IR 05000327/1987060
| ML20236W017 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 11/20/1987 |
| From: | Jenison K, Mccoy F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20236V976 | List: |
| References | |
| 50-327-87-60, 50-328-87-60, NUDOCS 8712070225 | |
| Download: ML20236W017 (63) | |
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o UNITED STATES NUCLEAR REGULATORY COMMISSION p*' [s Mo ,#'o,$ -
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REGION 11 g j 101 MARIETTA STREET. * * ATLANTA, GEORGI A 30323
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Report Nos.: 50-327/87-60 and 50-328/87-60 Licensee: Tennessee Valley Authority 6N38 A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Docket Nos.: 50-327 and 50-328 License Nos.: DPR-77 and DPR-79 Facility Name: Sequoyah 1 and 2 Inspection Conducted: September 6 - October 5, 1987 Lead Inspector: .NN,e M K. M. Jenison',7enfor F}&idept' Inspector
[/// $/9 7 Oate Signed
Accompanying Inspectors: P. E. Harmon, Resident Inspector D. P. Loveless, Resident Inspector W. K. Poertner, Resident Inspector W. C. Bearden, Resident Inspector M W. Branch, Se uoyah Restart Coordinator Approved by: Y/// s h F. R. McCby, Chff6f, Projects Seftion 1
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yate/igned S 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; followup of events; review of licensee identified items; review of IE information notices; and review of inspector followup item Results: Four violations were identifie paragraph three - Inoperable hydrogen monitor in modes 1 and (328/87-60-01)
paragraph three - Failure to meet 10 CFR 50.59 such that a required license amendment was not sought. (327, 328/87-60-02)
paragraph fifteen - Operation of essential raw cooling water (ERCW)
strainers and screen wash systems without procedures. (327,328/87-60-05)
8712070ggy 97g3yg gDR ADOCK 05000327 PDR
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i paragraph fifteen - Modifications to ERCW without 50.59 evaluatio ,
(327,328/87-60-06) l Three unresolved items were identifie paragraph.three - Hydrogen monitor operability for Unit (327/87-60-01)
paragraph five -
Operability of mechanical sleeves in polar crane wall penetrations. (327,328/87-60-03)
paragraph five -
Resolution of recently identified security issue (327,328/87-60-04)
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1 REPORT DETAILS Licensee Employees Contacted
- C. C. Mason, Deputy Manager, ONP H. L. Abercrombie, Site Director
- J. T. La Point, Deputy Site Director l
- L. M. Nobles, Plant Manager
- B. M. Willis, Operations and Engineering Superintendent
- B. M. Patterson, Maintenance Superintendent R. J. Prince, Radiological Control Superintendent c
- R. Harding, Licensing Group Manager '
L. E. Martin, Site Quality Manager J. 2. Hosmer, Project 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, Instrument Maintenance Group Manager
- C. L. Kelley, Site Security Manager
- J. R. Setliffe, Public Safety Service Chief
- R. W. Fortenberry, Technical Support Supervisor
- G. B. Kirk, Compliance Supervisor
- D. C. Craven, Assistant to the Plant Manager 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 Other licenree employees contacted included technicians, operators, shift engineers, security force members, engineers and maintenance personne * Attended exit interview Exit Interview
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The inspection scope and findings were summarized with the plant manager and members of his staff on October 6,1987. Four violations described in this report's summary paragraph were discussed. No deviations were discusse The ifcensee acknowledged the inspection finding The licensee did not identify as proprietary any of the material reviewed by the inspectors during this inspection. During the reporting period, frequent discussions were held with the site director, plant manager and other managers concerning inspection finding During the course of the exit the licensee committed to the following actions:
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t 2 Complete commitments 1-5 on containment spray pump 2-A as discussed in paragraph 3 for Unresolved Item 327, 328/87-50-0 , Complete commitments 1 and 2 for strengthening the SAL closure process as discussed in paragraph 18.b.(1). q 3. Licensee Action on Previous Inspection Findings (92702)
(Closed) Violation '(VIO) 327, 328/87-02-01,- Failure to Control. Design ,
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Change The inspector reviewed the licensee's response (Gridley/Zech) *
dated April 17, 1987, and TVA memo to file (Hosmer/ distribution, i B25 870901 018) dated September 1, 198 Inaddition,theinspectorhild-several meetings with the licensee (August 25, 1987 - Hosmer, Department'
of Nuclear Engineering; September 1, 1987 - Harding, TVA licensing) durirg which the review process for engineering change notices (ECN) and field ,
change requests (FCR) were discussed. The new design change contrcl . >
program described in SQEP-13, Procedure for Transitional Change Control, '
revision 6, appears to require an adequate review of descendant ECNs. In
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addition, the above stated memo to file commits to a review of design E change request documents if applicable. This item is close ' !,
(Closed) Unresolved Item (URI) 327, 328/87-36-02, Possible Inadequate Procedures, identified inadequacies in SI-218.2, Periodic Calibration of RCP Underfrequency Relays, SI-270.2, Fuses for Containment Penetration Conductor Overcurrent Protection, and SI-166.40, Pressurizer PORV and Block Valve Operability Test. The inspector revicwed the licensee's j response dated August 11, 1987, reviewed applicable surveillance instruc- ~l'
tions, and conducted interviews with cognizant licensee personnel. The inspector found the licensee's response adequate to resolve the concerns raised in inspection report 327, 328/87-36 and that the surveillance l instructions were adequate to meet the TS requirements. This item is close (Closed) URI 327, 328/87-50-01, Control of Systems Required for Mode 5 Operatio The inspector reviewed the circumstances that resulted in valve HCV-74-36 being open during the performance of SI-128. The inspector determined that the valve was not returned to its required shut position after completion of maintenance activities conducted on the valv As a result of this event the licensee issued a night order addressing the results of mishandling configuration control devices, discussed the event during shift turnovers and revised the governing precedure, Operations Section Letter Administrative (0$LA)-58, Maintaining Cognizance of Operational Status, to clarify the requirements for i returning a valve inside the clearance boundary to servic The inspector had no further questions. This item is close _ _ _ _ _ _ - - _ _ _ _ _ _ _
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y (Closed) URI 327, 328/87-30-08, Heatup. Rate 'Jpe'cified in TS 3.4. f' f ' Consistent With TS Figure 3.4-2. , TVA, WR:bliged general operatirq$ 3
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instruction (GOI) G0f-1 and GOI-2, plant startup from cold shutdown to'hnt standby, dated Auguqt 6,1987, and plant startup from hot standby to ,
,! minimum load, dated August 5, 1987, respectively. These procedures limit the heatup rate to 60 degrees fahrenheit (60 F) in any one' hour perio '
Surveillance instruction (SI)-1f?,i RCS and Pressurizer Temperacjre and f
, ' Pressure Limits, il being rarised to reflect the 60*F heatuk rde in any \
one hour period. t This item is closed based on the fact that'th licensee '
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is administrative y limiting the heatup rate to 60 F until the r inconsistency WW the TS can be resolve This item is close t ,'
(Closed) URI 327, 328/86-11-06, Evaluation of Reactor Trip Breaker TRTS)
Shunt Trip Modification Using Actual Plant Parameters. The licensee's evaluation of the RTB shunt t ip modification using act al plant values is docuraentad in quality information release (QIR) EEL'87?.34 dated F
' February 26, 1?d7. This item is close f ,
y (0 pen) VIO 327, 32.8/86-63-01, 02, 03, Loss of Special Hoclear Mater 41 (SNM), TVA/R. L.Gridley-NRC, Nelson Grace letter LM-861031-816, t
V October 31, 1986, reported a loss of 11 items of SNM lin-core (.hambers
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used for flux mapping) and committed to verification and dopumertatir.,n of i
- the missing detectors. Sequcyah Nuclear Plant was given 3 violstions in ;
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- NRC report 50-327, 328/86-63 on December 9,1986, for failure tc control The TVA response to the violations submithd or.s Varuary 8,1987,
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SN confirmed the results of the phyMcal inventory which sMwed 11 detectors were not accounted for and stated 4he detectors were believed to be in the hii;vlevel radwaste storage area. Corrective action included writing a new' procedure and impleurting a detailed method for .nattrial control and I- ; accountability for all SNM '(excluding nuclear fuel). Nuclear fuel is
controlled ueder TI-1, SM Control and Accountability System. TI-101, SNM (other than Muclear Fuel) Control and Accountability System, was issued on January 30, JfB7, and a second inventory was conducted during February / 5-18 i 1987. A13 SNM (excluding nuclear fuel) was inventoried with rouM documented on T-101, Attachment 3, Inventory Cover Sheet, dated Februath 24, 1987. The results: showed all non-fuel SNM was accounted for eteept f5 the 31 detectors. The 11 detectors were declared lost with some assurance,that they had been transferred to the high level radioactive waste storage area. The, February 24, 1987 inventory reflected the loss and deletes the 11' detectors from inventory records. Completion of corrective acticin was "epcrted to NRC in TVA letter L44-870323-808, TVA, R. Gridley/NRC, Stewart Ebneter dated March 23, 1987. Long term inventory of the" high radioactive waste storage area is a long term commitment item identified in the licensee's corporate commitment tracking system under item NC086047500 These items remain open pending Region II review of generic applicatio (Closed) VIO 327, 328/86-56-C1, Diesel Generator Building Exhaust Line Support NRC inspectors have reviewed the March 23, 1987 TVA respor.se to the violation and the corrective action take Non-conformance report (NCR) SQNCEB8301, revision 1, documents calculations and analysis to
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i support qualification of the eight diesel generator exhaust line The NRC concluded the installed design is acceptable and no hardware 1 modifications were necessary. This item is close !
(Closed) URI 327, 328/86-73-02, Adequacy of Condition Adverse to Quality (CAQ) Reviews with Respect to Generic Applicability. NRC report 327, 328/86-73 listed concerns with the adequacy of CAQ reviews in the aret of
\ generic applicability relative to procedure EN-DES-EP 1.2 EN-DES-EP-1.26 was superseded by OEP-17, Corrective Action, which was subsequently replaced with nuclear engineering procedure (NEP)-9.1, Corrective Action. NEP-9.1, Corrective Action, revision 2, provides guidance for performing a generic applicability review for department of nuclear engineering (DNE) CAQs. Administrative Instruction AI-12 (Part I), revision 2, Corrective Action, includes guidance for conducting generic reviews of CAQs initiated by the Office of Nuclear Power, the
! Division of Power System Operation, and Power Store Two examples of i
potential problems discovered prior to implementation of the revised instructions were the use of insoluble glue for purge dam installation and the lack of seismic criteria for field routed schedule 160 piping less than 2-inches in diameter. Weld process instructions requiring purge dams at Sequoyah specify the use of soluble glue, "disolvo tape", and 'disolvo papw" for purge dams. Installation of field routed schedule 160 piping less than 2-inches at Sequoyah is governed by CEB Report 80-5, dated August 1976, Alternate Analysis Criteria. This item is close (0 pen) URI 327, 328/87-46-01, Justification for Non-Destructive Examination (NDE) of Component Cooling Water System (CCS) Shell Window Weld The licensee agreed in report 87-46 to provide a summary of the justification for accepting a lack of weld penetration on one window weld and changing the NDE requirements from ultrasonic testing (UT) to dye penetrant testing (PT) and magnetic particle testing (MT) on the remaining window weld A justification memorandum TVA/G. J. Pitzl, dated September 8, 1987, provided justification that the penetration was acceptable from an applied stress calculation and that crack propagation was not likely. The memorandum states that it was difficult to obtain meaningful ultrasonic examination results on the #28 window weld and UT on the remaining windows would be waived. This item will remain open pending a more detailed review and discussions of the justificatio (Closed) VIO 327, 328/86-68-01, paragraph a, section 2.1.1.2, Deficiency D-2,1-3, Procurement of Isokinetic Probes for Unit 1 and Unit 2 Radiation Monitoring Systems. The TVA response to the violation dated April 24, 1987, noted that engineering change notice (ECN) L5194 included an unreviewed safety question determination (USQD) which determined that the radiation monitors will be non-safety grad Lomponents and piping associated with the monitoring system in the shield building will be seismically qualified. Documentation to establish seismic qualification of the probes could not be locate TVA DNE completed a new seismic calculation to sipport qualification of the isokinetic probes on August 5, 198 This qualification was reviewed and appeared to be adequat This item is close _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ___
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I 5 i (Closed) VIO 327, 328/86-68-05, paragraph d, section 2.4.15, Deficiency
- D-2.4-17, Support for Rerouted Chemical & Volume Control System (CVCS)
lines. NRC Inspectors reviewed the July 16, 1987 TVA response to this portion of the violation and the corrective action take Work plan (WP)
11277 (ECN L6231) rerouted two CVCS lines to eliminate interference with ;
new motor operators. One support was not located in accordance with the !
drawing specification tolerance. Field change request (FCR) 5788 was j issued to correct field and design errors in dimensions. The FCR resulted i in field walkdowns to verify the adequacy of the installatio The installations were verified adequate in WP 12594. The drawings are at drawing control and in the process of being updated. This item is close (Closed) VIO 327, 328/68-07, paragraph a, section 2.3.1, Deficiency D-2.3-1, Diesel Generator Lube Oil Soakback Pump Mountin NRC inspectors reviewed the July 16, 1987, TVA response to this portion of the violation and corrective action taken. Condition adverse to quality report (CnQR)
SQP870948 was written based on the inspection item that WP 9994 installation drawings did not specify the method, configuration, or material for mounting new motors to the foundation. The installation was completed in 1982. A category "A" FCR 5566 has been issued under ECN L5451 that will evaluate the installation and correct the installation drawing This item is close (Closed) VIO 327, 328/86-56-C.2, Untimely Resolution of Nonconformance Reports Indicating That Class B Systems Designed by Alternate Analysis May Not Meet Seismic Design Requirements. The specific technical concerns related to non-conformance reports (NCR) SWP8215 and SWP8222 are being addressed through TVA's alternate analysis review program described in the Sequoyah nuclear performance plan (SNPP). The unit 2 short term (restart)
phase of the program has been completed. TVA's actions will be evaluated by NRR and a safety evaluation report (SER) will be included in the overall SER for the SNPP. The generic aspects of this violation, the lack of prompt and proper corrective action, determination of deportability and effects on system operability, will be addressed by TVA through responses to NRC order (EA) 85-49. The NRC evaluation of TVA actions related to t
this order will be documented by a separate inspection report. Because the issues contained in this violation will be addressed by NRC's evaluation and closure of broader, but directly related issues, and that the specific startup required corrective actions are complete, this item is close (0 pen) Deviation (DEV) 327, 32S/86-11-05, Failure to Establish a Formalized Trending Program for Reactor Trip Breakers. NRC inspection report 327, 326/87-54, identified three concerns to be resolved by TV These concerns were, (1) the lack of a sigr.ature on preventive maintenance (PM) documents attesting to the review and acceptance of trend data, (2) the lack of evaluation guidance or acceptance criteria for trended parameters and, (3) the recording of only as-found breaker dropout voltages after lubrication values. A review of subsequent TVA actions was performed. The PM's have not yet been formally revised to address the above concerns. TVA has issued revision 3 to MI-10.9.1, Reactor Trip
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Switchgear Inspection, to incorporate changes from the latest revision of the Westinghouse maintenance program manua The inspector. reviewed this procedure revision and identified numerous additional concerns. In a number.of areas there were discrepancies between the procedure and the manual; inspections or tests not performed, the procedure was not as specific as _the. manual and procedure acceptance criteria was unclear and in one case .less conservative than specified in the manual (trending of undervoltage trip assembly (UVTA) dropout- voltage- tests). The pre-lubrication (as-found) dropout voltage tests, that previously were.not being trended, have now been deleted from the procedure. Numerous typographical errors existed in the new revision. These problems, are indicative of an inadequate technical review, and are similar to those
. identified as a part of violation 327, 328/86-11-04 related to the original reactor trip breaker maintenance instructio The maintenance procedure addresses replacement of the UVTA after 5 years, i based on a calculation of trip cycles versus the vendor's recommended life-cycle replacement schedule. The shunt trip ' attachment (STA)
replacement schedule in the technical manual. is the same as for the UVT However, no cycle or time-based schedule for replacement of the STA is specified in the SQN maintenance progra Procedure MI-10.9.1 and the Westinghouse maintenance manual provide for the periodic (18 months) inspection, cleaning, lubrication and testing of reactor trip switchgear (inside of the breaker cabinet) as well.as the breaker assemblies as component The PM program, however does not apaear to provide positive controls such that each cabinet receives the requi red maintenance in the event of installation of spare breakers or switching of breakers between cabinets during troubleshooting activities. The licensee stated that procedure MI-10.9.1 would be revised to resolve the remaining concerns noted above. Pending satisfactory completion of these actions, this item remains ope (0 pen) VIO 327, 328/87-42-01, Failure to Perform 10 CFR 50.59 Safety Evaluation for Revision 3 to the FSAR on Hydrogen Analyzer Accurac Specific corrective action and steps taken to prevent recurrence have been evaluated and deemed acceptable in NRC inspection report 327/328-87-4 Additional corrective action by TVA prior to startup was an evaluation of past final safety analysis report (FSAR) revisions to verify that proper unreviewed safety question determinations (USQD) had been performed or that no unreviewed safety questions existe TVA determined tr.at amendments to only FSAR sections 3,6, 7.1, 8.1 and 15 had a reasonable probability of having been issued without proper USQD's j Three USQDs, comarised of 44 separate safety reviews, were performed by !
TVA which determined that no unreviewed safety questions existed for these changes. The inspector reviewed TVA's USQDs and discussed specific safety
, evaluations with responsible engineers. TVA's corrective action on these items appears to be adequate. However, due to the large number of new safety evaluations that had to be performed on the five FSAR sections, the
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inspe-tor considers that the decision to limit the scope of this review to
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these sections should be reassessed. Pending further review of- this ]
question by the hRC, this item remains ope j (Closed) URI 327, 328/87-23-03, Inconsistent Safety Classification of Instrumentation. This item related to inconsistencies and errors in site procedures and drawings with regard to which instruments were safety-related and which instruments would be required in case of a design basis seismic event. To preclude inconsistencies between procedures, Division of Nuclear Engineering (DNE) performed a comprehensive _ review of drawings to identify the instruments required to be inspected and evaluated prior to unit startu This review was detailed and documented in calculation SQN-ISL-00 This listing was used to implement corrective actions to SQN-CAR-87-14. The inspector reviewed this calculation and considers this corrective action to be adequate. The issue of the inconsistency regarding
" safety-related" instruments is being addressed as part of a major effort to revise or replace the critical systems, structures and components (CSSC) list of SQA-134. This will be evaluated and tracked through 327, 328/87-52-02 (Example c.). This item is close (0 pen) URI 327, 328/87-26-01, Medium Voltage Circuit Breaker Sizin The NRC, through the review of TVA calculation SQNAPS 008, Short Circuit Study Medium Voltage System, determined that the 6.9 kv shutdown and-unit board circuit breakers are under-rated for the available symmetrical-fault current. This determination has been documented in a technical evaluation report dated March 23, 1987, and on the associated safety evaluatio TVA's management has been aware of these deficiencies since 198 However, disposition of these deficiencies in accordance with the requirements of NRC order EA 85-49 was not undertaken until December 24, 198 The disposition of the deficiencies associated with the shutdown boards is inconclusive; however, there is an ongoing review of this issue i by the office of special projects (OSP).
A technical evaluation report (TER) prepared by SAIC on March 23, 1987, stated that the fault interruption capabilities of the 6.9kv unit and shutdown boards are undersized for the available short circuit currents and do not conform to the industry standards. The electrical instruments-tion and control systems branch / division of pressurized water reactors (PWR) licensing-A prepared a safety evaluation report (SER) dated April 2, 1987. TVA's answer to the SER dated August 7,1987, agrees that the unit board breakers are undersized and has committed to develop a schedule to correct the current problem for the 6.9 kv unit board load breakers after unit 2 restar TVA, however, has determined that the size of the shutdown board breakers is adequate. This determination is based on tests performed by the breaker manufacturer which has shown that the breakers are capable of interrupting the available current. However, the manufacturer will not
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certify the breaker to this value. The NRC division of TVA projects, OSP l
1s currently evaluating TVA's answer to the SER. Pending the results of this evaluation, this item remains ope ,
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(0 pen) VIO 327, 328/86-49-01, Inadequate Corrective Action'for Upper Head Injection.(UHI) Isolation Valve Surveillance Failures; Possible Escalated
- Enforcemen The NRC responded on October 23, 1986, to TVA's letter-(Domer/ Grace) of August 19, 1986, and agreed with TVA that the portion of violation 86-19-01 concerning UHI hydraulic lock release valves, was inappropriately written against configuration control and withdrew'that portion.of the violatio The hydraulic lock release valves are used to adjust the stroke time of the UHI system isolation valves. In researching TVA's response to 86-19-01, the NRC discovered that Sequoyah has had a repeated history of failed UHI isolation valve response time surveillance (20 of 24 failures between 1981 and 1985). Although physical security of the hydraulic lock release valves-(as discussed in the response to violation 86-19-01) may not be a problem, it is possible that their throttle positions are changing due to system vibration during UHI isolation valve response time testing. Subsequent to: violation 86-19-01, the NRC identified that the Sequoyah UHI hydraul.ic lock release valves are equipped with a set screw type. mechanism that is used at other plants of the same design to prevent inadvertent. stem movemen Sequoyah was unaware of the existence of these set screws until notified by the NR The cause of the repeated UHI isolation valve surveillance failures were not adequately determined by TVA and corrective action was not taken to preclude further failure Inspection report 327, 328/87-37 states that TVA's corrective actions to ensure the set screws are tightened following adjustment of the UHI response time setting is satisfactory in that TVA has initiated a change to 51-196, Periodic Calibration of Upper Head Injection System Instrumentation, that ensures the locking set screw is tightened. The Inspector has determined that corrective actions to date
, are sufficient to support unit 2 restart, with respect to the UHI set screws. .However, the escalated enforcement aspect of this issue requires that the item remain ope (Closed) URI 327,328/87-08-05, Cable Tray Jumper Concern Paragraph 5, section 8, of the report details documented concerns that cable tray jumpers did not incorporate the use of a conduit. TVA memo from J. R. Hopson, Supervisor, electrical engineering unit, SNP; to R. M. ' Pierce, 315 LB-K, dated February 19, 1976, states, in part, that power cables can be run four and one-half feet horizontally and vertically unprotected between cable tray and conduit. The only exception to this allowance is a cable run in the cable spreading roo Cable "2V2451A" and the cable trays involved consist of two parallel runs less than one foot apart on a horizontal plane, with one tray having a second tray connecting at the point of cable re-entry. This accounts for the three
, (3) tray designators being used for the cable run, and meets the requirement for unprotected cable jumpers per memo to G. G. Stac This item is close (0 pen) URI 327, 328/87-50-03, Containment Spray Pump. During an-inspection documented in inspection report 327, 328/87-50 the inspector _ _ - _
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opened an unresolved item to track the past operability of both trains of -
containment spray (CS) for bcth units. Specifically, CAQR 3QP870860 was issued by the licensee to document the fact that the preoperational test for the CS pumps was not satisfied, in that, the pump head may not be adequate to provide the required system flow. The CAQR stated that preliminary analysis indicated that although the preoperational test for pump performance was not satisfied, the impact on containment integrity .
was minimal. Initially, the deportability of this CAQR and supporting gotential reportable occurrence (PRO) report was determined to be indeterminate." The CAQR was later determined, af ter approximately 2 months of engineering evaluation, to be reportable. The inspector determined that the licensee would have resolved this technical issue prior to plant restart. However, the use of indeterminate for situations --
where the licensee knows that a value used in TS and FSAR accident .'
analysis can not be satisfied by installed equipment is questioned. This issue was discussed with the licensee in a management meeting conducted on September 24, 198 As part of the resolution of the above CAQR, the licensee performed ..~ .
special test instruction (STI) STI-65, Containment Spray Pump Performanc The intent of the test was to reestablish a pump performance curve and verify that pump performance is adequate to provide the needed system flow. Additionally, this test was to measure actual heat exchanger
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differential pressure (DP) and compares it to the value of 10 psid used to size the pum Due to problems with installed flow instruments (ANUBAR),
the licensee has had to resort to the use of ultrasonic flow instruments ^~
during testing. The test results of STI-65 indicated that the 28 pump satisfied the manufacturers pump performance curve. However, the 2A pump failed to provide the required flow during testing. It was later determined that the ultrasonic flow instrument used during testing of the 2A pump failed it's post use calibration. A second test was performed using another ultrasonic flow instrument and again the pump flow curve failed to satisfy the pump head curve; however, on the second test the pump did deliver the required 4750 gpm minimum flow. A CAQR was issued to document the pump failure. Currently the licensee is evaluating the test results against new flow values which are being developed. Prior to accepting the current condition the licensee was asked to address the following inspector concerns:
c Does the manufacturer agree that the pump performance is acceptable a.1d not indicative of a possible pump failure? Since the installed flow instruments (ANUBAR) are not providing reliable readings, will correction factors, developed from testing, be used to scale the control room indication? What modifications are planned to either replace or relocate the installed instruments to eliminate the error associated with turbulent flow created by the elbow which is only approximately 1 pipe diameter downstream of the flow element? , How will TVA ensure that the newly established heat exchanger DP does not change and what additional margin will be added for fouling?
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The above concerns were discussed during a management meeting on September 24, 1987, and the exit interview on October 6,1987. During these discussions, the licensee committed to the following: Provide accident analysis with degraded flow condition to determine impact on containment pressure and temperatur . Perform an engineering evaluation of the test results for CS pump 2-A l and verify that test data is not indicative of possible pump failur !
This evaluation may involve discussion with the pump vendor if necessar Discuss further with NRC the need to scale control room indication using previous test result Review the location of the ANUBAR flow instruments and evaluate the possibility of any needed modification Verify heat exchanger DP during each SI or American Society for Mechanical Engineers (ASME) Boiler and Pressure Vessel Code section XI testing.of the pump, and add an acceptable fouling facto This item is still considered unresolved pending implementation of the above commitments. The inspector only considers items b and c above to be heatup issue (Closed) URI 328/86-62-08 and 327/86-62-01, Containment Hydrogen Analyzer Operabilit During an inspection conducted November 12-21, 1986, (IR 327, 328/86-62) the inspector identified several, as installed conditions, that could have affected the operability of the containment hydrogen analyzers. At the conclusion of that inspection, NRC Region II, Division of Reactor Safety (DRS), requested the office of Nuclear Reactor Regulation (NRR) to evaluate the identified conditions and determine if the as installed system satisfied 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 information back to NR The following excerpt from inspection report 327, 328/86-62, is provided as background information:
[During the review of modifications to the H2 analyzer, the inspector noted problems with the initial installation of the H2 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 Pla 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 within the containment and the containment dome a true indication will be gien of the hydrogen concentration within containment. The snalyzers are calfbrated to measure hydrogen concentration between zero and ten
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The field installation of the H2 monitors.for both Units 1 and 2-did i not implement the vendor (Consip Delphi, Inc.) requirements regarding sample lime slope and insulation. The failure- to properly route and .
insulate the: sample lines results in the condensation of moisture for I the containment post accident H2 sample 'in-route to the detecto ~
This installation can create two potential problems: (1) water traps present a tortuous )ath for the H2 gas to reach the' detector although the vendor did ind'cate, 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 lon as actual containment moisture !s greater than that the detector sees. The vendor indicated that the reading could be higher than actual' by as much as a factor of 5 although TVA-analysis, performed at the inspector's request, indicated a lesser error. These inaccuracies. appear to be in the conservative direction; however, 1 decisions based on the H 2 indications are not conservative, Specifically, Sequoyah function restoration guidelines FR-21, -l 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
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is greater than 6L These actions, if based on erroneous high Hr indication, would be non-conservative and may result-in post accident complication 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 Final -Safety Analysis Report (FSAR), the described accurac.y 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 NRC and TVA have attempted to resolve the H 2 analyzer operability issue. Additional information has been requested from TVA during numerous telephone calls with OSP. TVA was requested to consult their vendor, (Consip Delphi) as to the acceptability of the installed system regarding line slope (i.e. ,
water traps) and lack of insulatio The OSP reviewer indicated to TVA i that the instrument accuracy issue may be acceptable provided that the i 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 trap ,
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The vendor provided supplemental information regarding water traps to TVA 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 five (5) or six (6) faet. Greater vacuum will adversely affect the addition of reagent and calibration gasses making 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: Details of the January 13, 1987 Consip-Delphi letter Information that indicated the worst water trap in the sample lines did not exceed four (4) feet That the analyzer is not calibrated during an accident 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 mod ,
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 of containment. The results of this walkdown indicated that the worst water trap outside containment was five (5) feet instead of the four (4) feet claimed in item (b) 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, DNE design personnel indicated that they had not considered the portion inside containment as a potential problem, as they felt that temperatees in the area of the sample line would prevent moisture from condensing i' the lines. During further discussions with DNE personnel they indicated that a Westinghouse analysis of containment temperature post LOCA indicated that their assumption may not be correct in the area where the sample lines run near the containment air return fan The inspector requested that TVA walkdown the rest of the inside containment installation and provide a sketch showing sater traps and tubing installatio This walkdown identified several installation problems. 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 include valves specified on the drawing, and were also found with the lines uncapped. These two discrepancies were documented on conditions adverse to quality reports (CAQR) SQP 870430 and SQP 870431 and were evaluated for report bility 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 ir 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 }
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being able to provide a representative sample of containment H*
concentratio The walkdown also 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 meet the design requirements for the system, in that train A could not measure upper containment concentration and both trains had water trap problem DNE engineers are currently working on a design change to modify both trains of containment H2 analyzers to reduce the water traps to acceptable values and to rerun 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 questioned whether this location will provide a truly representative sample as to containment dome H2 concentration as stated in the original design and as currently stated in the FSA The above stated problems with the sample lines for train A of containment H2 analyzers resulted in the equipment being inoperable since installation. TVA performed an analysis of the original train B installation and determined that although the water traps exceeded the vendor's limit, containment temperature in the area of the traps should prevent condensatio TS 3.6.4.1 requires in the action statement that, "with one hydrogen monitor inoperable, restore the inoperable monitor to OPERABLE status within 30 days or be in at least H0T STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />".
The TS further requires in section 3.0.3 that, "When a Limiting Condition for Operation is not met, ... , within one hour, action shall be initiated to place the unit in a MODE in which the Specification does not apply".
The containment hydrogen monitors are required by section 3.6.4.1 of the i TS to be operable in modes 1 and Contrary to the above TS requirements, train A of containment hydrogen monitors has been inoperable since installation with the reactor in modes 1 and 2 without complying with the requirements of the action statemen This item is identified as violation 328/87-60-0 Although the inspection has concentrated only on unit 2, similar conditions may exist on unit I and this will be tracked under URI 327/87-60-0 (Closed) URI 327, 328/87-30-10, Auxiliary Feedwater (AFW) Pump Modifications. In 1984, TVA implemented ECN L 5342 to replace the Unit 1 and Unit 2 motor driven AFW pumps' pressure control valves with cavitating venturis. Justification for this modification was documented in an unreviewed safety quest 1on determination dated April 25, 1983. This modification resulted in increased system flow resistance which required a change to the pumps' minimum test act.eptance value of 1397 PSID specified in TS 4.7.1.2. Related Post Modification Testing indicates that with the
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increased flow resistance, AFW pump 2A-A could no longer provide the 440 gpm flow rate defined in the associated TS basis as a margin of safet This reduction in flow of-the 2A-A pump not only required a change to the TS minimum test acceptance value, but also constituted an unreviewed safety question as defined by 10 CFR 50.59. The licensee accepted this degraded tiow condition as documented in an unreviewed safety question determination dated November 1, 198 Following the modification, both of the units were returned to power operation (Unit 1 in April 1984 and Unit 2 in December 1984) without ever changing the TS or receiving prior Commission approval. The units operated in this condition until August 1985, when they were shutdown for environmental qualification reasons. This is in violation of 10 CFR 50.59 ,
(VIO 327, 328/87-60-02). UNI 327, 328/87-30-10 is closed based on the issuance of this violatio (Closed) VIO 327, 328/86-68-01, paragraph a, section 2.1.1.3, Deficiency D-2.1-3, Procurement of Isokinetic Probes for Unit 1 and Unit 2 Radiation Monitoring Systems. The TVA response to the violation dated April 24, 1987, noted that ECN L5194 included an unreviewed safety question determination (USQD) that the radiation monitors will be non-safety grad Components and piping associated with the monitoring system in the shield building will be seismically qualified. Documentation to establish seismic qualification of the probes could not be located. DNE completed a new seismic calculation to support qualification of the isokinetic probes on August 5, 1987. This item is close (Closed) VIO 327, 328/86-68-05, paragraph d, section 2.4.15, Deficiency D-2.4-17, Support for Rerouted Chemical and Volume Control System (CVCS)
Lines. NRC inspectors reviewed the July 16, 1987, TVA response to this portion of the violation and the corrective action take WP 11277 (ECN L6231) rerouted two CVCS lines to eliminate interference with new motor operators. One support was not located in accordance with the drawing specification tolerance. FCR 5788 was issued to correct field and design errors in dimensions. The FCR resulted in field walkdowns to verify the adequacy of the installation. The installations were verified adequate in WP 12594. The drawings are presently t'eing update This item is close (Closed) VIO 327, 328/86-68-05, paragraph d, section 2.4.18, Deficiency D-2.4-19, Diesel Generator 1A-A Installation Drawing Discrepancies. The July 16,1987 TVA response to this portion of the violation and the corrective action taken was reviewed. FCR 5566 was written to address the noted installation / drawing deficiencies. The revised drawings were sent to DNE for issue on September 2, 1987. Work requests were issued and have been completed to correct the 4 disconnected or loose hangers that were noted. This item is close (0 pen) VIO 327, 328/86-68-05, paragraph a, section 2.4.10, Deficiency D-2.4-12, Vital Battery V G6ps Between Foundation and Battery Racks. NRC inspectors have reviewed the July 16, 1987 TVA response to this portion of {
the violation and corrective action taken to date. TVA caution order 1606 i was written on September 1,1987, to prevent the use of vital battery V as
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a TS supply to battery boards I, II, III or I The caution order is required to remain in effect until correction of this item and allows the item to be classified as a non-startup item. The inspector considers removal of vital battery V from safety related functions to be sufficient i for restar This item will remain open pending review of final i corrective tction for the return to service of battery (0 pen) VIO 327, 328/86-68-05, paragraph a, section 2.4.10, Deficiency D-2,4-13, Vital Battery V Minimum Bend Radius Violation. NRC inspectors have revievad the July 16, 1987 TVA response this portion of the violation and correc Le action taken to date. TVA caution order 1606 was written on September 1, 1987, to prevent the use of vital battery V as a TS supply to battery boards I, II, III or I The caution order is required to remain in effect until correction of vital battery room V deficiencies identified in NRC inspection report 327, 328/86-68. This caution order will allow the bend radius violation to be classified as a non-restart item. This item will remain open pending NRC review of final corrective actio (Closed) VIO 327, 328/86-68-05, section 2.4.17, Deficiency D-2.4-18, Anchor Pull Records for Diesel Generator Building, HVAC Duct Support WR 8211949 was written and completed to perform anchor pull . tests on baseplate anchors of support 17A910-2-12 which was installed by work plan (WP) 12190. The WR tested and documented satisfactory results for all four baseplate anchors. Licensee action on this deficiency is satisfactor (Closed) VIO 327, 328/86-68-05, section 2.4.3, Deficiency 0-2.4-4, Modification WP 11912 Deficiencies on Pressure Transmitters 2-PDT-30-42
- and 2-PDT-30-4 NRC inspectors conducted a field inspection to verify that all discrepancies had been corrected. Work requests had been written and completed which corrected bolt engagement deficiencies on transmitter mounting plates, a missing hanger on 2-PDT-30-42, loose conduit connections, and loose transmitter supply tubing. This item is close (Closed) VIC 327, 328/86-68-05, section 2.4.2, Deficiency D-2.4-3, Modification WP 11554 Deficiencies on 2-PDT-30-44. NRC Inspectors conducted a field inspection of pressure transmitter 2-PDT-30-44 and verified that all conduit connections were tight and that the thread engagement problems on the transmitter mounting plate to panel had been corrected. Licensee action on this item is satisfactor (Closed) VIO 327, 328/86-68-05, section 2.3.4, Deficiency D-2.3-4, Feedwater System Pipe Hanger in The East Valve Room. The licensee cancelled the incorrect "as constructed" drawing 47A053-485 for the hanger in question and issued new drawings 47A400-17-6 and 47A400-17-6A to depict the hanger installation. NRC Inspectors conducted a field inspection and found the hanger to be in accordance with the drawin This item is close (Closed) VIO 327, 328/86-68-05, section 2.4.1, Deficiency D-2.4-1, ERCW Pipe Restraint 37A206-1-7 Deficiency and ERCW Pump R-A and Q-A Weld )
Deficiencies. Instruction change form (ICF)87-713 implemented a change I l
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to WP 12250 on pipe restraint 37A206-1-7. The ICF also implemented corrective active on weld deficiencies on ERCW pumps R-A and Q- Corrective action was completed on June 9, 1987. Licensee action on these items is adequate. This item is close (Closed) VIO 327, 328/86-68-07, section 2.3.2, Deficiency D-2.3-2, WP 1119 Technical Instruction (TI) 41-68 has been revised to incorporate changes that were required as a result of modifications accomplished under WP2229 This item is close (0 pen) VIO 327, 328/86-68-07, section 2.3.6, Deficiency D-2.3-6, Feedwater System Support Installation and Drawing Deficiencies. CAQR SQP871047 was written to address problems with feedwater system supports. CAQR corrective action generally explains that calculations support the actual installation and that the actual installation was agreed upon by the design and modification engineers. The CAQR does not address: (1) why modifications not in accordance with design drawings were installed and accepted, (2) why changes to the drawings were not processed at the time of installation, (3) what changes to the program will be made to prevent reoccurrence, and (4) when correct drawings will be issued to support the installation. This item will remain open pending NRC review of all corrective actio . Unresolved Items Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve violations or deviation Three unresolved items were identified during this inspection, and are identified in paragraphs three and fiv . Operational Safety Verification (71707) 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 followup activities and prioritization of work was accomplished by the license 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 condition .
i In inspection report 87-54 the inspector discussed six apparent discrepancies in the as-constructed configuration of the polar crane wall penetrations on unit On September 16, 1987 the licensee '
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issued CAQR SQP 87-142 This CAQR addressed the six discrepancies plus other penetration sleeves. The recommendations section stated,
" Sleeves located in the crane wall should be inspected and verified they are designed and sealed per the design drawings. The seals should be inspected for damage or deterioration." The CAQR will be reviewed for corrective actions and to determine operability of the mechanical sleeves. This item is considered unresolved and will be tracked as URI 327, 328/87-60-0 No violations or deviations were identifie b. Safeguards Inspection In the course of the monthly activities, the inspectors included a review of the licensee's physical security program. The performance of various shifts of the security force was observed in the conduct of daily activities including protected and vital area access controls; searching of personnel and packages; badge issuance and retrieval; patrols and compensatory posts; and escorting of visitor In addition, the inspectors observed protected area lighting, protected and vital areas barrier integrity. The inspectors verified an interface between the security organization and operations or maintenanc Specifically, the resident inspectors: interviewed individuals with security concerns, inspected security during outages, reviewed licensee security event reports, visited central or secondary alarm station, verified protection of safeguards information, and verified onsite/offsite communication capabilitie On September 29, 1987, the resident inspector became aware of a possible security issue which required licensee action. As a result of interaction with the licensee several security issues became evident. The content of these issues is considered safeguards information which was relayed to NRC Region II for resolutio This issue will be tracked as URI 327, 328/87-60-0 No violations or deviations were identifie c. Radiation Protection The inspectors observed health physics (HP) practices and verified implementation of radiation protection control. On a regular basis, radiation work permits (RWPs) were reviewed and specific work activities were monitored to ensure the activities were being conducted in accordance with applicable RWPs. Selected radiation protection instruments were verified operable and calibration frequencies were reviewe No violations or deviations were identifie . _ _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ -
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! Monthly Surveillance Observations (61726) f The inspectors observed / reviewed TS required surveillance testing and verified that testing was performed in accordance with adequate procedures; that test instrumentation was calibrated; that LCOs were met; l that test results met acceptance criteria requirements and were reviewed by personnel other than the individual directing the test; that i deficiencies were identified, as appropriate, and that any deficiencies 1 identified during the testing were properly reviewed and resolved by
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management personnel; and that system restoration was adequat For complete tests, the inspector verified that testing frequencies were met and tests were performed by qualified individual I The inspector observed a portion of SI-166, Summary of Valve Tests for ASME Section X In particular the inspector witnessed a portion of the valve stroke time testing associated with pressure control valve (PCV)-
1-5, steam generator (SG) #1 power operated relief valve, and PCV-1-30, SG #4 power operated relief valve. No discrepancies were noted with the portions of the SI observe On September 24, 1987, the inspector observed portions of SI-240, Functional Test of Control Room Intake Chlorine Detection System, in progres The procedure appeared to be adequate. The technicians were i following the procedure and appeared to be knowledgeable. During the '
performance of this SI the plant experienced an inadvertent control room isolation as described in paragraph 10 of this report. The performance of 1 this SI was halted until operations personnel determined the root cause of the event. The test then proceeded without inciden The inspector observed instrument mechanics (IM) performing SI-94.5, Steam Flow Channel Calibration .for Reactor Protector System Channel II The IM crew encountered no problems during this evolutio An inspector observed the performance of portions of SI-632.1, Auxiliary Building Portion of the Containment Spray System External Leakage. The surveillance consisted of a walkdown and visual checks of all system components, valves, pumps, flanges, and fittings located in the auxiliary building that could leak. Any leakage found was to be estimated and recorded with a WR written to correct any boundary leakage or any pump seal leakage above 10 drops per minute. The surveillance was associated with the B train of the containment spray system and was performed con-currently with STI-65, Containment Spray Pump Performance. No leakage requiring correction was identified during the performance of the tes The inspector determined that excess system leakage was identified during the subsequent performance of SI-632.1 for the A train of the containment spray system. The associated WRs are in the process of being worked with the test to be repreformed at a later dat _ _ _ _ - - _ _ _ . -
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7. Monthly Maintenance Observations (62703) Station maintenance activities of safety-related systems and components were observed / reviewed to ascertain that they were conducted in accordance with approved procedures, regulatory guides, industry codes and standards, and in conformance with T The following items were considered during this review: LCOs were met while components or systems were removed from service; redundant components were operable; approvals were obtained prior to initiating the work; activities were accomplished using approved procedures and were inspected as applicable; procedures used were adequate to control the activity; troubleshooting activities were controlled and the repair record accurately reflected what actually took place; functional testing and/or calibrations were performed prior to returning components or systems to service; quality control records were maintained; activities were accomplished by qualified personnel; parts and materials used were properly certified; radiological controls were implemented; QC hold points were established where required and were observed; fire prevention controls were implemented; outside contractor force activities were controlled in accordance with the approved quality assurance (QA) program; and housekeeping was actively pursued, The inspector witnessed a portion of the work activities associated with WR 827724 The purpose of the work request was to install the flood mode spool pieces to ensure proper fit-up. The inspector observed a portion of the work associated with the installation of the spool piece between valves 0-67-529 and 0-70-615. No discrepancies were note On September 28, 1987, the inspector observed portions of the functional tasting being performed on WP 12360. This WP was a partial implementation of ECN L5841 linking fire detection panel 0-L-633 output to the control room (plant) computer. This work was being performed under an approved procedure and appeared to De adequat The engineers appeared to be knowledgeable of the wor The inspector had no further question The inspector observed maintenance activities associated with the refurbishment of the 2A-A auxiliary feedwater pump. The pump shaft, impellers and diffuser were fitted into the casing and hand rotate A high point rub was observed and the pump was removed and ^
disassembled for inspection. Diaphragm locating pins were found loose enough (by design) to allow the pin shoulders to protrude slightly as the pins tilted inside their locator hole The 4 shoulders of the pins were chamfered after conferring with the pump vendor. The pump will be reinstalled and the high point rub checked l' again. The work is being performed under WR B232398, and will be l reviewed after the pump is reinstalled and returned to servic ho violations or deviations were identified.
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1 L Licensee Event Report (LER) Followup (92700)
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The following LERs were reviewed and close The inspector verified that:
reporting requirements had been met;. causes had been identified; corrective actions appeared appropriate; generic applicability had been considered; the LER forms were complete; the licensee had reviewed the event; no unreviewed safety questions were involved; and no violations of regulations or TS conditions had been identifie 'LERs Unit 1 327/86-033, Inoperable Gas Treatment System The design contract and seismic test traceability for charcoal trays installed in certain gas treatment systems was discovered to. be inadequate by the license The inspector reviewed the licensee's corrective action which included installing qualified and traceable trays in each of the plant gas treatment systems (control building emergency air cleanup system, emergency gas treatment system, and auxiliary building gas treatment system) and upgrading standard practice SQA-45, Control of Material, Parts and Servic This item is closed 327/87-11, Failure to Perform Increased Frequency Testing of Valves in Accordance With ASME Section.XI Due to Programmatic and Personnel Error .This inspector reviewed revisions to the inservice testing ~ procedures (SI-166 series) and TVA quality assurance (QA) audit report QSS-A-87-0004 that identified the problem and discussed corrective actions with the responsible mechanical test engineer. The licensee's corrective actions appear to be acceptable. This item is close /87-18, ASME Section XI Requiren:ent to Exercise Check Valves May Have Not Been Met Due to an Inadequate Procedure Caused by Personnel Erro Previous and current issues of SI-166.16 were reviewed by this inspector and this issue was discussed with the responsible mechanical test engineers. The licensee's corrective actions appear to be acceptabl This item is close LERs Unit 2 328/87-02, Inadequate Verification of Unit 2 Containment Leak Rate Due to Installation and Personnel Error. The inspector reviewed the revision to SI-158.1 providing a complete valve lineup and a written verification of a free flow path. The work request which relocated the vent valve to conform to the drawing and completed post modification test results were also reviewed. The inspector noted that the "as-constructed" system flow diagram (47W625-2) does not reflect the correct location of 2-FCV-43-33 and thus the corrected valve lineup in the SI does not correspond with the The licensee had identified this condition and a potential
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drawing deviation has been issued. The licensee's corrective actions appear to be acceptabl I
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The following LER was reviewed and remained open:
(0 pen) 327/87-10, Revision 1, Numerous Relays, Level Switches, Cycle Timers, Load Controllers and Meters Have Not Been Routinely Calibrated Because They_ Were Not Identified in Procedures. The root cause of, this problem was determined to be a lack of clearly defined departmental responsibilities for calibration of certain instrument Corrective actions were to calibrate all instruments (prior to unit restart for those determined necessary for operation), development of procedures to perform scheduled routine calibrations and consolidation of calibration responsibility details and instrument listings into one comprehensive procedur Discus:4 ions with responsible personnel and review of documents indicates that over 650 devices did not have calibration procedure As the calibration efforts are still in progress and the correction of the root cause has not yet been completed this LER remains ope . Event Followup (93702, 62703)
On September 24,1987, at 10:57 a.m. , the plant experienced an inadvertent control room isolation (CRI). The inspector interviewed technicians' who were performing SI-82, Functional Tests for the Radiation Monitoring System (Monthly) on 0-RE-90-126 at the time. The technicians stated that they had placed the monitor in the " block" position. Then they proceeded to connect a digital volt meter (DVM) between contacts 29 and 30 (the high radiation signal relay contacts). During this process, they inadvertently touched the alligator clip which was on contact 29, to contact 2 Contacts 28 & 29 are the block relay contacts, and are in extremely close proximity. When they were inadvertentantly connected, a high radiation signal was made up and the block switch was bypassed. This gave a train
"B' CRI. Everything functioned as expected, with the exception of the associated alarms. A high control room radiation alarm was not actuated nor was the local alarm. This was caused by the lack of a true high radiation rigna Under t' , direction of the shift engineer (SE) the isolation was reset and the se pence repeated to determine repeatability. Again a train "B" CRI occur ed without alarms. This event will be further reviewed with iss ance of the LE ' a deviations or violations were identifie Inspector Followup Items Inspector followup 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 i reviewed and evaluated by the inspector. The inspector has either o resolved the concern identified, determined that the licensee has performed adequately in the area, and/or determined that actions taken by
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the licensee have resolved the concern.
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(Close'd)' IFI 327, 328/85-23-09, Pressurizer Heatup and Cooldown. The inspector reviewed reportable occurrence report 1-85-196 and conducted interviews with cognizant engineering personnel concerning the -June 15, 1985 even Since this is considered to be licensee identified and corrective actions are considered adequate, no violation is being issue This item.is-close (Closed) IFI 327, 328/86-11-03, Control of Critical Systems, Structures or Components -(CSSC). This open item concerned the licensee's control of CSSC items. This issue was identified as an area of concern in inspection 327, 328/87-52 which identified additional issues with respect to the overall control of. the CSSC component population in the plant. The control of CSSC items will be followed through those initiatives identified in inspection report 327, 328/87-52. This item is close (Closed) IFI 327, 328/86-28-10, Residual Heat Removal (RHR) Tube Leak On April 23, 1986, the inspectors observed leak testing of the 28 RHR heat exchanger. ~ This testing was being performed as a part of the overall program to find the radiological leak into the component cooling syste Technical Instruction TI-58, Leak Rate Measurements, was reviewed. The inspectors observed portions of both parts of the test. Part 1 clearly showed no sign of tube to shell ' leakage. Part 2 had no acceptance criteria in the procedure and the inspector was unsure of how this data was to be utilize Since the issuance of this item, QA issued CAQR SQP870561 addressing proper use of tis and specifically acceptance criteria for TI-58. Proper resolution of this CAQR will address all of the inspectors concerns. This item is close (Closed) IFI 327, 328/87-02-08, Possible Loss of Water from Emergency Core Cooling System-(ECCS) Recirculation Sump Area in a Post LOCA Event, and i Possible Failure of One of the Two Air-return Fans During Spraydown of the Are A potentially reportable occurrence report (PRO) 1-87-013 was issued January 10, 1987, and significant condition report (SCR)
SQNNEB8623R0 was issued to document the licensee's preliminary evaluatio As a result, ECN L6853 was issued to install additional curbs and drains in unit 2 containment to preclude possible losses of water from the ECCS recirculation sump area and possible damage to the A-A air return fa The inspector reviewed the completed ECN and supporting documentation.and determined that licensee's actions are adequate to prevent future problems of the type identified. This item is close (Closed) IFI 327, 328/86-71-07, Vendor Wiring Workmanship in 480 Volt Vent and Shutdown Boards. In October of 1986, several instances of questionable workmanship involving vendor installed wiring in several 480 volt vent and shutdown board breaker cubicles were identified by the licensee. As a result, an expanded sample of cubicles were inspected (Ref. surveillance report #21-86-S-039) and the results of this inspection were forwarded to DNE- for evaluation. Per DNE direction, MRs 8217959, l B217962, B217960, B217961 and B209099 were issued to correct five isolated deficiencies. In addition, although DNE determined that a generic hardware problem did not exist (Ref. 825-870216-037), it was strongly recommended that enhanced surveillance activity in this area would be ,
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f pruden As a result, the licensee has committed to issue a new "500 l Series" SI to require a periodic cleaning and internal wiring inspection
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of IE breaker cubicles. This SI is to be issued prior to the Unit 1 Cycle 4 outage (Ref. S53-870904-905) and is not considered a restart ite This item is close (Closed) IFI 327, 328/86-49-06, Seismic Loading of Cables and Terminations from Vertical Cable Drops. NRC inspectors reviewed TVA employee concerns program element report (ECPER) 224.5(B). This report details the review and walkdown of the main control boards (MCBs) and electrical control boards (ECBs) to determine adequacy of support for vertical cable runs in the control room and cable spreading room. For areas that were inaccessib?e for inspection, design drawings and supporting statements of personnel involved during construction were attached. This item does not address and close the sidewall bearing pressure issue due to long vertical cable drops in the cable spreading room. Licensee action on this item is adequate. This specific aspect of vertical cable drops is close (Closed) IFI 327, 328/87-11-06, ECPER, Valve Mark Number Guidance, TVA has ,
issued revision 3 to ECPER MC-40503-SQN, Valves (test 70), June 13,198 i The revision specifies the requirements and usage of value marks by Sequoyah purchasing, engineering, modifications, maintenance and quality assurance departments. Licensee action on this item is adequate. This item is close (Closed) IFI 328/86-62-12, Vital Battery Room Temperature Problem This item concerned battery room temperatures that could not be properly controlled using thermostats. The problems resulted from a combination of space heater problems, damper settings, calibration of air conditioning, j and battery exhaust fan condition. IR 327, 328/87-42 reported completion
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of WRs to calibrate air conditioning system flow switches and temperature switches and verify proper operation of unit heaters. Remaining action to be completed was the replacement of battery room exhaust fans which were out of service. WP 12571 which replaced the battery room exhaust fan motors and was completed on August 31, 1987. This item is close (Closed) IFI 327, 328/86-32-12, TI-41, Scaling and Setpoint Documen Reactor Coolant System (RCS). IR 86-32 reported discrepancies between TI-41 scaling data sheets and instrument maintenance calibration procedure IR 87-36 noted the draft revision to TI-41 addressed the errors found by inspectors. Additional errors were discovered and corrected during a TVA review of additional instruments. Revision 8 to TI-41 was issued on September 4,1987 and incorporated corrections to deficiencies noted by NRC inspectors. Scaling data sheets and calculations were reviewed for RCS loop 1 overpower delta temperature (0PDT) setpoint calculator (TY-411M), RCS loop 1 overtemperaturc delta temperature (OTOT) setpoint calculator (TY-411L), RCS loop 1 OTDT, f1 (delta Q) (Ny-411A). This item is close (Closed) IFI 327, 328/87-11-05, Incorporation of NRC concerns into ECPER CO 19201-SQN, revision 6, " Conduit". Revision 7 and 8 to the element report have been issued and incorporate NRC concerns expressed in NRC report 327, 328/86-11. Revision 7 and 8 contain requirements for the
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3 revision and correction of applicable plant procedures and documentatio This item is close (Closed) IFI 327, 328/86-28-13, Replacement of General Electric PK-2 Terminal Block Posts. Potential failures of General Electric PK-2 terminal block posts were identified by the licensee in 198 An inspection program was implemented and completed which tested all posts for potential failur A follow-on program to replace all posts of that type was implemented. Replacement of posts for terminal blocks in safety related installations was completed under WR B284695 on September 29, 198 Replacement of suspect posts for the main transformers bank 1 and bank 2 (non-safety related) is scheduled to be completed prior to plant criticality, but is considered a nonstartup item. This item is close (Closed) IFI 327, 328/86-48-02, Implementation of the Technical Support Systems Engineering Section. As of August 17, 1987, the system engineering section had fully implemented the system engineering program for the ERCW and unit 2 residual heat removal (RHR) systems. This implementation status is on track to full implementation for 33 safety related systems over a two year period in accordance with TVA commitment Position duties and responsibilities were discussed with the designated RHR system engineer. The RHR system engineer's " notebook" and draft guidelines related to system notebooks, walkdowns, testing and trending were reviewe System investigations are addressed in SQA16 Development of formal guidelines and a training program and expansion to the remaining safety related systems remains to be done. However, the actions taken by TVA to implement this program for two systems demonstrates that the foundations of the program are in place, functioning and adequate. Therefore, this item is close (Closed) IFI 327, 328/86-37-05, Followup on CAR S7-10-017 Compliance Instrumentation Review by TVA Q CAR 85-10-17 has been closed by TVA Q The inspector reviewed the QA closeout actions for the CAR and revisions to SI-1, SQE8, TI-54 and TI-54.2. The reviews, evaluations and program changes made by TVA appear to have corrected the specific and generic deficiencies identified in the CAR. This item is therefore close (Closed) IFI 327, 328/86-71-03, (SI)-484, Reactor Vessel Level Indication System (RVLIS) Periodic Calibration. The inspector witnessed the calibration of the scaling circuit for the reactor coolant system hot leg temperature (T-hot) that is used in fluid density compensation. During one step of the procedure, the instrument technicians were unable to locate printed circuit card 68-430. The card was not in the referenced instrument rack. The card had been misplaced in an adjacent rac Westinghouse technicians had installed and functionally tested the RVLIS equipment, and had apparently misplaced the car The system was being calibrated for the first time by TVA personne The above card was placed in the wrong rack following vendor modification to the RVLIS. Unit I calibration was performed by the vendor. Unit 2 calibration was performed in the shop by TVA using the Unit 1 calibration
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data to ensure post modification functionin The cards were then returned to the racks waiting calibration with unit 2 data and post modification testing. Apparently the above card was placed in the incorrect slot at this time. During the recalibration procedure (SI-484)
this discrepancy was discoverad and reported to appropriate TVA personnei.
, The card was installed in the proper rack and calibration continue The
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post modification calibration (SI) properly discovered the above discrepancy and adequate corrective actions were taken. IFI 327, 328/86-71-03 is close (Closed) IFI 327, 328/86-31-05, Review of Facility Operating License (FDL)
Conditions, and NUREG-0737 (TMI-2 Action Plan Commitments). This item specifically addressed questions concerning NUREG-0737, Item II.F.1.2. ,
Post-accident High-Range Noble Gas and Gaseous Effluent Monitoring for Radioactive Iodines and Particulat During the inspection, the licensee stated that a request would be submitted in the future to change the basic design of the monitors to provide more reliable post-accident radiation monitoring. TVA with assistance from the vendor (Eberline) his re-conditioned the Eberline post accident monitoring system for both units 1 and Water damage condensation to several detectors was corrected and a preventive maintenance program established to dry the detectors periodicall Discussions with the TVA system engineer indicated that the system has performed reliability since the reconditioning efforts in January / February 198 No plans currently exist to replace this system. IFI 327, 328/86-31-05 is close (Closed) IFI 327, 328/86-31-07, Review of a Significant Condition Report (SCR) Identified at Watts Bar. An SCR from Watts Bar Nuclear Plant (SCR WBN-MEB-8620) was reviewed by the inspectors for verification of the review process at Sequoyah. The review and actions taken by the licensee appeared adequate. The SCR described the potential for losing water from the emergency core cooling system (ECCS) recirculation sump through floor drains to the auxiliary containment sump, and from there through openings in the sump's level transmitter standpipe to the containment racewa As a result of the review performed by the Sequoyah staff, the licensee discovered a potential problem with level transmitters associated with the auxiliary reactor building sump. The standpipes supporting the level transmitters are capped with a flange which serves as the mounting plates for the transmitters. A modification to the transmitters for unit 2 involved adding a vent tube to allow air displaced by rising water in the
! standpipe to be vented to a point above the minimum ECCS sump leve This l modification was required to make the transmitters operate correctl The l
tonsmitters associated with unit I have not had this modification performed, but the transmitters appear to be operating correctly. Since I the unit 2 transmitters required a special vent, the arrangement of the standpipes on unit 1 is questionabl The licensee is presently evaluating whether the unit 1 standpipes have a vent path that is not described on their prints or work plan . _ - . _ _ _ _ _ - _ _ - _ _ _
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1 As indicated above, the unit 2 standpipe vent is properly routed to maintain the minimum post loss of coolant accident (LOCA) level in the containment sump. A CAQR to correct the problem in Unit I has been written. IFI 327, 328/86-31-07 is close (0 pen) IFI 327, 328/86-37-04, Possible Emergency Diesel Generator Overloa On June 18, 1986, the licensee reported to the NRC that the emergency diesel generators may overload thirty seconds after. a loss of off site power concurrent with a phase B isolation and a safety injectio The overload was calculated to result from the starting current of the containment spray pumps. The overload condition would cause the output breakers on the emergency diesel generators (EDGs) to open and result i loss of safety related electrical equipmen TVA has analyzed the loading sequence of the EDGs and determined that a modification to the load sequencing, by delaying the start of the containment spray pump (CSP) from 30 r.econds to 180 seconds and delaying electric board room air handling unit start until after CSP start, will allow the EDGs to reach the hot kilowatt rating before loading. By allowing the EDGs to reach the hot kilowatt rating prior to sequencing the CSP and the air handling unit on to the bus, the overload condition is avoided and diesel engine damage will not occu The inspector reviewed ECN L6715 (reduce EDGs overload), modification criteria N2-6715-1 (reduce overload on EDGs) and discussed the modification with the TVA lead engineer. New sequence timers (set 180 seconds) have been installed for the CSP and the air handling unit restart has been delayed to 220 seconds by installation of a permissive delay timer. Post maintenance test (PMT-95) tested the sequence timer (Unit 2 only) satisfactoril Surveillance instruction, (SI)-26, Loss of Offsite Power with Safety Injection - D/G Containment Isolation Test, for Unit 2 is scheduled to be performed. This modification is completed (field work)
in Unit 2. TVA stated a separate ECN would be prepared for Unit During this inspection a review of PMT-95 was conducte While conducting PMT-95 the lead test engineer discovered that the relay timer coil installed in the B train was imprope The coil installed was an alternating current (AC) type vice the required direct current (DC) typ The conduct of PMT-95 alone would not have disclosed the installation of the incorrect device. The problem was revealed due to the diligence of the engineer, who was confirming test connections for the PMT by checking resistance values (not part of PMT-95). During the resistance checks different resistance values were noted and investigation revealed the improper device installed. The test was secured and all systems returned to normal. The supervisor was notified to correct the condition. It is not clear what actions were taken to procure and install the proper devic TS change 76 has been submitted to NRR by TVA letter dated December 17, 198 This item will remain open until the requested TS change is j approved, SI-26 satisfactorily confirms the new CSP sequence time and
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electric. board room air handling unit sequences after' the CSP, and the ._
disposition of the improper delay timing. device installation is confirmed
'to be in accordance with TVA procedures. IFI 327, 328/86-37-04 remains
.ope (Closed) IFI . 327/87-11-04, Missing or Loose Instrument Line Clamps. -This item is part of on going ECPER CO 17303-SQN revision'1. An NRC inspection determined that seismic analysis calculations did not account for loose or missing clamps on instrument line supports. TVA has determined that the loose and missing clamps were due to inadequate instructions for tightening of non-high strength' bolt connections. _ The inspector has-reviewed the revision to modification and additions instruction (M&AI)-9 and drawings 47A50-17/18/18A which give instructions for tightening / ~
torquing of bolts in unistrut pipe, conduit and tubing clamp These instructions appear to be adequat IFI 327, 328/87-11-04 is close (Closed) IFI 327/87-11-02, Testing of Concrete Anchor This is part of an on going ECPER CO 11306-SQN, revision Sequoyah procedures permitted testing of installed concrete anchors with the plates installed. Contact between plates and anchor shells was questioned.by the NRC. TVA general construction procedure G-32, Bolt Anchors Set In Hardened Concrete, and Sequoyah M&AI-10, Recall of Personnel to Plant, are currently being revised. IFI 327/87-11-02 is closed since the employee concern addresses the issue and requires acceptance of resolution by the'NR . Determination of. Adequate Seismic Mounting
'This -inspection was conducted in response to URI 327,328/87-54-02 to determine the adequacy .of seismic mounting for electrical components installed at the Sequoyah Nuclear Plan The inspectors examined- a- number of plant safety syttsm panels, and'
associated breakers, : relays, and protective devices to determine the adequacy of component mountin Selected components.were then compared with TVA design documents, vendor manuals and applicable qualification test reports to determine conformance with pertinent requirements. A general examination of component quality and review of housekeeping was
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also accomplished during the inspection. The following class 1E panels and associated devices were examined during the inspection:
6.9-kv Shutdown Board 2B-B 6.9-kv Shutdown Board 1A-A 480V Shutdown Board 2Al-A 480V Shutdown Board 181-B Reactor MOV Board 281-B Reactor MOV Board 1Al-A 480V Diesel Auxiliary Board 2Al-A A general examination of the following panels was also accomplished:
125V' Vital Battery Board I 125V Vital Battery Board II
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120V AC Static Inverter 1-III l 120V Vital Battery Charger III l 480V Shutdown Board 1A2-A J Examination of Seismic Installations The examination of the selected components indicates that in general, installations have been accomplished in accordance with requirement Class IE panel mountings were examined and found to accurately reflect the requirements of approved TVA design documents with regard to weld details and bolted connections. The- orientation of relays, breakers, and other protective devices examined was in accordance with applicable manufacturers instructions, and with the exception of the observations noted below were securely fastened to associated panels or racks, cable and wire support within the control cabinets was also considered to be adequat .9-kv Shutdown Board 1A-A
Cubicle 16; Panel voltmeter is not appropriately tightened (1 bolt of 4).
Cubicle 18; Questionable mounting of auxiliary relay (0PR), on stanchion inside of control cabine * ERCW 1A-A transformer cabinet; Neutral over current relay only has a lock washe *
PZR heater cabinet, offset mounting panel; flat washer on upper screw and no washer on lower screw *
Cabinet 21, back panel; plug weld is missing on floor plat Also loose nut at insulator support plat .9-kv Shutdown Board 28-B Cubicle IB; Questionable mounting of auxiliary relay (0PR), on stanchion inside of control cabine *
Panel 18; Auxiliary relay OPR mounting is questionabl *
Panel 21, backpanel; Cable 1 PP860 A looks like oil on raychem phases A and V Reactor MOV Board 1A-1A
Cubicle 8; Agastat timing relay model 2412AD is missing a mounting screw (1 of 4).
Panel 8; Agastat relay 2412AD is missing a mounting scre _ _ _ _ _ _ _ _ _
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Cabinet 4, hack panel; One panel mounting screw is missing in the .:
bottom of the panel,
Compartment 5C; Several broken wire strands on C phase (out of breaker).
125V Battery Board I Panel 3; Mounting screws for breakers 325, 326, and 327 lack sufficient thread engagement to ensure proper attachment to pane '
480 V D/G Aux Board 2Al-A-i
Cabinet 7E1; Mounting is apparently missing on breake ;
Gen'e'ral Inspection Activities While the primary focus of this inspection was a determination of the
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adequacy of component mounting, the inspectors also examined the general quality of components' located within the selected Class 1E panels. In i general, these . items were observed to be in good condition and exhibited l installed configurations which were in accordance with site requirement However, during the inspection several deficiencies were observed, and will require additional licensee attention in order to assure the safety related components will not be adversely affecte .9-kv Shutdown Board 28-B
Cubicle 21; Medium Voltage cable IPP860A which is installed in the rear of the cubicle exhibits an " oil film" on the heat shrink of phase "A" and "B" terminations. The substance is not in accordance with the termination kit manufacturers instructions and should be evaluated to determine the nature and effect of the contaminatio & JV Shutdown Board 181-B
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Cubicle 6; A Westinghouse potential transformer, type EMP-06, is 1 leaking an oil based substance onto ECCS wiring within the control cabinet. The licensee should take steps to replace the potential transformer and determine whether the leaking substance has adversely affected safety related components in the are *
Cubicle 6; Wire bundles to a 125V DC undervoltage auxiliary relay DC i SIBIE and to fuse 1-TU3-201-DL1-B have been damaged due to heat generated from the ballast resistors located above the potential transformers ' in this cabinet. The licensee should evaluate the j extent of damage to these circuits and relocate new or existing I circuits to prohibit contact with heat generating component *
Panel 6; ' westinghouse transformer leaking oil based substance on control cables, and wire bundles to 125 V DC undervoltage Aux relay I
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DC SIB 1E and to fuse 1-FU3-201-DL1-B have insulation damaged caused i
by ballast resisters located above the potential transforme *
Compartment 11B; Center bolt in bottom of panel is missing washer *
Compartment 10B; Loose screw on Westinghouse breake *
Termination Compartments; During the review of the shutdown boards the inspectors noted a considerable amount of debris in the rear termination compartments. The licensee should initiate thorough housekeeping in this area to assure that items such as nails, washers, etc. are removed to prevent inadvertent contact with vital electrical component V DC Vital Battery Board II
- Panel 3; Cable IV1570 exhibits _ jacket damage as the result of a locally generated fire. The licensee should evaluate the extent of damage to this cable and other cables in the vicinity, and determine the fire source which initiated the damag The inspector discussed the above items with licensee management. The licensee's response involved the issuance of CAQR 87-1457 and the development of an 8 part corrective action plan. These actions are listed below: CAQR 87-1457 initiated to document resolution of identified discrepancies and document recurrence control actio Develop generic fastener procedure or modify existing plant implementing procedures based on engineering criteria which will address requirements / directions to maintain seismic qualification of electrical equipmen Evaluate and correct deficiencies identified on NRC checklis Prepare preventive maintenance instructions (PMs) to inspect and correct hardware deficiencies associated with electrical board Modify plant implementing procedures to specifically address reinstallation of hardware to ensure configuration control (SQM-2, M&AI-9,IMI-134,MI-6.20). Develop briefing lesson plan to enhance the level of awareness of craftsmen, planners, and supervision on seismic issues (configuration maintenance). Incorporate briefing material into general employee training (GET) or SQM-2 training programs.
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31 As new PMs are prepared, include in the QA surveillance monitoring progra This program will be tracked by the resident inspectors under URI 327, 328/87-54-02, and will remain open until adequate licensee corrective actions are implemented for NRC concern . Design Control /DBVP Open Items List The following list of items is a compilation of items opened by the NRC design control team. The list identifies the reports in which the items were discussed and those required to be closed prior to rer. tart of unit 2:
Item Reports Restart Comments D2.1-1 86-27,86-55 No I D2.3-1 86-27,86-55 Yes 03.2-1 86-27,86-55 No 03.2-2 86-27,86-55,87-14 Yes D3.3-1 86-27,86-55,87-14 Yes D3.3-4 86-27,86-55 Yes OSP Projects Action D3.3-5 86-27,86-55 No D4.3-3 86-27,86-55,87-14 Yes 04.3-8 E6-27 No 04.3-9 86-27 No U5.3-2 86-27,86-55 Yes OSP Projects Action U5.3-4 86-27,86-55 Yes OSP Projects Action U5.3-5 86-27,86-55 Yes OSP Projects Action 05.3-6 86-27 Yes D6.1-1 86-27,86-55 31 06.1-2 86-27 Yes D6.1-3 86-27,86-55 31 06.3-1 86-27,86-55 Yes OSP Projects Action
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06.3-3 86-27 No 08S S6-38 31 OBS OBS .3 86-45 31 08S ,87-14 No OBS ,87-14 No 085 ,87-14 No OBS No OBS OBS ,86-55 Yes OSP Projects Action OBS OBS ,87-14 Yes OSP Projects Action OBS 3.10 87-14 31 OBS 3.11 87-14 31 OBS 3.12 87-14 31 OBS 3.13 87-14 31 OBS 3.14 87-14 31 OBS 3.15 87-14 31 085 .4 86-45 31 OBS OBS ,87-14 Yes OBS OBS 5.10 87-14 31 OBS 5.11 87-14 31
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OBS 6.12 86-55,87-14 No
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OBS 6.13 86-55,87-14 No OBS 6.14 86-55,87-14 Yes OBS 6.15 86-55,87-14 Yes 085 6.16 87-14 Yes I
085 6.17 87-14 Yes 085 6.18 87-14 Yes OBS 6.19 87-14 Yes OBS 6.20 87-14 No OBS ,86-55 Yes OSP Projects Action OBS ,86-55 Yes OSP Projects Action OBS ,86-55 Yes OSP Projects Action OBS ,86-55 Yes OSP Projects Action GEN-1 87-06,87-27- Yes GEN-2 87-06,87-27 Yes GEN-3 87-27 Yes MEB-2 87-06,87-27 No MEB-3 87-06,87-27 Yes MEB-6 87-06,87-27 Yes MEB-8 87-06,87-27 Yes MEB-9 87-06,87-27 Yes l MEB-10 87-27 Yes EEB-1 87-06,87-27 Yes
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EEB-2 87-06,87-27 Yes EEB-3 87-06,87-27 Yes EEB-6 87-27 Yes EEB-7 87-27 Yes j EEB-8 87-27 Yes EEB-9 87-27 Yes EEB-10 87-27 Yes EEB-11 87-27 Yes NEB-1 87-06,87-27 Yes NEB-2 87-06,87-27 Yes
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CEB-1 87-06,87-27 Yes CE8-2 87-06,87-27 Yes CEB-3 87-06,87-27 Yes f CEB-4 87-06,87-27 Yes CEB-5 87-06,87-27 Yes CEB-6 87-06,87-27 Yes CEB-7 87-06,87-27 Yes CEB-11 87-06,87-27 Yes CEB-12 87-06,87-27 Yes CEB-13 87-27 Yes CEB-14 87-27 Yes l CEB-15 87-27 Yes CEB-16 87-27 Yes CEB-17 87-27 Yes
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l 1 Design Baseline Verification Program (DBVP) Inspection Items (0 pen) OBS 6.3, IR 327, 328/86-38, Instrument Sensing Line Walkdow This item is related to observation 5.1, Walkdown Scope. A TVA DBVP walkdown of a sample of 200 instruments identified two discrepancies with sensing line connections on heating, ventilation and air conditioning (HVAC)
system The NRC DBVP team had a concern regarding the correctness of other HVAC instrument sensing line connections and the consequences of any discrepancies on system function. TVA has performed extensive inspections related to the instrumentation determined to be required for unit 2 startup in accordance with special maintenance instruction (SMI)-0-316-6 This TVA inspection resulted in several generic CAQRs related to HVAC sensing lines, including issues such as inadequate design details fe?
classification, materials, mounting details, and tubing connectiu details. Also, numerous discrepancies between the as-installed condition and design drawings were noted. In reviewing the procedures and documentation related to this issue this inspector has the following concerns:
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SMI-0-316-61 was issued to address deficiencies identified in corrective action report (CAR) 87-14. It does not specifically require inspection of tubing configuration (other than slope) or connection points. Although the CAQRs resulting from inspections to this procedure document problems related to these attributes, there is no objective evidence that all instrument lines were inspected for the The CAQRs written against HVAC design control (871147 and 871235)
address only flow switches, temperature switches, and differential pressure indicating switches. The inspector questions whether these generic deficiencies apply to any other HVAC instrumentation installation Restart determination sheets for CAQRs 871147 and 871235 indicate that the lack of design requirements does not constitute a significant possibility of system failure and thus none of the corrective actions are required for unit restar The inspector questions whether such a broad statement can be made, considering that seismic mounting of instruments may be inadequate or that connections to process lines may be imprope It appears that more detailed and case specific evaluations of field conditions should be performed and/or documente It is not clear if the corrective actions for CAQRs 871147 and 871235 will be applied to the remainder of the safety related HVAC instrumentation installations (non startup items). These generic actions include issuance of design details, field verification of conformance, modifications as required, and issuance of as-constructed drawing Pending resolution of the above concerns this item remains ope _ _ _ _ _ _ _ _ - _ _ _ _ _ _ - _ - _ .
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I (Closed). 085 327,'-328/87-06, General-2, Conditions Adverse to Quality-Operability Determinations. Nuclear engineering procedure (NEP)- and . TVA nuclear- quality assurance manual (NQAM) part ~1, section 2.16, determined a compcnent's operability by its ability to perform its safety related function as required by the TS rather than its design-relate function. Revision 3 to NQAM part 1, section 2.16 and revision 2 to 1 NEP-9.1 now. include design criteria as a consideration for- operability j-determination. This item is close (Closed) OBS 5.3-6, 327, 328/86-27, questioned the validity of calculation <
- B43-86-0210-924, 125v DC Vital Instrument Power System Voltage Drop Study and draft calculation SQN-E2-003, Voltage Drop Study for 125v DC Steam !
Throttle Valve and Vent Fan for Steam Driven AFW Pump System, because. of unverified assumptions. If one discounted the unverified assumptions, the existing system cabling would not support voltage requirement Revision 1 of SQN-E2-003 documented the validity of the assumptions including cable length, reference to national electric code 1987.for proper wiring sizes and letters from vendors for voltage requirements of equipmen Consequently, the calculations now support adequacy of the installed cable and this item is close (0 pen) OBS 5.7, IR 50-327,'328/86-55, noted that the EDG design failed to consider failure of the load breaker to trip or the effects of delayed tripping. TVA issued ECN "L5363 to consider revision of- the closing circuit to prohibit closing of the breaker unless load shedding had occurre ECN L5363 concluded that failure of a breaker to trip on a load shed signal could overload the EDG, but no corrective action is required
.because a single failure is within the design basis. SCR SQNEEBS6206RO-
-determined that'the condition is not adverse to quality. TVA responded to observation 5.7 in' a letter to NRC, dated September 1,1987, that failure of a load breaker to operate is a single failure and no further action is required. 'This -letter is currently under NRC evaluation for restart and this item remains open pending completion of this evaluatio (0 pen)' OBS NEB-2, 327, 328/86-06, section II.4, Containment Pressure ,
Transmitter Accuracy. The following concerns were noted: (1) instrument '
accuracy, (2) instrument's use in plant emergency procedures and (3) proper containment isolation. Concern (3) has been addressed by a test performed by TOBAR, report ETR 262 on TVA customer order No. 87NLF-75076A, attached to memo B4587090425 The results show no sign of failure at 2700 PSIG. There is sufficient evidence to close concern
, (3). Concerns (1) & (2) have been addressed and TVA has agreed to look
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for an instrument with better accurac An instrument has not been identified and procedures have not been revised to incorporate these instrument Therefore, item 327, 328/87-06 NEB-2 remains ope . Part 21 Reports (Closed) P2185-04, Faulty AK and AKR Low Voltage Circuit Breakers. This item was reviewed in inspection report 327, 328/87-36 as part of open item 327, 328/86-31-0 This item is close _ _ . _ _ _ - _ _ -
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(Closed) P2185-01, Effect of Lube Oil Modification on Circulating Syste !
The inspector reviewed the part 21 report and determined that it was applicable only to diesel generators with both an AC and a standby DC circulating pump. The inspector determined that the diesel generators at Sequoyah do not have a standby DC lube oil circulating pump. This item is close . IDI Inspection Findings During the special inspection conducted August 3-14, 1987, and referenced in IR 327, 328/87-52, the inspectors determined that apparent violations of regulatory requirements existed with respect to licensee actions regarding the essential raw cooling water (ERCW) strainers and screen wash syste Specifically the automatic back-wash functions of the strainers and the automatic screen wash had been disabled without adequate review of the actions and without instituting proper compensatory measures and/or procedure changes, detailed below:
The changes made to the operation of the strainers were made without a safety evaluation being made as required by 10 CFR 50.5 *
The changes made to the operation of the screen wash system were made without a safety evaluation being made as required by 10 CFR 50.5 ;
The changes made to the operation and control of the strainers and the screen wash system were implemented by issuance of a night order, OSLA-30, Night Order Book, and OSLA-99, Auxiliary Unit Operator Duty Locations and Responsibilities, instead of through the PORC approved procedure change process as required by TS 6.8.1 and 6. The changes to the operation and control of the strainers and screen wash system were inadequate in that the compensatory measures implemented (manual, periodic back-flushing) did not include instructions to monitor their operation during accidents. Since the normal monitoring functions (high differential pressure alarms) were also rendered inoperable to control room personnel, the possibility of fouling of the strainers and/or the screens could have rendered the ERCW inoperable during such event During the inspection walkdowns referenced in IR 327, 328/87-52, the inspectors found one strainer's differential pressure indicator off scale high at 6 psid. Review of the operators' log, revealed several I other instances of high strainer differential pressure above 6 psi }
None of the logged instances were accompanied by remarks indicating that the abnormalities were noted and appropriate actions taken.
l TS 6.8.1 states that written procedures shall be established, implemented l and ruaintained covering the activities referenced in appendix "A" of regulatory guide 1.33, revision 2, February 197 Appendix "A" of regulatory guide 1.33 reouires procedures for startup, operation, and shutdown of safety-related PWR system _ _ _ _ - _ .
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Contrary to the above, changes to the operation and control of the strainers and screen wash systems of the ERCW system were implemented by a night order issued on May 16, 1986, without the proper review and without proper changes to the system operating instruction Contrary to the above, OSLA-99 was used to record safety-related plant readings, when these readings were expected to prompt compensatory actions for defeated automatic safety functions. This is inappropriate since OSLA-99 is not a PORC approved and reviewed procedur The OSLA is also not retained for plant records. Additionally, out of specification readings were recorded without any action being taken to resolve the condition. The inspectors consider that had an appropriate system operating or surveillance procedure been used to accomplish system monitoring, this situation would not have occurre These examples constitute a violation, VIO 327,328/87-60-0 CFR 50.59 states that the licensee may make changes to the facility or to the procedures as described in the safety analysis report without prior Commission approval unless the proposed changes involve a change in the TS incorporated in the license or an unreviewed safety questio Contrary to the above, changes were made to the facility as described in the safety evaluation report and to procedures without performing a safety evaluation determination that an unreviewed safety question did not exis The changes made, as described in NRC inspection report 50-327,328/87-52, changed the operation of the ERCW strainers and the screen wash system from automatic operation to manual operation. These changes were made with no safety evaluation in place prior to their implementation as required by 10 CFR 50.5 This is a violation, VIO 327, 328/87-60-0 . Restart Ter,t Program The inspectors continued their review of the restart test progra The items reviewed along with the inspectors findings are listed below: The inspector reviewed unit 2 special test instruction (STI)-77, D/G 2A-A Load Sequence Test and STI-78, D/G 28-8 Load Seouence Tes This STI documented the testing of EDG 2A-A and 28-8 to handle their l design load sequence. The major portion of STI-77 provided instructions for the installation and removal of test equipment to obtain the required test data. The main body of STI-77 was to be performed in conjunction with diesel generators 2A-A and 2B-B loss of off site power with safety injection surveillance instruction The inspector reviewed unit 2 STI-79, Plant Control System Interlocks-Rod Stop This is a new procedure to test and document specific plant control interlocks which pertain to blockage of automatic and/or manual control rod withdrawal. STI-79 is non-technical specification relate However, the topic is discussed in section 7.7 of the FSAR. A portion of STI-77, 78, and 79 review consisted of ensuring that the procedures complied with
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- Instructions. During the review of STI-77,78, and 79 no discrepancies were noted. The inspector observed the performance of a L portion cf STI-79. The inspector verified that the pretest briefing was documented, . all prerequisites. were signed prior 'to starting the procedure,- chronological test log used and that testing
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was_ accomplished in a step by step manner per the procedure. The-only discrepancy noted was during the performance of step 6.2.1, intermediate range drawer N-35 high level rod stop; the step could not be completed due to a procedural error. The test was stopped and the' applicable switches were returned to their normal position via test director verbal- orders. The fact that the switches were returned to the normal position. was not . documented in the chronological test log. .After the inspector questioned.this the test director added this information to the chronological test log along
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with verification signatures that the switches were returned to thei normal positio The inspector reviewed and observed the performance of portions of-STI-72 .and STI-74, Diesel Generators 1A-A and 2A-A Restart Test The two tests were conducted concurrently. The testing was performed-to close several function analysis report (FAR) punchlist items for the EDG. syste The testing verified the following functions:
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High jacket water temperature (HJWT), low lube oil pressure (LOP), and high crankcase pressure (CP)' trips will trip the diese HJWT, LOP, and CP trips are blocked when an emergency start is presen Overspeed trip is not blocked by emergency start signa EDG manual control is blocked during emergency operation Safety injection (SI) reset timers will reset the sequence timer on initiation of SI following a blackou That when an emergency start occurs, whenever the EDG is idling, the diesel will accelerate to full spee That air tanks for the EDG air start subsystem can te pumped up to 300 psig in equal to or less than 30 minutes after 5 start That component cooling water (CCS) pump.28-8 will not start on low header pressure until approximately 20 seconds after a blackou STI-74 was satisfactorily performed with no discrepancies. STI-72 was performed with one test discrepancy, DN1, which identified the failure of the air start subsystem to return the system to 300 psig
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in the prescribed time due to a leaking air dryer valv The leakage has been corrected under WR 8289820 and a PMT which will consist of reperformance of the applicable sections of the STI is still pendin d. The inspector reviewed STI-65, Containment Spray Pump Performance, and observed portions of the test as performed on the B train of the containment spray system which was completed with satisfactory results. The subsequent performance of the test for the A train is being evaluated by the licensee due to possible degraded pump performance. The inspectors reviewed the completed test document for both trains. The purpose of this review was to verify that the performance of test activities were in compliance with administrative instruction (AI)-47, Conduct of Testing. Areas reviewed included documentation of pretest briefings, chronological log, test stoppages and subsequent restarts, verification signatures, test data, test deficiencies, shift engineers journal, and data calculation. The areas inspected were accomplished per AI-47 requirements exct;pt the following which were discussed with the STI-65 test director:
(1) Steps were marked N/A and not initialed. Step 7.10.3 of AI-47 requires that any step with a N/A be initialed by the person marking the step N/ (2) On the first performance of STI-65, steps 6.2.4 and 6.3.23 were marked N/A without annotation that the valves were positioned by another step in the procedure. Step 7.10.2.e of AI-47 allows the N/A of steps requiring an action (such as close or open a valve) that is accomplished by another instruction or other plant action, however the step number that fulfills the action must be noted with the N/ (3) On the first performance of STI-65, step 6.2.13 and data sheet 2 were marked N/A when the required flow rate could not be obtained. Step 7.10.1 of AI-47 states, "N/A is not to be used to ' skip' steps that could not be performed because the step was inadequate."
(4) The ultrasonic flow instrument installed on train A was found to be 22% out of calibration. No entries were made in the chronological test log pertaining to the fact that the flow instrument was found out of calibration and that the data previously obtained from the flow instrument was incorrec Paragraph 7.2.2.f of AI-47 states that records of events that delay testing, unusual events, or unexplained occurrences which ,
directly involve test activities or appear to be related to test i performance are to be documented in the chronological test lo '
(5) STI-65 was stopped due to test equipment problems for approximately a shift and a half and then restarted without
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shift engineer journal documentation that a review had taken l place to determine if system alignment and/or operations need to l
be repeated in order to recommence the tes Paragraph r
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- < 41 7.11.1.'d.2 of AI-47 recuires that prior to recommencing a test following an interrupt on, the shift engineer be notified to determine if system alignments and/or operations need to be repeated and that plant conditions are such that the-instruction can by resumed. The shift engineer is to review his journal and other pertinent information in order to reach a determination
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and document in his journal that such a review was complete This item was discussed with the operations supervisor assistan ,
(6). When operating containment spray pump 2A-A the pump vibrated and smelled of burning electrical wiring. This was documented in the chronological test log but a test deficiency was not writte Paragraph 4.5 of AI-47 state that one of the conditions for a test deficiency is when equipment operates in a suspected adverse manne The deviations from AI-47 requirements discussed above were documented by the licensee on CAQR SQP'871481. These deviations appear to be an isolated case and the corrective actions appear appropriate. The inspector will follow implementation of corrective actions described in CAQR SQP 87148 STI-42 and 43, High Voltage Testing. NRC inspectors reviewed Special Test Instructions STI-42 and STI-43, DC High Voltage Test For Selected Unit 2 IE Cables (Silicone Rubber Cables). STI-42 tested 7 cables in Train A which included 40 conductors. STI-43 tested 3 cables in Train B which included 10 conductors. All cables were silicone rubber from 3 different manufacturers. The cables were tested at either 9600 or 7200 volts DC while measuring'the insulation leakage current to groun Test failure was indicated by an increase in leakage current to ground over the specified five minute period. The cables selected.for test included #12 and #14 AWG 600 volt conductor Both test procedures were nearly the same except for the cables that were being teste The review indicated that both procedures were technically adequate to preform the required functions to mest test objectives. Equipment and personnel safety were addressed, steps were understandable, and adequate acceptance criteria was specified. Minor review comments i were discussed with test personne ' STI-81, Hydrogen Analyzer 2A and 2B Valves fail Safe Position Tes NRC inspectors reviewed STI-81 which would verify that the hydrogen analyzer 2A and 2B containment isolation valves (2-FCV-43-201, 202, 207, and 208) fail in a safe position on loss of electrical power and on the loss of control air. Inspectors noted the test cover sheet ,
did not have the yes/no block filled out regarding whether the aroce-dure was safety related. Also on the test cover sheet the f1nal plant operations review committee (PORC) review required yes/no blocks were not filled out. The test cover sheet had been signed by the responsible supervisor and the plant manage Both discrepancies i were discussed with test personnel and were corrected prior to j
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conducting the test. The test procedure was adequate to complete the required test. Acceptance criteria was clearly stated. Minor review comments were discussed with test personnel prior to the conduct of the tes . - - _ _ _ _ _ _ _ _-____ - ___ ___ _ _ _ _
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17. Readiness Fcr Heatup Inspection (Hold-Point #1, Mode 5-4)
This inspection was performed, in part, to provide the basis for determining the readiness of Sequoyah Unit 2 to commence plant heatup (i.e. , mode 5-4 change). Since the issuance of the Sequoyah nuclear performance plan (SNPP) the NRC has been performing program improvement inspections which are documented in numerous Inspection Report The portion of the inspection, documented in this report, is directed more toward the plants operational readiness assessment discussed in the SNPP and operational readiness report regarding Sequoyah activities list (SAL),
performance objectives and major projects closure Followup inspections in the restart readiness area, scheduled prior to mode change, will evaluate additional specific items which the NRC feels necessary to make the hold point release decision. Current plans for the entire release inspection include the following: Review of Licensing Activities Needed to Support Mode 5-4 Change (1) Resolution of items needed to support plant heatup Review of Outstanding Employee Issues (1) Review open NRC allegations for issues which may effect heatup (2) Review TVA's new employee concern program backlog and evaluate for, one selected system, any open issue that could effect heatup (3). For one selected system, review the status of open corrective action that resulted from the old employee concern program and assess open issues that may effect heatup Review Status of NRC Identified Issues (1) Review NRC outstanding items and verify that items effecting heatup are either closed or scheduled to be closed prior to heatup l
(2) Review status of any pending escalated enforcement items that could effect heatup
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(3) Review licensee assessment of defeated safety functions for FSAR Chapter 15 systems and ascertain adequacy of licensee review and established compensatory measure ^ Review of Testing Activities (1) Review results of LLRT inspection (2) Review results of restart test program (RTP) program and implementation inspection (3) Review status and inspection results for mode 5 SI test witnessing (4) Review quality of special test procedures that will be used during mode 4 & 3 testing (5) Review safety evaluation and inspection results of SI procedure upgrade
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(6) Review primary leak rate calculation and ensure acceptable primary leakage 4 (7) Review shutdown margin determination for rod movement or boron dilutions associated with heatup (8) Review effectiveness of controls that were established for the conduct of testing (i.e., administrative procedure AI-47)
e. Review of Plant Procedures Needed for Heatup (1) Review any changes to G01-1 & 2 and ensure that procedure was validated and operating personnel have been trained (2) Review special procedure for control of heatup/startup and ensure agreed NRC hold-points have been establishe Additionally, verify that proper levels of licensee review and management involvement have been established for mode change decisions f. Review of Licensee Operational Readiness (OR) Assessment (1) Review the closure of several SAL packages and verify compliance to SQA-190 (2) Review second interim operational readiness report and ensure TVA is resolving open i m es (3) Review TVA's assessment of special project closure contained in OR report and ensure NRC agrees with assessment / status (4) Review status of department performance criteria assessment and ensure personnel staffing goals have been met (5) Review outstanding modificaticas, maintenance requests, TACFs, PMs, and deficiency reports associated with one selected system and assess affect on operabilit (6) Review licensee safety evaluations which justify continued operation despite degraded conditions or outstanding evaluations (e.g. , cable testing, component cooling water heat exchanger
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performance, room cooler performance, cable routing, civil :
calculations, pipe support modifications, etc.). Assess impact on operabilit g. Review results of walkdown inspection on 3 to 5 safety systems (1) Verify effectiveness of independent verification process (2) Verify procedure adequacy and adherence (3) Verify correct use of configuration control log (4) Verify shift engineer and control room operator demonstrate adequate control of valve position changes and the valve lineup process in general (5) Verify that any deviations identified are properly evaluated and resolved (6) Verify system drawings used for walkdown reflect the results of DBVP 4
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44 Plant Material Condition (1) Conduct containment walkdown and verify that general condition will support plant heatup (i.e. , fire hazard, housekeeping, meltable materials, etc.)
(2) Conduct plant tour and assess general material condition and housekeeping (3) Review primary and secondary chemistry and discuss secondary system chemistry with chemistry supervisor (4) Review results of plant security inspection / verification (5) Review results of maintenance program inspection and ensure that any open items identified as prior to heatup have been resolved Conduct of Operations (1) Review level of management involvement in day-to-day operations (2) Review the effectiveness of the daily work list (DWL) and determine if it has reduced the administrative burden on the R0, ASE and SE (3) Review conduct of control room personnel (i.e., shift operations, logs, turnovers, communications, formality, etc. ) Note: this assessment is ongoing and will include sustained control room observations (4) Review the use of procedures, by operations, for evolutions conducted outside the control room 18. Conduct of Readiness of Heatup Inspection (CRHI)
This inspection addressed specific areas of the overall planned inspectio The letter designation from the planned inspection identified in paragraph 17 above, along with the inspectors comments and observations are listed below: CRHI Item E, Review of Plant Procedures Needed for Heatup 2) Review special procedure for control of heatup/startup and ensure agreed NRC hold points have been established. Additionally, verify that proper levels of licensee review and management involvement have been established for mode change decision Results:
The inspector reviewed revision 0 of Restart Test Instruction (RTI)
RTI-1.1, Master Test Sequence, Unit 2. The scope of this procedure
, was to verify that required testing has been satisfactorily completed, restart checklist has been completed, and adequate
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management confidence has been established prior to leaving established hold point The hold points were established through agreement with the NRC and are as follow:
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Before entry into mode 4 (hot shutdown)
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Before entry into mode 2 (startup)
Before entry.into mode 1 (power operations) l Before exceeding approximately 30% rated thermal power (i.e. ,
consistent with normal steam generator chemistry hold)
Before exceeding approximately 75% rated thermal power (ie. ,
consistent with normal procedure hold for core performance and nuclear instrument SI verification)
RTI-1.1 is broken into many parts and provides the level of management review needed to make the final determination as to the
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utilities readiness to leave established hold-points. This procedure also establishes the hierarchy of managers and supervisors needed to verify unit operational readines The inspector considers RTI-1.1 to be technically adequate and if properly implemented it should prompt the necessary reviews and document the appropriate verifications of operational readiness. The inspectors will follow implementation of this procedure during subsequent inspection b. CRHI item F, Review of Licensee Operational Readiness (OR) Assessment (1) Review the closure of several SAL packages and verify compliance to SQA 190 Results:
Scope of Sequoyah Activity List (SAL) Program The SAL program is described in standard practice administrative (SQA)-190, revision 1, Restart Item Organization And Sequoyah Activities List Disposition. The purpose of this program is to track items required to be completed prior to restart of Sequoyah units 1 & 2, to ensure that all such items are properly disposi-tioned, completed, and documented prior to reporting them to the NRC. As defined in SQA-190, a SAL Item is a statement of a condition and/or corrective action that must be accomplished either to restart one or both Sequoyah units or to implement a programmatic issue identified in the revised Sequoyah nuclear performance plan, volume I Scope of SAL Program Review A sample of " closed" or " restart complete" SAL items were selected for review by NRC inspectors, in order to determine whether the identified corrective action / commitment has been adequately addressed, completed, and documented, and that the documentation contained or referenced in the SAL item closure file provides an auditable path through which to track the required actions. As required per SQA-190, revision 1, the i documentation necessary to provide this auditable path is to be listed in section IV of form attachment 8, Basis For Disposition Of A SAL Ite __ ___ - -_______-____ D
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Discussion of SAL Items Reviewed SAL # 350, "SOI Valve Checklists Do Not Agree With As-Constructed Drawings" As identified in Corrective Action Report CAR 85-10-016, the valve checklists contained in several System Operating Instruc-tions (S0I) were not in agreement with the information shown on the as-constructed drawings for the system. NRC review of this item revealed the following:
- i Per the " Action To Prevent Recurrence' section of CAR 85-10-016, Procedure OSLA-104 was to have been revised to require the use of as-constructed drawings when revising valve checklists, and drawing control was to issue a section letter requiring that copies of all revised as-constructed drawings be sent to operations for their information and use. However, these actions were not verified by QA prior to the closure of the CAR and the lack of such verification ' as w not discovered during the SAL item closure review. Further review by NRC revealed that the required procedure revision had been accomplished but-that instead of issuing the section letter, administrative instruction (AI)-25 was revised to include the above stated required action. As such, even though the action required has been accomplished, it was not in accordance with the stated requirements, and therefore no readily auditable path exists in the SAL closure file or on the closed copy .
of the CA l Per the " Required Corrective Action" section of the CAR, all the systems listed in AI-37 were to have been reviewed I to ensure that the valve checklists in their respective SOIs were in agreement with the as-constructed drawing The information shown in section IV of the attachment B form documents the review of fifteen systems, by number, either all or in part. As there are twenty-one systems ,
listed in AI-37, several encompassing more than one S0I, !
it cannot be positively ascertained from the information provided that all of the required reviews have been accomplishe j Additional NRC evaluation of this item will be addressed during subsequent inspection :
SAL # 249, " Resolve Those Portions of CAR 85-09-014 and CAR 86-03-010 Required For Restart By Verifying Sequoyah Weld Program" l
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These CARS identified several items in the areas of welder 4 qualifications, and failure to document fit-up inspections as !
. required by AWS D1.1, Structural Welding Code. The required actions included resolution of the identified welder qualifica- (
tion issues, revision to procedure M&AI-5 to preclude further j errors of the types identified, a field walkdown to determine if j the lack cf a requirement for fit-up inspection resulted in {
hardware deficiencies, and a revision to procedure M&AI-11 to i require QC inspection of fit-up in the futur NRC review j determined that all required actions'were accomplished, properly documented, and that an auditable path does exist in the SAL closure fil SAL #292, " Resolve SCRCEB8627 By Verifying Acceptability Of )
Concrete Expansion Anchors In High Density Concrete Or Take 1 Corrective Action" The above SCR identifies the installation of concrete expansion anchors in high density concrete without the performance of the {
required qualification testing to ensure that these installations j will be capable of supporting the necessary loads. In addition, an evaluation was to have been performed to determine the acceptability of attaching supports to a 1/4" plate which was installed to reinforce a section of " weak" concrete, as identi-fied in NCR SQNPWP830 HRC review revealed the following:
The required qualification testing of anchors in high density concrete was performed in accordance with STI-9, revision 0, and the results of this testing revealed that there is no difference in the. performance of anchors in high density concrete from that in the concrete found elsewhere throughout the site. The results of this testing were found to be roperly documented and referenced in the SAL item closure f l Calculation SCG-1560 was performed to ascertain the accept-ability of supports attached to the above referenced 1/4" plate, and it was determined that, with one exception, all supports attached to this plate are acceptable. The one unacceptable support (47A560-6-69) was reworked in accordance with WP-12174 and is now acceptable. All of this supporting documentation is properly contained in the SAL item closure fil SAL # 313, " Training Of Management In New Employee Concerns !
Program" l
This item is as a result of a commitment in Section II.2.7 of tne revised nuclear performance plan (NPP). NRC review revealed that all Sequoyah personnel, including managers and supervisors, were irformed of the new employee concerns program via memo dated 2-4-86 (S06-860204-800), and that as of 3-10-86, all i
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Sequoyah personnel, including managers and supervisors, had received training in the program. All documentation supporting the performance of this training is included in the SAL Item closure fil It is determined that the commitment stated in NPP section II.2.7 has been adequately fulfille SAL # 343, " Revise AI-4 To Ensure Compliance With The Area Plan And Nuclear Quality Assurance Manual" This item is a result of CAR 85-03-004, which requires that long-term commitments are identified in plant instructions and that revisions to plant instructions do not inadvertently delete actions which are required by long-term commitments. NRC review reveals that revision 55 to AI-4 incorporates this requirement, and that this action is properly documented in the SAL item closure fil SAL # 353, " Verify Completion of Training of Shift Technical Advisors On The Safety Parameter Display System" This item is a result of Item 1 of the operational readiness review dated 11-14-85 (A02-851113-016) which requires that, prior to restart, shift technical advisors (STAS) will have successfully completed training on the safety parameter display system (SPDS). NRC review of the SAL item closure file revealed that SYS003.56, revision 0, 2-19-86, Lesson Plan for SPDS Training of STAS, and memo L17-860716-801, dated 7-9-86 which documents the training and oral exam results for 16 STAS are present, therefore this item is determined to be properly addressed and documente SAL # 389, " Revise Reactor Trip Instrumentation Functional and Response Time Test (RT) For Shunt Trip Modification" This item is a result of NRC generic letter (GL) 83-28, which requires that a functional and response time test be performed l on the shunt trip modification pertaining to reactor trip instrumentation. NRC review of the information contained in the SAL item closure file revealed that the following procedures -
were revised as a result of the GL:
SI-93, Rev. 9 51-90.8, Rev. 3 IMI-99, RT 4.6, Rev. 3 IMI-99, RT 4.7, Rev. 4 IMI-99, RT 4.8, Rev. 3 Therefore, it is determined that the closure of this SAL Item has been accomplished properly. (NOTE: This review is not intended to constitute an acceptance of the technical adequacy of the
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i test procedures, only that they were revised and that the revisions listed were instituted as a result of GL 83-28).
SAL # 591, " Clearly Communicate Management Goals And Objectives" This item is a nsult of a commitment in section II.2.2 of the revised nuclear performance plan, which states: " Effective management control requires that goals and objectives be clearly communicated. Because every employee is responsible for quality, employees must receive and understand this information, not just the managers." NRC review reveals that the following actions were performed:
On 8-29-86, a handout entitled "SEQUOYAH DISPATCH" was distributed to all Sequoyah employees. This handout itemized the site goals and objectives for 198 SQA-129, revision 6, Objectives In Plant Operation Sequoyah Nuclear Plant, was issued on 10-1-8 Copies of the above items are located in the SAL item closure fil Therefore it is determined that this SAL item was properly closed and the referenced commitment was adequately fulfille SAL # 163, " Resolve Branch Technical Position PSB-1 In Regards To The Auxiliary Power System" This item is a result of a NRC letter to TVA dated 3-26-86 (Re A02-860331-005) which states that, due to numerous system modifications, a reverification test of the voltage requirements for the attxiliary power system is. required. The licensee has performed the required testing which is documented in calculation SQN-APS-001, revision 1, dated 5-19-8 Answers to subsequent questions posed by NRC staff are documented in letters B25-861119-017, L44-860911-804, B25-860602-003, and L44-860602-80 On 1-13-87, the NRC accepted the licensee's response to this issue (Ref. letter A02-870116-007). Review of the SAL item closure file finds that all applicable documentation is contained therein. Therefore, it is determined that this item has been adequately tracked and closed. Note: The satisfactory completion of this item also adequately fulfills a commitment shown in section III.4.1 of the NP SAL # 357, " Verify Qualifications of N0E Inspector On-The-Job Training" This item is a result of Nuclear Safety Review Staff (NSRS)
Recommendation I-85-373-NPS-02, Issue #1, Correction of Incorrect Qualification Documents and Premature Certification NRC review of information contained in letter 508-860729-817 and ten attachments thereto, and letter 508-860910-845 determines l-
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that the remedial actions taken by the licensee are sufficiently ,
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adequate "to assure. that current NDE inspector training and experience records ~ are accurate and the prev.iously identified ~
' inaccuracies .resulted in no significant hardware deficiencie .I t Therefore, it is determined that the SAL item was properly dispositioned 'and documented in accordance with the SAL closure requirement ' SAL # 948, " Resolve Those' Portions Of ECTG Element Reports-17304 and 173.4R2 (Compression Fitting Problems) Yhat Are Required For Restart" This item was originally identified in Watts Bar SCR-6278R1 which was determined to have possible generic effects at .
Sequoya No hardware deficiencies similar to.those ~ identified at Watts Bar have been observed at Sequoyah, and as such, the licensee has determined that no actions are required to be accomplished prior to restart of Sequoyah Unit 2. The inspector agrees with this determination. However, ' the licensee will be performing the .following actions, which need not be completed
, prior to restart:
- Issuance of an installation procedure for compression fittings at Sequoyah Incorporation of periodic retraining requirements for installation and inspection personnel into TVA's training progra SAL # 279, " Resolve NCR-CEB-8414 By Reworking Seven Cable Tray Hangers On Shield Building For A Design Basis Accident and SSE'
The' deficiency identified in the above referenced NCR was that the original design of certain cable tray hangers did not address the design basis accident (DBA) loads as required by design criteria SQN-DC-V-1.3.4. Subsequently, CAQR SQT870595, dated 4-9-87, identified the following actions as being required l to be completed prior to unit 2 restart: !
Technically justify and document conclusions. in a prelimi- 1 nary evaluation. This was accomplished via calculation '
15156, revision 1, dated 7-31-87, and l' Document completion of WPs and FCRs for unit 2 and common l areas, which encompassed the reworking of seven cable tray hangers in accordance with the above preliminary calculatio This rework has been accomplished via WP 12162 which states that all field work was completed as of 11-17-86, in ,
accordance with ECN-L672 '
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NRC review of the SAL item closure package finds that all of the required information is contained therein, with the followin exception. SQA-190 attachment "C" form requires the the imple-menting manager to sign in the space provided in section II.B of'
the form, indicating his cognizance of the stated actions yet to be accomplished after unit restart. This~ required signature was found to be missing and had not been identified by the SAL item reviewer. The licensee'has corrected this proble SAL # 724, " Modify Existing Instrumentation And Piping Supports That Are Attached To 3/8" Embedded Plates" SCR CEB 8505R2 identified a condition whereby the attachment of instrumentation and piping supports to 3/8 thick embedded plates may have caused the plates to be overstressed. The required corrective action was to evaluate all of the 3/8"-
plates shown on drawing 48N914 and modify any supports found to be causing an overstress condition in the plates. The required evaluation was accomplished for unit 2 via ECN-L6792 'and the-resulting rework for unit 2 was completed per WP-12E4 as of-11-14-86. NRC review determines that all items stated as requiring completion. for restart of unit 2 have been adequately accomplished and documented, and that 'the information required is contained within the SAL item closure fil SAL # 325, " Write 17 New Maintenance Instructions For CSSC Equipment" This item is .the result of a commitment stated in section 11.4.2.4 of the NPP. NRC review determines that the following 17 maintenance instructions have.been issued, and therefore the stated commitment has been fulfilled: MI-10.10.1, MI-10.11.1, MI-10.14.1, MI-10.4.2, MI-10.5.1, MI-10.5.2, MI-10.5.3, MI-10.5.4, MI-10.5.5, MI-10.5.6, MI-10.6.2, MI-10.6.3, MI-12.1.1, MI-12.2.1, MI-12.3.1, MI-8.7.1, and MI-4. .
SAL # 154, " Issue ECN To Revise Vendor Manual To Show Removal Of Steam Generator Tube Line Blocking Devices As A Permanent Modification" Per DCR-1967, dated 7-22-83, it was determined that, due to the method of controlling SG chemistry employed at Sequoyah, the tube line blocking devices are not needed. In addition, if these devices were permanently removed, it would cause a decrease in man-rem exposures during refueling outages due to approximately 40 fewer man-hours of work time per SG per outag The actual removal of these devices was accomplished via WP-10566 (unit 1) and WP-10521 (unit 2), and the documentation of the modification is described in ECN-L6519, dated 7-25-8 ;
In addition, this ECN documents the required revisfor.' to
" Westinghouse Manuals On Steam Generator Series 51, Mechanical Improvement Modifications Procedure MRS 2.7.2 GEN-2". TVA memo
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B25-870202-009 states that, as ECN-L6519 documents the required revision to the vendor manual, the actual manual revision is not required to be accomplished prior to restart. The NRC inspector determined that the above stated actions appear to satisfy the technical issue and that the required information is contained within the SAL item closure fil SAL # 14, " Resolve SCR NEB 8522 by ensuring adequate seal flow to the RCPs by adjusting the stem setting on FCV-62-93 by mechanical means".
SCR NEB 8522 dated 12/30/85 identified FCV-62-93 as a fail closed valve. This description of condition stated: To ensure long-term event mitigation a qualified flow path to provide make-up to the RCS and to provide seal cooling to the RC pumps must be available. As an example, essential equipment FCV-62-93, CVCS heat trace and boron injection tank (BIT) heaters62-239 and 62-243 have not been addressed in the 10 CFR 50.49 progra ECN-L6634 dated March 6,1986, was prepared 'to adjust stem setting on FCV-62-93 to ensure that a minimum of 32 gallons per minute will flow through the valve at all times. In March 1987 revision 1 to the SCR stated in part: since there is a long term event which would not preclude operator action, manual operator actions outlined in 50I-62-IF are acceptable. Planning schedule dated March 24, 1987, indicated that ECN-6634 was canceled and field work would not be don Several inconsistencies exist in this SAL closure file:
No document specifically cancels ECN-6634. Revision 0 of the SCR does not specify an ECN. Revision 1 of the SCR does not state a cancellation. However, ECN-6634 was prepared in support of revision Block b6 of SCR revision 0 listed applicable vendor requirements as N/ However, the planning schedule states that modifications to the valve cannot be done pet Westinghouse. Documentation is to be provided to NEB by Westinghouse. The operating instruction is required to be changed for FCV-62-93. The SAL folder did not contain the Westinghouse informatio .1F states FCV-62-93 is a fail open valve. However, revision 0 of the SCR indicates a fail close valv *
The CVCS heat trace and BIT heater identified in revision 0 and revision 1 of the SCR as being 10 CFR 49 concerns are not addressed in this SAL. These items were not included in the descriptive title of the SA However, the SCR
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included them in the initiating example together with the seal / makeup. Some indication in the closure folder should l explain why they are not addresse l The documentation originally provided or referenced in this SAL folder is not sufficient for a stand alone closure packag Followup discussions on 9/28/87 with TVA personnel indicate that this item has been adequately addressed and that the system and procedures provide for proper operation. No mechanical change was accomplished on FCV 62-9 It is not clear that a revision to the 501 occurred to support long term seal flow. However, the current revision (31) provides for manual operation of bypass valves for long term seal flow. The CVCS heat trace and BIT heaters are not part of the bypass flow path and are not necessary for seal /make up flow when utilizing the bypass flow path. The inspector agrees with closure of this SAL ite SAL # 39, " Provide General Site Training on EQ" During this review a discrepancy between the date of preparation of the lesson plan and the training attendance records was noted. Discussions with the environmental qualification coor-dinator resolved the questions in that, actual EQ training started utilizing a draft lesson plan approved under training procedure TCT-1 The SAL verification group is- adding documents to the SAL 39 folder to support the above discussion and resolve the lesson plan vs attendance dates noted abov The inspector believes the verification process should have noted the conflicting dates and resolved this discrepancy prior to SAL 39 closure. An actual count of personnel trained was not available but the number of records indicate approximately 100 Long term goals are to provide training by job description and is tentatively scheduled to be in place by April 198 The documentation in this SAL folder contained inconsistencies that should have been resolved prior to closure. During this inspection additional information, to be made part of the folder, was provided that adequately supports closure of this SAL ite SAL # 51, " Resolve Environmental Qualification Inadequacies in CAR 86-02-007" This SAL addresses inadequate completion of data sheets (i.e. ,
blank spaces).
(a) Lubricant used in limitorque motors was not recorded properly on data sheet (b) Limitorque geared limit switches measurement of the i L-finger gap was not recorded '
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(c) -Incorrect equipment identification (MSIV Solenoids) in the WR (d) Failure to record calculated valves for percent unbalance Items (a), (c) and (d) above were resolved as follow:
(a) Quality control records indicated this correct lubricant was used (b) Solenoids were properly identified (c) Values were calculated This CAR response, dated March 27, 1986, stated that training for general foremen, foreman, planners and crafts to cover recuired entries on work / maintenance requests would be conducted anc a class would be given on reviewing work request package *
This training would be complete by 5/31/86. Only one reference to training could be found in the SAL folder which indicated that some training was conducted for craftsman, foreman, engineer, and supervisors present during a March safety meetin It appears that a high percentage of personnel were trained from a review of the attendance records. However, the exact percentage could not be determined. During discussions with maintenance and QA it apaeared (not documented) that QA reviewers had received training related to reviewer trainin Item b. above, L-finger gap measurement. The inspector reviewed MI-11.2A'in part. Step 14.3 details the gap measurement and is included to ensure' positive finger contact. The step states:
bend the finger or L bracket until minimum gap is obtaine The inspector believes any attempts to bend the L-finger would or could result in additional damage to the limit switch or rotor. This step should be reviewed to ensure bending as acceptable corrective actio Based on the above and discussions with TVA personnel the inspector believe sufficient corrective action has been accomplished to close this SAL item. However, all corrective actions were not included in the SAL closure package.
i The potential problem related above regarding the L-finger should be resolve {
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During followup review conducted on 9/29/87, records of training i attendance for class SQM-2, Maintenance Procedures, were provided, I indicating that TVA training for reviewers has been accomplishe Discussions with TVA personnel indicate that SQM-2 training occurs whenever significant changes to the procedure are imple-mented. During these discussions it was indicated that SQM-2
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l training included information regarding data review responsi-bilitie The inspector agrees with closure of this SAL ite During this followup the potential problem of the measurement of the L-Finger gap was not addressed and will be evaluated by NRC during subsequent inspection SAL # 96," Transitional Design Control System" Sequoyah Engineering Procedure (SQEP)-13, Protedure for Transi-tional Design Change Control, has been developec u d implemente This procedure supports the transition from the previous system to the system established in the NPP part II, section SQEP-13 provides for creation of the change control board (CCB)
consisting of senior plant management, licensing, quality assurance and DNE. Chaired by the site director, the CCB providet over all control of the transition perio This procedure was implemented September 4,1986, per project engineer memo dated September 3,1986, but reported in the corporate commitment tracking system as 9-11-8 With the minor exception of the dates above, this SAL package l provides sufficient information for closure.
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l SAL # 108, " Resolve NCRS CEB8030 and CEB 8031 by Restraining or
- Removing Block Walls in The Hot Sample Room" l
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The above NCRs are closed and documente ECN L5703 and ECN L5357 added structural restraints to unreinforced masonry block walls to protect safety related equipment from wall collaps ECN L4557 removed unreinforced masonry wall from units I and 2 around the hot sample room chillers. These actions stem from IE bulletin 80-11, Masonry Wall Desig The selected starting point of this SAL is at the NCR CEB8030 and CEB8031 poin Because of the selected start point it is i
I unclear from the SAL package that all the issues presented in bulletin 80-11 have been addressed and resolved. A mention of the original survey required by 80-11 is contained in memo, l Mr. Sprouse to Mr. Green dated March 1, 198 The documentation l from the selected SAL start point supports the closure of this l ite Consideration was given to the shielding effects, prior to the removal, of the masonry walls for normal power operations and deemed acceptabl No documentation was presented that addressed post accident radiation levels in and around the spaces affected by the wall remova _ _ _ _ _ - _ - - _ - - _ -
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The initial SAL item closure did not adequately address the post accident shielding (loss of) associated with the masonry u wall removal. Followup review was conducted on 9/29/8 Discussions with TVA personnel indicate that the wall in question was a partition wall and no credit for shielding was assume Additionally, there is no anticipated reason for any personnel to be in the vicinity of the removed walls during post accident conditions. The inspector agrees with closure of this SAL ite SAL # 111, " Respond to 1/15/86 Letter from B. J. Youngblood, (NRC Concerns Involving Design Control)".
This SAL item concerns a letter dated January 15, 1986, from Mr. Youngblood (NRC) to Mr. White (TVA) requesting additional information regarding earlier correspondence between NRC and TV Five areas were addressed as follows:
Why Browns Ferry design control problems identified via employee concerns do not apply at Sequoyah Explanation of how employee concerns, NSRS concerns, QA audit, etc., will be reviewed Basis for conclusion that Sequoyah design controls prior to June 1985 were adequate
How design changes at Watts Bar would be addressed at Sequoyah Description of the electrical design calculations review program These items were answered in TVA's response dated August 18, 1986, to Mr. Youngblood (NRC) from Mr. Gridley (TVA).
This SAL does not present any additional information and the level II verification field notes status indicates all questions were answere No follow-up response was necessar Based on the above the closure of this SAL is adequat SAL # 131, " Evaluate and close work plans or prepare and approve partial work plan completion form for Post Modification Tests (PMT)-10, 11, 14, 21, 29, 30, 33, 39, 47, 50 and 53".
PMT-10 Control Room Emergency Lighting Control room emergency lighting, as evaluated by TVA. is less than optimum and requires modification to comply with NUREG 0700 and NUREG 073 TVA has determined the lighting is acceptable
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for operation, as is, based on analysis of lighting under condition other than required by PMT-10 and operator familiarity with the location and function of the instrumentation and control PMT-11 Post Accident Sampling Facility Rev This PMT was not included in the SAL folder during the first review. However, the licensee provided the necessary documents when this was brought to his attention. It appears that this SAL was in the closure process during the transition from SAL 190 revision 0 to SAL 190 revision 1 and the scope of the item : -
changed (i.e. , PMT 11 was added). The licensee is presently investigating to determine if any other SAL package closures were closed based on revision 0 and if revision 1 changed the scope of the SA TVA memo dated November 18, 1985, provides final approval of the test results. However, a general comment in the attachment to the PMT states: TC 84-446 should be TC 84-159 Discussions with the licensee revealed that this was a very minor personnel erro PMT-14 Post Accident Sampling Facility Ventilation Unit 2 A temporary flow path (ventilation) between the sampling side and the hot side utilizing a spare 4-inen sleeve. The testing is incomplete until a modification is provided to allow the proper air leakage path and seal the 4-inch hole presently use DNE will remove the automatic flow control function from FCO-31-408 and the system will be balanced by the system engineering section. TVA states that this work can be completed during power operatio PMT-21 & 47 Long term onsite storage facility drainage system Unit 1 and 2 and Mobile Gantry Crane and associated equipment for low level radwaste storage facility Unit 1 and 2, respec-tively.
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TVA has determined that this is not a restart issu The inspector agree PMT-29 Phase 1 & 2 Addition of Common Station Service Transformer C and 6.9 KV Start Board Addition / Modification This item is listed as not safety related , but is included in this SAL. TVA memo dated 3-24-86 states that phase II test is acceptable and approves test exception, EX 2. A separate TVA memo dated 3-24-86 stated that phase I test results require resolution of deficiency (DN 13) and exception (EX 2) prior to final approva _ _ _ _ _ - - _ _ - _ - _ - _ _ - _ _ _ _ _ _ _ _ _ . - ___-_ - -_ .
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QA record change form (AI-7 attachment 20) dated 10-17-86 states that additional documents needed in the WP, PMT-29 phase I & II, for adequate documentation. The additional documents were not in the SAL folder. Discussions with TVA personnel revealed that these documents have been properly added to the W PMT-30 Radiation monitoring Additional Probes for Gas Effluent, Unit 1 & TVA memo dated November 20, 1986, states that this item has final approval of the test result However, the approval form attachment indicates an exception in that a portion of the testing is not signed off or witnesse No evidence in the SAL folder indicated this exemption has been correcte Discussions with TVA personnel revealed that the actual user copy of the test had been properly signed-of PMT-33 Diesel Generator Building Heating and Ventilation System Unit 1 & 2, Rev Discussions with TVA personnel revealed that this was a timing sequence problem and the proper reviews were conducted prior to implementing this PM PMT-39 Reactor Vessel Head Vent System This item deals with the indication of the reactor vessel (RV)
head vent throttle valves in the control room. The indications are inaccurate due to failure to mount the controllers per vendor requirement The USQD states that the operators can determine the valve status from the indication in the pressur-izer relief tank (PRT) (e.g. , level, temperature, pressure).
Additionally, the USQD indicates the valves will not completely close unless subject to system pressure. That is, isolation valves flow solenoid valve (FSV)-68-394 & 395 must be open to close the throttle valves completely and that SQNP function l restoration procedure (FR)-I.3 does not specify, when securing from venting, to shut the throttle valves FCV-68-396 or 397 before shutting the isolation valves FSV-68-394 or 395. A memo was sent to all licensed personnel, auxiliary unit operators l (AU0s) and shift technical advisors (ST/is) on September 16, 1986, explaining the problem and to determine positive indica-tions of the throttle valves by monitoring the PRT, if leakage is suspecte Also that temperature ele. ment 68-398 should aid in detecting leakage, if suspecte The memo did not address shutting the throttle valves prior to shutting the isolation valve to ensure system pressure completely closes the throttle valves as discussed in the USQ Discussions with TVA personnel indicated that a memo was sent to operations discussing the valve shutting sequence. ECN L6150 is scheduled to correct the controller mounting problem. This ECN is scheduled to be accomplished during the fourth refueling outage, The NRC will continue evaluation of this item during subsequent inspection _ _ _ _ _ _ - .- _____-= _. - - . _ - _ - .-
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PMT-50 Pressurizer Power Operated Relief Valve Test, Rev. TVA memo dated April 4,1986, provides final appr_ oval of these
' tests. One test deficiency (DN-1-PT-790) is included as, approve QA record change form (AI-7 Attachment 20): dated 10/17/86 states that the present contents do not provide adequate documentation regarding test deficiencies .and resolutions. No evidence that this QA concern was addressed is included in the SAL. folde Discussions with TVA . personnel revealed that the documents were
, subsequently added.to the work packag PMT-52 Containment Vent Isolation Logic Change Test, Rev. This PMT is in the SAL folder, but is not included in the title rubject of the SAL folde PMT-53 AFW Cavitating Venturi Modificatio TVA memo dated November 18, 1986, provides final approval of this test result. The inspector agrees with closure of this SAL ite Assessment of the above specific findings indicated a general weaknesses in the SAL closure process. Specifically,.the scope of the SAL item is not clearly established (i.e. , not described in any detail. and in some cases onl reports are used to limit SAL scope)y references
. This lack to of problem detailed scope resulted in both SAL item scope being increased while the closure process was on going.and SAL item corrective action being revised and not clearly described in the SAL packag This item was discussed with licensee management and the licensee committed to the following:
Establish the necessary controls to ensure that the scope of the SAL item that was closed is the correct revision and reflects the actual work performe Review closed SAL packages and ensure that revisions to commitments, including those in the SNPP, were properly and captured by the SAL closure process and reflected in the packag Based on the above commitments and this sample of the SAL closeout program, currently in progress at Sequoyah, the inspectors conclude -that the closure / verification process provides adequate documentation, either in the SAL folders referenced in the folder, or traceable from the folder to close the SAL issue. Specific concerns identified herein will be addressed in subsequent inspection ' '
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(2) Review second interim operational readiness report and ensure TVA is resolving open issues and review TVA's assessment of special project closure Sequoyah Unit 2 Operational Readiness Second Interim Report Section V, Major Projects Restart activities that are significant or have broad impact on other activities have been identified by the OR Staff as major projects / issues (MP/I). The identified MP/I were subjected to more detailed reviews under the OR program in order to provide additional assurance of completion for restar There are 22 identified MP/I. SQA-191, Evaluation of Operational Readiness Prior to Plant Restart, is the document implementing this portion of the Sequoyah OR revie SQA-191, revision 3 was reviewed and was found to contain adequate guidance to document the closure process for the MP/I when used in conjunction with the referenced SQA-190, Restart Item Origination and Sequoyah Activities List Dispositio In accordance with SQA-191 MP/I closure criteria were estab-lished. SQA-191 provides general objectives to be used as guidance in developing specific closure criteria for a given MP/ Three MP/I packages were reviewed; superheat issues, surveil-lance instruction review and design basel'1e verification program (DBVP). In all three the closure criteria are in accordance with the general objectives as applicable to the specific issue. The criteria were cleariy stated and the action necessary to close the item was also clearly stated. All three packages were signed off in the block stating " Project / Issue closed for Restart". In each case this signoff was qualified by stating that the items open were being tracked for closur Therefore the signature " Project / Issue closed for Restart" did not indicate the item was closed but that the open portions of the item were identified and were in a tracking syste Administrative errors were found in all three package Signatures for preparation of criteria and approval of criteria were missing from the superheat issue package on the attachment G cover sheet and on the attachment G data sheet dated April S, 198 The signatures for project / issue closed for restart were not dated as required in the surveillance instruction review packag In the DBVP package the same person on the same date signed for both the responsible manager and the principal manager in the project / issue closed fer restart block. This does not meet the intent for review and concurrence per section 5.0 of SQA-19 _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _
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In summary: The process of defining the criteria for closure for the MP/I was performed ~ in ' accordance with established guidelines in SQA-191. The signoff of MP/I as closed for restart with qualified signatures such that the item was not closed but just transferred to a different tracking system appears to be an exercise in paper shuffling. Although allowed by the SNPP, it would be more meaningful if- the signoff
" Project / Issue closed for Restart" meant that ' the item was closed. This would eliminate the possibility of transfer errors and would provide an easier method of verification. The admin-istrative errors identified. indicate a lack of attention to detai The administrative errors were referred to the operational readiness manager for resolution and this resolution will be assessed during final NRC operational readiness assessment (3) Review status of department performance criteria assessment and ensure personnel staffing goals have been met Performance Objective 2A, Staffing Adequate for Restart As required by section II, Performance Objectives and Criteria, of the Sequoyah unit 2 operational readiness report and SQA-191 attachment C, the assigned managers performed a self-evaluation of their organizations ability to meet the performance objec-tives as defined in attachment B of SQA-191. Assigned managers determined the level of review and documentation necessary within their organization to provide confidence that their performance objective reviews and evaluations were accurate and that identified exceptions were closed or wheduled in P-2 for completion before restart. The documentn iva of this self-evaluation was reported by means of the attachment E form. The attachment E forms were reviewed by OR manager and signed and dated to indicate concurrenc Criteria 2A, vacant positions critical to your organization for restart have been identified and fille The completed attachment E forms were reviewed for all assigned-manager All managers listed in SQA-191 attachment C responded as required. In most cases where staffing was initially less than needed for restart the vacant positions have been filled and updated attachment E forms submitted to document this resolution. Those managers who still have vacant positions -
needed for restart have made requests for the personnel and have i an outstanding P-2 item to track this restart ite Only l electrical maintenance, instrument maintenance and quality I manager's staff have active P-2 tracking. All other departments have documented that they have adequate staff for restart. In some areas additional staffing _ includes temporary staff, loaned personnel and contract personnel. The inspector determined that TVA has satisfied their commitments in this area and adequate staffing is either in place or currently schedule _ - _ _ _ _ - >