure to initiate a work request when
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chemistry personnel could not obtain a PRT sample due to apparent
blockage of the sample line.
An unresolved item was identified for the potential failure to meet the
UFSAR requirements for having an automatic gas analyzer, not adequately
revising the UFSAR to describe actual plant configuration for the gas
analyzer inappropriately closing the design change. package and not
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establishing a periodic sampling program for the various waste gas
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collection tanks.
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Operational Status of Facilities and Equipment
02.1 Loss of Emeraency Sirens
a. .Insoection Scope (71707)
The inspectors reviewed the February 4,1998.10 CFR 50.72 notification
due to a partial loss of emergency siren capability caused by inclement
weather.
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b.
Observations and Findinas
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On February-4,1998, at approximately 10:12 a.m., inclement weather in
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'the area caused a loss of-power to areas around the plant.
This caused
- a loss of approximately 29 out of 107 emergency sirens. The state of
. Tennessee and the NRC were promptly notified of the condition.
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majority of the sirens were restored by 12:00 p.m.
on February 5. and
all of the sirens were functioning as required by 8:00 a.m. on February-
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Licensee actions appeared to be appropriate during the inclement
weather conditions.
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Miscellaneous Operations Issues (92901)
08.1
(Closed) EA 97-232 (01013). Failure to Identify and Take Corrective
Actions for Loss of RCS Inventory Control While Drainino Pressurizer
(Closed) EA 97-232 (01023). Failure to Properly Loa a Unit 1 RCS Drain
Down Evolution
The inspectors verified the corrective actions for the above two
violations described in the licensee's response letter. dated August 11.
1997, to be comprehensive and reasonable.
The inspectors verified that
all corrective action items have been completed with the exception of
replacing the pressurizer upper-tap angle root valves.
The licensee's
response letter committed to replacing the pressurizer upper-tap angle
root valves during the Unit 1 Cycle 9 refueling outage (fall 1998) and
the Unit 2 Cycle 9 refueling outage (spring 1999).
08.2 (Closed) EA 97-409 (01013). Failure to Maintain Ooerable DC Vital
Battery Channels
(Closed) EA 97-409 (01023). Failure to Follow Procedures While Alianina
a Soare Vital Battery
(Closed) EA 97-409 (01033). Failure to Include Indeoendent Verification
Per Procedure While Alianina Vital Batteries
The inspectors verified the corrective actions for the above three
violations described in the licensee's response letter dated. January 7.
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1998, to be reasonable and complete with the following exception.
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A)plicable plant procedures in the Operations. Maintenance and
C1emistry areas have been reviewed to ensure that verification
requirements are correct and standardized: however, the procedure
revisions are pending.
The licensee committed in their response letter
to revise the applicable procedures by March 27, 1998.
08.3 (Closed) LER 50-327. 328/97011. Revision 0. Ooeration of Vital Battery
Board #4 Without a Battery Source
(Closed) LER 50-327. 328/97011. Revision 1. Doeration of Vital Battery
Board #4 Without a Battery Source
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The events described in these LERs were addressed in the closure of
violations, related to the same event. in Section 08.2 of this report.
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No new issues were revealed by the LERs.
II. Maintenance
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M1
Conduct of Maintenance
M1.1 General Comments
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a.
Insoection Scooe (61726 & 62707)
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Using inspection procedures 61726 and 62707, the inspectors conducted
frequent reviews of ongoing maintenance and surveillance activities.
The inspectors observed and/or reviewed all or portions of the following
work activities and/or surveillances:
0-SI-SXP-067-201.P
Essential Raw Cooling Water Pump L-B
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Performance Test. Rev. 0
0-SI-SXV-063-266.0
ASME Section XI Valve Testing: FCV-63-7
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Rev. 3
0-SI-SXV-070-201.0
CCS Pump C-S Discharge Check Valve (0-70-
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504) Quarterly Closing Test. Rev.1
0-50-70-1
Component Cooling Water System ~B" Train.
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Rev. 11
2-SI-SXP-070-201.B
Component Cooling Pump 2B-B Performance
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Test. Rev. 0
WO 97-943700-002
Implement DCN T-12958-A: Replace Existing
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Thermocouples with New System Design on
WO 98-305500-000
EDG 1B-B Electrical Outage: Generator
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Windings Repair
WO 98-002996-000
Auxiliary Charging Pump 2B Rebuild due to
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Low Output Flow: SON-2-PMP-084-0021
WO 98-344081-021
Calibrate Fuel Oil System Instrument PI-
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140 EDG 18-B
0-SI-0PS-083-151.B
Six Month Test Requirement on Electric
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Hydrogen Recombiner System Train B
Replace SCR on Hydrogen Recombiner B Phase
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b.
Observations and Findinas
In general the conduct of maintenance and surveillance activities
observed were good.
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During performance of surveillance procedures 0-SI-SXV-070-201.0 and 2-
SI-SXP-070-201.B the inspectors questioned the test methodology by which
the licensee tests the discharge check valves to satisfy ASME Section XI
code requirements for testing of check valves.
Specifically. the
licensee's procedure has the operating pump shut down after another pump
has been started.
The differential pressure developed between the
operating Jump and the pump just shutdown allows the discharge check
valve of tlat pump to be slammed shut.
This action could cause
potential damage to the valves over an extended period of time.
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!
discussions with operations personnel the licensee indicated that these
L
valves had been replaced previously. As a result, the inspectors
!
requested the licensee to review the procedure and determine if a better
i
testing method is possible to mitigate potential damage to the valves.
L
Until that review is completed this item is identified as Inspection
Followup Item (IFI 60-327/98-03-04). Valve Testing Methodology Review.
-The inspectors observed portions of the planned maintenance outage on
During performance of WO 98-305500 the licensee
identified that small sections of the diesel generator winding
insulation had become degraded.-
Specifically, in two sections of.the
windings the insulation was burnt. -With further examination, through
use of a thermography camera, the licensee identified several other.
areas with higher than normal temperatures in the windings. These areas
were suspect to similar insulation damage, although not visually
apparent. However. the licensee repaired the identified areas and
completed the maintenance activity without further delay.
Pending
further review and determination of the root cause for the degraded
winding insulation condition and examination of the other EDGs. this
issue is identified as an Inspection Followup Item (IFI 50-327/98-03-
05). EDG Degraded Generator Winding Insulation.
c; Conclusions
In general the conduct of maintenance and surveillance activities
observed were good.
M8
Miscellaneous Maintenance Issues (92902)
M8.1
(Closed) IFI 50-327. 328/96-04-13. Weak Freeze Protection Proaram The
freeze protection program was most recently discussed in Inspection
Report 50-327. 328/97-14. dated December 8.-1997.
Since that
inspection. the inspectors have continued to monitor the implementation
of the freeze protection program during the winter of 1997/1998.
No
significant equipment deficiencies have been noted during that period.
The inspectors concluded that the licensee has made significant
improvements to the material . condition of the various heat trace systems
and to the implementation of the freeze protection program.
III. Enaineerina
.El
Conduct of Engineering.(37551)
E1;1.Section XI Testina of Comoonent Coolina System (CCS) Valves
i
a.
Insoection Scooe (61726)
The inspectors reviewed the licensee's program for testing the operation
- and reliability of remotely operated valves in the component cooling
,
system.
l
--_-__
.
.
,
11
b.
Observations and Findinas
The inspectors observed preparations for testing of CCS pump discharge
valves and discussions during the pre-evolution briefing.
Operators
noted that the system crosstie valves had not operated properly in the
past and that the assistant unit operator (AUO) may have to manually
,"
.open the valve off its closed seat and then operate the valve using the
motor operator. When the operators operated CCS crosstie valve 1-FCV-
70-26, the valve would not o)en and required manual operator action.
The licensee initiated a worc request to address the failure.
Further review indicated that this valve. in addition to several others,
were listed in various emergency abnormal procedures and that it would
be necessary to operate these valves in order to mitigate certain plant
conditions or as part of the plant recovery actions.
However, the
inspectors determined that none of the valves were in the licensee's
ASME Section XI testing program.
Further licensee review was being
conducted to determine if the valves were in any other periodic testing
program.
The inspectors ex)anded the review to other CCS system valves and
determined that t1e CCS ~B" train system was designed with both unit 1
and unit 2 "B" train ECCS headers connected in parallel.
The
operational design for the system is such that during an accident the
accident unit would be aligned to the ~B" train supply header and flow
would be increased in the unit's "B" train RHR heat exchanger to greater
than 5000 gpm. The non-accident unit flow would be throttled down to
prevent exceeding the Jump design flow of 7000 gpm.
Opening and closing
of 1-FCV-70-153 and 2
CV-70-153 would be used to meet the design flow
for the accident unit.
However these valves were not in the licensee's
Section XI program for stroking in the " Closed" direction.
CCS containment isolation valves supplying the RCPs lube oil and motor
coolers and containment isolation valves supplying the RCP thermal
barriers automatically close on a containment isolation signal.
In
addition, in many of the emergency procedure recovery actions, the
l
isolation valves are reopened in order to sup)1y cooling to the RCP
j
seals and/or to restart the RCPs.
However, t1ese valves were not in the
'
licensee'sSection XI program for stroking in the "Open" direction.
The inspectors expanded the review and determined that many remotely
operated valves controlled from the safe shutdown panel were not
included in the licensee'sSection XI valve testing program.
Of 63
j
valves reviewed, only 31 were included in the Section XI program and
many of those were stroke time tested in only one direction. Tne
initial review indicated that testing of some of the valves would be
required to meet the Section XI valve testing program.
i
The licensee'sSection XI valve testing program as required by Oma-1988
Part 10 provides the basis for testing of remotely operated valves.
Section 1.1 states that. "The active or passive valves covered are those
.
which are required to perform a specific function in shutting down a
-
_-
_
a
.
12
reactor to cold shutdown condition, in maintaining the cold shutdown
condition, of in mitigating the consequences of an accident."
In
addition.-Section 1.2 provides exclusions to the code such as "(1)
valves used.only for operating convenience such as vent, drain,
instrument, and test valves: valves used only for system control, such
as pressure regulating valves: valves used only for system or component
maintenance."
In addition.10 CFR 50. Appendix B Criterion XI. Test Control, requires
that "a test program shall be established to assure that all testing
required to demonstrate that structures, systems, and components will
perform satisfactorily. in service is identified and performed in
accordance with written test procedures." The inspectors noted that
valves manipulated for contingency actions as directed by the various
levels of emergency procedures and valves manipulated during shutdown of
the plant would be recuired to be tested in accordance with written test
procedures as requirec by 10 CFR 50. Appendix B Criterion XI.
It
appeared to the inspectors that some
tested;however,furtherreviewwill.Qlveswerenotbeingadequately-
,
'
be necessary to resolve this issue.
The potentially inadequate valve testing is being identified as an
unresolved item pending further review. (URI 50-327. 328/98-03-06).
c.
Conclusions
1
The-licensee's valve testing p/ required valve testing.
rogram scope appeared to be too narrow and
may not include all necessary
This issue is
identified as an unresolved item.
E2
Engineertug Support of Facilities and Equipment
E2.1 Corrective Action Procram (405001
a.
Insoection Scooe
The inspectors reviewed corrective actions developed and implemented for
a random sample of Level A and B problem evaluation reports (PERs) for
which Site Engineering had responsibility. These PERs were written for
)lant deficiencies identified from September 1.1996, through
,
l-
r bruary 23, 1998. A total of 9 level A and 154 level B PERs were
e
identified as having been written during this time interval.
Thirteen
'
PERs were selected from this population and the following attributes of
the Corrective Action Program were evaluated:
Determination of licensee's root cause of equipment failure or
problem.
Determination of licensee's extent of condition review performed
for the deficiency.
Timeliness of engineering controls in identifying. rrclving and
implementing corrective actions for the deficiency.
i
. _ _ _ _ _ _ _ _ _ _ _ _ _ _
_ _ _ _ _ _ _ _ _ _ _ _ _ - _ .
-
.
13
Technical adequacy of any plant modifications or temporary
.
alterations developed for resolution of the deficiency.
Technical adequacy of any Justification for continued Operation
.
(JCO).
The above attributes were evaluated for com)liance with the guidance of
Generic Letter (GL) 91-18. Revision 1 and t1e licensee's procedure SSP-
3.4. Corrective Action, Revision 23.
b.
Observations and Findinas
The following PERs were reviewed in order to verify compliance with the
requirements of the Corrective Action Program delineated in procedure
SSP-3.4. Corrective Action. Revision 23:
SO962632PER. Level B. Use of work Orders for implementing
.
temporary alterations.
SO971519PER. Level B. 2-FCV-62-69 failed close resulting in loss
.
of normal letdown.
SO970170PER. Level B. Foxboro 62H controller output inappropriate
.
for given input.
S0970009. Level B. Decrease in reactor thermal power durir
aric
.
acid pump high discharge operation.
SO971204. Level B. Failure of pressurizer safety valves to meet
.
Technical Specification requirements.
SO97]928PER. Level B. Operations procedures do not fully reflect
.
the requirements / restrictions of 0122618.
j
S0970846PER. Level A. Control air containment isolation valve 1-
.
VLV-32-297 third failure of LLRT.
SO972471PER. Level B. Duct work access door for inspection of
.
Damper 2-DMP-313-1784 not sealed.
SO970378PER. Level B. Environmental qualification of flow switches
.
did not consider internal heat rise,
l
SO970423PER. Level B. Diesel engine IA-1 cylinder 8 piston-to-head
.
clearance fou.d outside acceptance criteria.
SO971778PER. Level B. Environmental Qualification Binder
.
Assessment. NA-50-97-36. identified numerous errors with binders.
SO972492PER. Level B. ASME Class Il and III relief valves failed
.
to meet test acceptance criteria.
-
.
14
S0971463. Level B. Recurring and apparently repetitive fan and fan
.
bearing failure / vibration problems.
Procedure SSP-3.4 established requirements for resolving degraded or
non-conforming conditions affecting safety or quality related equipment.
Specific hardware deficiencies have been identified which require the
initiation of a PER.
Root cause analyses are performed for all level
"A" PERs.
Additionally, responsibility has been assigned to the
Management Review Committee (MRC) to identify the need for root cause
analyses for all level "B" PERs, when necessary. Alternatively, an
apparent cause is documented for level B. C and D PERs where sufficient
cause determination information is collected to enable performance
monitoring and trend analysis.
The inspectors performed independent
reviews of the above PERs and verified that root cause analyses were
performed for deficiencies involving equipment degradation documented on
level B PERs.
The extent of condition reviews documented for the listed
deficiencies were sufficiently broad to reasonably identify the primary
root cause along with the contributing root causes.
The developed
corrective action plans were also determined to be adequate to ersure
recurrence control for the listed plant deficiencies.
Operability and
reportability reviews performed for the PERs were acceptable.
PERs for which a) parent causes had been prepared were reviewed in order
to verify that t1e degraded or non-conforming conditions associated with
the equipment had been adecuately resolved.
PERs No. S0970423PER and
SO972492PER documented harcware deficiencies which were resolved using
the assistance of the original ecuipment manufacturer (DEM).
A total of
. six PERs were dispositioned basec on apparent cause analyses.
The
extent of conditions reviews Jerformed for these PERs were determined to
be adequate. Additionally, tie apparent cause analysis and corrective
actions implemented were acceptable with the exception of PER No.
50971928PER.
PER No. SO971928PER was writtein to document a condition in which
operations procedures did not reflect precautions and limitations
specified in design change notice DCN No. 012261B for transferring loads
between 6.9 KV Common Boards A and B.
The precaution specified in the
DCN included load shedding of 2 reactor coolant pumps fed from 6.9 KV
Unit Board 2A and 2C prior to transferring the Common Board loads.
This
precaution was intended to maintain the common station service
transformer (CSST) windings within their respective capacity and
capability ratings and would have precluded the board transfer during
operational modes 1 through 3.
Based on review of past performances of
procedure PM029420000 the licensee determined that common board load
,
transfers had occurred in September of 1996 without complying with the
!
restrictions in the DCN.
l
The licensee performed operability and reportability evaluations for
this event and concluded that the event w6s not re)ortable because CSST
A was fully opera'cle at the time the Common Board 3 loads were
transferred.
The licensee concluded that no loss of functional
,
capability or component degradation resulted from this event and no
-
_
e
15
compensatory actions or alternate functional capabilities were required.
Additionally, immediate corrective actions taken for resolution of this
problem included revising procedure 0-S0-202-2, 6900 Volts Common
Boards.
The licensee also performed an extent of condition review and
identified the electrical equipment within the scope of DCN No. 0122618.
The following electrical equipment was listed:
6.9 KV Shutdown Boards
.
480 Volts Shutdown Boards
e
e
480 Volts RMOV. C&A Vent. Reactor Vent and Diesel Aux. Boards
.
480 Volts AC Transfer Switches
.
480 Volts Preferred Transfer Switches
e
6.9 K. Common Boards
e
480 Volts Boards fed from the Common Boards and the Fire
.
Protection Distribution Panel
The apparent cause documented for this problem was inappropriate use of
a ODCN plant modification which did not raauire impact reviews for
ensuring that plant procedures would have e n revised to incorporate
the precautions and limitations delineated in.che design output
documents. The use of ~0DCNs" to transmit design information was no
longer permitted and procedure SSP-9.3 established requirements for
impact reviews of all design changes to preclude occurrence of this
condition. Additional corrective actions documented in the PER included
the operations staff performing reviews of procedures and caution orders
(COs) to ensure that requirements / restrictions specified in DCN No.
012261B have been adecuately addressed and the procedures and C0s have
been revised as needec. The c apletion date shown for this corrective
I
action was November 14. 1997
Based on review of the PER the inspectors determined that the PER had
been rejected by site OA because of administrative problems identified
with the closure package.
The inspectors discussed this rejection with
,
!
site OA personnel and concurred with their observations that the closure
l
package lacked objective evidence which was required to support closure.
'
t'
Procedure SPP-9.4. 10 CFR 50.59 Evaluations of Changes. Tests and
Experiments, requires that procedures and revision to procedures shall
be evaluated in accordance with screening criteria to determine if a
safety evaluation is required.
If the conclusion of this process
indicates that a safety evaluation is required the safety evaluation
shall be prepared in accordance with the requirements of this procedure.
The inspectors requested TVA management to present objective evidence
which demonstrated that the plant procedures for the electrical
i
-
.
16
equipment listed above had been revised in accordance with procedure
SPP-9.4.
Upon receipi, of this request TVA management stated that this information
was not readily available.
They further stated that this information
would be included in the res)onse to site OA for resolution of the
rejection of the closure paccage.
The inspectors were informed that
j
this response would be available on March 27. 1998.
Based on a lack of
'
objective evidence within the PER which provides reasonable assurance
that: 1) an adequate extent of condition review had been aertormed to
identify plant 3rocedures that required revision and 2) tlat the
procedures had Jeen revised in accordance with the requirements of SPP-
9.4 this item is identified as URI 50-327.328/98-03-10 Revise plant
3rocedures to include precautions and load limitation requirements of
JCN No. 0122618.
1
c.
Conclusions
j
The inspectors concluded that equipment operability problems involving
degradations and non-conformances were being evaluated in accordance
with the guidance of Generic Letter 91-18. Revision 1.
Also,
implementation of the Corrective Action Program was generally in
j
accordance with the requirements of procedure SSP-3.4, Revision 23. and
j
met the regulatory requirements of 10 CFR 50 Appendix B. Criterion XVI.
'
IV. Plant Suonort
R1
Radiological Protection and Chemistry (RP&C) Controls
R1.1 Review of Radiation Protection Procram
a.
Insoection Scone (83750. 84750)
The inspectors reviewed implementation of . selected elements of the
licensee's radiation protection program.
The review included
'
observation of radiological protection activities including personnel
monitoring, radiological postings high radiation area controls, and
l
verification of posted radiation dose rates. contamination controls
within the radiologically controlled area (RCA). and container labeling.
In addition ALARA work planning, pre-job worker briefings. and job
execution observations were performed. The inspectors also reviewed
licensee records of personnel radiation exposure and discussed ALARA
program details, implementation and goals.
Requirements for these areas
were specified in 10 CFR 20 and Technical Specifications.
>
b.
Observations and Findinos
The inspectors toured the health physics facilities, truck ba.)
including the refueling floor, turbine building outside radica I M
material storage areas, and radwaste prc essing area. At the t m of
the inspection housekeeping was observed to be good.
Records reviewed
determined the licensee was tracking and trending personnel
.
o
17
contamination events (PCEs). The licensee had tracked approximately 48
personnel contamination reports (PCRs) for the 1998 fiscal year to date
which included skin and clothing contaminations.
Radiologically
controlled areas including radioactive material storage areas (RMSAs).
High Rad Areas. and Locked High Rad Areas were appro)riately posted and
radioactive material was appropriately stored and la)eled.
The inspectors reviewed operational and administrative controls for
entering the RCA and performing work. These controls included the use
of radiation work permits (RWP3) to be reviewed and understood by
workers prior to entering the RCA. The inspectors reviewed selected
RWPs for adequer
of the radiation protection requirements based on work
scope? locatica and conditions.
For the RWPs reviewed, the inspectors
noted that appropriate protective clothing. and dosimetry were required.
During tours of the plant, the inspectors observed the adherence of
plant workers to the RWP requirements. The inspectors observed personal
dosimetry was being worn in the appropriate location.
The inspectors discussed ALARA goals and annual exposures with licensee
management and determined the organizational structure and
responsibilities for the ALARA staff were clearly defined in
organizational charts.
The inspectors took independent smears to verify contamination control
in the Auxiliary Building Turbine Building, Radwaste processing area,
refueling floor roof, storage areas. and on the refueling floor. Al!
j
smears were counted and determined to be " acceptable." The inspectors
also independently walked posted control boundaries with a survey meter
on the refueling floor, storage areas, and tank storage areas and
determined that the radiation levels were all as stated on the most
recent survey.
The inspectors observed workers properly using friskers at the exit
locations from controlled areas. The inspectors observed workers
properly exiting the protected area through of the exit portal monitors.
l
l
The inspectors reviewed the active " Hot Spot" log as of February 5, 1998
and, at the time of the inspection, there were 49 labeled active hot
'
spots being tracked. The inspectors reviewed the " Hot Spot" removal
efforts -1997.
There were 8 successful campaigns and 2 unsuccessful
campaigns.
The most successful dose reduction was from 460 mrem / hour
contact before to 36 mrem / hour contact after removal efforts.
Two " Hot
Spots" located in the RHR/CS Hx rooms were reduced.during U1 and U2
outages; however, the dose rates returned essentially to pre-outage
levels upon start-up.
The inspectors reviewed the use of contamination containment devices, by
a records (log) review and selectively observed the devices at their
locations during tours of the plant.
At the time of the inspection
there were 62 contamination c u.h &ntainments. The inspectors found
that the earliest catch containment as put in 31 ace in 1995. The
licensee identified the reducti e nf these catc1 containments in
-
.
18
December 1997 as a Manager..1t. Focus area.
However the inspectors were
unable to review an action plan to track or reduce this work list.
The
licensee was informed that this focus area would be tracked as an
Inspector Follow up Item (IFI 50-327. 328/98-03-07). Review an action
plan to track and reduce the number of contaminated catch basins.
The Fiscal Year 1998 site exposure goal was set at 399 person-rem. At
the time of the inspection. the site person-rem was about 148.343
3erson-rem (not TLD corrected).
The inspectors uetermined that there
lad been no positive whole body counts during the U2C8 outage that
required additional assessments.
The U2C8 outage dose was 140 person-
rem which was the lowest dose for a Sequoyah refueling. The dose was 70
person-re"i lower than the previous best outage dose of 212 person-rem.
Individual radiation worker internal and external doses were being
maintained well below regulatory limits and the licensee was continuing
to maintain exposures ALARA.
The calendar year collective dose per unit
has trended downward from a high of about 850 person-rem in 1990 to
about 175 person-rem per unit in 1997.
The inspectors reviewed the Contaminated Square Footage Data and
observed that the licensee has reduced the area from a high in July 1990
of 14% to the present 0.75% on January 28. 1998. The licensee considers
326.522 square feet as the largest possible contaminated area
(denominator).
The 0.75% represents about 2449 square feet.
The inspectors reviewed the fiscal year generation of radwaste for the
period 1991 to 1/24/98. The total generated is shown by the following
table:
Fiscal iear
Cubic Feet Generated
j
1991
55545
1992
58865
1993
27560
'
1994
21586
!
1995
17989
i
1996
17466
1
l
1997
- 8139
l
1998
- 5050 (as of 1/24/98)
Note: * This does not include the excavated contaminated soil and
asphalt generated by the spills of May 19. 1997 (SO971429PER) 5500 cubic
i
feet and January 10,1998 (S0980021PER) 2007 cubic feet.
This reduction of the generation of radwaste demonstrates aggressive
management.
The inspectors reviewed Unit 2 Additional Equipment Building Sump Spill
on January 10. 1998. PER No.50980021PER and the actions taken by the
licensee in response to the identified problen.' The inspect. ors reviewed
the reportability requirements in the Offsite Dose Calculation Manual
(ODCM) Section 1.2.2.1 and Emergency Preparedness Implementing Procedure
_
.
19
Emeroency Plan Classification Matrix (EPIP-1) Section 7.2 Liquid
Effluents and concurred that the spill was not reportable.
The inspectors reviewed PER No. S0980110PER and the actions taken by the
licensee in response to the identified problem.
Late in the inspection
period, the licensee discovered that the computer based survey map
generation system had lost some required data.
One map survey 020598-6
lost both postings and smear survey results.
The inspectors discussed
his concern about the data loss and informed the licenseo that this
problem resolution would be tracked as an Inspection Fellowup Item (IFI
50-327, 328/98-03-08). Review the resolution of the survey mag
generation data loss.
c.
Conclusions
Radiological facility conditions and housekeeping in radioactive waste
storage areas, health 3hysics facilities, auxiliary building and
refueling floor were o] served to be good. Material was labeled
appropriately, and areas were pro
devices were appropriately worn. perly posted.Personnel dosimetry
Radiation work activities were
approariately planned.
Radiation worker doses were being maintained
well 3elow regulatory limits and the licensee was maintaining exposures
Contamination control was effective. Two Inspection Followup
Iteres were identified.
R1.2 Transoortation of Radioactive Materials
a.
Insoection Scooe (86750)
The inspectors evaluated the licensee's transportation of radioactive
. materials program for implementing the revised Department of
Transportation (DOT) and NRC trans)ortation regulations for shipment of
radioactive materials as required )y 10 CFR 71.5 and 49 CFR Parts 100
through 177.
b.
Observations and Findinas
The inspectors reviewed selected precedures and determined that they
adequately addressed the following:
1) assuring that the receiver has a
license to receive the material being shipped: 2) assianing the form.
quantity type, and proper shipping name of the material to oe shipped:
3) classifying waste destined for burial: 4) selecting the type of
package required: 5) assuring that the radiation and contamination
limits were met; and 6) preparing shipping papers.
The inspectors reviewed a sample of shipping papers and receipt surveys.
The inspectors determined that the shipping papers were complete and the
shipping as well as the receipt surveys were complete and met the
requirements.
h
.
20
c.
Conclusions
Based on the above reviews, the inspectors determined that the licensee
had effectively implemented a program for shi) ping and receiving
radioactive materials as required by NRC and X)T regulations.
R1.3 Water Chemistry Controls
a.
Insoection Scooe (84750)
The inspectors reviewed implementation of selected elements of the
licensee's water chemistry control program for monitoring primary and
secondary water quality. The review included examination of program
guidance and implementing procedures and analytical results for selected
chemistry parameters. Annual training for Post Accident Sampling was
observed.
b.
Observations and Findinas
The inspectors reviewed technical soecifications (TSs), which described
,
the operational and surveillance requirements for reactor coolant
activity and chemistry, and Final Safety Analysis Report (FSAR). Section
10.3.5, Water Chemistry. The section indicated that guidelines for
maintaining reactor coolant and feedwater quality were derived from
vendor recommendations and the current revisions of the Electric Power
Research Institute (EPRI) Pressurized Water Reactor (PWR) Primary and
Secondary Water Chemistry Guidelines.
The FSAR also indicated that
detailed operating specifications for the chemistry of those systems
were addressed in the Station Chemistry Section.
L
The inspectors reviewed selected analytical results recorded for Unit 1
I
'
and Unit 2 reactor coolant and secondary samples taken during the
inspection period. The selected parameters reviewed for primary
,
l
chemistry included dissolved oxygen, chloride, fluoride, and sulfate
levels.
The selected parameters reviewed for f.econdary chemistry
included hydrazine, iron, and cop)er levels. Those primary parameters
reviewed were maintained well witlin the relevant TS limits and within
the EPRI guidelines for power operations.
The inspectors reviewed procedure Post-Acci_ dent Samolina and Analysis
(1-TI-CEM-043-066.1 Rev.8) and attended the Radiochemical Laboratory
Analysis Continuing Training Annual Pass Training.
The inspectors
observed the training walk through demonstration of the procedure.
During the performance of the procedural steps the inspectors observed a
work request on the gas chromatograph. The work request (WR C008715)
i
had a 1993 date.
The inspectors inquired as to how the hydrogen
analysis would be performed with the on-line gas chromatograph out-of-
'
service. The licensee responded that a grab sample would be drawn and
i
transported to the chemistry lab for analysis.
The current final Safety
Analysis Report Section 9.5.10.2.2 (Rev. 12) Chemical Analysis System
i
states "The sample taken from the liquid sampling panel (LSP) is routed
j
to the on-line chemical analysis where the following analyses are
<
.
21
>
performed.
1.
Hydrogen concentration using gas chromatography".
No
reference was made to the use of an alternate analysis method. The
licensee provided additional data to support their belief that the
alternate method was acceptable.
These documents include the following:
Technical Specification (TS) Change 94-15. "Postaccident Sampling
.
(PAS) dated April 6.1995
"Living" UFSAR targeted for submittal to the NRC in early March
1998
The inspectors informed the licensee that the acceptability of using the
alternate method of analyzing a post accident hydrogen sample would be
tracked as an Unresolved Item (URI 50-327. 328/98-03-09). Determine the
acceptability of using an alternate method of analyzing post accident
hydrogen samples.
c.
Conclusions
Based on the above reviews it was concluded that the licensee's water
chemistry control program for monitoring primary and secondary water
quality had been implemented, for those parameters rcviewed. in
accordance with the TSs requirements. An Unresolved Item was
identified.
R2
Status of RP&C Facilities and Equipment
R2.1 Meteorolooical Monitorina Eauioment
a.
Insoection Scooe (84750)
Final Safety Analysis Report (FSAR) Rev. 12 Section 2.3.3.2 titled
On-Site Meteoroloaical Measurement Proaram described the operational
and surveillance requirements for the meteorological monitoring
instrumentation,
b.
Observations and Findinos
The inspectors toured the Nuclear Environmental Data Station with
cognizant licensee personnel to determine if the meteorological
instrumentation was operable and that data for wind speed. wind
direction, air temperature, and precipitation were being collected as
described in the FSAR.
The inspectors reviewed records and determined
the licensee had maintained a high level of operability for meteorology
equipment during 1997.
Wind speed and wind direction instruments at
thirty three, one hundred fifty and three hundred feet were operable
approximately 94% for 1997.
For the period 1993-1997 the equipment
availability was approximately 96%. The licensee's operability goal was
90%.
-
.
22
c.
Conclusions
Based on the above reviews and observations, it was concluded that the
meteorological instrumentation had been adequately maintained and that
the meteorological monitoring program had been effectively implemented.
R7
Quality Assurance in Radiation Protection and Chemistry
.
R7.1 Quality Assurance and Self Assessment
a.
Insoection Scoce (83750. 84750. 86750)
Licensee quality assurance activities and self-assessment programs were
reviewed to determine the adequacy of identification and corrective
action programs for deficiencies in the area of Chemistry and Health
Physics.
,
b.
Observations and Findinas
Reviews by the inspectors determined that quality assurance audits and
self-assessment efforts in the areas of chemistry and RP were
accomplished by reviewing chemistry and RP procedures, observing work,
reviewing industry documentation, and performing plant walkdowns to
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indude surveillance of work areas by supervisors and technicians during
'
normal work coverage.
Documeritation of problems by licensee
representatives were included in Quality Assurance Audits and self-
assessment Reports.
Corrective actions were included in the licensee's
Problem Investigative Process.
Closecuts of identified items were
completed in a timely manner.
The inspectors found the nuclear assurance reports insightful, and
detailed.
Identified items were trended and tracked for closecut. A
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selected sample of closeout actions were determined to be timely.
c.
Conclusions
The inspectors determined the licensee was conducting formal RP and
Chemistry audits as required by Technical Specifications and conducting
self-assessments.
The licensee was developing corrective action plans.
trending, and completing corrective actions in a timely manner.
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R8
Miscellaneous RP&C Issues (92904)
R8.1
(Closed) VIO 50-327.50-328/97-06-11: Failure to identify and promptly
correct an adverse condition resulting in the Auxiliary Building
Railroad Bay not being at a slight negative pressure and railroad track
seals not being installed.
The inspectors reviewed the Reply To Notice of Violation closure package
dated August 27. 1997 and independently verified the installation of
door seals.
PER No. SO971642PER closecut actions including the work
_
.
e
23
order 97-008520-000 to grout the door openings and the results of 0-TI-
SXX-000-016.0 were reviewed and found acceptable. This item is closed.
V. Manaoement Meetinas.
XI.
Exit Meeting Summary
The inspectors ) resented the inspection results to members of licensee
management at tie conclusion of the inspection on March 27, 1998. The
radiological control inspection exit was conducted on February 6,1998
and the engineering corrective action review inspection exit was
conducted on March 13, 1998. The licensee acknowledged the findings
presented.
During the inspection period, the inspectors asked the licensee whether
any materials would be considered proprietary.
No proprietary
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information was identified.
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PARTIAL LIST OF PERSONS CONTACTED
Licensee
- Bajestani. M., Site Vice-President
- Burton, .C. . Engineering and Support Systems Manager
- Butterworth. H., Operations Manager
Gates
J., Site Support Manager
- Freeman
E. Maintenance and Modifications Manager
Herron, J. . Plant Manager
- Kent, C., Radcon/ Chemistry Manager
- Koehl'. D. Assistant Plant Manager
O'Brien. B. , Maintenance Manager
.
- Salas. P.
Manager of Licensing and Industry Affairs
- Valente J. . Engineering-& Materials Manager
- Attended exit interview
INSPECTION PROCEDURES USED
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IP 37551: Onsite Engineering
E
IP 61726:
Surveillance Observations
!:
IP 62707: ' Maintenance Observations
IP 71707: Plant Operations-
IP 83750: Occupational Radiation Exposure
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IP 84750:
Radioactive Waste Treatment and Effluent and Environmental
-
Monitoring-
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IP 86750:
Solid Radioactive Waste Management and Transportation Of
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Radioactive Materials
IP 92901: . Followup.- Operations
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-IP 92902: Followup - Maintenance
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-IP 92903: Followup - Engineering
'
'IP 92904: Followup - Plant Support
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ITEMS OPENED AND CLOSED
Ooened
Ty.p.e item Number
-Status
Descriotion and Reference
_
50-327/98-03-01
Open
Potential Failure to Enter TS 3.11.2.5 LCO
Action Statement When Samples Indicated
High Concentrations of Oxygen in the PRT
(Section 01.4).
.
50-327/98-03-02
Open-
Failure of Site Personnel to Initiate a
PER After Analysis of the PRT Sample
)
Indicated a High Oxygen Concentration
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(Section 01.4).
>
.
.
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URI 50-327, 328/98-03-03
Open
Potential Failure to Meet UFSAR
{
Requirements. Failure to Revise the
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UFSAR. Inappropriately Closing a
Modification Package, and not
Establishing a Periodic Sampling
Program for the Waste Gas Collection
)
System (Section 01.4).
'
IFI 50-327/98-03-04
Open
Follow Licensee's Review of the
Section XI Valve Testing Procedure
to Determine if a Better Method
would be Available to Test the CCS
Pump Discharge Check Valves
(Section M1.1).
IFI 50-327/98-03-05
Open
Follow Licensee's Review of EDG
Degraded Winding Insulation (Section
M1.1).
URI 50-327,328/98-03-06
Open
Potential Inadequate Section XI
Valve Stroke Testing (Section E1.1).
IFI 50-327,328/98-03-07
Open
Review an Action Plan to Track and
Reduce the Number of Contaminated
!
Catch Basins (Section R1.1).
IFI
50-327,328/98-03-08
Open
Review the Resolution of the Survey
Map Generation Data Loss (Section
R1.1).
50-327.328/98-03-09
Open
Determine the Acceptability of Using
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an Alternate Method of Analyzing
Post Accident Hydrogen Samples
(Section R1.3).
50-327.328/98-03-10
Open
Revise procedures to include
precautions & load limit
requirements of DCN 012261B (Section
E2.1).
Closed
Tvoe Item Number
Status
Descriotion and Reference
50-327/EA 97-232
01013
Closed
Failure to Identify and Take
Corrective Actions for Loss of RCS
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Inventory Control While Draining
Pressurizer (Section 08.1).
,
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.
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50-327/EA 97-232
01023
Closed
Failure to Properly Log a Unit 1 RCS
Drain Down Evolution (Section 08.1).
-VIO
50-327, 328/EA 97-409
Closed
Failure to Maintain Operable DC
01013
Vital Battery Channels (Section
08.2).
50-327, 328/EA 97-409
Closed
Failure to Follow Procedures
01023
While Aligning a Spare Vital Battery
(Section 08.2).
50-327, 328/EA 97-409
Closed
Failure to Include Independent
01033
Verification Per Procedure While
Aligning Vital Batteries (Section
08.2).
LER
50-327. 328/97011/Rev 0 Closed
Operation of Vital Battery Board # 4
Without a Battery Source (Section
08.3).
LER
50-327, 328/97011/Rev 1 Closed
Operation of Vital Battery Board # 4
Without a Battery Source (Section
08.3).
IFI
50-327. 328/96-04-13
Closed
Weak Freeze Protection Program
(Section M8.1).
50-327. 328/97-06-11
Closed
Failure to Identify and Promptly
Correct an Adverse Condition
Resulting in the Auxiliary Building
Railroad Bay not Being at a Slight
Negative Pressure and Railroad Track
Seals n01. Being Installeo
(Section R8.1).
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