IR 05000327/1986024

Insp Repts 50-327/86-24 & 50-328/86-24 on 860318-21. Violations Noted:Inadequate Surveillance Test Procedure & Lack of Records Documenting Functional Testing of Mechanical Snubbers

ML20210Q376
Person / Time
Site:	Sequoyah
Issue date:	04/22/1986
From:	Jape F, Lenahan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20210Q364	List: IR 05000327/1986024 ML20210Q361 ML20210Q371
References
50-327-86-24, 50-328-86-24, IEB-80-11, NUDOCS 8605140063
Download: ML20210Q376 (7)

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O Kic UNITED STATES o NUCLEAR REGULATORY COMMisslON

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[" n REGION ll 101 MARIETTA STREET, y j

• I ~f ATLANTA, GEORGI A 30323

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Report Nos.: 50-327/86-24 and 50-328/86-24 i Licensee: Tennessee Valley Authority 6N38 A Lookout Place

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1101 Market Street

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Chattanooga, TN 37402-2801

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Docket Nos.: 50-327 and 50-328 License Nos.: DPR-77 and DPR-79 Facility Name: Sequoyah 1 and 2

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Inspection Conducted: March 18- 1, 1986 Inspector: h / 3 //lir J. J. Lenaha (/ Date Signed i Approved by: M 6t'f/b W 4 '

F. Jape, Section Chief v * Date Signed Engineering Branch Division of Reactor Safety SUMMARY Scope: This routine, unannounced inspection entailed 30 inspector-hours on site 4 in the areas of follow-up on a licensee identified item, IE Bulletin 80-11, licensee action on previous inspection findings, and the snubber surveillance progra Results: One violation was identified - Inadequate Procedure and Lack of Records i Documenting Functional Testing of Mechanical Snubbers. (paragraph 5).

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B605140063 860430 PDR O ADOCK 05000327 PDR s

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REPORT DETAILS Persons Contacted Licensee Employees

• L. D. Alexander, Supervisor, Mechanical Modification

• R. C. Burchell, Compliance Engineer

• R. C. Murray, Engineering Aide, Mechanical Maintenance L. A. Rather, Civil Engineer, Office of Engineering

• A. H. Ritter, Quality Assurance Engineer, Office of Engineering

• H. R. Rogers, Compliance Engineer

• P. R. Wallace, Plant Manager Other licensee employees contacted included five engineer NRC Resident Inspectors K. M. Jenison

• L. J. Watson P. E. Ha rmon

• Attended exit interview Exit Interview The inspection scope and findings were summarized on March 21, 1986, with ,

those persons indicated in paragraph 1 above. The inspector described the areas inspected and discussed in detail the inspection findings. No dis-senting comments were received from the license The following items were identified:

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Violation 327, 328/86-24-01 - Inadequate Procedure and Lack of Records Pertaining to Functional Testing of Mechanical Snubbers, paragraph Unresolved Item 327, 328/86-24-02, Load Ratings of Mechanical Snubbers, paragraph The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspection. Licensee Action on Previous Enforcement Matters (Closed) Violation 327,328/85-15-02, Inadequate Procedure for Prepara-tion of Reinforced Masonry Wall As-Built Drawings. The licensee's actions to correct this violation are stated in their June 1,1981 response to NR To correct this problem, the licensee reviewed the results of the field surveys conducted to prepare the masonry wall

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as-built drawings and reviewed the stresses calculated in the masonry walls. This review disclosed that the calculated stresses were less than one-tenth of the allowable masonry wall stresses. Therefore, the licensee concluded that additional field surveys were not required The inspector concurred with this conclusio To preclude s H 'ar problems, the licensee issued guidelines for field surveys of civil-related structures in a memorandum dated July 14, 1981, Subject: Sequoyah Nuclear Plant - Division of Engineering Design's Response to the Nuclear Regulatory Commission Violation Item 327, 328/81-15-02 - Inadequate Procedure for the Preparation for Field Survey of Reinforced Masonry Walls. These guidelines were incorporated into Engineering Procedure (EP) 3.39, " Field Survey of Civil-Related Features, in Category I Structures - Preparing far, Conducting, and Documenting." The inspector reviewed the procedure and noted that EP 3.39 is currently being revised to be issued as a Civil Engineering Branch Information procedure due to reorganization of the Division of Engineering Design (EN DES) into the Office of Engineering (OE). This item is close b. (Closed) Violation 327, 328/85-15-03, Failure to Control Engineering Procedures Used by Onsite EN DES Representativ,es at Sequoya The l licensee's actions to correct this violation are stated in their June 1, 1981, response to NRC Region II for Inspection Report 50-327, 328/81-15. This violation concerned the use of uncontrolled engineer-ing procedures and design criteria by EN DES personnel located at the Sequoyah site. This group of approximately 12 engineers were involved in modifications of pipe hanger supports. To correct this problem, the licensee issued controlled copies of engineering procedures and design criteria to the EN DES representatives at the Sequoyah site. Due to reorganizations within TVA, a large engineering design organization was relocated from TVA Knoxville EN DES offices to the Sequoyah site in 1985. This organization, which numbers approximately 200 design engi-neers, is designated the OE Sequoyah Engineering Project Office (SQEP).

The pipe hanger modification group was absorbed into this organizatio The inspector examined the TVA Office of Engineering Procedures Manual and the Sequoyah Engineering Project Manual and Administrative Instruc-tions. These documents contain requirements for document control and are controlled in accordance with TVA and NRC Quality Assurance re-quirements. The inspector examined the document control center within the Sequoyah Engineering Project and noted that it contained controlled copies of design criteria, drawings, and procedures. The inspector examined Audit Number 85-29 which was conducted by the TVA Quality Management Staff in the Civil Design Section of the SQEP. This audit covered the document control program. One deficiency was noted during this audit. This deficiency has been closed. During resolutira of the deficiency, the document control program for other Sections L'.oin the SQEP were examined to verify that document control within SQEP met TVA and NRC QA requirement Violation item 327, 328/81-15-03 is close .

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3 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 unresolved item which was identified during this inspection is discussed in paragraph 5. Snubber Surveillance Program, Units 1 and 2 (61729)

The inspector examined procedures and quality records related to the snubber surveillance program. Acceptance criteria utilized by the inspector appear in Technical Specification (TS) 3/4. Review of Snubber Surveillance Procedures The inspector examined the following procedures which control snubber surveillance activities:

(1) Surveillance Instruction SI-162.1, Visual Examination of Snubbers (2) Surveillance Instruction SI-162.2, Snubber Functional Testing (HydraulicandMechanical) ,

(3) Maintenance Instruction MI-6.13A, Removal and Reinstallation of Hydraulic and Mechanical Snubbers (4) Maintenance Instruction Mi-6.13B, Functional Testing and Adjusting Hydraulic Snubbers

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(5) Maintenance Instruction MI-6.13D, Basic Engir.eers Hydraulic Snub-bers Repairs and Rebuilding (6) Maintenance Instruction MI-6.13E, Paul-Monroe Snubbers Overhaul Instructions Review of the above procedures disclosed the following violation:

TS 6.8.1 requires that written procedures be established covering activities - referenced in Appendix A of Regulatory Guide (RG) 1.3 ~

Paragraph 8.b of RG 1.33 Appendix A requires that procedures be written and implemented for each surveillance test listed in the TSs. Contrary to this requirement, procedures were not written to cover functional testing of mechanical snubber required by TS 4.7.9.e.1 which requires verification that snubber activation takes place in both directions of travel. The inspector noted that without a procedure, the results of snubber activation testing were not documented for testing performed prior to September 1985. The lack of records is in violation of TS 6.10 which requires results of functional testing be retaine This violation was identified to the ifcensee as Violation item 327, 328/86-24-01, Inadequate Procedure for and Lack of Records Pertaining to Functional Testing of Mechanical Snubber _ _ _ _

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b. Review of Quality Records The inspector reviewed the following snubber surveillance quality records:

(1) Visual inspections performed on Unit I snubbers between February and April 1984 and September through November 1985. During both of these inspections, all Unit 1 snubbers were found to be visually operabl (2) Visual inspections performed on Unit 2 snubbers between August and October 1983 and between September and December 1984. All Unit 2 snubbers were found to be visually operable during these inspection (3) Results of functional tests performed on Unit 1 mechanical snub-bers in February - April 1984, and September - November 1985. Two of the mechanical snubbers failed the drag (frictional resistance to movement) functional test in the 1984 test while four snubbers failed the drag functional tests in 1985. Since more than two snubbers failed the functional tests in 1985 (three in initial sample lot, one in first subsequent lot), it was necessary to test two additional snubber lots (one lot for each failure in excess of two) to comply with the TS requirement The inspector reviewed the functional test results performed on the additional sample

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lots and verified thac the correct minimum additional number of snubbers had been tested. The inspector verified that the snub-bers that failed the functional test in 1984 had been retested in i

1985 as required by the TS (4) Cursory review of results of functional tests performed on Unit 2 mechanical snubbers in February - April 198 As discussed in paragraph 5.a. above, the results of activation testing performed on the mechanical snubbers were not documente Review of the quality records disclosed that the same size mechanical snubbers had different load ratings, depending on date of manufacture, i For example, some of the PSA i snubbers installed on the piping system I have maximum rated capacities of 250 pounds, while others have a maximum rated capacity of 350 pounds. Similar differences were noted for other size PSA mechanical snubbers. The inspector questioned whether the installed snubbers comply with the rated load specified on the piping support drawings. Review of the results of drag tests l performed on Unit 1 mechanical snubbers in September - November 1985, disclosed that the drag force had increased more than 50 percent on four snubbers (numbers F0H-2045, FPCH-486, SIH-1105, and SIH-109)-since these snubbers had last been tested. From review of the records, it was not clear whether or not this problem had been noted and evaluated

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by the licensee. However, the measured drag forces were still well below the maximum 2 percent of capacity specified in the licensee's test acceptance criteria. Pending further review by the licensee and NRC, this problem was identified to the licensee as Unresolved Item 327,328/86-24-02, Load Ratings of Mechanical Snubber Within the areas inspected, no deviations were identified.

6. (0 pen) IE Bulletin 80-11, Masonry Wall Design In response to an NRR letter, dated April 21, 1980, the licensee performed a design reanalysis of all masonry walls in Units 1 and The licensee analyzed reinforced masonry walls and determined that the as-constructed reinforced walls conformed to design requirements. However, in performance of the design analysis for non-reinforced masonry walls, the licensee determined that some of the non-reinforced walls in the proximity of safety-related equipment did not conform to seismic design requirements. This problem was reported to NRC Region II as a construction deficiency report-able under 10 CFR 50.55(e) on October 17, 1980, for Unit 2 and as a LER for Unit 1 on November 14, 1980. The problem was documented on nonconformance report (NCR) numbers SQN CEB 8030 (for Unit I walls) and SQN CEB 8031 (for Unit 2 walls). The inspector previously examined corrective actions to disposition the NCRs during an inspection conducted at the Sequoyah site on February 10-12,1981, (see Report Number 50-327/81-05 and 50-328/85-04).

The inspector examined the status of these NCRs during the current inspec-tion. It was noted that both NCRs are still open pending completion of work required under Engineering Change Notice (ECN) L-5703. This ECN involves reinforcement of four unreinforced walls in the hot sample room on Elevation 690' of the Auxiliary Buildin This ECN also requires identifying poten-tial failure zones of unreinforced block walls which have not been repaired under the above NCRs so that safety related equipment is not placed within the failure zone. Discussions with licensee engineers disclosed that the required repair work to close out the ECN and NCRs will be completed within the next few months. IE Bulletin 80-11 remains open pending closeout of the NCRs and EC Within the areas inspected, no violations or deviations were identified.

7. Licensee Identified Items (50.55(e))

(Closed) 328/81-02-30, Inadequate Handling of Design Engineering Procedure Change On December 11, 1980, the licensee notified NRC Region II by telephone of a potentially reportable item under 10 CFR 50.55(e) concerning handling of changes to Engineering Design procedures. This item was identi-fied during a QA audit (Audit No. JA800-13) of document control in the TVA Division of Engineering Design (EN DES). Subsequent to the telephone notification, this item was further evaluated by the licensee and was determined not to be reportable under 10 CFR 50.55(e) on December 22, 1980, since the identified deficiency did not affect the design activities per-formed for any of TVA's nuclear plants. This review is documented in a

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worksheet for determination of Reportability for 10 CFR 50.55(e) for this item. The audit finding concerned issuing some changes to EN DES engineer-ing procedures by memorandums and implementing the changes prior to review of the memos by the EN DES Quality Assurance Branch. This was being done in conflict with TVA-document control procedures. However, since the proposed changes were written, reviewed, and approved by knowledgeable engineers and their supervisors, plant safety was not affected. The audit finding was resolved by establishment of a requirement to control use of memorandums to transmit quality information which implemented the TVA QA document control program. This item is closed.

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