IR 05000327/1986018
| ML20141E767 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 04/02/1986 |
| From: | Falconer D, Wilson B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20141E757 | List: |
| References | |
| 50-327-86-18, 50-328-86-18, GL-83-28, IEB-85-003, IEB-85-3, NUDOCS 8604220375 | |
| Download: ML20141E767 (21) | |
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, jk#M%q UNITED STATES
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f NUCLEAR REGULATORY COMMISSION
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REGION li o
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,j 101 MARIETTA STREET N W.
t ATL ANT A, GEORGI A 30323
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, Report Nos.:
50-327/86-18 and 50-328/86-18 Licensee:. Tennessee Valley Authority
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'6N38 A Lookout Place
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Chattanooga,.TN 37402-2801 Docket.Nos.: 50-327 and 50-328 License Nos.:
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Facility Name: 'Sequoyah I and 2 Inspection Conducted: February 24-28, 1986 D. P. 1A_.m 4 -u ss Team Leader:
D. P. Falconer Date Signed Team Members:
.D. S. Brinkman-N. C. Choules, O. P. Gormley, A. T. Howell, R. L. Lloyd, and D. Persinko Approved by
/b m 4hf 06 v
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B. K. Wilson, Acting Chief Date Signed Operational Programs Section Division of Reactor Safety SUMMARY Scope: This special announced inspection entailed 224 inspector-hours on site in the area of maintenance activities.
Results: No violations or deviations were identified.
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8604220375 860409 PDR ADOCK 05000327 Q
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REPORT DETAILS
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1.
Persons Contacted a
Licensee Employees
- P. R. Wallace, Plant Manager l
- B. Patterson, Maintenance Superintendent
- W. S. Wilburn, Technical Services Manager
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- R. W. Olson, Modificatiot: Manager
- G. B. Kirk, Compliance Supervisor
- L. S. Bryant, Mechanical Maintenance Supervisor l
- M. A. Skarzinski, Electrical Maintenance Supervisor
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- G. S. Boles, Mechanical Maintenance Supervisor
- H. D. Elkins, Instrument Group Supervisor
- R. V. Pierce, Mechanical Maintenance Supervisor
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- M. R. Harding, Engineering Group Supervisor
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- M.
R. Sediccik, Modification Electrical Supervisor
- L. D. Alexander, Modifications Mechanical Supervisor Other licensee employees contacted included engineers, technicians, mechanics, and office personnel.
NRC Resident Inspectors
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- K. Jenison
- L. Watson
- P.
Harmon
- Attended exit interview 2.
Exit Interview The inspection scope and findings were summarized on February 28, 1986, with those persons indicated in paragraph 1 above.
The inspector described the areas inspected and discussed in detail the inspection findings.
No dissenting comments were received from the licensee.
The status of items identified in this report and IE Report 327/85-45, 328/85-45 which require completion prior to unit restart was provided to the licensee as summarized below.
(0 pen) IFI 327/85-45-01, 328/85-45-01 - Review all outstanding maintenance requests, design change requests, engineering change notices to ensure outstanding work associated with safety related equipment is reviewed in a manner which challenges system operability; any work required to resolve problems associated with questionable operability of safety related equip-ment should be completed prior to unit restart.
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(0 pen) IFI 327/85-45-02, 328-85-45-02 - Complete replacement and post modification testing of VHI level switches on Unit 2 prior to unit restart.
(Closed) IFI 327/85-45-03, 328/85-45-03 - Provide an assessment and status of actions taken to date in response to Inspection and Enforcement Dulletin 85-03.
(Closed) IFI 327/85-45-04, 328/85-45-04 - Evaluate the results of MOVATS testing and inspection over a large data base to determine the necessity for full completion, prior to unit restart, of MOVATS testing and inspection on all motor operated valves which have been rewired pursuant to 10 CFR 50.49.
(0 pen) IFI 327/85-45-05, 328/85-45-05 - Complete work associated with those
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MRs identified as requiring completion prior to restart.
(0 pen) VIO 327/85-45-09, 328/85-45-09 - (a) Determination if the valve rewiring problem with valve 2-FCV-70-134 was isolated or generic is complete.
(b) Establishment of the failure to prescribe preventative l
maintenance represents an isolated case cr if it represents a generic
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problem is open.
Seismic qualification of ASCO (Ocen) UNR 327/85-45-11, 328/85-45-11
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solenoid valve with changed hiounting brackets.
(0 pen) UNR 327/85-45-12, 328/85-45-12 - Environmental qualification of ASCO solenoid valves after the removal and reinstallation of valve body screws Resolve the question of UHI (0 pen) UNR 327/85-45-17, 328/85-45-17
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operability due to past UHI level switch unreliability.
(0 pen) IFI 327/86-18-01, 328/86-18-01 - Complete evaluation of Barton 288A applications and replace unreliable applications or provide justification for operation with unreliable Barton 288A applications prior to unit restart.
The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspection.
3.
Licensee Action on Previous Enforcement Matters a.
(0 pen) Violation 328/85-24-03:
Inoperability of ice condenser intermediate doors, l
During the December 2-6, 1985 inspection, the inspectors toured the l
Unit 2 ice condenser intermediate plenum and observed that several intermediate deck doors were severely iced over.
This icing problem
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was attributed to piping leaks from several air handling units and was l
l believed to have been unrelated to the general recurring icing situa-tion, t
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Complete resolution of this violation cannot be accomplished until Unit 2 is restarted and brought to full power for several weeks; however, based on the licensee's December close out of several MRs for piping leaks in the air handling units, the icing problems on the intermediate deck doors due to the piping leaks are considered closed, b.
(0 pen) Violation 327/85-45-06, 328/85-45-06:
Failure to complete corrective actions associated with CAR 4b-82-05 and associated supple-ments and to properly manage the review process to prevent recurrence.
The inspector determined that although the licensee was making some progress in closing out MRs datec prior to February 18, 1983 which had been field completed but had not completed the review and final closure process, that a substantial quantity of MRs in this category were still open. Approximately 90 mechanical maintenance MRs in this category had been closed out since December. Approximately 260 mechanical mainten-ance MRs in this category remained open. The inspector also noted that 326 electrical maintenance MRs in this category had been recently submitted to Quality Assurance for their approval, however, these MRs had not been closed out by the end of the inspection. Closure of these MRs recaining open will be the subject of further followup action.
This violation remains open.
The inspector also reviewed the licensee's program to prevent a recurrence of this failure to close out field completed MRs.
The violation noted that in addition to the 670 MRs dated prior to February 18, 1983, 710 MRs were identified as having been field completed more than 60 days prior to the December 1985 inspection, but had not been completely closed out.
In response to this portion of the violation, the inspection team was informed that the licensee had assigned a general foreman to devote his full time efforts to resolving this problem and to obtain proper close out of this second group of field completed but not administratively closed out MRs. The inspector noted that the licensee had revised its procedure for processing Work Requests (WRs) and MRs (Revision 18 to SQM 2).
This revision was approved on February 27, 1986 and is intended to provide additional guidance and controls for managing the processing of WRs and MRs to ensure that the problems noted in this violation will not recur.
The licensee's corrective actions appear responsive to the concerns previously expressed; however, additional experience with the recently approved revision to SQM-2 will be required to demonstrate the success of these corrective actions.
This violation will remain optri, c.
(0 pen) Violation 327/85-45-09, 328/85-45-09:
Failure to establish and implement procedures Example (a):
Failure to remove a jumper wire from around torque switch.
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The licensee checked all valves for jumper wires which had been zodified prior to finding the jumper, and no jumpers were found.
The licensee revised the work plans used to modify the valves to require additional verification that the jumper wires were removed and all but two valves have been modified using the revised work plans.
MOVATS testing has not identified any other jumpers on valves tested thus far. It appears that the licensee's corrective action for the violation has been adequate.
This item will remain administratively open until the licensee formally submits its response to this violation.
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Example (b):
Failure to establish a preventive maintenance program for the auxiliary air compressor dryers when the vendor manual, for those components, recommended preventive maintenance at specific intervals.
The licensee has written / revised the following PMs involving the auxiliary air compressors and air compressor dryers to include vendor recommendatiuns:
- PM #1118-032; Auxiliary Control Air Compressor A-A PM #1117-032; Auxiliary Control Air Compressor B-B
- PM #1450-032; Auxiliary Control Air Dryer A-A
- PM #1451-032; Auxiliary Control Air Dryer B-B
- PM #1489-032; Auxiliary Control After Filter B-B
- PM #1477-032, Auxiliary Control Pre-Filter B-B The licensee has also revised standard practice 50M-57; " Preventive Maintenance Program," such that each vendor PM recommendation, including the frequency of performance, should be considered but not required in the establishment or revision of PMs.
The licensee committed to a review of vendor manual maintenance recommendations and to compare those recommendations to existing PM reauirements.
This manual by manual review should be completed concurrent with presently scheduled activities to implement NRC Generic Letter 93-28.
This violation will remain open until the licensee submits its formal response and completes the additional review of vendor recommended maintenance items for inclusion into existing PMs or for issuance of additional PMs.
Example (c):
Numerous and sustained housekeeping deficiencies in auxiliary building contaminated areas.
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The inspection team toured areas identified in report 327/85-45, 328/85-45 and noted that deficient areas were clean and that good housekeeping practices were in effect.
This item will remain administratively open until the licensee formally submits its response to this violation.
d.
(0 pen) Unresolved Item 327/85-45-11, 328-45-11: Seismic qualifications of ASCO solenoid valve with changed mounting brackets.
The licensee plans to perform a seismic evaluation of changing the brackets on the ASCO solenoid valves.
This item will remain open pending completion of this evaluation.
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(0 pen) Unresolved Item 327/85-45-12, 328/85-45-12:
Removal and retorquing of screws on ASCO solenoid valves.
The licensee has not formalized its plans for the resolution of this item.
Preliminary plans are to retorque the screws on all solenoid valves in accordance with the vendor recommendation.
This item will remain open pending further review of the licensee's corrective action.
f.
(0 pen) Unresolved Item 327/85-45-17, 328/85-45-17:
Demonstrate that the multiple failures of Barton 288A UHI level switches to meet allowed setpoint tolerances during decreased surveillance interval testing did not constitute UHI system inoperability.
The inspection team reviewed the licensee's evaluation of UHI level switch history. This evaluaticn consisted of a review of calibration data between January, 1983 and August, 1985 and concluded that evidence did not substantiate that the UHI isolation logic was ever inoperable in a mode where it was required between June 1983 and August 1985. The inspection team determined that the licensee's evaluation did not provide a comprehensive evaluation of UHI system operability between January 1983, and August 1985, in that: (1) The licensee's evaluation did not evaluate operability during the period of January 1983, -
June 1983, and; (2) did not consider the scenario of inadequate UHI inventory due to early UHI isolation logic actuation.
Until the licensee provides a comprehensive evaluation of UHI system operability between January 1983, and August 1985, this item will remain open.
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(0 pen) Unresolved Item 327/85-45-18, 328/85-45-18: Provide a complete description of corrective actions to preclude the circumstances which resulted in the installation of UHI level switches with incorrect QA level designations.
The inspection team verified that the implementation of corrective actions was underway.
Until the licensee completes all corrective actions to resolve this problem, this item will remain open.
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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.
One new unresolved item identified during this inspection is discussed in paragraph 10.
UNR 327/86-18-07, 328/86-18-07:
Provide documentation that would verify PM #0909-317 or that vendor recommended maintenance has been accomplished for specified pump elements.
5.
General Assessments and Conclusions The inspection team considers that the license * is providing suf ficient
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management attention to the resolution of weaknesses identified during the December 2-6, 1985 maintenance inspection (IE Report Nos. 327/85-45,
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328/85-45). Full implementation of corrective actions was not complete at the time of this inspection; however, the inspection team considers that adequate resources have been dedicated to ensure timely completion.
Progress was noted on most items and improvement in the overall maintenance program was apparent.
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is a controlled process and that the provisions of design change packages
are reflected in the as-installed modifications. Approved modifications are i
implemented by qualified personnel with adequate supervision.
The depen-dance on maintenance related contracted services is minimal and the inspec-tion team considers that adequate management controls are provided to ensure the quality of contracted services.
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The inspection team is concerned that the preliminary evaluation of Barton l
288A switch applications in response to the UHI level switch problem has identified other unreliable applications, it is considered that the
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licensee should complete this evaluation and provide replacements for unreliable Barton 288A switch applications or provide justification for operation with unreliable Barton 288A's installed prior to unit restart.
Resolution of this concern has been identified as inspector followup ite.1 327/86-18-01, 328/86-18-01 in paragraph 6.c of this report.
6.
Review of Previous Maintenance Concerns and Inspector Followup Items a.
(Closed) IFI 327/85-24-01, 328/85-24-01:
The following concerns regarding maintenance management were identified in Inspection Report No. 50-327/85-24 and 50-328/85-24:
1.
SQM-2, Maintenance Management System Procedure, had no timeliness
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requirements for post work review.
Several maintenance requests
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(MRs) that were performed in 1981 had only recently received post maintenance reviews.
The licensee had identified these MRs and approximately 2000 other MRs as lacking a timely review.
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The maintenance planners assembled the maintenance request work packages using verified procedures and instructions. The foreman or craftsmen performing the work had no procedural requirement to verify that these procedures were still correct and were the latest revisions, even if the job was worked months af ter the package was assembled.
This was of concern due to the large backlog of MRs that were in the available-to-work category.
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SQM-2, Maintenance Management System Procedure, lacked procedural l
guidance in the prioritization of routine maintenance.
SQM-2 divided routine maintenance into three categories, P1, P2 and P3, l
but did not define the significance or urgency associated with
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these priorities.
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There were several cases of priority down grading of MRs that l
lacked middle to upper management inputs into the decision process.
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The maintenance request system appeared overburdened with non-maintenance work activities.
An example was an MR for manu-l l
facturing a plexi glass desk top.
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During this inspection (February 24-28, 1986), the inspection team l
noted that SQM-2 had been recently revised (Revision 18 was approved on
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February 27,1986). The following changes were included in Revision 18 to resolve the above concerns:
1.
A requirement was added to Section N of SQM-2 requiring the individuals responsible for performing post work reviews to
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Section E.1 of SQM-2 was revised to require that prior to starting a job, the foreman shall ensure that the instructions attached to
l the WR package are the latest revision and if not, the foreman shall obtain and attach the latest revision.
3.
Section C.3 of SOM-2 now states that WRs assigned priority P1 should be planned and work initiated within seven days and that
l work should be completed on an expedited basis.
WRs assigned priority P2 should be planned and work should be initiated within 21 days. These work items should be completed utilizing normally i
allocated resources. WRs assigned priority P3 should be worked as work load permits.
4.
Section D.1 of SQM-2 permits anyone to request a cnange in WR priority; however, Section D.1 was revised in Revision 18 to require that the requestor must supply justification for the
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proposed change to the cognizant section supervisor who may then approve the proposed priority change.
The cognizant section supervi,or is the appropriate management level for approving l
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changes in WRs priority since the cognizant section supervisor is
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responsible for originally establishing the WR priority level.
5.
Section E of SQM-2 has been revised to require that once a WR has been submitted, the responsible planner will determine if the work requested requires an MR form to plan and document the work activities. An MR form is required if the requested work falls into any of the following categories (other work may be performed using only the WR form, thereby avoiding overburdening of the MR system):
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Work on CSSC items.
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Work o-Class 1E equipment.
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Work on 10 CFR 50.49 equipment.
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Work which is NPRDS reportable.
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As directed by the implementing supervisor.
The revisions to SQM-2 noted above satisfy the concerns previously expressed in inspector followup item 327/85-24-01, 328/85-24-01; therefore, this inspector followup item is closed.
b.
(0 pen) IFI 327-85-45-01, 328-85-45-01: Review all outstanding Mainten-ance Requests (MRs), Design Change Requests (DCRs), and Engineering Change Notices (ECNs) to ensure that all outstanding work associated
with safety related equipment is reviewed and that all work required to resolve problems associated with questionable operability of safety related equipment is completed prior to restart of the affected unit.
Cognizant engineers should be interviewed to ensure that all issues which may involve operability of safety related equipment have been formally identified with an MR, OCR or ECN.
The inspection team interviewed several members of the licensee's maintenance staff and was provided with pr'ntouts of open MRs for each of the maintenance sections.
The interviews disclosed that the licensee's staff, including cognizant egaineers, have been contacted and urged to identify (via MRs) all t s tges which may involve the operability of safety related equipmen0G ;The printouts of open MRs were reviewed by the inspector; the pr%ntouts were noted to include designators showing those MRs which the-licensee had deemed necessary for completion prior to startup. The ine.nection team also reviewed the licensee's criteria for determining which MRs required completion prior to plant startup.
This criteria included:
CSSC items, 10 CFR 50.49 items, items which receive electric power from redundant power supplies, and items which affect the operability of equipment required operable by the plant's technical specificaticns. The inspection team
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reviewed a sample of the open MRs and determined that this criteria was being appropriately applied.
Therefore, the inspection team concluded that the licensee's program for identifying open MRs which must be completed prior to plant startup is satisfactory; however, the licensee has not implemented a program for determining and identifying which DCRs.and ECNs require completion prior to plant startup.
Inspector followup item 327/85-45-01, 328/85-45-01 is considered closed as it applies to MRs and remains open as it applies to DCRs and ECNs.
c.
(0 pen) IFI 327/85-45-02, 328/85-45-02:
Replacement and post-modifi-cation testing of Unit 2 Barton 288A UHI level switches.
The licensee had not completed the replacement of the Unit 2 UH1 level switches due to a delay in +.he fabrication of switch mounting plates; therefore, this inspector followup item will remain open pending completion of replacement and post-modification test activities.
The inspection team reviewed the licensee's preliminary evaluation of
'the Barton 288A applications. This evaluation has identified unreli-able Barton 288A applications in the RCS loop RTD bypass lines. The licensee should complete the evaluation of all Barton 288A applications and for those applications determined to be unreliable, either provide suitable replacements pricr to restart or provide justification for continued cperation with unreliable Barton 288A applications.
Resolutjan of this item will be identified as inspector followup item (327/86-18-01,328/86-18-01).
d.
(Closed) IFI 327/85-45-03, 328/85-45-03:
Assessment and status of actions taken in response to Inspectica and Enforcement Bulletin (IEB)
85-03.
The licensee has identified 21 valves on each unit in the high-head safety injection, intermediate-head safety injection, and emergency feedwater systems for which a program has been developed to meet the requirements of IEB 85-03.
The inspection team reviewed piping drawings and confirmed that valves required for operational readiness in the above systems are included in the 21 identified valves.
The licensee is bypassing the torque switches completely in the open direction and all except the last two to three percent of travel in the closed direction.
The torque switches will only provide a torque-out upon the valve disk contacting the valve seat.
The licensee has obtained design d4A 4 * the 21 valves and is performing M0 VATS testing on them. The licen'se6 will perform differential tests on one of each type (size and dif ferential pressure) of high-differential pressure valves included in the 21 valves.
The licensee plans to submit their response to IEB 85-03 in May 1986, as required by the bulletin.
The proposed response to the bulletin appears to be adequate to meet the requirements of the bulletin; therefore, this item is considered closed.
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(Closed) IFI 327/85-45-04, 328/85-45-04:
Evaluation of M0 VATS test program and the results of MOVATS testing.
The licensee had previously identified 241 motor operated valves (MOV)
on the two units for possible MOVATS testing prior to fuel load; however, as a result of problems identified through MOVATS testing, the licensee plans to complete testing on the 241 valves, plus approxi-mately 60 additional. valves prior to startup.
The licensee had completed M0 VATS testing on approximately 170 valves at the time of this inspection.
The inspection team reviewed the licensee's M0 VAT testing program which included review of procedures and test data and witnessing of testing.
The licensee has prepared detailed procedures for MOVATS testing and corrective maintenance on Limitorque valves.
The procedures, in general, were adequate.
Through use, the licensee has identified improvements that it plans to make in the MOVATS testing procedure MI-10.43. The inspection team considered that precautions should be added to the procedure to note that for certain types of valves OPEN and CLOSED torque switch settings are located opposite the OPEN and CLOSE terminations. The licensee agreed to add this precaution.
This will be identified as inspector followup item (327/86-18-02, 328/86-18-02) for subsequent inspection followup.
In the past, the licensee had not established and documented baseline torque switch settings for limitorque valves.
Initial torque switch settings were generally those set by the vendor when the Limitorque operaters were supplied to the licensee. The settings were apparently determined from design information provided in the purchase orders for the operators. Torque switch settings were then normally set the same as the "as found" settings when maintenance was performed.
The licensee is in the process of establishing baseline torque switch settings based on design specification and MOVATS testing data. A file is being established for each v.sive which will include the design specification, the MOVATS testing data, and the baseline torque switch settings. It should be noted that in most cases the licensee plans to bypass the torque switch except for the last two to three percent of travel in the closing direction.
The licensee's program for control and testing of Limitorque valve operators appears to be adequate.
During MOVATS testing on Upper Head Injection (VHI) gag valves, which the inspection team observed, it was determined that valves 2-MOVP-87-22 and 2-MOVP-87-24 were either mislabeled or their power feeds were switched.
The licensee determined through further review that the valves were mislabeled with magic markers.
The licensee removed the markings and correctly labeled the valves.
f.
(0 pen) IFI 327/85-45-05, 328/85-45-05:
Eighteen of 25 MRs selected for review during the December 2-6, 1985 inspection were identified as requiring completion prior to plant startup.
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The inspection team reviewed the status of the 18 MRs and determined that 15 of these MRs had been closed out. The remaining three MRs ( A536974, A546226 and A521756) had not yet been completed; therefore, this inspector-followup item remains opens, g.
(Closed) IFI 327/85-45-08, 328/85-45-08i Concerns'regarding PM program administration.
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l (1) Standard practice SQM-57 has recently been changed (PORC Accept-l ance 2-25-86) such that the PM completion due date may be extended for a maximum of 25% of the frequency rate if so approved by the i
l general foreman or maintenance planner; deferrals or cancellations shall be approved by the maintenance group or maintenance
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engineering section supervisor. This procedure revision wts made to assure that appropriate management and engineering personnel
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would be involved regarding proper and timely performance of PMs.
(2) Based on an independent sample of completed PMs, several examples were noted by the inspection team for which PM requirements were l
i not met, were partially performed or had missing data in blanks i
that required data or information. However, in each case QA had i
not reviewed and approved the performance of the PM. Until the PM l
performance is reviewed and' approved by.QA, the PM is not considered complete and will not be entered into the document i
control unit. The inspection team did not review any QA reviewed
and approved PM performances which were incomplete with respect to l
data or sign offs.
Concerns were noted, with timeliness of QA L
review and approval of completed PMs.
(3) SQM-57 provides for a format review of temporary or permanent l
changes to be made to 10 CFR 50.49 equipment PMs, however, no formal procedure exists' for non 10 CFR 50.49 equipment The
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inspection team did not review any PMs which had been temporarily l
changed, either approved or not approved. As an enhancement to
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the PM program, the inspection team noted that a formal change
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(temporary / permanent) process should also be included for non-10 CFR 50.49 equipment PMs in SQM-57.
Development of a formal change process for non-10 CFR 50.49 equipment PMs will be identi-fled as an inspector followup item 327/86-18-03,328/86-18-03).
h.
(0 pen) IFI 327/85-45-10, 328/85-45-10:
Failure to provide Plant
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Operations Review Committee (PORC) review of maintenance standard
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l practices.
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During the December 2-6, 1985 inspection, it was noted that procedures
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which describe and control the maintenance program such as SQM-1 and
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l SQM-2 were written as standard practices which do not. receive Plant
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Operations Review Committee (PORC) review. The licensee committed to
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j PORC review the maintenance program procedures (50M-1, SQM-2, SQM-57, l
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SQM-58) and to also review the other standard practices to determine if
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others require PORC review.
Additionally, the licensee committed to issue an LER on this matter.
The inspection team verified that the licensee has issued LER 1-85-046 on this matter. The following standarc practices have received PORC review:
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Date of PORC Review 1.
SQM-1 Sequoyah Nuclear Plant Maintenance Program 1/3/86 2.
SQM-2 Maintenance Management System 12/27/85
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SOM-57 Preventive Maintenance Program 1/3/86 4.
SQM-58 Maintenance History and Trending 12/24/85 5.
SQM-62 10 CFR 50.49 Program: Qualification 1/3/86 Maintenance Data Sheets (QMOS)
Implementation, Environmental Qualification, Deviation Report and Category II Upgrade Control The licensee will conduct a review of all standard practices to determine which procedures require PORC review (administration, maintenance, engineering, operations, safety). Prior to receiving PORC approval, a process known as informal PORC is conducted.
In this process, the package that will be up for PORC review is routed through each PORC member for review and comments. The process currently takes approximately 3 months; no time limit is specified. Completion of standard practice reviews and PORC approval of selected standard practices will remain an open item.
1.
(Closed) IFI 327/85-45-14, 328/85-45-14: Implemented the requirements of mechanical maintenance section letter ( MMS L-A36 ), Common-Mode Failures, Maintenance Initiated.
The inspection team verified during this inspection that the licensee had implemented the requirements of MMSL-A36 by conducting a training session on the requirements of MMSL-A36 for the mechanical maintenance section on February 6, 1986.
This inspector followup item is closed.
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(0 pen) IFI 327/85-45-15, 328/85-45-15:
Ensure that all applicable personnel have received training as stated in the Sequoyah Nuclear Performance Plan, paragraph 4.13.
The inspection team noted that the licensee is in the process of determining which engineers missed Unreviewed Safety Question Determi-nation (USQD) training. Until the licensee completes this determination and provides retraining, this item will remain open.
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(0 pen) IFI 327/85-45-16, 328/85-45-16: Continuing problems with loose nuts on Masoneillan valves in the Steam Generator Blowdown System.
The licensee's planned corrective action for this problem is to apply locktight and stake the threads of tFe valve stems.
This has been completed on two valves.
The licensee plans to apply locktight and stake the threads of other valves on an as-needed basis.
This item will remain open to see if this is an effective corrective action.
The inspection team also reviewed the licensee's corrective actions to the following concerns identified in report 327/85-45, 328/85-45:
1.
Concern:
(Paragraph 6 Page 10) Potential problems could exist in assuring effective trend analysis of out of calibration (00C)
conditions of various instruments / components, if 00C conditions are not reported as failures.
In response to this concern, the licensee revised Standard Practice l
SOM-58, Maintenance History And Trending, on December 24, 1985, to include trending.
However, paragraph 5.2 of SOM-58 indicates that surveillance testing, which includes calibration checks, is not covered in the procedure.
Discussions with the instrument maintenance group revealed that 00C conditions are currently reported as failures and are documented according to the NPRDS reporting procedures manual; however, prior tp December 1985, tracking and trending of 00C conditions were not accomplished. The licensee has recently located 93 00C report, on j
the Upper Head injection Barton 288A level switches and load?d them into its trending system.
No ef fort is planned at this t tne to retrieve
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similar data on 00C conditions involving other components prior to January 1986.
The licensee should revise SQM-58 to clearly indicate how to process and trend 00C conditions. To adequately assess tracking of 00C conditions, further inspection will be required. This item is identified as inspector followup item (327/86-18-04, 328-86-18-04).
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Concern:
(Paragraph 8, Page 16) Weaknesses were noted in training of planners regarding the 10 CFR 50.49 program at Sequoyah.
In response to the concern, the licensee indicated that EQ
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training was scheduled to begin December 16, 1985.
Closecut:
The " Maintenance and Modification EQ Procedure Review and Training Seminar" began on December 19. 1985, and will continue until all those selected personnel involved in maintenance and modification of 10 CFR 50.49 applicable equipment have been trained. The inspection team has reviewed the lesson plan for SQN 10 CFR 50.49 program and found it to be acceptable.
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Concern:
(Paragraph 11, Page 25) Weaknesses were noted in the training of planners regarding post maintenance testing for ASME Section XI valves.
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This concern was related to NSRS concern R-85-03-NPS-04 and will be closed out by NSRS.
Discussions with NSRS personnel indicated that post maintenance testing of ASME Section XI valves training course was established and was I
determined to be adequate.
I 7.
Administrative Control of Contracted Services The licensee's use of contracted services wa0hrogrammatically reviewed.
The licensee makes little use of contracted services with most work performed by TVA personnel, even during outages. Contract personnel do not form a regular nor significant percentage of the TVA work force. Contrac-tors are used on an as-needed basis to perform specialty work or to augment the TVA work force when the workload is high. The following summarizes the
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contracted services utilized within approximately the past two years or planned to be utilized in the near future in the noted groups:
1)
Mechanical maintenance - Formanite performs as needed repairs of valve and flance leaks during plant operation. Upon shutdown, valves and flanges repaired by Furmanite during operation are repaired permanently by TVA or are replaced. A contract to perform drain cleaning is about to be let.
2)
Technical Services Group - Westinghouse has performed sludge lancing of the steam generators.
3)
I&C maintenance - TVA contracted with Westinghouse to provide expertise in installing the Unit 1 Reactor Vessel Level Instrumentation System (RVLIS).
In the case of the Westinghouse sludge lancing contract and the Furmanite contract, the entire job was performed by the contractors. On the RVLIS contract, Westinghouse provided the technical expertise and the manpower was provided by TVA.
In addition to the above groups, contracted services utilized by the plant modifications group were also discussed. The modifications group appears to use contractors more frequently than the other groups.
During non-outages for the past 2 years, approximately 5-7% of the work force consisted of contractors and during outages, approximately 10-15%. These percentages do not represent excessive use of contractors as part of the TVA work force.
Experience required / qualifications necessary are specified by the licensee through experience clauses in the request for bids.
Determination of whether the contractor possesses the necessary qualifications is determined by the licensee through a review of information provided by the contractor when bidding for the job.
The only plant document noted by licensee personnel governing contractor use is NQAM, Part III, Section 2.1, which discusses procurement.
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The contracted work is accomplished within the licensee's basic framework for all maintenance or modification work.
Within this framework, upon issuance of a work request, it is determined by the cognizant engineer whether the work involves critical structures, systems and components (CSSC)
or not.
Next, a determination is made whetner or not the work involves a modification.
Preparation of the work package follows established guide-lines for modifications performed by permanent station personnel.
Contractor procedures are reviewed by the cognizant engineer and included in the work plan. As the work progresses, the cognizant engineer is expected to follow the job. QC of contractor work is accomplished by the licensee's QA/QC department. This can be done by requiring licensee's QC approvals at holdpoints within the procedures or by letting the contractor's QC approve procedural holdpoints and having the licensee's QA department review the completed procedures.
Acceptance of the contractor's work is accomplished by the cognizant engineer. No individual work packages were reviewed during this inspection.
No programmatic deficiencies were noted in this area.
8.
Safety-Related (MOV) Motor Operated Valve Program The inspection team reviewed the licensee's progress in the implementation of a comprehensive safety-related MOV maintenance program.
This effort includes thq development of preventive maintenance procedures and the revision of current Limitorque valve maintenance procedures.
Procedure MI 11.2 - Motor Operated Valve Adjustment Guidelines, a PORC approved generic procedure has been replaced by the following PORC approved, actuator specific procedures:
a)
MI 11.2A - Limitorque Actuators Corrective Maintenance Procedure for SB-00, SMB-000 and SMB-00 Actuators b)
MI 11.28 - Limitorque Actuators Corrective Maintenance Procedure for SMB-0 thru SMB-4 and 58-0 thru SB-4 Actuators c)
MI 11.2C - Limitorque Operators Corrective Maintenance Procedure SMB-000 and SMB-00 Actuators with HBC-0 thru HBC-3 Actuators d)
MI 11.2D - Limitorque Operators Corrective Maintenance Procedure for SMB-0 thru SMB-4 Actuators with HBC thru HBC-10 Actuators A draft procedure for preventive maintenance on safety-related MOVs has also been written.
During the review of Procedure 11.2A the inspection team noted that in setting the torque switch, the procedure states that "unless otherwise directed by cognizant engineer, set the open and close torque switches as found."
No values are specified.
The procedures should be revised to
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include torque switch settings. As currently written, if an error is made when setting the torque switch, maintenance personnel making subsequent settings are unlikely to catch the error and will promulgate the error.
This item will be identified as inspector followup item (327/86-18-05, 328/86-18-05) for subsequent inspection followup.
9.
Maintenance Instruction Enhancement The Sequoyah Nuclear Performance Plan committed to a reduction in the tiering of procedures and the removal of cumbersome interdependencies between procedures. To improve maintenance instructions, the licensee has instituted a " Maintenance Instruction Enhancement" program. As part of this program all maintenance instructions will be reviewed for improvements incluc'ng reduction of cross referencing.
Additionally, new instructions will be prepared where necessary. A need for 17 new instructions has been identified thus far.
The procedure review is being performed jointly by mechanical and electrical and by I&C. Mechanical / electrical has drafted a guideline to be used when reviewing and rewriting procedures. The guideline incorporates recommenda-tions made in INPO and NRC publications. Completion of the writer's guide by the licensee and prioritization of procedure review are expected by I
mid-April whereupon review and rewriting of procedures will commence. I&C has developed a checklist to use in reviewing and rewriting procedures and has commenced rewriting procedures.
Plant Maintenance utilizes sueveillance instructions (SI) to track technical specification commitments. The sis refer to maintenance instructions (MI)
for mechanical / electrical maintenance and instrument maintenance instruc-tions (IMI) for instrwnent maintenance.
The IMIs can refer to specific instructions on respons? time testing, channel calibration, and functional testing. Governing overall ' maintenance are maintenance standard practices l
(SQM).
During the inspection, the revised SI-75 was reviewed for interdependencies.
In SI-75, it was noted that:
a)
the prerequisites required that the provisions of SQM-2 and SQM-62 have been satisfied b)
the prerequisites required that the appropriate appendices of IMI-135 have been obtained c)
the prerequisites stated that the provisions of IMS-19 are applicable d)
the precautions stated that IMI-118 should be used for filling and back, flushing possible contaminated instrument sensing lines e)
the body of the work did not cross-reference.
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The licensee indicated that although many other maintenance instructions were referenced, they are well-understood procedures used for overall guidance. Although there was some cross-referencing, the licensee did not believe it inhibited accomplishment of the work.
It was also noted that MI-4, " Maintenance of CSSC Valves," had been rewritten in. draft form to stand alone.
Previously, maintenance of CSSC valves required the use of MI-4, MI-6.15 and MI-6.20.
Because I&C are rewriting procedures independently from mechanical /
electrical, the licensee should assure that these groups communicate to benefit from knowledge each gains regarding good principles in procedure writing that are applicable to all procedures.
A review of rewr/tten maintenance instructions to be performed af ter the program has progressed sufficiently will be identified as an inspector followup item (327/86-18-06, 328/86-18-06).
10.
PM Program Review The inspection team chose the following PMs to review with respect to content timely completion and processing to further assess the licensee's PM Program.
- PM #0909-317 " Inspect Pump Subassemblies" PM #0621-090 "ERCW Liquid Monitor" PM 0619-090 "S.G. Blowdown Liouid Sample Monitor" PM #0148-082 " Quarterly MI 10.27 on D/G BAT 2B-B" PM #0909-317 was last officially accomplished (QA reviewed and approved) on February 23, 1984. The PM requires the following inspections to be accom-plished on a quarterly basis to verify component adequacy: Physical damage; cleanliness; integrity of protective covers, seals, and all closures; integrity of protective coatings and preservatives; signs of condensation or corrosion; desiccants and inert gas blankets; signs of vermin activity; and marking and identification.
Vendor manual recommended preventive mainten-ance, such as shaft rotation, was not included in this PM. Administrative Instruction AI-36; " Storage, Handling, and Shipping of QA Material," defines the storage requirements to maintain CSSC material and equipment in an acceptable condition.
The licensee indicated that preventive maintenance items required by PM #0909-317 were regularly accomplished by power stores utilizing AI-36.
The licensee was unable to locate requested AI-36 documents that would verify that inspection items required by PM #0909-317 were being accomplished on:
(1) centrifugal charging pump element, (2) safety injection pump element, (3) turbine driven auxiliary feedwater pump element, (4) RHR Pump Rotating Element, (5) #3 HTR drain pump, (6) #7
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HTR drain pump, and (7) stator cooling water pump. Also, requested docu-mentation (other PMs or AI-36) could not be located which would verify that vendor recommended maintenance, such as pump shaft rotation, was being accomplished on the seven pump subassemblies listed in PM #0909-317. Until the licensee is able to provide documentatio, that would verify PM #0909-317 or that vendor recommended maintenance has been accomplishment by some alternate process, this item is identified as an unresolved item.
(327/86-16-07,328/86-18-07)
11.
Review of Programmatic Aspects of Plant Modifications The inspection team reviewed plant modification initiation, planning practices, scheduling, status reporting, tracking, and documentation of modification work.
The idtoectors reviewed Sequoyah Administrative Instruction AI-19, P1, ant Modifications: After Licensing, and discussed the modification program with the appropriate licensee personnel responsible for developing and implementing the modification program. The purpose of AI-19 is to provide the method for requesting and implementing all modifications to the physical facilities of the Sequoyah Nuclear Plant. This process includes requesting, authorizing, wcrkplan preparing, reviewing, performing, and documenting of the work. The workplan is the written instruction by which modification work is planned, approved, and performed.
A workplan basically consists of written work instructions, copies of the implementing documents, design drawings, Engineering Change Notices (ECNs), Unreviewed Safety Question Determinations (USQDs), and tests and/or inspections to verify satisfactory completion of the work. This method appears to be an effective means of controlling work.
A review of the backlog of all categories of plant modifications indicates that a total of 646 modifications have not been implemented at the time of this inspection.
This is considered to be a manageable backlog.
To deternine the licensee's method of ensuring that no unworked item will degrade-equipment or impede operator action necessary for safe operations of the plant, the inspectors obtained a list of all unimplemented plant modifications.
The inspection team reviewed this list and selected 10 modifications for evaluation and made a determination of those which, in its opinion, required completion prior to plant startup, and those for which completion was not required prior to startup. The list of selected modifications was then given to the manager of the Modification Branch for an independent review and determination. The licensee's determinations were then compared with the inspectors' previous determinations. This comparison showed that, within the selected sample of modifications, the licensee had identified as requiring completion before startup, all the modifications the inspectors had so identified. Table 1 lists the ECNs/DCRs selected for this sample.
The licensee is apparently complying with the commitment to complete all necessary work prior to plant startup; however, the Modifica-tion Branch has not established a formal program to ensure that all out-standing DCRs and ECNs associated with safety related equipment are reviewed
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in a manner which challenges system operability. This portion of inspector followup item 327/85-45-01, 328/85-45-01 shall remain open until the formal determination and completion of all outstanding DCRs and ECNs which may impact operability of safety-related equipment.
Table 1 MODIFICATION REQUESTS REVIEWED BY INSPECTOR AND LICENSEE COMPLETI0P REQUIRED BEFORE PLANT STARTUP ECN/DCR NUMBER NRC INSPECTOR DETERMINATION LICENSEE DETERMINATION F41545 YES YES F45208S NO NO L5457/D0972S YES YES L5531/010055 NO NO
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L6148/D16995 NO NO L6347/018745 NO NO L6546/D09725 YES YES L6556/D09725 YES YES L6579/D09725 YES YES L6595/F40755 YES YES
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r The inspectors reviewed 21 completed or cancelled workplans, for technical
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and administrative adequacy. Additionally, 100 recently completed modifica-
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tions were reviewed to determine the average number of Field Change Requests
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(FCRs) associated with each modification package. This review indicated
that about 1.5 FCRs were associated with eacq completed modification.
This
~ does not appear to be an excessive amount.
In all cases, the technical adequacy of each work plan, including USQD determination, workplan detail, QC inspector involvement, and post modification testing seemed satisfactory.
Several minor administrative weaknesses were noted, however, in many of the completed workplans.
Examples include: not checking appropriate blocks on various attachments; missing dates; unnumbered pages; exceeding the 30 day
. limit from the completion of the field work to turning the workplan over to the workplan coordinator; and, use of inappropriate substitute signatures.
In one instance, DCR-1777S was approved in October 1982. The DCR provided for the changing of the motor / drive gear ratio of Unit 1 Limitorque operators, model SMB-00 for valves 1-FCV-62-90 and 91 in order to obtain an
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acceptable stroke time. The valves had failed SI-166.1, post maintenance
test for stroke time (10 seconds is the requirement, and the best stroke
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per MR. A-05207 on December 20, 1984.
Satisfactory valve stroking (8.1 seconds for FCV-62-90, and 8.3 seconds for FCV-62-91) occurred on December 29,1982 in 4ccordance with 51-166.1; however, work plan documentation was j
not completed until March 8,1985 Apparently, QA discovered the lack of documentation, and.the mechanical section of the modifications branch l-documented the completed work in accordance with AI-19. This appears to be an isolated case and the inspectors did note an improving trend in the i
administrative quality for the most recently completed workplans as a result of corrective actions to previous enforcement actions. The inspectors also observed that even though AI-19 invokes AI-4 as the procedure to use in order to make changes to workplans, AI-4, does not specifically address
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workplan changes.
I The inspectors interviewed the Manager of the Modification Branch as well as the Mechanical and Electrical Section Supervisors about the types and amount of training that the Modifications Branch craftsmen receive.
These crafts-men receive little formal training; clearly significantly less training than
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briefings, including mock-up training when necessary and in some instances, formal classroom training prior to the commencement of major modifications
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(e.g. 3 day course cg Limitorque Motor Operators prior to performing an E0 modification to replace Limitorque motor operators with qualified opera-
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With the exception of the classroom training, retained at the training center, no documentation of modification branch training exists.
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