IR 05000327/1988034: Difference between revisions

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{{Adams
{{Adams
| number = ML20154R483
| number = ML20247C149
| issue date = 09/15/1988
| issue date = 03/09/1989
| title = Insp Repts 50-327/88-34 & 50-328/88-34 on 880606-0711. Violations Noted.Major Areas Inspected:Operational Safety Verification,Including Operations Performance,Sys Lineups, Radiation Protection & Safeguards & Housekeeping Insps
| title = Forwards Corrected Notice of Violation from Insp Repts 50-327/88-34 & 50-328/88-34
| author name = Harmon P, Jenison K
| author name = Mccoy F
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
| author affiliation = NRC OFFICE OF NUCLEAR REACTOR REGULATION (NRR)
| addressee name =  
| addressee name = Kingsley O
| addressee affiliation =  
| addressee affiliation = TENNESSEE VALLEY AUTHORITY
| docket = 05000327, 05000328
| docket = 05000327, 05000328
| license number =  
| license number =  
| contact person =  
| contact person =  
| document report number = 50-327-88-34, 50-328-88-34, NUDOCS 8810040275
| document report number = NUDOCS 8903300133
| package number = ML20154R471
| package number = ML20247C153
| document type = INSPECTION REPORT, NRC-GENERATED, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| document type = CORRESPONDENCE-LETTERS, NRC TO UTILITY, OUTGOING CORRESPONDENCE
| page count = 32
| page count = 2
}}
}}


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NUCLEAR REGULATORY COMMISSION REGION 11 101 MARIETTA ST., $q ', , , , j[ ATLANTA. GEORGIA 30323 Report Nos.: 50-327/88-34 and 50-328/88-34 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 .
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Facility Name: Sequoyah 1 and 2 Inspection Conducted: June 6 - July 11, 1988
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Inspectors:-1 6 M [ A M    /iff[
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K.mJenyn,seniorRestdentInspector   fate /51gned i A AmAt fri    9kVl88 P. J. Parmon, 5dngr Mesident Inspector  Date Signed Resident Inspectors: D. P. Loveless W. K. Poertner P. G. Numphrey K. D. Ivey    I Approved by: JP[   7f /E)[
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K.fl. J6nisfn Acting Chief,  /Date'51gned I ProjectsStet}on1    l DivisionofTVAProjects    !
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2  OfficeofSpecialProjects Summary Scope: This routine, announced inspection involved inspection onsite by the  <
  : Docket Nos'.. 50-327, 50-328-
Resident Inspectors in the areas of operational safety verification  !
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  [ License;Nos. OPR-77, DPR-79-
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including o  performance, system lineups, radiation  i protection, perations safeguards and housekeeping inspections; maintenance  i observations * surveillance testing observations; review of previous inspection Iindings; followup of events; review of licensee identified items; review of IENs; and review of IFI Results: Three potential violations were identifie Paragraph 7, 327,328/88-34-02 Paragraph 8, 327,328/88-34-03 Paragraph 9, 327,328/88-34-04 l
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H -Mrf Oliver D) Kingsley,fJh 1 Senior.,Vice President, Nuclear Power;
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  ? Tennessee. Valley Authority-6N 38A LookoutLPlace-1101 Market Street-
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  ;L  . Chattanooga, TN 37402-2801
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  *0ne unresolved item was identifie Paragraph 4,(327,328/88-34-01)
No deviations were identifie An Enforcement Conference sur. mary pertaining to Violation 327,328/
88-34-02 is contained in paragraph "Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve violations or deviation There were no Unit I startup items identified in this repor _ _ _ _ _ _ _ _
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REPORT DETAILS Persons Contacted Licensee Employees H. Abercrombie, Site Director J. Anthony, Operations Group Supervisor
*R. Beecken, Maintenance Superintendent J. Bynum, Vice President, Nuclear Power Production M. Cooper, Compliance Licensing Manager
  *0. Craven, Plant Support Superintendent H. Elkins, Instrument Maintenance Group Manager R. Fortenberry, Technical Support Supervisor J. Hamilton, Quality Engineering Manager J. La Point Deputy Site Director L. Martin,$iteQualityManager R. Olson Modifications Manager J. Patrick, Operations Group Manager R. Pierce Mechanical Maintenance Supervisor
* Ray,SIteLicensingStaffManager
* Rogers,ld, licensing EngineerPlant Reporting Section 8. 3chofie i
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  *S. Smith, Plant Manager
*S. Spencer, Licensing Engineer C. W11ttemore, Licensing Engineer NRC Employees M. Branch l A. Long
* Attended exit interview NOTE: Acronyms and initialisms used in this report are listed in the last paragrap . Operational Safety Verification (71707) Plant Tours The inspectors observed control room operations; reviewed applicable logs including the shif t logs, night order book, clearance hold order book, configuration log and TACF log; conducted discussions with control room operators; verified that proper control room staffing was maintained; observed shift turnovers and confirmed operability of instrumentation. The inspectors verlfied the operab'lity of selected emergency systems, and verified compliance with TS LCO The inspectors verified that maintenance work orders had been


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==Dear Mr. Kingsley:==
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submitted as required and that followup activit es 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 including potential fire hazards, fluid leaks    and conditions,ibrationsandplanthousekeeping/cleanlinesscondItion excessive v The inspectors walked down accessible portions of the following safety-related systems on Unit 1 and Unit 2 to verify operability and proper valve alignment:
SYSTEMS Auxiliary Feedwater System Containment Spray System Residual Heat Removal System SafetyInjectionSystem UpperHeadInjectionSystem No violations or deviations were identified b. Safeguards Inspection In the course of the monthly activities, the inspectors included a review of the licensee's physical security program. The performance of various shifts of the security force was observed in the conduct l    protected and vital area access l of daily activities controls; including:l searching of personne and packages; escorting of visitors; badge issuance and retrieval; patrols and compensatory post In addition, the inspectors observed protected and vital area barrier integr' protectedty. The inspectors  area lighting, verified interfaces between the security organization and operations or maintenance. Specifically, the Resident Inspectors:
interviewed individuals with security concerns reviewed licensee security event report visited central or secondary alarm station observed power supply test verified protection of Safeguards Information verified onsite/offsite communication capabilities No violations or deviations were identified, c. Radiation Protection The inspectors observed HP practices and verified the implementation of radiation protection control On a regular basis, RWPs were reviewed and specific work activities were monitored to ensure the activities were being conducted in accordance with the applicable
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SUBJECT: ' REPORT.NOS.-50-327/88-34 AND 50-328/88-34''
 
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RWP Selected radiation protection instruments were verified operable and calibration frequencies were reviewe The following RWPs were reviewed:
  . In-. regard to - our letter of January 12, 1989 concerning our. Notice of Violation,
88-01-12: Unit 1 Containment, All Area : All RWP Areas (chemistry personnel only).
  . issued ~ on September'15, 1988,' for ' activities conducted 1 at your Sequoyah facility, we have. noted an: error. in the statement of the Noticiof Violation. >
 
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No violations or deviations were identified 3. Sustained Control Room Observation (71715)
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The inspectors observed control room activities and those plant activities directed from the control room for approximately 6 hours in each 12 hour shift for this rnort perio The observation consisted of one shift inspector per shif; supported by one shift manager per shift and other OSP management, on 06/28/88 at 1700, 24 hour on-site shif t coverage by the NRC was terminate Normal inspection coverage was resumed at this time, Control Room Activities Including Conduct of Operations The inspectors reviewed control room activities to determine that operators were attentive and responsive to plant parameters and conditions; operators remained in their designated areas and were attsntive to plant operations, alarms and status; operators employed cm.nunication, terminology and nomenclature that was clear and formal; and operators performed a proper relief prior to being discharged from their watch standing duties, Control Reom Activities Including Response to Transient and Emergency Conditions The inspector witnessed the Unit 2 operations emergency aersonnel respond to adverse plant conditions created by a severe t1under and electrical storm that occurred on June 25, at 4:50 p.m. The storm caused a switchyard breaker to trip and resulted in an initiation of the "carrier received indicator " alarms and various other control alarms. At essentially the same time, it was reported that damage had occurred that had disabled the Safety and Security tower and winds had resulted in a parked semi-trailer overturning at the plant site In addition, a fire alarm indicated that a fire had occurred in the turbine building. The responding emergency team determined the cause of the alarm to be a result of smoke entering the building from the auxiliary boiler exhaust via the roof ventilatio The responses and evaluations of these situations by the operators were well managed by the shift personne :
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i Control Room Hanning The inspectors reviewed control room manning and determined that TS requirements were met and a professional atmosphere was maintained in ,
the control room. The inspectors found the noise level and working conditions to be acceptable. The inspectors observed no horse play l and no radios or other non-job related material in the control roo ,
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Operator compliance with regulatory and TVA administrative guidelines l were reviewed. No deficiencies were identified, i
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. In addition, the control room appeared to be clean, uncluttered, and ;
well organized. Special controls were established to limit personnel '
in the control room inner are Routine Plant Activities Conducted In or Near the Control Room !
The inspectors observed activities which require the attention and [
;  direction of control room personnel. The inspectors observed that t necessary plant administrative and technical activities conducted in t or near the control room were conducted in a manner that did not ,
compromise the attentiveness of the operators at the controls. The !
licensee has established a 505 office in the control room area in i which the bulk of the administrative activities, including the '
i  authorized issuance of keys, takes place. In addition the licensee .
has established H0, WR, SI, and modification matrix functions to t i  release the licensed operators from the bulk of the technical i i  activities that could impact the performance of their duties. These ;
j  matrixed activities were transferred into the WC '
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j e. Control Room Alarms and Operator Response to Alarms i
i  The inspectors observed that control room avaluations were performed
 
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utilizing approved plant procedures and that control room alarms were responded to promptly with adequate attention by the operator to the alarm indications. Control room operators appeared to believe the
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alarm indications. None were identified by the inspectors that were
 
either ignored by the operators or timed-out.
 
! Fire Brigade i
j  The inspectors reviewed fire brigade manning and qualifichtions on a j  routine basis. Both manning and qualifications were found to meet TS
 
requirement ,
,  The inspector reviewed the training received by the new fire brigade
:  crew to ascertain whether an appropriate amount of operations knowledge is imparted to the crews. The fire brigade is broken into j  a "composite crew" format which naturally lends itself to providing l  plant knowledge. The crew is composed of personnel with the following experience:
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1 Steamfitter 1 Electrician 2 Firefighters This crew then receives 12 weeks of intensive trainin Two weeks of this training includes familiarization with all safe shut 0wn (Appendix R) systems. The training includes comaonents, f h pat i s, and safety significance. Additionally, the training includos cwo weeks of intensive training on fire protection systems in the plan Following the classroom training the crew completes system qualification cards for in plant knowledge of the systems. Typical qualification card items are listed below:
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LocatetheUpperHeadInjectionaccumulatorandsurgetank
        :j Find enclosed accorrected- copy; of the Notice of Violationi .Your October'13,.
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1988 : response to this violation .was . adequate and no'' further response is required.
State the cooling medium for the Spent Fuel Pit Cooling System
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State whether there is any radiation associated with the EGTS and describe how it is contained
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i.ist the emergency supply for the 6900 V Shutdown Boards The training received by the crews appears adequate and appropriat the affected unit A505 will res)ond with the crew and Additionally,"incident function as command". This indivicual will control all non-fire protection plant equipment and make reccommendations concerning priority of plant equipment to be protected. Operation of plant equipment other than the fire protection systems by the compoCte crew is prohibited. This arrangement is consistent with estaolished plant procedures and policies and appears appropriate to the fire brigade functions, Shift Briefing / Shift Turnover and Relief The inspectors observed that U0s completed turnover checklists, conducted control panel and significant alarm walkuown reviews and significant maintenance and surveillance reviews prior to telle The inspectors observed that sufficient information was transferred on plant status, operating status and/or events and abnormal system alignments to ensure the safe operation of the Unit. ASOS relief was conducted and sufficient information appeared to be transferred on plant status, operating status and/or events, and abnormal system alignments to ensure the safe operation of the Uni ASOS were observed reviewing shif t logbooks prior to relie Shift briefings were conducted by the offgoing 50 Personnel assignments were made clear to oncoming o:)erations personne Significant time and effort were expended d scussing plant events, plant status, expected shift activities, shift training, significant
 
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surveillance testing or maintenance activities, and unusual plant conditions, Shift Logs, Records, and Turnover Status Lists The inspectors reviewed 505, 00, A505 and STA logs and determined that the logs were completed in accordance with administrative requirements. The inspectors ensured that entries were legible; errors were corrected initialed and dated; logbook entries adequately reflected plant status; significant operational events and/or unusual parameters were recorded; and entry into or exit from TS LCOs were recorded promptly. Turnover status checklists for R0s contained sufficient required information and indicated plant status parameters, system alignments and abnormalities. The following additional logs were also revie,wed:
Night Order Log System Status Log Configuration Control Log Key Log Temporary Alteration Log No discrepancies or deficiericies were identified, Control Room Recorder / Strip Charts and Log Sheets The inspector observed operators check, install, mark, file, and route for review, recorder and strip charts in accordance with the established plant processes. Control room and plant equipment logsheets were found to be complete and legible; parameter limits were specified; and out-of-specification parameters were marked and reviewed during the approval proces . Management Activities TVA management activities were reviewed on a daily basis by the NRC shif t inspectors, shift managers, and Startup Manager, Daily Control of Plant Activities (War Room Activities)
The licensee conducted a series of plant activities throughout each day to control plant routines. These activities were referred to by the licensee as War Room activities. War Room activities were observed by the shift manager on a daily basis and were found to be an adequate method to involve upper level management in the day-to-day activities affecting the operation of the units, Management Response To Plant Activities and Events Review of the licensee's corrective actions associated with restart following the June 8, 1988, reactor trip:
 
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l The reactor trip of June 8,1988, was the fif th in a series of  !
reactor trips that occurred subsequent to the first Sequoyah Unit 2 restart on Ma 13, 1988. Following this trip the NRC requested that i  the licensee'ys post-trip review assess the four previous trips and  .
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determine if there were any common factors associated with the trip !
 
Additionally, on June 13, 1988, the licensee met with the NRC in  i Rockville, MD, at a public meeting for the purpose of presenting  t i  their assessment and any corrective action planned. During the  -
j  meeting, the licensee indicated that a major contributor to several  t of the trips was the material condition of the secondary plant as  :
;  well as a lack of detailed procedures for steam generator (SG) level  ;
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contro t 1988, the Assistant Of rector for Inspection Programs, j
j On June 16)NRC,li TVAPD OSP detailsofthe met with the Sequoyah management and discussed the censee's immediate and long term corrective actions.
 
3  The licensee committed to the following corrective actions and  i
 
evaluations prior to plant restart:   ,
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!  Review and reduce the backlog of outstanding work requests (WRs)
on secondary plant equipment aild evaluate their possible  ;
contribution to reducing the risk of balance of plant (80P)
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Revise operating instructions to enhance plant start-up activities to control feedwater flow and SG 1evels during low  !
level power ascension.
 
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I  * Require the Plant Operations Review Committee (PORC) to evaluate l future plant trips and recommend procedural changes, where  !
applicable, to reduce the probability of future plant trip i
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]  Shif t operating crews will be trained on the Sequoyah simulator l 1  in using the revised operating instructions for startup of the  i l  feedwater control system.
 
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)  The inspectors reviewed the procedural changes and training  >
i  incorporated as a result of the licensee's commitments. Each was  I l  reviewed as to whether the commitment was implemented and that the  [
plant would be in compliance with the safety analysi The following !
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sumarizes this review and inspector coments:  [
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l  Training for the operating crews was observed and det. ermined to (
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be acceptabl }
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General Operating Instructions, G01 1, rev. 77, Plant Startup  I i
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from Cold Shutdown to Hot Standby - Units 1 and 2, and G01-2,  i rev. 56, Plant Startup from Hot Standby to Minimum Load - Units  l l  1 and 2, incorporated the requirement for the shif t operating  l 1  supervisor (505) to make a systematic review of all open work i  activities relative to the respective units for the purpose of  j
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identifying maintenance activities that could affect system operability prior to mode change. NRC observation of this process indicated acceptable condition for Unit 2 operatio Observation of this review will be conducted by the inspectors during Unit I startup. Further changes were made to Admin-istrative Instruction, AI-5, rev 43, Shift Relief and Turnover, requiring that prior to assuming the watch, the oncoming shift personnel (505, A505,STA, and representatives from the radio-logical chemical laboratory radiological control group, and the waste processing group) ass,emble in the work control center for a briefing on all work activities in progress and scheduled work activities to be performed during the upcoming shif t for both units. The work activities must be approved by the SOS prior to implementatio The inspectors reviewed the changes pertaining to the above areas and found them acceptable. The inspector observed several shift turnovers conducted in the work control center to verify that proper briefings on work activities were presente GOI-2, rev. 56, incorporated changes for maintaining feedwater control and SG 1evels during plant startup activities that were developed through simulator validation. The changes provided instruction for switching from manual to automatic operation of the feedwater system. Additionally, the new method changed the SG 1evels that the operator must try to maintain at low power levels from the 33% programmed level to 48% in each S The inspectors reviewed these changes and could not determine that the plant had been analyzed for a condition of a SG water mass increase of the magnitude required in the G01-2 revisio The licensee was asked to provide the safety evaluation of this change. The licensee had only performed a USQD screening and determined that the FSAR supported the increase in SG 1evel from 33% to 48% level at less than or equal to 3% reactor power. The inspectors requested that the ifcensee provide a more detailed analysis to support the level increas The licensee I
corresponded with the nuclear steam system supplier Westing-l house, who indicated that they did not have sufficient site
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specific information to support a SG 1evel increase from 33% to 48% at 0% reactor power. Rather, Westinghouse indicated that the precautions, I'mitations, and sotpoints docutuent indicated that the control band for SG program level was plus or minus 5%.
G01-2 was again revised (rev. 57) to require the SGs to be operated at programed level, plus or minus 5%, during startup and plant operations. The fact that Westinghouse could not support the licensee position that the plant accident analysis for a main steamline break was still bounded was of concern to the NR This item is identified as URI 327, 328/88-34-0 This issue will be reviewed further to determine whether a i        i
 
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violation of NRC regulations occurred when the initial change was evaluated for compliance with 10 CFR 50.59 requirement The inspector discussed this concern with ifcensee management prior to the actual implementation of GOI-2. The licensee
sWe appreciate'your' cooperation in this matter.
;  agreed that further review was necessary and revised GOI-2 to delete the change to the programmed level, i  A!-30, rev. 19, Nuclear Plant Conduct of Operation, incorporated the requirement that experienced dedicated coaching be provided
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by TVA for inexperienced operators during startup and transfer from manual to automatic operation of the feedwater control I  system. Although this dedicated coaching later appeared to not I  be fully necessary, actions taken by the licensee to allow the l  A505 to directly supervise significant operations by unit l  operators were considered to be appropriate, effective, and acceptabl AI-18, rev. 51, Plant Reporting Requirements, incorporated the
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requirement for the PORC to review and approve each plant trip l  report prior to restart of the plant. The inspector considered l
this practice to be a noteworthy improvemen . Engineered Safety Features Walkdown (71710)
l The inspector verified operability of the containment spray system on Unit 1 by completing a walkdown of the system. This inspection was documented in the SSQE Inspection Report 327,328/88-2 . Shift Surveillance Observations and Review (61726)
Lices.see activities were directly observed to ascertain that surveillance of safety-related systems and components was being conducted in accordance with TS requirement The inspectors verified that; testing was performed in accordance with adequate procedures; test instrumentation was calibrated; LCOs were met; test results met accestance criteria reoutrements and were reviewed by personnel other than "he individual directing the test; deficiencies were identified, as appropriate, and any deficiencies identified during the testing were properly reviewed and resolved by management personne :; and system restoration was adequate. For completed tests, the inspector verified that testing frequencies were met and tests were performed by qualified individual The following activities were observed / reviewed:
SI-2: Shift Log - Units 1 and SI-3: Daily, Weekly, and Monthly Logs - Units 1 and 2.


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SI-79: Power Range Neutron Flux Channel Calibration By Incore-Excore Axial Imbalance Comparison. This SI is
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required at least once per month when above 15% reactor l  powe The incore axial imbalance is obtained from a moveable detector flux map which is analyzed by the incore computer progra SI-129.1: SafetyInjectionPumpCasingandDischargeVenting.


l  5!-137.1: Reactor Coolant System Unidentified Leakage Measuremen .2: Reactor Coolant System Water Inventory.
Sincerely, O
Y /34f%b hiuk ld85g, Frank R. McCoy,' Assistant Director for Inspection Programs TVA Projects Division
    . 0ffice'of Nuclear Reactor Regulation Enclosure:
Revised' Notice of Violation
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No violations or deviations were identified.
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1 7. Shift Maintenance Observations and Review (62703) Station maintenance activities of safety-related systems and components were observed / reviewed to ascertain that they were i
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l conducted industry codesin accordance with and standards, andapproved procedures,ith in conformance w TS. regulatory guides
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The following items were considered during this review: LCOs were met while components or systems were removed from service; redundant i
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components were operable; approvals were obtained prior to initiating l the work; activities were accomplished using approved procedures and I  inspected as appifcable; procedures used were adequate to control the l  activity; troubleshooting activities were controlled and the repair record accurately reflected what actually took place; functional testing and/or calibrations were components or systems to service; performed QC records prior were to returning 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; / ire prevention controls were implemented; outside contractor activities were controlled in accordance with the approved QA program; and housekeeping was actively pursued, Temporary Alterations The following TACFs were reviewed:
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0-88-08-02: Condensate Storage Tank Temporary connections to drain valves to allow makeup water feed from a mobile vendor demineralize No violations or deviations were identified.
 
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11 Work Requests The inspectors observed work in progress and reviewed work packages for the following work requests / work plans:
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WR 8245103: Repair of the "A" train main feedwater pump turbine speed control system to correct pump t oscillations and provide a more controlled feed -
flow to the SG l WP E437A-01: Testing and repair of all safety-related room coolers due to the discovery of broken shafts on certain room cooler motors caused by impro)er fan belt tensioning. The inspector observed tie work on the "A" and "B" trains of the Boric Acid ,
Transfer & AFW Pump Cooler No violations or deviations were identifie Subsequent to the management meeting held with TVA on June 13, the inspectors reviewed the scope of the maintenance work requests for Unit 2 that were pending when the reactor trips occurred on June 6 :
j    and June 8. The purpose of this review was to establish:
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    * Whether the approximately 128 WR's listed as "Startup Priority"
;    was complete and conservative in bounding all necessary work to be performed prior to Unit 2 startu *
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Whether the screening criteria used in the "Startup Priority" .
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determination was adequate and conservativ l
 
    * Selection of a representative sample of those WR's not deter- i
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mined to be "Startup Priority" and apply the screening criteria I as an independent audit on the process.
 
I    The screening criteria ised was a check list, which was applied to l
>    the total outstanding work list of 1308 items listed for Lnit 2 and l
]    Comon. Answering "Yes" to any one of the j    sheet placed the WR in the "Startup Priority"questions category: on the check !
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    * Is the WR a Main Control Room generated WR?
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    * If the WR is not completed, will the operators be required to I
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use remote indications, manual controls or other compensatory i measures?
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If the WR is not completed, could false indications cause the
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in plant operators (AUO's) to notify the control room? (An l example is a plugged / dirty sight glass on a drain tank). l
    * If the WR is not completed, could controller problems develop i
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1    that could cause instability in the secondary plant (BOP)? [
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  * If the WR is not completed, could an identified prob 1cm worsen later and not be isolable / workable at power? (e.g. a minor 1 steam leak that could develop into a serious leak that is not '
isolable with 2 valve protection). i
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Is the WR one of those identified by the Operations staff as one they consider necessary for restart?
The screeninc criteria was considered adequate by the inspector, and I was then applied to 38 selected WR's that were not on the startup !
lis Each of the 38 were discussed with TVA staff familiar with the ,
screening proces The inspector agrees with TVA staff's determination of non-startup category for each of the selected sample ;
item TVA completed all Startup Priority WR's prior to Unit 2 '
startup on June 2 '
No violations or deviations were identified d. Hold Orders The inspectors reviewed various H0s to verify compliance with AI-3, revision 38, Clearance Procedure, and that the H0s contained adequate ;
information to pro)erly isolate the affected portions of the system being tagge Adcitionally the inspectors inspected the affected i equipment to verify that the recuired tags were installed on the ;
equipment as stated on the H0 The following H0s were reviewed: ;
Hold Order  Equipment 2-88-516: "A" Train Main Feedwater Pump for work on I the governor valve positione : 28 Annulus Vacuum Fa I
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2-88-487: 28 690 Elevation Penetration Room Cooler to repair a broken shaf : Positive Displacement Charging Pump to I'
replace a plext glass cover gaske No violations or deviations were identifie I
      ,
 
      ,
e. Maintenance Activities Affecting Plant Operations On 07/05/88, at 2:30 p.m., Unit 2 operators received indication that !
the pressure indicator (2-PIS-87-21) for UHI isolation valve 2-87-21 ;
was erratic and indicating high (4000 psig) when all previous '
readings were steady at approximately 3000 psig. The pressure !
indicator is the sole method on-line to monitor the condition of the i isolation valve's actuator. The actuator is a hydraulic actuator pre-charged with nitrogen to 1400 psig, then hydraulically charged to I
 
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3000 psig. A bladder separates the nitrogen from the hydraulic sid A pre-charge of 1400 asig provides sufficient stored energy to stroke the UHI isolation va:ve silut when the UHI water accumulator reaches its low level setpoint during a LOCA event. This action assures delivery of sufficient water inventory to the core and prevents injectionofUHIsystemnitrogenintothecor The pressure indicator was removed from service and re-calibrate /08/88 at 2:30 p.m.,
After reinstalling )the pressure indicator on(a delay of 3 days , the actuato be reading below the alarm setpoint of 2970 psig. A Westinghouse analysis had previously been provided to allow a limited number of rechargings of the hydraulic side of this accumulator. Assuming that the pressure decrease was due to nitrogen leaks, a maximum of 4 rechargings was allowed before the nitrogen preload was considered less t,1an that required to properly stroke the isolation valve. This is based in part on the volume and pressure of the compressed nitrogen and the assumed nitrogen loss to decrease pressure to the alarm point. Af ter 4 such recharges, the licensee's procedure (SI 744) requires a stroke test of the isolation valve to verify operabil lty. An originally installed weight indication method of determining the volume of nitrogen in the accumulator was unreif able and ineffective. Since only pressure could be read on-line, the alternate method of allowing 4 recharges and then providing positive assurance of operability by a stroke test was developed by the licensee and Westinghouse. This is considered a compensatory measur Licensee management (plant manager, maintenance manager, operations among others) met at 4:30 p.m. on 07/08/88 and manager decided toand P0RS,ine valve operability by another metho determ      The decision was to perform a pre-charqe test instead, which was considered a more reliable method of determining that sufficient nitrogen was availabl The pre-charge test requires declaring the isolation valve inoperable, draining the actuator's hydraulic side, and then measuring the nitrogen side pressur A plan of action was drawn up which included gathering any spares or replacement parts, a procedural change to SI 744 to allow the pre-charge test in lieu of the stroke test, and several contingency action The spares were not found and made available untti 07/09/88, and the procedure was not changed until 07/10/88. By the time the licensee was ready to implement the test, the accumulator pressure alarm had been received and recharging accomplished a total of 7 more times. After the fourth recharge, at 1:30 p.m. on 07/09/88, the still-in-effect requirements of SI 744 required an immediate stroke test of the isolation valve. This was not done. By the time the licensee had finally performed an operability test by checking the pre-charge at 1:55 p.m. on 07/10/88, over 24 hours had elapsed since an operability determination had been required by SI 744. When the pre-charge test was finally performed, the nitrogen
 
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which is less than the minimum of pressurewasfoundtobe1165psig}mittoensureoperabilit psig specified as the lower 1 The loss of nitrogen was determined to be due to a leaking nitrogen charging valve (Schrader valve). This valve was replaced, the nitrogen side recharged to 1400 psig, and the valve returned to service at 3:55 p.m. on 07/10/8 While the management decision to perform a pre-charge test rather than the required stroke test was probably acceptable and would have adequately demonstrated operability, the execution of the plan was not well coordinated. Several dela parts and changing the procedure. ys were encountered Althou  in locating several levels of management were involved in this evolution,ghtbeworkwasdelayedfor over 24 hours past the point when the valves should have been repaired or declared inoperable. In conjunction with these delays, it is considered that the licensee did not take appropriate actions when conditions (the 4th thru 7th low pressure alarm and recharging evolutions) indicated potential valve inoperabilit Subsequent to this event, TVA asked Westinghouse to provide an analysis to determine whether the valve would have performed its intended function with the as-found pressure of 1165. A Westinghouse analysis dated 7/12/88, asserted that the valve would have stroked closed in approximately 8 seconds, as opposed to 4 seconds with a fully charged accumulator. This asserted condition is stated to result in an additional injection of 120 cubic feet of t;HI water to
,
the core bringing the total injected volume to 1170 cubic feet.
 
I This additional volume is within the accident analysis assumption of I
'
a maximum 1180.5 cubic fee This sug ests the valve may have been post facto operable, but does not relieve the licensee of their commitment to demonstrate operability by compliance with T.S. and their own procedure While the system arrangement provides a second, series valve operated by the opposite ESF train, which probably would have actuated properly, single failure criteria require redundant equipment to be operabl T.S. 3.5.1.2 requires the UHI system to be OPERABLE (including the isolation valves) or, to restore the system to OPERABLE in 1 hour or be in HOT STANDBY within the next 6 hours. This action statement was not entered until 12:31 p.m. , on 07/10/88, when work on the valve bega Since the valve is determined to be operable by performance of a verification test whenever 4 recharges have occurred, the valve should have been declared inoperable after the recharge performed at 1:30 p.m. , on 07/09/88, when procedural actions to stroke time test the valve were not taken. The appropriate action statement was not entered on a system required for safe shutdown. This is considered a violation of T.S. 3.5.1.2, for failure to comply with a TS action statemen This item is identified as Violation 327,328/88-34-0 . ': e -l      i
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l    15
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On July 28,1988, the NRC held an enforcement conference with TVA at i the Sequoyah Nuclear Plant to discuss concerns related to the t l
apparent noncompliance with T.S. 3.5.1.2 described abov Attendees '
at the conference are delineated in the attachment to this repor '
;
The meeting was opened by J. Partlow, Director, Office of Special Projects, who along with F. McCoy, Assistant Director for TVA Inspection Programs, discussed the NRC concerns with this specific ,
even NRC management stated their concern that the licensee had
:  failed to comply with procedures established to confirm UHI valve
 
operability when cond'tions indicated a potential for valve >
inoperability. Additionally, given this set of circumstances, the !
licensee failed to enter the action statement of T.S. 3.5.1.2 until '
operability could be confirmed. NRC management questioned the l conservatism and safety consciousness of TVA's actions with respect .
j  to this even !
l l  TVA was asked to address their own investigation into the event and I
]  the specific concerns of the NRC. TVA presented their evaluation of (
,  the event and their conclusions as to how the the noncompliance with !
      '
!  T.S. was allowed to occu l TVA presented background information and details of the event which !
agreed with the NRC's evaluation in most instances. A copy of the !
material presented by TVA at this conference has also been included l in the attachment to this inspection repor The Sequoyah plant -
manager acknowledged at the enforcement conference that the plant had ;
been in violation of T.S. 3.5.1.2 for a period of approximately 23 i hours, from 1:30 p.m. on 07/09/88 until 12:31 p.m., on 07/10/88. TVA ;
presented an analysis performed by Westinghouse that supports their '
      .
determination that the safety significance associated wit 1 this event was minimal and that the valve in question would have functioned if called upon during the time frame the plant was outside the T.S. TVA demonstrated at the enforcement conference that the event was caused by a lack of coordination among various site groups and was not a result of nonconservative management actio . Event Followup (93702, 62703)
At 11:59 p.m., on 6/29, a blackout signal was initiated on Unit 16900 volt shutdown board 1-B-8. The initiating event was the tripsing of the feeder breaker to the shutdown board from the 6900 volt unit 30ard. The feeder breaker (#1722) tripped when maintenance workers were attempting to replace a fuse in the breaker's position indicating light circui The circuit was inadvertantly grounded when maintenance workers were replacing the blown fuse, causing the breaker trip circuit to actuat When the 1-8 8 shutdown board was deenergized, all 4 EDG units started. The 1 B-8 shutdown board was reenergized when the 1-B B EDG care up to speed and tied onto the bu The other EDG's did not tie on to their respective buses because those buses continued to be energized from the unit board Af ter resetting the breaker 1722 trip circuit, the unit boards were paralleled with the 1-B-B EDG, and the EDG's were stoppe All systems
 
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performed as designed, and an ENS notification made to NRC at 12:08 on 6/3 !
At 7:29 p.m., on June 3,1988, EDG 1A-A was made inoperable for the performance of SI-307.1, Degraded Voltage Relay Response Time Testing and *
Timer Verification. At that time the Unit 2 00 logged in the LCO log that '
LCO for TS 3.8.1.1 was entered. At 10:40 p.m. on June 3, 1988, SI 30 was completed and EDG 1A-A was returned to servic During the subsequent '
shif t turnover meeting at approximately 11:30 p.m. a discussion of the '
work performed for the previous shif t resulted in the 505 realizing that :
the requirements of TS 3.8.1.1 had not been met. TS 3.8.1.1 requires that with an EDG inoperable, the operability of the remaining AC sources must ,
be demonstrated by performance of SR 4.8.1.1.1.a and 4.8.1.2.a.4 within :
one hour and at least once per eight hours thereaf ter. Failure to meet l the requirements of TS 3. 8.1.1 is identified as Violation  :
327,328/88-34-03,    j s
9. Followup on Previous Inspection Findings (92702)  ;
  (Closed) URI 327,328/88-26-03, Resolution of RCS Leak Rate Determination !
Proces {
On April 6, at approximately 6:50 a.m., the licensee completed f Reactor Coolant System Water !
computations Inventory. The forresults Part 1indicated of SI-137.2, an initial unclassiffed RCS leak i rate of 1.09 _gpm which if considered unidentified, would have :
exceeded the T5 Ifmit of 1 gpm. As required by procedure the  i chemistry laboratory was notified to perform Part 2 of SI-13).2. At ;
the time, the 505 was at the shif t meeting preparing for turnover of i the watch to the oncoming shift crew. He informed the Assistant 505 !
by phone, not to enter the LCO for RCS leakage because procedural , i problems had caused them to enter the same LCO unnecessarily in the !
past. This decision was made even though the operators had noted abnormal increases in the reactor building auxiliary floor and !
equipment drain sump levels throughout the shif '
At 7:55 a.m., the licensee entered LCO 3.4.5.2 for RCS leakage when a i gasket on 2-PDT 62-47, the differential pressure transmitter on the r
  #4 reactor coolant pump seal return line, was found to be leaking. A [
Notification of Unusual Event was not made within 5 minutes per !
IP-1, RCS Leakage, which required entry into the Radiological (
Emergency Plan if leakage exceeds the TS limit. At 8:20 a.m. , !
licensee management personnel reviewed the decision and issued a [
NOV At 8: 42 a.m., the differential pressure transmitter was isolated utilizing the root valve At 9:11 a.m. , the licensee ,
notified NRC Headquarters in accordance with the one hour emergency reporting requirements. Although this notification was made within one hour of the management decision to enter the NOVE, the inspectors ,
noted that this was accomplished approxiestely 76 minutes af ter entry [
into LCO 3.4.5.2 (which, by the licensee's radiological emergency [
procedures, required a declaration of unusual event) and nearly i r
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t hours after the operators had verifiable indi:ation that leakage  l might be outside of TS limit l AOI-6, Small Reactor Coolant System Leak (Modes 1, 2, & 3), had not been entered. A01-6 states that one pose,ible symptom of a small reactor coolant leak is receiving the "Reactor Building Auxiliary Floor and Equipment Drain Sump High" alarm, window 19 of XA 55-5A on panel 1-M-5. This elarm was received twice during the shif t as  !
stated above. Additionally with the high leak rate as calculated in  !
SI-137.2 and the discovery, of 2-PDT-62 74 leaking the inspector cont,iders that it would have been prudent to perform the actions of AOI- Although non performance of the recommendations in A01-6 does  l not appear to violate any licensee or NRC requirements, the inspectors have concern that the licensee's annunciator response  t procedures do not provide an initiation path for the A01 procedures,  i l
        -
At 5:45 p.m.dicatedthe SI-13 in  an licensee acceptable exited the NOUE leakage when rate of 0.48a gp new performance of l
Subsequent performance of SI 137.5 Primary to Secondary Leakage via  '
Steam / Generators, reflected that 0.16 gpm of this leakage rate was attributable to the tube leak in steam generator 3 discussed in  '
Inspection Report 88-2 The licensee estimated that between 250-300
;
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gallons of inventory had leaked during the entire event by estimating the leakage rate from 2-PDT-62-47 to be 0.61 gpm and by confirmation i of the pocket sump levels. The licensee issued a statement to the  ;
l press on this occurrence at 11:00 a.m. on April i
! The delays in entering and reportint the NOUE and the LCO on RCS leak  !
j rate and the concerns involving in' tiation of A0! procedures were  f
, identified as Unresolved Item 88-26-0 ;
J l During this event TVA had used a cumbersome method to calculate  I i unidentified RCS leakage and to determine what part, if any, that a  j i
pricary to secondary leak p, layed in this unidentified leakage valu :
j  the licensee s RCS inventory measurement procedure  !
; Specificallyld SI-13 wou perform an inventory balance and if the unclassified
>
1eakage was ebove a specific value they would then recuest that a
, primary to secondary leakage measurement be performed 'n accordance  .
with SI-137.5. Performing a primary to secondary leakage calculation  ,
only to quantify unidentified leakage resulted in both a delay in  l completing the RCS unidentified 1(akage measurement and a lack of  l
:
'
consistent primary to secondary leakage trending data. The staff  ;
considers that this methodology was a maior contributor to the delays  t
, associated with entry into (and applicable reporting of) the NOUE and  i
: LCO, as identified in Unresolved Item 86-26 0 l I        !
! Revision 22 of $1-137.2 revised the method to require that primary to  l i secondary leakage measursent be performed every 72 hours and be a  ;
prerequisite to the inventory balance performed by SI-137.2. This  j
,
ne method should produce both consistent primary to secondary  '
1eakage trending data as well as expedite the determination of RCS l
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leakag This method also provides adequate corrective action to preclude raising questions such as those indicated under Unresolved Item 88-26-03 discussed abov The NRC staff reviewed the e/ent with respect to the utilization of SI-13 It was determined that the intent of LCO 3.4.5.2 was to
'
consider any known leakage to be unidentified until an identification of the source was made. Therefore, unclassified leakage is unidentified leakage and LC0 3.4.5.2 chould have been entered at 6:55 Although j the Lispector had earlier discussions with the licensed operaters, it was determined that not entering the action statement was identi, led and resolved independently by the licensee managemen At 7:55 a.m. , on April 6, the operators entered LCO 3.4.5.2 when the leak
      '
was actually observed. At this time the operations staff still did not l enter a NOUE as required by the REP because the 505 haf left instructions '
to the contrary. Tne inspector discussed this decision with the operators i at the tim The Sequoyah Radiological Emergency Plan IP-1 Emergency Plan  :
Classification Logic which implements these requi,ements, r requires that t the operators enter a NOUE if the primary system leak rate is greater than ;
that allowed in the TS. In addition, REP Implementing Procedure IPel, j also states, if there is any reason to doubt whether a given condition has '
actually occurred, the shift engineer or Site Emergency Director will proceed with the required notification without waiting for formal confirmatio In addition, REP Implementing Procedure IP-1, also states, if there is any :
reason to doubc whether a given condition has actually occurred, the shift engineer or Site Emergency Director will proceed with the required  ,
notification without waiting for formal confirmatio l
_
_
IP-2, Notification of Unusual Event, requires that the not'tication of the [
        ^
Operations Duty Specialist be made within 5 minutes af ter .he declaration r of the even on A)ril 6,1988 at 7:55 a.m. the licensee entered i Contrary LCO 3.4.5.2to the above,ing tlat the RCS leakrate was greater than the TS acknowledg allowable limits but did not enter a NOVE until 8:20 a.m. when licensee and NRC management reviewed the event. This is a violation of the above j requirements and will be considered Violation 327,328/88-34-04. This portion of URI 88-26-03 is close The inspector reviewed AI-4, Preparation, Review, Approval and Use of Site I Procedures / Instructions, for guidance on use of A0Is. Section 16.3 states !
L h ,
that:
  >
      '
    ,
A01s and Els are prepared to act as guides during potential emergencies. They are written so that a trained operator will know ,
E  l _, : MAR 0 9:190..
i k
ps '  ,[[0liverD.TKingsley,Jr. 21
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cc w/ enc 1: . . . . ,. ., .
 
F.'LF Moreadith; Vice' President,..
i in advance the expected course of events that will identify the situation and will provide the immediate action to be take It is the operator's res particular situation is.ponsibility to analyzethe Once identified andoperator determine what is to takethe prompt appropriate action to prevent or mitigate the consequences of a serious conditio The inspector reviewed the operator training lesson plans associated with A0I-6 for new license training and requalification training including both classroom and simulator portions. Also, a selected nurrber of additional AOI training lesson plans for licensed operators were reviewed. Training appeared to be adequate and appropriate for the procedure usage ,
L Nuclear Engine'ering 3.; ^L
      ,
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Initiating documents for A0Is are not provided at Segouyah. The many unique situations which could occur in the plant are too numerous to provide instruction for every scenario. Therefore, the A0Is are designed as symptom based instructions. The operators are trained on what parameters may indicate a need to enter the procedur The inspector reviewed the event in question and determined that the operators had handled it in an appropriate manner. There is no requirement for an entry into the A01. Furthermore, discussions with the '
   .J. L.'LaPoint,: Site' Director:
operators and training personnel have shown that a more significant leakage event would have prompted A0I entr This portion of URI 88-26-03 is close ,
  * iSequoyah Nuclear.' Plant
Additional review of this event and licensee corrective actions and responses will be reviewed under Violation 88-34-0 Therefore, URI 327,328/88-26-03 is close . ExitInterview(30703)
  % R. Lc Gridley, Director
The inspection scope and findings were summarized on July 18, 1988, with L those persons indicated in paragraph 1. The Senior Residents described ;
the areas inspected and discussed in detail the inspection findings listed belo The licensee acknowledged the ir,spection findings and did not ;
identify as proprietar    -
during the inspection.y any of the material reviewed by the inspectors Inspection Findings:    :
Three violations were identified in paragraphs 7, 8, an One URI was identified in paragraph :
No deviations or inspector follow-up items were identifie !
During the reporting period, frequent discussions were held with the Site Director, Plant Manager and other managers concerning inspection finding i
 
; .l l
 
No commitments were made by the plant manager or his designee during the exit meetin . List of Abbreviations ABGTS- Auxiliary Buf1 ding Gas Treatment System ABSCE- Auxiliary Building Secondary Containment Enclosure AFW -
Auxiliary Feedwater AI -
Administrative Instruction A0I -
Abnormal 0)erating Instruction AU0 -
Auxiliary Jnit Operator A505 - Assistant Shift Operating Supervisor BIT -
BoronInjectionTank C&A -
Control and Auxiliary Buildings CAQR- Conditions Adverse to Quality Report CCP -
Centrifugal Charging Pu.sp CCfS - Corporate Commitment Tracking System COPS - Cold Overpressure Protection System CSSC - Critical Structures, Systems and Components CVI - Containment Ventilation Isolation DC -
Direct Current DCN -
Design Change Notice DNE -
Division of Nuclear Engineering DTVAP - DivisionofTVAProjects ECCS - Emergency Core Cooling System EDG -
Emergency Diesel Generator EI -
Emergency Instructions ENS -
Emergency Notification System ESF -
Engineered Safety Feature FCV -
Flow Control Valve FSAR - Final Safety Analysis Report G0C -
General Design Criteria GL -
Generic Letter HIC -
Hand-operated Indicating Controller H0 -
Hold Order HP -
Health Physics IN -
NRC Information Notice IFI -
Inspector Followup Item IM -
Instrument Maintenance IMI -
Instrument Maintenance Instruction IR -
 
==Inspection Report==
KVA -
Kilovolt-Amp KW -
Kilowatt KV -
Kilovolt LER -
Licensee Event Report LCO -
Limiting Condition for Operation LOCA - Loss of Coolant Accident HI -
Maintenance Instruction NB -
NRC Bulletin NOV -
Notice of Violation
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  .
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NRC -
Nuclear Regulatory Commission OSLA - Operations Section Letter - Administrative OSLT - Operations Section Letter - Training OSP -
Office of Special Projects PMT -
Post Modification Test PORC - Plant Operations Review Committee P0RS - Plant Operation Review Staff PRO -
Potentially Reportable Occurrence i QA
  -
Quality Assurance  t QC
  -
Ouality Control  !
RCS -
Reactor Coolant System RG -
Regulatory Guide  .
RM -
Radiation Monitor RHR -
Residual Heat Removal RWP -
Radiation Work Permit  .
RWST - Refueling Water Storage Tank  '
SER -
Safety Evaluation Report SG -
Steam Generator SI -
Surveillance Instruction S0I -
System Operating Instructions SOS -
Shift Ooerating Supervisor SQM
  -
Sequoyah Standard Practice Maintenance ,
SR -
Surveillance Requirements
!  SR0 -
Senior Reactor Operator  l STI -
Special Test Instruction i
TACF - Teworary Alteration Control Room t TROI - Tr s king Open Items  i TS
  -
Technical Specifications  I TVA -
Tennessee Valley Authority UO -
Unit Operator URI -
Unresolved Item
.
USQD- Unreviewed Safety Question Determination
'
WCG -
Work Control Group
;  WP -
Work Plan WR -
Work Request  f
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i Attachment.
 
; Enforcement Conference Attendance  (;
: List and Licensee Slides i
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  *l U .*
,  ATTACHMENT
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. TENNESSEE VALLEY AUTHORITY
   .
SEQUOYAH NUCLEAR PLANT EVENTS SURROUNDING
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THE 2-FCV-87-21 UHI ISOLATION VALVE
!  ISSUE
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JULY 28,1988
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ATTENDANCE LIST Enforcement Conference July 28, 1988 Attendees TVA S. A. White R. L. Gridley J. R. Walker Ken Meade J. R. Bynum N. C. Kazanas M. A. Cooper Ed Vigluicci J. T. LaPoint M. J. Ray L. E. Martin J. B. Brady S. J. Smith H. R. Rogers B. Charleson NRC J. Partlow B. Pierson P. Harmon F. McCoy K. Jenison K. Poertner l
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SUMMARY OF EVENTS UHI ISOLATION VALVE
.
02/15/88 SI 744 WRITTEN TO PROVIDE METHOD OF MONITORING CHARGES TO ACCUMULATOR BASED ON WESTINGHOUSE ANALYSIS 03/88 PRE-CHARGED 2 FCV 87 21 N2 ACCUMULATOR TO 1382 psig PRIOR TO ENTRY TO MODE 3 AND VERIFIED VALVE OPERABILITY 07/05/88 OPERATIONS NOTED ERRATIC PERFORMANCE OF 2 PIS 87 21 (HYDRAULIC SYSTEM PRESSURE INDICATOR). WR B788800 WRITTEN TO REPAI /08/88 AT 1400, PORS HAD A DISCUSSION WITH NRC ON THE INOPERABLE PRESSURE INDICATOR (2 PIS 87-21)
07/08/88 AT 1430 EDT, PIS REPA! RED AND HYDRAUUC SYSTEM PRESSURE FOUND LOW (2647 psig). OPERATIONS RECHARGED TO 3034 psig. SYSTEM ENGINEER NOTIFIED AT 1530 ED /08/88 AT 1830 EDT, PLANT MANAGEMENT WAS INFORMED OF THE LOW HYDRAULIC SYSTEM PRESSURE AND DETERMINED A PRE CHARGE CHECK WAS THE APPROPRIATE ACTION TO TAKE. MANAGEMENT DIRECTED SYSTEM ENGINEERING / MAINTENANCE TO ESTABLISH A PLAN OF ACTION TO PERFORM PRE CHARGE l
l 07/08/88 AT 1930 EDT AND AT 0450 EDT ON 07/09/88, HYDRAULIC ACCUMULATOR PRESSURE REACHED LOW SETPOINT (2970 psig) AND WAS RECHARGED BY OPERATIONS j 07/09/88 AT 1100 EDT, SCHRADER VALVE N BLADDER WAS CHECKED FOR
 
l  LEAKS SMALL LEAKAGE NOTE /09/88 AT 1300 EDT, HYDRAUUC ACCUMULATOR PRESSURE REACHED THE LOW SETPOINT (2970 psig) AND WAS RECHARGED BY OPERATIONS. THIS WAS THE FOURTH PHYSICAL CHARGE AND IN HINDSIGHT SI 198 SHOULD HAVE BEEN PERFORMED AT THIS POIN ROCUS1. 35
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SUMMARY OF EVENTS UH1 ISOLATION VALVE (cont.)
 
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07/09/88 AT 1800 EDT, CALLED NRC RESIDENT AT HOME TO DISCUSS AND GIVE THE STATUS OF THE ACTION PLAN FOR REPAIR OF 2-FCV 87 2 /09/88 AT 1820 EDT, AT 2100 EDT, AND AT 0333 EDT ON 7/10/88, HYDRAULIC ACCUMULATOR PRESSURE REACHED LOW SETPOINT (2970 psig) AND WAS RECHARGED BY OPERATION /10/88 AT 0930 EDT, PORS TALKED Wi1H THE NRC TO INFORM THEM OF THE PROGRESS MADE AND THE ACTIONS REMAINING BEFORE VALVE REPAIR WAS COMPLETE /10/88 AT 1231 EDT, ENTERED LCO 3.5.1.2 TO PERFORM PRECHARGE ON 2 FCV 87-21 AND PERFORM MAINTENANCE ON SCHRADER VALV NITROGEN PRESSURE WAS FOUND TO BE 1164.5 psig. LEAKAGE FROM THE SCH1ADER VALVE WAS REPAIRE /10/88 AT 1555 EDT, LCO 3.5.1.2 WAS EXITED. THE NITROGEN PRESSURE WAS LEFT AT 1387 psig.
 
l 07/10/88 DNE WAS REQUESTED TO EVALUATE AS FOUND AFFECTS OF NITROGEN
;
PRESSURE ON RESPONSE TIME OF 2 FCV 87 21 AND ACCIDENT ANALYSI /11/88 WESTINGHOUSE EVALUATED THE CONDITION AND CONCLUDED THE LOW NITROGEN PRESSURE AND SUBSEQUENT VALVE RESPONSE TIME IS BOUNDED BY THE CURRENT UNIT 2 CYCLE 3 UHI ANALYSIS.
 
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ROGERS 7, 35
 
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CONCLUSIONS
* SI-196 ' PERIODIC CALIBRATION OF UPPER HEAD INJECTION SYSTEM INSTRUMENTATION" IS THE INSTRUCTION WHICH RESPONSE TIME HSTS THE SUBJECT VALVES TO PROVE OPERABILIT * SI-744, "MONITORING OF UHI ISOLATION VALVE ACCUMULATOH PRESSURE,"
DID NOT CONTAIN SUFFICIENT INFORMATION TO PERFORM AN ADEQUATE ASSESSMENT FOR VALVE OPERABILIT * THE LEAKING SCHRADER VALVE CAUSED THE LOW NITROGEN PRESSURE AND RESULTED IN GEVERAL RECHARGES PRIOR TO VERIFICATION OF PRECHARG * MANAGEMENT DETERMINED THAT A NITROGEN PRECHARGE WAS THE MOST ACCURATE AND 5:"alENT WAY TO DETERMINE SYSTEM STATUS WITH RCTCur TO ACCUMULATOR HYDRAULIC PRESSURE.-
* MANAGEMENT INTERPRETED SI-744 TO INDICATE THAT A NITROGEN PRECHARGE CHECK WAS AN ALTERNATIVE TO THE RESPONSE TIME TEST AFTER THE FOURTH CHARG * THE NITROGEN PRECHARGE CHECK WAS PLANNED BUT NOT EXPEDITIOUSLY PERFORMED.
 
l ( * OPERATIONS PERSONNEL RELY ON SYSTEMS ENGINEERING TO I  DETERMINE THE NUMBER OF CHARGES TO EACH UHI ISOLATION l  VALVE ACCUMULATOR AND WHEN ACTION IS REQUIRE * DASED ON AN EVALUATION FROM WESTINGHOUSE, THE "AS FOUND' CONDITION OF LOW NITROGEN PRESSURE DID NOT REPRESENT A SAFETY CONCER i l
P j      KONC.143 l
  --- -- . . ---- _ . _ ._ . . . _ - - - - _ . . . _ _ . -- _ _ _ _ _ _
 
  .
:.'.
.
ASSESSMENT OF SAFETY SIGNIFICANCE
* 2 FCV 87-21 WAS CAPABLE OF PERFORMING iTS INTENDED FUNCTIO * THERE WAS A MINIMAL EFFECT ON UHI ISOLATION VALVE STROKE TIME DUE TO THE LOW NITROGEN PRESSURE IN THE VALVE ACCUMULATOR. TESTING ON UNIT I INDICATED THE RESPONSE TIMES WERE APPROXIMATELY .2 SECONDS SLOWER DUE TO THE LOW PRESSUR * THE UNIT 2 CYCLE 3 ANALYSIS INDICATES THE "AS FOUND'
CONDITION OF LOW NITROGEN PRESSURE IS BOUNDED EVEN IF A SINGLE FAILURE OF THE REDUNDANT ISOLATION VALVE IS ASSUME * THE REDUNDANT UHI ISOLATION VALVE, 2 FCV 87 22 WAS OPERABLE DURING THIS EVEN * A SECOND UHI INJECTION PATH WAS OPERABLE DURING THIS EVENT
,
l EATETf.143
 
_
: '/. .'
.
.
ACTIONS IS BEING REVISED TO PROVIDE ACTI IN THE DETERMINATION OF.AUHI VALVE OPER NUMBER OF CHARGES, DEPENDENT U HITROGEN PRECHARG .
OPERATIONS INTERPRET THE ACTIONSPERSONNEL OF SI 744, WILL BE TRAINED AN EVALUATION WILL BE MADE CONCERNI E HITROGEN PRESSURE IN THE ACCUMULATO ADDITIONAL CHECK  CHARGES ARE ALLOWED BEFO TEST IS REQUIRE .
THE NON TS sis WILL BE REVIEWED AND REVIS
\
BE TAKEN IN THE EVENT THE A ARE NOT ME .
l THE UHI SYSTEM REMOVAL PLAN WILL BE PURSU .
WESTINGHOUSE HAS PERFORMED PRELIMINAR 1  WHICH INDICATES THE UHI SYSTEM CAN .
\
i
\
\
\
S744, 143
  -_- . --
 
'' *
.
; .. .
-
.
ACTIONS i
1. 81-744 IS BEING REVISED TO PROVIDE ACTIONS TO AID IN THE DETERMINATION OF UHI VALVE OPERABILITY. A RESPONSE TIME TEST WILL BE REOUIRED AFTER A CERTAIN NUMBER OF CHARGES, DEPENDENT UPON THE ORIGINAL NITROGEN PRECHARG . OPERATIONS PERSONNEL WILL BE TRAINED ON HOW TO  l lNTERPRET THE ACTIONS OF SI 74 . AN EVALUATION WILL BE MADE CONCERNING INCREASING THE NITROGEN PRESSURE IN THE ACCUMULATORS SUCH THAT ADDITIONAL CHARGES ARE ALLOWED BEFORE A PRECHARGE CHECK TEST IS REQUIRE . THE NON TS sis WILL BE REVIEWED AND REVISED AS APPROPRIATE TO CLARIFY THE ACTIONS WHICH SHOULD BE TAKEN IN THE EVENT THE ACCEPTANCE CRITERIA ARE NOT ME . THE UHI SYSTEM REMOVAL PLAN WILL BE PURSUE WESTINGHOUSE HAS PERFORMED PRELIMINARY ANALYSIS WHICH INDICATES THE UHI SYSTEM CAN BE REMOVED AT SO !
l 51744. 143
    - _ - - _ - _ _ .
 
- _ _ _ _ _ _ _ _ _ _ ___ _ _
        '
        ' ' *
. : '; ;
          -
  .
  .
IISIDE gCUTSIDE C0elTAlle(HT CONTAINNENT 12"
      ~
    !
1 MEH8RANE l
I n  (Y 1800 FT3
    : 2-FCV-87-22 ugui0  QAs
 
I
    ' 2-FCV-8 7-2l
    \ l 7  V
    .f" a
T  M FOR UMl1800ACCUMULATO PS-87.-24 8800 FTjG
    * DeoA-u 12*  130LAfl0N VALVES 8*    VALVES CLOSE OM 8  LOW LEVEL I N CHECK YALVES f  ACCUHULA TO R
 
  / h  8'
FOUR INJECTION 5*  PORTS (5* 00)
   .
   .
REACTOR VESSEL MEAD Upper Head injection System Schematic
' -T -  Nuclear: Safety and Licensing.'
          *
  >
        .
  . M. Burzynski,., Acting Site Licensing Manager-TVA Representative, Rockville H- -
 
  . Office-JGeneral.; Counsel, TVA-
  '* *
  ; State lof Tennessee
* ,. e >r ,.
  ,
  ,
        . ,
bec'w/ encl:
.
0; M. Crutchfield, NRR-B.iD. Liaw, NRRl SE C. Black,:NRR-R. C. Pierson, NRRc nl. J. Watson, NRR/RII:
SCHRADER
J. '.B. Bra'dy, ' NRR/RII.
'.     .
      '
VALVE FOR NITROGEN FILL BLADDER !  *
S UNI YALyg    HYORAULIC ' '
N ACCUMULATOR-G40 .


,
J. Rutberg, OGC NRC Resident-Inspector
H    1__  .
  ,NRC' Document Control Desk 4.%L<'
j      ,
NRR/ II   NRR/RII Mad,    <&en 2/6 /89   2/F89
NYDRAULIC  Dlk i
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}}
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Latest revision as of 05:11, 16 December 2021

Forwards Corrected Notice of Violation from Insp Repts 50-327/88-34 & 50-328/88-34
ML20247C149
Person / Time
Site: Sequoyah  Tennessee Valley Authority icon.png
Issue date: 03/09/1989
From: Mccoy F
Office of Nuclear Reactor Regulation
To: Kingsley O
TENNESSEE VALLEY AUTHORITY
Shared Package
ML20247C153 List:
References
NUDOCS 8903300133
Download: ML20247C149 (2)
v • d • e


Text

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 : Docket Nos'.. 50-327, 50-328-
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H -Mrf Oliver D) Kingsley,fJh 1 Senior.,Vice President, Nuclear Power; 

 ? Tennessee. Valley Authority-6N 38A LookoutLPlace-1101 Market Street-
;L  . Chattanooga, TN 37402-2801
 '

Dear Mr. Kingsley:

~ 

,

SUBJECT: ' REPORT.NOS.-50-327/88-34 AND 50-328/88-34 

   -
 . In-. regard to - our letter of January 12, 1989 concerning our. Notice of Violation,
 . issued ~ on September'15, 1988,' for ' activities conducted 1 at your Sequoyah facility, we have. noted an: error. in the statement of the Noticiof Violation. >
  ~'
  '
    -
        :j Find enclosed accorrected- copy; of the Notice of Violationi .Your October'13,.

1988 : response to this violation .was . adequate and no further response is required.

sWe appreciate'your' cooperation in this matter.

.

Sincerely, O Y /34f%b hiuk ld85g, Frank R. McCoy,' Assistant Director for Inspection Programs TVA Projects Division 

    . 0ffice'of Nuclear Reactor Regulation Enclosure:

Revised' Notice of Violation 

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cc w/ enc 1: . . . . ,. ., . F.'LF Moreadith; Vice' President,.. L Nuclear Engine'ering 3.; ^L 

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 .J. L.'LaPoint,: Site' Director:
 * iSequoyah Nuclear.' Plant
%  R. Lc Gridley, Director
  .
' -T -  Nuclear: Safety and Licensing.'
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 . M. Burzynski,., Acting Site Licensing Manager-TVA Representative, Rockville H- -
  . Office-JGeneral.; Counsel, TVA-
 ; State lof Tennessee
,

bec'w/ encl: 0; M. Crutchfield, NRR-B.iD. Liaw, NRRl SE C. Black,:NRR-R. C. Pierson, NRRc nl. J. Watson, NRR/RII: J. '.B. Bra'dy, ' NRR/RII.

J. Rutberg, OGC NRC Resident-Inspector 

 ,NRC' Document Control Desk 4.%L<'

NRR/ II NRR/RII Mad, <&en 2/6 /89 2/F89 

 -

_ _ _ _ . . _ _ _ _ . _ _____s . _ _ . . _ _ _ . __ j }}

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