ML20199L344
| ML20199L344 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 04/01/1986 |
| From: | Harmon P, Jenison K, Linda Watson, Weise S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20199K437 | List: |
| References | |
| 50-327-86-15, 50-328-86-15, IEIN-86-004, IEIN-86-4, NUDOCS 8604100353 | |
| Download: ML20199L344 (12) | |
See also: IR 05000327/1986015
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SS REcg UNITED STATES
o NUCLEAR REGULATORY COMMISSION
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ATL ANT A, GEORGI A 30323
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Report Nos.: 50-327/86-15, 50-328/86-15
Licensee: Tennessee Valley Authority
6N38 A Lookout Place
1101 Market Street
Chattanooga, TN 37402-2801
Docket Nos.: 50-327 and 50-328 License Nos.: DPR-77 and DPR-79
Facility Name: Sequoyah Units 1 and 2
Inspection Conducted: February 6 - March 5, 1986
Inspectors: M I 2__ T at Signed b
K. M. Jenison, denior KsidfiPE Inspector
L!&J. ilatsog, esident[spe[orJ~ Ae/f% Da't'e' Si g ned
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. Harmen, w de t 'In
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Approved by: . ,- 4 Mb / h
S. P. Weise, Section Chief Date Signed
Division of Reactor Projects
SUMMARY
Scope: This routine, announced inspection involved 265 resident inspector-hours
onsite in the areas of: operational safety verification (including operations
performance, system lineups, radiation protection, safeguards and housekeeping
inspections); surveillance and maintenance observations; review of previous
inspection findings; followup of events; review of licensee identified items;
review of IE Information Notices; and review of inspector followup iterrt.
Results: One violation (failure to comply with Technical Specification 6.2.3,
Independent Safety Engineering Group) was identified.
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REPORT DETAILS
1. Licensee Employees Contacted
H. L. Abercrombie, Site Director
- P. R. Wallace, Plant Manager
- L. M. Nobles, Operations and Engineering Superintendent
- B. M. Patterson, Maintenance Superintendent
- J. M Anthony, Operations Group Supervisor
- R. W. Olson, Modifications Branch Manager
M. R. Sediacik, Electrical Section Manager, Modifications Branch
H. D. Elkins, Instrument Maintenance Group Manager
C. W. LaFever, Instrument Engineering Supervisor
M. A. Scarzinski, Electrical Maintenance Supervisor
- M. R. Harding, Engineering Group Manager
- D. C. Craven, Quality Assurance Staff Supervisor
D. L. Cowart, Quality Surveillance Supervisor
- D. E. Crawley, Health Physics Supervisor
- G. B. Kirk, Compliance Supervisor
M. L. Frye, Compliance Engineer
H. R. Rogers, Compliance Engineer
- R. C. Burchell, Compliance Engineer
- E. W. Whitaker, Licensing Engineer
D. H. Tullis, Mechanical Maintenance Group Supervisor
J. H. Sullivan, Regulatory Engineering Supervisor
C. E. Chmielewski, Nuclear Engineer, NSS
Other licensee employees contacted included technicians, operators, shift
engineers, security force members, engineers and maintenance personnel.
- Attended exit interview.
2. Exit Interview
The inspection scope and findings were summarized with the Plant Manager and
members of his staff on March 10, 1985. The licensee acknowledged the
inspection findings. The licensee did not identify as proprietary any of.
the material reviewed by the inspectors during this inspection. During the
reporting period, frequent discussions were held with the Site Director,
Plant Manager and other managers concerning inspection findings. At no time
during the inspection was written material provided to the licensee by the
inspectar.
3. Licensee Action on Previous Inspection Findings (92702)
(Closed) Unresolved Item 328/81-34-01. The unresolved item concerned the
control of system lineup with the System Operating Instructions (SOIs)
during preoperational testing. The licensee implemented a configuration
control program which controls valves by tagging if the valve is placed in a
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configuration other than that prescribed by the SOI. In addition, S0Is have
been reviewed to assure the accuracy of the valve listings. This item is
closed.
(Closed) Violation 328/82-31-01. This item was closed for Unit 1 in NRC
Inspection Report 327,328/84-34. The inspector reviewed the licensee's
response of February 1,1983. The licensee maintains positive control of
health physics training and determination of occupational dose by requiring
completion of these requirements prior to issuance of dosimetry. Personnel
entering the Auxiliary Building and Control Building are checked by security
personnel for dosimetry and proper placement of the dosimetry prior to
entrance. This item is closed.
(Closed) Violation 327,328/84-01-01. The inspector reviewed the licensee's
response dated March 15, 1984. An audit of the review cycle was conducted
and it appeared to be adequate. This item is closed.
(Closed) Violation 327/85-17-02. The inspector reviewed. the licensee's
response dated August 28, 1985. The licensee's efforts in the area of
Radiation Work Permit adherence have been audited by the inspector. This
item is closed.
(Closed) Violation 327,328/85-26-11. The inspector reviewed the licensee's
response dated October 7,1985. An audit of the licensee's identification
of items requiring Maintenance Request initiation was conducted. This item
is closed.
(Closed) Violation 327,328/85-32-01. The inspector reviewed the licensee's
response dated November 26, 1985. A review of subsequently completed
surveillances was conducted. This item is closed.
(Closed) Violation 328/85-35-01. The inspector reviewed the licensee's
response dated January 9, 1986. The licensee's corrective actions appear to
be adequate. The licensee's commitment date of April 1, 1986, for revision
of SI-1 will be reviewed under Inspector Followup Item 327,328/86-15-01.
This item is closed.
(Closed) Violation 327,328/85-23-02. The inspector reviewed the licensee's
response dated August 29, 1985. A revised response to violation
327,328/83-31-01 was submitted on September 9, 1985, deleting the commitment
for checks of key card records. This item is closed.
(Closed) Violation 327,328/85-23-03. The inspector reviewed the licensee's
response dated August 29, 1985. Observations of individuals over the past
six months have indicated that personnel are properly displaying picture
badges. This item is closed.
(Closed) Violation 327,328/85-26-03. The inspector reviewed the licensee's
responses dated October 7, 1985, and January 3, 1986. Corrective steps
identified in the responses have been verified. The inspector has reviewed
the QA audits of surveillances for personnel dosimetry and frisking. These
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audits indicate an improvement in these areas. The licensee's audits for
strict compliance to health physics practices has improved and the inspector
has noted an increased awareness among plant personnel of proper placement
of dosimetry and frisking te:hniques. This item is closed.
4. Unresolved Items
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Unresolved items are matters about which more information is required to
determine whether they are acceptable or may involve violations or
deviations. No unresolved items were identified during this inspection.
5. Operational Safety Verification (71707)
a. Plant Tours
The inspectors observed control room operations, reviewed applicable
logs, conducted discussions with control room operators, observed shift
turnovers, and confirmed operability of instrumentation. The
inspectors verified the operability of selected emergency systems,
reviewed tagout records, verified compliance with Technical
Specification (TS) Limiting Conditions for Operation (LCO) and verified
return to service of affected components. The inspectors verified that
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maiatenance work orders had been submitted as required and that
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followup activities and prioritization of work was accomplished by the
- licensee.
Tours of the diesel generator, auxili a ry , control, and turbine
buildings and containment were conducted to observe plant equipment
conditions, including potential fire hazards, fluid leaks, and
excessive vibrations and plant housekeeping / cleanliness conditions.
One concern was identified regarding the connection of scaffolding to
the ERCW supply to the IB-B Auxiliary Feedwater pump. The inspect'n'
discussed the concern with the licensee and will verify removal of the
scaffolding prior to startup.
The inspectors walked down accessible portions of the following
safety-related systems on Unit I and Unit 2 to verify operability and
proper valve alignment:
Residual Heat Removal System (Units 1 and 2)
Diesel Generator 1A-A and 1B-B Air Start System, ERCW Supply
and Fuel Oil System (Units 1 and 2)
Auxiliary Control Air (Units 1 and 2)
125 VDC Vital Battery Boards and Vital Batteries
120 VAC Vital Instrument Power Boards
The inspector observed security and health physics activities for
movement of new fuel casks into the protected area.
No violations or deviations were identified.
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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, packages and vehicles; patrols and compensatory
posts; badge issuance and retrieval; and escorting of visitors. In
addition, the inspectors observed protected area lighting, protected
and vital areas barrier integrity and verified the interface between
the security organization and operations and maintenance. The
inspectors visited the central alarm station and interviewed security
personnel regarding the concern identified below.
During the inspection period the inspector identified concerns
regarding crowding and searches at the control point to the protected
area. These concerns were discussed with the licensee and additional
administrative controls have been implemented. Additional training has
also been conducted for security personnel controlling access. The
inspector has observed activities at the control point and determined
that ' improvements have been made in these areas. The inspector will
continue to monitor these controls during routine security inspections.
No violations or deviations were identified.
c. Radiation Protection
The inspectors observed Health Physics (HP) practices and verified
implementation of radiation protection control. On a regular basis,
radiation work permits (RWPs) were reviewed and specific work
activiti were monitored to assure the-activities were being conducted
in accordance with applicable RWPs. Selected radiation protection
instruments were verified operable and calibration frequencies were
reviewed.
On January 15, 1986, the licensee determined that cracks in the walls
of the condensate demineralizer waste evaporator (CDWE) building were
allowing seepage of radioactive water into a non-regulated area. An
NRC specialist reviewed this event and the results of the inspection
are provided in NRC Inspection Report 327,328/86-06. In addition to
the radiclogical aspects of the inspection, several concerns were
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raised regarding maintenance of the evaporator recirculation pumps and
COWE ventilation. These items will be identified for resident
inspector followup as Inspector Followup Item 327,328/86-15-02.
No violations or deviations were identified.
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6. Engineered Safety Features Walkdown (71710)
The inspector verified operability of the Emergency Diesel Generators (EDGs)
on Units 1 and 2 by conducting a partial walkdown of the EDGs. This
walkdown will be completed in the next inspection period. The following
specifics were reviewed and/or observed as appropriate:
a. that the licensee's system lineup procedures matched plant
drawings and the as-built configuration;
b. that equipment conditions were satisfactory and items that might
degrade performance were identified and evaluated (e.g. hangers
and supports were operable, housekeeping etc, was adequate);
c. with assistance from licensee personnel, the interior of the
breakers and electrical or instrumentation cabinets were inspected
for debris, loose material, jumpers, evidence of rodents, etc;
d. that instrumentation was properly valved in and functioning, and
calibration dates were appropriate;
e. that valves were in proper position, breaker alignment was
correct, power was available, and valves were locked as required;
and
f. local and remote instrumentation was compared, and remote
instrumentation was functional.
Several concerns involving minor leakage in the air start system, support of
the local gauges for the air receiver tanks, failure to include one drain
valve on the ERCW cooling water checklist, and one hanger discrepancy were
identified to the licensee for corrective action. These items will be
followed under Inspector Followup Item 327,328/86-15-03.
No violations or deviations were identified.
7. Monthly Surveillance Observations (61726)
The inspectors observed Technical Specification (TS) required surveillance
testing and verified that testing was performed in accordance with adequate
procedures; that test instrumentation was calibrated; that Limiting
Conditions for Operation were met; that test results met acceptance criteria
and were reviewed by personnel other than the individual directing the test;
that deficiencies were identified, as appropriate; that any deficiencies
-identified during the testing were properly reviewed and resolved by
management personnel; and that system restoration was adequate. For
complete tests, the inspector verified that testing frequencies were met and
tests were performed by qualified individuals. - . .
The inspector witnessed / reviewed portions of the following surveillance test
activities:
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SI-120 Diesel Generator Monthly Electrical Inspection
SI-7 Electrical Power Systems: Diesel Generators
SI-8 Boric Acid Flow Paths - Temperature Verification
SI-16 BIT Heat Tracing
GOI-6H System Apparatus
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No violations or deviations were identified.
8. Monthly Maintenance Observations (62703)
a. Station maintenance activities of safety-related systems and components
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were observed / reviewed to ascertain that they were conducted in
!' accordance with approved procedures, regulatory guides, industry codes
and standards, and in conformance with TS.
The following items were considered during this review: LCOs met while
components or systems were removed from service; redundant components
a operable; approvals obtained prior to initiating the work; activities
accomplished using approved procedures and inspected as applicable;
procedures adequate to control the activity; troubleshooting activities
controlled and the repair record accurately reflected what actually
took place; functional testing and/or calibrations performed prior to
returning components or systems to service; quality control records
maintained; activities accomplished by qualified ' personnel; parts and
materials used properly certified; radiological controls implemented;
QC hold points established where required and observed; fire prevention.
controls implemented; outside contractor force activities controlled in
accordance with the approved Quality Assurance (QA) program; and
housekeeping actively pursued.
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b. The inspector reviewed a modification to the control circuits for
containment isolation valves 1-FCV-30-15 and 1-FCV-30-56 implemented to
comply with environmental qualification requirements. The
modifications relocated a diode and resistor from potentially harsh
environments inside containment to the control room. The inspector
noted that one jumper was installed with the letter designation
transposed. The licensee corrected the error. The inspector verified
that the circuit was installed in accordance with drawings 45N1648-5,
Rev. 18 and 45N1648-3, Rev. 18 and mounting detail 47A348-284. The
inspector also observed QC review of holdpoints. No violations or
deviations were identified.
c. The inspector reviewed a modification to reactor protection set I
- involving reroute of potentially submerged cables for the hot leg and
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cold leg RTDs. The inspector reviewed WP 11896, ECN L6533 and drawing
45N1661-2, Rev. 5. The licensee identified that although the wiring
connections had been made correctly, the wiring connections had been
made using the wire numbers and not considering wire colors on the
outboard cable to the instrument board cabinet. In order to assure
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that color coding dces not affect future work on the circuit, the
licensee is modifying the connections to also match wire colors. The
inspector observed the QC review of holdpoints. No violations or
deviations were identified.
d. The inspector reviewed installation of the remote operators for the
Main Steam pressure operated relief valves (PORVs). The remote
operators were installed to assure that the PORVs could be operated in
the event of a fire in the steam vaults. Work Plans (WPs) 11714
(Unit 1) and 11715 (Unit 2) were reviewed. The inspectors noted during
a walkdown of the installation that the remote handwheel open/close
permanent indication had been marked in pencil to indicate th2: the
handwheel should be operated in the opposite direction. Interviews
with +he cognizant engineer indicated that the post modification test
has not been completed. The cognizant engineer was not aware of the
pencil markings but stated that the indication would be verified for
proper labeling. The engineer indicated that two operator extensions
were being redesigned to provide appropriate seismic support. Seismic
qualification and verification of the operator instructions for valve
operations will be reviewed prior to startup. No violations or
deviations were identified,
f e. On January 16, 1986, during post modification NDE examinations, the
licensee determined that two 2 inch tees welded into the CVCS piping at
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the boric acid transfer pumps were cracked. Followup on procurement
and issuance of material and reportability under Part 21 is identified
as Inspector Followup Item 327,328/86-15-04.
f. During this inspection report period the licensee performed a
modification to the reactor trip breakers on both Unit I and 2. The
modification involved the placement of a shunt coil in parallel with
the already installed undervoltage coil. This modification was
accomplished by installing a rotary type interposing relay between the
trip breaker undervoltage coil circuit and the shunt trip coil circuit.
The installed interposing relay is energized from the Solid State
Reactor Protection System in parallel with the undervoltage coil
resulting in the trip bar of the breaker being actuated by both coils.
The reactor trip bypass breakers did rot receive a similar
modification. The modification process was observed by the inspectors
and the following documents were reviewed:
Work plan 11691, 9418, 11762
M ana AI - 7, Cable Terminations, Splicing and Repairing Damaged
Cables
Vendor Instructions 6848056 and 072584
Engineering Change Notices L5458, L6293
Field Change Notice TVA-0-40559
Hold Order 1109
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During the performance of this modification one practice was questioned
with respect to industrial safety practices and discus:ed with licensee
management.
No violations or deviations were identified.
9. Licensee Event Report (LER) Followup (92700)
The following LERs were reviewed and closed. The inspector verified that:
reporting requirements had been met; causes had been identified; corrective
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actions appeared appropriate; generic applicability had been considered; the
LER forms were complete; the licensee had reviewed the event; no unreviewed
safety questions were involved; and violations of regulations or Technical
Specification conditions had been identified.
LERs Unit 1
327/84-024
327/84-052
327/85-046
327/86-001'
327/86-01 Special Report
327/84-030, Rev. 1
10. Event Followup (93702, 62703)
a. On February 2, 1986, the licensee identified that Rod Bow Penalties
calculated after a core redesign on Unit 2 Cycle 3 were in error as a
result of an incorrect rod loading pattern being entered into a
computer program. This item was communicated to NRC Region II
management and will be assigned to a specialist inspector, Inspector
Followup Item 327,328/86-15-05.
b. On February 12, 1986, while performing Surveillance Test (SI 197 -
Periodic Calibration of Control Building Heating, Ventilating and Air
Conditioning) on the fresh air intake to the Control Room Air System
intake temperature switches, an Instrument Maintenance technician
failed to follow a prescribed action. This error resulted in a Control
Building Ventilation isolation and a startup of the emergency cleanup
system. Because both units were in mode 5, there was little safety
significance associated with this event. This issue is closed based on
licensee corrective actions.
c. On February 20, 1986, while performing a non-safety related
surveillance, an Auxiliary Unit Operator tripped a breaker in error.
This action resulted in a loss of power to Radiation Monitor RM-90-101
and resulted in an Auxiliary Building Isolation. Because both units
- were in mode 5, there was little safetyspignificance associated with
this event. This issue is closed based on' licensee corrective actions. I
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d. As a result of an audit of the licensee's actions associated with
several onsite issues, the inspector reviewed the activities of the
Independent Safety Engineering Group (ISEG). Technical Specifications 6.2.3 requires the ISEG to:
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examine plant operating characteristics, NRC issuances, industry
advisories, Licensee Event Reports and other sources which may
indicate areas for improving plant safety
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maintain surveillance of plant activities to provide independent
verification that these activities are performed correctly and
that human errors are reduced as much a practical
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make detailed recommendations for revised procedures, equipment
modifications, or other means of improving plant safety to the
Assistant Director for Maintenance and Engineering of the Division
of Nuclear Power
A one year audit period was chosen to examine ISEG performance. It was
determined that the ISEG performed an adequate review function with
respect to LERs and those documents that support the managerial
decision-making process on NRC reportability. However, there is no
formal documentation that the ISEG examined industry advisories or NRC
issuances. In addition, there have been no formal detailed
recommendations for revised procedures, equipment modification,
improvements to plant safety or reduction in personnel errors that have
resulted from the above reviews. The efforts of five full-time
engineers, involving approximately ten thousand manhours, appeared not
to generate any formal recommendations with the exception of the LER
issuances. This is a violation of TS 6.2.3, and will be identified as
violation 327,328/86-15-06.
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The basic reporting stature of the ISEG was not being complied with in
that ISEG is reporting to the Site Director instead of a corporate
Assistant Director off-site. The Assistant Director for Maintenance
and Engineering of the Division of Nuclear Power has not received
reports from the ISEG for over two years. The position was apparently
changed during one of the previous TVA reorganizations that has
occurred. TS changes have not been approved to allow this. This is a
further example of violation 327,328/86-15-06.
The process with which the ISEG maintains surveillance of the plant for
independent verification of plant activities and reduction of personnel
errors is limited to the processing of LERs and the documentation used
to determine NRC reportability. This is not a violation of the TS,
however, it is a weakness in the practices of the ISEG. <
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The inspectors reviewed those ISEG reports published during this audit
period,
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TITLE DATE INITIATING FACTORS
Breaches and Fire Watches 3/85 Commitment to NRC
Shutdown Activities 4/85 Request by NRC resident
AFW isolation 6/85 4/85 event
Containment Spray room 6/85 4/85 event
cooler isolation
Spent fuel pit level drop 1/86 12/85 event
Containment Hydrogen 1/86 Evaluation of
analyzer failures documentation used to
determine NRC
reportability
Based on the above reports, the inspectors agree with the findings
stated in inspection report 327/84-24, with respect to the ISEG
activ'ities in response to events and special requests. The inspectors
found that the reports and evaluations included adequate descriptions
of the scope of work to be performed, background, technical
information, sequence of events, causative factors and recommended
corrective actions. With respect to staffing, the inspectors again
agree with the findings stated in NRC Inspection Report 327/84-24 in
that combined Compliance staff and ISEG staffing, training schedules,
and training requirements (STA qualification) did not appear to prevent
the ISEG from performing its intended function.
Further inspector review of ISEG functions determined that the safety
significance of the above violation was lessened in this case because
each of the functions was being conducted onsite by another
organization. In some cases there was even duplicate effort to review
documents by several TVA organizations. Nonetheless, the TS
requirements discussed above were not being performed in any formal
documented fashion by the ISEG.
11. IE Information Notices (92701)
The following IE Information Notices (IENs) were reviewed and closed. The
inspector verified that: corrective actions appeared appropriate; generic
applicability had been considered; the 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.
IEN 86-04 Transient Due to Loss of Integrated Control System
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12. Inspector Followup Items (92701)
Inspector Followup Items (IFIs) are matters of concern to the inspector
which are documented and tracked in inspection reports to allow further
review and evaluation by the inspector. The following IFIs have been
reviewed and evaluated by the inspector. The inspector has either resolved
the concern identified, determined that the licensee has performed
adequately in tne area, and/or determined that actions taken by the licensee
have resolved the concern.
IFIs
327/84-24-04 Generic Fittings
327,328/85-10-01 Annunciator Adequacy
327,328/85-16-02 Use of Single Cell Chargers on Vital Batteries
327,328/85-16-04 Drawing Revisions for DG Battery Rack Brace
327,328/85-16-06 Battery Equalizing Charges
327/85-17-08,328/85-17-07 Clarify RCS Unidentified Leakage Procedure
327/85-17-03,328/85-17-02 Control of material surveys
327/85-17-07,328/85-17-06 Aux.iliary Building Isolations
327,328/85-23-05 Radiation Records
327,328/85-26-01 Repair of DG Air Reducer Valve
327,328/85-23-06 Proper Use of Yellow Bags
327,328/85-43-09 Installation and Testing of Containment Rad
Monitors
327,328/85-43-10 Nameplate Correction on Containment Pressure
Transmitter
327,328/85-43-12 Air Supply to Hydrogen Monitors
327,328/86-06-02 Verification of Maintenance on Containment
Rad Monitors
327,328/86-06-04 Verification That ESF Has No Override Features
13. Cold Weather Operations (71714)
The licensee's preparations for cold weather operations were audited by the
inspectors and found t be adequate for safety related systems.
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