ML20154N512

Insp Repts 50-327/88-36 & 50-328/88-36 on 880712-0805. Violation Noted.Major Areas Inspected:Operational Safety Verification,Including Operations Performance,Sys Lineups, Radiation Protection & Safeguards & Housekeeping Insps

ML20154N512
Person / Time
Site:	Sequoyah
Issue date:	09/15/1988
From:	Harmon P, Jenison K NRC OFFICE OF SPECIAL PROJECTS
To:
Shared Package
ML20154N502	List: ML20154N499 ML20154N505 ML20154N512
References
50-327-88-36, 50-328-88-36, NUDOCS 8809290327
Download: ML20154N512 (19)

See also: IR 05000327/1988036

Text

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J* . UNITED STATES

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g NUCLEAR .9EGULATORY COMMISSION

o * REGION ll

\'e,,,, j8 101 MARIETTA ST N.W.

ATLANTA. GEORGIA 30323

Report Nos.: 50-327/88-36 and 50-328/88-36

Licensee: Tennessee Valley Authority

6N38 A Lookout Place

1101 Market Street

Chattanooga, TN 37402-2801

Docket Nos.: 50-327 and 50-328 License Nos.: OpR-77 and OPR-79

Facility Name: Sequoyah 1 and 2

Inspection Conducted: July 12 - August 5, 1988

Inspector: t A /$u d jen '7/M/RP,

P. Ef Harmon, SepYop' Resident Inspector Date Signed

Resident Inspectors: D. P. Loveless

W. K. Poertner

P. G. Humphrey

Approved by: Y/h1 de

K. A' Jehisfn Acting Chief,

'7!/Cff

/)ateAi~ghed

ProjectsSectIon1

Div1sion of TVA Projects

SUMMARY

Scope: This routine, announced inspection involved inspection onsite by the

Resident Inspectors in the areas of operational safety verification

including o performance, system lineups, radiation

protection, perationssafeguards and housekeeping inspections; maintenanc

observations * surveillitnce testing observations; review of previous

inspectionfIndings;andreviewoflicenseeidentifieditems.

Results: One violation was identified.

Paragraph 6. - Failure to test Containment Spray check valves per

10 CFR 50 Appendix J. (327,328/88-36-01)

• 0ne unresolved item was identified.

Paragraph 2.a - Auxiliary Feedwater valve out of alignment per

50I-3.1, Auxiliary Feedwater. (327,328/88-36-02)

No deviations were identified.

"Unresolved items are matters about which more information is required to

determine whether they are acceptable or may involve violations or deviations,

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Closures: LER's:

(0 pen) LER 327/88-07, Opening of Unit 1 containment results in

secondary containment envelope outside the boundary set for

surveillance testing of auxiliary building gas treatment system

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(Closed) LER 327/88-21, Improper RHR valve alignment resulting in

loss of RCS inventory.

(Closed) LER 327/88-16, Rev.1 Inadvertent main steam isolation

caused by an inadequate review o,f a work package.

(Closed) LER 327/87-03 Potential for loss of containment air return

fanduetoadesignandconstructiondeficiency.

(0 pen) LER 327/88-14, LER 327/88-17, LER 327/88-23, Spurious

containment ventilation isolations due to iMI-induced radiation

monitor actuations.

(Closed) LER 327/87-61 Rev.1, Associated circuits that share a

common power sup)1y wIth appendix R circuits lacked selective

coordination due ;o inadequate design calculations.

(0 pen) LER 328/88-20, Check valves used as containment isolation ,

valves in a raw water system did not pass leak rate test due to

improper application of valve usage.

(Closed) LER 328/88-24, Reactor trip resulting from low reactor

coolant system flow signal caused by a procedure noncompliance.

(Closed) LER 328/88-25, Failure to comply with a TS action statement

for diesel generator operability verification.

Violations:

(0 pen) VIO 327,328/87-66-02 Failure to establish, implement, and

maintain system operating Instruction procedures for system 63

(safety injection),

(Closed) VIO 327,328/87-76-02, failure to follow procedure.

(0 pen) VIO 327,328/88-02-01, failure to comply with procedural

requirements.

(Closed) VIO 327 328/88-06-02, Failure to adequately identify and

correct 50I checkiists for system aligreent.

(Closed) VIO 327,328/88-06-01 failure to specify qualifications and

train individuals performing system alignments.

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(Closed) VIO 327,328/88-20-01, Failure to develop or implement

procedures.

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(Closed)VIO 327,328/88-20-02, Missed surveillance test.

(0 pen) VIO 327 328/88-20-03, Failure to compl

specification ilmiting condition for operations.y with technical

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(0 pen)VIO 327,328/88-20-04, Failure to ensure timely notification of

the NRC of a loss of safety functions.

Unresolved items:

(Closed) URI 327,328/88-29-05, Adequacy of testing of check valves

72-547 and 72-548.

(Closed)URI 327,328/88-22-01, AFW valve out of position.

Conclusions:

In the area of Operational Safety Verification one URI was identified

concerning a mispositioned valve in the AFW system. The remainder of the

items inspected in this area a)) eared to be adequate. In the areas of

surveillance and maintenance all items reviewed appeared to be adequate.

Additionally the licensee's corporate commitment tracking system was

reviewed, and on a limited scope of review, it appeared to be adequate.

Those items listed above were reviewed for closure during the inspection

period. In those items designated as "closed" the licensee's actions

appeared to be adequate. The items designated as "open" required further

review by the inspector or further action by the licensee as identified in

the body of the report. Four items remain open from this re] ort which

recuire resolution prior to Unit I restart. They are Viola; ion 327

32E/88-36-01, LER 327/88-07, LER 328/88-20 and Violation 327,328/88-20'03.

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REPORI DETAILS

1. Licensee Employees Contacted

J. Anthony, Operations Group Supervisor

R. Beecken, Maintenance Superintendent

J. 83

• H. Co/num, oper, Compliance Vice President, Nuclear

L'icensing Power Production

Manager

D. Craven

H. Elkins,, Plant Support SuperintendentInstrument Maintenance Group Mana

R. Fortenberr , Technical Support Supervisor

J. Hamilton, uality Engineering Manager

• J. La Point eting Site Director

L. Martin $iteQualityManager

R. Olson,, Modifications Manager

Operations Group Manager

J.

R. Patrick,

Pierce Mechanical Maintenance Supervisor

M. Ray,SIteLicensingStaffManager

R. Rogers Plant Reporting Section

• B. Schofie,ld, Licensing Engineer

• S. Smith, Plant Mana er

S. Spencer, Licensin Engineer

M. Sullivan, Radiolo ical Controls Superintendent

C. Whittemore, Licensing Engineer

NRC Employees

• Attended exit interview

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

paragraph.

2. OperationalSafetyVerification(71707)

a. Plant Tours

The inspectors observed control room operations; reviewed applicable

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

configuration log and TACF log; conducted discussions with

book,

contro l room operators; verified that proper control room staffing

was maintained; observed shift turnovers and confirmed operability

of instrumentation. The inspectors verlfied the operability of

selected emergency systems, and verified compliance with TS LCOs.

The inspectors verified that maintenance work orders had been

submitted as required and that followup activities and prioritization

of work were accomplished by the licensee.

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

buildings, and containment were conducted to observe plant equipment

conditions, including potential fire hazards, fluid leaks and

excessivevibrationsandplanthousekeeping/cleanlinessconditions.

During an inspection tour of the unit #1 containment on August 1, a

large number of scaffolds, equipment, and other items were visible

which were being utilized for work efforts necessary to support work

required for restart of the unit. The ice condenser was included in

the tour and the flow passages between the ice baskets in the areas

that had been cleaned appeared acceptable. However the ice condenser

floor and turning vanes had not yet been cleaned and a large amount

of ice build-up existed there. Work was continuing and close-out

cleanliness inspections had not been performed pertaining to these

two areas.

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:

ResidualHeatRemoval(Unit 1)

Diesel Generator Starting Air (Units 1 and 2)

Auxiliary Feedwater (Unit 2)

During the walkdown of the AFW system the inspector identified that

valve 2-FCV-3-824, isolation valve to a sample sink, was open as

opposed to its 50! required configuration of closed. This was

reported immediately to the U0 who placed the valve in the

configuration 100 as out of position. The valve was later placed in

the proper posit'on. This item will be reviewed further during the

next inspection period and is identified as URI 327,328/88-36-02.

No violations or deviations 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 shif ts 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;

and badge issuance and retrieval; patrols and compensatory posts.

In addition,

protected thevital

and inspectors observed

area barrier protected

integrity. area lighting,

The inspectors verified

interfaces between the security organization and both operations or

maintenance. Specifically, the Resident Inspectors:

(1) interviewed individuals with security concerns

(2) inspected security during outages

(3) reviewed licensee security event report

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(4 visited central or secondary alarn station

(5 verified protection of Safeguards Information

(6 verified ansite/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 the

activities were being conducted in accordance with the applicable

RWPs. Selected radiation protection instruments were verified

operable and calibration frequencies were reviewed.

The inspectors reviewed RWP #88-18-00 Rev. I during this reporting

aeriod. The work location was for all areas of the auxiliary

auilding, except containment, and pertained to the inspection of pipe

supports for SMI-0-317-69 and associated work. Protective clothing

was referenced and respirator protection was specified for specific

areas within the building. Dose rate meters or dose warning devices

were required for various areas identified within the auxiliary

building per the special instructions. In addition, HP coverage,

housekeep'ng, and the use of tools were specified with reference to

ALARA considerations. The briefing attendance record was reviewed.

No deficiencies were noted.

The inspector reviewed RWP 1-88-19, unit 1 containment, upper and

lower. No deficiencies were noted.

No violations or deviations were identified.

3. Monthly Surveillance Observations (61726)

Licensee activities were directly observed to ascertain that surveillance

of safety-related systems and components was 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 identiffed 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.

Work activities in progress associated with the performance of SI-260.2.1,

Rev.3: BIT Cold Leg Injection Flow Balance, Pump Performance and Check

Valve Test, were reviewed during this reporting period. This activity

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provided detailed steps to determine that the CCPs injection line flow

rates into tha reactor coolant system and total flow rates were within

technical specification limits. It further provided that the check valves

in the flow path were fully stroked open during plant cold shutdown. No

deficiencies or violations were noted.

The inspector monitored activities in progress associated with the

performance of SI-109, Channel Calibration for RHR Flow Rate. No

deficiencies were noted.

The inspector reviewed the latest performance of SI-5, Auxiliary Feedwater

Valves Position Verification, and 50!-3.2, Auxiliary Feedwater System.

The procedures appeared to be adequate and the instruction correctly

performed.

No violations or deviations were identified.

4. Monthly Maintenance Observations (62703)

Station maintenance activities of 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 TS.

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 arior to initiating the

work; activities were ac;complished using approvec procedures and were

inspected as applicable; procedures used were adequate to control the

activity; troubleshooting activities were controlled and the repair

records accurately reflected what actually took place; 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; sarts and materials used were

properly certified; radiological contro's 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.

The inspector reviewed work activities in progress during the serformance

of WR #B751026. This activity consisted of troubleshooting anc the repair

of the reactor building floor and equipment drain sump pump. The problem

referenced was that the pump would not automatically start as required

when a high water level condition existed in the sump. A second problem

existed in that the pump would not trip upon a low level condition. The

work and documentation reviewed appeared satisfactory.

The inspector reviewed activities associated with WR #8281268 for the

repair of the 2A condensate booster pump. These activities were essential

to correct lubrication and cooling water seal problems. The suspected

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cause of the lubrication problem was that the oil pressure was actually

greater than normal. This was caused by the auxiliary oil pump not

operating correctly; not starting when required; failing to stop when the

pressure reached the predetermined set-point, and therefore, contributing

to a higher oil pressure in the system. No deficiencies were noted.

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The inspector monitored work activities in progress associated with WR

B789963. The purpose of this work request was to replace the outboard

packing on component cooling water pump 1A. No deficiencies were noted.

No violations or deviations were identified.

5. Licensee Event Report Followup (92700)

The following LERs were reviewed and evaluated for closure. The inspector

verified that: reporting requirements had been met; causes had been

identified; corrective actions appeared appropriate; generic applicability

had been considered; the LER forms were complete; the licensee had

reviewed the event; and no unreviewed safety questions were involved.

LER's Unit 1

(0 pen) LER 327/88-07, Opening of unit 1 containment results in secondary

containment envelope outside the boundary set for surveillance testing of

auxiliary building gas treatment system.

The inspector reviewed this event and the licensee's short and long term

commitments. The short term commitments were found acceptable for the

restart of Unit 2. However, the corrective actions required for the

restart of Unit I have not been implemented and the licensee has committed

in the LER to revising the response by September 1,1988. Pending the

review and acceptance of this response, this item will remain an open

restart item for Unit 1.

(Closed) LER 327/88-21, Improper RHR valve alignment resulting in loss

of RCS inventory.

This incident was reviewed by the shif t inspector and documented in

IR 327,328/88-28. The LER was later reviewed and it was determined that

the licensee's short and long term corrective actions were appropriate.

The immediate actions were to correct the valve alignment and restore the

RCS inventory to the required volume. The long term actions were to

revise the applicable procedures to prevent reoccurrence. This included

a revision to AI-30, Rev. 19, Nuclear Plant Conduct of Operation, that

implemented the requirement to use cards to record information when

verbally directed to change the status of plant equipment and then

verbally repeat back the information to the supervisor prior to

performing the manipulation. Additionally, the procedure required

the AUO's to realign the equipment to the original position in the

event that other than the desired results are encountered. A further

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commitment in the LER involved the revision (Rev. 48) of SOI 68.1, Reactor

Coolant System, to add a H0 on valve, HCV-74-34, during RCS drain-down to

a specified level to prevent an inadvertent loss of suction to the RHR

system. The requirement to place the H0 was also implemented in 50I 74.1,

Rev. 45, Residual Heat Removal System.

Based on the review of the event and the corrective actions taken by the

Licensee, this LER is closed.

(Closed) LER 327/88015, Rev. 1, Inadvertent main steam isolation caused by

an inadequate review of a work package.

This event resulted in an inadvertent main steam line isolation signal

being generated while replacing the flexible sense lines on steam flow

transmitter 1-FS-1-108. At the time of this event bistable 1-FS-1-21A had

already been placed in the tripped condition by maintenance personnel.

Wnen bistable 1-FS-1-108 was accidentally tripped during the maintenance

activity, this completed the two out of three logic and generated a main

steam isolation signal. The main steam isolation valves were closed at

the time the signal was generated so an actual isolation did not occur.

The inspector reviewed the licensee's submittal and proposed corrective

actions and found them acceptable.

This item is closed.

(Closed) LER 327/87-03, Potential for loss of containment air return fan

due to a design and construction deficiency.

During design reviews at Sequoyah, the licensee determined that the

potential existed for damage to and possible loss of one of the two

containment air return fans installed in each unit's containment. The

potential damage mechanism was water accumulation from the containment

spray system that could enter the fan housing and impinge directly on the

fan blades after a design basis accident requiring containment spray. The

fan housing is located flush with the upper containment floor. The

previously installed kick plate style curbing had been removed as it

interfered with opening the nearby personnel hatch. With no curbing

around the fan, water from the containment spray system could accumulate

on the floor, enter the fan, and disable it. Only the train A fan for

each unit was affected, because the other fan is mounted above the floor

level.

Curbing was redesigned and installed for the Unit 2 fan prior to plant

startup. The work for the Unit 1 fan was completed August 2,1988. In

addition to the modifications to each fan, Revision 11 to SI-19,

Containment Systems Divider Barriers, Removable Curbs, Personnel Access

Doors and Equipment Access Hatches 3rovides a means of ensuring the

curbing around the A train fans is 'nstalled prior to closecut of the

containrent after an outage.

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This item is closed.

(0 pen) LER 327/88-014 LER 327/88-017, LER 327/88-023, Spurious

Containment Ventilation Isolations due to EMI-Induced Radiation Monitor

Actuations.

The first of these three events occurred on March 14, 1988, and was caused

by IM's working on the containment purae radiation monitor,1-RM-90-130

without first having the operations staff place the monitor in "Block".

The IM personnel returned the radiation monitor's local sample pump switch

to the normal (run) position and the pump switch actuation caused an

electromagnetic interference spike to be induced into the monitor. The

EMI spike caused the tripping of the high radiation bistable, and the

subsequent CVI. The corrective action for this event was the issuance of

a memorandum to IM personnel, requiring them to contact operations so that

the RM trip signal could be blocked before performing any work on RMs

capable of actuating ESF equipment.

The second event, described in LER 327/88-017, occurred March 31, 1988.

This CVI was initiated when an AVO noticed that the abnormal flow alarm

light for 1-RM-90-130 was illuminated on the local RM panel. In

attempting to clear tne alarm, the AVO jogged the RM sainple aump switch

off and then back on. The pump switch actuation caused an Ell spike to

trip the high radiation bistable, and a CVI occurred, The LER identified

the root cause of this event as improperly controlling the operation of

the sample pump switch af ter it had been identified as the cause of the

March 14 CVI described above. The corrective action prescribed for this

event included the issuance of a memorandum to operations personnel

imilar to the one previously issued to the IMs. In addition, a H0 was

placed on the local sample pump switch to prevent operation until switch

replacement could be accomplished.

The third event, described in LER 327/88-023, occurred June 7, 1988, when

two CVIs occurred within 30 minutes of each other. These CVIs were

initiated by EM personnel working on 1-RM-90-130. The work, performed

under WR 8262490, was to replace the local sample pump switch on the RM

which had caused the previous two CVIs. This WR was reviewed by the Unit

1 A505 prior to its im31ementation. Power to the pump had been removed

before the work was initiated, and the A505 and the work planners assumed

that no EMI spike could be generated when the pump switc1 was actuated.

While the pump itself is powered from 480-volt power, an auxiliary set of

contacts to indicate pump status opens and closes in parallel with the

pump power supply. These auxiliary contacts are electrically isolated

from the 480-volt power supply, but are common to the 120-volt power that

actuates the radiation analyzer for the RM. TVA has theorized that the

status circuitry and the auxiliary contacts are the components causing the

EMI induced trips of the RM. Since the 480-volt pump power supply was

thought to be the source of the EMI spikes, (and that power was isolated),

the RM's handswitch was not placed in the "Block" position, which would

have prevented the CVIs described by this LER.

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These three LERs will remain open pending the completion of the licensee's

corrective actions to preclude recurrence of CVIs associated with

operation of the RM prior to placing the handswitch in "Block".

(Closed) LER 327/87061, Rev.1, Associated circuits that share a common

power supply with appendix R circuits lacked selective coordination due to

inadequate design calculations.

During calculation reviews the licensee identified several cases where a

fault on appendix R associated circuits could cause interruption of a

required circuit. The cause of this deficiency was due to use of design

cable lengths for fuse / breaker sizing.

This LER was reviewed in inspection report 327,328/88-19 and was left open

pending review of revision 1 of the LER. The inspector reviewed the

revision and found the description and corrective actions adequate.

This item is closed.

LER's Unit 2

(0 pen) LER 328/88-20, Check valves used as containment isolation valves in

a raw water system did not pass leak rate test due to improper application

of valve usage.

The licensee's proposed corrective action was to replace the unit one

valves prior to entering mude 4 operation. The inspectors reviewed the

status of the work and determined that most of the field work had been

completed. However, the associated work packages, WP 7378-01 and WP

7378-02, had not been closed. This item will remain open and require a

disposition prior to unit 1 entering mode 4.

(Closed) LER 328/88-24, Reactor trip resulting from low reactor coolant

system flow signal caused by a procedure noncompliance.

The on-shif t inspectors reviewed the licensee's analysis of the events

associated with this reactor trip and the determination that the trip was

a result of a failure to follow procedure when removing and returning the

RCS flow transmitter to service during the calibration process. This was

identified as violation, VIO 327,328/88-28-01. The corrective actions

taken by the licensee includes determining the cause of the trip and a

review of the event with the instrument maintenance personnel to ensure

lessons learned from this event were identified and to re-emphasize the

necessity of procedural compliance.

A further commitment was cocitained in the LER to review previous reactor

trips for a similar occurrence of common equipment interactions causing

reactor trips and is being carried in the licensee's CCTS, Control No.

NCOSS013001.

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This issue will be reviewed under Violation 327,328/8.8-28-01. The LER is

closed.

(Closed) LER 328/88-25, Failure to comply with a TS action statement for

diesel generator operability verification.

This issue involves the failure to meet the requirements of TS 3.8.1.1

action A when diesel

voltage relay testing. generator 1A-A was removed from service for degraded

This event was reviewed in Inspection Report 327,328/88-34 and resulted in

a violation being issued. The inspector reviewed the LER and found the

licensee's corrective actions adequate.

This item is closed.

No violations or deviations were identified.

6. Licensee Action on Previous Inspection Findings (92702)

(0 pen) VIO 327,328/87-66-02, Failure to establish, implement, and maintain

systemoperatinginstructionproceduresforsystem63(safetyinjection).

The inspector reviewed 501-63.1 Emergency Core Cooling System, and

determined that the corrections , identified in this violation had been

completed and documented in Inspection Report 327,328/87-76. This item

has been determined adequate for the restart of Unit 1. However, the

commitment to implement a phase 2 procedures enhancement program to ensure

human factors and consistency and clarity in all 501s has not been fully

implemented. This issue will remain open.

(Closed)VIO 327,328/87-76-02, Failure to follow procedure.

This event involved two examples of failure to follow procedure. The first

example resulted in an improper inspection of the 2A-A Hydrogen recombiner

and failure to identify anc remove an obstruction from the recombiner

orifice. The second example involved the failure to properly drain and

depressurize a section of AFW piping prior to issuing a clearance on the

system. Immediate actions were taken to correct the conditions and

long-term commitments were to revise SI-153.4, Test Requirements for the

Electric Hydrogen Recombiner System, to enhance the instruction and to

implement training to insure procedural compliance.

The inspectors reviewed the training documentation and found this effort

to be satisfactory. The SI-153.4 revision has not been completed but has

been entered into the licensee's CCTS, Control No NC0880105001. The

srocedures for Unit 1, SI-153.3.1, Test Requirements for the Electric

iydrogen Recombiner 1A-A, and 51-153.3.2, Test Requirements for the

Electric Hydrogen Recombiner 18-B, have been issued.

Based on these corrective actions, this item is closed.

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(0 pen) VIO 327,328/88-02-01, Failure to comply with procedural

requirements.

The inspectors reviewed actions taken by the licensee as a result of the

four examples identified in the subject violation cited. The first

example cited the opening of the MSIVs with the reactor coolant system

temperature below that required by the procedure and resulted in a reactor

trip. The second example involved opening only the #4 steam generator

MSIV which was in conflict with the system operating instruction, 501-1,1,

Main Steam Supply, which required all four MSIVs to be opened simulta-

neously. The licensee's corrective actions associated with the two

exam)les above included upgrading of 501-1.1 to a category "A" procedure

whici requires the operator to have the procedure present and referred to

during the performance of the activity. Further actions included a

maximum pressure difference limitation prior to opening the MSIVs and the

installation of temporary gauges for monitoring the pressures. Example #3

cited the use of an "information only" drawing utilized to perform

troubleshooting / work in the plant on the containment spray system. The

response to this issue is currently being revised. Example #4 involved

poor housekeeping practices and the failure to properly perform SI-187,

Containment Ins)ection. The corrective actions involved satisfactorily

re-serforming tie SI and active participation by slant management to

emplasize the importance of maintaining a high stancard of work ethics.

Based on the above, this item has been determined technically adequate for

Unit I restart but will remain open until the licensee's revised response

has been received and evaluated.

(Closed) VIO 50-327,328/88-06-02, Failure to adequately identify and

correct 50! checklist; for system alignment.

The inspector reviewed a random sample of the 50!'s and verified that

revisions had been incorporated to correct the discrepancies identified.

Further, it was verified that G01-6, Rev. 34, Apparatus Operations

implemented the commitment for adding a definition ser. tion for electrical

devices. The licensee's response tc IR 327,328/88-06 received on

March 30, 1988, which stated that all power availability checklists

contained in AI-58, Maintaining Cognizance of Operational Status - Con-

figuration Status Control, Appendix A, were reviewed to identify any

devices whose required position could be misinterpreted. In addition, the

correct position for each com)onent was identified and correctiens to the

checklists were made as needec. Valve alignments were then fielt) verified

and documented by utilizing the corrected checklists and no discrepancies

were discovered. The above licensee efforts appear satisfactory and

therefore this violation is closed.

(Closed)VIO 327,328/88 06-01, Failure to specify qualifications and train

individuals performing system alignments.

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The inspectors reviewed the revised method for independent verification i

implemented in Rev. 42 of G01-6. This revision specified the method for

independently verifying e In adc ition, AI-37, Rev. 5,

,

Independent Verification,was quipment

revisedstatus.

to implement the requirement for ,

separation of independent verification. The methods utilized for '

verification, and the qualifications were specified for those persons

performing the verifications. The licensee s corrective actions were  !

) appropriate to correct the identified issue. This violation is closed. ,

(Closed) VIO 327,328/88-20-01, Failure to develop or implement procedures. f

.

A review of the corrective actions completed by the licensee appear .

adequate. Those actions completed included a revision to Al-6, Log I

,

Entries and Review, which addressed the level of detail for log entries

a review of formal SQN TS interpretations for technical adequacy  :

! implementing the use of TSs into the licensed operator

and clarity;

simulator tra ining program; and entries made into the operation logs to l

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reflect the findings of the valve non-actuation by the previous shifts. t

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However, the licensee committed to training the Unit 1 operators on  :

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procedure changes and TS interpretation changes before Unit 1 enters mode  ;

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2 operation. This commitment must be satisfied prior to Unit 1 entering t

mode 2. The commitment is identical to that made for corrective action

to VIO 327,328/88-20-03 below and will be tracked under that item.

1

Therefore, VIO 327,328/88-20-01 is closed. l

I (Closed) VIO 327,328/88-20-02, Missed surveillance test.

The ins i

1 actions.pector reviewed

The short termthe licensee's

action long

involved term andsampling

immediate short term corrective

of the #3 cold '

i leg accumulator which identified that the boron concentration was above j

that allowed by TS. The inleakage from the RCS causing this problem was '

i corrected. The long term corrective actions involved a revision of SOI

l 63.1, Emergency Core Cooling System, and SI-2, Shif t Log. Based on this f

j review, corrective actions taken by the licensee were determined to be -

j technically adequate. This issue is closed.

l VIO 327,328/88-20-03, .

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tionpen)imiting

l condition for operations. Failure to comply with technical specifil

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This violation arose from operators having the 2A-A CCP hand switch in the  !

pull-to-lock position when the pump was required to be operable. Per .

, conversations with the operators, they were relying on a TS interpretation >

l that they believed existed which determined the pump to be opera)le with l

,

the hand switch in this position. Since this event, the licensee has

! reviewed the TS interpretations because some were found in disagreement  :

with the TS and is requiring the operators to rely more on the TS. In f

j addition, the licensee committed to perform additional TS training of the ,

i Unit 1 operators. This item will remain open and should be resolved [

prior to Unit 1 entry into Mode 2.

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(0 pen) VIO 327,328/88-20-04, Failure to ensure timely notification of the

NRC of a loss of safety functions.

The licensee's management became involved in the issue and has directed

the 50S's to be conservative in evaluations of events involving TSs and to

initiate a notification when situations indicate this action could be

required. Based on these corrective actions, this item is closed as it

pertains to the unit I restart but will remain open until a formal NRC

acknowledgement to the licensee's response has been issued.

(Closed) URI 327,328/88-29-05, Adequacy of testing of check valves 72-547

and 72-548.

of the testing of valves 72-547 and

The

72-548 inspector in that they reviewed

are not thetype adequacy"C" leak rate tested per 10 CFR 50

Appendix J. The adequacy of the containment isolation design with respect

to GDC-56 was reviewed by the staff during the review of the nuclear

performance plan and is documented in the May 1988 SER. The SER ap

to address only the outboard isolation valves stating the following:peared

Isolation designs which are adequate on "some other defined basis"

are described in the standard review plan (SRP) Section 6.2.4,

"Containment Isolation System," and ANSI Standard N271-1976,

"Containment Isolation Provision; for Fluid Systems." For contain-

ment Spray line penetrations, as well as for other essential systems,

the SRP and the ANSI standard identify the use of remote manual

valves in lieu of automatic valves as acceptable. TVA, on the other

hand, has traditionally relied on the closed system outside contain-

ment rather than identify an outboard remote manual valve as an

isolation valve.

Therefore, the staff conclusion that the testing of penetrations X-48A and

X-488 was acceptable, may not have taken into consideration the testing of

the check valves.

The inspector reviewed the testing of valves 72-548 and 72-547 as well as

valves 72-555 and 72-556, the RHR spray isolation valves, which are similar

in function. These valves are not in a configuration to be type "C" tested

aer Appendix J. There is no isolation between the valves and the spray

leaders making it impossible to individually test these valves.

On June 8,1988, NRC management notified the licensee that they were in

violation of Aspendix J. The licensee declared the containment isolation

system inoperable at 2:10 p.m. and entered the Action Statement for

LCO 3. 6.1.1. The licensee exited the LC0 upon determining that the

containment isolation system remained operable as defined by the TS. This

decision was based on the fact that the containment spray isolation

configuration was similar to that of the UHI system and that an NRC

approved exeeption from Appendix J type "C" testing existed on the UHI

system. This JC0 was documented on ICF 88-0935 to SI-14.2, Verification

of Containment Integrity, under the provisions of 10 CFR 50.59.

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10 CFR 50 Appendix J states that:

II.H.3 Type C testing is required for those valves that, " Are

required to operate intermittently under postaccident conditions..."

III.C.1 "Type C tests shall be performed by local pressurization.

The pressure shall be applied in the same direction as that

when the valve would be required to perform its safety

function..."

III.C.2 "Valves, which are sealed with fluid from a seal system

shall be pressurized with that fluid to a pressure not less

that 1.10 Pa."

Contrary to the above, the containment spray and RHR spray inboard

containment isolation valves have not been type C tested for the If fe of

the plant. This is a violation and shall be identified as VIO

327,328/88-36-01.

The licensee discussed this issue with the inspector and stated that they

believe that they were always in compliance with the re This

was based on a statement from Appendix J III.C.3 stating:gulations.

Leakage from containment isolation valves that are sealed with fluid

from a seal system may be excluded when determining the combined

leakage rate: provided , that;

(a) Such valves have been demonstrated to have fluid leakage rates

that do not exceed those s

associated bases, and (b)pecified in theisolation

The installed technical specifications

valve seal-wateror

system fluid inventory is sufficient to assure the sealing function

for at least 30 days at a pressure of 1.10 Pa.

This statement discusses only the combined type B and C leakage rate

calculations from a water sealed system. The inspector does not take

issue with the exclusion of the penetration from the combined leakage rate

calculation per III.C.3. The inspector also recognizes that Type C testing

for the outboard containment spray and RHR spray isolation valves pursuant

to III.C.2. is acceptable. However, this does not exemat the licensee

from performing a type C test under the provisions of TII.C.1 for the

inboard containment spray and RHR spray isolation valves.

of these check valves

The issues

for both unitsofisAppendix

addressedJ requirements and testing /88-36-01;

as Violation 327,328 therefore,

URI 327,328/88-29-05 is closed.

(Closed)URI 50-327,328/88-22-01, AFW valve out of position.

The inspectors reviewed the corrective actions committed to by the

licensee to prevent exiting an LCO when the system has not been properly

realigned. This included a review of Rev.16 to Al-6, Log Entries and

Review, and associated log forms which frplemented the requirement for

documenting all specific actions /equipeent which could affect the

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operability of a system. This documentation was intended to insure that

equipment that had been repositioned was reviewed and properly re-aligned

prior to declaring the system operable. Based on these procedural changes

incorporated by the licensee, this item is closed.

7. Commitment Tracking Review

The inspector reviewed the licensee's CCTS and TROI systems for timeliness

in meeting commitments, coordination between the two systems and the

licensee's implementation. Over 100 items from the CCTS were reviewed for

timeliness. Two items were identified as having missed the commitment

date. Both items were discussed with NRC/OSP management prior to becoming

late.

These tracking and trending systems will be reviewed further during the

operational readiness inspection to be conducted prior to the unit one

restart. No violations or deviations were identified during this review.

8. Exit Interview (30703)

The inspection scope and findings were summarized on August 9, 1988, 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.

Inspection Findings:

One violation was identified in paragraph 6.

One unresolved item was identified in paragraph 2.a.

No deviations or inspector follow-up items were identified.

The licensee expressed at the exit interview that the plant was always in

compliance with Appendix J as it relates to the violation discussed in

paragraph 6 of this report. The resident inspectors explained that the

licensee's position did not agree with the NRC staff's interpretation of

the regulations. The licensee was also informed that they may further

address this issue in their response to the Notice of Violation.

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

Director, Plant Manager and other managers concerning inspection findings.

9. List of Abbreviations

AFW -

Auxiliary Feedwater

AI -

Administrative Instruction

ALARA - As Low As is Reasonably Achievable

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ANSI -

American Nuclear Standards Institute

AVO -

Auxiliary Unit Operator

A505 -

Assistant Shift Operating Supervisor

81T -

Boron Injection Tank

C&A -

Control and Auxiliary Buildings

CCP -

Centrifugal Charging Pump

CCTS -

Corporate Commitment Tracking System

COPS -

Cold Overpressure Protection System

CVI -

Containment Ventilation Isolation

DC -

Direct Current

EH -

Electrical Maintenance Technician

EMI -

Electromagnetic Interference

ESF -

Engineered Safety Feature

FCV -

Flow Control Valve

FS -

Flow Switch

GDC -

General Design Criteria

GOI -

General Operating Instruction

HCV -

Hand Control Valve

H0 -

Hold Order

HP -

Health Physics

ICF -

Instruction Change Form

IN -

NRC Information Notice

IM -

Instrument Maintenance

IR -

Inspection Report

JC0 -

Justification for Continued Operations

LER -

Licensee Event Report

LC0 -

Limiting Condition for Operation

MI -

Maintenance Instruction

MSIV -

Main Steam Isolation Valve

NOV -

Notice of Violation

NRC -

Nuclear Regulatory Commission

OSP -

Office of Special Projects

PRO -

Potentially Reportable Occurrence

QA

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Quality Assurance

QC

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Quality Control

RCS -

Reactor Coolant System

RM -

Radiation Monitor

RHR -

Residual Heat Removal

RWP -

Radiation Work Permit

SER -

Safety Evaluation Report

SI -

Surveillance Instruction

SMI -

Special Maintenance Instruction

501 -

System Operating Instructions

505 -

Shift Operating Supervisor

SRP -

Standard Review Plan

TACF -

Temporary Alteration Control Room

TROI -

Tracking Open Items

TS -

Technical Specifications

TVA -

Tennessee Valley Authority

00 -

Unit Operator

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URI -

Unresolved Item

VIO -

Violation i

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WP -

Work Plan

WR -

Work Request

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