ML20134Q330
ML20134Q330 | |
Person / Time | |
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Site: | Sequoyah |
Issue date: | 11/19/1996 |
From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
To: | |
Shared Package | |
ML20134Q321 | List: |
References | |
50-327-96-11, 50-328-96-11, NUDOCS 9612020233 | |
Download: ML20134Q330 (17) | |
See also: IR 05000327/1996011
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U.S. NUCLEAR REGULATORY COMISSION
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REGION II
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Docket Nos: 50 327, 50 328
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Report Nos: 50-327/96-11, 50-328/96-11
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Licensee: Tennessee Valley Authority
l Facility: Sequoyah Nuclear Plant, Units 1 & 2 '
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Location: Sequoyah Access Road '
Hamilton County, TN 37379
l Dates: September 15 through October 26. 1996
Inspectors: M. Shannon, Senior Resident Inspector
l D. Starkey, Resident Inspector
l C. Rapp, Reactor Inspector (Sections E8.1 through
E8.7) 1
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W. Sartor, Reactor Inspector (Section Pl.2) l
l S. Sparks, Project Engineer-
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Approved by: M. Lesser, Chief
Reactor Projects Branch 6
Division of Reactor Projects
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Enclosure 2
9612O20233 961119
PDR ADOCK 05000327
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EXECUTIVE StM MRY
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Sequoyah Nuclear Plant. Units 1 & 2 i
NRC Inspection Report 50 327/ % 11, 50 328/96 11 l
- This. integrated inspection included aspects of licensee operations, i
maintenance, engineering, plant support, and effectiveness of licensee I
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controls in identifying, resolving, and preventing problems. The report l
covers a six week period of' resident inspection. -In addition,'it includes the. '
[ -results of an announced inspection by.an engineering inspector.
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-Operations j
e Operations management initiated a positive program to discuss,
y during shift turnovers. recent configuration control issues in an
L effort to reduce the' number of configuration control problems i
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o. A non cited violation (!JCV) was identifed for failure to use a
i procedure when performing a main control room switch manipulation
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(Section 01.2).
, e Operators were not aware that a radiation monitor with " low
! counts" would not perform its-designed Auxiliary Building .;
[ - Isolation (ABI) function (Section 02.1). 1
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! Maintenance
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o - A weakness was identified in the licensee's corrective action ]
- ' program for closing.a problem report on previously identified AFW
bearing oil problems without substantial evaluation (Section
M2.1).
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e A positive observation was noted when Nuclear Assurance identified l
four previous Problem Evaluation Reports (PER) related to i
! Auxiliary Feedwater (AFW) bearing oil problems (Section M2.1).
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l e - A weakness was identified regarding the licensee's switchyard i
- _ preventive. maintenance program (Section M2.2). !
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o A violation was-identified for failure to install a temporary i
,f missile shield during excavation in the area of Essential Raw-
l- Cooling Water (ERCW) underground piping (Section M2.3).
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Enaineerina
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o A violation was identified in that the DG starting air system i
relief valves were set above the design condition limit (Section
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e An NCV was identified for failure to incorporate procedural
l guidance when an Abnormal Operating Instruction .(A0I) was upgraded
l to an Abnormal Operating Procedure (A0P) (Section E8.4).
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l Plant Sucoort
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e The licensee conducted a challenging. Radiological Emergency Plan
(REP) drill scenario in preparation for the November 6, 1996,
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graded REP exercise. During the drill critique, the licensee was
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quick to identify drill deficiencies and ways to make improvements
in the 2EP program (Section Pl.1).
e The emergency program was observed to be well managed and
l- receiving management support. Effective corrective actions taken
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to previous open items permitted the closure of two violations and -
two IFIs.- (Section Pl.2)
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. Reoort Details
Summary of Plant Status
Unit 1 began the inspection period in power operation. The unit )
operated at power for the duration of the inspection period.
Unit 2 began the inspection period in power operation. On October 11, l
the unit began a controlled shutdown from 100% power because of a
suspected failure of a reactor coolant pump seal and later that day
operators manually tripped the Unit due to equipment problems and
entered Mode 3. (See Inspectioc, Report 50 327,328/96 13). The unit
entered Mode 5 and commenced a forced outage to replace two reactor
coolant pump seal packages and one reactor coolant pump motor. On ,
October 24, 1996, when the repairs to the reactor coolant pumps had been
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completed, the unit entered Mode 4. When the report period ended, the
unit was in Mode 4 awaiting completion of repairs to the motor driven
auxiliary feedwater pumps.
I. Operations
01 Conduct of Operations l
01.1 General Comments (71707)
Using Inspection Procedure 71707, the inspectors conducted frequent
reviews of ongoing plant operations. In general, the conduct of I
operations was good. Particularly noteworthy were the thoroughness and
3rofessionalism of operations shift turnover briefings. Operations has
)egun discussing, during shift turnover briefings, recent instances of
configuration control problems. This is considered a positive !
initiative by operations management to increase operator awareness of i
such issues in an effort to reduce the number of configuration control
problems. Additional operational events and observat%ns are detailed .
in the sections below. 1
01.2 Inaoorooriate Ooerator Action
On September 24, 1996, a licensed operator assigned to Unit 1 ;
repositioned a Unit 2 Emergency Gas Treatment System (EGTS) Fan A
suction damper control switch from the "A-Auto" position to the "Close"
position and immediately returned the switch to "A-Auto." The damper
was in the closed position both before and after the switch operation
and no damper movement actually occurred. The operator performed this
switch movement to verify the switch spring-return to-auto feature of
the switch. However, the operator did not request the unit supervisor's
permission prior to the test nor did he use Procedure 0-50 65 1
Emergency Gas Treatment System Air Cleanup and Annulus Vacuum,
Revision 0, which gives direction on system alignment and operation.
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Operations management took appropriate disciplinary action and stressed I
to all operators that unapproved testing activities do not meet
management expectations. The ins)ectors concluded that no realignment
of the EGTS occurred because of t1e unauthorized switch test and that
o)erations management took immediate actions to emphasize to operators
t1eir expectations regarding such activities.
The failure to implement the EGTS system operating procedure when
operating the EGTS system is considered a violation of TS 6.8.1.a. This ;
licensee identified and corrected violation is being treated as a Non- I
Cited Violation, consistent with Section VII.B.1 of the NRC Enforcement
Policy (NCV 50-327, 328/96 11-01).
02 Operational Status of Facilities and Equipment
02.1 Radiation Monitor Inoperable Due to Low Counts
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a. Insoection Scope (71707)
The inspectors reviewed the deficiency related to " low counts"
associated with radiation monitor 0-RM 90101C, Auxiliary Building Vent
Monitor-Iodine, and the operability requirements for the monitor.
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b. Observations and Findinas
On September 18, 1996, during a routine tour of the main control room
(MCR), the inspectors noted a Work Request (WR) sticker, WR C280035,
dated April 12, 1996, attached to radiation monitor 0-RM-90-101C which
indicated that the monitor had ' low counts." The inspectors questioned
operators regarding the operability of the monitor and were informed,
and subsequently verified, that the iodine channel monitor, channel C of i
0-RM 90101, was not required by either the Offsite Dose Calculation
Manual (0DCM) or TS. However, the 00CM does require the iodine sampler,
a cartridge in the radiation monitor flow path which is analyzed weekly )
by Chemistry, to be operable. The ODCH also requires the channel A
particulate sampler and the channel B noble gas activity monitor be
operable. The inspectors verified with Chemistry that the iodine
sampler was, in fact, operable and that weekly samples were being taken.
Discussions with the radiation monitor system engineer indicated that a
condition of low counts renders channel C inoperable. The inspectors l
also learned that repairs to the monitor were awaiting parts and that l
the repairs were scheduled for the week of November 4,1996. The work '
order (WO) associated with the monitor repair stated that the reason for
the low counts was a bad "HV" power supply or a bad detector.
Further review by the inspectors of the operability requirements for I
monitor 0-RM 90 101C revealed that the Updated Final Safety Analysis )
Report (UFSAR), Section 11.4.2.2.4 states that either of the three
channels of 0 RM 90101 (A B, or C) automatically initiates an
Auxiliary Building Isolation (ABI). On September 26, following a '
discussion with the Shift Manager regarding the loss of Auxiliary
Building Isolation (ABI) function for 0 RM-90-101C. the MCR monitor was
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tagged with an "IN0P" tag. On September 28.- Problem Evaluation Report
t (PER) No. SQ%2511PER was written by operations to address the validity
1 of the ABI initiation'since the monitor was not required by either TS or i
the ODCM. The PER also questioned the time frame during which the- i
monitor would not have performed the ABI function. On October 3, 1996.
maintenance personnel replaced the detector on 0-RM 90-101C.. -
-successfully completed the_ post maintenance test (PMT), and returned the
monitor to service.
c. Conclusions
The-inspectors concluded that operators were not aware that 0 RM 90101C
would not perform its designed ABI function with a condition of " low
counts" and. therefore, did not consider the monitor for 0 RM 90 101C to
be inoperable. ~ However, once the question of operability was raised by
the inspectors, operations took appropriate action to identify the
monitor as inoperable and to write a PER. The inspectors will-follow up
on the resolution of PER No. SQ962511PER regarding the ABI function of
0 RM 90 101C. This item is identified as Inspector Followup Item (IFI)
50 327, 328/96-11 02. Review Corrective Action of PER No. SQ962511PER
.Related to ABI Function of Radiation Monitor 0 RM 90 101C.
II. MainteGanCR
M1 Conduct of Maintenance
M1.1 GeneralComtg.niiE2707)
a. Insoection Scoce (61726 & 62707)
-The inspectors observed and/or reviewed all or portions of the following ,
work activities and/or surveillances: ;
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e WO9629423 Change inboard and outboard bearing oil,and
perform section XI test
e WO9304301 Replace flex conduit to MFIV 2 MV0P 003 0033A
e WO9407044 Replace flex conduit to MFIV 2 HV0P-003 00478 l
e' W09302957
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Replace EDG starting air-system relief valve
e WO9302971 Replace EDG starting air system relief valve
e WO9628678 Replace failed primary water pump seal :
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b. Observations and Findinos
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The inspectors noted that the work activities and the performance of
surveillance activities were adequately performed.
M2 . Maintenance and Material Condition of Facilities and Equipment
i M2.1 Auxiliary Feedwater Pumo (AFW) 1B B Bearina Oil Discoloration
a. Insoection Scoce (62707)
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The inspector observed a scheduled preventive maintenance activity on
(. the 1B B AFW pump which included changing the. oil on the inboard and
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outboard pump bearings.
i b. Observations and Findinas
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i On September 30,19%, the inspector observed preventive maintenance
- being performed on the 1B B AFW pump. The maintenance was performed
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under WO 9629432 and included changing the oil in the inboard and
outboard pump bearings. The oil wnich was drained had a noticeable dark
discoloration and the subsequent oil sample results indicated a high
level of iron and copper. . Also, while inspecting the bearing housing,
the licensee discovered two metal fragments which were believed to have
come from the threads of the oil drain plug when it was over tightened
during its last installation. The licensee performed a visual
inspection of the bearings and did not identify any abnormalities. New
oil was added, an American Society of Mechanical Engineers (ASME)
Section XI test was performed on the pump, and the oil was flushed and
replaced again following the Section XI test. i
The licensee documented the discovery of. the discolored oil in PER No.
SQ962516PER and discussed their oil sample findings with the pump i
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vendor. In a letter from the vendor to the licensee dated October 2,
1996, the vendor stated that both the pump and bearing vendor were aware
of instances (throughout the industry) of " black oil" but had not been l
able to determine.the exact source of the oil discoloration. The vendor l
further stated that they were not aware that this condition and/or the
resulting " black oil" caused failure or accelerated failure of the
bearing, and subsequently the ) ump. The vendor recommended that the
licensee continue to monitor t1e condition and quality of the oil and to
change it periodically. The licensee informed the inspector that they !
intend to drain and sample the oil after each quarterly run of the pump.
On October 7, 1996, the vendor stated in another letter to the licensee,
that the pum) should )erform satisfactorily until the next refueling
outage and tlat TVA s1ould follow the recommendations concerning the ,
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monitoring and changing of-the oil. The vendor further stated that they
.had not established any specific allowable percentages of elements found
in the oil as indicators to change the oil. !
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As a result of this most recent problem with AFW bearings / oil, the
licensee's Nuclear Assurance organization initiated PER No. SQ962542PER,
dated October 2,1996, which referenced four previous PER's related to
AFW bearing oil problems, and classified these four PERs as examples of
inadequate recurrence control. One of those four PERs, No. SQ951743PER,
dated October 5,1995, had also identified high metal content in the 1B-
B AFW bearing oil. That PER was closed in April 1996 without a root
cause analysis, without an extent of condition review, without a review
of 3revious similar events, or without interim actions addressing the :
, hig1 metal content. '
c. Conclusions
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) A positive observation was noted when Nuclear Assurance identified four i
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previous PERs related to AFW bearing oil problems. l
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A weakness was identified in the licensee's corrective action program
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for failure to adequately address previously identified AFW bearing oil
problems. '
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M2.2 Exolosion of Potential Transformer in 500 KV Switchyard :
a. Insoection Scooe (62707)
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On October 5,1996, a potential transformer (PT) in the 500 KV a
switchyard exploded. The inspector reported to the site to assess the
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damage to the switchyard and to verify that neither unit was affected by
the explosion.
- b. Observations and Findinas
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The explosion of the PT caused the loss of Bus 1 in the 500 KV
switchyard. Switchyard relays sensed the electrical fault, as designed,
and power circuit breakers o)ened to clear the differential fault.
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During the event, oil from t1e failed PT sprayed onto the gravel in the
switchyard and ignited. The fire was extinguished in approximately 16
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minutes. Additionally, shrapnel from the ex)losion damaged the 500 KV
to 161 KV intertie transformer as well as otler switchyard components
such as insulators. Both units experienced various control room alarms
but no plant equipment was affected and both units continued to operate
at full power. There were no personnel injuries during the event.
Approximately one hour after the initiation of the event, the licensee
simultaneously declared, then exited, a Notification of Unusual Event
due to an ex)1osion within the protected area. The licensee also
determined tlat the loss of the intertie transformer did not affect the
reliability of the required off site power sources.
The licensee subsequently replaced three pts, including the one which
. exploded, and returned the 500 KV Bus 1 to service on October 12, 1996.
However, when the inspection period ended, the intertie transformer
- remained out of service for repairs and other PM activities.
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The inspector reviewed the PM history related to the type of PT which
failed and learned that preventive maintenance had never been performed
on these particular pts since they were purchased in 1972. The
recommended PM interval was noted to be six years. Due to increased
attention which the licensee has recently placed on switchyard
maintenance, these particular pts had been scheduled to be inspected
during the next outage in 1997.
c. Conclusions
The inspector concluded that the licensee's failure, over a period of
years, to ensure that the 500 KV switchyard pts were routinely
inspected, contributed to the eventual failure of the PT. This is
considered a weakness of the switchyard PM program.
M2.3 Yard Fire Hydrant Reoair/Reclacement
a. Inspection Scope (62707)
The inspectors reviewed the activities related to repair / replacement of ,
a yard fire hydrant adjacent to the ERCW underground piping. !
b. Observations and Findings
During tours of the facility the inspectors noted excavation in the j
area of the ERCW underground piping missile shield. Excavation was i
directly adjacent to the missile shield. The inspector requested the
licensee to provide information regarding requirements for excavation
near safety related equipment. The inspector learned that Site Standard
Practice (SSP)-7.4. Work Permits. Revision 7. required that Site
Engineering shall be notified by the cognizant engineer prior to any I
excavations within 10 feet of Category 1 structures (buildings,
manholes, conduit banks, etc.).
On June 18, 1996, excavation permit No. 94 09292-00 was signed and
issued by Site Engineering to remove earth from around a fire hydrant
adjacent to an ERCW concrete missile shield in order to replace the
hydrant. The permit required temporary missile protection if the
excavation was within six feet from the edge of the ERCW permanent
missile protection. The inspector verified that the fire hydrant was
less than two feet from the ERCW permanent missile protection and
therefore personnel should have contacted Site Engineering for specific
guidance on installing temporary missile protection. The actual
excavation to replace the fire hydrant was started on October 4.1996.
The inspector reviewed WO 9409292 and noted that, in step 5.1. the work
supervisor initialed the step acknowledging that the excavation would be
performed per the SSP-7.4 excavation permit which was part of the work
package. However, the work supervisor did not contact Site Engineering
for specific instructions nor did he install any temporary missile
protection as required by the excavation permit, even though the hydrant
was less than the required six feet from the permanent ERCW missile
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. protection. The failure to install temporary missile protection for
ERCW piping as required by SSP 7.4 is considered to be a violation (VIO
50 327.328/96-11 03).
Following discussions with the licensee, PER No. SQN962668PER was i
initiated to document that temporary missile protection.was not in place j
and that the excavation was immediately adjacent to the ERCW permanent l
missile protection concrete slab. !
c. Conclusions
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The failure to follow a procedure, which required a temporary missile
shield, while excavating in the area of ERCW missile shield, is l
considered to be a violation. l
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III. Encineerina l
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El Conduct of Engineering 1
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E1.1 General Comments (37551)
An inspection was' conducted on September 23 27..1996, in the areas of
service water system operational performance in accordance with NRC
Temporary Instruction (TI) 2515/118. This inspection concentrated on
resolution of existing open items associated with the Service Water
System inspection. The NRC review concluded the licensee had adequately i
addressed the technical issues associated with the service water
systems. Section E8 discusses items related to this service water
followup inspection.
E2 Engineering Support of Facilities and Equipment l
E2.1 Diesel Generator (DG) Startina Air system Relief Valves
a. Insoection Scooe (37551)
During the previous inspection period, the inspector observed an
emergency diesel generator (DG) starting air system relief valve lifting
due to overpressure. The inspector reviewed the documentation
associated with the relief valve PM program and the relief valve
corrective maintenance history,
b. Observations and Findinas
Due to problems being experienced with the DG starting air system
pressure control switches, the system relief valves had been documented
as lifting on several occasions. During tours with an assistant unit
operator (AU0) the inspector observed a lifting DG starting air system
relief valve. The inspector had noted that the relief valve was lifting
with a pressure of 345 psig on the starting air system receiver tank.
This observation was discussed in detail in IR 96 09 and included a
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violation for inadequate corrective action associated with the repair >
and replacement of the starting air compressor pressure control ;
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switches.
In order to determine proper operation of the relief valve, the
inspector reviewed the lift setpoints for the system relief valves. The
system control drawing. CCD No.l.2 47W839 2. NOTE 3. listed the design
' pressure as 250 psig. This drawing information was incorrect. The i
inspector noted that normal system pressure is controlled between 250-
300 psig.
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The design basis document, SQN-DC-V-11.8. documented the maximum I
operating condition as 300 psig and the design condition for the system !
at 330 psig. The work history noted that the relief valves were set in l
a range of 340 to 360 psig. The licensee is committed to the 1986
Edition of the ASME Pressure Vessel Code. The 1986 Edition of the ASME
Code,Section VIII UG 125 (c), states that all aressure vessels shall be ,
protected by a pressure relieving device that s1all prevent pressure l
from rising more than 10% above the maximum allowable working pressure 1
(operating condition) of the system. Contrary to the ASME code, the DG
starting air system relief valves were set above the allowable limit of
330 psig and this is considered to be a violation (VIO 50 327 328/96-11- 1
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c. Conclusions
The failure to properly adjust the DG starting air system relief valve
(8) setpoints is considered to be a violation.
E8 Miscellaneous Engineering Issues (92902. TI 2515/118)
E8.1 (CLOSED) IFI 95 03-01: Generic Letter (GL) 89 13 Actions on Dead Leg
Flushing, Chemical Treatment. High Pressure Fire Protection (HPFP)
System and Airside Cooler Testing i
This IFI identified that the licensee's GL 8913 committed actions were !
not fully implemented. Neither the licensee's actions nor the docketed !
GL 89-13 response fully encompassed the HPFP system. Also, the
licensee's docketed GL 89-13 response omitted discussion of room cooler
air side testing. l
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The inspector toured the ERCW intake pumping station and inspected the
ERCW pumps, strainers, traveling screens, and flood mode sump pumps.
Additionally, the inspector noted the chemical chlorination injection
line was being replaced. '
Regarding room cooler air side testing. the licensee's GL 89 13
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response, dated September 22, 1995, discussed that periodic air flow
testing was performed on the air side of the Emergency Safeguards
Features (ESF) room / area coolers and lower containment vent coolers to
confirm minimum air flow recuirements. The inspector determined that
this periodic testing was acequate.
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Regarding the.HPFP system, the licensee's position was that the HPFP
system was not a safety-related system and the HPFP system was not
included as a service water system as defined by GL 8913 because it did !
not add heat to the ultimate heat sink. The inspector concurred with :
the: licensee's position that the HPFP was not a service water system as l
defined by GL 8913. However, based on Technical-Specification
requirements, the licensee was maintaining the HPFP comparable to the GL
89 13 requirements. .
E8.2 (CLOSED) VIO 95-03 02: Inadequate Design Control Measures for ERCW,
This was a four part' violation that identified numerous deficiencies in I
design control measures associated with ERCW strainer plugging, use of
the HPFP system for flood mitigation, acceptability of replacement DG
batteries, and the setpoint calculation for turbine building isolation.
The inspectors reviewed the corrective actions contained in the
licensee's response dated May 22, 1995. Based on the inspectors review,
these corrective actions had been implemented and adequately addressed
the deficiencies. Accordingly, this violation is closed.
E8.3 (CLOSED) URI 95 03-03: Interpretation of Design Basis Flood
This Unresolved Item (URI) questioned whether the licensee's
categorization of the design basis for two 100% capacity ERCW upper deck
sump pumps as an " event" versus an " accident" was consistent with NRC
regulations. Due'to the licensee's classification that the upper deck
sump pumps were required to mitigate certain " events" but not the
consequences of an accident, the sump pumps had-not been included in any
pump testing or maintenance program.
The inspectors concluded that the upper deck sump pumps would not be
considered safety-related by any existing regulation. However,
occurrences such as fires, floods, missiles, storms, or earthquakes were
considered." events" and any event can lead to or cause an accident that
requires analysis under Chapter 15 of the UFSAR. Since the sump pumps
have some importance to safety, the licensee should have a testing
program to comply with General Design Criteria (GDC) I. GDC I requires ,
components important to safety be tested to quality standards
commensurate with the im)ortance of the safety function to be performed.
The inspector verified tie licensee had placed the ERCW sump pumps in-
the second ten-year inspection interval:for ASME Section XI. Since ASME
Section XI testing clearly meets the requirements of GDC I, this URI is
closed.
E8.4 (CLOSED) VIO 95-03 04: Inadequate Procedures or Improper Procedure
Implementation
This violation identified five examples of deficiencies with either
procedure quality or adherence. The examples cited were inadequate
review of procedure Abnormal Operating Instruction (A0I) 7. Probable
Maximum Flood,' failure to post a transient fire load permit, failure to
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place a work request sticker on inoperable control room instrumentation,
and inadequate performance of an equalivanency evaluation. The
inspectors reviewed the corrective actions contained in the licensee's
response dated May 22, 1995. Based on the inspectors review, these
corrective actions had been implemented and adequately addressed the i
deficiencies. Accordingly, this violation is closed. '
During the review of corrective actions for inadequate review of
procedure A01-7, the inspectors noted that a licensee Quality Assurance ,
(QA) audit had identified procedure Abnormal Operating Procedure (A0P)- '
N.03, Flooding, Revision 0, contained references to procedure 0 FP-MXX-
000 003 and did not contain actions that were in A0I 7. The licensee
had canceled procedure 0-FP-MXX-000-003. Flood Preparation - Parts, !
Tools, and Equipment to be Moved Above Elevation 723.1, and included a )
list of supplies and equipment that were to be moved above the flood
level in procedure A0P N.03. The licensee had issued PER No.
SQ962256PER dated August 2.1996 to document these QA audit findings. ,
The licensee issued A0P N.03 revision 1 effective September 6,1996 to I
address the QA audit findings, j
10 CFR 50, Appendix B, Criterion III, " Design Control " states in part ,
that " Measures shall be established to assure that applicable regulatory )'
requirements and the design basis . . . are correctly translated into
s)ecifications, drawings, procedures, and instructions." Contrary to
t1e above, the licensee failed to ensure the procedural guidance
provided in A0I-7 was pro)erly translated to A0P-N.03. However, the ,
licensee had identified tie problem and taken prompt corrective action. '
This licensee-identified and corrected violation is being treated as a
Non Cited Violation, consistent with Section VII.B.1 of the NRC
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Enforcement Policy. This is item is identified as NCV 50 327. 328/96- 4
11-05. Inadequate Translation of Procedural Guidance During AOP Upgrade
Program.
E8.5 (Closed) VIO 95 03 05: Failure to Identify Conditions Adverse to
Quality
This violation identified three examples for failing to initiate a
problem evaluation report of conditions adverse to quality. The
examples cited were multiple calculations that were not adequately
documented for stand alone review, multi)le deficiencies with plant
service water system identified during tie licensee's self assessments
in 1993 and 1994, and failure to comply with TS 6.2.3.4. The inspectors
reviewed the corrective actions contained in the licensee's response
dated May 22, 1995. Based on the inspectors review, these corrective
actions had been implemented and adequately addressed the deficiencies.
Accordingly, this violation is closed.
E8.6 (CLOSED) IFI 95-03 08: LC0 Considerations for Select Room Coolers
The licensee had issued a memorandum to Operations personnel providing
guidance on entry into LCOs when room coolers were removed from service.
The memorandum contained a matrix that related room coolers to the
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a)plicable LC0 and the unit or units affected. The inspectors concluded
t1e memorandum provided sufficient guidance to the operators.
E8.7 (CLOSED) IFI 95 03-10: Implementation of New Ultrasonic Testing
Methodology
This IFI identified the licensee's ultrasonic testing (UT) of piping had i
not been o)timized. The UT was a pass / fail test without attempting to
quantify t1e corrosion rate or predict through-wall failures. Within
the past year, the licensee began to gather data to determine corrosion
rate or predict through wall failure. The program had not been in
effect long enough to produce quantifiable results. i
The inspector held discussions with the engineering personnel involved
in the wall thickness inspections and reviewed the test data for two
areas inspected using UT identified as 1-67 D G057 and 1-67 W-G024.
Licensee trending of UT data indicated that base material thickness for ,
piping area 1-67 W-G024 was ap3 roaching minimum wall thickness and was I
recently replaced. Based on t1e inspectors evaluation, this program was
found to be adequate.
IV. Plant Support i
P1 Conduct of EP Activities )
Pl.1 Observation of Radioloaical Emeraency Preoaredness (REP) Drill
a. Insoection Scoce (82301) l
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On October 2, 1996, the inspector observed portions of an REP drill
which the licensee conducted in pre)aration for the November 6 full
scale REP Graded Exercise. On Octo)er 4, 1996, the inspector attended
the licensee's formal critique of the October 2 drill.
b. Findinas and Observations
The inspector observed the activation of the Technical Support Center I
(TSC) during this total loss of all offsite AC electrical power drill
scenario. To give a realistic effect the TSC normal lighting was
disabled and the TSC was illuminated only by installed emergency
lighting and hand carried flashlights. The TSC was staffed
expeditiously and appeared to function smoothly even with limited
lighting. The inspector observed that the licensee experienced problems
with the Integrated Computer System (ICS), an initial shortage of phone
headsets, and telecommunication problems with the corporate emergency ,
response center. These deficiencies were discussed by the licensee at i
the formal critique following the drill.
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c. Conclusions
The inspector concluded that the licensee conducted a challenging REP
drill scenario in preparation for the November 6,1996, graded REP
exercise. During the drill critique, the licensee was quick to identify
drill deficiencies and discussed ways to make improvements in the EP
program.
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Pl.2 Followuo !
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a. InsDeCtion SCODe (82701)
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The inspection focused on program initiatives to correct program I
deficiencies that were identified in an emergency preparedness l
inspection conducted in April 1996 and documented in Inspection Report i
50 327, 50-328/96 04.
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b. Observations and Findinas
Since the April inspection the licensee had conducted a self assessment
of the emergency preparedness program and completed the 50.54(q) review 1
of the program. The reviews resulted in some minor inconsistencies !
being corrected but both the self assessment and 50.54(q) review
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validated an effective program. The inspector's review of 1)
documentation addressing the maintenance of the emergency preparedness
- program, 2) equipment and facilities, and 3) review of training i
- documents and training was accomplished with no safety-significant
>
issues identified.
The focus of inspection observations was on the open items from the
April inspection. The inspector reviewed the radiological monitoring
i instrumentation in the Control Room against the instrumentation ranges
- and nomenclature identified in the EALs. No issues were identified,
which closed IFI 50 327, 328/96-04 05. The inspector reviewed selected
copies of the Emergency Plan and Implementing Procedures to verify that
controlled copies were being properly maintained. No discrepancies were
,
noted, thus closing VIO 50 327, 50 328/96 04-06. The inspector reviewed
the status of the batteries for the OSC radios. The batteries were
fully charged, with 11 spares available. The licensee had implemented a
program for maintaining the batteries. This closed VIO 50-327,
50 328/96 04-07. The inspector reviewed the licensee's implementation
of its tracking and closing of items identified as issues during drills.
The inspector found the licensee to be extremely aggressive in tracking
items and assigning responsibility for corrective action. This closed
IFI 50 327, 50 328/96-04 09.
c. Conclusions
The inspector's observations verified that the program was being managed
effectively, and that good corrective actions had been taken to
previously identified issues. Two open violations (50 327,
50 328/96 04 08 and 50-327, 328/96 04 10) were not reviewed because
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i additional information had been provided to NRC and a reply had yet to
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be provided.
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The emergency program was obstrved to be well managed and receiving
management support. Effectivo corrective actions taken to previous open
- items permitted the closure of two violations and two IFIs.
V. Manaarment Meetinas
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X1 Exit Meeting Summary
The inspectors ) resented the 11spection results to members of licensee
,
management at t1e conclusion of the inspection on November 5,1996.
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The licensee acknowledged the findings presented.
! The inspectors asked the licer see whether any materials would be
considered proprietary. No p'oprietary information was identified.
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! PARTIAL LIS1 0F PERSONS CONTACTED
Licensee
- Adney, R., Site Vice President
- Beasley, J., Acting Site Quality Manager
- Bryant, L., Outage Manager
- Burzynski, M., Engineering & Materials Manager
Driscoll, D., Training Marager
- Fecht, M., Nuclear. Assurar.ce & Licensing Manager
Fink F., Business and Wo"k Performance Manager
- Flippo, T., Site Support 11anager
- Harrington, W., Acting Ma'ntenance Manager
- Herron, J. , Plant Manager
Kent, C. 'Radcon/Chemistr) Manager
Lagergren, B., Operations ianager
Rausch, R. Maintenance and Modifications Manager
Reynolds, J., Operations Superintendent
- Rupert, J., Engineering and Support Services Manager
- Shell, R., Manager of Licensing and Industry Affairs
Skarzinski, M., Technical Support Manager
- Smith, J., Licensing Supervisor
Summy, J., Assistant Plant Manager
Symonds, J. Modifications Manager
- Attended exit interview
INSPECTION PROCEDURES USED
IP 37551: Onsite Engineering
IP 40500: Effectiveness of Licensee Controls In Identifying,
Resolving, & Preventing Problems
IP 61726: Surveillance Observations
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IP 62707: Maintenance Observations
IP 71707: Plant Operations
IP 71750: Plant' Support Activities
IP 82301: Evaluation of Exercises for Power Reactors
IP 92902: Followup Maintenance
TI 2515/118: Service Water System Operational Performance Inspection
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IO 82701: Operational Status of the Emergency Preparedness Program
- IHMS OPENED. CLOSED. AIO DISCUSSED
Ooened
TyRg Item Number
_ Status Descriotion and Reference
NCV 50 327, 328/96-11 01 Open/ Failure to Implement EGTS System
Closed Operating Procedure When Operating
EGTS (Section 01.2).
IFI 50-327, 328/96 11-02 Open Review corrective Action of PER No. i
SQ962511PER Related to ABI Function
of Radiation Monitor 0 RM-90-101C
(Section 02.1).
VIO 50 327. 328/96-11-03 Open Failure to Install Temporary Missile
Protection for ERCW Piping as
Required by SSP-7.4 (Section M2.3).
VIO 50-327, 328/96 11-04 Open Failure to Set DG Starting Air )
System Relief Valves with the ASME l
Code Limit (Section E2.1). j.
NCV 50 327, 328/96 11 05 Open/ Inadequate Translation of Procedural
Closed Guidance During A0P Upgrade Program.
(Section E8.4) ,
Closed
Typf Item Number Status Descriotion and Reference
IFI 95 03 01 CLOSED GL Actions on Deadleg Flushing Chemical
Treatment. HPFP System & Airside Cooler Testing
(Section E8.1)
VIO 95 03 02 CLOSED Inadequate Design Control Measures for ERCW.
HPFP and EDG Batteries (Section E8.2)
URI 95 03 03 CLOSED Interpretation of Design Basis Flood (Section
E8.3)
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VIO 95 03 04 CLOSED Inadequate Procedures or Improp: Procedure
Implementation (Section E8.4) ,
VIO 95 03-05 CLOSED Failure to Identify Conditions Adverse to l
Quality (Section E8.5) l
IFI 95 03 08 CLOSED LC0 Considerations for Select Room Coolers
(Section E8.6)
IFI 95 03-10 CLOSED Implementation of New Ultrasonic Testing
Methodology (Section E8.7)
IFI 96 04 05 CLOSED Inconsistency between Numenclature in the EALs
and Control Room, and Proper Terminology in the
EALs (Section Pl.2)
VIO 96 04 06 CLOSED Failure to Maintain Controlled Volumes of the I
EPIPs up to date (Section Pl.2) l
VIO 96 04-07 CLOSED Failure to Maintain Operational Readiness of the i
Batteries for the Emergency Two way Radios in l
the OSC (Section Pl.2)
IFI 96-04-09 CLOSED Verify the Tracking and Resolution of Corrective
Action Items and Items Needing Improvement
Identified in Drill Reports (Section 1.2)
LIST OF ACRONYMS USED
ABI -
Auxiliary Building Isolation l
AC - Alternating Current
AFW -
A0I -
Abnormal Operating Instruction
A0P -
Abnormal Operating Procedure
ASME -
American Society of Mechanical Engineers
AU0 -
Assistant Unit Operator
CCP -
Centrifugal Charging Pump
CFR -
Code of Federal Regulations
CLA -
Cold Leg Accumulator
DG -
Diesel Generator
DRP - Division of Reactor Projects
ECCS -
Emergency Core Cooling Systems
EDG -
EGTS - Emergency Gas Treatment System
EHC -
Electro Hydraulic Control
EP -
ERCW - Essential Raw Cooling Water
ESF -
Engineered Safeguard Features
GDC -
General Design Criteria
GL -
Generic Letter
gph -
Gallons per hour
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HV - High Voltage
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ICS -
Integrated Computer System
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IFI -
Inspector Followup Item
IR -
Inspection Report
KV -
Kilo Volt
LC0 -
Limiting Condition for Operation
LER -
Licensee Event Report
MI -
Maintenance Instruction
MSIV - Main Steam Isolation Valve
MCR -
Main Control Room
NIS -
Nuclear Instrumentation System
NOUE -
Notification of Unusual Event
NCV -
Non cited Violation
NRC -
Nuclear Regulatory Commission
NRR -
Nuclear Reactor Regulation
j ODCM -
Offsite Dose Calculation Manual
PCF -
Procedure Change Form
PER -
Problem Evaluation Report
PM -
Preventive Maintenance
PMT -
P00 -
Plan of the Day
PT -
Potential Transformer
. psig -
pounds per square inch gage
. QA -
Quality Assurance
! QC - Quality Control
! RCS -
i REP - Radiological Emergency Plan
RHR -
RM -
Radiation Monitor
- rpm -
Revolutions per Minute
RVLIS - Reactor Vessel Level Indication System
SALP - Systematic Assessment of Licensee Performance
SFP -
Spent Fuel Pit / Pool
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SI -
Surveillance Instruction
SR0 -
Senior Reactor Operator
. SSP -
Site Standard Practice
Solid State Protection System
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SSPS -
TI -
Tem)orary Instruction l
TS -
Tec1nical Specifications
4
TSC -
l TVA -
Tennessee Valley Authority
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UFSAR - Updated Final Safety Analysis Report
UT -
Ultrasonic Testing
URI -
Unresolved Item
VCT -
Volume Control Tank
VDC -
Volts Direct Current
Violation
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VIO -
WO -
Work Order
WR -
Work Request j
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