ML20134B074

Insp Repts 50-327/85-32 & 50-328/85-32 on 850906-1005. Violation Noted:Failure to Follow Procedure During Test of Control Room Chlorine Detection Sys

ML20134B074
Person / Time
Site:	Sequoyah
Issue date:	10/30/1985
From:	Jenison K, Linda Watson, Weise S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20134B062	List: IR 05000906/2010005 ML20134B060 ML20134B074
References
50-327-85-32, 50-328-85-32, NUDOCS 8511110226
Download: ML20134B074 (12)

See also: IR 05000327/1985032

Text

r-

A R E T t,, UNITED STATES I

. o NUCLEAR REGULATORY COMMISSION I

[ # ,$ REGION 11

g j 101 MARIETTA STREET, N.W. l

• 2 ATLANTA, GEORGI A 30323

s,

...../

Report Nos.: 50-327/85-32 and 50-328/85-32

Licensee: Tennessee Valley Authority

6N11B Missionary Ridge Place

1101 Market Street

Chattanooga, TN 37402-2801

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

Facility Name: Sequoyah linits 1 and 2

Inspection Conducted: September 6, - October 5, 1985

Inspectors: 6 f7 . d.,, Ini, /4/34/85

K.M.Jenison(/SeniorResidentInspector Date Signed

C T dlnai,L, An/D /RE

L. J. Watson, Re ident Inspector Date Sfgned

Approved by: . [ 3v!D

S. P. Weise, Section Chief Date Signed

Division of Reactor Projects

Sl'MMARY

Scope: This routine, announced inspection involved 325 resident inspector-hours

onsite in the areas of: operational safety verification including operations

performance, system lineups, radiation protection, security and housekeeping

inspections; surveillance and maintenance observations; review of previous

inspection findings; followup of events; review of licensee identified items;

Engineered Safety Feature; and review of inspector followup items.

Results: One violation was identified - Failure to follow procedure during a

test of the Control Room Chlorine Detection System (paragraph 10).

g1110226851030

0 ADOCK 05000327

PDR

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REPORT DETAILS

1. Licensee Employees

Persons Contacted

H. L. Abercrombie, Site Director

• P. R. Wallace, Plant Manager

L. M. Nobles, Operations and Engineering Superintendent

• B. M. Patterson, Maintenance Superintendent

• J. M. Anthony, Operations Group Supervisor

• D. C. Craven, Quality Assurance Supervisor

D. E. Crawley, Health Physics Supervisor

J. L. Hamilton, Quality Engineering Supervisor

• G. B. Kirk, Compliance Supervisor

D. H. Tullis, Mechanical Maintenance Group Supervisor

• R. C. Birchell, Compliance Engineer

• C. L. Wilson, Nuclear Engineer

• C. E. Bosley, QA Evaluator, Division of QA, Quality Assurance Branch

• D. L. Cowart, Quality Surveillance Supervisor

Other licensee employees contacted included technicians, operators, shift

engineers, security force members, engineers and maintenance personnel.

• Attended exit interview

2. Exit Interview

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

members of his staff on October 7, 1985. A violation described in paragraph

10 and a second example of a previous violation described in paragraph 6

were discussed. The licensee acknowledged the inspection findings and did

not identify as proprietary any material reviewed by the inspectors during

this inspection. During the reporting period, frequent discussions were

held with the Site Director, Plant Mannger and his assistants concerning

inspection findings. At no time during the inspection was written material

provided to the licensee by the inspector.

3. Licensee Action on Previous Inspection Findings (92702)

(Closed) Violation 328/83-16-02. The licensee's response of October 7,

1983, was reviewed and the indicated corrective actions were audited. The

licensee conducted Mechanical Maintenance Section training on the importance

of adhering to mandatory Quality Assurance procedural hold points. The

licensee's corrective actions are considered complete.

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(Closed) Violation 328/84-21-05. The licensee's response of September 20,

1984, was reviewed and the indicated corrective actions were audited. The

licensee conducted training on the requirement for the independent verifi-

cation of processed hold orders. In addition, administrative action was

taken with respect to the involved individuals. The licensee's corrective

actions are considered complete.

(Closed) Violation 328/83-31-03. The licensee's response of March 15,

1984, was reviewed and the indicated corrective actions were audited. The

licensee conducted training on a variety of operational subjects involved

with this violation. Surveillance Instructions were revised to include the

methods and details of valve locking. The licensee's corrective actions are

considered complete.

(Closed) Violation 328/83-31-04. The licensee's response of March 15,

1984, was reviewed and the indicated corrective actions were audited. The

licensee amended its maintenance procedures to require that both Assistant

Shift Engineers be required to sign prior to the removal from service of any

inverter, 6900-volt shutdown board or 480-volt shutdown board. In addition,

this topic was included in licensed operator requalification training. The

licensee's corrective actions are considered complete.

! (Closed) Unresolved Item 327, 328/85-26-04. Corrective maintenance was

reviewed on containment isolation valves 2-67-580A through D. Two of these

y valves were examined by the inspector after being cut from the Essential Raw

Cooling Water system and disassembled. The valves were badly corroded and

the internal flapper arm pins were out of round. The seating surface was

worn, but there was no indication of foreign materials within the valves.

These valves were retested and determined to be operable. The licensee ,

updated their maintenance history associated with these components. This

item is considered to be closed.

4. Unresolved Items

No unresolved items were identified during this,it.spection.

5. Operational Safety Verification (71707)

a. Plant Tours

The inspectors observed control room operations, reviewed applicable

logs, conducted discussions with control room operators, observed shift

turnovers, and confirmed operability of instrumentation. The

inspectors verified the operability of selected emergency systems,

reviewed tagout records, verified compliance with Technical

Specification (TS) Limiting Conditions for Operation (LCO) and verified

return to service of affected components. The inspectors verified that

maintenance work orders had been submitted as required and that

followup activities and prioritization of work was accomplished by the

licensee.

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Tours of the diesel generator, auxiliary, control, and turbine

buildings were conducted to observe plant equipment conditions,

including potential fire hazards, fluid leaks, and excessive vibrations

and plant housekeeping / cleanliness conditions.

The inspectors walked down accessible portions of the following

safety-related systems on l' nit 1 and l' nit 2 to verify operability and

proper valve alignment:

Residual Heat Removal System (l' nits 1 and 2)

Charging Pump Flowpath (l' nits 1 and 2)

Diesel Generators (l' nits 1 and 2)

Control Room Ventilation Chlorine Detection System (Common)

b. Security

During the course of the inspection, observations relative to protected

and vital area security were made, including access controls, boundary

integrity, search, escort, and badging. No violations or deviations

were identified.

c. Radiation Protection

The inspectors observed Health Physics (HP) practices and verified

implementation of radiation protection control. On a regular basis,

radiation work pennits (RWPs) were reviewed and specific work

activities were monitored to assure the activities were being conducted

in accordance with applicable RWPs. Selected radiation protection

instruments were verified operable and calibration frequencies were

reviewed.

On September 26, 1985, the inspector observed workers frisking out of a

regulated zone, on EL690 at the hallway laading to the hot machine

shop. The licensee's procedure, Radiological Control Instruction,

RCI-1, Radiological Hygiene Control, requires frisking of the hands and

feet with a counter provided at the ev.it to the area. One maintenance

section worker exiting the regulated area frisked his feet, but did not

frisk his hands. Failure to follow the radiation protection procedure

for frisking when exiting a regulated zone is a violation; however,

since the licensee was in the process of implementing corrective action

for a similar violation (327, 328/85-26-03), involving the failure to

frisk out of a contaminated zone, this incident constitutes a further

example of that violation.

Corrective action for this incident included the assignment of an HP

technician to the maintenance section to provide additional training

and assure awareness of Health Physics (HP) procedures and practices.

This training will be completed by January 3,1986.- Implementation of

these actions are intended to prevent recurrence of similar incidents.

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Current audits conducted by the licensee indicate a substantial

improvement in overall compliance with HP requirements during the past

year, and adequacy of corrective actions will be verified by TVA

through future audits.

In addition, the inspector noted that individuals were picking up the

hand held monitor without frisking the hand used to pick up the

monitor. This is a poor health physics practice and was brought to the

attention of plant management. The inspector will continue to monitor

the frisk out process to assure proper controls are in place.

6. Engineered Safety Features Walkdown (71710)

The inspectors verified operability of the Component Cooling Water System

(CCS) on Units 1 and 2 by performing a partial walkdown of the accessible

portions of the system. The remainder of the walkdown on this system will

be completed in the next inspection period. The following specifics were

reviewed and/or observed as appropriate:

a. that the licensee's system lineup procedures matched plant drawings and

the as-built configuration;

b. that equipment conditions were satisfactory and items that might

degrade performance were identified and evaluated;

c. with assistance from licensee personnel, the interior of the breakers

and electrical or instrumentation cabinets- were inspected for debris,

loose material, jumpers, evidence of rodents, etc.;

d. that instrumentation was properly valved in and functioning and

calibration dates were appropriate;

e. that valves were in their proper positions, breaker alignment was

correct, power was available, and valves were locked as required; and

f. local and remote instrumentation was compared, and remote instrumen-

tation was functional.

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During the tour, the inspectors identified several discrepancies:

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housekeeping in several areas was marginal

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new piping segments were attached to existing fire protection- piping

using masking tape

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valve labelling and location identifier accuracy

- conduit degradation

This was brought to the attention of the licensee. The licensee attributed

the problem to outage work activities.

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The inspector reviewed housekeeping logs kept by the licensee in accordance

with procedure SQA-66, Plant Housekeeping. TVA management housekeeping

tours are performed approximately monthly. Ditcrepant areas identified

during tours are rechecked to assure corrective action has been taken. The

inspectors also reviewed Operations Section Letter OSLA-99, Auxiliary l' nit

Operator (Al'0) Duties, and determined that Al'Os are required to identify

housekeeping problems. The inspectors will review plant housekeeping and

licensee implementation of SQA-66 and OSLA-99 during the remainder of the

outage. Followu on this issue is an Inspector Followup Item

(327, 328/85-32-02) p

.

No violations or deviations were identified.

7. Monthly Surveillance Observations (61726)

The inspectors observed TS required surveillance testing and verified that

testing was performed in accordance with adequate procedures; that test

instrumentation was calibrated; that Limiting Conditions for Operation were

met; that test results met acceptance criteria requirements and were

reviewed by personnel other that the individual directing the test; that

deficiencies were identified, as appropriate, and that any deficiencies

identified during the testing were properly reviewed and resolved by

management personnel; and that system restoration was adequate. For the

completed tests, the inspector verified that testing frequencies were met

and tests were performed by qualified individuals.

The inspector witnessed / reviewed portions of the following surveillance test

activities:

SI-688.2 Functional Test for Accident Radi nion Monitor System

IMI-99 Reactor Protection System RT 11.6 & 11.8, Response Time

Test of Delta T/Tavg Channels 2 and 4

SI-40 Centrifugal Charging Pump

SMI-0-90-1 High Dose Rate Calibration for Containment High Range

Accident Monitors

No violations or deviations were identified in this area.

8. MonthlyMaintenanceObservations(62703)

a. Station maintenance activities of safety-related systems and components

were observed / reviewed to ascertain that they were conducted in

accordance with approved procedures, regulatory guides, industry codes

and standards, and in conformance with TS.

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The following items were considered during this review: LCOs were met

while components or systems were removed from service; redundant

components were operable; approvals were obtained prior to initiating

the work; activities were accomplished using approved procedures and

were inspected as applicable; procedures used were adequate to control

the activity; troubleshooting activities were controlled and the repair

record accurately reflected what actually took place; functiona)

testing and/or calibrations were perfomed prior to returning

components or systems to service; quality control records were -

maintained; activities were accomplished by qualified personnel; parts

and materials used were properly certified; radiological controls were

implemented; QC hold points were established where required and were

observed; fire prevention controls were implemented; outside contractor

force activities were controlled in accordance with the approved

Quality Assurance (QA) program; and housekeeping was actively pursued.

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b. During the l' nit I refueling outage the inspector observed portions of

steam generator maintenance and audited documentation of the work '

activities involving the cleaning of the secondary side by sludge

lancing, primary side eddy current examinations and plugging of the

Row I and other tubes for all four steam generators. - The following

procedures were reviewed / observed by the inspectors:

Radiation Work Permit: 02-1-85112

Maintenance Requests: A549689, A549690, A549692,

AS49528, A549691, A533110,

4 A301950, A302397, A302398,

A302399

x

Vendor Standard: CFS-STD-020, Steam Generator

Tube Sheet Sludge Re1 oval

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Maintenance Instructions: MI 3.7, Preparation for

Performance of . and Recovery

From Steam Generator Sludge

Lancing

MI 3.1, Removal and Installa-

tion of Steam Genera' tor' Primary

Manway Cover, l' nits 1 an_d 2

MI 3'. 3 , Steam Generator *

Secondary Side Inspection

m3

MI 3.4, Breaching Penetration

X-54 Without Breaching the

ABSCE for Eddy Current Testing, "

Helium Leak Testing, Sludge

Lancing and Other Purposes w

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MI 3.2, Method of Plugging

Steam Generator Tubes

Standard Practices: SQA 119, l'nreviewed Safety

Question Determination (l'SQD)

SQM 001,Sequoyah Nuclear Plant

Maintenance Program

l'SQD Documentation: l'SQD 85-0998, involving use of

a special eddy current test

probe for Row 1 tubes.

d

l'SQD 85-0999, involving

performance of worker platform

training.

ASME Code Document: ASME Code Section XI, 1977

<

amended by Summer 1978 addenda

The licensee began steam generator (SG) maintenance with a visual

examination of the secondary side using a fiberscope to determine the

condition of the steam generators. Video recordings were made of the

in:;pection. It was determined that sludge lancing was needed to remove

sediment on the secondary side at the tube sheet. The inspector

observed sludge lancing activities, which involved a newly developed

technique.

All four SGs were sludge lanced between three to four sweeps each with

a total of approximately 1750 pounds of sludge removed. This averaged

over 400 pounds'per SG. Fiberscopic examinations after completion

indicated that the SGs were essentially clean. The new technique was

found to be more effective for sludge removal.

The licensee stated that the sludge removed consisted of approximately

70% iron and 30% copper. The licensee is also replacing the main

feedwater heaters and the moisture separator reheater tube bundles

, during this outage to eliminate copper from the secondary system. The

licensee recovered two small pieces of a drill bit from one steam

generator. No damage was attributed to this material. The licensee

also had to recover parts of a camera that came loose during a

s fiberscopic exam.

"

The licensee inspected 100% of the tubes on all four SGs using eddy

current probes, with the exception of the l'-bend portion of the Row 2

tubes. This exception was made due to the difficulty associated with

an inspection of these lf-bends and no industry wide history of failures

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\ in the Row 2 l'-bend area.

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.The eddy current exams identified .that four Row 1 tubes had indications

of corrosive cracking. Although the indications were minor and could

riot be categorized as to depth, the licensee decided to plug the Row 1

tubes in all four steam generators to ensure that cracks did not

develop in these tubes. The licensee will evaluate the indications and

can later remove the Row 1 tube plugs as desired. The licensee is

evaluating a stress relieving process which employs electric heaters to

remove induced thermal stresses as a part of the process that could

return the plugged Row 1 tubes to service. Three other tubes with

indications of less than 30% through wall were plugged. At the end of

this inspection period, the licensee was still evaluating the eddy

current data and may elect to plug additional tubes.

The licensee also utilized a new device for tube plugging developed by

Combustion Engineering. The device was installed in the steam

. generator and manipulated remotely to install *;ube plugs. The device

is capable of employing a magazine which can be loaded with a number of

plugs at one time reducing entries into the SG. The device offered

reductions in the dose and time associated with SG tube plugging. The

licensee estimated that the dose - associated with the plugging

operations during this outage was reduced from approximately 200 rem to

50 rem.

c. Replacement of the 1-A Centrifugal Charging Pump mechanical seals was

observed. The following documents were reviewed / observed in part:

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Maintenance Instruction (MI) 6.4 - Removal, Inspection and

Replacement of Centrifugal Charging Pump Seals

Surveillance Instruction (SI) 40 - Centrifugal Charging Pump

Maintenance Request A529430 '

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During the performance of the seal replacement, the technicians

identified that an 0-ring, issued from Power Stores, was not the size

specified by the vendor. This appeared to be due to mispackaging of

the 0-ring by the vendor, since the shipping package and the receipt

documentation matched the material identification numbers specified by

the vendor. A new 0-ring was requisitioned to replace the defective

one,

d. During this outage period, preventive maintenance was conducted on both

l' nit 1 and l' nit 2 Reactor Coolant Pumps (RCP). One activity involved

an evaluation of the breakaway torque associated with each RCP motor.

Maintenance Request A529848 was used to obtain the breakaway torque for

each RCP motor and the data was evaluated against vendor's acceptance

criteria. The inspector observed the performance of the preventive

maintenance on the l' nit 2 loop 3 RCP with no discrepancies . identified.

The licensee later identified the t' nit 1 loop 2 RCP as not meeting the

acceptance criteria and disassembled the subject pump to perform

corrective maintenance.

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No violations or deviations were identified.

9. Licensee Event Report (LER) Followup (92700)

The following LER's were reviewed and closed. The inspector verified that:

reporting requirements had been met; causes had been identified; corrective

actions appeared appropriate; generic applicability had been considered; the

LER forms were complete; the licensee had reviewed the event; no unreviewed

safety questions were involved; and violations of regulations or TS condi-

tions had been identified.

a. LER Unit 1

327/82115 Inoperable Upper Containment Personnel Airlock

(Revision 1)

327/83093 Inoperable Condenser Vacuum Flow Rate Monitor

(Revision 1)

327/83100 Automatic Control Valve Declared Inoperable

,

327/83165 Primary Containment Internal Pressure (Revision 1)

327/83168 1 A-A Diesel Generator (DG) Failed to Start

327/83177 2 A-A DG Failed to Trip

327/83183 Limitorque Operator Limit Switch Failed

327/83186 1 A-A DG Trip

.

327/84011 Control Habitability System (Revision 1)

327/84034 No Flow Indication on 'B' Essential Raw Cooling Water

Header

327/84045 Inoperable Auxiliary Air Compressors (Revision 1)-

327/85003 Surveillance Interval Exceeded

327/85022 Failure to Complete Hourly Fire Watch

327/85024 Failure to Complete Hourly Fire Watch

'327/85025- Failure to Obtain a Noble Gas Sample

327/85028 Failure to Complete Hourly Fire Watch

327/85031 Auxiliary Building Isolation

327/85033. Main Control Room Isolation

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327/85035 Emergency Diesel Generator Start

327/85036 Failure to Complete Hourly Fire Watch

b. LER l' nit 2

328/84004 Loss of 6900 Volt l' nit Board

328/84020 Inadvertent Safety Inje: tion (Revision 1)

10. EventFollowup(93702,62703,61726)

a. On August 27, 1985 an engineered safety feature actuation occurred as a

result of a Train B main control room isolation signal. The main

control room isolation occurred during the performance of Surveillance

Instruction (SI) 240, Functional Test of Control Room Air Intake

Chlorine Detection System. Step 4.4 of SI 240 requires the technician

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to place switch HS-43-205B in the test position prior to introducing

chlorine fumes into the detection system. The technician performing

the surveillance and the assistant observing his actions failed to

implement step 4.4 of SI 240, and as a consequence, initiated an

engineered safety feature actuation when the chlorine fumes were

introduced into the. detection system. This failure to follow procedure

constitutes a violation (327, 328/85-32-01). The technician placed the

subject switch in the test position after becoming aware of the main

control room isolation. He then continued the surveillance, initialing

Section 4.4 of Appendix B to SI 240 and reapplying the chlorine

standard to the detection system, without informing appropriate

supervisory or operations personnel.

As a result of previous Inspector Followup Item (327, 328/85-26-07),

the licensee committed to provide formal instructions to employees on

actions to be taken when the employee fails to follow procedures. The

licensee issued a maintenance notice entitled, Your Responsibilities

in Following Instructions, to all maintenance employees on or about

July 22, 1985. Based on inspector review, a majority of the mainte-

nance technicians appear to have received the notice. The technician

that was involved in the above failure to follow procedure was tem-

porarily assigned to the TVA training center during the period that

the notice was issued and therefore was not . fully aware of its

contents. Inspector Followup Item 327, 328/85-26-07 will-remain open

pending further NRC assessment.-

b. On' September 27, 1985, a Combustion Engineering employee abraded his

plastic ~ gloves and scraped his hand on the SG tube sheet while per-

forming steam generator tube plugging activities. The individual

_

was removed from the area for decontamination. Initial contamination

was approximately 1,000 cpm. The licensee decontaminated the hand to a

level of 400 cpm. At the advice of an offsite physician, the licensee

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decided to take the individual to the hospital for further treatment.

The licensee declared an l'nusual Event in accordance with IP-1,

Emergency Plan Classification Logic, and IP-2, Notification of l'nusual

Event, in anticipation of transporting a contaminated person to an

offsite medical facility. The individual, however, refused to be

transported offsite and continued decontamination efforts. He

successfully reduced the contamination to below acceptable limits, and

the t'nusual Event was terminated. Reports of the incident were made to

the NRC and the State of Tennessee, as required.

'll. Inspector Followup Items (92701)

Based on inspection activities in the affected functional areas the

.following items were determined to require no additional specific followup

and are closed.

328/84-21-04

328/84-31-05

328/84-31-06

327/84-11-03

327/83-23-04