ML20205P021

Insp Repts 50-327/86-19 & 50-328/86-19 on 860306-0415. Violation Noted:Failure to Establish Adequate Procedures for Verification of Positions Critical to Operation of Auxiliary Bldg Gas Treatment Sys

ML20205P021
Person / Time
Site:	Sequoyah
Issue date:	05/06/1986
From:	Debs B, Harmon P, Jenison K, David Loveless, Linda Watson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20205P007	List: ML20205P003 ML20205P014 ML20205P021
References
50-327-86-19, 50-328-86-19, IEIN-85-069, IEIN-85-69, IEIN-86-017, IEIN-86-17, NUDOCS 8605210078
Download: ML20205P021 (22)

See also: IR 05000327/1986019

Text

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na Mag UNITED STATES

/ o NUCLEAR REGULATORY COMMISSION

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$ REGloN 11

D 101 MARIETTA STREET, N.W.

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Report Nos.: 50-327/86-19 and 50-328/86-19

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 l

Facility Name: Sequoyah Units 1 and 2 l

Inspection Conducted: March 6 - April 5, 1986

Inspectors: **

K. M. Jenison, denior Resid p I6s

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Date Signed

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L. J. Watson, Kesident EnsqpG or [ ~

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P. E. Harmoa, <esident Ins fctor y

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Date Signed

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D. P. ]vtn e s s , Kesident Wfspectorf

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Date Signed

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Approved by: /

B. T. Debs, Section Chief. Date' Signed

Division of Reactor Projects

Summary

Scope: This routine, announced inspection involved 451 resident inspector-hours

j onsite in the areas of: operational safety verification (including operations

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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; review of Part 21 implementation; and review of

inspector followup items.

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Results: Three violations were identified:

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PDR ADOCK 05000327

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1. Failure'to establish adequate procedures as required by Technical Specifica-

tion (TS) 6.8.1 for verification of valve positions critical to the ,

operation of ~ the auxiliary building gas treatment system, emergency gas  !

treatment system and upper head injection system (paragraph 3).

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2. Failure to implement procedures as required by 10CFR 50 Appendix B,

Criterion V, for the following activities (paragraphs 6 and 10):

a. Control of fuses in en Energency Diesel Generator support system.

b. Review of Unreviewed Safety Question Determination for a field change

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request (FCR) to the Unit 2 Train A hydrogen analyzer.

c. Review of system drawings and independent review of system design prior

to approval of a FCR. ,

d. ' Provisions for auditabl'e record of design reviews which support plant

,modjfications.

e. Plant Operations Review Committee review of modifications.

3. Failure to meet the Limiting Gondition for Operation for TS 3.6.4.1 which

requires the two trains of hydrogen analyzers to be operable in Modes 1 and

2 (paragraph 10).

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REPORT DETAILS

1. Licensee Employees Contacted

H. L. Abercrombie, Site Director l

• P. R. Wallace, Plant Manager

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• 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. Sedlacik, Electrical Section Manager, Modifications Branch l

• H. D. Elkins, Instrument Maintenance Group Manager l

C. W. LaFever, Instrument Engineering Supervisor l

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

D. H. Tullis, Mechanical Maintenance Group Supervisor

J. H. Sullivan, Regulatory Engineering Supervisor

• P. R. Hitchcock, Mechanical Engineer, Mechanical Maintenance

• L. S. Bryant, Engineering Supervisor, Mechanical Maintenance

• W. E. Andrews,' Site Quality Manager, QA

• T. A. Kontovich, Electrical Maintenance Engineering Supervisor

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• M. J. Blankenship, Manager, Information Services

J. S. Steigleman, Unit Supervisor, Fealth Physics

C. L. Lagasse, Instrument Maintenance Foreman

Other. licensee employees contacted included technicians, operators, shift

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engineers, security force members, engineers and maintenance personnel.

Other:

• R. W. Bass, BETA

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• Attended exit interview

2. Exit Interview

The inspection scope and findings were summarized with the Plant Manager and

members of his staff on April 15, 1985. Three violations, two of which

involved multiple examples, were discussed. The violations are described in

paragraphs 3, 6, and 10. ~ Three unresolved items, described in paragraphs 5

and 7, were also discussed. The licensee acknowledged the inspection

findings. The licensee did identify material reviewed by the inspectors

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during this inspection as proprietary. However, no proprietary information

was included in this inspection report. 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 inspector.

3. Licensee Action on Previous Inspection Findings (92702)

(Closed) Violation 327/85-17-04 and 328/85-17-03. This violation involved

examples of inadequate written procedures in three separate areas: (1)

surveillance testing, (2) maintenance activities, and (3) post-modification

testing. The inspector reviewed the licensee's corrective actions for the

procedures involved and the documentation of the procedural changes. The

licensee's corrective actions appear to be adequate. This item is closed.

(Closed) Unresolved Item 327,328/85-43-02. This unresolved item was

identified when the inspectors determined, during a walkdown of the

auxiliary building gas treatment system (ABGTS), that valves in the air

supply to all air operated dampers in the ABGTS were not included in the

valve checklist for system operability. Isolation of these valves could

result in loss of the capability to automatically open dampers required for

system operability.

The inspector reviewed additional examples of licensee controls for position

verification of other valves critical to the operation of safety-related

dampers and valves. The inspector determined that the system lineup

checklist for the emergency gas treatment system (EGTS) did not include air

supply valves, which if isolated could result in the inoperability of

dampers required to open for use of the EGTS. The inspector also reviewed

the control of the hydraulic lock release valves which must be in a

throttled open position to assure the closure of the UHI isolation valves on

low UHI water accumulator level. The inspector determined that the valves

were not locked in position and the position was not verified during system

operability walkdowns.

TS 6.8.1 requires that procedures be established as recommended in Appendix

A to Regulatory Guide 1.33, Revision 2. RG 1.33 requires that procedures

address startup of safety-related equipment. The licensee utilizes System

Operating Instructions to meet this requirement. Failure to adequately

establish procedures for the control of valves critical to the operation of

safety-related equipment is a violation (327,328/86-19-01). Unresolved item

327,328/85-43-02 on this issue is closed.

(Closed) Unresolved 327,328/86-06-06. The inspectors reviewed modifications

to the hydrogen analyzers which resulted in failure to provide a safety-

related air supply to the analyzers. Two violations as discussed in

paragraph 10 of this report were cited. This unresolved item is closed.

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(0 pen) . Violation 327, 328/85-45-06. The licensee's response to the

violation dated March 20, 1986, was reviewed. The inspector noted that the

response to the violation did not address corrective action in regard to

trending calibration data for safety-related systems to assure that

out-of-calibration conditions are identified and evaluated. The licensee's

Nuclear Performance Plan does address this trending program. Followup on

these licensee actions on trending will. be reviewed as part of the inspec-

~ tion of the Nuclear Performance Plan commitments.

The inspectors observed installation and testing of the Upper Head Injection

level switches. One inspector followup item and one unresolved item were

identified as described in paragraphs 7 and 8. The installation of the

level switches is considered complete; therefore, part b, of the violation

is. closed. The violation will be held open until inspection of corrective

action for part a. is completed.

4. Unresolved Items

Unresolved items are matters about which more information is required to

determine whether they are acceptable or may involve violations or devia-

tions. Three unresolved items were identified during this inspection as

discussed in paragraphs 5 and 7.

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 Specifica-

tion (TS) Limiting Conditions for Operation (LC0) and verified return

to service of affected components. The inspectors verified that

maintenance work orders had been submitted as required and that

followup activities and prioritization of work was accomplished by the

licensee.

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

excessive vibrations and plant housekeeping / cleanliness conditions.

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:

Residual Heat Removal System (Units 1 and 2)

Diesel Generdtor 1A-A and IB-B Air Start System, ERCW Supply

and Fuel Oil System (Units 1 and 2)

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Auxiliary Control Air (Units 1 and 2)

Auxiliary Building Gas Treatment System (Units 1 and 2

One violation discovered during the walkdown of the Emergency Diesel

Generator is discussed in paragraph 6.

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; escorting of visitors;

badge issuance and retrieval; and patrols and compensatory posts.

In addition, the inspectors observed protected area lighting, protected

and vital area barrier integrity and verified the interface between the

security organization and operation and maintenance. The inspectors

visited the secondary alarm station and interviewed security personnel

regarding response to security events. A concern was identified

related to the update of procedures. The licensee corrected the

concerns prior to the end of the inspection period.

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 activi-

ties 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.

(1) On January 15, 1986, the licensee determined that cracks in the

walls of the Condensate Demineralizer Waste Evaporator Building

(CDWEB) were allowing seepage of radioactive water into a

non-regulated area. An NRC specialist reviewed this event and

the results of the inspection were provided in NRC Inspection

Report 327,328/86-04. In addition to the radiological aspects

of the inspection, several concerns were raised regarding main-

tenance of the evaporator recirculation pumps and CDWE venti-

lation. Areas of concern identified by subtitle below were

reviewed.

(a) t4aintenance Activities

The inspector reviewed the licensee actions concerning the

maintenance of radwaste systems in the CDWEB. The

licensee has experienced problems with drainage from steam

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traps in the moisture and steam wash drain system, blocked

floor drains and failure of recirculation pump seals

resulting from loss of seal water. The floor around the

pumps and other areas subject to leakage slopes toward the

outside wall of the CDWEB and away from the drain

resulting in standing water in these areas.

The licensee has initiated modifications to reslope the

floor toward the drains and provide a backup supply of

seal water to the pump seals. The licensee has unclogged

floor drains and routed drains from the steam traps and

moisture separator to the floor drains. The licensee

stated that the repair of the cracks in the building wall

has been completed and the floor will be recoated

following work to reslope the floor. However, due to

other work loads, the licensee has delayed implementation

of some of these work plans.

(b) Review of Major Changes to the Liquid Radwaste System In

Accordance With TS 6.15

In 1982, the licensee changed the permanent lineup of the

radwaste system to allow the CDWE to process all radwaste

produced by the plant. The licensee removed the original

waste and auxiliary waste evaporators from service.

Previously, the CDWE only processed waste from the

condensate demineralizer system and the floor drain

collector tank. The new configuration allows the CDWE to

process the contents of the tritiated drain tanks. In

addition, the licensee installed and utilized mobile

radwaste procsssing equipment with temporary connections

to the radwaste system. The licensee stated that

permanent piping changes were not made to accomplish these

functions.

These changes in the permanent lineup involved a major

change to the liquid radwaste system and thus should have

been reviewed in accordance with TS 6.15. The licensee

provided the inspector with a safety evaluation dated

April 26, 1985. The inspector reviewed the safety

evaluation and although it discusses the 10 CFR

50.59 evaluation, the inspector determined that it

did not meet all the requirements for the review

required by TS 6.15. The licensee also provided an

FSAR update on April 11, 1985. The FSAR update does

not appear to meet the requirements of TS 6.15.

Also, the licensee was not able to provide evidence

of a PORC review of the radwaste system change.

Determination of the licensee's compliance with TS 6.15 is identified as Unresolved Item 327,328/86-19-02.

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.(c)' CDWEB Ventilation-

,The inspector reviewed the ventilation to the CDWEB and -

determined that' the CDWEB ventilation is supplied by the

' Auxiliary Building general ventilation system. The

exhaust. is routed to' the Fuel Handling area ventilation

system and to the Auxiliary Building stack. Radiacion

monitors in -the Auxiliary Building stack cause an

isolation of any radi_oactive release to the environment

during normal operation on receipt of a high radiation

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signal.

However,- the -CDWEB is isolated from the Auxiliary

Building during an Auxiliary Building Isolation (ABI).

The' CDWE is continuously manned during operation of the

processing system. During extended periods of Auxiliary

Building isolation or indications of high radiation levels

in the CDWEB, the system is manually shutdown and the CDWEB

s is evacuated. The building remains evacuated until deter-

-minations are made that radiation levels in the 'ouilding .

are acceptable for reentry. .The evacuation is controlled

, administratively. Review of the licensee's administrative

controls for evacuation and cleanup of the CDWEB -is identi-

fied as IFI'327,328/86-19-04

~ The CDWEB is a Seismic Category 'I building with ~one

entrance through double doors from the yard and one

entrance from the Auxiliary Building. The FSAR . states

that the CDWEB will be maintained at a slight negative

pressure by the normal ventilation system. This is not

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accomplished during an ABI. The inspector expressed a

concern that the building could contain airborne radiation

and be' isolated from cleanup systems. The licensee is

evaluating the CDWEB _for potential release paths. This

issue is the first example of Unresolved Item

327,328/86-19-03.

(d) HVAC

The inspectors reviewed documentation related to the HVAC

for the CDWEB. The CDWEB has two HVAC units which are

described in the FSAR and are designed to maintain the

building temperature below 105 degrees F. One of these

units has been inoperable for approximately two years.

The second unit does not operate at optimal performance

and has : at times been inoperable during summer months.

There is no method to assure that the FSAR temperature has

been maintained. This issue is the second example of

Unresolved Item 327,328/86-19-03.

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(e) Preventive Maintenance and ALARA

Working conditions and -ALARA implementation in this

building, which is continuously manned when the CDWE is in

operation, have been a continuing problem. Additional

cleanup time for spills was expended because of the

chronic problems with the floor drains stopping up and the

floor sloping away from the drain in many areas.

Contamination under control panels in the control area

have resulted from the spills. Plans for permanent

improvements were initiated by DCR 1513 in February,1982.

To date only a few of the modifications have been made.

These modifications were made in August, 1985.

FSAR Section 11.2.4 states that all equipment installed to

reduce radioactive effluents to the minimum practical

level is maintained in good operating order. In addition,

the section states. that in order to assure that these

conditions are met, administrative controls. are exercised

on overall operation of the system, preventive maintenance

is utilized to maintain equipment in peak condition and

experience available from similar plants is used in

planning for operation. In light of the problems

discussed above, many of which have existed since the

original design of the CDWEB and were not corrected for a

number of years after increasing the volume of radwaste

processed by the CDWE, adherence to licensee commitments

in regard to maintaining the liquid radwaste system in

good operating condition is questionable.

The inspector discussed the preventive maintenance program

with the licensee. The FSAR states that preventive

maintenance will be implemented based on vendor

recommendations. The licensee stated that the only

preventive maintenance was walkdowns of the liquid

radwaste system and correction of problems affecting

operation. The inspector will review implementation of

vendor recommendations. This review is identified as the

third example of Unresolved Item 327,328/86-19-03.

(2) On March 26, 1986, during an observation of work being done under

MR A-529943, the inspector reviewed RQP 02-0-86668 associated with

the job. It was noted that workers were wearing the appropriate

protective clothing. Also, the RWP log showed that the indivi-

duals were not exceeding their stay limits. The inspector

observed that a condition on the RWP required "HP to provide Job

Coverage." An HP trainee had signed off on March 25, 1986, for

this coverage. The workers told the inspector on March 26, 1986,

that the HP had pulled an air sample prior to work commencing the

day befora. When questioned, the workers stated that they had not

seen any HP coverage on the job that day.

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Licensee personnel indicated to the inspector that there was no

problem with the situation. They indicated that the RWP was

unclear, in that coverage was only required when breaching the

system or when performing special processes on potentially

contaminated components. The licensee further indicated that only

clean piping was being worked on during the time of the inspector's

observations. The inspector reviewed the surveys for the zone and

found the piping to be within acceptable limits for the welding

and grinding being done. The apparent poor ALARA practice of

fitting and welding clean pipe in a contaminated area was brought

to the attention of the licensee.

The inspector discussed with the licensee the procedures for use

of HP trainees in day-to-day activities. Trainees are required to

complete each section of a Health Physics training program and

complete an oral examination on that section before they are

allowed to perform tasks covered under that section. The

inspectors reviewed the qualifications of the trainees involved

with the surveys under RWP-0-86668 and determined that they had

completed the appropriate sections of their qualifications.

No violations or deviations were identified.

d. Inspection of Licensee's Performance of Primary Calorimetries

The inspectors evaluated the licensee's performance of primary

calorimetries to ascertain secondary electrical power generation.

Sequoyah Unit 1 electrical output decreased beginning in the third fuel

cycle in June 1984. TVA employed a vendor to investigate the problem,

confirm the cause of the reduction in electrical output and identify a

course of actinn to recover the loss in output.

Preliminary determinations were that the reduction in electrical output

was being caused by fouling of the venturi nozzles used for feedwater

flow measurement. The fouling of the venturi nozzles caused a change

in the ratio of actual flow through the nozzle to the differential

pressure across it. This ratio of flow rate to differential pressure

was used by the P-250 process computer to calculate reactor power.

A special test was written to incorporate the use of ASME nozzles on

the condensate side of Unit 1. Calorimetries were performed using the

condensate flow nozzles, the P-250 and a third set of specialized

instruments (Rosemonts). In 1983 corrections were made to the P-250

calorimetric based on the difference between the condensate and

feedwater calorimetries. This correction was applied directly to the

flow conversion constant. In 1984 the licensee determined that the

condensate flow nozzles were also starting to foul.

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The licensee contracted with a vendor to develop a calorimetric

comparison process. The comparison method was approved by the licensee

for use in 1985. This calorimetric comparison was incorporated into a

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Technical Instruction (TI-2). After each performance of TI-2, a

correction was made to the feedwater flow conversion constant such that

the P-250 and Rosemont generated calorimetrics remained within 1% of

each other.

The inspector found the calorimetric comparison process to be repea-

table and the conversion constants appeared to be conservative with

respect to.the setting of primary instrumentation.

No violations or deviations were identified.

c. The inspectors reviewed documentation concerning an Auxiliary Building

Isolation event that occurred on April 4,1986 at 0740 CST. The event

was caused by an electrician stepping on the disconnect switch for the

" Instrument Power Distribution Panel 1A" transformer, causing the

switch to open. The inspectors reviewed the event to verify that the

event was caused tar personnel error and not by some underlying cause.

The electrician involved was working overhead on fire protection

modifications, and was climbing down from the scaffolding at the time

of the occurrence. The licensee reported this event within four hours.

No violations or deviations were identified.

6. Engineered Safety Features Walkdown (71710)

a. The inspector verified operability of the Emergency Diesel Generators

(EDGs) on Units 1 and 2 by completing a walkdown of the EDGs. The

following specifics were reviewed and/or observed as appropriate:

1. that the licensee's system lineup procedures matched plant

drawings and the as-built configuration;

2. that equipment conditions were satisfactory and items that might

degrade performance were identified and evaluated (e.g. hangers

and supports were operable, housekeep0 g etc, was adequate);

3. 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;

4. that instrumentation was properly valved in and functioning and

calibration dates were appropriate;

5. that valves were in proper position, breaker alignment wac

correct, power was available, and valves were locked as required;

and

6. local and remote instrumentation was compared, and remote

instrumentation was functional.

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b. During the walkdown, the inspector was accompanied by several Auxiliary

Unit Operators (AU0s) over several days who assisted in locating and

verifying breakers, fuses, switches, and other electrical components

listed in the Power Availability Checklists. The checklists are part

of System Operating Instructions S0I-82.1, .2, .3, and .4 which verify

status and availability of the four EDGs.

Using the S01s and the attendant checklists to perform the safety

system walkdown, the inspector discovered that 10-ampere fuses were

installed for the AC auxiliary lube oil pumps for EDG 2A-A. This is

a departure from the checklist in that the checklist specifies that

1-ampere fuses are to be installed.

10 CFR 50 Appendix B, Criterion V, requires that activities affecting

quality be prescribed by documented instructions, procedures, or

drawings, of a type appropriate to the circumstances and that these

activities be accomplished in accordance with these instructions,

procedures, or drawings. The licensee failed to accomplish activities

affecting quality in accordance with the established procedure in that

incorrect fuses had been installed in EDG safety-related support

systems. This is identified as the first example of Violation

327,328/86-19-06. Additional examples of this violation are discussed

in paragraph 10 of this report.

Procedure checklist 82.3J, which covered operability of EDG 2A-A

electrical components, was very difficult for the inspector and the

experienced AU0s to follow and complete. In several instances, the

AVO, who had been using the checklists for some time, could not readily

find and/or identify the components on the checklist. Some fuses were

so difficult to read that it was not possible to verify the type and

size without pulling the fuses out of the bayonet clips. In several

cases, pulling fuses starts an EDG. Notes are included in the

checklists to alert the operators to this possibility. Nevertheless,

on April 6, 1986, an inadvertent start of the EDGs occurred when an AU0

tried to rotate a fuse in a clip and the fuse popped out. The event

took place while the AVO was performing an EDG electrical component

verification using S01 82.3. This inadvertent start of the EDGs while

checking fuses is not an isolated event. The problems evidenced by the

difficulty of the AU0s performing fuse checks required by the check-

lists appears to be due to both inadequate training of the AU0s and

poorly written procedures. This issue will be followed as IFI 327,-

328/86-19-05.

The checklists have cross-references listed in some cases that have no

meaning for the operators. These cross-references are inserted to help

identify the fuses and switches by both type and/or location. In some

cases these cross-references are useful in locating and identifying

equipment that an individual operator may see only once a year.

However, the inspector encountered enough instances of the operators

not being able to find or identify equipment (especially fuses) to make

the checklist less than an ideal document.

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When the operators were questioned as to why they had not revised the

checklists to make them easier to use, they indicated that the proce-

dure to initiate changes was both cumbersome and rigid in its imple-

mentation. As a result, procedura changes to correct and modify the

checklists were not made when areas for enhancement were identified by

the operators. The fuses identified in the violation as being the

wrong size were apparently installed at the time the modification that

originally installed the auxiliary lube oil pumps was implemented in

1982.

Another violation involving fuses was issued to the licensee in

December 1985, as violation 327,328/85-46-04. The corrective actions

for this violation included correcting the procedure that specified the

wrong size fuses in the Auxiliary Building Gas Treatment System, and

changing the administrative procedures which cover the reviews of

modifications.

The inspector learned during discussions with licensee personnel that a

program to verify correct fuse size and type is presently in effect.

The fuse verification program was initiated by the licensee in January

1986. In addition to the fuses identified by the inspector, the

licensee has discovered other discrepancies involving fuses of the

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wrong size or type during this inspection period. These licensee

identified items involved improper fuses installed in two vital battery

chargers and in the EDG emergency start circuits. The program as

described appears similar to the one that was implemented in 1982 in

response to violation 327,328/82-18-01. This 1982 program, was com-

pleted in August 1984. Further inspection of the fuse verification

program will be included in the followup inspection of corrective

action for Violation 327,328/86-19-06.

c. In addition to the violation detailed above, two separate followup

items were identified by the inspector as a result of the safety

system walkdown of the EDGs. Additionally, several minor errors in

the procedure were identified to the licensee for correction.

The inspector observed an Auxiliary Unit Operator (AU0) perform a

walkdown to place a diesel generator back in service. The AU0 dis-

covered that the cooling water throttle valves were improperly set.

The 501 calls for the throttle valves to be adjusted a selected number

of turns from full open, but the as found setting for three of the

- eight valves indicated that the valves had been adjusted from the full

closed position. In each case, the as found position was conservative

with respect to cooling water flow. The base cause of the misposi-

tioned valve and the cooling system design will be reviewed as IFI

327,328/86-19-07.

The inspector also observed trash and debris in control and power

cabinets. Housekeeping concerns identified during the walkdown will

be followed as IFI 327,328/86-19-08.

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d. During a review of the licensee's disposition of Significant Condition

Reports

was (SCRs)

identified. related

The Officeto

ofthe EDGs, an0E)

Engineering app (arent programmatic

reviewer of an SCR fromproblem

the Browns Ferry plant made what appears to be an incorrect determina-

tion of non-applicability to the Sequoyah units. The reviewer based

part of his determination of non-applicability on a questionable -

interpretation of the term " generic". Inspection of licensee controls

on the review of SCRs for generic applicability is identified as IFI

327/328 86-19-09.

7. Monthly Surveillance Observations (56700, 61700, 61726)

The inspectors observed 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:

PMT 74 Post Modification Testing of the Shunt Trip Modification

to the Reactor Trip Breakers

PMT-10 Emergency Control Room Lighting

WP 11907 Post Modification Testing of Upper Head Injection (UHI)

Level Switches

During the inspection of the post modification testing of the UHI level

switches, which was conducted after the replacement of the Barton Model 28St.

UHI level switches by Static 0 Ring (SOR) level switches, the inspector

observed instrument maintenance technicians set the stroke time for UHI

valve 2-FCV-87-22. The inspector reviewed Work Plan 11907 including the

post modification test requirements. The valve stroke time requirements

were provided by Westinghouse based on the preoperational test of the UHI

system. The stroke time requirement was 3.5 seconds plus or minus 0.05

seconds.

During a subsequent control room tour, the inspector observed that the alarm

setting for the charge on the hydraulic accumulators, which are bled down to

close the UHI valve, was at approximately 2800 psig. The stroke time had

been set for the valve with the accumulator fully charged. A fully charged

accumulator can be over 3000 psig. However, this value was not recorded

during the post modification test. Two of the control room readings

indicated up to 3025 psig. The inspector questioned licensee concerning the

discrepancy and the effect on valve stroke time.

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The licensee retested one valve utilizing an accumulator charged to 2800

psig. The stroke time was 3.57 seconds or 0.02 seconds over the required

stroke time. The licensee indicated that the stroke time for the valve with

-

a fully charged accumulator had been 3.52 seconds. This indicates that the

difference in the accumulator charge results in a 0.05 second slower stroke

time.

The licensee has requested Westinghouse to determine if the stringent stroke

time is necessary to meet TS 4.5.1.2.c which requires the valve to close

automatically at a prescribed water level. Review of the Westinghouse

analysis and determination of compliance with the TS is identified as

Unresolved Item 327,328/86-19-10.

8. Moi.hly Maintenance Observations (62703)

a. Station maintenance activities of safety-related systems and components

were observed / reviewed to ascertain that they were conducted in accor-

dance 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

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) progran; and

housekeeping actively pursued,

b. The inspector observed work being done on the repiping of the boric

acid system between the boric acid mixing tanks and the boric acid

transfer pumps. The work was being performed under MR A-529943. The

I inspector reviewed four procedures associated with this work:

M&AI-1 Control of Weld Documentation and Heat Treatment

MI-6.15 General Procedures, Tightening Mechanical Bolted

"

Joints

M&AI-11 Fabrication, Installation, and Documen:ation of

Seismic Supports and Supports Attacher to Seismic

Category I Structures

MI-6.21 Repairs and Replacements of ASME Section XI Components

The above procedures were all PORC approved and controlled copies were

being utilized. The inspector observed that the work was being done in

accordance with procedures and that appropriate QC hold points were

being signed off. It was noted that a current welding permit was in

effect and that a fire watch was posted.

_. _ _ _ _ . _ _ _ . _ -_ _ _ _ . .___-_ _ ___ _ _

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c. The inspector observed special maintenance being performed on EDG 1A-A

under Special Maintenance Instruction SMI 0.82.2, Repair and Replace-

ment of Diesel Generator Power Assemblies. -This special maintenance

was initiated by a periodic test of oil samples that indicated the

presence of excess lead in the oil of the 1A-A diesel.

Inspection of the bearings and power assemblies (piston and connecting

rods), revealed one cracked connecting rod bearing and several wrist

pin bearings with excessive wear. In addition, two connecting rods had

metal burr development on the top half of the bearing basket at the

basket to rod blade interface. Both connecting rods and all damaged or

worn bearings were replaced.

The cracked bearing is being investigated by the licensee to determine

the failure cause and mechanism. The burr development is a recurring

problem on this model (EMD) engine. The problem is caused by a loose

fit of the bearing basket.

Work on the diesel was performed by the Mechanical Maintenance Section

in accordance with Surveillance Instruction SI-7.1, Diesel Generator AC

Electrical Power Source Operability Verification (Diesel Generator /

Offsite Source), and Post Modification Test PMT-10.1. During mainten-

ance, Maintenance Instruction MI-6.20, " Configuration Control During

Maintenance Activities " was followed.

d. The inspector witnessed the installation of the UHI water accumulator

level switches for Unit 2. The new level switches, manufactured by

Static 0-Ring (SOR) were installed to replace the Barton 288A model.

The functional test performed after the new switches were installed

involved the introduction of a " dummy" signal which simulates an

accumulator low water level. The low level signal generated by the

level switches should cause the accumulator isolation valves to shut,

thereby preventing the introduction of nitrogen into the upper head of

the reactor vessel following a LOCA. Instead of causing the isolation

valves to shut on low level in the accumulator, the switches as

installed worked in reverse, shutting the valves when the simulated

level was raised above setpoint, and allowing the valves to be opened

when the level was lowered below setpoint.

Review of the work plan, WP 11907, verified that the switches were

installed as specified by the work plan. When the instrument mainten-

ance technicians determined that the work plan was in error, the test

was stopped and the Office of Engineering (0E) was contacted to

determine the source of the error.

OE reviewed the print supplied to implement the work plan and deter-

mined that the print was in error. The licensee also determined that

the Unit 1 level switches, which had been installed under a similar

work plan, had been installed backwards. Post modification testing had

a

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15

not been conducted for the Unit 1 switches at the time of discovery of

the error. The error was corrected by OE and the switches subsequently

reinstalled correctly on both units.

Inspection of the modification review performed by 0E for the print

issued to implement the original work plan is identified as IFI

327,328/86-19-11.

No violations or deviations were identified.

9. Licensee Event Report (LER) Followup (92700)

The following LER was reviewed and closed. 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; no unreviewed

safety questions were involved; and violations of regulations or TS condi-

tions had been identified.

328/85-12 Containment Hydrogen Analyzer Air Supply

10. Event Followup (93702, 62703)

On December 11, 1985 the licensee identified, as a result of a Quality

Control Division system walkdown, that the reagent air supply for the Unit 2

A train containment hydrogen analyzer was connected to a nonessential air

system, i .e. , control air. The A train containment hydrogen analyzer was

declared to be inoperable and the licensee issued Licensee Event Report

328/85-12. Unresolved Item 327,328/86-06-06 was identified to followup on

the error. Based on the discussion below, the Unresolved Item is closed.

LER 328/85-12 and the following additional documents were reviewed:

NCR EEB 8014 Non-Conformance Report - Electrical Engineering

Branch

DCR 972 Design Change Request

FCR 2468 Field Change Request

FCR 3275 Field Change Request

EN DES-EP 3.10 Office of Engineering Procedure - Design

Verification Methods and Performance of Design

Verification

EN DES-EP 4.06 Office of Engineering Procedure - Field Change

Requests Initiated by NUC PR

AI-19 Pt. IV Office of Nuclear Power Administrative Instruction

- Plant Modifications After Licensing

In addition, interviews and meetings were held with licensee personnel in

order to evaluate the root cause of the incident and the licensee's cor-

rective actions. The following issues were identified:

a. NCR 8014 was written to identify a significant condition adverse to

quality. It specified that certain portions of the hydrogen monitors

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were to be relocated to an accessible mild environment. In conjunction

with NCR 8014, DCR 972 was issued to facilitate the environmental

qualification to NUREG 0588 requirements of safety related components.

One of the approximately one hundred ECNs generated by DCR 972 was ECN

6023 for relocation of hydrogen analyzer panels.

When ECN 6023 was implemented, the cognizant modifications engineer

determined that nonessential air was available in the area where Units

1 and 2 train A hydrogen analyzer monitors were to be relocated and

essential air would have to be piped into the area. FCR 2468 was

written by the site cognizant engineer to exchange a non-essential

reagent air supply for the originally designed essential air supply.

The cognizant engineer discussed the change, by telephone, with the

appropriate Office of Engineering (0E) review engineer, and together

they erroneously determined that the reagent air supply was only needed

for calibration and therefore did not have to be safety related. This

personnel error was presented in LER 328/85-12 as the root cause of the

event.

The inspector determined that personnel error was a contributing

factor; however, it was not the root cause of the event. The site

cognizant engineer, the OE review engineer and the engineer who

performed the OE independent check failed to comply with AI-19 and EP

4.06 which require determination of FCR category based on the

Unresolved Safety Question Determination (USQD) evaluation prior to FCR

approval. When questioned, all three engineers stated that the USQD

was not reviewed prior to the erroneous determination that FCR 2468 was

within the ECN 6032 USQD.

10CFR50 Appendix'B Criteria V, states that activities affecting quality

shall be prescribed by documented instructions, procedures, or

drawings, of a type appropriate to the circumstances and shall be

accomplished in accordance with these instructions, procedures, or

drawings.

1. The cognizant engineer, OE review engineer, and the OE independent

checker engineer failed to accomplish activities affecting quality

in accordance with procedures in that procedures AI-19 and EP-4.06

which required a review of the appropriate USQD prior to FCR

categorization and approval were not implemented. As a result, an

inappropriate category was chosen and the FCR was approved in

error. This is the second example of Violation 327,328/86-19-06.

2. Reviews conducted by the OE review and independent checker

engineers were not conducted in accordance with EP 3.10 which

requires design drawings to be carefully reviewed by experienced

design engineers. At the time that FCR 2468 was approved by the

OE review engineer and OE independent checker engineer, no

drawings were reviewed by either party. In addition the indepen-

dent checker engineer did not perform an independent review but

instead, based his decision on a conversation with the OE review

engineer. This is a third example of Violation 327,328/86-19-06.

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3. EP 3.10 requires that measures be applied to assure the adequacy

of design documents. The procedure states that a minimum of one

established, identifiable verification method will be used to

assure design adequacy and that suitable documentation will be

provided to show the method used, by whom, and when the verifica-

tion was made. EP 3.10 further requires the form of verification

to be auditable. Neither the OE review engineer nor the OE

independent checker engineer established an auditable record to

validate that a review took place. This is a fourth example of

Violation 327,328/86-19-06.

b. The Plant Operations Review Committee (PORC) reviewed and approved FCR

2468 on July 19, 1984 and failed to identify that nonsafety-related air

was being substituted for safety-related air. The " red marked" prints

that accompanied the FCR when it was presented to PORC did identify the

change in air supplies. The change description section on FCR 2468

failed to adequately identify the work to be performed and the category

chosen was in error because the FCR differed from the assumptions that

were made in the original USQD. The USQD incorporated in ECN 6032

refers to both DCR 972 and NCR SQN EEB 8014. NCR SON EEB 8014 refers

to the reagent gas as instrument air which is safety-related air.

TS 6.5.1.6 requires the PORC to be responsible for review of all

proposed changes or modifications to unit systems or equipment that

affect nuclear safety. Administrative Instruction AI-19, Part IV

implements this requirement. AI-19 requires the PORC to review and

verify USQD special requirements to ensure that the workplan implements

them as necessary. Although a review was conducted by PORC as required

by TS 6.5.1.6, AI-19 was not implemented in that the PORC failed to

perform an adequate review of USQD requirements for a design change to

a safety-related system.

10 CFR 50 Appendix B, Criterion V requires that activities affecting

quality be accomplished in accordance with prescribed procedures.

Failure to implement AI-19 requirements as discussed above is a fifth

example of Violation 327,328/86-19-06.

c. The root cause of the modification error was not personnel error. It

was an OE practice of conducting Category A field change design

approval and review by engineers over the telephone without supporting

documentation and in violation of existing OE procedures for design

review. In addition, the technical supervisory review consisted of a

signature check and encompassed no technical evaluation of the FCR.

A review of ten additional FCRs was conducted. Design change approval

and review was inadequate in all but three cases which were in the

civil engineering area.

The NRC encourages licensee initiative for self-identification and

correction of problems. Therefore, the NRC may not issue a Notice of

Violation for a violation that meets all of the following tests:

- It was identified by the licensee

_

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- It fits a Severity Level IV or V

- It was reported, if required

-

It was or will be corrected, including measures to prevent

recurrence, within a reasonable time

-

It was not a violation that could reasonably be expected to have

been prevented by the licensee's corrective action for a previous

violation. Because the licensee failed to identify and correct the

programmatic root cause of this event, Violation 327,328/86-19-06

is not considered licensee identified,

d. Unit 2 was operated from approximately December 26, 1984

1985, in a mode that required both hydrogen analyzer trains to Aug(ust

also 21,

referred to as hydrogen monitors) to be operable in accordance with

TS 3.6.4.1. During this period, the A train hydrogen analyzer did not

have a seismically qualified air supply and therefore was not operable.

In addition, there were three one week periods and one three day period

during this time in which the B train hydrogen analyzer on Unit 2 was

out of service and TS 3.0.3 applied. This is a violation (328/86-19-12).

As a result of the inspector's review it was determined that two

factors existed which justified the mitigation of the safety signifi-

cance and thus the severity of Violation 328/86-19-12. The first

mitigating factor was that during the period when TS Limiting Condition

for Operation 3.6.4.1 was violated, there was an operable hydrogen

mitigation (igniter) system which did not depend on data from the

hydrogen analyzer system to be initiated. The hydrogen mitigation

system is required to be energized by procedure during implementation

of the Abnormal Operating Instruction for reactor coolant system

leakage. The second mitigating factor was that there were two means

of obtaining a hydrogen sample. One of the means utilizes the post

accident sampling system and the hot-lab gas chromatograph.

11. IE Information Notices (92701)

The following IE Information Notices (IEN) 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.

(Closed) IEN 86-17 Update of Failure of Automatic Sprinkler System Valves

to Operate. The inspectors reviewed the licensee's action to close IEN

86-17. It was determined through discussions with licensee personnel that

they do not currently have Automatic Sprinkler Corporation of America

(ASC0A) deluge and pre-action valves installed at Sequoyah. Furthermore,

no mechanical latching valves of any kind are used in the fire protection

system. This information is sufficient to close this item.

(Closed)IEN85-69 Cheating on License Examinations

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12. Inspector Followup Items (92701)

Inspector Followup Items (IFI) 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 the

area, and/or determined that actions taken by the licensee have resolved the

Concern.

327,328/85-26-06 Control of Root Valves by S0Is

327,328/85-45-02 Replacement of UHI Level Switches

13. 10 CFR PART 21 EVALUATION (36100)

The inspectors reviewed the licensee's program for meeting the requirements

of 10CFR21. During this inspection the following procedures were reviewed:

SQA-94 10CFR21 Evaluation and Reporting Requirements -

Procedure No. - 1200R05

SQA-84 Reportable Occurrence

SQA-45 Quality Control of Materials and Parts and Service

AI-18 Plant Reporting Requirements

Part 21 requires directors and responsible officers of organizations which

construct, operate, or own NRC licensed facilities to:

(1) report any defects in basic components,

(2) report any failures to comply with NRC requirements that could

result in a substantial safety hazard,

(3) post 10CFR21 regulations, Section 206 of the Energy Reorganization

Act of 1974, and procedures adopted pursuant to Part 21 regula-

tions,

(4) specify in procurement documents Part 21 applicability; and

(5) maintain records to show compliance with Part 21.

The inspectors verified that licensee procedures included provisions for

evaluating deviations and informing the Site Director of deviations

evaluated to be a defect or determined to be a failure to comply with

requirements related to a substantial safety hazard.

The inspectors noted that AI-18, Plant Reporting Requirements, File Package

18, Notification and Licensee Event Reports (LER), addressed reporting Part

~

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21 requirements in LER format. The 30 day reporting requirements of the LER

are substantially different from the two day requirement for Part 21.

However, this difference is not proceduralized. It should be noted that the

Site Director is required to notify the Commission of Part 21 safety hazards

within two days following the receipt of the information. This discrepancy

will be followed as IFI 327,328/85-19-13.

The inspectors reviewed three records of evaluated deviations of conditions

that did not result in a report to the Commission. The items were handled

in accordance with procedure, appeared to be factual and complete, and the

inspectors agreed that the findings were a logical conclusion of the review.

Three records of deviations that were identified as Part 21 reportable were

reviewed. The inspectors verified the proper handling of these records. It

was noted that the Commission reports were issued within the time frames of

the Part 21 requirements.

The inspectors verified the appropriate posting of requisite documents. The

locations were considered adequate and the postings met the requirements of

10CFR21.

Licensee procedures were reviewed to ensure that controls were appropriate

to assure that each procurement document for a facility or basic component,

when applicable, specifies that provisions of 10 CFR Part 21 apply.

The inspectors ascertained that licensee procedures assured licensee

maintenance of records. It was found that the preparation and disposition

of records were appropriate and met the requirements of Part 21.

No violations or deviations were identified.