ML20134Q330

Insp Repts 50-327/96-11 & 50-328/96-11 on 960915-1026. Violations Noted.Major Areas Inspected:Licensee Operations, Maint,Engineering,Plant Support, & Effectiveness of Licensee Controls in Identifying,Resolving & Preventing Problems

ML20134Q330
Person / Time
Site:	Sequoyah
Issue date:	11/19/1996
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20134Q321	List: IR 05000327/1996011 ML20134Q317 ML20134Q327 ML20134Q330
References
50-327-96-11, 50-328-96-11, NUDOCS 9612020233
Download: ML20134Q330 (17)

See also: IR 05000327/1996011

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U.S. NUCLEAR REGULATORY COMISSION

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REGION II

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Docket Nos: 50 327, 50 328

License Nos: DPR 77, DPR 79

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Report Nos: 50-327/96-11, 50-328/96-11

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Licensee: Tennessee Valley Authority

l Facility: Sequoyah Nuclear Plant, Units 1 & 2 '

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Location: Sequoyah Access Road '

Hamilton County, TN 37379

l Dates: September 15 through October 26. 1996

Inspectors: M. Shannon, Senior Resident Inspector

l D. Starkey, Resident Inspector

l C. Rapp, Reactor Inspector (Sections E8.1 through

E8.7) 1

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W. Sartor, Reactor Inspector (Section Pl.2) l

l S. Sparks, Project Engineer-

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Approved by: M. Lesser, Chief

Reactor Projects Branch 6

Division of Reactor Projects

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Enclosure 2

9612O20233 961119

PDR ADOCK 05000327

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EXECUTIVE StM MRY

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Sequoyah Nuclear Plant. Units 1 & 2 i

NRC Inspection Report 50 327/ % 11, 50 328/96 11 l

This. integrated inspection included aspects of licensee operations, i

maintenance, engineering, plant support, and effectiveness of licensee I

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controls in identifying, resolving, and preventing problems. The report l

covers a six week period of' resident inspection. -In addition,'it includes the. '

[ -results of an announced inspection by.an engineering inspector.

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-Operations j

e Operations management initiated a positive program to discuss,

y during shift turnovers. recent configuration control issues in an

L effort to reduce the' number of configuration control problems i

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o. A non cited violation (!JCV) was identifed for failure to use a

i procedure when performing a main control room switch manipulation

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(Section 01.2).

, e Operators were not aware that a radiation monitor with " low

! counts" would not perform its-designed Auxiliary Building .;

[ - Isolation (ABI) function (Section 02.1). 1

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! Maintenance

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o - A weakness was identified in the licensee's corrective action ]

' program for closing.a problem report on previously identified AFW

bearing oil problems without substantial evaluation (Section

M2.1).

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e A positive observation was noted when Nuclear Assurance identified l

four previous Problem Evaluation Reports (PER) related to i

! Auxiliary Feedwater (AFW) bearing oil problems (Section M2.1).

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l e - A weakness was identified regarding the licensee's switchyard i

_ preventive. maintenance program (Section M2.2).  !

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o A violation was-identified for failure to install a temporary i

,f missile shield during excavation in the area of Essential Raw-

l- Cooling Water (ERCW) underground piping (Section M2.3).

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o A violation was identified in that the DG starting air system i

relief valves were set above the design condition limit (Section

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e An NCV was identified for failure to incorporate procedural

l guidance when an Abnormal Operating Instruction .(A0I) was upgraded

l to an Abnormal Operating Procedure (A0P) (Section E8.4).

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l Plant Sucoort

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e The licensee conducted a challenging. Radiological Emergency Plan

(REP) drill scenario in preparation for the November 6, 1996,

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graded REP exercise. During the drill critique, the licensee was

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quick to identify drill deficiencies and ways to make improvements

in the 2EP program (Section Pl.1).

e The emergency program was observed to be well managed and

l- receiving management support. Effective corrective actions taken

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to previous open items permitted the closure of two violations and -

two IFIs.- (Section Pl.2)

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. Reoort Details

Summary of Plant Status

Unit 1 began the inspection period in power operation. The unit )

operated at power for the duration of the inspection period.

Unit 2 began the inspection period in power operation. On October 11, l

the unit began a controlled shutdown from 100% power because of a

suspected failure of a reactor coolant pump seal and later that day

operators manually tripped the Unit due to equipment problems and

entered Mode 3. (See Inspectioc, Report 50 327,328/96 13). The unit

entered Mode 5 and commenced a forced outage to replace two reactor

coolant pump seal packages and one reactor coolant pump motor. On ,

October 24, 1996, when the repairs to the reactor coolant pumps had been

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completed, the unit entered Mode 4. When the report period ended, the

unit was in Mode 4 awaiting completion of repairs to the motor driven

auxiliary feedwater pumps.

I. Operations

01 Conduct of Operations l

01.1 General Comments (71707)

Using Inspection Procedure 71707, the inspectors conducted frequent

reviews of ongoing plant operations. In general, the conduct of I

operations was good. Particularly noteworthy were the thoroughness and

3rofessionalism of operations shift turnover briefings. Operations has

)egun discussing, during shift turnover briefings, recent instances of

configuration control problems. This is considered a positive  !

initiative by operations management to increase operator awareness of i

such issues in an effort to reduce the number of configuration control

problems. Additional operational events and observat%ns are detailed .

in the sections below. 1

01.2 Inaoorooriate Ooerator Action

On September 24, 1996, a licensed operator assigned to Unit 1  ;

repositioned a Unit 2 Emergency Gas Treatment System (EGTS) Fan A

suction damper control switch from the "A-Auto" position to the "Close"

position and immediately returned the switch to "A-Auto." The damper

was in the closed position both before and after the switch operation

and no damper movement actually occurred. The operator performed this

switch movement to verify the switch spring-return to-auto feature of

the switch. However, the operator did not request the unit supervisor's

permission prior to the test nor did he use Procedure 0-50 65 1

Emergency Gas Treatment System Air Cleanup and Annulus Vacuum,

Revision 0, which gives direction on system alignment and operation.

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Operations management took appropriate disciplinary action and stressed I

to all operators that unapproved testing activities do not meet

management expectations. The ins)ectors concluded that no realignment

of the EGTS occurred because of t1e unauthorized switch test and that

o)erations management took immediate actions to emphasize to operators

t1eir expectations regarding such activities.

The failure to implement the EGTS system operating procedure when

operating the EGTS system is considered a violation of TS 6.8.1.a. This  ;

licensee identified and corrected violation is being treated as a Non- I

Cited Violation, consistent with Section VII.B.1 of the NRC Enforcement

Policy (NCV 50-327, 328/96 11-01).

02 Operational Status of Facilities and Equipment

02.1 Radiation Monitor Inoperable Due to Low Counts

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a. Insoection Scope (71707)

The inspectors reviewed the deficiency related to " low counts"

associated with radiation monitor 0-RM 90101C, Auxiliary Building Vent

Monitor-Iodine, and the operability requirements for the monitor.

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b. Observations and Findinas

On September 18, 1996, during a routine tour of the main control room

(MCR), the inspectors noted a Work Request (WR) sticker, WR C280035,

dated April 12, 1996, attached to radiation monitor 0-RM-90-101C which

indicated that the monitor had ' low counts." The inspectors questioned

operators regarding the operability of the monitor and were informed,

and subsequently verified, that the iodine channel monitor, channel C of i

0-RM 90101, was not required by either the Offsite Dose Calculation

Manual (0DCM) or TS. However, the 00CM does require the iodine sampler,

a cartridge in the radiation monitor flow path which is analyzed weekly )

by Chemistry, to be operable. The ODCH also requires the channel A

particulate sampler and the channel B noble gas activity monitor be

operable. The inspectors verified with Chemistry that the iodine

sampler was, in fact, operable and that weekly samples were being taken.

Discussions with the radiation monitor system engineer indicated that a

condition of low counts renders channel C inoperable. The inspectors l

also learned that repairs to the monitor were awaiting parts and that l

the repairs were scheduled for the week of November 4,1996. The work '

order (WO) associated with the monitor repair stated that the reason for

the low counts was a bad "HV" power supply or a bad detector.

Further review by the inspectors of the operability requirements for I

monitor 0-RM 90 101C revealed that the Updated Final Safety Analysis )

Report (UFSAR), Section 11.4.2.2.4 states that either of the three

channels of 0 RM 90101 (A B, or C) automatically initiates an

Auxiliary Building Isolation (ABI). On September 26, following a '

discussion with the Shift Manager regarding the loss of Auxiliary

Building Isolation (ABI) function for 0 RM-90-101C. the MCR monitor was

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tagged with an "IN0P" tag. On September 28.- Problem Evaluation Report

t (PER) No. SQ%2511PER was written by operations to address the validity

1 of the ABI initiation'since the monitor was not required by either TS or i

the ODCM. The PER also questioned the time frame during which the- i

monitor would not have performed the ABI function. On October 3, 1996.

maintenance personnel replaced the detector on 0-RM 90-101C.. -

-successfully completed the_ post maintenance test (PMT), and returned the

monitor to service.

c. Conclusions

The-inspectors concluded that operators were not aware that 0 RM 90101C

would not perform its designed ABI function with a condition of " low

counts" and. therefore, did not consider the monitor for 0 RM 90 101C to

be inoperable. ~ However, once the question of operability was raised by

the inspectors, operations took appropriate action to identify the

monitor as inoperable and to write a PER. The inspectors will-follow up

on the resolution of PER No. SQ962511PER regarding the ABI function of

0 RM 90 101C. This item is identified as Inspector Followup Item (IFI)

50 327, 328/96-11 02. Review Corrective Action of PER No. SQ962511PER

.Related to ABI Function of Radiation Monitor 0 RM 90 101C.

II. MainteGanCR

M1 Conduct of Maintenance

M1.1 GeneralComtg.niiE2707)

a. Insoection Scoce (61726 & 62707)

-The inspectors observed and/or reviewed all or portions of the following ,

work activities and/or surveillances:  ;

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e WO9629423 Change inboard and outboard bearing oil,and

perform section XI test

e WO9304301 Replace flex conduit to MFIV 2 MV0P 003 0033A

e WO9407044 Replace flex conduit to MFIV 2 HV0P-003 00478 l

e' W09302957

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Replace EDG starting air-system relief valve

e WO9302971 Replace EDG starting air system relief valve

e WO9628678 Replace failed primary water pump seal  :

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b. Observations and Findinos

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The inspectors noted that the work activities and the performance of

surveillance activities were adequately performed.

M2 . Maintenance and Material Condition of Facilities and Equipment

i M2.1 Auxiliary Feedwater Pumo (AFW) 1B B Bearina Oil Discoloration

a. Insoection Scoce (62707)

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The inspector observed a scheduled preventive maintenance activity on

(. the 1B B AFW pump which included changing the. oil on the inboard and

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outboard pump bearings.

i b. Observations and Findinas

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i On September 30,19%, the inspector observed preventive maintenance

being performed on the 1B B AFW pump. The maintenance was performed

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under WO 9629432 and included changing the oil in the inboard and

outboard pump bearings. The oil wnich was drained had a noticeable dark

discoloration and the subsequent oil sample results indicated a high

level of iron and copper. . Also, while inspecting the bearing housing,

the licensee discovered two metal fragments which were believed to have

come from the threads of the oil drain plug when it was over tightened

during its last installation. The licensee performed a visual

inspection of the bearings and did not identify any abnormalities. New

oil was added, an American Society of Mechanical Engineers (ASME)

Section XI test was performed on the pump, and the oil was flushed and

replaced again following the Section XI test. i

The licensee documented the discovery of. the discolored oil in PER No.

SQ962516PER and discussed their oil sample findings with the pump i

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vendor. In a letter from the vendor to the licensee dated October 2,

1996, the vendor stated that both the pump and bearing vendor were aware

of instances (throughout the industry) of " black oil" but had not been l

able to determine.the exact source of the oil discoloration. The vendor l

further stated that they were not aware that this condition and/or the

resulting " black oil" caused failure or accelerated failure of the

bearing, and subsequently the ) ump. The vendor recommended that the

licensee continue to monitor t1e condition and quality of the oil and to

change it periodically. The licensee informed the inspector that they  !

intend to drain and sample the oil after each quarterly run of the pump.

On October 7, 1996, the vendor stated in another letter to the licensee,

that the pum) should )erform satisfactorily until the next refueling

outage and tlat TVA s1ould follow the recommendations concerning the ,

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monitoring and changing of-the oil. The vendor further stated that they

.had not established any specific allowable percentages of elements found

in the oil as indicators to change the oil.  !

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As a result of this most recent problem with AFW bearings / oil, the

licensee's Nuclear Assurance organization initiated PER No. SQ962542PER,

dated October 2,1996, which referenced four previous PER's related to

AFW bearing oil problems, and classified these four PERs as examples of

inadequate recurrence control. One of those four PERs, No. SQ951743PER,

dated October 5,1995, had also identified high metal content in the 1B-

B AFW bearing oil. That PER was closed in April 1996 without a root

cause analysis, without an extent of condition review, without a review

of 3revious similar events, or without interim actions addressing the  :

, hig1 metal content. '

c. Conclusions

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) A positive observation was noted when Nuclear Assurance identified four i

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previous PERs related to AFW bearing oil problems. l

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A weakness was identified in the licensee's corrective action program

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for failure to adequately address previously identified AFW bearing oil

problems. '

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M2.2 Exolosion of Potential Transformer in 500 KV Switchyard  :

a. Insoection Scooe (62707)

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On October 5,1996, a potential transformer (PT) in the 500 KV a

switchyard exploded. The inspector reported to the site to assess the

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damage to the switchyard and to verify that neither unit was affected by

the explosion.

b. Observations and Findinas

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The explosion of the PT caused the loss of Bus 1 in the 500 KV

switchyard. Switchyard relays sensed the electrical fault, as designed,

and power circuit breakers o)ened to clear the differential fault.

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During the event, oil from t1e failed PT sprayed onto the gravel in the

switchyard and ignited. The fire was extinguished in approximately 16

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minutes. Additionally, shrapnel from the ex)losion damaged the 500 KV

to 161 KV intertie transformer as well as otler switchyard components

such as insulators. Both units experienced various control room alarms

but no plant equipment was affected and both units continued to operate

at full power. There were no personnel injuries during the event.

Approximately one hour after the initiation of the event, the licensee

simultaneously declared, then exited, a Notification of Unusual Event

due to an ex)1osion within the protected area. The licensee also

determined tlat the loss of the intertie transformer did not affect the

reliability of the required off site power sources.

The licensee subsequently replaced three pts, including the one which

. exploded, and returned the 500 KV Bus 1 to service on October 12, 1996.

However, when the inspection period ended, the intertie transformer

remained out of service for repairs and other PM activities.

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The inspector reviewed the PM history related to the type of PT which

failed and learned that preventive maintenance had never been performed

on these particular pts since they were purchased in 1972. The

recommended PM interval was noted to be six years. Due to increased

attention which the licensee has recently placed on switchyard

maintenance, these particular pts had been scheduled to be inspected

during the next outage in 1997.

c. Conclusions

The inspector concluded that the licensee's failure, over a period of

years, to ensure that the 500 KV switchyard pts were routinely

inspected, contributed to the eventual failure of the PT. This is

considered a weakness of the switchyard PM program.

M2.3 Yard Fire Hydrant Reoair/Reclacement

a. Inspection Scope (62707)

The inspectors reviewed the activities related to repair / replacement of ,

a yard fire hydrant adjacent to the ERCW underground piping.  !

b. Observations and Findings

During tours of the facility the inspectors noted excavation in the j

area of the ERCW underground piping missile shield. Excavation was i

directly adjacent to the missile shield. The inspector requested the

licensee to provide information regarding requirements for excavation

near safety related equipment. The inspector learned that Site Standard

Practice (SSP)-7.4. Work Permits. Revision 7. required that Site

Engineering shall be notified by the cognizant engineer prior to any I

excavations within 10 feet of Category 1 structures (buildings,

manholes, conduit banks, etc.).

On June 18, 1996, excavation permit No. 94 09292-00 was signed and

issued by Site Engineering to remove earth from around a fire hydrant

adjacent to an ERCW concrete missile shield in order to replace the

hydrant. The permit required temporary missile protection if the

excavation was within six feet from the edge of the ERCW permanent

missile protection. The inspector verified that the fire hydrant was

less than two feet from the ERCW permanent missile protection and

therefore personnel should have contacted Site Engineering for specific

guidance on installing temporary missile protection. The actual

excavation to replace the fire hydrant was started on October 4.1996.

The inspector reviewed WO 9409292 and noted that, in step 5.1. the work

supervisor initialed the step acknowledging that the excavation would be

performed per the SSP-7.4 excavation permit which was part of the work

package. However, the work supervisor did not contact Site Engineering

for specific instructions nor did he install any temporary missile

protection as required by the excavation permit, even though the hydrant

was less than the required six feet from the permanent ERCW missile

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. protection. The failure to install temporary missile protection for

ERCW piping as required by SSP 7.4 is considered to be a violation (VIO

50 327.328/96-11 03).

Following discussions with the licensee, PER No. SQN962668PER was i

initiated to document that temporary missile protection.was not in place j

and that the excavation was immediately adjacent to the ERCW permanent l

missile protection concrete slab.  !

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The failure to follow a procedure, which required a temporary missile

shield, while excavating in the area of ERCW missile shield, is l

considered to be a violation. l

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III. Encineerina l

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El Conduct of Engineering 1

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E1.1 General Comments (37551)

An inspection was' conducted on September 23 27..1996, in the areas of

service water system operational performance in accordance with NRC

Temporary Instruction (TI) 2515/118. This inspection concentrated on

resolution of existing open items associated with the Service Water

System inspection. The NRC review concluded the licensee had adequately i

addressed the technical issues associated with the service water

systems. Section E8 discusses items related to this service water

followup inspection.

E2 Engineering Support of Facilities and Equipment l

E2.1 Diesel Generator (DG) Startina Air system Relief Valves

a. Insoection Scooe (37551)

During the previous inspection period, the inspector observed an

emergency diesel generator (DG) starting air system relief valve lifting

due to overpressure. The inspector reviewed the documentation

associated with the relief valve PM program and the relief valve

corrective maintenance history,

b. Observations and Findinas

Due to problems being experienced with the DG starting air system

pressure control switches, the system relief valves had been documented

as lifting on several occasions. During tours with an assistant unit

operator (AU0) the inspector observed a lifting DG starting air system

relief valve. The inspector had noted that the relief valve was lifting

with a pressure of 345 psig on the starting air system receiver tank.

This observation was discussed in detail in IR 96 09 and included a

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violation for inadequate corrective action associated with the repair >

and replacement of the starting air compressor pressure control  ;

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switches.

In order to determine proper operation of the relief valve, the

inspector reviewed the lift setpoints for the system relief valves. The

system control drawing. CCD No.l.2 47W839 2. NOTE 3. listed the design

' pressure as 250 psig. This drawing information was incorrect. The i

inspector noted that normal system pressure is controlled between 250-

300 psig.

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The design basis document, SQN-DC-V-11.8. documented the maximum I

operating condition as 300 psig and the design condition for the system  !

at 330 psig. The work history noted that the relief valves were set in l

a range of 340 to 360 psig. The licensee is committed to the 1986

Edition of the ASME Pressure Vessel Code. The 1986 Edition of the ASME

Code,Section VIII UG 125 (c), states that all aressure vessels shall be ,

protected by a pressure relieving device that s1all prevent pressure l

from rising more than 10% above the maximum allowable working pressure 1

(operating condition) of the system. Contrary to the ASME code, the DG

starting air system relief valves were set above the allowable limit of

330 psig and this is considered to be a violation (VIO 50 327 328/96-11- 1

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c. Conclusions

The failure to properly adjust the DG starting air system relief valve

(8) setpoints is considered to be a violation.

E8 Miscellaneous Engineering Issues (92902. TI 2515/118)

E8.1 (CLOSED) IFI 95 03-01: Generic Letter (GL) 89 13 Actions on Dead Leg

Flushing, Chemical Treatment. High Pressure Fire Protection (HPFP)

System and Airside Cooler Testing i

This IFI identified that the licensee's GL 8913 committed actions were  !

not fully implemented. Neither the licensee's actions nor the docketed  !

GL 89-13 response fully encompassed the HPFP system. Also, the

licensee's docketed GL 89-13 response omitted discussion of room cooler

air side testing. l

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The inspector toured the ERCW intake pumping station and inspected the

ERCW pumps, strainers, traveling screens, and flood mode sump pumps.

Additionally, the inspector noted the chemical chlorination injection

line was being replaced. '

Regarding room cooler air side testing. the licensee's GL 89 13

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response, dated September 22, 1995, discussed that periodic air flow

testing was performed on the air side of the Emergency Safeguards

Features (ESF) room / area coolers and lower containment vent coolers to

confirm minimum air flow recuirements. The inspector determined that

this periodic testing was acequate.

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Regarding the.HPFP system, the licensee's position was that the HPFP

system was not a safety-related system and the HPFP system was not

included as a service water system as defined by GL 8913 because it did  !

not add heat to the ultimate heat sink. The inspector concurred with  :

the: licensee's position that the HPFP was not a service water system as l

defined by GL 8913. However, based on Technical-Specification

requirements, the licensee was maintaining the HPFP comparable to the GL

89 13 requirements. .

E8.2 (CLOSED) VIO 95-03 02: Inadequate Design Control Measures for ERCW,

HPFP, and DG Batteries

This was a four part' violation that identified numerous deficiencies in I

design control measures associated with ERCW strainer plugging, use of

the HPFP system for flood mitigation, acceptability of replacement DG

batteries, and the setpoint calculation for turbine building isolation.

The inspectors reviewed the corrective actions contained in the

licensee's response dated May 22, 1995. Based on the inspectors review,

these corrective actions had been implemented and adequately addressed

the deficiencies. Accordingly, this violation is closed.

E8.3 (CLOSED) URI 95 03-03: Interpretation of Design Basis Flood

This Unresolved Item (URI) questioned whether the licensee's

categorization of the design basis for two 100% capacity ERCW upper deck

sump pumps as an " event" versus an " accident" was consistent with NRC

regulations. Due'to the licensee's classification that the upper deck

sump pumps were required to mitigate certain " events" but not the

consequences of an accident, the sump pumps had-not been included in any

pump testing or maintenance program.

The inspectors concluded that the upper deck sump pumps would not be

considered safety-related by any existing regulation. However,

occurrences such as fires, floods, missiles, storms, or earthquakes were

considered." events" and any event can lead to or cause an accident that

requires analysis under Chapter 15 of the UFSAR. Since the sump pumps

have some importance to safety, the licensee should have a testing

program to comply with General Design Criteria (GDC) I. GDC I requires ,

components important to safety be tested to quality standards

commensurate with the im)ortance of the safety function to be performed.

The inspector verified tie licensee had placed the ERCW sump pumps in-

the second ten-year inspection interval:for ASME Section XI. Since ASME

Section XI testing clearly meets the requirements of GDC I, this URI is

closed.

E8.4 (CLOSED) VIO 95-03 04: Inadequate Procedures or Improper Procedure

Implementation

This violation identified five examples of deficiencies with either

procedure quality or adherence. The examples cited were inadequate

review of procedure Abnormal Operating Instruction (A0I) 7. Probable

Maximum Flood,' failure to post a transient fire load permit, failure to

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place a work request sticker on inoperable control room instrumentation,

and inadequate performance of an equalivanency evaluation. The

inspectors reviewed the corrective actions contained in the licensee's

response dated May 22, 1995. Based on the inspectors review, these

corrective actions had been implemented and adequately addressed the i

deficiencies. Accordingly, this violation is closed. '

During the review of corrective actions for inadequate review of

procedure A01-7, the inspectors noted that a licensee Quality Assurance ,

(QA) audit had identified procedure Abnormal Operating Procedure (A0P)- '

N.03, Flooding, Revision 0, contained references to procedure 0 FP-MXX-

000 003 and did not contain actions that were in A0I 7. The licensee

had canceled procedure 0-FP-MXX-000-003. Flood Preparation - Parts,  !

Tools, and Equipment to be Moved Above Elevation 723.1, and included a )

list of supplies and equipment that were to be moved above the flood

level in procedure A0P N.03. The licensee had issued PER No.

SQ962256PER dated August 2.1996 to document these QA audit findings. ,

The licensee issued A0P N.03 revision 1 effective September 6,1996 to I

address the QA audit findings, j

10 CFR 50, Appendix B, Criterion III, " Design Control " states in part ,

that " Measures shall be established to assure that applicable regulatory )'

requirements and the design basis . . . are correctly translated into

s)ecifications, drawings, procedures, and instructions." Contrary to

t1e above, the licensee failed to ensure the procedural guidance

provided in A0I-7 was pro)erly translated to A0P-N.03. However, the ,

licensee had identified tie problem and taken prompt corrective action. '

This licensee-identified and corrected violation is being treated as a

Non Cited Violation, consistent with Section VII.B.1 of the NRC

,

Enforcement Policy. This is item is identified as NCV 50 327. 328/96- 4

11-05. Inadequate Translation of Procedural Guidance During AOP Upgrade

Program.

E8.5 (Closed) VIO 95 03 05: Failure to Identify Conditions Adverse to

Quality

This violation identified three examples for failing to initiate a

problem evaluation report of conditions adverse to quality. The

examples cited were multiple calculations that were not adequately

documented for stand alone review, multi)le deficiencies with plant

service water system identified during tie licensee's self assessments

in 1993 and 1994, and failure to comply with TS 6.2.3.4. The inspectors

reviewed the corrective actions contained in the licensee's response

dated May 22, 1995. Based on the inspectors review, these corrective

actions had been implemented and adequately addressed the deficiencies.

Accordingly, this violation is closed.

E8.6 (CLOSED) IFI 95-03 08: LC0 Considerations for Select Room Coolers

The licensee had issued a memorandum to Operations personnel providing

guidance on entry into LCOs when room coolers were removed from service.

The memorandum contained a matrix that related room coolers to the

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a)plicable LC0 and the unit or units affected. The inspectors concluded

t1e memorandum provided sufficient guidance to the operators.

E8.7 (CLOSED) IFI 95 03-10: Implementation of New Ultrasonic Testing

Methodology

This IFI identified the licensee's ultrasonic testing (UT) of piping had i

not been o)timized. The UT was a pass / fail test without attempting to

quantify t1e corrosion rate or predict through-wall failures. Within

the past year, the licensee began to gather data to determine corrosion

rate or predict through wall failure. The program had not been in

effect long enough to produce quantifiable results. i

The inspector held discussions with the engineering personnel involved

in the wall thickness inspections and reviewed the test data for two

areas inspected using UT identified as 1-67 D G057 and 1-67 W-G024.

Licensee trending of UT data indicated that base material thickness for ,

piping area 1-67 W-G024 was ap3 roaching minimum wall thickness and was I

recently replaced. Based on t1e inspectors evaluation, this program was

found to be adequate.

IV. Plant Support i

P1 Conduct of EP Activities )

Pl.1 Observation of Radioloaical Emeraency Preoaredness (REP) Drill

a. Insoection Scoce (82301) l

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On October 2, 1996, the inspector observed portions of an REP drill

which the licensee conducted in pre)aration for the November 6 full

scale REP Graded Exercise. On Octo)er 4, 1996, the inspector attended

the licensee's formal critique of the October 2 drill.

b. Findinas and Observations

The inspector observed the activation of the Technical Support Center I

(TSC) during this total loss of all offsite AC electrical power drill

scenario. To give a realistic effect the TSC normal lighting was

disabled and the TSC was illuminated only by installed emergency

lighting and hand carried flashlights. The TSC was staffed

expeditiously and appeared to function smoothly even with limited

lighting. The inspector observed that the licensee experienced problems

with the Integrated Computer System (ICS), an initial shortage of phone

headsets, and telecommunication problems with the corporate emergency ,

response center. These deficiencies were discussed by the licensee at i

the formal critique following the drill.

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c. Conclusions

The inspector concluded that the licensee conducted a challenging REP

drill scenario in preparation for the November 6,1996, graded REP

exercise. During the drill critique, the licensee was quick to identify

drill deficiencies and discussed ways to make improvements in the EP

program.

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Pl.2 Followuo  !

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a. InsDeCtion SCODe (82701)

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The inspection focused on program initiatives to correct program I

deficiencies that were identified in an emergency preparedness l

inspection conducted in April 1996 and documented in Inspection Report i

50 327, 50-328/96 04.

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b. Observations and Findinas

Since the April inspection the licensee had conducted a self assessment

of the emergency preparedness program and completed the 50.54(q) review 1

of the program. The reviews resulted in some minor inconsistencies  !

being corrected but both the self assessment and 50.54(q) review

'

validated an effective program. The inspector's review of 1)

documentation addressing the maintenance of the emergency preparedness

program, 2) equipment and facilities, and 3) review of training i

documents and training was accomplished with no safety-significant

>

issues identified.

The focus of inspection observations was on the open items from the

April inspection. The inspector reviewed the radiological monitoring

i instrumentation in the Control Room against the instrumentation ranges

and nomenclature identified in the EALs. No issues were identified,

which closed IFI 50 327, 328/96-04 05. The inspector reviewed selected

copies of the Emergency Plan and Implementing Procedures to verify that

controlled copies were being properly maintained. No discrepancies were

,

noted, thus closing VIO 50 327, 50 328/96 04-06. The inspector reviewed

the status of the batteries for the OSC radios. The batteries were

fully charged, with 11 spares available. The licensee had implemented a

program for maintaining the batteries. This closed VIO 50-327,

50 328/96 04-07. The inspector reviewed the licensee's implementation

of its tracking and closing of items identified as issues during drills.

The inspector found the licensee to be extremely aggressive in tracking

items and assigning responsibility for corrective action. This closed

IFI 50 327, 50 328/96-04 09.

c. Conclusions

The inspector's observations verified that the program was being managed

effectively, and that good corrective actions had been taken to

previously identified issues. Two open violations (50 327,

50 328/96 04 08 and 50-327, 328/96 04 10) were not reviewed because

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i additional information had been provided to NRC and a reply had yet to

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be provided.

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The emergency program was obstrved to be well managed and receiving

management support. Effectivo corrective actions taken to previous open

items permitted the closure of two violations and two IFIs.

V. Manaarment Meetinas

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X1 Exit Meeting Summary

The inspectors ) resented the 11spection results to members of licensee

,

management at t1e conclusion of the inspection on November 5,1996.

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The licensee acknowledged the findings presented.

! The inspectors asked the licer see whether any materials would be

considered proprietary. No p'oprietary information was identified.

.

! PARTIAL LIS1 0F PERSONS CONTACTED

Licensee

• Adney, R., Site Vice President

• Beasley, J., Acting Site Quality Manager

• Bryant, L., Outage Manager

• Burzynski, M., Engineering & Materials Manager

Driscoll, D., Training Marager

• Fecht, M., Nuclear. Assurar.ce & Licensing Manager

Fink F., Business and Wo"k Performance Manager

• Flippo, T., Site Support 11anager

• Harrington, W., Acting Ma'ntenance Manager

• Herron, J. , Plant Manager

Kent, C. 'Radcon/Chemistr) Manager

Lagergren, B., Operations ianager

Rausch, R. Maintenance and Modifications Manager

Reynolds, J., Operations Superintendent

• Rupert, J., Engineering and Support Services Manager

• Shell, R., Manager of Licensing and Industry Affairs

Skarzinski, M., Technical Support Manager

• Smith, J., Licensing Supervisor

Summy, J., Assistant Plant Manager

Symonds, J. Modifications Manager

• Attended exit interview

INSPECTION PROCEDURES USED

IP 37551: Onsite Engineering

IP 40500: Effectiveness of Licensee Controls In Identifying,

Resolving, & Preventing Problems

IP 61726: Surveillance Observations

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IP 62707: Maintenance Observations

IP 71707: Plant Operations

IP 71750: Plant' Support Activities

IP 82301: Evaluation of Exercises for Power Reactors

IP 92902: Followup Maintenance

TI 2515/118: Service Water System Operational Performance Inspection

<

IO 82701: Operational Status of the Emergency Preparedness Program

IHMS OPENED. CLOSED. AIO DISCUSSED

Ooened

TyRg Item Number

_ Status Descriotion and Reference

NCV 50 327, 328/96-11 01 Open/ Failure to Implement EGTS System

Closed Operating Procedure When Operating

EGTS (Section 01.2).

IFI 50-327, 328/96 11-02 Open Review corrective Action of PER No. i

SQ962511PER Related to ABI Function

of Radiation Monitor 0 RM-90-101C

(Section 02.1).

VIO 50 327. 328/96-11-03 Open Failure to Install Temporary Missile

Protection for ERCW Piping as

Required by SSP-7.4 (Section M2.3).

VIO 50-327, 328/96 11-04 Open Failure to Set DG Starting Air )

System Relief Valves with the ASME l

Code Limit (Section E2.1). j.

NCV 50 327, 328/96 11 05 Open/ Inadequate Translation of Procedural

Closed Guidance During A0P Upgrade Program.

(Section E8.4) ,

Closed

Typf Item Number Status Descriotion and Reference

IFI 95 03 01 CLOSED GL Actions on Deadleg Flushing Chemical

Treatment. HPFP System & Airside Cooler Testing

(Section E8.1)

VIO 95 03 02 CLOSED Inadequate Design Control Measures for ERCW.

HPFP and EDG Batteries (Section E8.2)

URI 95 03 03 CLOSED Interpretation of Design Basis Flood (Section

E8.3)

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VIO 95 03 04 CLOSED Inadequate Procedures or Improp: Procedure

Implementation (Section E8.4) ,

VIO 95 03-05 CLOSED Failure to Identify Conditions Adverse to l

Quality (Section E8.5) l

IFI 95 03 08 CLOSED LC0 Considerations for Select Room Coolers

(Section E8.6)

IFI 95 03-10 CLOSED Implementation of New Ultrasonic Testing

Methodology (Section E8.7)

IFI 96 04 05 CLOSED Inconsistency between Numenclature in the EALs

and Control Room, and Proper Terminology in the

EALs (Section Pl.2)

VIO 96 04 06 CLOSED Failure to Maintain Controlled Volumes of the I

EPIPs up to date (Section Pl.2) l

VIO 96 04-07 CLOSED Failure to Maintain Operational Readiness of the i

Batteries for the Emergency Two way Radios in l

the OSC (Section Pl.2)

IFI 96-04-09 CLOSED Verify the Tracking and Resolution of Corrective

Action Items and Items Needing Improvement

Identified in Drill Reports (Section 1.2)

LIST OF ACRONYMS USED

ABI -

Auxiliary Building Isolation l

AC - Alternating Current

AFW -

Auxiliary Feedwater

A0I -

Abnormal Operating Instruction

A0P -

Abnormal Operating Procedure

ASME -

American Society of Mechanical Engineers

AU0 -

Assistant Unit Operator

CCP -

Centrifugal Charging Pump

CFR -

Code of Federal Regulations

CLA -

Cold Leg Accumulator

DG -

Diesel Generator

DRP - Division of Reactor Projects

ECCS -

Emergency Core Cooling Systems

EDG -

Emergency Diesel Generator

EGTS - Emergency Gas Treatment System

EHC -

Electro Hydraulic Control

EP -

Emergency Preparedness

ERCW - Essential Raw Cooling Water

ESF -

Engineered Safeguard Features

GDC -

General Design Criteria

GL -

Generic Letter

gph -

Gallons per hour

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HV - High Voltage

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ICS -

Integrated Computer System

.

IFI -

Inspector Followup Item

IR -

Inspection Report

KV -

Kilo Volt

LC0 -

Limiting Condition for Operation

LER -

Licensee Event Report

MI -

Maintenance Instruction

MSIV - Main Steam Isolation Valve

MCR -

Main Control Room

NIS -

Nuclear Instrumentation System

NOUE -

Notification of Unusual Event

NCV -

Non cited Violation

NRC -

Nuclear Regulatory Commission

NRR -

Nuclear Reactor Regulation

j ODCM -

Offsite Dose Calculation Manual

PCF -

Procedure Change Form

PER -

Problem Evaluation Report

PM -

Preventive Maintenance

PMT -

Post Maintenance Test

P00 -

Plan of the Day

PT -

Potential Transformer

. psig -

pounds per square inch gage

. QA -

Quality Assurance

! QC - Quality Control

! RCS -

Reactor Coolant System

i REP - Radiological Emergency Plan

RHR -

Residual Heat Removal

RM -

Radiation Monitor

rpm -

Revolutions per Minute

RVLIS - Reactor Vessel Level Indication System

SALP - Systematic Assessment of Licensee Performance

SFP -

Spent Fuel Pit / Pool

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SI -

Surveillance Instruction

SR0 -

Senior Reactor Operator

. SSP -

Site Standard Practice

Solid State Protection System

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SSPS -

TI -

Tem)orary Instruction l

TS -

Tec1nical Specifications

4

TSC -

Technical Support Center

l TVA -

Tennessee Valley Authority

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UFSAR - Updated Final Safety Analysis Report

UT -

Ultrasonic Testing

URI -

Unresolved Item

VCT -

Volume Control Tank

VDC -

Volts Direct Current

Violation

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VIO -

WO -

Work Order

WR -

Work Request j

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