ML20199L344

Insp Repts 50-327/86-15 & 50-328/86-15 on 860206-0305. Violation Noted:Failure to Comply W/Tech Spec 6.2.3 Re Independent Safety Engineering Group

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: ML20199K434 ML20199K478 ML20199L344
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

Text

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SS REcg UNITED STATES

o NUCLEAR REGULATORY COMMISSION

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f . k .N 101 M ARIETTA STREET.N.W.

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

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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;

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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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