ML20205P421

Insp Repts 50-327/86-20 & 50-328/86-20 on 860303-14. Violation Noted:Failure to Establish & Implement Procedure for 18-month Annual ESF Functional Input Check of Reactor Trip Sys

ML20205P421
Person / Time
Site:	Sequoyah
Issue date:	04/18/1986
From:	Brooks C, Carroll R, Garner L, Holland W, Holmesray P, Mcneil S, Linda Watson, Weise S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20205P381	List: ML20205P378 ML20205P407 ML20205P421
References
50-327-86-20, 50-328-86-20, NUDOCS 8605210408
Download: ML20205P421 (28)

See also: IR 05000327/1986020

Text

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S Of Gg UNITED STATES

1. Do

f NUCLEAR REGULATORY COMMISSION

d' *\ s ./* REGION 18

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I bI 101 MARIETTA STREET. N.W.

E ATL ANTA, GEORGI A 30323

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Report Nos.- 50-327/86-20, 50-328/86-20

Licensee: Tennessee Velley Authority

6N38 A Lookout Place

1101 Market Street

Chattanooga, TN 37401

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

Facility Name: Sequoyah Units 1 and 2

Insp'ction Conducted: March 3 - 14, 1986

Inspectors: [/[a-__ _  % j[/kDate Signed

~

P .~ HoliiFe s nay , inspecti .Te[ Leader

2f2

R. E. C ii, Jr., P ect Engineer

WM/06

Date Signed

YY$-  : _Y$ ll$Fkh

j(late Signed

W. E. Hollan'd, deside/ In ector

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Date Signed

L.W. Earner, Resi Mnt A pector

_9/'Ai,Ans

>rs' QRntfnspector

L. J. tson, esi

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Date Signed

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S. A. .c sei ,R cto

$_ AA

pe g io'ns Engineer

YhYN

Date Si ned

Approved by: ~/ _

S. P. Weise, Section Chief

h

Date Signed

Division of Reactor Projects

SUMMARY

Scope: This special, announced inspection involved 354 inspector-hours onsite in

the area of operational readiness verification, including: selected areas of the

Sequoyah Nuclear Performance Plan, Volume II; licensee's action on open items

from the Operational Readiness Inspection of December 1985 which were documented

in Inspection Report 327,328/85-46; and testing associated with Environmental

Qualification (EQ) modifications.

Results: In the areas inspected, three violations were identified:

8605210408 860423

PDR ADOCK 05000327

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1. Failure to establish and implement a procedure for the 18 month manual

engineered safety feature (ESF) functienal input check of the reactor trip

system. (Paragraph 10)

2. Failure to verify the positions of containment isolation valves. (Paragraph

13)

3. Improper procedural implementation of Technical Specification (TS)

requirements for the Plant Operations Review Committee, resulting in quorum ,

recuirements not being met. (Paragraph 16)

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REPORT DETAILS

1. Licensee Employees Contacted

"P. R. Wallace, Plant Manager

• L. M. Nobles, Operations anc Engineering Superintendent

• B. M. Patterson, Maintenance Superintendent

"J. M. Anthony, Operations Group Supervisor

• R. W. Olson, Modifications Branch Manager

• M. R. Sediacik, Electrical Section Manager, Modifications Branch

M. R. Harding, Engineering Group Manager

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• D. C. Craven, Quality Assurance Supervisor

• C- B. Kirk, Compliance Supervisor

• H. R. Rogers. Compliance Engineer

*E. W. Whitaker, Licensina Engineer

M. L. Frye, Compliance Engineer

> 0. H. Tullis, Mechanical Maintenance Group Supervisor

J. H. Sullivan, Regulatory Engineering Supervisor

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• W. H. Mackay, Reactor Engineering Supervisor

• K. W. Allen, Reactor Engineer

• R. H. O'Donnell, Staff Engineer

• F. E. Denny, QA Engineer

• H. B. Rankin, Design Services Manager

• L. D. Alexander, Mechanical Modifications Supervisor

I *J. A. McPherson, Engineering and Test Unit Supervisor

l *M. A. Cooper, Mechanical Engineer

• M. Word, Mechanical Engineer

• D. L. Widner, Modification Engineer

• R. M. Mooney, Systems Engineering Supervisor

• W. E. Andrews, Site Quality Manager

• K. Mogg, Office of Engineering (DE), Civil Engineering Supervisor

• T. K. Rochelle, OE, Civil Engineering Supervisor

Other licensee employees contacted included technicians, operators, shift

engineers, security force members, engineers and maintenance personnel.

Accompanying NRC Personnel:

• S. P. Weise, Section Chief, Division of Reactor Projects

• K. M. Jenison, Senior Resident Inspector, Sequoyah

• Attended exit interview

2. Exit Interview

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

members of his staff on March 14, 1986. Violations described in

Paragraphs 10, 13 and 16 were discussed. -The licensee acknowledged the

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

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the material reviewed by the inspectors during this inspection. .At no time

during the inspection was written material provided to the licensee by the

inspectors.

3. Licensee Actior, on Previous Enforcement Issues (92702) C

a. (0 pen) Unresolved Item 327, 328/85-46-07; Review of additional

information to determine acceptability of Post Modification Test (PMT)

53 for Auxiliary Feedwater (AFW) System Cavitating Venturis

modification. The issue was originally addressed in inspection report

327, 328/85-46. The report found that the adequacy of the modification

was questionable since the purpose of the venturi is to protect the AFW

pump from runout damage up to a maximum of 650 GPM flow. Test

deficiency DN-3 identified that the vibration exceeded the acceptance

criteria in the Y-axis where displacement was 250 mils zero to peak

versus acceptable displacement of 219 mils.

The inspector was furnished additional information with regard to' l

disposition of DN-3. The information included:

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A memo from R. M. Mooney (Systems Engineering Section Supervisor)

to J. H. Kincaid (Civil Engineer, CEB, OE) dated December 16,

1985, relating to the AFW piping vibration and cavitating venturi.

This memo addressed concerns with regard to the DN-3 disposition

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by Mr. Kincaid and requested additional information.

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Comments concerning the branch sample line downstream of the

cavitating venturi on AFW pump 2B-B by R. M. Mooney dated February

4, 1986. These comments addressed the possibility of a failure to

the non-safety-related portion of this line (which is normally

isolated from the safety-related portion of the system) due to

resonance during cavitation. The comments stated that the.

Long-Term Vibration Program would address this condition.

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Clarification of displacement readings by R. M. Mooney dated

February 6, 1986, including calculations and special graphs of

vibration data for the discharge piping of AFW Pump 28-B on

November 23, 1984. This information concluded that the process i

piping is acceptable even under worst case cavitation, but

cavitation modes should be avoided for normal operation.

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Memo from S. S. Long (System Engineer) to R. M. Mooney dated

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February 7,1986. This memo addresad the point at which venturi-

cavitation would occur (500 to 625 GPM) and indicated action was

needed to add cautions to applicable procedures to minimize

operation in this range.

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Memo from J. H. Kincaid to R. M. Mooney dated February 6,1986.

This memo stated that disposition of DN-3-dated November 23, 1985,

was still technically correct and provided additional information

to substantiate this position.

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The inspector reviewed the additional information and conducted an

inspection of the installed modification. The inspector found that the

first structural support for the sample branch line was welded to the

AFW piping and connected to smaller diameter sample tubing. This

, connection point appeared marginal and an engineering evaluation to

evaluate this connection was requested. The inspector also requested

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to see the OE concurrence on the disposition of deficiency DN-3. The

licensee stated that the test package had not been provided to OE for

review and approval at the time of the inspection; however, this would

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be accomplished when the package was complete. Based on the

information provided and discussions with the licensee, the inspector

determined that additional actions would be required in order to fully

i address this item. These additional actions are:

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Licensee establishment and implementation of the Long-Term

}j Vibration Program for this modification to monitor for any

degradation of safety-related components.

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Revision of applicable procedures to ensure that operation in the

cavitation range for these components will be minimized.

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OE review / approval of PMT-53 (which includes DN-3 for AFW pump

venturi 2B-B) and review of the engineering evaluation for the

sample line support te AFW piping.

This item will remain unresolved pending receipt of further licensee

information.

b. (Closed) Unresolved Item 327,328/85-46-09; Review of Licensee's Program ,

for Temporary Alteration Control. This item was identified in ,

inspection report 327, 328/85-46. The report stated that revision 19

to AI-9 (Control of Temporary Alterations and Use of. the Temporary

Alterations Order) requires that retesting requirements be identified -t

on the temporary alteration control form, but the inspector was unable

to determine if long term temporary modification requirements are

covered by this requirement.

The inspectors reviewed AI-9, Revision 20. This procedure requires

that ... " applicable required tests demonstrating return to normal,

shall be clearly stated on, or attached to, the control form"

(Temporary Alteration Control Form (TACF)). The inspectors then held

discussions with senior management and learned that temporary

alterations were a high priority with regard to reducing the number in

the plant. The inspectors reviewed status reports which indicated that -

temporary alterations have been reduced from over 800 in 1982 to 154 as

of March 3, 1986. Recent trending indicated that this reduction was

, continuing and that very few new temporary alterations were being '

authorized.

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The inspectors conducted a review of the active temporary alterations

by reviewing the temporary alteration control logs which are maintained

in the control room. The inspectors selected 20 active temporary

alterations and r'eviewed the TACFs for compliance with Al-9. The TACFs

reviewed were:

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85-2015, Agastat replacement on containment air return fans 2A-A

and 2B-B.

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84-0015, Cable routing change for cable 2PM4481.

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85-2007, Install mot e r on Reactor Building lower compartment

cooler fan 2A-A.

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85-2009, Install non QA heat trace.

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80-0625, Disable auto trip for "C" backup pressurizer heaters.

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82-2039, Disable hotwell pump trip during SI.

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82-2050, Disable auto trip for "C" backup pressurizer heaters.

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S3-2001, ERCW strainer backwash modification.

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84-2008 Install temporary clamp to fire protection hood.

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84-2016, Install TC f rom J-box to outside of C-zone for charging

pumps.

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81-2286, Change linkage for 2-FCV-74-16.

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81-2287, Change linkage for 2-FCV-74-28.

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81-2442, Remove check valve internals from valve 0-77-680.

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84-2039, Remove hand indicating controllers and replace with level

indicating controllers.

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81-2479, Install jumper around 2-PCV-63-58.

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83-2047, Install non QA bonnet on 2-FCV-62-170.

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83-2046, Move cables 2PM910 and 2PM911.

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85-0091, Replace agastat on containment air return fans 1A-A and

IB-B.

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86-2001, Modify low speed shaft on centrifugal charging pump 2A-A

speed increaser.

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86-2002, Install non QA heat trace.

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During the review of the preceding TACFs, the following items were

identified:

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Control room flow diagram for system 77 was not marked to identify

installation of temporary alteration 81-2479, nor was a TACF tag

installed on the main point of control. Preparations were

underway, however, to remove this temporary alteration in the near

future; and since additional examples were not found, this was

considered an isolated case.

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Required tests were not identified on TACF or attached to TACF for

temporary alterations 85-0091, 86-2001, and 86-2002 which were

established after Revision 19 to AI-9. The inspectors noted that

most of the TACFs reviewed prior to implementation of Revision 19

to AI-9 did not address testing requirements. Consequently, the

i inspectors held discussions with two STAS who were conducting a

i review of all outstanding TACFs to determine if Unresolved Safety

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Question Determinations (USQDs) were adequate and if testing had

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been conducted to assure that the temporary alteration had not ,

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affected operability of the component oi systen. Except for three

! temporary alterations which were still under review, their

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preliminary findings indicated that adequate testing had been

conducted.

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The AI-9 testing requirements for those temporary changes which

are considered significant cnanges, did not appear explicit enough

to provide the necessary instructions / guidance for quality

implementation, since the upper tier document requiranent was

incorporated without additional clarification. Additionally, the

inspectors identified that the plant QA staff was the responsible

section for establishing AI-9, even though it is implemented by

plant line personnel.

[

Based on the discrepancies identified by the inspectors and the

questionable practice of making the QA staff responsible for a line

procedure, a meeting was held with operations plant management. The

inspectors presented their findings and stated that they considered ,

that a programmatic review of the. temporary alterations program was

needed to assure that plant personnel understood all requirements and

had a workable program in place. The plant manager committed to

conduct a review of the program and implement changes as necessary to

improve this program. The followup and, review of this commitment shall

be identified as an Inspector Followup Item (327, 328/86-20-01),

c. (Closed) Violation 321,328/84-38-01. See paragraph 7.a.

4. Unresolved Items

Unresolved Items are matters about which more information is required to

determine wnether they are acceptable or may involve violations ~ or 1

deviations. One resolved item was identified in paragraph 14. i

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5. Review of Preoperational Tests

The inspector reviewed preoperational test W-8,5 concerning verification of

the plant setpoints against the Precautions, Limitations and Setpoints (PLS)

document. The licensee had determined that a deficiency . identified in the

preoperational test had not be'en resolved prior to startup. The licensee

reviewed the deficiency and acquired vendor and OE approval of the

disposition in January, 1986. The deficiency involved the alarm setpoint

for "High Flux at Shutdown." The licensee had conservatively set the alarm

at one-half decade startup rate in accordance with an FSAR commitment. The

PLS document required a setpoint of a factor of five above the countrate at

shutdown. The one-half decade setpoint was approved. The licensee issued a

discrepancy report on the failure to have proper concurrences on disposition

of preoperational test deficiencies prior to startup. Additional

preoperational te'tss are under review by the NRC due to similar findings by

the licensee on other preoperational tests.

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During the review, the inspector identified one setpoint on the auto reset

of manual block on high pressurizer pressure which had not met the

acceptance criteria but had been signed as acceptable. The licensee

provided calibration cards which indicated that the instrument had been

recalibrated to the proper setpoint prior to startup. The licensee is

reviewing preoperational test W-8.5 in detail to assure that the appropriate

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revision of the PLS document was met at startup.

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In the areas inspected, no violations or deviations were identified.

6. Followup on Inspector Identified Items (92701)

a. (0 pen) Inspector Folicwup Item 327, 328/85-46-08; Verification of

licensee commitment to INDO to clear all temporary alterations made

prior to January 1,1984. The inspectors reviewed the status report

for temporary alterations dated March 3,1986, and determined that 82

temporary alterations remained active in the plant which were initiated

prior to 1984. This item will remain open until all temporary

alterations implemented prior to 1984 are cleared.

b. (0 pen) Inspector Followup Item 327,328/85-46-06; Control Room Emergency

Ventilation (CREV) Automatic Actuation Feature, was opened to require

inspection to determine if testing is performed to verify the automatic

functions of CREV upon receiving signals from high chlorine, high

temperature or smoke detectors. The sensors for high chlorine, high

temperature and smoke are functionally tested but the CREV automatic

1' actuation from these sensors is not. No regulatory requirement was

found to perform such tests. The Watts Bar final draft Technical

3 Specifications does require all automatic functions of CREV .to be

tested. This item will remain open pending further discussion with the '

licensee as to its disposition.

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7. Verification of Nuclear Performance Plan, Volume II

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a. Post Modification Task Force

Following the identification of two instances of inadequate system

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modification testing in violation 327,328/84-38-01, the licensee ,

established a task force to review their modification testing

i activities. This included Post Modification Tests (PMTs), Functional

Tests (FTs), and applicable Preoperational (PRE 0P) Tests. The initial

four man task force consisted of engineers from the Quality Assurance

Staff, Systems / Post Modification Test Group and the Division of Nuclear

J Services. This initial group was subsequently expanded to include four

i additional engineers when concerns were raised over the possible

existence of temporary alteration test deficiencies; particularly when

temporary alterations are made permanent- through the use of

! " Documentation Only" engineering change notices (ECNs).

The Task Force reviewed modifications that were performed through the

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period of 1979 to 1985, and made a determination of testing adequacy

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using engineering judgement / experience, Topical Report TVA-TRA-TR75-1,

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Part IV of SQN AI-19; and the Nuclear Quality Assurance Manual (NQAM).

The results of the task force review was documented in their report of

j May 1, 19b5, and is summarized as follows:

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Concerns

No. With Number Resulting In PR0s

Type of

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Number Adequate with PRO * being Found

Modification Surveyed Test Concerns Written Reportable

Initial Review:

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- PMT Required 4 4 0 0 0

- PRE 0P or NO

PMT/FT Required 9 N/A N/A N/A N/A

- FT Required 12 9 3 0 0

Expanded Review:

- FT Required 51 46 5 2 0

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- FT Not Required 20 N/A N/A N/A N/A

- FT Not CSSC 2 N/A N/A N/A N/A

- TACF-FT Required 11 11 0 0 0

l - TACF-FT Not

Required 15 N/A N/A N/A N/A

124 70 8 2 0

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"Potentially Reportable Occurrence

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Additional functional testing was performed in order to resolve four of

the eight concerns identified. Out of the remaining concerns, three

were resolved when additional information was obtained. The last

concern deals with modifying the Unit 1 B Train Feedwater Regulstion

Valves in order to increase their associated stroke times. . This item

is scheduled for completion by April 18, 1986, and is being tracked by

licensee corrective action tracking _ system (CATS) item 85201. -

The Task Force identified other discrepancies and concerns in the form

of recommendations. The licensee's May 31, 1985 response to violation

327,328/84-38-01 identified four of these recommendations that were to

be acted on in order to strengthen the Sequoyah Testing Program. These

four recommendations and their final disposition are addressed below:

(1) TACFs - Revise the NQAM and Plant Instructions to address testing

of temporary alterations, including those which later become

permanent modifications (ie., an ECN issued as " Documentation

Change Only' and does not require a PMT/FT).

The NQAM was revised accordingly to read, " Temporary alterations

which are considered significant changes as. determined by PORC

and/ or become permanent modifications by the submission of a DCR

shall be tested: (a) to assure - system integrity; and (b) to

provide for evaluating the performance of the alteration before

system operation".

Administrative Instruction AI-9 was. revised in the same manner.

Since AI-9 is the lower tier document that provides the

instruction for temporary alteration control, the licensee has

agreed to evaluate the need for more _ explicit

instructions / guidance at the working level. This item will bc

tracked under the inspector followup item addressed in paragraph 3-

of this report.

(2) FT Instructions - Specify in AI-19 that FT instructions contain as

a minimum, the test scope, precautions, and acceptance criteria.

AI-19'was revised to require FT instructions to contain: test

scope; prerequisites; precautions; acceptance criteria; test

equipment data; provisions for recording details of the test; and

verification sign offs. Stated requirements' appear to be adhered ~

to.

(3) USQD Special Requirements - Include any USQD special requirements

concerning testing in PMT scoping documents, and review USQDs to

ensure that any special requirements are included in .the test

instructions.

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A memorandum was dispatched to OE requesting the discontinuance of

placing special test requirements in USQDs prepared by Design.

AI-19, Part IV was revised to include a precaution for the work

plan preparer to review USQDs for any special test requirements.

(4) Test Deficiencies - Revise AI-19 to include requirements for

identifying and correcting test deficiencies during PMT/FT

performance.

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AI-19, Part IV was revised to include complete and specific

guidelines as to the documentation and disposition of test

deficiencies.

(Closed) Violation 327,328/84-38-01; Failure to Conduct Post

Modification Tests. The June 27, 1985 NRC acknowledgement letter

confirmed that the above recommendations were corrective action

commitments. Implementation of these corrective action commitments has

been determined to be satisfactory; therefore, this item is considered

closed.

b. Systems Engineering Section

Section 2.4.6 of the Nuclear Performance Plan (NPP), Vol. II, describes

, the Systems Engineering Section (SES). The core of this group was

drawn from the preoperational test group which subsequently became the

post-modification test group after plant startup. Although this group

was re-named SES in February 1985, the procedure which defines the SES

responsibilities was approved in January 1986.

Sequoyah Nuclear Plant Standard Practice SQA 168, Systems Engineering,

defines the purpose, scope and responsibilities of the SES. This

instruction describes the System Engineer as the System technical

expert who reviews and prioritizes modifications requests, modification

workplans, and post-maintenance testing. He also provides technical

input for safety evaluations and reportable events. He performs as a '

task leader in directing investigations and tests to resolve system

related problems, improve system reliability and efficiency, and

troubleshooting efforts. He additionally performs as a test director

controlling special tests, pre- and post-modification tests and other

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nonroutine performance tests. In order to perform all these tasks ~, the

System Engineer must maintain cognizance of his assigned systems '

through periodic walkdowns, surveillance observations, maintenance

4 reports and corrective action reports. In addition to SQA168, licensee

personnel stated that section guidelines were under development to

specifically define training, qualifications and procedures to be used

by the SES.

The SES currently consists of ten dedicated systems engineers who are i

assigned up to eight systems. The SES is supplemented by about 22

additional engineers from Electrical Maintenance, - Instrument

Maintenance, Mechanical Test, Reactor Engineering, Chemical Unit, and

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Site Services who perform SES responsibilities as a collateral duty.

Some engineers have completed the formal systems training conducted at

the Power Operetion Training Center and technical training has been

completed in the area of piping vibration. Training has been or will

be scheduled for Post-Modification Testing, Special Test Methods and

Instrumentation Piping Wall Loss, and Water Hammer. Guidelines are

under development for Walkdown Procedures and Systems Notebook

Development and Maintenance. The Systems Notebook is a major effort by.

4 the licensee to define system boundaries, design criteria, maintenance

and problem history and lend consistency to the SES program throughout

personnel changes. Additionally, facilities are being installed which

will permit access to work requests for component failure trending.

The SES is in its early stages. Plant-wide training (currently planned

to be performed after plant start-up) is necessary to assure that the

engineers are provided with the required information and

j pre-implementation reviews to assist them in performing their duties.

For example, SQA-168 contains an Investigation Report form which is

used by plant personnel to request an investigation of abnormal system

performance, repeated failures or a total loss of the system. No

Investigation Reports have yet been received by the SES and none are

expected prior to the plant-wide training. The inspector noted that

the Volume II statement that "PMTs will be a major activity for the

systems engineer" had a limited impact. PMT has a specific definition

at SQN and is limited to major or complicated tests which are outlined

by design engineers in the Retest Scoping Document. The majority of

modifications at SQN are completed without issuance of a Retest Scoping

Document. In this case, a post-modification functional test is

controlled by the Modifications Engineer without involvement of the

System Engineer unless requested. Interviews with .some modifications

engineers indicated a lack of knowledge of SES and its function.

SES personnel appeared dedicated to the concept and highly motivated.

The SES was found to be as described in the Nuclear Performance Plan;

however, as noted in the plan, full implementation will be an ongoing

effort.

c. Engineering Change Notice (ECN) Backlog

A review was performed of the licensee's task force efforts to close

out the backlog of completed ECNs to which the licensee committed in

the NPP, section 4.11. The inspector found that though the task force

was established in August, 1985 to close out all backlogged ECNs, it

was redirected in October 1985, to review only the safety or safety

related aspects of the ECNs completed by September 20, 1985, and'

adjudged to be Quality Assurance (QA) applicable.by the TVA Office of i

Engineering scoping document for the modification. No separate review '

of the safety significance of each ECN was performed by the task force.  ;

Of the 785 modifications that were complete but required closure in l

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September 1985, 287 were considered to be QA applicable and had their j

safety aspects closed out. By February 1986, an additional 119 ECNs

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were completed that required closure. These ECNs have not been

reviewed for their QA applicability nor have their safety significant

aspects been closed out. Only 18 ECNs have been entirely closed since

September 1985. This has resulted in a net backlog increase of 101

ECNs. ECN closures are not currently scheduled to recommence until

after unit startups are complete.

d. Reduction in Outage Workloads

Section 4.11.1(b) of the NPP stated that in July 1984, there were 1069

open modification workplans. Licensee management concluded that this

number was too large and took action to decrease the number. This

action resulted in a 30 percent reduction in the number of open

workplans by October 1985. In reviewing this reduction in ope,

workplans, the inspector found that the majority of the reductions were

achieved through either closing workplans that had remained open due to

outstanding deficiencies, or due to consolidating workplans that were

redundant. Additionally, some workplans were cancelled-to complete the

30% reduction. The workplans that were cancelled lacked safety

significance.

e. Management Control Quality Assurance

The inspector reviewed the following licensee commitments as stated in

Nuclear Performance Plan Section 3.2.3 on upgrading procedures to

assure effective management control of plant activities

(1) The licensee stated in NPP section 3.2.3.(a) th t tiering of

procedures would be reduced by decentralizing central office

j manuals and procedures. The inspector reviewed the licensee's

1 actions to eliminate redundant upper tier procedures,

i

In the past, the licensee had nineteen Area Plan Program manuals

of corporate . level procedures, each consisting of one to four

volumes. These procedures were categorized as -either licensee

pulicies (not regulatory), requirements (regulatory requirements

or commitments), or standards (guidance or recommendations). The

procedures were implemented by each nuclear plant by issuing site

procedures.

The licensee established a program in May 1985, to review the Area

Plan Program manual procedures to determine if the procedures

required revision, reassignment to another category, or

cancellation. The objective was to eliminate duplication between

the upper tier documents and site procedures. Approximately 124 <

upper tier procedures have been cancelled to date. Area Plan

'

'  !

Program manuals in resource management, radiation protection, l

emergency preparedness, preliminary operations, field services and l

,

.

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12

core management have been cancelled. The environmental protection

program manual will be cancelled in the future. The licensee

! stated that the review of _ the corporate level procedures was

approximately 15*; complete.

I

The cancelled procedures have been sent to the site for

verification that policies, requirements, and standards are

implemented by site procedures. The licensee is utilizing an

existing administrative control procedure to track the cancelled

procedures through the site review process. This procedure

assigns each procedure a tracking number and requires that target

completion dates be established. The latest target completion

date for the onsite procedure review is June, 1986. QA

verification of appropriate site procedure revisions is required

for all cancelled documents involving requirements or policies.

The licensee stated that as of January 1986, the review of the

upper tier procedures has been stopped and future actions with

regard to revising or cancelling upper tier procedures was under

review by corporate management. These future actions will I

consider the workload on plant personnel who are reviewing and

processing the site procedures affected by the revisions ~ and

cancellations.

(2) The licensee stated in NPP section 3.2.3.(c) that an experienced

, SRO would be assigned to review and update operating procedures.

In addition, the licensee stated that this individual would review

.

modification work plans to assure that appropriate operating

procedures were revised and training requirements identified upon

completion of the modification.

The inspector discussed the review processes with the assigned SRO

and reviewed Administrative Instruction AI-19, Part IV, Plant

i Modifications After Licensing. The licensee stated that this

procedure was under revision to provide better guidance on the

, review of work plans for procedure revisions. Although the

'

program has not been set up as stated in the NPP, the functions

discussed are performed by SR0s in different sections.

(3) The licensee stated in NPP section 3.2.3.(d) that the upgrade and

reformat of emergency operating procedures (E0Ps) (non-RVLIS) had

been completed in August 1985. These revisions were made to meet

NUREG-0737 requirements. In addition, the licensee stated that

training on the revised procedures was completed prior to

implementation. ,

The inspector reviewed the licensee's responses to Supplement 1 to 1

! REG-0737 (Generic Letter 82-33) dated October 31, 1983,

sugust 21, 1985 and January 13, 1986. These letters provided the

schedule for implementation of the E0Ps, the Procedures Generation

Package (PGP), the Writer's Guide and responses to NRC questions.

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13

The inspector verified that the E0Ps had been implemented in two

phases. The first set was implemented on October 4, 1984, and the

second set was implemented on August 21, 1985. The licensee's

responses provided in their January 13, 1986 letter are currently

under review by the NRC.

The inspector reviewed the PGP and verified: that a Step

Deviation Log _had been maintained to document deviations from the .

'

generic vendor guidelines; that a verification and validation

program was established and had been conducted during the review

process; and that discrepancies had been identified and resolved.

In Part IV.D.4 of the PGP, the licensee stated that a

plant / control room walk-through would be conducted to assure that

the procedures were compatible with plant / control room hardware.

The inspector determined that although the licensee had conducted

the control room walk-through, documentation of a plant

walkthrough was not available. The licensee stated that additional

information would be provided. This is identified as Inspector

Followup Item (327,328/86-20-02).

Part C.12 of the Writer's Guide states that procedures will be

structured such that the E0Ps can be implemented by the minimum

shift staffing required by the plant's Technical Specifications.

The licensee stated that only licensed operators had been

considered in this review. The . inspector identified a concern

that at least minimum staffing of Auxiliary Unit Operators should

have been considered and that the licensee should also examire

staffing in any other support areas. The inspector discussed this

concern with the licensee and determined that the Radiological

Emergency Plan has provisiuns to assure adequate staffing in a

time frame consistent with the implementation of emergency

actions.

4

The inspector reviewed the initial training as described in the

January 13, 1986 response. The inspector verified that the

licensee completed simulator training in accordance with Part 0,

Table 1 of the response. In addition, the inspector verified that

the licensee conducted classrcum training for all E0Ps prior to

implementation. The inspector reviewed selected training records

!

and determined that written examinations and simulator evaluations

had been conducted on the E0Ps. No violations or deviations were

identified in the training area.

I During the review of the licensee's August 21, 1985 response,-the

inspector determined that statements appear to imply that the

titles and contents of the Sequoyah E0Ps are the same as the

vendor guidelines. The inspector discussed the statements with

the licensee and determined that certain-of the vendor guidelines

a

had been ' combined and/or renumbered such that the correlation

,

between the E0Ps and the vendor guidelines were not comparable on

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4

14

the basis of title. The licensee is reviewing this submittal to

assure that sufficient information is provided tc clarify the

differences between the vendor guidelines and the Sequoyah E0Ps.

In the areas inspected, no violations or deviations were identified.

8. Taylor to White Letter of 2/11/86

A follow-up inspection was performed on material descrepancies identified

during an equipment qualification inspection conducted by the Office of

Inspection and Enforcement (I&E) on January 6-17, 1986. These descrepancies

were identified in section c. of the enclosure to a letter from

James M. Taylor (NRC) to Steven A. White (TVA) dated February 11, 1986.

Maintenance Requests have been generated to correct items 2, 3, 4, 5, 9, 11,

and 12. Item number 6 was corrected by fully closing valve 2-63-598. The

pipe support question identified in item number 7 is under evaluation. The

housekeeping concern identified in item number 1 will be reviewed during

future inspections.

In the areas inspected, no violations or deviations were identified.

9. PMTs Associated with Environmental Qualification (EQ) Modifications

The licensee is currently performing some 67 maintenance or modification

activities on safety-related electrical equipment in order to satisfy the EQ

requirements of 10 CFR 50.49. The inspector reviewed the PMTs associated

with a selected number of these modifications. A brief discussion follows

to clarify the licensee's terminology and program. The PMT program is

controlled by Administrative Instruction AI-19, Part IV, (Plant

Modifications Af ter Licensing). This instruction requires a PMT if OE

requires it through issuance of a test scoping document. The test scoping

document contains the scope, purpose, test description and acceptance

criteria. The plant systems engineer then uses the scoping document to

prepare a detailed test instruction. Af ter completion of the PMT, test

results are reviewed by OE. If no scoping document is issued, no PMT is

required. None of the EQ modifications reviewed required a PMT. Per AI-19,

in cases where OE determines that scoping documents are not required, the

modifications cognizant engineer must prepare a functional test instruction

as part of the workplan which implements the modification. The functional

test is used to ensure that new components perform their intended function

and that the work did not inadvertentty degrade an operating system or

component. In general (although not always the case), PMTs are used for

major system modifications and involve system level tests (similar to

preoperational tests); whereas functional tests are used for component level

modifications and involve component level tests (such as device calibration,

response time or insulation integrity checks). The criteria OE uses to ,

determine when a PMT is required is procedurally stated in generalities and  ;

is the subject of close scrutiny by licensee management. More detailed i

criteria is being developed. All of the EQ modification workplans reviewed 1

contained functional test instructions and acceptance criteria. It was I

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15

evident through discussions with various licensee representatives throughout

the inspection that considerable supervisory and management attention has

been focussed in the area of these functional tests. The following

paragraphs describe the functional tests reviewed:

a. Limitorque Valve Modifications

Engineering Change Notice (ECN) L6544 was issued to implement a

Category "D" Field Change Request (FCR) and resolve a Significant

Condition Report (SCR) on the EQ of Limitorque Actuators. In order to

resolve the SCR, unqualified wiring within the limit switch compartment

is being replaced with qualified wiring. Prior to this work,

connection drawings and elementary diagrams were revised by the FCR in

order to simplify and clarify the drawings and correct drawing errors

to facilitate the re-wiring effort. For example, some drawings were

shown with a limit switch and torque switch wired in the valve opening

control circuit which were jumpered out and not functionally in the

circuit. The drawings were changed so that during the re-wiring work,

the limit switches and torque switches did not have to be wired into

the circuit and tnen jumperd out. In a second type of change, one type

of valve closing control circuit was found to have a torque switch

wired in such a manner that it couldn't function as designed. The

wiring drawing was changed to correct this situation prior to the EQ

re-wiring work. A third type of valve closing control circuit was

found to have a torque switch bypassed by a limit switch until the

valva reached the 97% closed position. Since an identical limit switch

was also in series with this torque switch / limit switch combination,

the torque switch was effectively bypassed and therefore not a

functional part of the circuit. The drawings were changed to remove

the torque switch from the circuit for stopping valve motion in the

closed direction.

The inspector expressed a concern that changes to the second and third

types of circuits described above were more than a simplification of

the circuit or a substitution of an equivalent circuit. In the second

example for instance, a valve closed limit switch opened to stop the

drive motor in the closed direction in the pre-existing configuration.

In the new configuration a limit switch and torque switch are in

parallel in the closing circuit such that the limit switch must actuate

at 97% valve closure and the torque switch must also actuate before the

drive motor will be deenergized. The result of this change is that the

valve is now torqued shut on every cycle as opposed to jus +. having

torque protection in the event of a limit switch missadjt . ment or

failure. In the third example discussed above, a 1979 ECN .4 0 . 2257)

was implemented to install the limit switch bypass around the torque

switch. The intent of this ECN was to prevent the torque switch from

operating in mid stroke, but to restore the torque switch protection

during the last few percent of valve travel in the closed position.

The new modification to this circuit removes the torque switch

protection at all times.

,

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_. . _. - _ _ _ - _ _ _ _.

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Licensee design personnel stated that each actuator's application was

considered prior to changing the control circuits. In general, gate or

. globe valves use torque switches in the closing circuit except for

'

fast-acting valves which should coast to the seat. Torque switches are

not used in control circuits for butterfly valves except for valves

with rubber seats and those where seat leakage is critical. This

, essentially constituted a redesign of the control circuits for some of

j the valves. The 1979 ECN which bypassed the- torque switches was

apparently improperly implemented. No torque switches in' the revised

i circuits can stop valve motion in mid-stroke, and this ECN has now been

properly corrected. The inspector questioned if the drawing

i

'

descrepancies and non-functional torque switches (incorrectly wired

control circuits) had been evaluated for reportability. Licensee

representatives indicated that a formal evaluation was not performed as

outlined in SQN-84, Reportable Occurrences. The inspector was unable

4

to determine whether the drawing discrepancies and non-functional

torque switch could have prevented the fulfillment of a safety function.

This issue is an Inspector Follow-up Item (327,328/86-20-03).

The modification work required removing all installed wiring and

re-wiring the Limitorque valves per the new drawings. The functional

tests conducted by Modifications personnel consisted of a hand cycling

of the valve actuators with a check on limit switches, closing and

opening contactors, and in some cases annunciators with the valve in

the fully closed, fully open, and in the mid position. The valves were

then cycled opened and closed electrically. After completion of these

j tests, electrical maintenance personnel were to perform additional EQ

i

'

maintenance which consisted of grease inspections on the main gear case

and limit switch gearbox, limit switch adjustments, limit switch

, contact gap check and inspection, gasket inspections, motor insulation

checks, and stroke timing. In addition, baseline data will be

'

collected using the Motor Operated Valve Analysis and Test System

(M0 VATS) equipment.

Alt'iough the inspector initially expressed a concern about the adequacy

of the post-modification functional test required by the EQ

modification, the concern was rendered moot by the extensive efforts

i performed following the modification. These efforts (EQ maintenance,

M0 VATS, and routine surveillance tests) were not formally required as

post-modification tests by the licensee and the documentation will not

reflect that the modification and follow-up maintenance actions are .

related. The inspector, however, took credit for these follow-up

activities in order to make a determination that the tests following

] the modification activity were adequate. 1

>

l

l b. Containment Pressure Transmitter Modifications

,

' ECN 6554 and.Workplan 11912 replaces the existing containment pressure

transmitters 1 & 2 PDT 30-42 and 1 & 2 PDT 30-43 with qualified

transmitters. These transmitters provide input to containment-

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isolation and containment spray logic. The replacement transmitters

were made by the same manufacturer as the previous transmitter and are

i functionally and electrically equivalent. Functional testing consisted

of a bench calibration, post-installation calibration, response time

test, and local leak rate test. All functionals were performed with

< pre-existing Surveillance Instructions and Instrument Maintenance

e Instructions, each with applicable acceptance criteria. One potential

'

problem was found with the post-installation calibration data which had

not been evaluated by the licensee. The as-found data on both Unit 2

transmitter < was out-of-tolerance even though the bench calibration had

recently been performed. Ur.it 1 as-found calibration data was not -

recorded since maintenance personnel considered this an initial

calibration not requiring as-found data. Licensee representatives

speculated that the transmitters zero adjustment knob was disturbed

,

during the in-tallation.

A lack of consistency was noted in the way functional tests were

performed on Unit 1 and Unit 2. The functional test instructions

required that the " applicable portions" of the channel calibration

, instruction be performed. Some of the procedure steps completed on the

Unit 1 transmitter were not performed and marked "not applicable" on

the data sheets for the Unit 2 transmitters. These steps involved

cable resistance measurements on wires not affected by the

modification. Licensee representatives later stated that these steps

were indeed not applicable for the purpose of the post-modification

functional test and could have been deleted during the Unit 1

transmitter calibration. The use of such terminology as " perform the

"

applicable portions of ... is a recurring deficiency and will be

tracked as an Inspector Follow-up Item (327,328/86-20-11).

c. Annulus Differential Pressure Transmitters

i

ECN L6488 and Workplan 11931 replaces the existing differential

pressure transmitters 1 & 2 PDT 65-80, 82, 90 and 97. These

transmitters function in the Emergency Gas Treatment System to control

annulus vacuum. The replacement transmitters were functionally

equivalent to the previous transmitters. Functional tests consisted of

a bench calibration, post-installation instrumentation calibration and

loop calibration. One concern was expressed to modifications personnel

regarding the level of control exercised over verification of hi and lo

!

side instrument connections to differential pressure transmitters.

This work plan contained caution statements and several verification

signatures that the hi/lo pressure taps were properly connected. -The

workplan for the containment pressure transmitters, previously

discussed, contained none of these control measures. Modification

personnel indicated that there is no policy for these checks and the

differences are due to the personal preferences of the modification

engineers. Since all post-modification functional tests hook up test

.

. . - . . . . .. . . . , . - . . . . - . _ , . _ . , . . _

_. . . , . . . . ~ _ , , . . _ , . . _ . - . , _ _ . , _ , , ..

_ . _ . _ _ - _ . . _ _ .__ _ _ .

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1 equipment downstream o' the instrument isolation valves, an extra

j measure of control is aporoprit.te to prevent incorrect hookup _- of

i transmitters. This item was aiscussed with licensee representatives

j during the inspection and again during the exit meeting.

1

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d. Containment Electrical Penetrations

i

l' ECN L6490 and Workplan 11801 installed containment . electrical

!

penetrations for Radiation Monitoring and Nuclear Instrumentation

Systems. Functional tests consisted of a soap bubble check of weld

integrity during a Containment Integrated Leak Rate Test (substituted '

for a local leak rate test requirement for convenience), conductor

continuity checks and 500VDC megger test of insulation integrity. No

problems were identified with this modification.

i e. Temperature Switches In Various Systems

I ECN 6551 and Workplan 11916 changed setpoints for various switches in

i Systems 1, 12 and 30. The setpoints .were changed to account for

excessive drift due to the extreme' environment encountered in the event

j of postulated accident conditions. The setpoints were chang'e d using

! existing plant procedures. Functional tests consisted of the

.

application of heat with a heat gun and a verification that the switch

j actuation created the desired response (such as valve or damper

isolation). No problems were identified with this modification.

i f. Steam Generator, Containment Sump, and Pressurizer Lever Transmitters

! This activity was considered maintenance and was' performed on seventeen

1

Barton level transmitters. The change consisted of hard wiring 'a pin '

, connector internal to the transmitter. The work was controlled by

Special Maintenance Instruction 2-317-23 which' was based upon

manufacturers instructions for completing the change. A problem with

the continuity of the pin connection _was noted during the environme.ntal

tests. The recommended fix consists of soldering the pin connection.

'

PMTs consisted of an instrument calibration per existing procedures.

The calibration was not shifted by the modification and no adjustments

were necessary on the transmitters reviewed. No problems were

'

identified with this change.

In the areas inspected, no violations or deviations were identified.

i 10. Engineered Safety Feature Logic Review

The inspector conducted a review of ' selected TS surveillance requirements

and procedures, and verified that the following -TS requirements were

adequately addressed in surveillance procedures: ,

!

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TS 4.3.1.1.1, Table 4.3-1, Item 19

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1

, - - - -%_,,.-. _ , , -_v. ,y.,,,~m ,.,,,.,,.-_,,,....,.---r.-_r.,,., #%.,,.,,--,...ew,m.~, ,,~m .-...-....n ,my... . ., ,

. _ . . _ _ _ . . _ _ _ . _ _. --

_ . _. _ _ - _ _ _ _ _ _ _ _ _ -

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TS 4.3.2.1.1, Table 4.3-2,. Items 1.a, 1.b, 2.a, 2.b, 3.a.1,.

3.'a.2, 3.b.1, 3.b.2, 3.c.1, 3.c.2, and 6.b

TS 4.5.2.e.2.a, 2.b and 2.c

TS 4.6.3.2.a and 2.b

TS 4.7.3.b

!

TS 4.7.8.d.2

TS 4.8.1.1.2.d.2, 3, 4.a, 4.b, 5, 6, 7a, 7b, 7c, 8, 9, 10.a. 10.b,

10.c, and 11

! Surveillance procedures reviewed in total or in part included:

AI-4 Document Control, revision 53

'

l SI-7 Electrical Power System: Diesel Generators, revision 33

1

l SI-9 Actuation of Automatic Valves via SI signal for

i non-testable Boric Acid and ECCS Flow Path Valves,

j revision 18.

SI-26.1A Loss of Offsite Power with Safety Injection - D/G 1A-A

j CNTNT ISOL Test', revisions 9,10 and 11

SI-26.1B Loss of Offsite Power with Safety Injection - D/G 1B-B

l Test-

1

i SI-26.2A Loss of Offsite Power with Safety Injection - D/G 2A-A

l CNTMT ISOL Test, revision 12 and 13

t

i SI-26.2B Loss of offsite power with Safety Injection - D/G 28-B

i Test, revision 11

,

l SI-90-8 Reactor Trip Instrumentation monthly functional test

t (SSPS) Unit 1, revision 3

l SI-119 ERCW auto actuation from an SI signal, revision 6

i

SI-135 EGTS cleanup subsystem automatic start, Units 1 and 2,

revision 7

SI-247.100 Response time testing of the Engineered Safety Feature

Instrumentation (refueling outage)' Units 1 and 2,

revision 6

i

! During this review, the inspector identified that the relay contacts

!

associated with the manual Engineered Safety Feature (ESP) control room

! switches HS-63-133A and HS-63-1338 were not included in the testing of the

!

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Reactor Trip System (RPS). These contacts, as shown on plant drawing

45N699-1, are in parallel with the manual .RPS control switches,1-RT1 and

RT2 (Unit 1). Thus, testing of the RPS manual switches verifies proper

operation of the remainder of the circuit. A similar condition exists on

+ Unit 2. The requirement to perform a surveillance on this circuit is in

Technical Specification 4.3.1.1.1 which requires a test to be performed as

prescribed in Table 4.3-1. Table 4.3-1 (item 19, note 4) requires " manual

ESF functional input check every 18 months." Technical Specification

e 6.8.1.c requires procedures to be written for surveillance of safety related

equipment. Since the above equipment is safety related, failure to have a

procedure for the surveillance is not in accordance with TS 6.8.1.c, and is

a Violation (327,328/86-20-04).

The inspector determined that some errors are being incorporated into

surveillance procedures during the revision process. The items found by the

inspector had also been identified by the licensee and revisions were in

progress to correct the specific items. Three items of interest in this

area are: (1) two steps (4.3.3 and 4.3.4) were dropped from revision 10 of

SI-26.1A probable cause was inadvertent deletion by the word processor

i operator; (2) SI-26.2A, revision 13 was issued with a non-conservative TS

'

value for diesel generator frequency (58.1 Hz vs. 58.8 Hz, step 11 of data

4

sheet 5) - considered as a typo; and (3) SI-7, revision 34 was found during

performance to have verification of diesel generator fuel oil tank levels no

longer incorporated in the procedure - probable cause was failure to

properly incorporate revised pages into the procedure prior to issuance

'

(e.g., steps were put on subsequent page which was not replaced). These

items were discussed with plant management.

In addition, review of AI-4, Document Control, indicated a weakness in

processing some revisions. In processing non-intent changes, the Plant

Operations Review Committee (PORC) will review a hand written change, then

. it will be typed, returned to PORC and issued to the field. During a PORC

!

meeting, an inspector witnessed two such changes being returned to PORC. In

this instance it was observed that these items were identified as having

previous PORC approval and as a result were immediately approved. Thus the

responsibility for verifying the technical adequacy of the typed revision

{ rests with the typist and word processor proof reader. Neither of these are

i technical people. The licensee is considering a change to AI-4 so that the

, typed version is returned to the originator for review prior to the final

!

PORC approval. The licensee's corrective actions, if appropriate, to reduce

the number of problems specified in (1), (2) and (3) above and the change to

AI-4 is considered an Inspector Followup Item (327,328/86-20-05).

i 11. Drawing Control

As part of the logic surveillance test procedure review, drawings were

utilized which were either controlled copies in the control room and the

technical support center (TSC) or ones obtained directly from drawing

control. A comparison between those available for use and those obtained

from drawing control revealed no discrepancies in revision dates. The

inspector did note several minor discrepancies not effecting technical

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information such as drawing references and engineering change number

references were inaccurate or missing. The licensee had recently identified

! this in an internal TVA memorandum from J. B. Vineyard to H. B. Rankin dated

March 4, 1986. This memorandum stated that "as-configured drawings reviewed

during the audit contained numerous errors. . . while most problems were

! minor, the number of' errors identified indicated a failure to maintain

i complete program control of the as-configured drawings located in the

'

control room". Inspection of the licensee's resolution of this statement is

'

an Inspector Followup Item (327,328/86-20-06).

In the areas inspected, no violations or deviations were identified.

,

12. Quality Assurance Staff Responsibility For Plant Procedures

The QA staff is assigned as the responsible group for the following

! procedures:

1 AI-4 Plant Instructions-Document Control

j AI-7 Recorder Charts & Quality Assurance Records

i Al-9 Control of Temporary Alterations & Use of The Temporary

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Alterations Order

AI-11 Receipt Inspection Nonconforming Items, QA Level / Description

Changes and Substitutions

. AI-12 Adverse Conditicns and Corrective Actions.

AI-13 Control of Inoperable & Unavailable CSSC Equipment

AI-20 Inspection Program

AI-26 Prevention of Foreign Material in The Primary System

AI-32 Quality. Assurance Surveys

l AI-34 Training and Certification Program for QC Inspectors ,

AI-36 Storage, Handling, & Shipping of QA Material

AI-39 Critical Structures, Systems & Components-(CSSC)

SQA1 System of Standard Practices

SQA134 Critical Structures, Systems & Components -(CSSC)

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SI-114 Preservice Baseline Inspection for TVA SQNP-Units 1 and 21

SI-114.1 ASME Section XI In-service Inspection Program Unit 1

SI-114.2 Inservice Inspection Program for TVA SQNP (Unit 2 Only)

'

SI-284 Ultrasonic Inspection of Pressurizer Relief Line Repair-

SQA159 Standards and Guides for QA Level III Items

SQA160 Materials Which May Come in Contact With RX Coolant

j SQA161 Procurement of 10 CFR 50.49 Equipment

l SQA162 Purchase Specifications For CSSC Materials r

Some of these procedures are implemented by the line organization.

Region II personnel are currently reviewing the appropriateness of this

practice with respect to line and quality assurance staff independence.

This is an Inspector Followup Item (327,328/86-20-07).

1

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In the areas inspected, no violations or deviations were identified.

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13. Verification of Primary Containment Integrity

The inspector reviewed the licensee's procedure Surveillance Instruction

SI-14, Verification of Containment Integrity-Unit 1, Revision 27. This

procedure was provided to demonstrate containment integrity through veri-

fying the proper positioning of all containment isolation valves, with

the exception of energized automatic isolation valves, while operating in

4 mode 4 or above at least every 31 days and prior to heat up to mode 4 from

mode 5 for each cold shutdown as required by TS 4.6.1.1.a. A comparison of

the as constructed drawings of selected systems penetrating containment was

made with SI-14. This comparison revealed the positions of 20 vent, drain  ;

and test valves, which form isolation barriers to their associated contain-

ment penetrations, that were apparently not verified during the performance

2

of SI-14 in Unit 1. However, for the affected systems, the position of

these particular valves is self disclosing and/or maintained with system

alignment check sheets. These valves are as follows:

"

Containment

System Penetration Isolation Valves

1

Chemical & Volume X-15 62-707

Control

Component Cooling X-29 70-735

X-50A 70-737 f

X-508 70-6788  ;

X-52 70-691B ,

X-35 & X-53 70-702B,C,E & F l

70-703

70-760

70-762

70-763

Containment Spray X-48A 72-543

4

72-545 t

X-48B 72-546

72-544

s

Fuel Pool Cooling and X-82 78-228A  :

Cleaning X-83 78-226A

Upper Head Injection X-110 87-523  ;

The inspector reviewed the surveillance records for the performance of SI-14

prior to the mode change from 5 to 4 on May 20, 1985, and while the unit was

in mode 4 or above from May 20 to August 24, 1985. The licensee performed

SI-14 on the following dates:

May 17, 1985 June 3, 1985  ;

June 6, 1985 June .19, 1985

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June 27, 1985 July 25, 1985

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During these surveillances, the containment isolation valves listed above

were not verified for their proper alignment as required by TS 4.6.1.1.a

in order to demonstrate containment integrity while operating in mode 4 or

above, or prior to heat up to mode 4. The failure to check the positioning

of these containment isolation valves will be identified as Violation

(327/86-20-08). The licensee should conduct a detailed review on both

Sequoyah units to determine if there are any additional containment isola-

tion valves that are not incorporated in SI-14.

14. Review of Chemical and Volume Control System Containment Penetration

Boundaries .

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The inspector reviewed the licensee's compliance with 10 CFR 50 Appendix A,

General Design Criteria (GDC) 54, 55, 56 and 57 in the design of the

following Chemical and Volume Control System (CVCS) containment penetra-

tions:

Penetration Function

X-16 Volume Addition Through Charging and

Pressurizer Spray j

X-43A Loop 3 Reactor Coolant Pump (RCP)

Seal Water

X-43B Loop 2 RCP Seal Water

,

X-43C Loop 4 RCP Seal Water

X-43D Loop 1 RCP Seal Water

Table 6.2.4-1 of the FSAR indicates that penetration X-16 is designed to '

meet GDC 56, and is considered as an Isolation Class I penetration (having

as a minimum two isolation valves in series, one inside containment and one ,

outside). There are no commitments to the GDC indicated for penetrations l

X-43A, B, C, or D, but the table did classify them Isolation Class II '

penetrations (having as a minimum one isolation valve).

Section 6.2.4.3 of the FSAR states that "the requirements and intent of NRC

General Design Criteria 54, 56, and 57, and Regulatory Guide 1.11, have been

met with only three exceptions" - neither of which includes the above

penetrations. A review of the above penetrations revealed that their i

current design apparently does not comply with the requirements of GDC 55,

56, or 57 as none of these penetrations possess an automatic, remote manual,

or locked closed containment isolation volve outside containment.

(FCV-62-90 could be used to meet this requirement for penetration X-16, but

it is not co.isidered as such by the licensee or Table 6.2.4-1 of the FSAR.) ,

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This apparent failure to meet the GDC was discussed in a telephone

conference call between TVA - Licensing /0E, NRR - Contai, ment Systems

Branch, IE - Operating Reactor Programs Branch, and Region Il on April 14,

1986. During this conference, the licensee indicated that these penetra-

tions were considered to meet the GDC since each has an inside containment

barrier consisting of a check valve, and an outside containment barrier

consisting of a " closed system." Accordingly, TVA agreed that penetration

X-16 was incorrectly categorized as an Isolation Class I penetration

designed to meet GDC 56; instead, Table 6.2.4-1 should be revised to show

penetration X-16 as an Isolation Class II penetration designed to meet

GDC 55. NRR acknowledged the use of a " closed system", but only in

conjunction with other outside isolation barriers (e.g. , remote manual

valves, manual handwheel valves, etc.); and in either case, an exemption to

the GDC should have been taken. Pending further followup by the NRC with

its licensing staff, this shall be identified as Unresolved Item (327,

328/86-20-09).

15. Design Changes and Modification

Engineering Change Notice (ECN) L5095, ,reviously inspected in NRC

Inspection Report No. 327,328/85-46, was reviewed to determine if the proper

analyses and PMTs had been performed to assess the effects of the ECN's

installation of block and drain va'ves on the various containment

penetrations modified. The inspector found that a seismic analysis of the

system design modification had been performed at the Watts Bar Nuclear Power

Plant. Though no seismic analyses were specifically performed at Sequoyah,

the licensee asserted that these modifications had been appropriately

analyzed as the systems and the modifications performed at Sequoyah were

apparently identical to those analyzed at Watts Bar.

A review of the local leak rate test requirements and results indicated that

no additional local leak rate tests were required to be or were actually

4

performed to test these modification ~s. Additionally, it was determined that

the performance of these modifications had not caused an increase in the

containment penetrations local leakage rates measured during the licensee's

performance of the periodically required Type C local leakage rate tests. ,

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16. Onsite Review Committee (40700)

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The inspector reviewed the Sequoyah Nuclear Plant Standard Practice

procedure SQA21, Onsite Independent Review (Plant Operations. Review

Committee (PORC)), for compliance with TSs in the areas of composition,

,

alternates, quorum, responsibilities and records. The minutes of meetings

held in the months of May, June, July, August, September, November, and

December 1985, were reviewed for proper centent as defined by TSs. The

inspector attended one PORC meeting to observe the conduct of the meeting.

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The review of SQA21 against TS 6.5.1 revealed that the procedure was l

adequate in the areas of alternates, quorum, responsibilities and records.

In the area of composition, SQA21 did not comply with TS 6.5.1.2 which

establishes a PORC composed of the Chairman and six members. SQN21-

establishes a PORC composed of the Chairman and eight members with

provisions that the Operations Supervisor or the Assistant Operations )

Supervisor and the Engineering Group or Engineering Section Supervisor can  !

participate as a voting member. This,in effect, incorporated as members,

two alternates: the Assistant Operations Supervisor and the Engineering

Section Supervisor. The use of these individuals as members, vice

alternates, resulted in the quorum requirements not being met since an

insufficient quorum of members existed. The persons utilized did meet ANSI

N18.1-1971 qualifications; and the inspector noted that a 1984 TS amendment

request had been submitted to NRC, but was never approved.

Approximately forty examples of inappropriate PORC composition were found

during the review of 1985 PORC minutes (e.g. meeting numbers 3351, 3353,

3356, 3359, 3364, 3367, 3378, 3381, 3389, 3401, 3402, 3403, 3407, 3420, I

3421, 3422, 3429, 3434, 3437, 3449, 3471, 3473, 3512, 3513, 3521, 3663, '

3674,3676,3678,3679,3684). This improper implementation of TS require-

ments for PORC, which resulted in the quorum requirements not being met, is

a Violation (327,328/86-20-10).

17. Items Requiring Licensee Action Prior to Res: art

There are four restart items that have been identified from the proceeding

paragraphs; three of which were addressed in the March 25, 1986 letter from

J. A. Olshinski to S. A. White. A summary of these four restart items,

reference to their applicable report paragraph, and any specific comments

about these items are presented below.

a. The 18 month manual engineered safety feature functional input check of

the reactor trip system per TS 4.3.1.1.1. was not being performed, nor

was there a procedure for this test. It is expected that an

appropriate procedure will be established and implemented such that the

required TS surveillance is performed. This item has been identified

as Violation 327,328/86-20-04 and is further addressed in paragraph 10

of this report,

b. A review of systems 62, 70, 72, 78 and 87 in Unit I revealed 20 vent,

drain and test valves, each forming a containmentnisolation barrier,

which were not verified shut during the performance of SI-14

(Verification of Containment Integrity). It is recognized that for the

valves identified, their position is self-disclosing and/or maintained

with system alignment check sheets. However, there may be other

containment penetrating systems where this is not the case. Conse-

quently, the-licensee should conduct a detailed review on both Sequoyah

units to determine if there are any additional containment isolation

valves that are not incorporated in SI-14. This item has been

identified as Violation 327/86-20-08 and is further addressed in

paragraph 13 of this report.

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c. Five containment penetrations in the CVCS do not appear to meet General

Design Criterion 55, 56 or 57, and no exception appears to have been

taken. This item is being reviewed by the NRC Licensing Staff. The

licensee should pursue this item to resolution, ensuring that similar

situations don't exist in other containment penetrating systems. This

has been identified as Unresolved Item 327, 328/86-20-09 and is further

addressed in paragraph 14 of this report.

d. Based on identified discrepancies, the plant manager committed to

conduct a review of the temporary alterations control program and

implement changes necessary to improve this program. In a March 18,

1986 letter from R. Gridley to J. A. Olshinski, it was indicated that

each open temporary alteration was to be reassessed to ensure that

plant safety is not degraded due to the existence of the alterations.

At the time of the NRC Operational Readiness Inspection, three

temporary alterations were still being evaluated for adequate testing.

Since documentation of testing is required to be with the TACF,

improvement in this area should be considered. The licensee review of

the temporary alterations control program is being tracked as Inspector

Followup Item 327, 328/86-20-01, and is further addressed in paragraph

3.b. of this report,

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