IR 05000327/1986050

Enforcement Conference Repts 50-327/86-50 & 50-328/86-50 on 860825.Major Areas Discussed:Util Surveillance Review Program

ML20214H852
Person / Time
Site:	Sequoyah
Issue date:	09/17/1986
From:	Brady J, Carroll R, Debs B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20214H835	List: IR 05000327/1986050 ML20214H833
References
50-327-86-50-EC, 50-328-86-50, NUDOCS 8612010063
Download: ML20214H852 (19)

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Sm Etig . - UNITE 3 STATES Do NUCLEAR REGULATORY COMMISSION

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[ REGION 18 g j 101 MARIETTA STREET, * 's ATLANTA. GEORGI A 30323

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Report Nos.: 50-327/86-50 and 50-328/86-50 Licensee: Tennessee Valley Authority 6N38 A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801

' Docket'Nos.: 50-327 arid 50-328 License Nos.: DPR-77 and DPR-79 Facility Name: Sequoyah 1 and 2 Meeting Conducted: August 25, 1986 Project Engineers: / fidded 9//6/#6 J/B. Brady g

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Date Signed 5 x_ 0//Y$b Yate Signed R. E.T rrol

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Approved by: w /7 B. T. Debs, Section Chief D4te signed Division of Reactor Projects

SUMMARY An Enforcement Conference was held at Region II on August 25, 1986,..at 1:00 p.m.~,

EDT to review items pertaining to the Sequoyah Surveillance Program. TVA gave chronology of the Surveillance Review Program since, August 1985.' The program is in its fourth evolution, the latest having started in June 1986. The program requires that review of all surveillance instructions for technical adequacy be completed prior to restart. TVA stated they neither = feel their surveillance .

program was out of control' nor did they have a programmatic breakdown in this program. TVA believes their present review program is adequ~ ate and will identify and correct any procedural problems. The slides used by TVA during the pre-sentation are contained in the attachmen .

8612010063 861003 PDR ADOCK 05000327 G PDR l .

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REPORT DETAILS 1. Attendance NRC J. N. Grace, Regional Administrator G. G. Zech, Director, Division of TVA Projects A. F..Gibson, Director, Division of Reactor Safety (DRS)

A. B.-Beach, Deputy Director, Enforcement Staff, IE G. R. Jenkins, Director, Enforcement and Investigation Coordination Staff S. P. Weise, Branch Chief, TVA Projects K. P. Barr, Branch Chief, Division of Radiation Safety and Safeguards B. T. Debs, Section Chief, TVA Projects M. B. Shymlock, Section Chief,'TVA Projects B. A. Wilson, Acting Section Chief, DRS K. M. Jenison, Senior Resident Inspector, TVA Projects R. E. Carroll, Project Engineer, TVA Projects J. B. Brady, Project Engineer, TVA Projects G. K. Hunegs, Project Engineer, TVA Projects C. L. Vanderniet, Reactor Engineer, DRS TVA C. C. Mason, Deputy Manager of Nuclear Power R. L. Gridley, Director, Division of Nuclear Safety and Licensing, Sequoyah Nuclear Plant H. L. Abercrombie, Site Director,- Sequoyah Nuclear Plant P. R. Wallace, Plant Manager, Sequoyah Nuclear-Plant M. R. Harding, Site Licensing Manager, Sequoyah Nuclear Plant R. H. Buchholz, Site Reprasentative, Sequoyah Nuclear Plant M. E. Frye, Plant Operating Review Staff,' Sequoyah Nuclear Plant W. E. Andrews, Site Quality Manager, Sequoyah Nuclear Plant E. W. Whitaker, Licensing Engineer, Sequoyah Nuclear Plant G. B. Kirk, Compliance Licensing Supervisor, Sequoyah Nuclear Plant H. D. Elkins, Jr., I&C Section Supervisor, Sequoyah Nuclear Plant

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R. W. Fortenberry, Technical Support Supervisor, Sequoyah Nuclear Plant J. M. McGriff, Branch Chief, EI & Controls - SI Review Coordinator T. A. Ippolito, Consultant, DBA Event-Discussions-The Regional Administrator opened by reviewing the NRC concerns on the surveillance progra ihe Directcr of TVA Projects expanded on the con-ceins, briefly describing the surveillance deficfencies identified by both TVA and NRC during late 1985 and 198 Mr. C. -C. Mason, Deputy Director of clear Power, gave brief opening statements for .TVA. Mr. P. R. Wallac , ave an opening overview of the surveillance - program history. Mr. M. E. Frye gave a detailed presenta-tionlof the surveillance program review from August 1985 until present. *

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TVA stated that their review of QA Audit Reports, NRC Inspection Reports, and Reportable Event History Files prior to August 1985 did not indicate generic problems. The review program started in August 1985 with a one for one check between Technical Specification Requirements and Surveil-lance Instructions (nine deficiencies identified). Based on problems associated with the 6.9 kv penetration testing, the program was revised in February 1986 to include random sampling of -137 surveillance require-c.ents (minor discrepancies). Based on failure to implement a surveillance requirement on the manual SI hand switch, the program was revised again in March 1986 to include a Task Forc A revised Technical Review Program was added to the ongoing Administrative Program in June 1986. TVA stated that the Technical Review Program will be completed prior to startu The NRC stated that the licensee should be identifying and correcting their own problem The NRC questioned if TVA is now identifying tneir own problems only because of programs the NRC has forced upon them, and if TVA is now convinced that they have had a programmatic breakdown in the surveil-lance area. Mr. P. R. Wallace answered that he did not feel the program was out of control nor that a programmatic breakdown had occurred. He did not believe that these problems represented widespread problems, but isolated example Mr. Wallace stated that the reason that prior QA reviews had not been effective in picking up problems was that QA had not been staffed for or tasked with an in-depth Technical Review. QA involvement from a technical standpoint started in June 1986. The technical people now assisting QA in the review include some Watts Bar personnel that are familiar with earlier Watts Bar type surveillance problem The NRC generically questioned ASME Section XI Pump Performance Testin The question was in regard to operators deviating from procedures to obtain acceptable ERCW pump performance data. TVA responded that the Independent Safety Engineering Group (ISEG) had investigated this issue and found no other such occurrence The NRC thanked TVA for their presentation and closed the meetin Attachment: Enforcement Conference Agenda l

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S ATTACIDfENT ENFORCEMENT CONFERENCE AGENDA .

SEQUOrgy SyRVEILLANCE PROGRAM REVIEV l

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PROBLEM Through TVA reviews and NRC inspections performed since August 1985

- Three specific problem areas

- Some examples Surveillance Requirements not implemented

- SI hand switch not tested for manual trip

- 31 day ESF circuitry test Surveillance Requirements not properly implemented in procedures

- Molded case circuit breaker testing

- Undervoltage and underfrequency functional test Implementation of surveillance program

- Review of test data failed to identify recurring problems

- Test results were not reviewed in a timely manner

- Procedure not properly performed (i.e., ERCW pump test)

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BACKGROUND Through an evolutionary process with heavy management envolvement:

- From August 1985 (both units in mode 5)

- June 1986 (Full technical review program)

Prior to August 1985 no indications of generic problems:

- TVA QA Audit reports

- NRC inspection reports

- Reportable event history files A'ugust 1985: Because of findings at Watts Bar

- Two year program developed (July 1987)

- Check list developed

- Section supervisor lists and schedules

- Intent: Technical and Administrative February 1986: Suplemental steps taken due to problems associated with 6.9KV penetration testing

- Random sample of 137 Surveillance Requirements

- Minor discrepancies (no safety concerns)

March 1986: Identified failure to implement a surveillance requirement on the manual SI handswitc SR/SI Task Force implemented

- Ensure implementation of every surveillance requirement

- Approximately 180 items identified

- Ten items reported to NRC (LER)

- Final report issued June 1986: Results of the SR/SI task force, and testing of molded case circuit breakers

- Further acceleration of review process

- Complete technical review program

- Technical review checklist

- Prior to restart L _ _ _ __-

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SUMMARY OF MANAGEMENT INVOLVEMENT Heavy Management involvement:

- Evolutionary process

- Prior to August 1985

- Two year review program - August 1985

- Suplemental steps (February 1986, March 1986)

- Technical review June 1986 (Prior to restart)

Phase I and Phase II:

- Phase I: Technical adequacy review (prior to restart)

- Phase II: Complete administrative portion, using writers guide

- Consistency, format

- Human factors l

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CORRECTIVE ACTIONS Objective of Phase I: Prior to restart

- Ensure technical adequacy

- All surveillance instructions which implement surveillance requirements

- All supporting procedures

- Checklists (consistancy/ traceability)

- Engineers trained

- QA involvement l

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ASSURANCE OF TECHNICAL ADEQUACY Technical specification compliance:

Administrative relationships

- Modes of operability

- Frequencies

- Surveillance Requirements Technical relationships:

- Setpoints

- Verification (Technical Specification, surveillance instruction, plant drawings, Final Safety Analysis Report)

- Pump and valve program (section XI)

Methodology of testing:

- Industry Standards

- Maintenance and test equipment

- Interface with other plant systems

- Return to normal Calculations:

- Calculations used in procedures

- Process correction (i.e. head and temperature)

- Numerical values / process values Acceptance Criteria:

- Clearly stated What it is What to do

- Technical Specification allowable values Operability evaluation:

- Any item marked no on checksheet i

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SI-1 Appendix F Procedure N _

Page 7 of 10 08/06/86 SI REVIEW CHECKLIST TECHNICAL ADEQUACY Technical Specification Compliance *

YES N/A NO Does the procedure address the Technical Specification applicable modes and performance modes, and are modes referenced correctly? O O O Is the surveillance " frequency" clearly and correctly given, including all special conditions, Technical Specification notes and ISI requirements? O O O Is the Technical Specification reference complete and lI correct? O O O g Does the procedure ensure literal compliance with the y Technical Specification? O O O Do the Technical Specification setpoints agree with instrument tabs, FSAR, and applicable drawings? O O O Is the SI-1 SI/SR cross-reference complete and correct

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or if not, has an update been submitted to the MSU? O O O Does the procedure obtain data required by the pump and valve program? O O O I Is the frequency consistent with the pump and valve program? O O O f Are all instructions listed as a supporting instruction for performance under the SI undergoing or has been

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'l_ 1 Are all compliance instruments for this surveillance listed in TI-54 or TI-54.2? O O O

! Methodology i

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verified against the applicable standards and are they correct (i.e. FSAR, Technical Specification bases, ANSI, IEEE, ASME, ANS, Reg Guides, TVA Topical l Report TVA-TR75-1A, Vendor Recommendations, etc)? O O O Does the range and accuracy of M&TE equipment corre-spond to the specified test tolerances? O O O Does the procedure match a:-constructed plant drawings? O O O C

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SI-1 Appendix F Procedure No.

i- Page 8 of 10 08/06/86 SI REVIEW CHECKLIST l YES N/A NO Does the procedure ensure that plant conditions are not adversely affected (LCO and system interaction)? O O O

. Is return to normal service docusented? O O O Calculation and Equation

' Are all equations necessary for calculations clearly I listed, understandable, and correct? O O O Are engineering units / process variable numbers correct (e.g., does 3.601 volts really correspond to 173*F)? O O O Have head and temperature corrections been properly applied? O O O Acceptance Criteria l Is acceptance criteria and what should occur if the I acceptance criteria is not met stated clearly? O O O Are Technical Specifications and allowable values I clearly stated (include FSAR setpoints and values)? O O O For process instrumentetion do maximum / minimum values in functional test ensure the instrument is within the I manufacturer's specified tolerance? (Applicable to instrument maintenance only) O O O II. ADMINISTRATIVE ADEQUACY Does the procedure address common mode failure criteria (e.g., IMS-19, EMSL-A36)? O O O Does the procedure require signoff for all important prerequisites? O O O Is the purpose of the procedure correctly stated? O O O Does the procedure list all special equipment required for the test including all required tolerance and qualifications? O O O Are all unincorporated temporary changes in compliance

{ with AI-47 0 0 0 Does the procedure require SR0's approval to perform this test? O O O

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SI-1 Appendix F Procedure No.

' Page 9 of 10 08/06/86 SI REVIEW CHECKLIST YES N/A NO Does the procedure verify other redundant loops or equipment are in non-tripped condition? O O O Does the procedure notify oper: tor which annunciators will light?

O O O Do all reactor trip and ESF analog channels have status lamp check? O O O 1 Are "As Found Data" and "As left Data" collected? O O O 1 Is the procedure clear as to the intent of each section? O O O 1 Does the procedure identify all hold points necessary? O O O 1 Does the procedure require all data takers to be identified by signature / initials and date on all pages where data is collected? O O O 1 Is the procedure grammatipally correct? O O O I .)t-15. Are calibration due dates and TVA identification numbers recorded for all test equipment used for Technical

t- Specification or ISI? O O O 1 Is sufficient room provided for all calculations? O O O 1 Does the procedure ensure that a system mix which might create difficulty in determining satisfactor'/ completion does not exist? 3 0 1 Is the procedure clear and will it be performed the same 1 way every time? O O O 1 k*here trains of similar equipment exist, are the procedures consistent? O O O 2 Does all information in the SI text match the corresponding item in the data sheet? O O O

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. SI-I Appendix F Procedure N Page 10 of 10 08/06/86 SI REVIEW CHECKLIST YES N/A NO 2 Does the instruction require documentation of double verification for: Test equipment removal and proper equipment restoratio O O O Pretest equipment lineups where incorrect lineup would jeopardize the operation of safety systems? O O O Return to service of equipment that is placed in an "off normal" configuration for the operating mode? O O O 2 Are all tests to be run concurrent with this SI listed in the instruction? O O O I

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, SI-l Appendix F Attachment 1 08/06/86 OPERABILITY EVALUATION SI NOTE: This evaluation must be completed only if the applicable SI is revised due to a technical inadequac .

Did the technical inadequacy invalidate any part of the previously run SI?

, If so, what part? Could this technical inadequacy be Part 21

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reportable? Is a PRO necessary due to the technical inadequacy? Does the technical inadequacy require the test to be re-run immediately?

If so, has it been scheduled? Does the technical inadequacy require the test to be re-run prior to starting the applicable unit?

If so, has it been scheduled?

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REVIEW IMPLEMENTATION Checksheet review performed by qualified engineer:

- Incorporate output documents from baseline verification As-constructed drawings Design criteria documents System evaluation reports

- Tables from TS and Surveillance Instruction which have been verified by DNE Group leader (manager) to approve review:

Program Manager:

- Verifies checksheet, USQD, revision requests

- Checks for operebility evaluation

- Logs review complete

- Tracks revisions through final PORC review

- Tracks all T.S. related surveillance instructions and supporting procedures Quality Assurance:

- Quality engineering section review all revisions generated anc associated check lists

- Quality surveillance Perform independant review of the output from the surveillance review program Update status on program, weekly to plant manager L _ _ . . . _ . . - _ _ . _ __ _ - . . . . .

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CURRENT STATUS PHASE I Approximately 1,100 procedures:

- Surveillance instructions / supporting procedures

- Tracked estimated 60-70 staff hours each review:

- Review for technical adequacy

- 26 staff years

- 252 re.iews complete as of August 18, 1986 Estimated completion (Unit 2) - October 15, 1986 l

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ASSURANCE OF PROPER IMPLEMENTATION Training in the plent surveillance program:

- Implementing procedures

- Reviewing and approving test performance

- Informing Management of CAQs Perform timely review of test data:

- Ensures equipment operable

- Instruction properly performed

- As found data meets plant requirements Have initiated a process to revise TS

- Clarity

- Remove tables

- Implement SR/SI task force recommendations L

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LOhGER TERM ACTIONS Complete Phase II progtam:

- Writers guide To ensure that program integrity is maintained:

- All future revisions using checklist

- Program for properly implementating T.S. changes

- Trending program

- Identify recurring problems

- Verifying effectiveness of short term corrective actions

- Continued QA involvement in surveillance program l

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SUMMARY Corrective actions developed to address identified problem areas Long term actions to ensure maintenance of SR program Management involvement has been demonstrated:

- Evolutionary

- August 1985 to June 1986 Safety Implications:

- Items from TVA reviews and NRC inspections since April 1986 have been assessed to have no significant safety impact

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