IR 05000327/1992038

Insp Repts 50-327/92-38 & 50-328/92-38 on 921230-930114. Violations Noted.Major Areas Inspected:Event Which Occurred 921223-24 & Resulted in Unit 2 Refueling Water Storage Tank Solution Being Below TS Min Temp Limit

ML20128B137
Person / Time
Site:	Sequoyah
Issue date:	01/14/1993
From:	Holland W, Kellogg P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20128B128	List: IR 05000327/1992038 ML20128B124
References
50-327-92-38, 50-328-92-38, NUDOCS 9302020409
Download: ML20128B137 (10)

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Report Nos.: 50-327/92-30 and 50-328/92-38 Licensee: Tennessee Valley Authority 6N 38A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Docket Nos.: 50-327 and 50-328 License Nos.: DPR-77 and DPR-79 Facility Name: Sequoyah Units 1 and 2 Inspection Conducted: ember 30, 1992 through January 14, 1993 Lead Inspector: h // F3

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.sTdpt Inspector IT te Signed Inspectors: S. M. Shaeffer, Resident inspector Approved by: .

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[ f/ Daj/[.73 f e 51gned Fa_if histrsectimr4A Divis on-e actor Projects SUMMARY Scope:

This special resident inspection was conducted on site to review an event  !

which occurred on December 23 and 24, 1992 and resulted in the Unit 2 refueling water storage tank solution being below its technical specification minimum temperature limit for approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Areas reviewed as part <

of the inspection activities included: Procedures associated with evolutions in progress; and administrative procedures associated with conduct of testing, conduct of operations, configuration control, and issociated procedures which address procedure change processe a 9302020409 930115 PDR ADOCK 05000327 0 PDR

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i Results:

Apparent violations were identified with regard to failure to maintain the l Unit 2 Refueling Water Storage Tank solution temperature at or above 60 .

degrees F during Mode 1 operation for approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; failure to-follow the requirements of Technical Specification 6.8.1 for surveillance- i procedures and administrative instructions associated with Conduct of Testing,  !

Conduct of Operations, and Procedural Administrative Controls; and failure._to change safety-related procedures as required by TS 6.5.lA.- These apparent violations span the functional areas of Operations and Engineering / Technical ,

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in the area .of Safety Assessment / Quality Verification, a weakness was identified with regard to licensee management's failure to evaluate if the complex or infrequently performed test or evolutions )rocess should have been *

applied to testing evolutions which occurred on Decem>er 22 and 23, 1992;

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rep 0R1 DE1 AILS  : Persons Contacted Licensee Employees

• R. fenech, Site Vice President ]

• R. Beecken, Plant Manager ,

• L. Bryant, Maintenance Manager

• L. Bush, Acting Operations Manager

• M. Cooper, Site Licensing Manager

• 1. filppo, Site Quality Assurance Manager J. Gates, Technical Support Manager _

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• J. Hamilton, Quality Audit and Assessment Manager-

• C. Kent, Radio.ogical Control Manager  ;

• K. Meade, Licensing Engineer R. Rausch, Modifications Manager

• ll. Rogers, Acting Technical Support Manager

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J. Smith -Regulatory Licensing Manager

• R. Thompson, Compliance Licensing Manager ,

• p. Trudel, Nuclear Engineering Manager

• J. Walker, Operations program Manager

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J. Ward, Engincoring and Modifications Manager '

• H. Welch, Operations Superintendent

• K. Whittenberg, Public Relations NRC Employees B. Wilson, Chief, DRp Branch 4 P. Kellogg Chief, DRP Section 4A

• Attended exit intervie Other licensee employees contacted included control,' room operators, shift technical advisors, shift supervisors and other plant personne '

Acronyms and initialisms used in this report are listed in'the last paragrap : Action 1on Previous inspection findings (71707,92701,92702)'

(Closed) URI 327, 328/92-36-02, Determination of Root Cause of. Event'

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involving a failure to Maintain the Unit:2-RWST Solution Temperature Above the Minimum TS' Value- for Approximately 24 Hours.. This issue was i initially addressed in inspection report 327,328/92-36. In that report',.thezroot cause of the event was-identified to be a lack of proper planning, coordination, . and' configuration controls.during the -

corrective actions being implemented for missed ISI-. pressure testin During this inspection period, the inspectors specifically focused on>

review in the following areas:. .;

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Adequacy of procedures involved in testing evolution Testing activities being conducted concurrently on December 23 and 24, 1992, which appeared to contribute to the low RWST solution temperature j

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event on Unit 2 included 2-SI-SXI-067-001.B. INSERVICE PRESSURE TEST OF ESSENTIAL RAW COOLING WATER SYSTEM - SUPPLY HEADER 28-B, Revision 1; 2-SI-SXI-072-0Dl.B. FUNCTIONAL PRESSURE TEST OF CONTAINMENT SPitAY SYSTEM -

1 RAIN B, Revision 0: and 2-SI-SXP-072-001.B CONTAINMENT. SPRAY PUMP 20-B ,

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QUARTERLY OPERABILITY TEST, Revision 0. The inspectors reviewed the completed test procedures listtd above in-detail and made the following observation SI-SXI-067-001.B - Test was started on December-22 at 11:10 > m and was completed on December 24 at 7:30 am. The purpose of t1e test was to provide detailed steps to perform a system inservice pressure test on ERCW system supply header 28-B as required by ASME Section XI. The procedure authorized performance of_ the test in all Modes of operation. No precaution or limitations were identified with regard to system interactions. Step 4.4 [3?

required notification of Unit I and 2 R0s that the instruct'on '

places equipment in an off-normal configuration which may be noted in the Test Awareness Log. The procedure aligned normal flow of '

ERCW through Containment Spray Heat Exchanger 2 .

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2-SI-SXI-072-001.B - Test was started on December 22 at 8:30 pm and was completed on December 23 at 7:47 am. The purpose of the test was to provide detailed steps to perform a system inservice pressure test on the Unit 2 Containment Spray System Train B as required by ASME Section XI. No precautions or limitations were identified for performance of the test. Step 4.1 (2) stated

" coordinate performance of this instruction with test director of 2-SI-SXP-072-001.B." Note at_beginning of section 6.0 states that-

"this instruction relies on 2-SI-SXP-072-001.B to provide system a configuration required to pressurize the test boundary. System-

alignment, realignment and configuration control is maintained by 2-SI-SXP-072-001.B." The-conduct of testing log noted that 28-B

, Containment Spray Pump-was started on December 23 at 5:10 am. The log noted that the pump test was stopped on December 23 at 7:45 a .

- 2-SI-SXP-072-001.B - Test was-started on December 22 at 8:30 pm and was completed on December 23 at 8:57 am. The purpose of the test as stated in section 1.1 was to assess the operational- -

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readiness of Containment Spray System Pump 20-B in accordance with ~

ASME Section XI and determine operability of the CS Pump 28-B-suction and discharge check valves: however, the conduct of testing log attached to the test performance package stated "This  !

test is being performed to support 2-SI-SXI-072-001.B. It will

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not be used to satisfy any Section XI pump testing and not used j for any rescheduling purposes. It is only to provide valve .

alignments for the inservice pressure test. Steps 4.2 [1], [5), [6], [9), 6.0 [21), [22), [24), 7.0-[2), [3] will be N/A'd." ,

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Technical support engineering and operations SOS signatures approved the above test log rtatements. No precauti.ons or limitations listed in section 3.0 addressed any system interaction potential problem The inspectors also noted that a test deficiency (DN-1) was identified for ster 4.3 (2]; however, the test deficiency log was not included in the reviewed test documentation packag This log should have been provided as a j part of the package as required by SSP- J J

The in',)ectors also reviewed completed test procedures 2-SI-SXI-067- j 0013 , INSERVICE PRESSURE TEST Of ESSENTIAL RAW COOLING WATER SYSTEM - l

$* T r'LY HEADER 2A-A, Revision 1; 2-SI-SXI-072-001. A. FUNCTIONAL PRESSURE IEST Of CONTAINMENT SPRAY SYSTEM - TRAIN A. Revision 0. 2-SI-SXI-067-001.A was started on December 26 at 10:15 am and completed on December 27 at 3:49 pm. 2-St-SXI-072-001.A was started on December 23 at=5:55 pm 1 and completed on December 23 at 9:10 pm. The inspectors noted that test separation for the A train ERCW and CS systems inservice pressure testing was such that RWST solution cooldown interaction was avoide The inspectors also reviewed the completed test procedure 2-SI-SXP-072-001.A. CONTAINMENT SPRAY PUMP 2A-A QUARTERLY OPERABILITY TEST, Revision SI-SXP-072-001.A was started on December 23 at 5:55 pm and completed on December 23 at 10:30 pm. The inspectors noted that this test was being accomplished during the time period that was identified with regard to.the Unit 2 RWST solution temperature being below 60 degrees f. The inspectors determined that this procedure also included steps that were N/A'd in the same manner that wat discussed for 2-SI-SXP-072-00 Administrative Requirements for the Conduct of Testin After review of the preceding test procedures, the inspectors-reviewed Site Standard Practice SSP-8.1, CONDUCT Of TESTING, '

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Revision 4. The stated purpose of SSP-8.1, in part, was to provide guidelines to ensure responsible personnel coordinate test interactions to eliminate the possibility of overlapping test and-maintenance activities. The SSP also. addressed the use of N/A,

- Step 3.11 of the SSP authorizes the use of N/A to-be used for not performing procedural steps if an evaluation determines N/A is the acceptable method, and justification is provided in the conduct of test log for tne instruction, The SSP also requires review.and approval of the responsible test supervisor and SOS /ASOS for the justification to N/A instruction steps.- The inspectors also noted thet section 3.16 of SSP-8.1 discussed complex infrequently? >

performed tests-or evolutions ~and referenced-SSP-8,51. Complex or-infrequently performed tests or evolutions were defined, in part,.

as special, infrequ?ntly performed surveillance testing- that involves complicated sequencir) or placing the plant in unusual configuration The inspectors then reviewed Site Standard Practice SSP-8.51,- l

- COMPLEX OR INFREQUENTL'r PERFORMED TESTS OR EVOLUTIONS, RevisionL The ctated purpose of SSP 8.51, in part, was to provide guidance

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on additional procedural requirements and management involvement required for complex or infrequently performed tests or evolutions. SSP-8.51 stated that SSP-2.3 provided instructions for preparation of site procedures and the methodology for determining and designating procedures as CIPTE The inspectors then reviewed Site Standard Practice SSP-2.3, ADMINIS1 RATION Of S11E PROCEDURES, Revision The stated purpose of SSP-2.3, in part, was to establish minimum requirements for preparation, review, approval, use, and cancellation of Site Instructions. The inspectors noted that section 3 of SSP- provides the instructions for processing of changes to safety-related instructions. The inspectors review of the SSP determined that the review process implemented the requirements _of TS 6.5.lA; however, the review did not identify any allowance for changes as noted during the reviews of 2-SI-SXP-072-001.A and B which appeared to be authorized by SSP-8.1. The inspectors also noted that Appendix G to SSP-2.3 was a checklist for determination of-complex infrequently performed tests or evolutions that require additional management oversight and controls. The ins)ectors reviewed the checklist and considered the guidance to_Je confusing. The inspectors were informed that the licensee had'

concluded that implementation of the CIPTE process was not required for the ASME Section XI ISI testing being conducted.on December 22 and 23, 1992. This was based, in part, on the licensee's determination that system pressure test insper,tions did not meet the criteria for implementation of the CIPTE proces he inspectors also reviewed Site Standard Practice SSP-1 CONDUCT OF OPERATIONS, Revision The stated purpose of SSP-12.1, in part,-was to provide requirements, guidelines, and-instructions for the conduct of operations to ensure shift-operations are conducted in en effective, consistent manner in-accordance with the operating license, plant arocedures, and applicable regulatory requirements at Sequoyat Nuclear Plan Section 3.8 of SSP-12.1 addresses requirements for-control ofc equipment and system status and requires that operators maintain cognizance of operational status of_ equipment and systems.-

Section 3.9 of-SSP-12.1 addresses operator. logkeeping requirements. This section requires logging of major evolutions commenced and completed including changing of plant conditions and operation of equipment. Section 3.10 of SSP-12.1 addresses shift turnover and includes checklists for operators which: includes, in part, surveillances, tests, or evolutions in progress or planned t:

and abnormal lineups or conditions. The inspectors noted that 3 shift turnovers-occurred-between the time that the'CS Pump'28-B was started (December 23 at approximately Sil0 Lam) and the tim that operators noticed the RWST solution temperature was below TS-limits (December 24 at approximately 3:00 am)~.

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The inspectors reviewed Site Standard Practice SSP-12.2, SYSTEM AND EQUIPMENT STATUS CONTROL, Revision 1.- The stated purpose of

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SSP-12.2, in part, was to es'ablish the responsibilities and programmatic methods for obtaining, maintaining, and documenting  !

control of equipment and system configuration status in accordance '

with design, regulatory, and corporate requirements. Section 6 of

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SSP-12.2 addressed a method of test awareness control. The procedure required the OCC ASOS to maintain a " Strong" communication link in order to keep the Unit R0s and SR0s cognizant of testing in progress. The inspectors reviewed the  !

Operations Group Test Awareness Log Sheets For the-period of December 22 and 23, 1992. They noted that testing for Unit 2 Train A CS was being accomplished between December 23 at 8:50 pm .

and December 24 at 6:30 am. The inspectors reviewed Unit 2 operator logs for December 23 and 24,1992 and determined that several evolutions associated with the Unit 2 RWST were accomplished in addition to the testing evolution involving '

operation of the 20-8 CS pump. These evolutions included recirculation of the RWST solution from 10:30-am to 2:12 pm on December 23 per S01-78.1, Revision 41, blending to the Unit 2 RWST-from 2:48 pm to 3:30 pm per S01 62.2, Revision 39,Section V Operation of 2A-A CS Pump in full flow recirculation to the Unit 2 RWST from 5:50 pm to 10:30 pm. During these e nlutions, the inspectors concluded that operators did not monitor RWST temperature indication as a parameter that could have been affecte Conclusions Based on these reviews, the inspectors concluded the following:

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Surveillance instruction 2-SI-SXI-067-001.B ap) eared to be adequate-to accomplish the stated purpose of t1e procedur Surveillance instruction 2-SI-SXI-072-001.B appeared to be adequate to accomplish the stated purpose of the procedure; however, the procedure required a supporting procedure to pressurize the test boundary for inspectio Surveillance instructions 2-SI-SXP-072-001.A and 2-SI-SXP-072-001.8 were not adequate with-regard to the manner in-which they were used. These procedures contained several steps which were N/A'd in accordance with SSP-8.1; however,:

no procedure change was-processed to address the new purpose of the procedur <

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Site Standard Practice SSP-8.1 was inadequate in that the ,

procedure authorized a process for the N/Aing.of steps .'

without following the. requirements to make changes to '

safety-related procedures as outlined in SSP-2.3. The inspectors concluded-that the N/A process outlined in SSP-8.1 was'not as required by TS 6.5.l h in -

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Site Standard Practis @ 't.1 was not followed in that operators did not maintas,. .ontrol of equipment and system status, and cognizance of operational status of equipment and system In addition, operator shift turnover, 1 including required checklists for surveillances,' tests, or  ;

cvolutions in progress or planned, and abnormal lineups or conditions did not identify the abnormal Unit 2 RWST ,

solution temperature condition during 3 shift turnovers-that- ,

occurred between the time that the CS Pump 28-0 was-started .

(December 23 at approximately 5:10 am) and the time that operators noticed the RWST solution temperature was below TS limits (December 24 at approximately_3:00.am). a

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Site Standard Practice SSP-2.3 was-not followed in that'

changes to two safety-related procedures were made without following the process described in the procedur Site Standard Practices SSP-8.1, SSP-8,51, and SSP-2.3 all describe, in part, a process to allow for additional management oversight and control for complex or-infrequently-

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performed tests or evolutions. The CIPTE process was .

determined by the licensee to'be not applicable to the testing evolutieas which were_being accomplished on December ,

22 and 23, 1993. -Therefore additional management controls-for these evolutions were not in place. The inspectors concluded that all the ASME Section XI pressure testing evolutions, when taken as one activity, were specia infrequently performed surveillance tests that involvs '

complicated sequencing.or placirg the plant in unusual

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configurations, l.icensee management's failure to evaluate if the CIPTE process should _have been applied to this activity was considered as a weaknes Regulatory issues

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Technical Specification LC0 3.5.5. requires, in part, that.the

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refueling water storage tank shall be operable with a minimum solution temperature of_60 degrees f. Failure to maintain the Unit 2 RWST solution temperature at or above 60 degrees F during Mode 1 operation for approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is identified as an apparent violation (327, 328/92-38-01).-

Technical Specification 6,8,1 requires, in part; that_ written

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procedures be established,_ implemented, and maintained, lhi includes procedures for control and operation of' safety-related systems. -Contrary to this requirement,Ethe following procedures- '

were eithec ' inadequate to accomplish the task, or were not'

followed:

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Surveillance instruction < 2-SI-SXP-072-001.A and 2-SI-SXP- -"

072-001.0 were not adequate with regard to the manner-in which they were use ,

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Site Standard Practice SSP-8.1 was inadequate in that.the procedure authorized a process for. making changes to safety-related procedures which was contrary to SSP-2.3 and TS 6.5.l Site Standard Practice SSP-12.1 was not followed in that-operators did not maintain control of equipn9nt and system status, and cognizance of operational status of equipment and systems with regard to Unit 2 RWST solution temperature requirement Site Standard Practice SSP-2,3 was not followed in that_ _

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changes to surveillance instructions 2-SI-SXP-072-001.A;and 2-SI-SXP-072-001.B were made without following the process-described in the procedur Failure to follow the requirements of TS 6.8.1 for the procedures and/or administrative instructions listed above is identified as an apparent violation (327, 328/92-38-02) '

Technical Specification 6.5 lA requires, 'in part, tha+ procedures required by Specification 6.8.1, and changes .thereto, shall be reviewed c by a qualified individual other than the individual vdu) prepared the procedure or change; approved by the appropriate responsible manager -

designated in writing by the plant manager; reviewed to determine whether or not-adaltional, cross-disciplinary review isLnecessary; and reviewed to determine whether or not an unreviewed safety question is involved pursuant to110 CFR 50.59. Contrary to this requiremen surveillance ' instructions 2-SI-SXP-072-001.A and 2-SI-SXP-072-001.8 were changed prior to their performances on December:22 and 23, 1992.withoutL review as' required by TS 6.5.lA. Failure.to change safety-relatedi procedures as-required by TS 6.5.lA is identified as an apparent ~

violation (327,-328/92-38-03). '

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The inspectors held several' discussions with licensee. personnel and management-curing.the inspection period. -The licensee had established .

an incident investigation team after the event and was in the process o conducting-an incident investigation when the-inspection period ende The inspectors did not review any of.the incident-investigation team

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findings prior to-the report period endin Within the areas inspected, three apparent violations were identifie . Enit Interview The inspection stape and results were summarized ca January 14, 1993 with those-individuals identified by an asterisk in1 paragraph--I abov '

The inspectors described 'the areas inspected and discussed in detail .the ,

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inspection findings listed below.- Proprietary material Was not1 reviewed ' .:

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durir,g the inspection period. Dissenting _ comments were not-received:

from the' license .

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8- 4 Item Number Qtscription and Reference V!0.327, 328/92-38-01 Failure to maintain the Unit 2- .

Refueling Water Storage-Tank:

soluti_o_n temperature.at or above 60 degrees F during MODE.1 operation--

for appr_oximately-24 hours-(paragraph _2),

VIO 327, 328/92-38-02 Failure to follow the requirements: '

of Technical Specification 6.8.1-fore

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surveillance procedures and administrative instructions associated with Conduct _of Testing, Conduct of Operations, and'

Procedural. Administrative Controls-L(paragraph 2).

VIO 327, 328/92-38-03 -failure to change.-safety-related procedures as required'by TS 6.5;1 <

(paragraph 2). List of Acronyms and .Initialisms s ASME - American Society of. Mechanical-Eng'ineers ASOS -

Assistant Shift Operations Supervisor CFR -

Code of: Federal Regulations CIPTE - Complex orLinfrequently: Performed Tests or Evolutions CR -

Control Room CS -

Containment Spray DN -

Deficiency Number-DRP - Division of-Reactor. Projects i ERCW - Essential Raw Cooling Water ISI -

Inservice-Inspectio ..

LC Limiting-Condition for Operation N/A -

Not Applicable (

NRC -

.. Nuclear; Regulatory Commissio_n OCC -

Operations. Control Center'

R _ReactorfOperator RWS1 -

Refueling < Water Storage Tank:

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. Surveillance Instruction 501 - -System Operating Instruction SOS -

Shift _ Operating Supervisor-SRO -

-Senior Reactor Operator SSP- -

Site Standard Practice TS -

Technical Specifications-

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-Tennessee Valley Authority URI -

Unresolved item

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