IR 05000327/1986020
| ML20205P421 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 04/18/1986 |
| From: | Brooks C, Carroll R, Garner L, Holland W, Holmesray P, Mcneil S, Linda Watson, Weise S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20205P381 | List: |
| References | |
| 50-327-86-20, 50-328-86-20, NUDOCS 8605210408 | |
| Download: ML20205P421 (28) | |
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S Of Gg UNITED STATES
- Do f NUCLEAR REGULATORY COMMISSION
d' *\ s ./* REGION 18
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I bI 101 MARIETTA STREET. E ATL ANTA, GEORGI A 30323 s, v )
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Report Nos.- 50-327/86-20, 50-328/86-20 Licensee: Tennessee Velley Authority 6N38 A Lookout Place 1101 Market Street Chattanooga, TN 37401 Docket No and 50-328 License Nos.: DPR-77 and DPR-79 Facility Name: Sequoyah Units 1 and 2 Insp'ction Conducted: March 3 - 14, 1986 Inspectors: [/[a-__ _ % j[/kDate Signed
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P .~ HoliiFe s nay , inspecti .Te[ Leader 2f2 R. E. C ii, Jr., P ect Engineer WM/06 Date Signed YY$- : _Y$ ll$Fkh j(late Signed W. E. Hollan'd, deside/ In ector
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?f*/ L _ 4 A 2.< '#Ar M Date Signed L. Earner, Resi Mnt A pector
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>rs' QRntfnspector L. tson, esi
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$_ AA pe g io'ns Engineer YhYN Date Si ned Approved by: ~/ _
S. P. Weise, Section Chief h
Date Signed Division of Reactor Projects SUMMARY Scope: This special, announced inspection involved 354 inspector-hours onsite in the area of operational readiness verification, including: selected areas of the Sequoyah Nuclear Performance Plan, Volume II; licensee's action on open items from the Operational Readiness Inspection of December 1985 which were documented in Inspection Report 327,328/85-46; and testing associated with Environmental Qualification (EQ) modifications.
Results: In the areas inspected, three violations were identified:
8605210408 860423 PDR ADOCK 05000327 G PDR
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1. Failure to establish and implement a procedure for the 18 month manual engineered safety feature (ESF) functienal input check of the reactor trip syste (Paragraph 10)
2. Failure to verify the positions of containment isolation valves. (Paragraph 13)
3. Improper procedural implementation of Technical Specification (TS)
requirements for the Plant Operations Review Committee, resulting in quorum ,
recuirements not being met. (Paragraph 16)
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REPORT DETAILS Licensee Employees Contacted
"P. R. Wallace, Plant Manager
- L. M. Nobles, Operations anc Engineering Superintendent
- B. M. Patterson, Maintenance Superintendent
"J. M. Anthony, Operations Group Supervisor
- R. W. Olson, Modifications Branch Manager
- R. Sediacik, Electrical Section Manager, Modifications Branch M. R. Harding, Engineering Group Manager i
- D. C. Craven, Quality Assurance Supervisor
- C- B. Kirk, Compliance Supervisor
- H. R. Rogers. Compliance Engineer
- *E. W. Whitaker, Licensina Engineer M. L. Frye, Compliance Engineer
> 0. H. Tullis, Mechanical Maintenance Group Supervisor J. H. Sullivan, Regulatory Engineering Supervisor
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- H. Mackay, Reactor Engineering Supervisor
- W. Allen, Reactor Engineer
- H. O'Donnell, Staff Engineer
- E. Denny, QA Engineer
- B. Rankin, Design Services Manager
- D. Alexander, Mechanical Modifications Supervisor I * A. McPherson, Engineering and Test Unit Supervisor l * A. Cooper, Mechanical Engineer
- Word, Mechanical Engineer
- D. L. Widner, Modification Engineer
- R. M. Mooney, Systems Engineering Supervisor
- E. Andrews, Site Quality Manager
- K. Mogg, Office of Engineering (DE), Civil Engineering Supervisor
- T. K. Rochelle, OE, Civil Engineering Supervisor Other licensee employees contacted included technicians, operators, shift engineers, security force members, engineers and maintenance personne Accompanying NRC Personnel:
- S. P. Weise, Section Chief, Division of Reactor Projects
- K. M. Jenison, Senior Resident Inspector, Sequoyah
- Attended exit interview Exit Interview The inspection scope and findings were summarized with the Plant Manager and members of his staff on March 14, 198 Violations described in Paragraphs 10, 13 and 16 were discussed. -The licensee acknowledged the inspection findings. The licensee did not identify as proprietary any of
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the material reviewed by the inspectors during this inspection. .At no time during the inspection was written material provided to the licensee by the inspector . Licensee Actior, on Previous Enforcement Issues (92702) C (0 pen) Unresolved Item 327, 328/85-46-07; Review of additional information to determine acceptability of Post Modification Test (PMT)
53 for Auxiliary Feedwater (AFW) System Cavitating Venturis modification. The issue was originally addressed in inspection report 327, 328/85-46. The report found that the adequacy of the modification was questionable since the purpose of the venturi is to protect the AFW pump from runout damage up to a maximum of 650 GPM flow. Test deficiency DN-3 identified that the vibration exceeded the acceptance criteria in the Y-axis where displacement was 250 mils zero to peak versus acceptable displacement of 219 mil The inspector was furnished additional information with regard to' l disposition of DN- The information included:
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A memo from R. M. Mooney (Systems Engineering Section Supervisor)
to H. Kincaid (Civil Engineer, CEB, OE) dated December 16, 1985, relating to the AFW piping vibration and cavitating ventur ; This memo addressed concerns with regard to the DN-3 disposition
by Mr. Kincaid and requested additional informatio ;
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Comments concerning the branch sample line downstream of the cavitating venturi on AFW pump 2B-B by R. M. Mooney dated February 4, 1986. These comments addressed the possibility of a failure to the non-safety-related portion of this line (which is normally isolated from the safety-related portion of the system) due to resonance during cavitatio The comments stated that th Long-Term Vibration Program would address this conditio Clarification of displacement readings by R. M. Mooney dated February 6, 1986, including calculations and special graphs of vibration data for the discharge piping of AFW Pump 28-B on November 23, 1984. This information concluded that the process i piping is acceptable even under worst case cavitation, but cavitation modes should be avoided for normal operatio Memo from S. S. Long (System Engineer) to R. M. Mooney dated
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February 7,1986. This memo addresad the point at which venturi-cavitation would occur (500 to 625 GPM) and indicated action was needed to add cautions to applicable procedures to minimize operation in this rang Memo from J. H. Kincaid to R. M. Mooney dated February 6,198 This memo stated that disposition of DN-3-dated November 23, 1985, was still technically correct and provided additional information to substantiate this position.
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The inspector reviewed the additional information and conducted an inspection of the installed modification. The inspector found that the first structural support for the sample branch line was welded to the AFW piping and connected to smaller diameter sample tubing. This
, connection point appeared marginal and an engineering evaluation to evaluate this connection was requeste The inspector also requested i
to see the OE concurrence on the disposition of deficiency DN- The licensee stated that the test package had not been provided to OE for review and approval at the time of the inspection; however, this would
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be accomplished when the package was complete. Based on the information provided and discussions with the licensee, the inspector determined that additional actions would be required in order to fully i address this item. These additional actions are:
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Licensee establishment and implementation of the Long-Term
}j Vibration Program for this modification to monitor for any degradation of safety-related component Revision of applicable procedures to ensure that operation in the cavitation range for these components will be minimize OE review / approval of PMT-53 (which includes DN-3 for AFW pump venturi 2B-B) and review of the engineering evaluation for the sample line support te AFW pipin This item will remain unresolved pending receipt of further licensee informatio (Closed) Unresolved Item 327,328/85-46-09; Review of Licensee's Program ,
for Temporary Alteration Contro This item was identified in ,
inspection report 327, 328/85-46. The report stated that revision 19 to AI-9 (Control of Temporary Alterations and Use of. the Temporary Alterations Order) requires that retesting requirements be identified -t on the temporary alteration control form, but the inspector was unable to determine if long term temporary modification requirements are covered by this requiremen The inspectors reviewed AI-9, Revision 20. This procedure requires that ... " applicable required tests demonstrating return to normal, shall be clearly stated on, or attached to, the control form" (Temporary Alteration Control Form (TACF)). The inspectors then held discussions with senior management and learned that temporary alterations were a high priority with regard to reducing the number in the plant. The inspectors reviewed status reports which indicated that -
temporary alterations have been reduced from over 800 in 1982 to 154 as of March 3, 198 Recent trending indicated that this reduction was
, continuing and that very few new temporary alterations were being '
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The inspectors conducted a review of the active temporary alterations by reviewing the temporary alteration control logs which are maintained in the control roo The inspectors selected 20 active temporary alterations and r'eviewed the TACFs for compliance with Al-9. The TACFs reviewed were:
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85-2015, Agastat replacement on containment air return fans 2A-A and 2B- , Cable routing change for cable 2PM448 , Install mot e r on Reactor Building lower compartment cooler fan 2A- , Install non QA heat trac , Disable auto trip for "C" backup pressurizer heater , Disable hotwell pump trip during S , Disable auto trip for "C" backup pressurizer heater S3-2001, ERCW strainer backwash modificatio Install temporary clamp to fire protection hoo , Install TC f rom J-box to outside of C-zone for charging pump , Change linkage for 2-FCV-74-1 , Change linkage for 2-FCV-74-2 , Remove check valve internals from valve 0-77-68 , Remove hand indicating controllers and replace with level indicating controller , Install jumper around 2-PCV-63-5 , Install non QA bonnet on 2-FCV-62-17 , Move cables 2PM910 and 2PM91 , Replace agastat on containment air return fans 1A-A and IB- , Modify low speed shaft on centrifugal charging pump 2A-A speed increase , Install non QA heat trac .. . - .
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1 During the review of the preceding TACFs, the following items were identified:
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Control room flow diagram for system 77 was not marked to identify installation of temporary alteration 81-2479, nor was a TACF tag installed on the main point of control. Preparations were underway, however, to remove this temporary alteration in the near future; and since additional examples were not found, this was considered an isolated cas Required tests were not identified on TACF or attached to TACF for temporary alterations 85-0091, 86-2001, and 86-2002 which were established after Revision 19 to AI-9. The inspectors noted that most of the TACFs reviewed prior to implementation of Revision 19 to AI-9 did not address testing requirements. Consequently, the i inspectors held discussions with two STAS who were conducting a i review of all outstanding TACFs to determine if Unresolved Safety
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Question Determinations (USQDs) were adequate and if testing had
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been conducted to assure that the temporary alteration had not ,
I affected operability of the component oi systen. Except for three
! temporary alterations which were still under review, their f
preliminary findings indicated that adequate testing had been conducte The AI-9 testing requirements for those temporary changes which are considered significant cnanges, did not appear explicit enough to provide the necessary instructions / guidance for quality implementation, since the upper tier document requiranent was incorporated without additional clarification. Additionally, the inspectors identified that the plant QA staff was the responsible section for establishing AI-9, even though it is implemented by plant line personne [
Based on the discrepancies identified by the inspectors and the questionable practice of making the QA staff responsible for a line procedure, a meeting was held with operations plant management. The inspectors presented their findings and stated that they considered ,
that a programmatic review of the. temporary alterations program was needed to assure that plant personnel understood all requirements and had a workable program in place. The plant manager committed to conduct a review of the program and implement changes as necessary to improve this program. The followup and, review of this commitment shall be identified as an Inspector Followup Item (327, 328/86-20-01), (Closed) Violation 321,328/84-38-0 See paragraph . Unresolved Items Unresolved Items are matters about which more information is required to determine wnether they are acceptable or may involve violations ~ or 1 deviations. One resolved item was identified in paragraph 1 i
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6 Review of Preoperational Tests The inspector reviewed preoperational test W-8,5 concerning verification of the plant setpoints against the Precautions, Limitations and Setpoints (PLS)
document. The licensee had determined that a deficiency . identified in the preoperational test had not be'en resolved prior to startup. The licensee reviewed the deficiency and acquired vendor and OE approval of the disposition in January, 198 The deficiency involved the alarm setpoint for "High Flux at Shutdown." The licensee had conservatively set the alarm at one-half decade startup rate in accordance with an FSAR commitment. The PLS document required a setpoint of a factor of five above the countrate at shutdown. The one-half decade setpoint was approved. The licensee issued a discrepancy report on the failure to have proper concurrences on disposition of preoperational test deficiencies prior to startu Additional preoperational te'tss are under review by the NRC due to similar findings by the licensee on other preoperational test '
During the review, the inspector identified one setpoint on the auto reset of manual block on high pressurizer pressure which had not met the acceptance criteria but had been signed as acceptabl The licensee provided calibration cards which indicated that the instrument had been recalibrated to the proper setpoint prior to startu The licensee is reviewing preoperational test W-8.5 in detail to assure that the appropriate
.i revision of the PLS document was met at startup.
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In the areas inspected, no violations or deviations were identifie . Followup on Inspector Identified Items (92701) (0 pen) Inspector Folicwup Item 327, 328/85-46-08; Verification of licensee commitment to INDO to clear all temporary alterations made prior to January 1,198 The inspectors reviewed the status report for temporary alterations dated March 3,1986, and determined that 82 temporary alterations remained active in the plant which were initiated prior to 198 This item will remain open until all temporary alterations implemented prior to 1984 are cleare (0 pen) Inspector Followup Item 327,328/85-46-06; Control Room Emergency Ventilation (CREV) Automatic Actuation Feature, was opened to require inspection to determine if testing is performed to verify the automatic functions of CREV upon receiving signals from high chlorine, high temperature or smoke detector The sensors for high chlorine, high temperature and smoke are functionally tested but the CREV automatic 1' actuation from these sensors is not. No regulatory requirement was found to perform such tests. The Watts Bar final draft Technical 3 Specifications does require all automatic functions of CREV .to be tested. This item will remain open pending further discussion with the '
licensee as to its dispositio .
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t Verification of Nuclear Performance Plan, Volume II l Post Modification Task Force Following the identification of two instances of inadequate system
modification testing in violation 327,328/84-38-01, the licensee ,
established a task force to review their modification testing i activities. This included Post Modification Tests (PMTs), Functional Tests (FTs), and applicable Preoperational (PRE 0P) Tests. The initial four man task force consisted of engineers from the Quality Assurance Staff, Systems / Post Modification Test Group and the Division of Nuclear J Services. This initial group was subsequently expanded to include four i additional engineers when concerns were raised over the possible existence of temporary alteration test deficiencies; particularly when
temporary alterations are made permanent- through the use of
! " Documentation Only" engineering change notices (ECNs).
The Task Force reviewed modifications that were performed through the
period of 1979 to 1985, and made a determination of testing adequacy
using engineering judgement / experience, Topical Report TVA-TRA-TR75-1,
Part IV of SQN AI-19; and the Nuclear Quality Assurance Manual (NQAM).
- The results of the task force review was documented in their report of j May 1, 19b5, and is summarized as follows
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Concerns No. With Number Resulting In PR0s Type of
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Number Adequate with PRO * being Found Modification Surveyed Test Concerns Written Reportable Initial Review:
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- PMT Required 4 4 0 0 0
- PRE 0P or NO PMT/FT Required 9 N/A N/A N/A N/A
- FT Required 12 9 3 0 0 Expanded Review:
- FT Required 51 46 5 2 0
- FT Not Required 20 N/A N/A N/A N/A
- FT Not CSSC 2 N/A N/A N/A N/A
- TACF-FT Required 11 11 0 0 0 l - TACF-FT Not Required 15 N/A N/A N/A N/A 124 70 8 2 0
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"Potentially Reportable Occurrence
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Additional functional testing was performed in order to resolve four of the eight concerns identified. Out of the remaining concerns, three were resolved when additional information was obtained. The last concern deals with modifying the Unit 1 B Train Feedwater Regulstion Valves in order to increase their associated stroke times. . This item is scheduled for completion by April 18, 1986, and is being tracked by
licensee corrective action tracking _ system (CATS) item 8520 The Task Force identified other discrepancies and concerns in the form of recommendations. The licensee's May 31, 1985 response to violation 327,328/84-38-01 identified four of these recommendations that were to be acted on in order to strengthen the Sequoyah Testing Program. These four recommendations and their final disposition are addressed below:
(1) TACFs - Revise the NQAM and Plant Instructions to address testing of temporary alterations, including those which later become permanent modifications (ie., an ECN issued as " Documentation Change Only' and does not require a PMT/FT).
The NQAM was revised accordingly to read, " Temporary alterations which are considered significant changes as. determined by PORC and/ or become permanent modifications by the submission of a DCR shall be tested: (a) to assure - system integrity; and (b) to provide for evaluating the performance of the alteration before system operation".
Administrative Instruction AI-9 was. revised in the same manne Since AI-9 is the lower tier document that provides the instruction for temporary alteration control, the licensee has agreed to evaluate the need for more _ explicit instructions / guidance at the working level. This item will bc tracked under the inspector followup item addressed in paragraph 3-of this repor (2) FT Instructions - Specify in AI-19 that FT instructions contain as a minimum, the test scope, precautions, and acceptance criteri AI-19'was revised to require FT instructions to contain: test scope; prerequisites; precautions; acceptance criteria; test equipment data; provisions for recording details of the test; and verification sign offs. Stated requirements' appear to be adhered ~
t (3) USQD Special Requirements - Include any USQD special requirements concerning testing in PMT scoping documents, and review USQDs to ensure that any special requirements are included in .the test instructions.
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A memorandum was dispatched to OE requesting the discontinuance of placing special test requirements in USQDs prepared by Desig AI-19, Part IV was revised to include a precaution for the work plan preparer to review USQDs for any special test requirement (4) Test Deficiencies - Revise AI-19 to include requirements for identifying and correcting test deficiencies during PMT/FT performance.
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AI-19, Part IV was revised to include complete and specific guidelines as to the documentation and disposition of test deficiencie (Closed) Violation 327,328/84-38-01; Failure to Conduct Post Modification Tests. The June 27, 1985 NRC acknowledgement letter confirmed that the above recommendations were corrective action commitments. Implementation of these corrective action commitments has been determined to be satisfactory; therefore, this item is considered close Systems Engineering Section Section 2.4.6 of the Nuclear Performance Plan (NPP), Vol. II, describes
, the Systems Engineering Section (SES). The core of this group was drawn from the preoperational test group which subsequently became the post-modification test group after plant startup. Although this group was re-named SES in February 1985, the procedure which defines the SES responsibilities was approved in January 198 Sequoyah Nuclear Plant Standard Practice SQA 168, Systems Engineering, defines the purpose, scope and responsibilities of the SE This instruction describes the System Engineer as the System technical expert who reviews and prioritizes modifications requests, modification workplans, and post-maintenance testing. He also provides technical input for safety evaluations and reportable events. He performs as a '
task leader in directing investigations and tests to resolve system related problems, improve system reliability and efficiency, and troubleshooting efforts. He additionally performs as a test director controlling special tests, pre- and post-modification tests and other
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nonroutine performance tests. In order to perform all these tasks ~, the System Engineer must maintain cognizance of his assigned systems '
through periodic walkdowns, surveillance observations, maintenance 4 reports and corrective action reports. In addition to SQA168, licensee personnel stated that section guidelines were under development to specifically define training, qualifications and procedures to be used by the SE The SES currently consists of ten dedicated systems engineers who are i assigned up to eight systems. The SES is supplemented by about 22 additional engineers from Electrical Maintenance, - Instrument Maintenance, Mechanical Test, Reactor Engineering, Chemical Unit, and
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l Site Services who perform SES responsibilities as a collateral dut Some engineers have completed the formal systems training conducted at the Power Operetion Training Center and technical training has been completed in the area of piping vibration. Training has been or will be scheduled for Post-Modification Testing, Special Test Methods and Instrumentation Piping Wall Loss, and Water Hammer. Guidelines are under development for Walkdown Procedures and Systems Notebook Development and Maintenance. The Systems Notebook is a major effort by.
4 the licensee to define system boundaries, design criteria, maintenance and problem history and lend consistency to the SES program throughout personnel changes. Additionally, facilities are being installed which will permit access to work requests for component failure trendin The SES is in its early stages. Plant-wide training (currently planned to be performed after plant start-up) is necessary to assure that the engineers are provided with the required information and j pre-implementation reviews to assist them in performing their dutie For example, SQA-168 contains an Investigation Report form which is used by plant personnel to request an investigation of abnormal system performance, repeated failures or a total loss of the syste No Investigation Reports have yet been received by the SES and none are expected prior to the plant-wide training. The inspector noted that the Volume II statement that "PMTs will be a major activity for the systems engineer" had a limited impact. PMT has a specific definition at SQN and is limited to major or complicated tests which are outlined by design engineers in the Retest Scoping Document. The majority of modifications at SQN are completed without issuance of a Retest Scoping Documen In this case, a post-modification functional test is controlled by the Modifications Engineer without involvement of the System Engineer unless requested. Interviews with .some modifications engineers indicated a lack of knowledge of SES and its functio SES personnel appeared dedicated to the concept and highly motivate The SES was found to be as described in the Nuclear Performance Plan; however, as noted in the plan, full implementation will be an ongoing effor c. Engineering Change Notice (ECN) Backlog A review was performed of the licensee's task force efforts to close out the backlog of completed ECNs to which the licensee committed in the NPP, section 4.11. The inspector found that though the task force was established in August, 1985 to close out all backlogged ECNs, it was redirected in October 1985, to review only the safety or safety related aspects of the ECNs completed by September 20, 1985, and'
adjudged to be Quality Assurance (QA) applicable.by the TVA Office of i Engineering scoping document for the modification. No separate review '
of the safety significance of each ECN was performed by the task forc ;
Of the 785 modifications that were complete but required closure in l
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September 1985, 287 were considered to be QA applicable and had their j safety aspects closed out. By February 1986, an additional 119 ECNs l
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were completed that required closur These ECNs have not been reviewed for their QA applicability nor have their safety significant aspects been closed out. Only 18 ECNs have been entirely closed since September 1985. This has resulted in a net backlog increase of 101 ECN ECN closures are not currently scheduled to recommence until after unit startups are complet d. Reduction in Outage Workloads Section 4.11.1(b) of the NPP stated that in July 1984, there were 1069 open modification workplans. Licensee management concluded that this number was too large and took action to decrease the number. This action resulted in a 30 percent reduction in the number of open workplans by October 1985. In reviewing this reduction in ope, workplans, the inspector found that the majority of the reductions were achieved through either closing workplans that had remained open due to outstanding deficiencies, or due to consolidating workplans that were redundant. Additionally, some workplans were cancelled-to complete the 30% reduction. The workplans that were cancelled lacked safety significanc e. Management Control Quality Assurance The inspector reviewed the following licensee commitments as stated in Nuclear Performance Plan Section 3.2.3 on upgrading procedures to
- assure effective management control of plant activities
(1) The licensee stated in NPP section 3.2.3.(a) th t tiering of procedures would be reduced by decentralizing central office j manuals and procedure The inspector reviewed the licensee's 1 actions to eliminate redundant upper tier procedures, i
In the past, the licensee had nineteen Area Plan Program manuals of corporate . level procedures, each consisting of one to four volume These procedures were categorized as -either licensee pulicies (not regulatory), requirements (regulatory requirements or commitments), or standards (guidance or recommendations). The procedures were implemented by each nuclear plant by issuing site procedure The licensee established a program in May 1985, to review the Area Plan Program manual procedures to determine if the procedures required revision, reassignment to another category, or cancellation. The objective was to eliminate duplication between the upper tier documents and site procedures. Approximately 124 <
upper tier procedures have been cancelled to dat Area Plan
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Program manuals in resource management, radiation protection, l emergency preparedness, preliminary operations, field services and l
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core management have been cancelled. The environmental protection
- program manual will be cancelled in the futur The licensee
! stated that the review of _ the corporate level procedures was approximately 15*; complet I The cancelled procedures have been sent to the site for verification that policies, requirements, and standards are implemented by site procedure The licensee is utilizing an existing administrative control procedure to track the cancelled procedures through the site review proces This procedure assigns each procedure a tracking number and requires that target completion dates be established. The latest target completion date for the onsite procedure review is June, 198 QA verification of appropriate site procedure revisions is required for all cancelled documents involving requirements or policie The licensee stated that as of January 1986, the review of the upper tier procedures has been stopped and future actions with regard to revising or cancelling upper tier procedures was under review by corporate managemen These future actions will I consider the workload on plant personnel who are reviewing and processing the site procedures affected by the revisions ~ and cancellation (2) The licensee stated in NPP section 3.2.3.(c) that an experienced
, SRO would be assigned to review and update operating procedure In addition, the licensee stated that this individual would review
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modification work plans to assure that appropriate operating procedures were revised and training requirements identified upon completion of the modificatio The inspector discussed the review processes with the assigned SRO and reviewed Administrative Instruction AI-19, Part IV, Plant i Modifications After Licensing. The licensee stated that this procedure was under revision to provide better guidance on the
, review of work plans for procedure revisions. Although the
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program has not been set up as stated in the NPP, the functions discussed are performed by SR0s in different section (3) The licensee stated in NPP section 3.2.3.(d) that the upgrade and reformat of emergency operating procedures (E0Ps) (non-RVLIS) had been completed in August 1985. These revisions were made to meet NUREG-0737 requirements. In addition, the licensee stated that training on the revised procedures was completed prior to implementatio ,
The inspector reviewed the licensee's responses to Supplement 1 to 1
! REG-0737 (Generic Letter 82-33) dated October 31, 1983, sugust 21, 1985 and January 13, 1986. These letters provided the schedule for implementation of the E0Ps, the Procedures Generation
- Package (PGP), the Writer's Guide and responses to NRC questions.
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The inspector verified that the E0Ps had been implemented in two phases. The first set was implemented on October 4, 1984, and the second set was implemented on August 21, 1985. The licensee's responses provided in their January 13, 1986 letter are currently under review by the NR The inspector reviewed the PGP and verified: that a Step Deviation Log _had been maintained to document deviations from the .
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generic vendor guidelines; that a verification and validation program was established and had been conducted during the review process; and that discrepancies had been identified and resolve In Part IV.D.4 of the PGP, the licensee stated that a plant / control room walk-through would be conducted to assure that
- the procedures were compatible with plant / control room hardwar The inspector determined that although the licensee had conducted the control room walk-through, documentation of a plant walkthrough was not available. The licensee stated that additional information would be provide This is identified as Inspector Followup Item (327,328/86-20-02).
Part C.12 of the Writer's Guide states that procedures will be structured such that the E0Ps can be implemented by the minimum shift staffing required by the plant's Technical Specification The licensee stated that only licensed operators had been considered in this revie The . inspector identified a concern that at least minimum staffing of Auxiliary Unit Operators should have been considered and that the licensee should also examire staffing in any other support areas. The inspector discussed this concern with the licensee and determined that the Radiological Emergency Plan has provisiuns to assure adequate staffing in a time frame consistent with the implementation of emergency actions.
The inspector reviewed the initial training as described in the January 13, 1986 response. The inspector verified that the licensee completed simulator training in accordance with Part 0, Table 1 of the response. In addition, the inspector verified that the licensee conducted classrcum training for all E0Ps prior to implementation. The inspector reviewed selected training records
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and determined that written examinations and simulator evaluations had been conducted on the E0Ps. No violations or deviations were identified in the training area.
I During the review of the licensee's August 21, 1985 response,-the inspector determined that statements appear to imply that the titles and contents of the Sequoyah E0Ps are the same as the vendor guidelines. The inspector discussed the statements with the licensee and determined that certain-of the vendor guidelines a
had been ' combined and/or renumbered such that the correlation
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between the E0Ps and the vendor guidelines were not comparable on l
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14 the basis of titl The licensee is reviewing this submittal to assure that sufficient information is provided tc clarify the differences between the vendor guidelines and the Sequoyah E0P In the areas inspected, no violations or deviations were identifie . Taylor to White Letter of 2/11/86 A follow-up inspection was performed on material descrepancies identified during an equipment qualification inspection conducted by the Office of Inspection and Enforcement (I&E) on January 6-17, 1986. These descrepancies were identified in section of the enclosure to a letter from James M. Taylor (NRC) to Steven A. White (TVA) dated February 11, 198 Maintenance Requests have been generated to correct items 2, 3, 4, 5, 9, 11, and 12. Item number 6 was corrected by fully closing valve 2-63-598. The pipe support question identified in item number 7 is under evaluatio The housekeeping concern identified in item number 1 will be reviewed during future inspection In the areas inspected, no violations or deviations were identifie . PMTs Associated with Environmental Qualification (EQ) Modifications The licensee is currently performing some 67 maintenance or modification activities on safety-related electrical equipment in order to satisfy the EQ requirements of 10 CFR 50.4 The inspector reviewed the PMTs associated with a selected number of these modifications. A brief discussion follows to clarify the licensee's terminology and program. The PMT program is controlled by Administrative Instruction AI-19, Part IV, (Plant Modifications Af ter Licensing). This instruction requires a PMT if OE requires it through issuance of a test scoping document. The test scoping document contains the scope, purpose, test description and acceptance criteri The plant systems engineer then uses the scoping document to prepare a detailed test instruction. Af ter completion of the PMT, test results are reviewed by OE. If no scoping document is issued, no PMT is required. None of the EQ modifications reviewed required a PMT. Per AI-19, in cases where OE determines that scoping documents are not required, the modifications cognizant engineer must prepare a functional test instruction as part of the workplan which implements the modification. The functional test is used to ensure that new components perform their intended function and that the work did not inadvertentty degrade an operating system or componen In general (although not always the case), PMTs are used for major system modifications and involve system level tests (similar to preoperational tests); whereas functional tests are used for component level modifications and involve component level tests (such as device calibration, response time or insulation integrity checks). The criteria OE uses to ,
determine when a PMT is required is procedurally stated in generalities and ;
is the subject of close scrutiny by licensee management. More detailed i criteria is being developed. All of the EQ modification workplans reviewed 1 contained functional test instructions and acceptance criteri It was I l
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evident through discussions with various licensee representatives throughout the inspection that considerable supervisory and management attention has been focussed in the area of these functional test The following paragraphs describe the functional tests reviewed: Limitorque Valve Modifications Engineering Change Notice (ECN) L6544 was issued to implement a Category "D" Field Change Request (FCR) and resolve a Significant Condition Report (SCR) on the EQ of Limitorque Actuators. In order to resolve the SCR, unqualified wiring within the limit switch compartment is being replaced with qualified wirin Prior to this work, connection drawings and elementary diagrams were revised by the FCR in order to simplify and clarify the drawings and correct drawing errors to facilitate the re-wiring effort. For example, some drawings were shown with a limit switch and torque switch wired in the valve opening control circuit which were jumpered out and not functionally in the circuit. The drawings were changed so that during the re-wiring work, the limit switches and torque switches did not have to be wired into the circuit and tnen jumperd ou In a second type of change, one type of valve closing control circuit was found to have a torque switch wired in such a manner that it couldn't function as designe The wiring drawing was changed to correct this situation prior to the EQ re-wiring work. A third type of valve closing control circuit was found to have a torque switch bypassed by a limit switch until the valva reached the 97% closed position. Since an identical limit switch was also in series with this torque switch / limit switch combination, the torque switch was effectively bypassed and therefore not a functional part of the circuit. The drawings were changed to remove the torque switch from the circuit for stopping valve motion in the closed directio The inspector expressed a concern that changes to the second and third types of circuits described above were more than a simplification of the circuit or a substitution of an equivalent circuit. In the second example for instance, a valve closed limit switch opened to stop the drive motor in the closed direction in the pre-existing configuratio In the new configuration a limit switch and torque switch are in parallel in the closing circuit such that the limit switch must actuate at 97% valve closure and the torque switch must also actuate before the drive motor will be deenergized. The result of this change is that the valve is now torqued shut on every cycle as opposed to jus +. having torque protection in the event of a limit switch missadjt . ment or failur In the third example discussed above, a 1979 ECN .4 0 . 2257)
was implemented to install the limit switch bypass around the torque switch. The intent of this ECN was to prevent the torque switch from operating in mid stroke, but to restore the torque switch protection during the last few percent of valve travel in the closed positio The new modification to this circuit removes the torque switch protection at all time ,
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- Licensee design personnel stated that each actuator's application was considered prior to changing the control circuits. In general, gate or
. globe valves use torque switches in the closing circuit except for
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fast-acting valves which should coast to the sea Torque switches are not used in control circuits for butterfly valves except for valves with rubber seats and those where seat leakage is critical. This
, essentially constituted a redesign of the control circuits for some of j the valves. The 1979 ECN which bypassed the- torque switches was apparently improperly implemented. No torque switches in' the revised i circuits can stop valve motion in mid-stroke, and this ECN has now been properly correcte The inspector questioned if the drawing i
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descrepancies and non-functional torque switches (incorrectly wired control circuits) had been evaluated for reportabilit Licensee representatives indicated that a formal evaluation was not performed as outlined in SQN-84, Reportable Occurrence The inspector was unable
to determine whether the drawing discrepancies and non-functional torque switch could have prevented the fulfillment of a safety functio This issue is an Inspector Follow-up Item (327,328/86-20-03).
The modification work required removing all installed wiring and re-wiring the Limitorque valves per the new drawings. The functional tests conducted by Modifications personnel consisted of a hand cycling
- of the valve actuators with a check on limit switches, closing and opening contactors, and in some cases annunciators with the valve in the fully closed, fully open, and in the mid positio The valves were then cycled opened and closed electrically. After completion of these j tests, electrical maintenance personnel were to perform additional EQ i
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maintenance which consisted of grease inspections on the main gear case and limit switch gearbox, limit switch adjustments, limit switch
, contact gap check and inspection, gasket inspections, motor insulation checks, and stroke timing. In addition, baseline data will be
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collected using the Motor Operated Valve Analysis and Test System (M0 VATS) equipmen Alt'iough the inspector initially expressed a concern about the adequacy of the post-modification functional test required by the EQ modification, the concern was rendered moot by the extensive efforts i performed following the modification. These efforts (EQ maintenance, M0 VATS, and routine surveillance tests) were not formally required as post-modification tests by the licensee and the documentation will not reflect that the modification and follow-up maintenance actions are .
- related. The inspector, however, took credit for these follow-up activities in order to make a determination that the tests following
] the modification activity were adequat >
l l Containment Pressure Transmitter Modifications
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' ECN 6554 and.Workplan 11912 replaces the existing containment pressure transmitters 1 & 2 PDT 30-42 and 1 & 2 PDT 30-43 with qualified transmitters. These transmitters provide input to containment-l
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isolation and containment spray logic. The replacement transmitters were made by the same manufacturer as the previous transmitter and are i functionally and electrically equivalent. Functional testing consisted of a bench calibration, post-installation calibration, response time test, and local leak rate test. All functionals were performed with
< pre-existing Surveillance Instructions and Instrument Maintenance e Instructions, each with applicable acceptance criteria. One potential
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problem was found with the post-installation calibration data which had not been evaluated by the licensee. The as-found data on both Unit 2 transmitter < was out-of-tolerance even though the bench calibration had recently been performed. Ur.it 1 as-found calibration data was not -
recorded since maintenance personnel considered this an initial calibration not requiring as-found dat Licensee representatives speculated that the transmitters zero adjustment knob was disturbed
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during the in-tallatio A lack of consistency was noted in the way functional tests were performed on Unit 1 and Unit The functional test instructions required that the " applicable portions" of the channel calibration
, instruction be performed. Some of the procedure steps completed on the Unit 1 transmitter were not performed and marked "not applicable" on the data sheets for the Unit 2 transmitter These steps involved cable resistance measurements on wires not affected by the modificatio Licensee representatives later stated that these steps were indeed not applicable for the purpose of the post-modification functional test and could have been deleted during the Unit 1 transmitter calibration. The use of such terminology as " perform the
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applicable portions of ... is a recurring deficiency and will be tracked as an Inspector Follow-up Item (327,328/86-20-11).
c. Annulus Differential Pressure Transmitters i
ECN L6488 and Workplan 11931 replaces the existing differential pressure transmitters 1 & 2 PDT 65-80, 82, 90 and 9 These transmitters function in the Emergency Gas Treatment System to control annulus vacuu The replacement transmitters were functionally equivalent to the previous transmitters. Functional tests consisted of a bench calibration, post-installation instrumentation calibration and loop calibration. One concern was expressed to modifications personnel regarding the level of control exercised over verification of hi and lo
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side instrument connections to differential pressure transmitter This work plan contained caution statements and several verification signatures that the hi/lo pressure taps were properly connected. -The workplan for the containment pressure transmitters, previously discussed, contained none of these control measure Modification personnel indicated that there is no policy for these checks and the differences are due to the personal preferences of the modification engineers. Since all post-modification functional tests hook up test
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1 equipment downstream o' the instrument isolation valves, an extra j measure of control is aporoprit.te to prevent incorrect hookup _- of i transmitters. This item was aiscussed with licensee representatives j during the inspection and again during the exit meeting.
. Containment Electrical Penetrations i
l' ECN L6490 and Workplan 11801 installed containment . electrical
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penetrations for Radiation Monitoring and Nuclear Instrumentation Systems. Functional tests consisted of a soap bubble check of weld integrity during a Containment Integrated Leak Rate Test (substituted '
for a local leak rate test requirement for convenience), conductor continuity checks and 500VDC megger test of insulation integrity. No problems were identified with this modification.
i Temperature Switches In Various Systems I ECN 6551 and Workplan 11916 changed setpoints for various switches in i Systems 1, 12 and 30. The setpoints .were changed to account for excessive drift due to the extreme' environment encountered in the event j of postulated accident conditions. The setpoints were chang'e d using
! existing plant procedure Functional tests consisted of the
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application of heat with a heat gun and a verification that the switch j actuation created the desired response (such as valve or damper isolation). No problems were identified with this modification.
i Steam Generator, Containment Sump, and Pressurizer Lever Transmitters
! This activity was considered maintenance and was' performed on seventeen
Barton level transmitters. The change consisted of hard wiring 'a pin '
, connector internal to the transmitte The work was controlled by Special Maintenance Instruction 2-317-23 which' was based upon manufacturers instructions for completing the change. A problem with
- the continuity of the pin connection _was noted during the environme.ntal
tests. The recommended fix consists of soldering the pin connection.
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PMTs consisted of an instrument calibration per existing procedure The calibration was not shifted by the modification and no adjustments
- were necessary on the transmitters reviewe No problems were
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identified with this chang In the areas inspected, no violations or deviations were identifie i 1 Engineered Safety Feature Logic Review The inspector conducted a review of ' selected TS surveillance requirements and procedures, and verified that the following -TS requirements were adequately addressed in surveillance procedures: ,
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TS 4.3.1.1.1, Table 4.3-1, Item 19 i
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TS 4.3.2.1.1, Table 4.3-2,. Items 1.a, 1.b, 2.a, 2.b, 3.a.1,.
3.'a.2, 3.b.1, 3.b.2, 3.c.1, 3.c.2, and TS 4.5.2.e.2.a, 2.b and TS 4.6.3.2.a and TS 4.7.3.b
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TS 4.7.8. TS 4.8.1.1.2.d.2, 3, 4.a, 4.b, 5, 6, 7a, 7b, 7c, 8, 9, 10.a. 10.b, 10.c, and 11
! Surveillance procedures reviewed in total or in part included:
AI-4 Document Control, revision 53
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l SI-7 Electrical Power System: Diesel Generators, revision 33
l SI-9 Actuation of Automatic Valves via SI signal for i non-testable Boric Acid and ECCS Flow Path Valves, j revision 18.
- SI-26.1A Loss of Offsite Power with Safety Injection - D/G 1A-A j CNTNT ISOL Test', revisions 9,10 and 11 SI-26.1B Loss of Offsite Power with Safety Injection - D/G 1B-B l Test-
i SI-26.2A Loss of Offsite Power with Safety Injection - D/G 2A-A l CNTMT ISOL Test, revision 12 and 13 t
i SI-26.2B Loss of offsite power with Safety Injection - D/G 28-B i Test, revision 11
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l SI-90-8 Reactor Trip Instrumentation monthly functional test t (SSPS) Unit 1, revision 3 l SI-119 ERCW auto actuation from an SI signal, revision 6 i
SI-135 EGTS cleanup subsystem automatic start, Units 1 and 2, revision 7
SI-247.100 Response time testing of the Engineered Safety Feature Instrumentation (refueling outage)' Units 1 and 2, revision 6 i
! During this review, the inspector identified that the relay contacts
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associated with the manual Engineered Safety Feature (ESP) control room
! switches HS-63-133A and HS-63-1338 were not included in the testing of the
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4 Reactor Trip System (RPS). These contacts, as shown on plant drawing 45N699-1, are in parallel with the manual .RPS control switches,1-RT1 and RT2 (Unit 1). Thus, testing of the RPS manual switches verifies proper operation of the remainder of the circuit. A similar condition exists on
+ Unit 2. The requirement to perform a surveillance on this circuit is in Technical Specification 4.3.1.1.1 which requires a test to be performed as prescribed in Table 4.3-1. Table 4.3-1 (item 19, note 4) requires " manual ESF functional input check every 18 months." Technical Specification e 6.8.1.c requires procedures to be written for surveillance of safety related equipment. Since the above equipment is safety related, failure to have a procedure for the surveillance is not in accordance with TS 6.8.1.c, and is a Violation (327,328/86-20-04).
The inspector determined that some errors are being incorporated into surveillance procedures during the revision process. The items found by the inspector had also been identified by the licensee and revisions were in progress to correct the specific items. Three items of interest in this area are: (1) two steps (4.3.3 and 4.3.4) were dropped from revision 10 of SI-26.1A probable cause was inadvertent deletion by the word processor i operator; (2) SI-26.2A, revision 13 was issued with a non-conservative TS
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value for diesel generator frequency (58.1 Hz vs. 58.8 Hz, step 11 of data
sheet 5) - considered as a typo; and (3) SI-7, revision 34 was found during performance to have verification of diesel generator fuel oil tank levels no longer incorporated in the procedure - probable cause was failure to properly incorporate revised pages into the procedure prior to issuance
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(e.g., steps were put on subsequent page which was not replaced). These items were discussed with plant managemen In addition, review of AI-4, Document Control, indicated a weakness in processing some revision In processing non-intent changes, the Plant Operations Review Committee (PORC) will review a hand written change, then
. it will be typed, returned to PORC and issued to the field. During a PORC
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meeting, an inspector witnessed two such changes being returned to PORC. In this instance it was observed that these items were identified as having previous PORC approval and as a result were immediately approved. Thus the responsibility for verifying the technical adequacy of the typed revision
{ rests with the typist and word processor proof reader. Neither of these are i technical people. The licensee is considering a change to AI-4 so that the
, typed version is returned to the originator for review prior to the final
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PORC approval. The licensee's corrective actions, if appropriate, to reduce the number of problems specified in (1), (2) and (3) above and the change to AI-4 is considered an Inspector Followup Item (327,328/86-20-05).
i 1 Drawing Control As part of the logic surveillance test procedure review, drawings were utilized which were either controlled copies in the control room and the technical support center (TSC) or ones obtained directly from drawing control. A comparison between those available for use and those obtained from drawing control revealed no discrepancies in revision date The inspector did note several minor discrepancies not effecting technical i
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information such as drawing references and engineering change number references were inaccurate or missing. The licensee had recently identified
! this in an internal TVA memorandum from J. B. Vineyard to H. B. Rankin dated March 4, 1986. This memorandum stated that "as-configured drawings reviewed during the audit contained numerous errors. . . while most problems were
! minor, the number of' errors identified indicated a failure to maintain i complete program control of the as-configured drawings located in the
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control room". Inspection of the licensee's resolution of this statement is
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an Inspector Followup Item (327,328/86-20-06).
In the areas inspected, no violations or deviations were identified.
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12. Quality Assurance Staff Responsibility For Plant Procedures The QA staff is assigned as the responsible group for the following
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1 AI-4 Plant Instructions-Document Control j AI-7 Recorder Charts & Quality Assurance Records i Al-9 Control of Temporary Alterations & Use of The Temporary
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Alterations Order AI-11 Receipt Inspection Nonconforming Items, QA Level / Description Changes and Substitutions
. AI-12 Adverse Conditicns and Corrective Action AI-13 Control of Inoperable & Unavailable CSSC Equipment
- AI-20 Inspection Program AI-26 Prevention of Foreign Material in The Primary System AI-32 Quality. Assurance Surveys l AI-34 Training and Certification Program for QC Inspectors ,
AI-36 Storage, Handling, & Shipping of QA Material AI-39 Critical Structures, Systems & Components-(CSSC)
SQA1 System of Standard Practices SQA134 Critical Structures, Systems & Components -(CSSC)
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i SI-114 Preservice Baseline Inspection for TVA SQNP-Units 1 and 21 SI-114.1 ASME Section XI In-service Inspection Program Unit 1 SI-114.2 Inservice Inspection Program for TVA SQNP (Unit 2 Only)
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SI-284 Ultrasonic Inspection of Pressurizer Relief Line Repair-SQA159 Standards and Guides for QA Level III Items
- SQA160 Materials Which May Come in Contact With RX Coolant j SQA161 Procurement of 10 CFR 50.49 Equipment l SQA162 Purchase Specifications For CSSC Materials r
- Some of these procedures are implemented by the line organizatio Region II personnel are currently reviewing the appropriateness of this practice with respect to line and quality assurance staff independenc This is an Inspector Followup Item (327,328/86-20-07).
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In the areas inspected, no violations or deviations were identified.
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13. Verification of Primary Containment Integrity The inspector reviewed the licensee's procedure Surveillance Instruction SI-14, Verification of Containment Integrity-Unit 1, Revision 2 This procedure was provided to demonstrate containment integrity through veri-fying the proper positioning of all containment isolation valves, with the exception of energized automatic isolation valves, while operating in 4 mode 4 or above at least every 31 days and prior to heat up to mode 4 from mode 5 for each cold shutdown as required by TS 4.6.1.1.a. A comparison of the as constructed drawings of selected systems penetrating containment was made with SI-14. This comparison revealed the positions of 20 vent, drain ;
and test valves, which form isolation barriers to their associated contain-ment penetrations, that were apparently not verified during the performance
of SI-14 in Unit However, for the affected systems, the position of these particular valves is self disclosing and/or maintained with system alignment check sheets. These valves are as follows:
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Containment System Penetration Isolation Valves
Chemical & Volume X-15 62-707 Control Component Cooling X-29 70-735 X-50A 70-737 f X-508 70-6788 ;
X-52 70-691B ,
X-35 & X-53 70-702B,C,E & F l 70-703 70-760 70-762 70-763 Containment Spray X-48A 72-543
72-545 t X-48B 72-546 72-544 s
Fuel Pool Cooling and X-82 78-228A :
Cleaning X-83 78-226A Upper Head Injection X-110 87-523 ;
- The inspector reviewed the surveillance records for the performance of SI-14 prior to the mode change from 5 to 4 on May 20, 1985, and while the unit was in mode 4 or above from May 20 to August 24, 1985. The licensee performed SI-14 on the following dates
May 17, 1985 June 3, 1985 ;
June 6, 1985 June .19, 1985
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June 27, 1985 July 25, 1985
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During these surveillances, the containment isolation valves listed above were not verified for their proper alignment as required by TS 4.6.1. in order to demonstrate containment integrity while operating in mode 4 or above, or prior to heat up to mode The failure to check the positioning of these containment isolation valves will be identified as Violation (327/86-20-08). The licensee should conduct a detailed review on both Sequoyah units to determine if there are any additional containment isola-tion valves that are not incorporated in SI-1 . Review of Chemical and Volume Control System Containment Penetration Boundaries .
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The inspector reviewed the licensee's compliance with 10 CFR 50 Appendix A, General Design Criteria (GDC) 54, 55, 56 and 57 in the design of the following Chemical and Volume Control System (CVCS) containment penetra-tions:
Penetration Function X-16 Volume Addition Through Charging and Pressurizer Spray j X-43A Loop 3 Reactor Coolant Pump (RCP)
Seal Water X-43B Loop 2 RCP Seal Water
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X-43C Loop 4 RCP Seal Water X-43D Loop 1 RCP Seal Water Table 6.2.4-1 of the FSAR indicates that penetration X-16 is designed to '
meet GDC 56, and is considered as an Isolation Class I penetration (having as a minimum two isolation valves in series, one inside containment and one ,
outside). There are no commitments to the GDC indicated for penetrations l X-43A, B, C, or D, but the table did classify them Isolation Class II '
penetrations (having as a minimum one isolation valve).
Section 6.2.4.3 of the FSAR states that "the requirements and intent of NRC General Design Criteria 54, 56, and 57, and Regulatory Guide 1.11, have been met with only three exceptions" - neither of which includes the above penetration A review of the above penetrations revealed that their i current design apparently does not comply with the requirements of GDC 55, 56, or 57 as none of these penetrations possess an automatic, remote manual, or locked closed containment isolation volve outside containmen (FCV-62-90 could be used to meet this requirement for penetration X-16, but it is not co.isidered as such by the licensee or Table 6.2.4-1 of the FSAR.) ,
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This apparent failure to meet the GDC was discussed in a telephone conference call between TVA - Licensing /0E, NRR - Contai, ment Systems Branch, IE - Operating Reactor Programs Branch, and Region Il on April 14, 198 During this conference, the licensee indicated that these penetra-tions were considered to meet the GDC since each has an inside containment barrier consisting of a check valve, and an outside containment barrier consisting of a " closed system." Accordingly, TVA agreed that penetration X-16 was incorrectly categorized as an Isolation Class I penetration designed to meet GDC 56; instead, Table 6.2.4-1 should be revised to show penetration X-16 as an Isolation Class II penetration designed to meet GDC 55. NRR acknowledged the use of a " closed system", but only in conjunction with other outside isolation barriers (e.g. , remote manual valves, manual handwheel valves, etc.); and in either case, an exemption to the GDC should have been taken. Pending further followup by the NRC with its licensing staff, this shall be identified as Unresolved Item (327, 328/86-20-09).
15. Design Changes and Modification Engineering Change Notice (ECN) L5095, ,reviously inspected in NRC Inspection Report No. 327,328/85-46, was reviewed to determine if the proper analyses and PMTs had been performed to assess the effects of the ECN's installation of block and drain va'ves on the various containment penetrations modifie The inspector found that a seismic analysis of the system design modification had been performed at the Watts Bar Nuclear Power Plant. Though no seismic analyses were specifically performed at Sequoyah, the licensee asserted that these modifications had been appropriately analyzed as the systems and the modifications performed at Sequoyah were apparently identical to those analyzed at Watts Ba A review of the local leak rate test requirements and results indicated that no additional local leak rate tests were required to be or were actually
performed to test these modification ~ Additionally, it was determined that the performance of these modifications had not caused an increase in the containment penetrations local leakage rates measured during the licensee's
- performance of the periodically required Type C local leakage rate test ,
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16. Onsite Review Committee (40700)
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The inspector reviewed the Sequoyah Nuclear Plant Standard Practice procedure SQA21, Onsite Independent Review (Plant Operations. Review Committee (PORC)), for compliance with TSs in the areas of composition,
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alternates, quorum, responsibilities and records. The minutes of meetings held in the months of May, June, July, August, September, November, and December 1985, were reviewed for proper centent as defined by TSs. The inspector attended one PORC meeting to observe the conduct of the meetin _ _
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The review of SQA21 against TS 6.5.1 revealed that the procedure was l adequate in the areas of alternates, quorum, responsibilities and record In the area of composition, SQA21 did not comply with TS 6.5.1.2 which establishes a PORC composed of the Chairman and six member SQN21-establishes a PORC composed of the Chairman and eight members with provisions that the Operations Supervisor or the Assistant Operations )
Supervisor and the Engineering Group or Engineering Section Supervisor can !
participate as a voting member. This,in effect, incorporated as members, two alternates: the Assistant Operations Supervisor and the Engineering Section Superviso The use of these individuals as members, vice alternates, resulted in the quorum requirements not being met since an insufficient quorum of members existed. The persons utilized did meet ANSI N18.1-1971 qualifications; and the inspector noted that a 1984 TS amendment request had been submitted to NRC, but was never approve Approximately forty examples of inappropriate PORC composition were found during the review of 1985 PORC minutes (e.g. meeting numbers 3351, 3353, 3356, 3359, 3364, 3367, 3378, 3381, 3389, 3401, 3402, 3403, 3407, 3420, I 3421, 3422, 3429, 3434, 3437, 3449, 3471, 3473, 3512, 3513, 3521, 3663, '
3674,3676,3678,3679,3684). This improper implementation of TS require-ments for PORC, which resulted in the quorum requirements not being met, is a Violation (327,328/86-20-10).
1 Items Requiring Licensee Action Prior to Res: art There are four restart items that have been identified from the proceeding paragraphs; three of which were addressed in the March 25, 1986 letter from J. A. Olshinski to S. A. White. A summary of these four restart items, reference to their applicable report paragraph, and any specific comments about these items are presented belo The 18 month manual engineered safety feature functional input check of the reactor trip system per TS 4.3.1.1.1. was not being performed, nor was there a procedure for this tes It is expected that an appropriate procedure will be established and implemented such that the required TS surveillance is performed. This item has been identified as Violation 327,328/86-20-04 and is further addressed in paragraph 10 of this report, A review of systems 62, 70, 72, 78 and 87 in Unit I revealed 20 vent, drain and test valves, each forming a containmentnisolation barrier, which were not verified shut during the performance of SI-14 (Verification of Containment Integrity). It is recognized that for the valves identified, their position is self-disclosing and/or maintained with system alignment check sheet However, there may be other containment penetrating systems where this is not the cas Conse-quently, the-licensee should conduct a detailed review on both Sequoyah units to determine if there are any additional containment isolation valves that are not incorporated in SI-1 This item has been identified as Violation 327/86-20-08 and is further addressed in paragraph 13 of this repor ._
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26 c. Five containment penetrations in the CVCS do not appear to meet General Design Criterion 55, 56 or 57, and no exception appears to have been taken. This item is being reviewed by the NRC Licensing Staff. The licensee should pursue this item to resolution, ensuring that similar situations don't exist in other containment penetrating systems. This has been identified as Unresolved Item 327, 328/86-20-09 and is further addressed in paragraph 14 of this repor d. Based on identified discrepancies, the plant manager committed to conduct a review of the temporary alterations control program and implement changes necessary to improve this progra In a March 18, 1986 letter from R. Gridley to J. A. Olshinski, it was indicated that each open temporary alteration was to be reassessed to ensure that plant safety is not degraded due to the existence of the alteration At the time of the NRC Operational Readiness Inspection, three temporary alterations were still being evaluated for adequate testin Since documentation of testing is required to be with the TACF, improvement in this area should be considered. The licensee review of the temporary alterations control program is being tracked as Inspector Followup Item 327, 328/86-20-01, and is further addressed in paragraph 3.b. of this report, i
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