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Insp Repts 50-327/89-09 & 50-328/89-09 on 890305-0405. Violations Noted.Major Areas Inspected:Operational Safety Verification,Including Operations Performance,Sys Lineups, Radiation Protection,Safeguards & Housekeeping Insps
	ML20246K075
Person / Time
Site:	Sequoyah
Issue date:	05/03/1989
From:	Brady J, Jenison K; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	;
Shared Package
ML20246K035	List: ML20246K029; ML20246K044; ML20246K075;
References
	50-327-89-09, 50-327-89-9, 50-328-89-09, 50-328-89-9, GL-81-07, GL-81-7, GL-88-07, GL-88-7, IEB-88-011, IEB-88-11, NUDOCS 8905170237
	Download: ML20246K075 (23)
	v • d • e

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' p ittgv . UNITED STATES

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,N NUCLEAR REGULATORY COMMISSION

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REGION 11

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101 MARIETTA STREET, N.W.

ATLANTA, GEORGI A 30323

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' Report Nos.: 50-327/89-09, 50-328/89-09

Licensee: . Tennessee Valley Authority

6N 38A Lookout Place

1101. Market Square

Chattanooga,,TN 37402-2801

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

Fa'cility .Name: .Sequoyah Units 1 and 2

Inspection Conducted: ' March 5,1989' thru ' April 5,1989

Inspectors: % k

K. Jenison, Senior Resident Inspector

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Date Signed

Inspectors: P. Harmon, Senior Resident Inspector

P. Humphrey, Resident Inspector

D. Loveless, Resident Inspector

Accompanying Personnel: P. Balmain, Reactor Engineer

Approvbd by: -1 A d 4 MJ49'

J 8Brady, . Actf/ig Chief, Project Section 1 Date Signed

TVA Projects Divi.sion

Sum: nary

Scope: This routine n:onthly inspectica by the Resident Inspectors was in the

area of operational safety verification including operations

performance, system lineups, radiction protection, safeguards, and

housekeeping inspections. Other areas inspected included maintenance

observations, surveillance testing observations, ' refueling

activities, review of previous inspection findings, follow-up - of .

events, review of licensee identified items, and review of inspector

follow-up items.

l Results: The licensee's performance in the areas of operational safety

verification, and maintenance and surveillance obser:ations was

generally adequate, except as noted below, and was fully capable of

supporting plant operations. Management participation in the outage

was positive. The area of vendor manual control and validation is of

concern. The radiation protection and security areas were adequate.

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s905170237 890509

PDR ADOCK 05000327

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The licensee had on three occasions failed to establish, implement

and/or maintain procedures. These examples, described below, were

identified as violation 50-327 328/89-09-03.

Failure to establish an adequate slave relay performance testing

procedure which resulted in inadvertent initiation of reactor

trip signals (paragraph 12.a).

Failure to establish adequate procedures to control the

activities affecting the operability and configuration of

tornado dampers resulting in an inadvertent entry into an LCO.

(paragraph 13.b).

Failure to follow procedures relative to maintaining vendor

manuals in a technically adequate status (paragraph 14.b). ]

Two Non-cited vilations were identified:

Erroneous Response Time Test procedure (paragraph 4). l

Introduction of argon gas into the hydraulic actuator bladder

of an UHI valve (paragraph 5.b).

Two unresolved items were identified:

Operability of fan motors for certain ECCS room coolers

(paragraph 2.a). l

Operability of UHI valve with scaffolding interference

(paragraph 5.5).

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REPORT DETAILS

1. Persons Contacted

Licensee Employees

J. Bynum, Vice President, Nuclear Power Production

J. LaPoint, Site Director

S. Smith, Plant Manager

T. Arney, Quality Assurance Manager

R- Beecken, Maintenance Superintendent

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M. Cooper, Compliance Licensing Manager

D. Craven, Plant Support Superintendent

S. Crowe, Site Quality Manager

R. Fortenberry, Technical Support Supervisor

J. Holland, Corrective Action Program Manager

J. Patrick, Operations Superintendent

R. Pierce, Mechanical Maintenance Supervisor

M. Burzynski, Site Licensing Staff Manager

A. Ritter, Engineering Assurance Engineer

R. Rogers, Plant Support Superintendent j

M. Sullivan, Radiological Controls Superintendent i

S. Spencer, Licensing Engineer

P. Trudel, Project Engineer

C. Whittemore, Licensing Engineer }

NRC Attendees

J. Brady, Acting Chief, Projects Section 1, TVA Projects Division

" Attended exit interview

Acronyms and initialisms used in this report are listed in the last

paragraph.

2. Operational Safety Verification (71707)

a. Plant Tours

lhe inspecto"s observed control room operations and reviewed

applicable logs including the shift logs, night order book, clearance

hold order book, configuration log and TACF log. No issues were

identified with these specific logs.

The inspectors also conducted discussions with control room l

operators, verified that proper control room staffing was maintained, ;

observed shift turnovers, and confirmed operability of instruments- l

tion. The inspectors verified the operability of selected emergency

systems, and verified compliance with TS LCOs.

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

buildings, were conducted to observe plant equipment conditions,

including potential fire hazards, fluid leaks, and excessive #

vibrations and plant housekeeping / cleanliness conditions. The plant

was observed to be clean and in adequate condition, The inspectors

verified that maintenance work orders had been submitted as required

and that followup activities and prioritization of work was

accomplished by the licensee.

The inspectors walked down accessible portions of the following

safety-related systems on Unit 1 and Unit 2 to verify operability and

proper valve alignment:

Containment Spray (Unit 1)

Emergency Gas Treatment System (Units 1 & 2)

Upper Head Injection (Units 1 & 2)

Chemical and Volume Control (Unit 1, Train A)

Residual Heat Removal System (Unit 2)

On March 7, 1989 the licensee determined that 13 fan motors from

ECCS room coolers had not been lubricated in accordance with the

licensee's Qualified Maintenance Program approved for meeting the

requirements of 10 CFR 50.49. The program required lubrication

schedules for the motors to be performed by August 19, 1988. On

August 19, 1988, DNE issued a memorandum to plant maintenance

allowing an extension of these dates by three months. Thi s

extension expired for all motors by Decenser 16, 1988.

On March 10, 1989 DNE issued a second tremorandum extending the duc

date for all motors to April 15, 1989. This memo and the associated

review meet the requirements of GL 88-07. The operability of the

motors from the end cf the original extension until the March 10

memo, along with the timeliness of the DNE analysis, will be reviewed

by NRR/ Headquarters EQ group. These items are considered unresolved

and will be tracked as URI 327,328/89-09-01, Motor Lubrication.

No deviations or violations were identified.

b. Safeguards Inspection

In the course of the monthly activities, the inspectors included a

review of the licensee's physical security program. The performance

of various shifts of the security force was observed in the conduct

of daily activities including: protected and vital area access

controls; searching of personnel and packages; escorting of visitors;

badge issuance and retrieval; and patrols and compensatory posts.

In addition, the inspectors observed protected area lighting, and

protected and vital area barrier integrity. The inspectors verified

interfaces between the security organization and both operations and

maintenance. Specifically, the Resident Inspectors:

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1. interviewed individuals with security concerns

2. inspected security during outages

3. visited central and secondary alarm stations

4. verified protection of Safeguards Information

5. verified onsite/offsite communication capabilities

No violations or deviations were identified.

c. Radiation Protection

The inspectors observed HP practices and verified the implementation

of radiation protection controls. On a regular basis, RWPs were

reviewed and specific work activities were monitored to ensure that

the activities were conducted in accordance with the applicable RWPs.

Selected radiation protection instruments were verified operable and

calibration frequencies were reviewed and found acceptable. The

following RWPs and RIR reports were reviewed in detail:

(1) Radiological Work Permits

RWP 89 20250 00 00 Timesheet 25, U-2 Aux. Bldg. pipechases,

charge pump rooms, HX Reoms, Penetration Rooms and UHI.

RWP 89 00108 00 00 Timesheet 3, NRC inspection, all areas,

(2) Radiological Incident Reports

(a) Tne inspector reviewed R. irs 89-20,31,& 33, which documented

an occurrence on February 24, 1989 that involved three

individuals that were found in a C-Zone area and had failed

to sign in on the RWP. However, the individuals were

dressed in the proper protective clothing as required by

the RWP. Immediate corrective actions were taken and the

individuals were removed from the area and disciplinary

actions are pending.

The individuals involved were laborers that were hired by

the licensee for the outage work. Each had received the

General Employee Training designed to inform workers of the

plant rules and safety requirements, specifically those in

area of radiation protection. The incident was attributed

to a failure to follow procedure.

The inspector observed the on scene prompt and adequate

corrective actions taken by the licensee and had no

further questions pertaining to this issue.

No violations or deviations were identified.

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No trends were identified in the operational safety verification area. The

licensee continued to perform plant operations in an adequate manner.

General conditions in the plant were acceptable and conditions identified

by the NRC were promptly resolved by the licensee. Radiation protection

and security are adequate to continue two unit operations.

3. Engineered Safety Features Walkdown (71710)

The inspector verified operability of the Emergency Gas Treatment System

on Units 1 and 2 by completing a walkdown of the systems. Minor drawing

errors were noted and discussed with the licensee. Additionally, the

inspector noted discrepancies between the SOI configuration and the flow

diagram configuration. These were reviewed by the licensee and

corrections to the checklist and drawings will be accomplished.

4. Surveillance Observations and Review (61726)

Licensee activities were directly observed / reviewed to ascertain that

surveillance of safety-related systems and components were being

conducted in accordance with TS requirements.

The inspectors verified that: testing was performed in accordance with

adequate procedures; test instrumentation was calibrated; LCOs were met;

test results met acceptance criteria requirements and were reviewed by

personnel other than the individual directing the test; deficiencies were

identified, as appropriate, and any deficiencies identified during the

testing were properly reviewed and resolved by management personnel; and

system restoration was adequate. For completed tests, the inspector

verified that testing frequencies were met and tests were performed by

qualified individuals.

The following activities were observed / reviewed with no deficiencies

identified except as noted:

SI-60, Automatic Transfer of 6.9 ks Unit Boards With Unit on

Backfeed.

As per SI-94.5 Reactor Trip Instrumentation Refueling Outage Channel

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Calibration (S/G Feedwater Flows), the inspector re/iewed actf vities

in progress, the calibration of the reactor trip instrumentation.

During the process, the inspector noted that precaution 3.1 stated

that "Only one protection set can be functionally tested at any one

time. All other protection set cebinet doors shall be closed." l

However, the inspector noted that in addition to the Protection Set I l

l cabinet doors being open, the Protection Set II cabinet door was also !

open and efforts associated with SI-247.2.921A, Response Time Test,

Containment Sump Level Channel II, were in progress.

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The inspector questioned the technicians and was told that it was

acceptable to have.more than one set of cabinet doors open at a time

while in Mode 6. The test procedure was erroneous in that the pre-

caution was applicable only while the plant was in Mode 1-5 and not

in Mode 6 as mentioned in the procedure. The procedure has been

updated. This item will be tracked as NCV 327,328/89-09-04. The

resolution was . deemed by the inspector to be adequate and the

violation is not being cited because the criteria specified in

Section V.G. of the Enforcement Policy were satisfied.

5. Monthly Maintenance Observations and Review (62703)

Station maintenance activities on safety-related systems and components

were observed / reviewed to ascertain that they were conducted in accordance

with approved procedures, regulatory guides, industry codes and standards,

and in conformance with T.S.

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

while components or systems were removed from service; redundant

components were operable; approvals were obtained prior to initiating the

work; activities were accomplished using approved procedures and were

inspected as applicable; procedures used were adequate to control the

activity; troubleshooting activities were controlled and the repair

records accurately reflected the activities; functional testing and/or

calibrations were performed prior to returning components or systems to

service; QC records were maintained; activities were accomplished by

qualified personnel; parts and materials used were properly certified;

radiological controls were implemented; QC hold points were established

where required and were observed; fire prevention controls were

implemented; outside contractor force activities were controlled in

accordance with the approved QA program; and housekeeping was actively

pursued,

a. Temporary Alterations (TACFs)

The following TACFs were reviewed:

TACF 82-97-87

No violations or deviations were identified.

b. Work Requests

The following work requests were reviewed:

WR B283321 SIS Accumulator Tank #2

WR B783822 MS drair. high level

WR B237670 Lower Compartment Moisture High

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WR B797907 Letdown Relief to th'e PRT

WR B238391 Pressurizer Spray' Temperature

WR B775052 UHI Isolation Valve Accumulator Nitrogen Leak

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On . March 16, 1989, the inspector witnessed licensee efforts to-

identify a nitrogen leak on the Unit 1 UHI isolation valve-

1-FCV-87-24 accumulator. This WR was written to replace either the

whole . accumulator and bladder assembly or the Schrader valve. At-

approximately 9:30 a.m. the licensee determined that nitrogen was

leaking from the accumulator Schrader valve and made the decision to

replace only.the Schrader valve.

i At .10:00 a.m., nitrogen was bled from the accumulator and UHI

isolation valve 1-FCV-87-24 was declared inoperable with the valve

open'. Consequently, Unit 1 entered TS LC0 3.5.1.2 action statement

"a". The existing Schrader valve was removed _ at 10:12 a.m. and

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replaced with a new Schader valve at 10:14 a.m. At approximately

10:15 a.m., precharging of the 1-FCV-87-24 was initiated using a gas

cylinder and precharging rig which had been placed in the Unit 1 UHI

room prior to working WR B-775052. This gas cylinder charged the

1-FCV-87-24 accumulator to approximately 1300 psig and not 1467 psig

-as required' . At approximately 10:30 a.m., the licensee's test

director ordered additional nitrogen cylinders be brought to complete

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precharging. During this time the inspector noted that gas cylinder

No. ICC-3A2015, which was used to precharge the accumulator, was

labeled as argon and not nitrogen as specified. The inspector asked

the licensee's test director why argon had been used instead of

nitrogen. The test director was unaware that argon had been used and

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immediately ordered the maintenance team to bieed the argon from the

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accumulator.

Technical Specification (TS) 6.S.I.a requires that procedures

recommended in Appendix "A" of Regulatory Guide (RG) 1.33, Revision

2, February 1978, be established, implemented, and maintained. This

includes procedures for performing maintenance The requirements of

TS 6.8.1.a are implemented in part by procedures included as work

instructions within work request WR No. B-775052, "UHI isolation

valve accumulator nitrogen leak."

WR No. B-775052, work instruction step 9, required that after

1-FCV-87 24 isolation valve accumulator repair or Schrader valve

installation, a nitrogen (N2) precharge (to 1467 psi) must be

established,

Failure to precharge the 1-FCV-87-24 isolation valve accumulator with

nitrogen as specified in WR B-775052 is a violation of the above

requirements. The licensee reviewed the incident as documented in

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l PQIR-NE-MTB-SQP MM - 89 011 R0, Possible' ' Ef fect of ' Inadvertent

! Introduction of Argon Gas into the Hydraulic Actuator Bladder of

ll UHI Valve 1-FCV-87-24. The' calculations showed that the valve

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would respond similarly with an Argon charge as it would with

a Nitrogen charge. Therefore, it would be categorized as an issue

l' with low safety significance. This item will be tracked as NCV

327,328/89-09-05. This violation is not being cited because the

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criteria specified in Section V.G. of the Enforcement Policy were ,

sati sfi ed.

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All maintenance work as specified in WR B-775052 with the exception

of post maintenance testing was completed at approximately 11:26 a.m.

l- The licensee test director then informed the control room to make

preparations to perform SI-166.6 to verify the operability of

1-FCV-87-24. . Prior to performing SI-166.6, a member of the

maintenance team informed;the test director that a temporary tubular

scaffolding support was installed through the yoke of isolation valve

1-FCV-87-24. in such a way that the shaft to valve stem coupling would

have impinged on the scaffolding support before the valve stroked

fully closed. The test director instructed the maintenance workers to

disassemble the scaffolding and remove the tubu'ar support. The

inspector questioned how long this situation had existed and whether

the valve had been operable during that period of . time. After

removal of the scaffolding the control room was informed-. that

1-FCV-87-24 was clear and SI-166.6 was performed successfully. -At

12:27 p.m. 1-FCV-87-24 was declared operable.

This event is currantly under licensee and vendor review. Following

this review a decision will be made as to the operability of the

valve whfle the scaffolding was attached to it. This item is

unresolved and is identified as URI 327,328/89-09-02.

c. Hold Orchrs

The inspectors reviewed the following H0s to verify compliance with

AI-3, Revision 38, Clearance Procedure, and that the H0s contained

adequate information to properly isolate the affected portions of the

sy: tem being tagged. Additionally the inspectors verified that the

required tags were installed on the affe:ted equipment.

Hold Order Equipment

H0 2-89-416 2RCW Pump Motor, 6.9 KV Shutdown l

Board, 28-B C/8.

H0-1-89-150 1-FCV-1-16, Loop 4 Steam Supply to

TDAFW Pump

No violations or deviations were identified.

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6. Management Activities in Support of Plant Operations

TVA management activities were reviewed on a daily basis by the NRC

inspectors. Resident inspectors observed that planning, scheduling, work

control and other management meetings were effective in controlling plant

activities. First line supervisors appear to be knowledgeable and

involved in the day to day activities of the plant. Management response

to those plant activities and events that occurred during this inspection

period appeared timely and effective. An example of this management action

was the professional and conservative approach to resolution of the

leaking flux thimbles and management response 'to the NRC in plant and

refueling initiatives. ,

7. NRC Inspector Follow-up Items, URIs, Violations (92701, 92702)

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(Closed) VIO 327,328/88-44-02, Failure to Follow IncoN Pmbe Work

Instructions

On September 9, 1988, the licensee reported an incident .. volving the

accidental removal of a Unit 1 incore flux detector from the core during

the performance of troubleshooting and repair activities per WR B296449.

The incident was determined to have resulted from an inadequate

instruction and failure to follow the precautions listed in the

instruction.

The inspector reviewed the licensee's corrective actions implemented to

prevent reoccurrence of the incident which consisted of a new procedure,

MI-13.3.8, Incore Flux Detectors Removal and Installation. The specific

purpose was to provide detailed instruction and precautions for the incore

work activity.

The licensee's corrective actions were determined to be acceptable. This

violation is closed.

(Closed) VIO 327,328/88-29-04, Inadequate Weld and Valve Testing

Procedures

The violation identified two examples of inadequate procedures. The first

example involved the adequacy of TVA general construction specification

G-29, Radiographic Examination on Welded Joints. The second example

involved the adequacy of Technical Instruction TI-89, Inservice

Inspection.

Corrective actions in the first example included the documentation of weld

thickness measurements in the individual work packages in accordance with

procedure SQM-17, General Requirements for Welding, Heat Treatment and

Allied Field Operations at Sequoyah and the performance of inspections on

ten similar welds.

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Corrective actions on the second example included the revision of TI-89 l

and the verification that testing was actually performed under work plans '

WP 6813-01 and WP 12309 for Units 1 and 2 respectively.

The inspector reviewed appropriate portions of the above procedures, work

plans, and test results and had no further questions. The licensee's

corrective actions appear to be adequate. This violation is closed.

8. Licensee Event heport Followup (92700)

UNIT 1

(Closed) LER 327/87012 Loss of Decay Heat Removal Resulting from False

Indications of RCS Level in Sight Glass Due to Debris Accumulation.

This LER described the event of January 28, 1987, during which RHR

suction was lost for a period of 1.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months while the RCS was partially

drained for Steam Generator tube repairs. Operators were maintaining

level in the RCS at elevation 695 feet-6 inches by a sight glass indicator

with remote video monitor displayed in the control room. RHR pump 1A-A

was running in the cold leg recirculation mode with very low decay heat

rates due to the extended shutdown. The RCS level was verified and logged

at 30 minute intervals by the UO. At 1:30 a.m., the VO observed level out

of sight high and directed an AVO to go to containment to verify actual

level in the sightglass. The AVO reported that level was indicating 696

feet-6 inches, 12 inches above normal. The UO began lowering level back

to 695 feet-6 inches at a rate of 30 gpm at 3:30 a.m. At 6:20 a.m., the

running RHR pump began exhibiting signs of cavitating and lost suction.

The pump was immediately stopped and the level was checked, At the time,

level was at 696 feet-4 inches by the sight glass, a change of only 2

inches from the initial level. The UO entered ADI-14, Loss cf RHR

Shutdown Cooling, and began to raise level back up in the PCS. At 7:14

a.m. , maintenance personnel in containment reported to the VO that water

was rising in the S.G. bowl as observed through the open manways. The UO

stopped filling the RCS but the level continued to the point of spillover

from the S.G manways. The water spilled from the manways for

approximately 10 minutes, and was later estimated to be a spill of

approximately 500 gallons. At 7:50 a.m., the 1B-B RHR pump was started and the

loss of RHR event terminated.

After regaining RHR shutdown cooling, operators flushed the sight glass

connection and saw some suspended solid-type debris flushed from the

connection. RCS water level was then raised and lowered to verify correct

operation of the sight giass.

Although 1.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months elapsed before RHR cooling was reestablished, RCS

temperature increased only 20 degrees, from 95 to 115 degrees. The root

cause of this event was determined to be a partially plugged sight glass

connection which caused the UO to change level resulting in both the loss

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of suction to the RHR pump, and the subsequent spill when he tried to

recover. No equipment damage, loss of shutdown margin, or personnel

contamination or injury resulted from this event. The licensee instituted

corrective action to add a redundant level indicator in the form of c

Tygon hose connected to another RCS loop, and will also periodically

flush the indicator connections. In addition, procedures were revised to

add details of the elevation of pertinent design features, and the approx-

imate gallons per inch between those features. The corrective actions are

considered adequate to krevent recurrence of this event.

This LER is closed.

9. NRC Bulletins and Generic Letters (92703) l

IEBs and GLs are documents issued by the NRC which require certain specific

actions of the addressee. The inspector has reviewed the actions taken by

the licensee as a response to the IEB and GL listed below. The inspector

verified that: the licensee had performed the specific actions required by

the bulletin; corrective actions appeared appropriate; generic

applicability had been considered; licensee had reviewed the event and

that appropriate plant personnel were knowledgeable; no unreviewed safety

questions were involved; and that violations of regulations or TS

conditions did not appear to occur.

(Closed) Generic Letter 81-07, Control of Heavy Loads. The inspector

reviewed Generic Letter 81-07 and discussed the issues with Mr. K. Sang

of NRR. Based on the NRC Safety Evaluation Report dated March 26, 1985,

" Control of Heavy Loads," the NRC staff has concluded that the issue as

it relates to the Sequoyah is closed.

(0 pen) IEB 88-11, Pressurizer Surge Line Thermal Stratification. On March

3,1989 the inspector observed inspections of the pressurizer surge line

performed by the licensee under SMI-0-68-4, Examination of the Reactor

Coolant System Pressurizer Surge Lines. Additionally, the inspector

independently verified certain measurements taken as a result of the

bulletin. The inspector did not identify any deficiencies. NRR review

of the licensee's submittal on this bulletin remains open.

10. Cold Weather Preparations (71714)

Through several inspection periods, the inspectors reviewed the licensee's

program of protective measures for extreme cold weather as proceduralized

in GOI-6, Freeze Protection. The inspector verified that the licensee

was inspecting systems susceptible to freezing to ensure the presence of

heat tracing, space heaters, and/or insulation; the proper setting of

thermostats; and that the heat tracing and space heating circuits have

been energized. These inspections were performed by the licensee on a

weekly basis throughout periods of freezing temperatures.

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No violations or deviations were noted. This inspection activity is

closed and will be performed again at the onset of freezing temperatures.

11. Temporary Instructions

(Closed) TI 2515/94, Inspection for Verification of Licensee Changes Made

to Comply with PWR Moderator Dilution Requirements, Multi-Plant Action

Item B-03.

The inspector reviewed this item and determined that it was not applicable

to the Sequoyah Nuclear Plant.

This item is closed.

12. Event Follow-up (93702)

a. The inspector reviewed two incidents that occurred on March 25, 1989,

at Unit 2 while it was in cold shutdown for refueling which resulted

in an SI/ Reactor trip signal initiation during the performance of

IMI-99, RT-601A, Rev. 6, Response Time Testing Engineered Safety

Features Actuation Slave Relays (K601, K620, K-621). Both incidents

resulted from the failure to reset permissives P-11 and P-12 when

returning the SSPS to normal upon completion of the response time

testing. The first incident occurred when the SSPS was returned to

service after Seing taken out for the test and a trip signal was made

up through a pressurizer low pressure. The second signal was initi-

ated as a result of a low Tave and an indicated high steam flow. The

high steam flow signal was initiated when the bistable for one steam

transmitter was tripped for backfilling and a second steam flow

transmitter drif ted upward and indicated a high steam flow. The

upward drif t was caused by the changing conditions in the system.

During a review of the prccedure RT-601A, it was determined that no

requirement for resetting the permissives existed and this resulted

in the two trip signal initiations. T.S. 6.8.1, Procedures and

Programs, requires that written procedures be established, imple-

mented and maintained for certain activities including maintainenance l

and testing. Contrary to this requirement, the procedure used in

performance of the testing of the slave relays, IMI-99, RT-601A,

Rev. 6 was inadequate as evidenced by the initiation of the reactor

trip signals as descrf bed above. This issue is identified as an

example of VIO 327,328/89-09-03 for failure to nave an adequate test

procedure.

b. During turbine generator maintenance activities, the licensee

identified indentations on some of the turbine blades and suspected

it to be erosion-induced porosity. The vendor was contacted through

a technical response request and after analyzing the blades, made

the determination that -the indentations were casting markings and

that the blades were acceptable to use-as-is.

The licensee's actions appear to be adequate.

- _ _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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c. During the refueling outage for Unit 2, the incore flux thimbles were

inspected by an eddy current technique. As a result, 16 thimbles

were replaced. Following replacement, new high pressure seals were

installed by the vendor.. When the RCS .was refilled, leaks were

identified on six of the new seals. Plant management decided to

drain down the RCS and inspect the new seals rather than re-torque as

recommended by the vendor. The inspection revealed minor scratches

and other physical indications at the seal areas of each of the six

leaking thimbles. These indications were removed and new seals

installed. After refilling the RCS, the seals were hydrostatically

tested to approximately 400 psig without any indication of leaks.

The licensee's actions to resolve the problem appeared to be both

prudent and conservative.

,

13. Refueling Activities (60710)

a. .The inspector continued to monitor the . Unit 2, cycle 3 outage

activities. Plant management was involved in the day to day plant

activities. Management was observed to be technically ' competent and

their decisions did not sacrifice quality to meet schedules. Based on

those activities. reviewed, the inspector. judged management's

participation in the outage to be very positive. In addition,

management was found to be very responsive to NRC initiatives. j

Surveillance activities were reviewed on a regular basis and were ,

.found to be in compliance with TS requirements. Of those reviewed,

strict procedure compliance was observed in all instances' except as

noted in NCV 327,328/89-09-04. However, based on the number of ;

surveillance observed, overall performance was determined to be '

acceptable.

The inspector witnessed day to day involvement by the Quality Control

personnel in various plant activities and reviewed documented !

inspection results and their dispositions to verify that the quality

assurance program was effective. It was concluded that these programs

were properly implemented and were effective.

Fuel handling was reviewed and was determined to be weak in the

area of refueling operation. The handling equipment appeared to be

marginally adequate for the operation and various interlocks were l

by passed. This also contributed to the incident during which the i

fuel transfer cart was bent in the upender and the issuance of I

VIO 327,328/89-07-01. However, during core loading, the

inspector verified that continuity was maintained between the fuel

and excore monitors, communication with the control room was

maintained, fuel accountability methods were established, and TS

requirements implemented and that this part of the operation was

performed in an acceptable manner.

-__ _ _ _ _ -__-_-____ _ _ _ __- - __ - - _____--_-__-__________--___- - -_-- _ ___ _ _ __-_ _

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j. In general, radiation contamination was kept to a minimum with work

! areas and personnel being closely monitored. Radiological controls

were in place for the various activities and measures were imple-

,

mented to insure compliance. However, some problems were experienced

with airborne radiation resulting from improper installation of air

'

eductors to the RCS and the use of portable vacuum systems with

missing filters. These problems were identified and were corrected

early in the outage and resulted in the improvement of airborne

contamination conditions.

>

Radiation protection was determined to ' be carried out in an

acceptable manner.

Housekeeping was sufficiently maintained in the thoroughfare areas.

However, work areas, specifically the RHR pump and heat exchanger

rooms, were not maintained at the same high standard during the

outage. This was brought to the attention of the maintenance

superintendent and immediate corrective actions were taken. Overall

housekeeping conditions improved to an acceptable level in these

areas.

The inspector determined that the training and staffing of plant

personnel was adequate for the outage activities.

In summary, refueling activities were determined to be adequately

performed. Management appeared knowledgeable of the plant status at

all times and activities were conducted in a safe and responsible

manner.

b. The inspector reviewed the incident involving closure of the two

tornado dampers that occurred on March 20, 1989, which placed the

plant in a Limited Condition of Operation for a period of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and

20 minutes without the condition being recognized by the operating

personnel. The dampers were closed to accommodate replacemer;t of ,

smoke detectors 0-XS-31A-3 and 0-XS-31A-4 that are located in the

ducts that supply suction for the ccntrol building pressurizing fans.

Operations personnel did not realize that closing the tornado dampers

rendered both trains of the control room emergency ventilation system

inoperable. With both trains inoperable. the action statement for

LCO 3.7.7 could not be met and therefore LCO 3.0.3 was applicabic.

The dampers were closed at 8:30 a.m. on March 20, 1989. The condi-

tion was discoverec' and the dampers were reopened at 2:50 p.m. on the

same day. The time limits for LCO 3.0.3 would have been exceeded if

the condition had continued for an additional 40 minutes.

The craft workers related the problem of replacing the smoke

detectors with high air flow in the ducts. The ASOS reviewed the

applicable ventilation drawings and determined that the suction to

the duct could be isolated by closing the tornado dampers. Handswitch

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0-HS-31A-180A, which would be utilized to close and isolate the duct,

identified that power to the switch was supplied from vent board

1Al-1. Upon reviewing the vent board, a placard was found on the door

of the tornado damper control transformer whi:h stated; " breaker

normally open per 501-30.7 reference SCR SQNIIG86136." The ASOS

reviewed S01-30.7, Onsite Electrical Power Systems Board Rooms

Heating, Venting, anr.' Cooling , and found nothi ng related to the

dampers to prevent their closure. In cddition, 50I-30.1, Control

Building and Control Room Heating, Air Conditioning and Ventilation

System, was reviewed which required the normal breaker position to be

open. Review of the SOI revealed that no warnings were included to

prevent breaker closure to allow operation of the handswitch and

closure of the dampers.

1

At that time, the AS0S closed the dampers which resulted in isolating

the suction of the control room pressurizing fans. This was not

realized until 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and 20 minutes later and the plant was in

LCO 3.0.3.

This issue resulted from inadequate procedures, S0I-30.1 and

S01-30.7, that failed to address the necessary precautions to prevent

the incident stated above. T.S. 6.8.1, Procedures and Programs,

requires that written procedures be established, implemented and

maintained for certain activities including maintenance. Contrary to

this requirement, procedures to control the activities affecting the

operability and configuration of the tornado dampers were not

adequate as evidenced by the inadvertent entry into LCO 3.0.3. This

is identified as a second example of VIO 327,328/89-09-03 for failure

to have an adequate procedure.

c. An RCS water spill of approximately 45 gallons from the number 3

steam gent:rator plenum was experienced during the Unit 2 Cycle 3

Outage. This resulted from the failure of the sump pumps placed in

the S/G plenums to operate and remove the leakage emitted from the

nozzle dams during S/G tube testing. The pump failures arose from a

cross wiring problem that resulted in starting the hot leg sump pump

when the cold leg plenum reached a high level and vice versa. A

functional test of this equipment, supplied by the Westinghouse

Company, failed to expose the problem since all visual inspections

indicated the control box to be normal.

Immediate corrective actions were taken by the licensee to clean the

spill and to correct the wiring problem. The inspectors were

notified and the incident was reviewed. Based on the immediate

response of the licensee and the low degree of safety significance,

the inspector had no further questions.

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14. Plant Startup from Refueling (71711)

a. The inspector walked down the accessible portions of the Residual

Heat Removal System during the Unit 2, cycle 3 refueling outage to

determine the adequacy of flow diagram drawing, 1,2,47W810-1, to

evaluate the licensee's configuration control, and to determine the

overall condition of the system. Results of the walkdown revealed

certain drawing discrepancies. Instruments shown to be physically

located in the RHR pump rooms were actually outside the rooms. Also,

valve leak-off lines, associated with valves74-524,526,527, and 529

located inside the RHR heat exchanger rooms, returned to the piping

system at a location other than that shown on the drawing. These

drawing deficiencies were of minor safety significance. However,

the licensee is reviewing these drawings to make the necessary

corrections.

Some housekeeping deficiencies were identified in the RHR pump rooms

at a time when plant outage cleanup was in progress. This item was

brought to the attention of the licensee. In particular, the pump

rooms were dirty, equipment had been left in the rooms, a rubber hose

was left lying on the floor, and water was found running across the

floor from the cooler. This information was given to the licensee and

immediate corrective actions were taken. The area was again reviewed

by the inspector and was found to be clean,

b. A review of the historical activities on Residual Heat Removal valve,

2-FCV-74-2 (14" Copes-Vulcan gate valve with Limitorque Operator) was

performed during this inspection period to determine the

acceptability of this valve for its intended function. Work

requests and surveillance initiated during the past two years

accounted for a major portion of the review. The work requests

reviewed included those that had been completed and those that remain

outstanding and are listed as follows: !

WR Date

Number Initiated Status Subject

8210787 12-23-86 Closed Clean boron and adjust i

packing

B217092 12-22-86 Closed Replace electrical splices

B217532 12-22-86 Closed Replace splice for cable

B210784 1-30-87 Closed Clean boron from bonnet and

stud bolts

B219733 1-27-87 Closed Replace in line splices

B211064 4-27-87 Closed Clean boron from valve

external

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B203732 10-03-87 Closed Clean exterior valve surface

of boron

B288251 11-03-87 Open Disassemble and repair

B203736' 8-16-88 0 pen- Repair or replace backseat

No entries were found in ' the trending program relative to valve

2-FCV-74-2. ~However, the inspector determined that on four separate

occasions, work orders were generated to have boron residue cleaned

from this valve during a 10 month time frame. Once the valve was

disassembled to replace packing, it was determined that the cause of

the leaks was a result of a gouge in the stem. This issue was

reviewed with the system engineer who was of the opinion that valve

cleaning work requests should not be a part of the trending program.

The inspector asked that the issue be reconsidered to which the

licensee agreed.

WR package, B288251, was lost during the administrative review cycle

by the licensee and therefore created a problem in the work

verification process. WR B203736 was initiated to substantiate

acceptability of work performed under the lost WR package and to

repair backseating problems with the valve. However, work on the

replacement WR was not performed until approximately one year later

and at that time the valve and bonnet were replaced because the valve

mating surface to the bonnet was less than the standard size.

The inspector noted that the work request instructions for the valve

operator did not totally agree with those published in the controlled

copy of the vendor's manual. The lubrication materials specified in

the manual were not correct.

The plant controlled vendor's manual for this valve specified a

requirement to lubricate the valve drive sleeve top bearing every six

months. The plant schedule was to lubricate this area during each

!- refueling outage (eighteen months). Further review into this area

revealed that the maintenance schedule had been implemented from a

different vendor manual. However, this different vendor manual had

not been included in the controlled copy of the vendor manual

utilized for the subject valve.

Sequoyah Engineering Procedure, SQEP-39, Review and Approval of

Vender Manuals / Revisions, was established by the licensee to control

vendor input and insure that vendor manuals reflected complete

information for the equipment specified. Section 3.1 requires the

Discipline Lead Engineer to provide the technical review of new

vendor manuals and vendor proposed revisions to ensure applicability

to the component level where appropriate and verify vendor manual

completeness. Two areas in specific to be utilized in the guide-

line for vendor manual review are periodic testing schedules

L_____ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ . . _ _ _ _ _ _ . _ _ _ _ _ _ . _ _ . _ _ ___ ___._______________o

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and lubrication requirements. Contrary to SQEP-39, Work Package WP

B203736 specified a lubrication, Neo Lube Dag 156, which was not on

the approved lubrication listed in Copes-Vulcan Vandor Manual for the

subject valve. The licensee stated that the Limitorque manual

supplied as part of the vendor's manual for the 2-FCV-74-2 valve was

a 1971 edition and a 1983 version of the Limitorque manual,

SQN-VTD-W120-3620, is used by the work control group to assemble the

work packages for valves with Limitorque operators.

T.S. 6.8.1, Procedures and Programs, requires that written

procedures be established, implemented and maintained for activities

including maintenance and testing. Failure to maintain the

2-FCV-74-2 vendor manual in a technically adequate status is

contrary to section 3.1 of SQEP-39 and is identified as a thira

example of VIO 327,328/89-09-03 for failure to follow procedures.

This violation is similar to URI 327,328/88-50-07 which was also

associated with vendor manual control and validation problems.

These issues collectively may be indicative of a programmatic

deficiency in the licensee's vendor manual control and validation

process.

c. A review of the historical activities on essential raw cooling water

pump M-B (0-PMP-067-0444 - Johnston Pump Co. Vertical Turbine Pump

Serial No. 1221-1228) was performed during this inspection period to

determine the acceptability of this pump for its intended function.

Work requests and surveillance initiated during the past two years

accounted for a major portion of the review. The work requests

reviewed included those that had been completed and those that remain

outstanding and are listed as follows:

B 283562 - Reduce ptcking leak off to proper amount on ERCW pump

M-B.

B 132009 -

ERCW pump M-B pump packing needs adjusting and/or

replaced.

B 209677 - Adjust ERCW pump M-B packing to stop excessive

leakage.

B 295193 - ERCW pump M-B, Adjust packing.

PM 2806 -

ERCW Pump M-B load shed TDR.

PM 1651 -

Lubricate packing box on ERCW pumps.

The licensee's controlled vendor manual for this pump was reviewed

and determined to be the most recent revision. No deficiencies were

noted during this review.

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15. Exit Interview (30703)

The inspection scope and findings were summarized on April 5,1989, with

those persons indicated in paragraph 1. The Senior Resident Inspector

described the areas inspected and discussed in detail the inspection

findings listed below. The licensee acknowledged the inspection findings

and did not identify as proprietary any of the material reviewed by the

inspectors during the inspection.

Inspector Findings:

(0 pen) URI 327,328/89-09-01, " Motor Lubrication"

(0 pen) URI, 327,328/89-09-02, "UHI Valve Operability with Scaffolding

Interference"

(0 pen) Violation 327,328/89-09-03, " Failure to Establish, Implement

and/or Maintain Procedures"

(Closed) NCV 327,328/89-09-04, " Response Time Test Procedure"

(Closed) NCV 327,328/89-09-05, " Introduction of Argon instead of Nitrogen

into Hydraulic Actuator Bladder of UHI Valve"

(Closed) Violation 327,328/88-44-02, " Failure to Follow Incore Probe Work

Instructions"

(Closed) Violation 327,328/88-29-04, " Inadequate Weld and Valve Testing

Procedures

(Closed) TI 2515/94, " Inspection for Verification of Licensee Changes

Made to Comply with PWR Moderator Dilution Requirements,

Multi-Plant Action Item B-03"

(Closed) LER 327/87-012, " Loss of Decay Heat Removal"

(Closed) GL81-07, " Control of Heavy Loads"

(0 pen) IEB 88-11, " Pressurizer Surge Line Thermal Stratification"

During the reporting period, frequent discussions were held with the Site

Director, Plant Manager and other managers concerning inspection findings.

16. List of Acronyms and Initialisms

ABGTS -

Auxiliary Building Gas Treatment System

ABI -

Auxiliary Building Isolation

l ABSCE -

Auxiliary Building Secondary Containment Enclosure

AFW -

Auxiliary Feedwater

AI -

Administrative Instruction

AGI -

Abnormal Operating Instruction

,

AVO -

Auxiliary Unit Operator

ASOS -

Assistant Shift Operating Supervisor

l

<

ASTM -

American Society of Testing and Materials

BIT -

Boron Injection Tank

BFN -

Browns Ferry Nuclear Plant

C&A -

Control and Auxiliary Buildings

CAQR

-

Conditions Adverse to Quality Report

CCS -

Component Cooling Water System

CCP -

Centrifugal Charging Pump

t

___ _ _ _ _ _ _ _ _ _ _ _ . _ _ . _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _

_ _ _ _ _ _ _ - _ _ _ _ - _ - _ _

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CCTS -

Corporate Commitment Tracking System

CFR -

Code of Federal Regulations

COPS -

Cold Overpressure Protection System

CS -

Containment Spray

CSSC -

Critical Structures, Systems and Components

CVC3 -

Chemical and Volume Control System

CVI -

Containment Ventilation Isolation

DC -

Direct Current

DCN -

Design Change Notice

DG -

Diesel Generator

DNE -

Division of Nucleer Engineering

ECN -

Engineering Change Notice

ECCS -

Emergency Core Cooling System

EDG -

Emergency Diesel Generator

EGTS -

Emergency Gas Treatment System

EI -

Emergency Instructions

ENS -

Emergency Notification System

E0P -

Emergency Operating Procedure

EO -

Emergency Operating Instruction

ERCW -

Essential Raw Cooling Water

ESF -

Engineered Safety Feature

FCV -

Flow Control Valve

FSAR -

Final Safety Analysis Report

GDC -

General Design Criteria

G01 -

General Operating Instruction

GL -

Generic Letter

HVAC -

Heating Ventilation and Air Conditioning

HIC -

Hand-operated Indicating Controller

H0 -

Hold Order

HP -

Health Physics

ICF -

Instruction Change Form

IDI -

Independent Design Inspection ,

'

IN -

NRC Information Notice

IFI -

Inspector Followup Item

IM -

Instrument Maintenance

IMI -

Instrument Maintenance Instruction

IR -

Inspection Report i

KVA -

Kilovolt-Amp

KW -

Kilowatt j

KV -

Kilovolt !

LER -

Licensee Event Report l

LCO -

Limiting Condition for Operation l

LOCA -

Loss of Coolant Accident

MCR -

Mair. Control Room

MI -

Maintenance Instruction

MR -

Maintenance Report

MSIV -

Main Steam Isolation Valve

NB -

NRC Bulletin

_ _ _- - _ - _-_ -_ _ __-_.

_ _ _ _ - _ - _ _ _ _ _ _

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NCV -

Non-cited Violations

NQAM

-

Nuclear Quality Assurance Manual

NRC -

Nuclear Regulatory Commission

OSLA -

Operations Section Letter - Administrative

OSLT -

Operations Section Letter - Training

Pl S -

Precautions, Limitations, and Setpoints

PM -

Preventive Maintenance

PPM -

Parts Per Million

PMT -

Post Modification Test

PORC - Plant Operations Review Committee

PORS -

Plant Operation Review Staff

PRO -

Potentially Reportable Occurrence

QA

-

Quality Assurance

QC

-

Quality Control

RCDT -

Reactor Coolant Drain Tank

RCP -

Reactor Coolant Pump

RCS -

Reactor Coolant System

RG -

Regulatory Guide

RHR -

Residual Heat Removal

RIR -

Radiological Incident Report

RM -

Radiation Monitor

RO -

Reactor Operator

RPI -

Rod Position Indication

RPM -

Revolutions Per Minute

RTD -

Resistivity Temperature Device Detector

RWP -

Radiation Work Permit

RWST -

Refueling Water Storage Tank

SER -

Safety Evaluation Report

SG -

Steam Generator

SI -

Surveillance Instruction

SMI -

Special Maintenance Instruction

501 -

System Operating Instructions l

SOS -

Shift Operating Supervisor i

SQM

-

Sequoyah Standard Practice Maintenance

SQRT

-

Seismic Qualification Review Team ,

SR -

Surveillance Requirements !

SRO -

Senior Reactor Operator

SSOMI -

Safety Systems Outage Modification Inspection

SSQE

-

Safety System Quality Evaluation .

SSPS -

Solid State Protection System ]

STA -

Shift Technical Advisor i

STI -

Special Test Instruction

TACF -

Temporary Alteration Control Form >

TAVE -

Average Reactor Coolant Temperature I

TDAFW -

Turbine Driven Auxiliary Feedwater

TDR -

Time Delay Relay

TI -

Technical Instruction

TREF -

Reference Temperature

TROI -

Tracking Open Items j

l

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TS -

Technical Specifications

TVA -

Tenr.essee Valley Authority

UHI -

Upper Head Injection

UD -

Unit Operator )

'

URI -

Unresolved Item

USQD -

Unreviewed Safety Question Determination

VDC -

Volts Direct Current

VAC -

Volts Alternating Current

WCG -

Work Control Group

WP -

Work Plan

WR -

Work Request

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ - _ - - - - - _

ML20246K075

Text

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