ML20235V048
| ML20235V048 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 09/28/1987 |
| From: | Jenison K, Mccoy F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20235V045 | List: |
| References | |
| 50-327-87-50, 50-328-87-50, NUDOCS 8710140514 | |
| Download: ML20235V048 (37) | |
See also: IR 05000327/1987050
Text
UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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REGION il
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101 MARIETTA STREET.N W.
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ATLANTA GEORGIA 30323
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Report Nos.:
50-327/87-50, 50-328/87-50
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, 1987 thru August 5, 1987
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Inspector:[K. M~ Jenison, Senior /Esigni Irispector
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Date' Signed
Accompanying Personnel:
P. E. Harmon, Resident Inspector
D. P. Loveless, Resident Inspector
W. K. Poertner
esident Inspector
W.
anch S uoyah Restart Coordinator
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Approved by.
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F. R. McCoy, Chief, Projtetf Section 1
{Vate />igne'd
Division of TVA 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
inspection findings; review of licensee identified items; review of inspector
follow-up items; Surveillance Instruction Review Program, Restart Testing
Program; and review of 1984 Thimble Tube Ejection Event.
Results:
Three unresolved items were identified:
327,328/87-50-01, Control of systems required for mode 5 operation,
paragraph 11.b.
327,328/87-50-02, Adequacy of the long term surveillance instruction
program, paragraph 11.b.
327,328/87-50-03, Preoperational testing of the containment spray pumps
and the ice condenser doors, paragraph 13.
8710140514 870929
ADDCK 05000327
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> REPORT DETAILS
1.,
Licensee Employees Contacted
H. L. Abercrombie,. Site Director
.*J. T.tLa Point, Deputy Site Director
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- L. M. Nobles, Plant Manager
8. M. Willis, Operations and Engineering Superintendent
8. M. Patterson,' Maintenance Superintendent
R.'J. Prince, Radiological-Control Superintendent
H. R. Harding, Licensing-Group Manager
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L. E. Martin, Site Quality Manager
D. W. Wilson, Proje::t Engineer
R.=W; Olson, Modifications Branch Manager
J. M.- Anthony, Operations Group Supervisor.
R. V. Pierce, Mechanical Maintenance Supervisor
,M. A. Scarzinski, Electrical Maintenance Supervisor
H. D. Elkins,LInstrument Maintenance Group Manager
E R. W. Fortenberry,.-Technical Support Supervisor
- G. 8. Kirk,. Compliance Supervisor
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0. C. Craven,-Quality Assurance Staff Supervisor
"J. H. Sullivan, Regulatory Engineering Supervisor-
J. L. Hamilton, Quality Engineering Manager
D. L Cowart, Quality Engineering Supervisor
.H. R. Rogers, Plant Operations Review Staff
- R. H. Buchholz, Sequoyah Site Representative-
M..A.. Cooper, Compliance Licensing Engineer
- R. P. Denise, Manager SI Review Program-
Other . licensee employees contacted included technicians, operators, shift
engineers, security force members, engineers and maintenance personnel.
- Attended exit interview
2.-
Exit Interview
The inspection scope and findings were summarized with the Plant Manager
and members of his' staff on August 5, 1987.
The licensee acknowledged the
inspection findings and did not identify as proprietary any of the
material reviewed by the ' inspectors during this < nspection.
During the
reporting period, frequent' discussions were held with the Site Director,
Plant Manager and other managers concerning inspection findings.
3.
Licensee Action on Previous Inspection Findings (92702)
(Closed) Unresolved Item (URI) 327,328/87-02-03, use of WR to Perform
Modifications to Control Room Drip Pans.
The inspector reviewed issues
related to the control building roof leaks identified in inspection report
87-08.
During this inspection all items were considered closed with the
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exception of' satisfactory completion of roof repairs.
The' inspector
reviewed Maintenance Instruction SMI-0-400-3, Removal and Replacement of
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Control- Building Roof Sealant.
Re-roofing was applied and completed on
June 5,1987 per this- procedure and WR B222858.
Security aspects of this
modification are discussed briefly in paragraph Sb of this report.
This
. item is closed.
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(Closed) URI 327,328/86-32-07, Functional Test of Chlorine Monitor.
This
item is- closed i by issuance of VIO 327,328/87-36-01 for failure to
adequately test the Chlorine Monitor.
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4;
Unresolved Items
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Unresolved. items are matters about which more information is required to
determine whether they are acceptable or may' involve violations or
deviations.
Three_ unresolved items - were -identified during this
inspection, and are~1dentified.in paragraphs 11 and 13.
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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 (LCO).
The inspectors verified that
maintenance work _ orders had been submitted as required and that
- follow-up activities and prioritization of work was accomplished by
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the licensee.
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Tours of the diesel- generator, auxiliary, control, and turbine
buildings, and containment were conducted to observe plant equipment
conditions, including potential fire hazards, fluid leaks, and
excessive vibrations and plant housekeeping / cleanliness conditions.
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
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of various shifts of the security force was observed in the conduct
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of daily activities including protected and vital area access
controls; searching of personnel and packages; badge issuance and
retrieval; patrols and compensatory posts; and escorting of visitors.
In addition, the inspectors observed protected area lighting,
protected and vital areas barrier integrity.
The inspectors verified
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an interface. between the security organization and operations or
maintenance.
Specifically,. the resident inspectors - observed
emergency drills; . responded to fires, inspected security during out-
ages, reviewed licensee security event reports /offsite communication
verified protection
of safeguards.information, and verified onsite
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capabilities.
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' The -inspector observed work being performed under.WR B222858 on the -
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control building . roof.
This maintenance work required moving the
protected area back to open the control building roof.
The security.
plan for Sequoyah was- temporarily updated to include provisions for
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this work.
The: inspector verified- that temporary fences, alarms,
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cameras, lighting and compensatory posts were all in place.
The
inspector observed portions of the return to service of the original
fence and lighting = systems. 'The inspector had no further. questions.
No violations or. deviations were identified.
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Radiation Protection
The inspectors observed health physics (HP)' practices and verified
implementation of radiation protection control.
On a regular basis,
radiation work ipermits - (RWPs) were reviewed and specific work-
. activities were monitored to ensure the activities were being
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conducted inj accordance' with applicable RWPs.
Selected radiation
protection instruments were verified operable and calibration
frequencies were' reviewed.
No violations or deviations were identified.
' 6.
Monthly Surveillance Observations-(61726)
The inspectors observed / reviewed' TS recuired surveillance testing and
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verified that testing was performed ' n accordance with adequate
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procedures; that test instrumentation was calibrated; that LCOs were met;
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that test. results met acceptance criteria requirements and were reviewed
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by personnel other than the individual directing the test; that
deficiencies were identified, as appropriate, and that any deficiencies
identified during the testing were properly reviewed and resolved by
management personnel; and that system restoration was adequate.
For
complete tests, the . inspector verified that testing frequencies were met
and tests were performed by qualified individuals.
The inspector witnessed a performance of Surveillance Instruction (SI)-40,
Centrifugal- Charging Pump.
The purpose of this SI is to perform the TS
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required ASME section XI testing of the pumps.
The inspector noted that
the.TSs required that the charging pumps be tested on recirculation flow
only and that SI-40 as presently written tests the pumps while they are
providing charging and seal injection flow.
Discussions with the
mechanical test section determined that SI-40 is presently under revision
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to test the pumps on recirculation flow only and-that the SI will be
performed with the required ' lineup prior to unit startup.
The inspector
does not: consider that the SI as' presently being performed calls into
question the-operability of the charging pumps based on the fact that the
system flow resistance has been. reduced and the pump discharge pressure is
still required to be above the value required by_the TSs. .It would. appear:
that the present method of testing the pumps is a better indicator of pump
performance than just testing on recirculation flow.
The inspector noted
no discrepancies during the actual performance of-the SI.
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7. .
Monthly Maintenance.0bservaticas (62703)
Station 1 maintenance activities of safety-related systems and components
were . observed / reviewed during special maintenance inspection 327,
328/87-37.
8.
Licensee Event. Report (LER) Follow-up (92700)
LERs reviewed during this inspection are identified in paragraph 11 of
this report.
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- 9.
Inspector Follow-tip Items
Inspector. Follow-up Items. (IFIs) are matters of concern to'the inspector
which 'are documented and tracked in inspection reports to allow further
review: and evaluation by the inspector.
The following IFIs have .been
reviewed and . evaluated by the inspector.
The inspector has either
resolved the concern identified, determined that the ifcensee has
. performed adequately in the area, and/or determined that . actions taken by
the licensee have resolved'the concern.
(Closed) IFI 327,328/86-60-08, Qualification and Certification of Sequoyah
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Quality Control (QC) Inspectors. The inspector reviewed a selected number
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of QC department inspector certification folders. The folders reviewed
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contained the proper certification documents for each inspector with only
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one minor clerical error. A review was conducted of the QC site
certification matrix which is the working document used to select
inspectors for specific jobs. A comparison was made between the
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certification documents in the folders and the site certification matrix.
Several discrepancies were found which prompted -the QC department to
undertake a 100% reverification of the matrix against the certification
folders. One additional discrepancy was found during this reverification.
L An investigation revealed that none of the. discrepancies resulted in QC
inspectors working on jobs they were not certified to inspect. This item
is closed.
10.
10 CFR Part 21 Reports
(Closed) P2184-05,ITE-27N Undervoltage Relays.
ITE-27N undervoltage
relays are utilized on the shutdown boards for degraded voltage
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protection. In October of 1984 the licensee replaced resistor R-11 with a
200 kilo-ohm resistor to correct the design deficiency identified with the
ITE-27N undervoltage relays.
The inspector reviewed the maintenance
request forms associated with the modification and verified that the work
was completed.
This item is closed.
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(Closed) P2184-01,A Control Panel . Bracket Support welded to the diesel
lube oil cooler has developed cracks in the weld and resulted in a small
lobe oil cooler leak.
The inspector verified that_ the control panel
support had been modified such that it was no longer welded to the diesel
generator lube oil cooler.
This item is closed.
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11.
Surveillance Instruction Program (61700, 61726)
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The licensee's submittal of March 24,1987 (Gridley/Ebneter), described
the Sequoyah surveillance instruction review and revision program.
The
intent of this program, as described in this document, was to ensure all
TS requirements were addressed and that sis and their supporting
instructions, covered by the program scope, were technically adequate to
fulfill the surveillance requirements of the Sequoyah TS.
An NRC
inspection (327,328/87-36) was conducted during the period of May 26
through June 5, 1987.
Four areas requiring additional inspection and one
unresolved item (URI 327,328/87-36-02) were identified.
URI 327,
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328/87-36-02 was not formally addressed by the licensee at the time this
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inspection took place, and will therefore remain an open startup item. The
four areas reviewed were as follows:
a.
Part II to Appendix F checklist of SI-1, Surveillance Program
Administrative Adequacy
The licensee stated in its submittal that "Part II of the checklist
is not being completed for this program".
This implied that Part II
to Appendix F would not be completed prior to the startup of Sequoyah
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Unit 2.
The licensee explained that certain items in Part II are
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from upper-tier documents and are checked to ensure necessary
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compliance.
Exception was taken by the NRC to this portion of the SI review
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program and the licensee was asked to re-evaluate whether or not one
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or all of the five most likely examples (listed below) would affect
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the technical adequacy of surveillance performance.
The five
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examples which most likely would affect the technical adequacy of
surveillance performance were:
consideration of common mode failure possibilities (Part II,
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requirement for SRO approval to perform the SI (Part II,
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Item 6)
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verification of impact on redundant loops (Part II, Item 7)
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verification of performance consistency (Part II, Item 18)
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requirements for independent verification (Part II, Item 21)
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During a review of this issue in inspection report 327,328/87-36 it
was determined that two licensee organizations (Quality Assurance and
the Surveillance Instruction Validation / Verification group) had also
identified the same issue.
The implementation of a licensee review
and corrective action, if required, were deferred to this inspection
from inspection 327,328/87-36.
The inspectors reviewed the licensee's evaluation of this issue which
was provided in memos (R. Densie/L Nobles) dated July 25 and 30,
1987.
The licensee's evaluation referenced a joint memo written
between the SI program manager and the site QA manager and concluded
that the SI-1 Appendix F Part II Items 1, 6, 7,18, and 21 were
adequately addressed. The licensee conducted a review of its IRG and
SIVV group findings and determined that of 105 instructions reviewed
for Items 1, 6, 7,18, and 21,18 procedures had negative findings.
The licensee determined that the identification of 18 individual
procedures that had concerns in this area did not constitute a
generic problem and that "the SI program has clear written guidance
to include - basic administrative requirements in the production of
sis, and the fact that we did not use the SI-1 Appendix F Part II
checklist to implement the program is inconsequential." The position
was further supported by an indepth review conducted by the licensee
which yielded only 5 of 111 surveillance procedures having
administrative procedures which had the " Potential" of being impacted
by one of the five administrative items.
The inspector reviewed this
evaluation and the particular procedures and could identify no sis
which would positively have been affected by one of the above stated
administrative issues.
In addition, the inspectors conducted indepth technical reviews of
the following sis in order to determine if the instruction was able
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to perform its technical intent as written; whether the instruction
fulfilled the requirement of the surveillance requirement for which
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credit was taken by the licensee; and whether any SI-1, Appendix F
Part II issues affected the technical adequacy of the sis.
SI-256, Periodic Calibration of Overcurrent and Ground Fault
Relays on RCPs and Backup Devices on 6.9kV Unit Boards, Units 1
and 2, Revision 9, June 2,1987. The inspector reviewed this SI
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and found it to be adequate. However, the inspector nc;ed the
wordings in section 6.2 of the SI, stated that "The activities
within each data package need not be performed in the sequence
specified by this procedure" could contribute to different ways
of performing the SI by different individuals.
The inspector
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discussed this' interpretation with the licensee, who stated that
the wording will be rephrased in a more stringent manner during
the.long-term surveillance instruction program.
SI-257, Periodic Functional of RCP Protective Devices, Units 1 -
and 2, Revision 11, June 2,:1987.
The inspector reviewed this
SI and found of t to be adequate. However, in Section 6.2 of the
SI, a. statement allows performance of the procedure in any
sequence. The inspector discussed this interpretation with the
licencee, 'who stated that the wording will be rephrased in a
more stringent manner during the long term surveillance instruc-
tion program.
SI-266.1.1, 60-Month Inspection of ITE'7.5HK-500 6900V Breakers,
Unit 1.and Common, Revision 2, June 3,1987. The inspector
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considered this: SI to be adequate.
The insp'ector noted that
section 6.26 of the SI addressed a numeral
1000" without any
units or definitions associated with it.
The inspector noted
the appropriate unit would be " number of trips".
The inspector
also noted that the SI has a statement that allows out of'
sequence performance of the steps in the SI.
The inspector-
considered this would allow the SI to be performed in a dif-
ferent manner or sequence and may produce different' results.
The inspector -also noted the SI is very brief. (e.g. Section
6.7), and not clear (e.g. section 6.22). and the figures are not
clear -or legible.
The licensee- stated that the electricians
performing this SI are trained to read and use it correctly and
that they. have vendor references 'available from vendor manual
control.
The inspector requested a copy of the vendor manual,
and noted that the figures are indeed better illustrations.
The
inspector discussed the ~SI with the SI review program manager
and stated that if any document was worth' placing in the proce-
dure it was worth being legible.
The SI review program manager
agreed.
SI-7.3, Diesel Generator Fuel Oil Transfer Pump Performance
Test, Unit 0,
Revision 1,
June 2,
1987.
The inspector
considered the SI to be adequate. However, the inspector noted
the SI does not address common-mode failure nor does it make
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reference to electrical maintenance section instruction letter
EMSL-A36. The licencee stated that they have instruments
designated for use on each train, and they will incorporate
EMSL-A36 into the SI. The inspector also noted that TS 4.0.5
required the SI to be performed in conformance with ASME
guidelines which stipulated a monthly test schedule. However,
the NRC has agreed in a letter (Novak/Parris) dated April 5,
1985, to a quarterly test schedule. The inspector noted that
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this NRC letter is not made a reference in the SI.
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SI-275.1, Testing of Non-Clase IE Load Circuit Breakers Fed from
Class IE Buses, Units 0,1, Revision 8, April 23,1987.
The
inspector considered this SI adequate. However, the inspector
noted that this SI also allows out-of-sequence performance of.
the procedure. This SI is short, and has one prime objective,
which is to infect a current of 300% to verify that the breaker
would trip within a certain ' time range.
Further, this short
test would normally be administered to about 30 different
circuit breakers whenever the SI is performed. In view of this,
the inspector considered such wordings inappropriate for the SI.
SI-275.2, Testing of Non-Class 1E Load Circuit Breakers Fed from
Class IE Buses, Units 0, 2, Revision 12, April 23,1987.
The
inspector considered this SI adequate, and the comments for this
SI are identical to those for SI-275.1 above.
SI-102 EM, Diesel Generator Monthly Electrical Inspections,
Units 1, 2, Revision 4, . April 21,1987.
This SI was determined
to be technically adequate.
This SI also was determined to be
administrative 1y adequate with regard to Review Checklist items
II.1,6,7,18 and 21.
SI-93,
Reactor Trip Instrumentation Functional Tests,
Conditional 7-Days, (Prior to Startup), Units 1 and 2,
Revision 10, May 1,
1987.
This SI was determined to be
technically adequate.
This SI also, was determined to be
administrative 1y adequate with regard to the Review Checklist
Items II.1,6,7,18,and 21.
5I-153.4, Test Requirements for the Electric Hydrogen Recombiner
System, Unit 2, Revision 2, May 11,1987.
The inspector con-
sidered the SI to be adequate. However, with regard to common
mode failure, the procedure only made reference to EMSL-A36.
SI-92, Remote Shutdown Monitoring Instrumentation Pressurizer
Pressure Channel Calibrations, Refuel Outage, Units 1 and 2,
Revision 12, April 8,
1987.
This SI was determined to be
technically adequate.
This SI was also determined to be admin-
istratively adequate with regard to Review Checklist Items
II.1,6,7,18, and 21.
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SI-109, Channel Calibration for RHR Flow Rate for Remote Shut-
down Monitoring, Refueling Outage, Units 1 and 2, Revision 9,
May 2, 1987.
This SI was determined to be technically adequate.
This SI was also determined to be administrative 1y adequate with
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regard to Review Checklist Items II.1,6,7,18, and 21.
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SI-247.701, Reponse Time Test of the Turbine-Driven Auxiliary
Feedwater Pump, (Refueling Outage), Units 1 and 2, Revision 4,
June 25, 1987.
This SI was determined to be technically
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adequate.
This SI was also determined to be administrative 1y
adequate with regard to Review Checklist Items 11.1,6,7,18, and
21.
SI-118,
Motor-Driven Auxiliary Feedwater Pump and Valve Auto-
matic Actuation,
Units 1 and 2, Revision 16, June 19,1987.
This SI was determined to be technically adequate.
This SI was
also determined to be administrative 1y adequate with regard to
the Review Checklist Items II.1,6,7,18, and 21.
SI-118.1, Turbine-Driven Auxiliary Feedwater Pump and Valve
Automatic Actuation, Units 1 and 2, Revision 16, June 19,1987.
This SI was determined to' be technically adequate.
This SI was
also determined to be administrative 1y adequate with regard to
Review checklist Items II.1,6,7,18, and 21.
b.
Surveillance Instruction Performance Observation
The following instructions were reviewed and observed during
performance in the field.
The procedures that were performed by the
licensee were previously licensee validated /or to be validated PORC
approved documents.
SI-24. A, Control Room Air Cleanup Subsystem (Train A).
The
inspector observed the performance of this procedure on July 28,
1987.
This instruction implemented the requirements of TS
surveillance requirement (SR) 4.7.7.b.
Step 5.1 of the
procedure requires the performer to verify the system lineup
prior to starting the fan.
This step was performed by verifying
damper position from the Control Room or utilizing the status
file and the configuration logs.
The inspector determined that
the use of these logs was appropriate.
Operations Section
Letter Administrative (OSLA)-58, Maintaining Cognizance of
Operational Status, requires that systems needed for the mode of
operation be maintained in accordance with the system operating
instruction (501) unless otherwise configured in the status log.
This SI appears to be adequate to meet the surveillance
requirement.
SI-38, Shutdown Margin, Units 1 and 2.
On July 26, 1987, the
inspector observed the performance of this procedure and
reviewed the results.
The instruction was found to meet the
requirements of SR 4.1.1.2.a and SR 4.1.1.2.b for current mode 5
performances.
The inspector questioned the Nuclear Engineer
about the Xenon contribution calculations.
The method used for
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this performance only addressed Xenon content following steady
state operations.
A further review showed that Technical
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Instruction (TI)-22, Shutdown Margin Calculation - Units 1 and
2, (one of the procedures utilized by the SI) gives additional
methods of calculating Xenon worth which includes appropriate
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methods for transient operations.
This SI was not reviewed for.-
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modes 1 through 4 uses.
The inspector'had no further questions.
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_ SI-175, . Low Pressur'e CO
System - Level and. Pressure.
The
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inspector reviewed this procedure to determine that it met the
requirements of SR. 4.7.11.3.2.a.-
On July 28, 1987, the inspec-
- tor observed a performance of this instruction.
This procedure
appeared to be adequate.
SI-180, Fire Pump Start Test.
The inspector observed a perfor-
mance of this procedure conducted on July 29,1987.' -The SI
appeared to be adequate and no. discrepancies were noted.
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SI-90.72, Quarterly Functional Test of Reactor Trip /ESF Instru-
mentation, Rack 12 - Unit 2.
The inspector observed portions of
this instruction on July 28, 1987.
The instruction being
performed was Instrument Maintenance Instruction (IMI)-99 FT
9.1, "Online/Offline", Functional Test of Steam Pressure Devia-
tion Channel. IV, Rack 12 (loops P-516 and P 546) - Units 1 & 2.
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This- instruction
implemented. the requirements of SR- 4.3.2.1.1.C.I.e, SR 4.3.2.1.1'.C.1.f and SR 4.3.2.1.1.C.4.d.
The
inspector questioned the. knowledge of the technicians on the
accuracies of the M&TE being.used.'
This will be followed in
future inspections.
The inspector observed testing up to step
5.15. in which 'the. pressure test point number was determined by .
the licensee to be incorrect.
The test was halted until it
could be corrected.
The inspector had no further questions.
SI-194, Periodic Calibration of Ice Condenser System.
The
inspector ' observed portions of this. instruction July 301987.
The SI appeared to be adequate and no discrepancies were noted.
SI-51, Weekly Chemistry Requirements. The inspector observed
portions of this instruction on July 30,1987.
The SI appeared
to'be adequate and no discrepancies were noted.
SI-128, Emergency Core-Cooling System Residual Heat Removal
Pumps.
The inspector observed a performance of this SI
conducted on July 31, 1987, on RHR pump 2A-A.
During the
performance of the SI the pump flow rate exceeded the acceptance
criteria as specified in the SI.
Investigation determined that
valve HCV-74-36 was in the open position which 'resulted in the
2A-A pump being cross connected with the 2B-8 pump which was
being used for shutdown cooling.
Valve HCV-74-36 was closed and
the surveillance was successfully accomplished.
Discussion with
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the ASE determined that valve HCV-74-36 was not returned to its
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' required position after the completion of maintenance activi-
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Review of the. circumstances that' resulted in valve HCV-74-36
being open and control of other systems required for mode 5 will
be identified as unresolved item 327, 328/87-50-01.
'
51-83, Channel Calibration for Radiation Monitoring.
The
inspector observed portions of this surveillance conducted on
July 29,1987.
During the performance of step 5.3 the Unit 1
Assistant Shift Engineer stopped personnel from performing the
procedure.
Radiation monitor 0-RM-90-101-0 was being cali-
brated.
Section 1 states that this monitor does not have any
TS requirements, so when the procedure was started an entrance
into an LC0 was not considered.
Step 5.3.7.2 requires the
monitor pump to be shutoff.
The pump circulates air through
monitors RM-90-101-A,B, and C.
Since RM-90-101-B is a TS
related monitor in the auxiliary building ventilation system, an
LCO (TS 3.3.3.10.b) was entered when the pump was shut off
without the knowledge of the operators or the technicians
performing the surveillance.
The licensee did however realize
the situation and took the appropriate action within the TS LCO
limits.
Additionally, a change was mde to the surveillance
instruction to reflect the common mode failure of the three
radiation monitors and the related TS requirement.
This is an
example of an SI-1, Appendix F, Attachment II, item 1 (common
mode) which must be addressed by the licensee in its long term
program and will be followed by URI 327,328/87-50-02,
c.
Inspector Follow-up Items and Licensee Event Reports
Open items are matters of concern to an inspector which are
documented and tracked in inspection reports to allow further review
<
and evaluation by inspectors.
The following open items were reviewed
and evaluated by the inspector in inspection report 327,328/87-36 and
determined to need additional action in order to be closed.
A brief
description of the current status of these items is provided below:
)
(Closed) URI 327,328/86-32-04, Pump performance data sheets from
SI-45.1 and SI-46 indicated a common practice of lining-out and
j
initialing original data, then recording new data without documenting
1
why the changes were made.
The licensee has issued Administrative
i
Instruction AI-47 Rev. O, Conduct of Testing. This procedure provides
{
adequate control for recording and documenting test changes.
This
i
URI is considered closed.
(0 pen) IFI 327, 328/86-32-12, Scaling data sheets in TI 41-68 contain
several scaling factor errors. Corrections to TI 41-68 have been made
1
and the revised procedure is being reviewed. Pending an approved
revision of TI 41-68 this item will remain open. Corrective action
j
must be complete prior to restart of both Units 1 and 2.
1
l
(Closed) URI 327, 328/86-32-07, Functional testing of Chlorine
Detection System requires that the alarm / trip function be tested as
,
,
part of the functional channel test.
Inspection Report 327,328/87-36
!
'
determined this item to be a violation.
URI 327,328/86-32-07 is
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_ _ _ _ _ _ _ _ _
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12
' closed, the licensee'si cwrective actions will be followed in '
Violation 327,328/87-36-01.-
_ (Closed) IFI 327,328/86-49-02, The licensee identified during a
review of an internal tracking system, that TS surveillance 4.7.9.e.3
and 4.7.9.f may not'have been complied with during the' implementation"g
- of SI-162.2. LA review of the licensee's actions indicates a thrbugh
review was made concerning the implementation. of SI-162.2. !The ,
W
results of their review indicates. that personnel error occurred
,
during calculations of snubber drag forces. The licensee revised the
procedure to clarify' the method for performing calculations.
Revision 6 of SI-162.2 which was approved on June 5, 1987, appears to
1
<
meet the funttional testing requirements for safety-related snubbers.
This IFI is considered closed.
-
I{
(Closed) Violation 327/06-20-08, Approxinstely 20 vent, drain and ,
test containment isolation valves were not verified to be in'their
proper position when SI-14, Verification of Containment lategrity,
was performed on. Hay 20, 1985. Revi m of the licensee's corrective
!q
action indicated all valves were' incorporated in either 51-14.1 or.
SI-14.2, except for 70-763.
1. d
,
Subsequently, the licensee has determined that the position of valve
70-763 does not require position verification because it.is a back-up
valve to 70-M6.
Violation 327,328/86-20-08 ie considered closed.
>
One additior,a1 IFI 'was reviewed which was not~ previously reviewed'in
. inspection report 327,328/87-36:
(Closed)'IFI. 327, 328/85-45-13,: Review implementation of DEP47 with
respect to tinely review of Watts 8ar' NCRs at Sequoyah.
The licensee
handles this issue through the implementation of AI-12, Rev.1,
Corrective Action. This instruction requiles items which may have a
potential affect on operability or have significant 4 pact on
conditions that affect quality be immediately transmitted to other
affected sites.
This procedure appears to' provide adequate control
to ensure timely dissemination of generic issues.
This IFI is
r,
closed.
The following licensee event reports (LERs) vera reviewed and closed.
The inspector verified that: reporting requirements had been met;
causes had been identified; corrective actinqs , appeared appropriate;
generic applicability had been considered; the LER forms were
complete; the licensee had reviewed the event; no unreviewed safety
I
questions were involved; and no new violations or deviations of
regulations or TS conditions were identified.
'
LERs Unit 1
i,87-005
Inadvertent Reactor Trip Breaker Opening Due To Personnel
l
Error During Performance Of A Post Maintenance Response
i
Time Test.
The maintenance technician was counseled on the
importance of correctly reading and following procedures to
i(
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13
1
prevent recurrence of simtiar events.
Maintenance craft
personnel received training on the details of this LER.
l-
This issue is closed.87-007
Deficient Procedures Fail To Include Response Time Testing
,0f A Small Portion Of Several Radiation Monitor Channels.
Tne licensee has updated the procedures to include response
time testing as specified in the TS. This issue is closed.87-008
Essential Raw Cooling Water Surveillance Requirement Not
Met As A Result Of A Surveillance Instruction Being
Inadequate Due To Personnel Error.
The licensee took
corrective action to ensure the eight manual isolation
e
valves 'were in their normal positions. In addition, SI-33
was revised to include the eight manual isolation valves
which should prevent recurrence of this issue.
This item
1
is closed.87-009
Ice Condenser pH Surveillance Requirement Not Met Due To
Plant Personnel Not Following Procedure.
The licensee
corrected procedure TI-11, which had conflicting sample
'
temperature values with the values specified in SI-58.
The
value was adjusted to 20 degrees C.
Both procedures-
conform to the specified value in the TS.
This item is
closed.
,,
e
87-014
BIT Heater Not Verit'ied Operable Every 31 Days Due To
Procedure InadequacyJ
The licensee revised SI-16 to
include the requirement to verify BIT Heater operability.
This item is closed.87-017
Surveillance Instruction Review Which Identified A
Potential Failure To Meet Minimum Boron Concentration Due
To Analytical Technique.
The licensee revised TI-11 and
7I-16 to retiect correct analytical technique.
This item
it' clued.
LERs Unit 2
87-006
Inadequate Determination Of The Heat Flux Hot Channel
i
Factor By The Incore Computer Program Due To Personnel
!
Error.
The licensee corrected the computer program anu
established the requirement for double verification of
changes to core monitoring computer programs.
This item is
closed.
In addition, the following Unit 1 LERs were reviewed in Inspection
Report 327, 328/87-36 and found to require additional licensee
corrective action.
A status and a brief discussion of these LERs is
addressed'below:
___
-.
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_ - _ _ _ _ _ _
_ _ - _ _ _ _
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.
14
86-020
Failure To Perform A Quarterly Functional Test per TS.
SI-244.2 Rev. 7 does not contain a channel functional check.
for-radiation monitor relay F-15-43.
SI-244 also does not
contain a check for F-15-43 although the LER states that
the SI for unit I should be correct.
The licensee has
revised these procedures to include a functional check for
This LER is considered closed.
y
86-039
Two Surveillance Requirements Not Performed Because of
Inadequate Procedures.
This item concerns the testing of
',,
the total interlock function for permissive P-4 in that two
of the five functions were not checked.
The licensee
e
developed and approved a new procedure, SI-268.3 Rev. O.
This procedure coupled with SI-94.2 Rev. 2 and SI-90.82
'
Rev. 5 now covers testing of the total interlock functions
i
for permissive P-4. This LER is considered closed.
i
/
86 042
Two Surveillance Requirements Not Performed Because of
Inadequate Procedures.
The licensee has requested relief
from ASME Boiler and Pressure Vessel Code,Section XI,
>
r
,
Subsection IWP-3100 -for several safety-related pumps
because of possible damage to the pump by throttling of the
pump miniflow recirculation loops during the running of the
test.
This item will remain open pending the response to
this issue.86-044,
Inadequate Verification Of ECCS Flow. Procedure SI-137.3
ms found to be inadequate in that it did not inclade RCP
seal pressure differential requirements.
Revision 4 of
SI-137.3 adequately addresses seal pressure differential
requirements. This LER is considered closed.
I
86-048
Inadequate Verification Of ECCS Flow Due To Procedural
'
-Inadequacy.
SI-260.2 was found to be inadequate in that
y
it allowed the testing of the CC' in mode 6 with their
miniflow valves closed.
A new procedure, SI-260.2.1 was
, . ,
issued to test the CCPs in mode 5 with their miniflow
,
valves open, and SI-260.2 is to be revised as part of the
.
,
"~/
corrective action for this LER.
j
have been otisfactorily tested in mode 5.
The Unit 1 CCPs
1
.
will be tened before Unit I restart, and this LER will
l
remain a Unit I restart item only.
j
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.$
"
d.
During the performance of inspection 327,328/87-36 several questions
i
were raised with respect to the Surveillance Instruction Program.
!
The questions were addressed in two memos to file (R. Denise/
I
L. Nobles) dated July 25 and 28,1987.
The inspector reviewed the
l
,
licensee's position on each of the questions which are summarized
i
below.
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Question 1.
The inspector-observed that the licensee's surveillance
instruction program description does not fully' discuss the long term
program and' no dates have been set for its completion.
The licensee
agrees that the long. term program has not yet been fully developed
and . documented. .This appears to be a restart issue, because it will
be -necessary to extract a long term commitment- in the licensee's
Nuclear Performance Plan addressing the surveillance instruction.long.
term program.
.In. addition,. several examples of issues which could
affect.-the adequacy- of the surveillance instructions have been
~
identified in the previous paragraphs of this section.
The
determination of a long term surveillance review program will be
.URI 327,328/87-50-02.
Question 2.
The inspectors determined that there was a second
independent group of reviewers which was not clearly addressed in the
ilicensee's submittal.
TVA stated that the group was identified in
-the SI program submittal'but was not named.
The group was determined
to be the Surveillance Validation and Verification group, and the
-inspector.has no further comments.
Question ' 3.
The inspectors . questioned the terms " independent
verification, independent review, second party verification, and
double verification signoff" which were used throughout the
licensee's submittal.
The licensee stated that "i_ndependent
verification, second party' verification and double verification
signoff" mean that an action has been independently (by another
p' arty) verified as complete and signed off.
The licensee stated that
independent verification and its interchanged words for the concept,
all- mean. verified; it is not acceptable that the first person simply
tell the second person that the required action was taken".
The
licensee has defined independent review to mean that "a person not
involved in the preparation of a work product has reviewed that work
product, usually a. document such as an SI".
The inspector has no
further comments.
Question 4.
The inspectors commented that it was not clear what
l
program or method was used to determine which instructions would not
be. included in the SI program prior to restart.
A set of criteria
was provided by the licensee froc a memo (L. Nobles / Plant staff)
dated January 20, 1987.
The criteria is separate from the SI review
program and is not referred to in the SI review program.
Based on a
,.
l
review of those SI procedures not reviewed in the prior to startup
phase of the SI review program, the inspectors were not able to
identify any procedures which, in the inspector's opinion, should be
reviewed prior to startup of either unit.
The inspector has no
further comments.
Question 5.
The inspectors questioned whether or not the latest
(post-CAR 86-050) SI-1 Appendix F (Part 1) checklist would be used by
the licensee to review those instructions which were determined not
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to be revised prior.to the startup of either unit.
The licensee
stated that "those instructions not on the list to be revised are
reviewed using the post-CAR 86-050 SI-1 Appendix F (Part 1) checklist
- to confirm that the instruction was adequate for its last performance
and fulfilled TS requirements.
If the review indicates that the
instructions are not technically adequate such that verification of
equipment operability is unsatisfactory, .these instructions will be
revised and performed prior to restart."
The inspector has no
further comments.
Question 6.
The inspectors stated that it was not clear what
standards are being used to determine skill of the craft in
Section III of the licensee's program.
The memos referred to above,
still did not define what level of craft skill the procedures were
written to.
The licensee's position was that the purpose of the SI
program is to write instructions which can be followed step by step
to fulfill the surveillance requirement.
However, neither the SI
program nor any other document supplied during this inspection
defined the skill level at which the sis are written.
This is
another example of the need to determine a long term SI review
program and will be followed by URI 327,328/87-50-02.
t
Question 7.
The inspectors commented that it was not clear what
training / screening process was used for personnel revising and
i
reviewing the instructions, especially'the responsible section super-
for persons who previously did
questionable work.
TVA stated that
visors determine the appropriate level of experience and knowledge
required to review and revise the instructions".
There does not
appear to be any objective standards established within the SI review
program to establish the minimum technical qualifications for those
p'ersons doing the technical reviews.
TVA additionally stated that
the qualifications for personnel performing SI reviews is governed
i
by SQA-21, and require a level of seniority, comp"etence, endorsement
j
by the supervisor and Plant Manager's approval.
The inspector
'
reviewed SQA-21 with respect to the standards set to determine if a
person was qualified to review and revise SI.
SQA-21 consisted of
only a list a names and gives no process or qualification standards
for reviewers.
This is another example for the need to identify a
long term SI review program and will be followed by URI 327, 328/
87-50-02.
Question 8.
The inspectors noted that section V. A of the licensee's
i
SI program stated that there is a dashed line from the site quality
'
assurance organization to the site Plant Manager and figure 1 in the
SI program showed a solid line.
The licensee determined that the
solid line in figure 1 was a typographical error and that the site
Quality Assurance Manager did not report to the Plant Manager.
The
inspector had no further comments.
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17
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Question 9.
The inspectors stated that the use of temporary changes
during validation needs to be clarified, especially on whether the
temporary changes will be made permanent.
The use of temporary
changes to procedures in general is still an open issue identified in
j
Inspection Report 327,328/86-62.
l
!
Question 10.
The inspectors noted that- figure 2 of the SI review
l
program plan did not show a return to the originating section after
final typing, and that this.should be clarified.
The licensee stated
that "the originating sections are the final reviewers of the changes
to the instructions".
The inspector had no further comments.
Question 11.
The inspectors observed that the verification /
validation package, ' Appendix J of the program plan, permitted
validation through simulated performance.
The NRC took the position
that validation through the use of simulated performance was not
acceptable.
The licensee stated that "a few instructions utilized
simulation equipment in the development of the SI, but verification
and validation are with plant equipment.
There was one case where a
spare fire hose was used instead of an inservice fire hose to
demonstrate the hydrostatic test setup, but this is not simulation in
the sense which would be inappropriate for validation."
The
inspector had no further comments.
Question 12.
The inspectors observed that the verification /
validation package, Appendix J of the SI review program plan,
permitted instructions which were only for data collection not to be
validated.
The NRC disagreed with this position.
The licensee in
the above cited memos stated that "we agree with this comment, and
all instructions which require such actions are verified / validated."
The inspector had no further comments.
Question 13.
The inspectors observed that Appendix J of the SI
review program plan permitted the cognizant reviewer to perform
instruction validation.
The NRC disagreed with this process.
The
licensee stated that "we agree with this and in the program,
validations are not performed by the instruction preparer and the
permissive comment in appendix J is not implemented." This licensee
did discuss one exception to the above statement.
This issue needs
to be included in the licensee's long term SI program and will be
followed as URI 327,328/87-50-02.
The inspector had no further
comments.
Conclusion:
The TVA SI program, as submitted to the NRC, has produced
adequate sis i.1 the short term.
The present surveillance instructions are
adequate to support the startup of either unit.
Long term control of
surveillance instruction upgrades including temporary changes, qualified
reviews, and administrative checklist items are not adequately described
___
.
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,
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in~ the licensee's submittals.
The submittal of 'a' detailed long term
SI program with' completion. dates and milestones is considered to be a
'
- startup item and will be~ addressed as such' in the staff's SER for
surveillance instruction review.
I
12.
Reevaluation;of the Seal Table Spill Event of 1984
The' ins)ector reviewed the following ' documents in an effort to resolve the
seal taale: issue.:
IR-327/84-11
,
.IR-327/84-24
'
IR-327/84-12 (HP report)
Nuclear Safety Review Staff (NSRS) Report 1-84-12-SQN.
Office of Nuclear Power Response to NSRS Report
Notice of Violation and Imposition'of. Civil Penalties EA84-119
Response to N.O.V. EA-119 date-6/6/85l
Revised-response;date 7/22/85.
IR-327/86-35 which closed IFI 84-11-03
IR-327/86-35-27 which closed VIO 327/84-24-01 thru -03
Inl addition to these - base documents, the . inspector reviewed . Various
' procedures, instructions and documents relating to the five items to be
-l
closed.
These documents are referenced where the individual items are'
discussed.
'
Violation 50-327/84-24-01
Technical Specification 6.8.1 requires the licensee to establish, imple-
ment, and maintain procedures recommended in Appendix A of Regulatory
Guide 1.33, Revision 2, February 1978.
Items 1.c,:1.e, 1.1., 7.e(1) and 9
,
of Regulatory Guide 1.33 specify that procedures are required-for equip-
ment. control, arocedure review-and approval, access to containment, access
,
control to raciation areas including a radiation work permit- system, and
. performing maintenance, respectively.
Contrary to the 'above, the licensee failed to establish and implement
adequate procedures for the conduct of equipment control, procedure review
and - approval, . performance of maintenance, radiation work permit access
control, and access to containment.
Examples of these failures are cited
below:
TVA Response
1.
Admission or Denial of the Violation
TVA admits the violation occurred as stated.
2.
Reason for the Violation
The violation resulted from the fact that adequate procedures were
not established and existing procedures were not implemented for the
____=_:--
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19
control of maintenance activities associated with the Unit 1 moveable
detector system.
NRC Comment:
,
(The presented " Reason for the Violation" only reiterates the cited
violation; it does not address the root cause of the violation.
Without adequate root .cause identification, the corrective actions
that follow for the specific examples tend to be symptomatic in
nature.)
Examples of Violation 327/84-24-01:
a.
On April- 19,1984, maintenance procedure SMI-0-94-1 for instru-
ment thimble tube cleaning and flushing was not implemented in
that Step 1.1 of the procedure forbids use of the thimble
cleaning system at power, and cleaning activities were performed
with Unit 1 at 30 percent power.
The procedure established at-
that time was inappropriate for use at elevated reactor coolant
system pressures and temperatures.
Corrective Action:
Special Maintenance Instruction (SMI)-0-94-1 has been cancelled
and replaced with Maintenance Instruction (MI)-1.10 "Incore Flux
Thimble Cleaning and Lubrication" incorporating lessons learned
in the thimble tube cleaning incident.
NRC Comment:
(This was a procedural violation.
Cancelling the procedure does
not address the violation.
No cause analysis is indicated by
the response, only that the problem was corrected by cancelling
the offending procedure.
The reason for the violation has not
i
been identified.
This response is inadequate.)
b.
Maintenance procedure SMI-0-94-1 was inadequately established
when issued on July 10, 1981, in that it contained no initial
conditions and no post-maintenance inspection or quality
assurance requirements for the thimble tube high pressure seals
which constitute a reactor coolant pressure boundary.
Corrective Action:
SMI-0-94-1 has been cancelled and replaced with MI-1.10.
MI-1.10 contains the applicable initial conditions to be met,
post-maintenance inspections to be done, and quality assurance
requirements (hold points) for the thimble tube high pressure
seals.
In addition, the incore thimble tube maintenance has
been included in the outage scheduling process.
l
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NRC Comment:
(As in item [a] above, cancellation of the flawed procedure does
not address the root cause.
This response addresses only the
symptom, not the cause.
Proper corrective action would include
.
action taken to preclude the issuance and use of a procedure
I
that was inappropriate for the conditions in effect at the time.
Failure to take adequate corrective action in this instance
I
should be considered a contributor to a later incident; namely,
the issuance and use of SI-166.3 to stroke-time test valve
1-FCV-63-1, which resulted in a RCS spill on February 1,1987.
L
The inability to recognize and correct a root cause continues to
l
lead to recurring failures involving inadequate procedures,
I
procedures used in inappropriate conditions, and cognizant
I
violations of procedures).
c.
Maintenance request implementing procedures for control and
review of maintenance activities associated with Maintenance
Request (MR) A-238084 dated April 18, 1984, was not implemented
in that:
(1) MR A-238084 did not delineate the applicable sections of
SMI-94-1 to be performed and thus provided inadequate work
instructions.
(2) MR A-238084 did not delineate requirements associated with
the job safety analysis as required by procedure SQM2,
Maintenance Management System.
(3) MR A-238084 did not reference the incore instrument
disassembly / reassembly instructions of MI-1.9.
(4) As of April 19, 1984, the Field Quality Engineering review
of MR A-238084 did not identify the deficiency of (a) above
and did not identify that the post maintenance testing and
quality assurance requirements referenced in MR A-238084
did not exist.
Corrective Actions:
A review of the MR process and QA review process has been
performed to ensure they meet the requirements of SQM-2, Main-
tenance Management System.
As a result of this review the
following adjustments have been made to upgrade the QA review
program:
(1) Initial MR review has been restricted to QA engineers,
management personnel (M-3 or above), or individuals desig-
nated by the section supervisors.
Designated individuals
f
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.
21
must contact a QA engineer for concurrence prior to
i
approving an MR.
!
NRC Comment:
(While .this corrective action implies that the violation
was caused by allowing unqualified individuals to review
MRs, that conclusion is not stipulated.
As a consequence,
1
it is not possible to determine the adequacy of the
i
corrective action taken.
Additionally, the procedure or
i
instruction that implements the corrective action is not
listed).
(2) Additional training has been provided to those personnel
authorized to review MRs.
The training included the
following:
(a)
Review of SQM-2 requirements for MR reviews.
(b) Review of requirements for identifying post-
maintenance testing for each MR.
(c) Review of Quality Assurance Section Instruction Letter
detailing MR review process (QA-SIL 5.3).
NRC Comment:
(The corrective actions listed imply that the training
given was of a one-shot, non-continuing nature.
This does
not appear adequate to prevent the recurrence of this
problem as the list of qualified reviewers changes.
This
appears to be a temporary fix).
(3) The Quality Assurance Section Instruction Letter, which
provides guidelines for review of maintenance request, was
revised to update systems and components requiring
post-maintenance testing.
d.
Administrative Instruction (AI)-8, Access to Containment, was
not adequately established as of April 19, 1984, in that:
(1) No guidance or positive controls are delineated in the
procedure to ensure that af riocks remain accessible for
egress routes.
(2) Paragraph 2.4 did not clearly delineate those maintenance
l-
activities on the incore flux monitoring system for which
the clearance on the incore flux drive motors could be
I
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removed.
This resulted in incore detector system disas-
sembly activities being performed without the appropriate
clearance in effect.
Corrective Actions:
AI-8, Access To Containment, has been revised to clarify hold
order requirements for maintenance on the moveable detector
system and to ensure operability of personnel airlock
communications.
NRC Comment:
(This response appears adequate.
The corrective action should
preclude a recurrence of this violation.)
e.
AI-3, Clearance Procedure, paragraph 5.1.4, requires that no
work begin on equipment under clearance until the clearance is
issued to the person responsible for the work.
This requirement
was not properly implemented in that as of April 19, 1984, the
clearance for the incore detector drive motors covering thimble
tube cleaning activities was issued to a member of the opera-
tions staff and not to a field services supervisor responsible
for the cleaning activity.
Corrective Actions:
Sequoyah Nuclear Plant (SQN) personnel have been instructed to
ensure the person responsible for work is on the clearance (hold
order) prior to commencing work per AI-3, " Clearance Procedure,"
requirements.
This has been accomplished by including the AI-3
requirements in pre-outage briefing, periodic management safety
meetings, and by use of the existing clearance procedure
training classes.
NRC Comment:
(This response is inadequate as evidenced by a similar occur-
)
rence on February 1,1987, when a clearance on valve 1FCV-63-1
!
was issued to the ASE and not to the person responsible for the
work.
Positive controls in the form of specific changes to
clearance procedures and/or instructions on the hold / caution
tags may be indicated.
Every time a clearance is issued,
specific requirements such as issuance to applicable persons
should be mandated and controlled.
Training and lecturing
workers on adherence to procedures may be effective for rela-
tively simple procedures, but the use of upper tier documents
and the complicated nature of the procedure in question should
be considered when corrective actions are planned.)
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23
f.
Radiation Work Permit (RWP) 02-1-00102 issued January 1,1984,
for seal table area inspection and maintenance required workers
to verify the presence of a clearance on the incore instrument
probes prior to entering the containment lower compartments and
This requirement was not implemented on April 18-19,
1984, by workers entering the seal table area in-that the
clearance was not in effect on the problems during work
activities.
Corrective Actions:
The RWP procedure and RWP cover sheet have been revised to
require the RWP timesheet to be removed when incore probes are
in use.
AI-8 also contains requirements for having the RWP
l
timesheet approved and in place for maintenance activities on
the moveable detector system.
NRC Comment:
(While this corrective action appears adequate and relative to
the issue, no evidence can be found of the implementation of the
I
corrective action in a review of the RWP procedure RCI-14.
If
later revisions have removed this stipulation, failure to
maintain commitments may be indicated).
Violation 50-327/84-24-02
,
Technical Specification (TS) 6.5.1.6 requires that the Plant Operations
Review Committee (PORC) review unit operations to detect potential nuclear
,
safety hazards and review all procedures required by TS 6.8.1.
!
Contrary to the above, these requirements were not implemented in that the
PORC:
1.
Did not meet and review the operational hazards associated with
thimble tube cleaning activities to be conducted in containment with
the unit at power on April 19, 1984.
I
2.
Did not adequately review maintenance procedure SMI-0-94-1 for
thimble tube cleaning and flushing on July 10, 1981, as evidenced by
the deficiencies identified in Violation 1.(b) above.
TVA Response
1.
Admission Denial of the Violation
TVA admits the violation occurred as stated.
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24
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2.
Reason for the Violation
i
The violation occurred due to personnel error in that the hazards
associated with . cleaning the thimble tubes at power were not
i
recognized.
Consequently, the PORC did not convene and review this
activity prior.to performance.
NRC Commenti
(The root cause of item 1 is stated as personnel error in that the
hazards associated with the tube cleaning were not recognized and
submitted to PORC for review.
Personnel error is applicable when one
individual makes an avoidable error.
If one individual incorrectly
determined that PORC involvement was not required, the process of
.
submittal to PORC should be reviewed.
If the failure identified by.
the violation is determined to be a collective failure by the PORC, a
single individual. was not responsible for the error and a program-
>
matic or procedural error is indicated.
The presented " Reason for
Violation' does not address item 2, which states that an inadequate
1
review of SMI-0-94 was performed by PORC.)
Corrective Action
a.
The PORC is performing more indepth detailed reviews of pro-
cedures and activities to ensure compliance with established
plant requirements.
Additionally plant management personnel who
serve as members of PORC have reviewed the duties and
responsibilities of PORC, as identified in TS Section 6.5.1.6
and Sequoyah Standard Practice SQA-21, Onsite Independent Review
(Plant Operations Review Committee).
b.
AI-4 Requirements for PORC review of plant instructions will be
followed for plant activities.
l
NRC Comments:
1
(Corrective Action item [a] addresses only the quality of PORC
reviews.
The violation clearly states that PORC did not meet and
review the operational hazards associated with the thimble tube
cleaning process.
The corrective action does not match the violation
or even the stated reason the violation occurred.
Consequently,
corrective action [a] appears inadequate to correct the original
error or to preclude recurrence.)
(Corrective Action item [b] states that AI-4 will be followed in
future PORC reviews.
This implies that AI-4 was not necessarily
i
followed previously.
Mandating
AI-4 adherence as a corrective
action carries the implication that some other, unspecified, set of
review criteria was in use when PORC reviewed SMI-0-94-1 in July of
1981.
Application of and adherence to a procedure that was already
in place and required to be folicwed is not an appropriate corrective
action).
1
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25
Violation 50-327/84-24-03
10 CFR Part 50, Appendix B, Criterion II requires that activities affec-
ting quality shall be accomplished under suitably controlled conditions
which includes the use of appropriate equipment.
In addition,
Criterion III requires that appropriate measures be established for the
I
selection and review for suitability for the application of equipment.
Contrary to the above, as of April 19, 1984, the modified incore flux
monitoring system thimble cleaning tool used for thimble cleaning activi-
l
ties at power was not appropriate equipment for use on the reactor coolant
'
pressure boundary in that excessive stresses were transferred to the high
p essure seal on incore thimble D-12.
This resulted in a breach of the
j
reactor coolant pressure boundary.
In addition, management controls for
and reviews of modifications to the original vendor-supplied cleaning tool
were inadequate to prevent inappropriate modification of the tool and
subsequent use.
TVA Response
1.
Admission or Denial of The Violation
TVA admits the violation occurred as stated.
2.
Reason for the Violation
The violation occurred due to inadequate management controls being
established to ensure modifications to "special tools" received
appropriate reviews and approvals to prevent unauthorized modifi-
cations and use.
Corrective Actions:
Sequoyah Nuclear Plant has evaluated the need for establishing a program
to control the use and modification of "special tools." As a result of
this evaluation, SQN Standard Practice SQM-63, Special or Modified
Tooling-Primary System, has been issued outlining the requirements to be
followed for the use and modification of "special tools. '
In general,
special tools used on equipment fitting the following criteria fall within
the scope of SQM-63:
a.
Components which are in service, pressurized or energized.
b.
Components which, if the tool caused failure of the component, could
cause loss of primary coolant or the loss of uncontrollable amounts
of radioactive contaminated water during the use of the tool,
c.
Components which, if the tool caused failure of the component, I
could cause the loss of a safety function while the tool is
being used.
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This Instruction may.also be used to document evaluations of other tools
as requested for reasons such'as-industrial safety considerations.
NRC Comment:-
)
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.
.
.
1
(The. reason for the violation and the corrective action appear adequate in
-i
this response.)
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13. -Restart Test' Program
During ~ this . inspection period a special team . inspection was conducted to
evaluate the effectiveness of the Restart Test Program review process.
The objectives of this inspection were as follows:
To' verify that the Restart. Test Group (RTG) functional review process
is being adequately implemented.
.To verify that components / systems functions that are. identified as
requiring testing are properly dispositioned.
To provide a s' ample assessment of the technical adequacy of several
sis used to satisfy the functional testing requirements.
To provide 'a sample assessment of the technical adequacy of several
portions. of previously. completed preoperational tests that are being
used to satisfy the functional testing requirements.
_To provide a sample assessment of the effectiveness of previous post
maintenance testing.-
To provide a sample assessment of the correctness of the FSAR as it
relates to system functional requirements.
Tha inspectors reviewed the . identified system packages to verify
compliance to the specified program.
Specifically, the following items
were addressed during this review:
Verify that the functional analysis report (FAR) matrix package
contains the following documents as applicable:
Documents
i
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FAR (SIL-5)
Functional Review Matrix (SIL-2)
Punchlist Report (SIL-2, sect 5.2)
Test Outline (SIL-2, sect 5.7)
Restart Test Program Interface
Report (SIL-2, sect 5.1)
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27
Review (10-20%) Division of Nuclear Engineering (DNE) documents to
Restart Test Engineer (RTE) which list component / system functions
and verify that the functions were listed on the functional review
matrix (FRM) (SIL-2, Section 5.1).
'
Determine if RTE has identified any additional component / system
)
functions as a result of the reviews and ascertain the' reason the
i
functions . were 'not listed by DNE. . Verify that any additional
i
functions identified during the review were listed on the Punchlist
!
and determine if they were properly identified to DNE and if.the item
,
resulted in a Condition Adverse to Quality Report (CAQR).
Obtain
i
copies.'of any transmittal memorandum and place in system jacket.
Discuss with RTE their background experience and verify
qualifications, documented training, and required reading are in
accordance with SIL-1.
Review the FAR, including the punchlist report and FRM to verify
that, the above documents are in agreement as to number of identified
retests / tests to be performed, the disposition of punchlist items,
and the resolution of identified interface items.
Additionally, the
conclusions reached by the RTE should be evaluated and discussed with
the RTE.
The following points should be considered when performing
the above review:
(a) If the function has never been tested: is testing planned; what
type of function (i.e., control, indication, safety, etc.); will
a special test be written or will the existing SI be modified?
If a safety function is involved, was existing SI inadequate?
Was CAQR issued?
(b) If function was last tested during preoperational testing,
'
should it be included in an existing SI as a requirement or an
enhancement, added to a preventive maintenance program or ISI
program, etc.?
(c) Are TS, FSAR, and/or design criteria document changes necessary?
What method has TVA used to identify / track these changes?
'
Evaluate the supervisory and JTG review and approval of the system
package
On selected systems verify that the FRM reflects the functions listed
in the applicable FSAR and TS section.
l
On selected systems, conduct a sample review of the SI, preopera-
tional test, PMT, etc. , which TVA is taking credit for and verify
that the test and results were satisfactory. SIL-2, section 5.2 can
be used as a guide in this area. Also the checklists which are part
of the FAR should be evaluated.
_ _ _
,
a
28
The systems reviewed along with the inspectors findings are discussed
below:
a.
System No. 62, Chemical and Volume Control System (CVCS), is
described in Section 9 of the Final Safety Analysis Report (FSAR) and
applicable sections of the TSs.
The inspector discussed with the
RTEs: their related experience and educational background and
determined that both individuals were qualified per the procedure
requirements.
Their review of the system resulted in: (1) twelve
additional functions being added to the DNE listing of the system
functional requirements; (2) identifying redundant instrumentation
not included on a regular calibration schedule; (3) identification of
Condition Adverse to Quality Reports (CAQRs) not previously reviewed
for generic applicability for CVCS related equipment; (4) one valve
stroke time be:ng different than that in the FSAR but was found to be
included in a revision request; and (5) drawings were found with
discrepancies.
The restart test package appeared to be adequate
based on the selected sample reviewed by the inspector.
Areas found
to be deficient had been documented on punchlist or other tracking
documentation.
b.
System 92, Neutron Monitoring, is described in Section 7.2.1.1 of the
FSAR and Section 3.1.1.1 of the TS.
The inspector reviewed the FAR
'
and discussed the review process with the RTE.
The inspector
reviewed approximately 20% of the DNE documents submitted to the RTE
which listed component / system functions and verified that the
i
functions were listed in the FRM.
The inspector verified that all
'
open items in the FAR were listed on the punchlist.
The inspector
sample reviewed corpleted surveillance instructions listed in the FRM
to validate functions and verified that the functions were tested as
specified in the FRM.
The inspector did not attend the JTG meeting
i
that approved the system 92 FAR but was informed by the RTE that the
i
JTG review of the FAR found one technical error that had to be
'
corrected prior to final JTG approval.
Additionally, the inspector
.
noted that all system 92 functions were validated with surveillance
1
instructions. The inspector considers that this FAR adequately
addresses all system 92 functions and validations.
c.
System 30A1 and 30A2, Auxiliary Building Gas Treatment System and
Auxiliary Building Secondary Containment Enclosure, are described in
!
'
section 3/4.7.8 of the TSs and section 9.4.2 of the FSAR.
The
inspector interviewed the RTE and determined that the individuel met
the education and related experience requirement.
A review of the
!
engineer's actions associated with the restart tast package for this
system included the following: (1) deficiencies in the DNE listing of
the system functional requirements had resulted in additional
items
being added to the listing; (2) discrepancies identified between the
FSAR, TS, and the design specifications were added to the punchlist;
(3) CAQRs were reviewed for generic applicability for the system
equipment; (4) Engineering Change Notice Packages were reviewed and
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29
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i
evaluated, and
(5) interface points were identified and listed.
I
Based on a sample review of selected items, the inspector determined
that the restart test package for this system was acceptable.
d.
System No. 65, Emergency Gas Treatment System (EGTS), is described in
Section. 6.2 of the FSAR Section 6.2 of the TS.
The EGTS consists of
the Annulus Vacuum Control and - the Air Cleanup subsystems.
The
primary safety function is to maintain negative pressure within the
annulus and to remove airborne particulate and vapors from air drawn
from the annulus that may contain radioactive nuclei.
The inspector
reviewed the functional analysis report / matrix package for the EGTS
which contained the required documents.
The RTE is an experienced
contractor.
His qualification, documented training and required
reading were in accordance with TVA requirements.
All safety-related
functions were identified on the FRM.
The RTE identified two non-
safety related functions which are included as punchlist items.
One
TS change was requested- for paragraph 4.6.1.8.d.1 to change the
specification for the pressure drop across the combined HEPA filters
and charcoal absorber banks from less than 8-inches water gauge to
less than 5-inches water gauge.
This item is tracked on TVA's
punchlist.
The licensee determined that SI-142, EGTS Filter Train
Test, was inadequate in that it would not enable detection of bypass
leakage around the EGTS filters.
CAQR SCP871216 was written to
document this and proposed corrective action will include detection
of bypass leakage within the scope of the test. Based on a sample
review of selected items, the inspector determined that this restart
test package was acceptable.
e.
System 90, Radiation Monitoring, is described in Section 11 of the
FSAR and Sections 3.3.3.1, 3.3.3.9, 3.3.3.10, and 3.4.6.1 of the TS.
The inspector reviewed the FAR, FRM, and FAR punchlist and conducted
discussions with the RTE.
The inspector also observed the licensee
perform testing that validated functions identified in the FAR.
The
FAR identified two valves that were required to reposition after
receiving a signal from the appropriate radiation monitor that are
not being routinely tested.
The RTE has punchlisted this item. The
licensee will incorporate this testing into existing sis and perform
the additional testing.
After RTE review of the test results the
punchlist item will be cleared. Inspector review of the FRM and
punchlist identified that the punchlist and FAR did not agree on open
items, one FAR open item was omitted from the punchlist, and the FRM
did not properly document which documents the RTE had reviewed.
Both
of these items are administrative in nature and have been discussed
with the RTE.
These items have been added to the inspector's
l
punchlist for system 90 future follow-up.
The FAR required SI-83,
Channel Calibration for Radiation Monitors, be performed to validate
system 90 functions.
The inspector observed portions of this SI
being performed by the licensee and was satisfied with the
performance.
Per inspector discussion with the RTE, the intent when
preparing the system 90 FAR was to cover all raciation monitors that
,
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30
i
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are FSAR or TS invoked.
There are additional area radiation monitors
that are not FSAR nor TS invoked that are located throughout the
plant that are not discussed in the FSAR.
Subsequent to JTG approval
of the system 90 FAR, the RTE discovered that area radiation monitor
2-RE-90-2 (area monitor at containment door hatch) is TS required.
Radiation monitor 2-RE-90-2 was not addressed in the FAR and the RTE
i
'
is in the process of adding this area radiation monitor to the FAR.
This item has been added to the inspector punchlist for future follow
up.
f.
System 74, Residual Heat Removal, is described in section 5.5.7 of
!
the FSAR and Section 3.4.1.3 of the TS.
The principal function of
l
the system is to remove decay heat from the reactor core during
shutdown conditions.
The DNE input to the RTE included these
functions and the transfer and refueling mode of system operations
were added by the RTE.
The safety injection mode of system operation
was picked up by the Safety Injection system and Containment Spray.
system which are described in FAR packages 63A and 72 respectively.
Interfaces include the 6.9 KVA, 480VAC, component cooling water and
heating and ventilation systems. During interviews with the RTE the
inspector' determined that he was qualified to perform the reviews and
l
his output satisfied program requirements.
The review process
'
resulted in the need for a special test to be developed to satisfy
the testing requirements for the interlock between the containment
sump valve and the RHR inlet isolation valves.
This test requirement
,
was punchlisted against the final package approval and will be tested
and resolved prior to complete closure.
g.
System 18, Diesel Fuel Oil, is described in Section 9.5.4 of the FSAR
and Section 8 of the TS.
The inspector verified that the deficien-
cies identified in Inspection Report 327,328/87-43 regarding the
!
transfer capacity of the 7-day-tank to the 1-day-tank transfer pump
was resolved in the JTG approved system 18 FAR package.
Additionally,
the inspector
veriffad that the RTE qualifications satisfied the
program requirements.
h.
System 250, Vital Control Power.
This system is described in Sectica
8.3 of the FSAR and Section 8.2 of the TS.
The July 27, 1987 JTG
approved FAR was reviewed by the inspector.
During this review the
inspector compared the functions described in the FSAR and TS against
the functions identified by the RTE on the FRM. Additionally, the
'
inspector's sample of functions identified by DNE indicated a
'
consistency with the RTE's findings.
The RTE met the program
requirements for qualifications and demonstrated a thorough knowledge
of the system when interviewed by the inspector.
Two new tests were
identified to check the battery output ripple amplitude and to check
the harmonic distortion of the system inverters.
i.
System 31A, Control 8uilding Environmental Control, is described
in Section 9.4 of the FSAR and Section 3/4.7.7 of the TS.
The
July 20, 1987 JTG approved FAR was reviewed by the inspector.
The
l
.
.
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i
31
inspector verified that FSAR and TS functions were included in the
FRM review. A 20% sample of functions provided by DNE as required by
SQEP-63 indicated that they had been included in the FRM.
The
testing of system functions using original preoperational tests and
current sis were sampled to confirm satisfactory results as to the
acceptability of the specified test to satisfy the functional testing
requirement.
The RTE's qualifications were verified and the _
,
inspector's interview with the individual indicated that he was
knowledgeable of the system he was reviewing.
The inspector examined
the functional analysis package open items punchlist to confirm that
functions which require new tests were properly dispositioned.
Two
new tests have been identified which when issued will check battery
room exhaust fan C-8 time delay and isolation damper failed position
verification.
i
j.
System 72, Containment Spray (CS).
The preliminary findings of the
RTE review of this system were discussed in Inspection Report 327,
'
328/87-43.
During that review CAQR SQP870860 was issued due to the
fact that the preoperational test for the CS pumps was not adequately
satisfied, in that the pump head may not be adequate to provide the
required system flow.
The resolution for the original preoperational
test deficiency was to insta'11 an in-line orifice.
Although the
installation of this orifice did resolve the pump head issue, it
created a flow problem and this condition has existed since the
installation of the orifice. The RTE indicated that the special test
currently being developed will verify pump head and evaluate heat-
exchanger D/P in the event that additional analysis becomes necessary
due to actual pump head not satisfying original design.
This issue
is identified as URI 327, 328/87-50-03, pending resolution and
evaluation of CAQR SQP870860.
k.
System 30A3 and 30A4, Containment Air Return Fans and Containment
.
Vacuum Relief System, are described in Sections 3/4.6.5.6 and 3/4.6.6
'
of the TS and Sections 6.6 and 6.2.6 of the FSAR.
The Containment
Air Return Fan system's primary safety function is to enhance the Ice
i
Condenser and Containment Spray heat removal operation by circulating
air from the upper containment to the lower containment, through the
ice condenser, and then back to the upper containment.
A secondary
function is to limit hydrogen concentration in potentially stagnant
regions by ensuring a flow of air from these regions.
The Vacuum
Relief System is designed to protect the primary containment from
excessive external force and does not provide any accident mitigating
function.
The inspector reviewed the functional analysis resort /
matrix packages for these systems which contained the requ" red
documents.
The inspector interviewed the Restart Test Engineer
(RTE), an experienced contractor, and determined that the individual
met the education and related experience requirements.
All
safety-related functions were identified on the FRM.
One TS change
was requested for paragraph 4.6.3.2 to change the requirement that
i
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32:
the' valves listed on Table'3.6.2 be demonstrated operable once per 18
- months.
The method used in the surveillance requirement did not
demonstrate the isolation capability for.the three containment vacuum
relief lines which have separate pressure' switches that are com-
pletely ' independent of all other containment isolation signals from
any other system and the: valves would not respond to the = signals
specified in.SR 4.6.3.2.
This condition is identified in CAQR-SQP-
-870932 and is tracked on the TVA'punchlist.
The licensee determined that during conduct of preoperational test
TVA-6, not all of the ice condenser doors opened when the air return
fans were started as required by the design criteria. .This condition
was identified in CAQR-SQP-870860.
The corrective action for the
CAQR included revision of Section 5.2, System Testing, of the-SQN-DC-
V-13.9.5 design criteria to allow testing of the lower inlet doors to
the ice condenser by other approved methods.
The licensee did not
provide the inspector with an adequate analysis which provided
sufficient justification for not' testing the system as stated in the
original design criteria.
This issue is identified as URI'327, 328/
87-50-03, pending further evaluation by the inspector.
Test Witnessing
In addition to reviewing the above FAR packages the inspectors witnessed
the performance of portions of several sis that were identified by the
RTEs as being required to satisfy functional testing requirements.
SI-689, Auxiliary Control Air Operability Test.
The inspector witnessed
the performance of this test which verified that the safety-related air
compressors would start and " load" on a low air pressure signal and that
the non-CSSC equipment would isolate on further pressure drop to a speci-
fied set point.
The test instruction was appropriate for performance
of the test.
Some areas requiring minor maintenance were noted on the
test, comments and repair requests were generated.
The inspector has no
comments that have not been addressed.
SI-193, Containment Building and Auxiliary Building Ventilation Test.
The inspector witnessed the performance of portions of this test which
calibrated the annulus differential pressure channel 1-P-30-127 which is
common to loops 1-P-30-126 and 1-P-30-127.
The test instruction was
appropriate for performance of the test.
The inspector has no comments.
Joint Test Group (JTG) Activities
During the -course of this inspection the inspector attended several
meetings of the JTG.
The meetings were attended by a quorum of members
and minutes were recorded.
The inspector considered the meetings to be an
integral part of the overall review / approval process and the members in
attendance realized their individual as well as cumulative responsibility
[
to the overall product quality.
However, the inspectors did note that
L_____ _ __
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33
!
although 20 meetings have been conducted only 5 meeting minutes have been
issued.
The rest are still in the DRAFT state.
This was discussed with
,
the restart test program manager, who indicated that due to the number of
I
meetings currently being held they were behind and they recognized the -
-l
need to process the minutes in a more' rapid' fashion.
!
Miscellaneous' Activities
In addition to the above inspection the inspector discussed with the site
employee concern program representative (ECPR) any concerns which may have
been expressed by employees in this area.
The ECPR indicated that no
concerns have been expressed in this area.
Additionally, the inspector
attended the QA audit debrief for this area and determined that the
licensee's proposed corrective action for resolution of the audit findings
,
i
appeared to be appropriate.
During a meeting conducted on July 31, 1987, the licensee committed to
modify the current instruction on preparation of the final test analysis
report.
This modification is needed to ensure that the final product is
consistent between engineers and should ensure that open punchlist items
are properly resolved as well .as ensuring that the FRM open review items
are closed.
14.
Abnormal Operating Instructions
The inspector reviewed portions of the following abnormal operating
instructions (A0I):
A0I-2, Malfunction of Reactor Control System
AOI-3, Malfunction of Reactor Makeup Control
A0I-4, Nuclear Instrumentation Malfunctions
A01-5, Unscheduled Removal of RCP(s) Below P-8
A01-8, Tornado Watch / Warning
A0I-11, Loss of Condenser Vacuum
The inspector verified that the licensee had established procedures for
combating emergencies and other significant events as described in
Within this area no discrepancies were noted.
15.
Containment Hydrogen Analyzer Operability
l
During an inspection conducted November 12-21, 1986, (Inspection Report
i
327,328/86-62). the inspector identified several as-installed conditions
that could have affected the OPERABILITY of the containment hydrogen
l
analyzer (URIs 327/86-62-01, and 328/86-62-08).
At the conclusion of
(
that inspection, NRC Region II, Division of Reactor Safety, requested
'
the Office of Nuclear Reactor Regulation (NRR) to evaluate the identified
conditions and determine if the as-installed system satisfies the
OPERABILITY requirements of TS 3.6.4.1. As part of the NRC evaluation, TVA
was requested to verify several as-installed conditions and provide this
information to NRR.
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described accuracy was changed to plus or minus 1.5 percent
hydrogen.]
As a result of the initial inspection discussed above, a Notice of-
Violation was issued regarding inadequate design controls for this
installation.
Subsequent to the initial inspection the inspector has been
working with TVA and NRR/0SP to resolve the H2 analyzer OPERABILITY issue.
Additional information has been - requested from TVA .during numerous
telephone calls with NRR/OSP and TVA was requested to consult their vendor
as to the acceptability of the installed system regarding line slope
(i.e., water traps) and lack of insulation.
The OSP reviewer indicated to
TVA that the instrument accuracy issue may be acceptable provided that the
emergency procedures . reflected this inaccuracy, and the vendor provides
written evaluation of the actual installation.
TVA was requested to
walkdown the system and determine the location and magnitude of any water
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traps.
The vendor provided supplemental information regarding water traps to TVA
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in a January 13, 1987, letter.
The vendor stated in his letter that the
system-would still function provided that the inlet vacuum did not exceed
a cumulative water head in excess of 5 or 6 feet.
Greater vacuum will
adversely affect the addition of reagent and calibration gasses making
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calibration unreliable.
TVA provided the inspector the above letter and
an internal note which documented a telephone conversation of May 19,
1987, between TVA 'and OSP. In that note, TVA indicated that they provided
OSP the following information:
(1) Details of the January 13, 1987 Comsip letter
(2) Information that indicated the worst water trap in the sample
lines did not exceed four (4) feet
(3) That the analyzer is not calibrated during an accident
(4) That the vendor pump data included in the analyzer instruction
manual showed that the pump was designed to pull up to 24 inches
of Hg (27 ft. of water) vacuum in the least effective mode
The inspector requested that TVA walkdown (with the inspector) the
as-installed system.
The walkdown was restricted to Unit 2 only and
included the area outside of containment as well as portions of the
installation inside the containment.
The results of this walkdown
indicated that the worst water trap outside containment was 5 feet vs. the
4 feet claimed in item (2) above.
However., when the inspector walked down
the portion inside containment, water traps of approximately 14 feet for
train
"A" and 7 feet for train
"B" were noted.
When questioned, TVA's
Division Of Nuclear Engineering (DNE) design personnel indicated that they
had not considered the portion inside containment as a potential problem,
as they felt that temperatures in the area of the sample line would
prevent moisture from condensing in the lines.
During further discussions
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To understand ~ the issue regarding the OPERABILITY of the H2 analyzers the
~
following excerpt from Inspection Report 327,-328/86-62, is provided:
[During the review of modifications to the'H2 analyzer, the inspector
noted problems with the initial installation of the H 3 analyzers for
both Units 1 and 2.
The original H2 analyzers installed in the 1978
time frame were later upgraded to satisfy the requirements of NUREG 0737, TMI Action Plan.
NUREG 0737,,. Item II.F.1 (6), Containment Hydrogen Monitor, required'
the accuracy and placement of' the H2 monitors be provided and
justified to be adequate' for their intended function.
TVA in their
December 10, 1980 letter (L. M. Mills 'to A. Schwencer, NRC) on TMI
Action Plan Item II.F,1 (6) described the system as follows:
"As a
"
result of the analyzers capability and the mixing afforded by the-
hydrogen collection system which draws from compartments w;m,,n the
containment and: the containment dorae a true indication will be given
of the hydrogen concentration.within containment.
The analyzers are
calibrated to measure hydrogen concentration between zero and ten
percent with an accuracy of plus or minus one-tenth of one
percent...."
The field installation of the H2 monitors for both Units 1 and 2 did
-not implement the vendor (Comsip Delphi, Inc.) requirements regarding
sample line slope and insulation. 'The failure to properly route and
-insulate the sample lines results in the condensation of moisture for
'
the containment post accident H sample in-route to the detector.
2
This installation can create two potential problems: (1) water traps
present a tortuous path for the H ' gas to reach the detector although
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2
the vendor did indicate, in a phone call, that the pump was capable
of pumping any water that reaches the analyzer; and (2) a true
reading of containment vapor H2 concentration ~is not possible as long
as ' actual containment moisture is greater than that the detector
sees.
The vendor indicated that the reading could be higher than
actual by as much as a factor of five although TVA analysis, performed'
,
at the inspector's request, indicated a in ser error.
'
{
These inaccuracies appear to be in the conservative direction-
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however, decisions based on the H indications are not conservative.
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Specifically, Sequoyah Function Restoration Guidelines FR-Z1,
,
Response to High Containment Pressure,-instructs the' operator to NOT
,
place H2 recombiners in service and to consult the technical support
center for containment hydrogen purge instructions if H2 indication-
{
is-greater than 6%.
These actions, if based on erroneous high H2
1
indication, would be non-conservative and may result in post accident
complications.
)
The installed system does not appear to provide the degree of
accuracy originally claimed in TVA's December 10, 1980 letter.
In a
subsequent change to Section 6.2.5.3 of the Sequoyah FSAR, the
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with DNE ' personnel they indicated that a Westinghouse analysis of con-
tainment temperature- post LOCA indicated that _their assumption may not
be correct in the area where the sample lines run near the containment
air' return fans.
'
The; inspector, requested that- TVA walkdown the rest of the inside
containment installation and provide a sketch showing water traps and
tub _ing installation.
The results of this walkdown are not complete; .
however, several additional installation problems have been . identified.
Specifically, test , connections for the train
"A" installation were .
determined to not match the installation drawing as to location with
respect to the containment liner.
Additionally, these test connections
- were found to not inc'lude valves specified ' on the drawing and were
additionally found with the ' lines uncapped.
These two discrepancies
were documented on CAQR SQP 870430 and SQP 87031 and were evaluated for
7
deportability - on Potential Reportable Occurrence (PRO) 2-87-011.
The
containment integrity aspects of the missing valves were evaluated by the
licensee and TVA determined that the valves were most probably removed
after. the ,last_ successful test of the system which was conducted in
August 1985'_ during the current outage.
In addition to the' test valve
- problem, the walkdown determined that the train'"A" installation did not
run to upper containment as required.
Consequently, the only sample point
is at the top of the pressurizer cubical, thus not being able to provide a
representative sample of containment H
concentration.
The walkdown also
g
determined that although the train "B
sample line penetrated the floor
of the upper containment, it only ran upward approximately 18 inches.
-
Neither of these installations appear to meet the design requirements for
the -system, 'and ~ containment dome concentration is considered by the
inspectors to have ncver been adequately measured.
currently working on a design ' change to modify both trains of containment
H analyzers to reduce the water traps to acceptable values and to rerun
~
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the upper containment sample points.
However, during discussions with~DNE
engineers the inspector was informed that the modification will run the
upper' containment sample point only 6 feet from the floor and the
inspector questions whether this location will provide a truly represen-
tative sample as to containment dome H2 concentration.
This issue will be
addressed in TVA's submittal to OSP on the H2 analyzer issue.
d
This item will be remain unresolved (URI 328/86-62-08) pending OSP upper
management review for enforcement action.
Although, the inspection has
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concentrated only on Unit 2, similar conditions may exist on Unit 1 and
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this will be tracked under the original URI 327/86-62-01.
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