IR 05000327/1986059
| ML20212B883 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah |
| Issue date: | 12/03/1986 |
| From: | Blake J, Crowley B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20212B813 | List: |
| References | |
| 50-327-86-59, 50-328-86-59, NUDOCS 8612290337 | |
| Download: ML20212B883 (12) | |
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UNITE 3 STATES NUCLEAR REGULATORY COMMisslON
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REGION 11 g
j 101 MARIETTA STREET, N.W.
- ATLANTA, GEORGI A 30323 -
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Report Nos.:
50-327/86-59 and 50-328/86-59 Licensee: Tennessee Valley Authority
.6N38 A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Docket Nos.: 50-327 and 50-328 License Nos.: DPR-77 and DPR-79 Facility Name: Sequoyah 1 and 2 Inspection Conducted: October 20-24, 1986
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d Inspector:
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B. Crowley.
f Date Signed Accompanying Personnel:
T. K. McLellan, Reactor Construction Engineer, IE, DI, RCPB Approved b
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'd J J/ Blake, Section Chief Date Signed
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g(neering Branch iYision of Reactor Safety
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SUMMARY Scope:
This routine, announced inspection was conducted in the areas of inservice inspection (ISI) (Units 1 and 2), inservice testing (IST) of pumps and valves (Units 1 and 2), licensee action on previous enforcement matters (Units 1 and 2), and engineering calculations related to welding (Units 1 and 2).
Results:
One violation was identified - Failure to Meet Test Frequency Require-ments for Category A and B Valves - Paragraph 6.b.
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REPORT DETAILS 1.
Persons Contacted Licensee Employees
- P. R. Wallace, Plant Manager
- J. A. McPherson, Mechanical Test Supervisor
- G. B. Kirk, Compliance Licensing Supervisor
- H. R. Rogers, Plant Reporting Section Supervisor
- D. A. Barker, Mechanical Engineer - Mechanical Test Section
- J. T. Lewis, Lead ISI Engineer M. A. Cooper, Compliance Licensing Engineer R. C. Birchell, Licensing Engineer A
R. M. Emrath, Program Coordinator - ISI Programs Section
- R. E. Hoekstra, Civil Engineer Other licensee employees contacted included engineers HP technicians, security force members, and office personnel.
NRC Resident Inspectors
- K. Jenison, Senior Resident Inspector P. Harmon, Resident Inspector A. Loveless, Resident Inspector
- Attended exit interview 2.
Exit Interview The inspection scope and findings were summarized on October 24, 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.
(0 pen) Violation 327, 328/86-59-01, Failure to Meet Test Frequency Require-ments for Category A and B Valves - Paragraph 6.b.
(0 pen) Inspector Followup Item 327, 328/86-59-02, Clarification of Pump Testing Requirements - Paragraph 6.c.
The licensee did not identify as proprietary any of the material provided to or reviewed by the inspector during this inspection.
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Licensee Action on Previous Enfurcement Matters (0 pen) Unresolved Item 327, 328/86-13-03, Resolution of NRC NDE Van Inspection Findings.
See RII Report No. 50-327, 328/86-33 for a previous inspection of this item.
The inspector reviewed the status of individual items still open after the 86-33 report.
Based on discussions with the licensee, field observations as necessary, and review of licensee documenta-tion including calculations (see paragraph 7 below), a number of individual parts of this item can be closed.
The following is a summary and current status of individual items left open after the 86-33 report.
a.
TVA Item 21. Welds C1, C2, C3 and C4 - TVA was in the process of re-analyzing these undersized welds. This item remains open, b.
TVA Item 18, Welds N1, AA and CC - Welds were found to be acceptable by calculations. This item is closed, c.
TVA Item 23, Welds A D and E - Undersized welds were found to be acceptable based on calculations. This item is closed.
d.
TVA Item 26. Welds F and G - Weld design was different from that specified on drawing.
As built welds were found to be acceptable by calculations. This item is closed.
e.
TVA Item 15, Weld 1-46 - Welds different from that shown on drawing.
This item is a vendor furnished item.
Drawings reviewed by the NRC were TVA field drawings, which should not show the vendor welds. This item has not been resolved and remains open, f.
TVA Item 8, Welds El, E2, E3 and E4 - Undersized welds were found to be acceptable by calculation. This item is closed.
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TVA Item 9, Weld C - Weld was welded on 3 sides in lieu of required 4 sides.
Condition was found to be acceptable based on calculations.
This item is closed.
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TVA drawing 47A054, All Welds - Support did not meet drawing configu-ration.
As built support is acceptable based on calculations. The as built condition will be reflected on a revised drawing as part of the corrective action for Significant Condition Report (SCR) SQN-CEB 8606.
This item is closed.
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TVA drawings 47A055-93 and 170 - Welding did not meet drawing require-ments for spacing.
This item was accepted based on reinspection.
Deviations for spacing requirements were minor and had no significance on the support. This item is closed.
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TVA drawing 48N1216(R13), Welds C, F, and G - Thi:: is a large miscellaneous steel structure.
The NRC inspection documentation did not identify the location of the welds in question.
Based on verbal information TVA reinspected the area of the structure inspected by the NRC.
Although individuals welds and discrepancies could not be identified, all identified discrepancies ware resolved.
This item is closed.
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TVA drawing 47A056 - 170 (TVA Item 2), Welds G. M, N, 0, P, Q, R and T
- A number of problems were identified with this HVAC duct support.
Areas of the support were not painted; weld surface problems existed such as craters, weld profiles, undercut and slug; one weld was missing; and there was a space between one support plate and the concrete.
TVA has re-inspected this item and resolved all discrep-ancies. This item will be reviewed further during future inspections.
4.
Unresolved item (92701)
Unresolved items were not identified during the inspection.
5.
Inservice Inspection - Review of Program (73051) (Units 1 and 2)
The inspector reviewed the licensee's ISI program in the areas indicated below.
In accordance with 10 CFR 50.55a(g), the applicable code for both units is the ASME Boiler and Pressure Vessel (B&PV) Code,Section XI, 1974 Edition with Addenda through S75.
However, as indicated in TVA's submittal to the NRC, dated September 13, 1984 TVA has updated their ISI programs to the 1977 Edition. S78 Addenda of the ASME B&PV code except that the extent of examination for category B-J and C-F pipe welds is in accordance with the 1974 Edition S75 Addenda.
Steam Generator Tubing is to be inspected in accordance with Regulatory Guide 1.83.
In response to TVA's submittal, dated September 13, 1984, the NRC requested additional information by letter (Adensam to Parris), dated November 18 1985.
TVA provided additional information by letters (Gridley to Youngblood), dated March 12 May 6, and July 30, 1986.
The Safety Evalua-tion Report (SER) has not been issued.
The inspector reviewed the following program and QA documents relative to ISI:
Nuclear Quality Assurance Manual (NQAM) Part II, Section 5.1,
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Revision 0. Inservice Inspection - Nuclear Power Plant Components NQAM Part II, Section 6.3, Revision 0, Nondestructive Examination
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NQAM Part III, Section 1.1, revistun 0, Document Control
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NQAM Part III, Section 4.9, Revision 0, Handling of CSSC Test
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Deficiencies Surveillance Instruction (SI) 114.1, Revision 7. ASME Section XI
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Inservice Inspection Program - Unit 1 SI 114.2, Revision 7, Inservice Inspection Program for Tennessee
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Valley Authority, Sequoyah Nuclear Plant - Unit 2 only Technical Instruction (TI) 51, Revision 33, Nondestructive
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Examination (NDE)
Maintenance Instruction (MI) 6.21. Revision 10. Repairs and
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Replacements of ASME Sectior. XI Components The documents were reviewed in the areas of:
Use of an authorized nuclear inservice inspector (AN!!) and
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apprnval of plan and procedures by the AN!!
Review and approval of the ISI olan and procedures
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Identification of commitments and regulatory requirements
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Procedures for preparing plans and schedules and filing with
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enforcement and regulatory authorities Sufficient organizational staff to ensure performance of
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acceptable ISI work Site administrative procedures to define authorities and responsi-
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bilities for final evaluation and acceptance of ISI results QA review including assurance that plans and procedures have been
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reviewed by appropriate personnel and meet r.gulatory requirements Establishment of procedures for corrective action
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Oversee construction activities concerned with ISI
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Within the areas inspected, no violations or deviations were identified.
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Inservice Testing of Pumps and Valves (61700 and 61725) (Units 1 and 2)
r The inspector reviewed the licensee's IST Program in the areas indicated below to determine whether regulatory requiretrents and licensee committronts were being niet.
In accurdonce with 10 CfR 50.55a(g). the applicable code is the ASME B&PV Code,Section XI,1974 Edition, S75 Addenda for Unit 1 and j
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1977 Edition, S78 Addenda for Unit 2.
Based on TVA's IST Program submittal, dated March 3,1982, as revised by TVA submittal, dated November 4,1982, the NRC issued a Safety Evaluation Report (SER), dated April 5,1985. Based on issue of the SER and subsequent meetings, TVA submitted a revised IST program on August 16, 1985.
On June 6, 1986, TVA issued a revision to the August 16, 1985, submittal. On September 18, 1986, NRC requested additional information on TVA's latest IST program.
The revised SER, based on the August 16, 1985 and June 6, 1986, has not been issued.
a.
The inspector reviewed the following documents for control of IST activities:
SI-1, Revision 16, Surveillance Program Units 1 and 2
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SI-166. Revision 10 Summary of Valve Tests for ASME Section XI
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TI-89, Revision 1, Inservice Testing Required by ASME Section XI
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Mechanical Test Instruction (MTI) 14. Revision 2, Summary of ASME
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B&PV Code Pump and Valve Program Administrative Instruction (AI) 31. Revision 6, Control of
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Measuring and Test Equipment Al-4, Rev.sion 54 Plant Instructions - Document Control
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Standard Practice SQM 2. Revision 19. Maintenance Management
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Sys te.n NQAM Part III, Section 1.1, Revision 0. Document Control
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NQAM Part II, Section 4.9, Handling of CSSC Test Deficiencies
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The documents were reviewed for general content and to verify that:
The licensee had assigned responsibilities for:
preparation,
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review and approval IST procedures; scheduling of IST; performance of test functions; performance of maintenance; and performance of calibrations Adequate procedures existed for control and issue of test
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procedures That tests were scheduled at required frequencies
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b.
To verify that summary status lists are maintained to indicate the status of testing of pumps and valves, the inspector reviewed the following records:
i (1) Pump Evaluation shcots for July and October 1986, for the following pumps:
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Centrifugal Charging Pump 1A-A
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Centrifugal Charging Pump 18-B i
Containment Spray Pump 2A-A Containment Spray Pump 28-B
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(2) A sample of "S! Status Logs" and Computer Printout of " Stroke Times" and " Test Dates" for category A and B valves
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During review of the above valve summary documentation, the inspector noted that on numerous occasions category A and B valves had not been stroke tested at the scheduled frequencies required by the ASME B&PV Code and the Technical Specifications. Technical Specification 4.0.5 requires testing of ASME Class 1, 2 and 3 valves in accordance with ASME Section XI.
Paragraph IWV-3411 of the 1977 Edition of Section XI, applicable to Unit 2 and paragraph IWV-3410 of the 1974 Edition of Section XI, applicable to Unit 1, require stroke testing of category A and B valves every three months.
The Technical Specification defines the three months as 92 days and allows a 25% extension of the surveillance interval. The following two conditions, which violate the testing frequency requirements were found:
Review of computer printout data and test packages for Unit 1 i
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revealed a number of category A and B valves that were stroke
tested on or near July 25, 1985, and not tested again until on or about December 17, 1985.
The valves were in systems required to be operable in made 5 or cold shutdown.
A similar test frequency lapse occurred for the same Unit 2 valves.
The problem occurred because the plants were in cold shutdown (Mode 5) and TVA did not realize that the l
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test schedule for some category A and B valves covered by L
procedure S!-166.6 had to be maintained in mode 5.
This problem was identified by TVA on Potential Reportable Occurrence (PRO) 1-85-369, dated December 13, 1985. However, the condition was evaluated as being acceptable based on TVA's practice of scheduling the start of a test package at the required frequency and not controlling the completion date for the package or individual valves.
The package for the valves in question contained several hundred valves.
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inspector identified the following Units 1 and 2 category A and B valves (required to be maintained in mode 5) with test frequency lapses that appear to be random in time.
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Dates of Stroke Tests
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1-FVC-62-91
02/29/84 - 07/25/84
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1-FVC-70-206
04/23/85 - 12/17/85
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2-FVC-62-90
06/24/84 - 01/26/84
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2-FVC-67-346
06/28/84 - 11/26/84 2-FVC-67-352
06/28/85 - 02/03/86
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i 2-FVC-67-348
06/27/84 - 11/26/84
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The above test frequency lapses appear to have been caused by two
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problems. First, the surveillance procedure schedules tests based on issue of test packages at the required frequency.
TVA worked under the policy that as long as the package was completed within
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the required frequency, requirements were met. Where there are a significant number of components in a package, such as several hundred valves in the case of category A and B valves, it is next s
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to impossible to ensu.e that each component in the packages is
tested at the required frequency.
Second. TVA did not realize J
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that the frequencies for some category A and B valves in the test packages had to be maintained in Mode 5.
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This failure to stroke test category A and B valves at the
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required frequency is in violation of Technical Specification
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4.0.5 and ASME Section XI and is identified as Violation Item 327,
328/86-59-01 Failure to Meet Test Frequency Requirements for
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Category A and B Valves.
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c.
The inspector verified that the licensee had developed procedures for pump testing by identifying and examining the following test procedures:
SI-40 Revision 35 Centrifugal Charging Pump
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SI-37, Revision 27 Containment Spray Pump Test l
The procedures were reviewed in the areas of:
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.e General technical and administrative adequacy
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Plant equipment status evaluation and identifications
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Description of hydraulic circuit to be used
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Location and type or measurement for each code test parameter
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Allowable ranges for test variables
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Minimum flow and/or pressure for pump to fulfill safety function
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Minimum system operation time for stabilization
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Realignrrent of hydraulic circuits
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Review of test results
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Recording requirements
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Establishing of pump measurement reference values
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During review of the above procedures, the inspector noted that the l
procedures do not clearly cover paragraphs IWP-4220 (relative to pressure tap construction) and IWP-4520 (relative to instruments to measure vibration) of ASME Section XI.
Pending review of revised procedures, Inspector Followup Item 327, 328/86-59-02, Clarification of Pump Testing Requirements, is identified.
d.
The inspector verified that the licensee had developed procedures
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for valve testing by identifying and examining the following' test procedures:
SI-166, Revision 10, Summary of Valve Tests for ASME Section XI SI-166.1, Revision 36, Full Stroking of Category
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"B" Valves During Operation Within the areas inspected, no violations or deviations, except as noted in paragraph b., were identified.
7.
Review of Engineering Calculations Related to Welds (Units 1 and 2)
An on-site review of engineering calculations related to welds found to be deficient during TVA reinspection effort was conducted October 22-24, 1986.
The purpose of this inspection was to review engineering calculations for completeness, consistency of documentation, engineering evaluation and mathematical accuracy.
The accuracy of the design loads used in the cal-culations was not reviewed since such a review was considered to be outside the scope of this inspection.
The remainder of this inspection effort was completed in the IE office during the period October 13-21, 1986 and October 27 - November 20, 1986.
Thirteen (13) TVA items involving 211 pages of engineering calculations from Volume III (SCG 3074) were reviewed using the licensee's design criteria SQN-DC-U-24.1, Revision 2 and referen::e material AISC Steel Construction Manual 8th Edition and Design of Welded Structures by Blodgett. These items are considered closed relative to review of calculations.
In addition, calculations from (open) unresolved items in regards to reports No. 50-327, 328/86-13 and 86-33 were reviewed to assess the licensee's
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response to the NRC findings. All of these items, with the exception of TVA item 21 are considered closed relative to review of calculations.
Refer to Attachment 2 for details.
The Volume III (SCG 3074) engineering calculations and calculations from (open) unresolved items generally were found to be complete, accurate, and conservative in evaluating the deficient weld ccnditions identified during the TVA reinspection effort.
However, in some cases the calculation packages contained numerical and documentation errors, and had missing weld
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calculations, which indicated a lack of attention to detail by the designer and checker of the calculations. These discrepancies related to the consis-tency of documentatiori and in all cases, the identified deficiencies did not change the _end result and the overall conclusions.
These inconsistencies were pointed out to the TVA engineer and the calculation packages were revised to incorporate the NRC inspector's comments (see attachment 1 and 2 fordetails).
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Within the areas inspected, no violations or deviations were identified.
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Attachments:
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Table 1 - Engineering Calculations Reviewed
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Table 2 - Engineering Calculations
'l from NRC (0 pen) Unresolved Items
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ATTACHMENT 1 TABLE 1 ENGINEERING CALCULATIONS REVIEWED (VOLUME III SCG 3074)
TVA Item No.
Description 1A Instrument Support - Incomplete fusion and undercut 2A Instrument Support - Actual center to center dimension of skip weld not to required distance per design drawing 3A Instrument Support - Undersize vendor welds 4A Instrument Support - Incomplete fill along fusion line, undercut and undersize SA Instrument Support - Actual center to center dimension of skip weld not per drawing 6A Instrument Support - Craters with porosity, center to center dimension of skip weld not per drawing 7A Pipe Support - Undersize welds 8A Instrument Support - Actual weld leg length not per drawing 9A Conduit Support - Undersized welds 10A Conduit Support - Undercut welds 11A Electric Support - Slag on weld 12A Conduit Support - Actual weld leg length not per drawing AIS Duct Support (47A055-93) - Center to center dimension of stitch weld not per drawing AIS Pipe Support (47A054-28) - Welds not per drawing and undercut of welds
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ATTACHMENT 2 TABLE 2 ENGINEERING CALCULATIONS FROM NRC (OPEN) UNRESOLVED ITEMS TVA Item No.
Description (Report No./ Item No.) (Status)
Duct Support - Fitup gap for one weld greater than maximum allowed (50-327, 328/86-33-05) (Closed)
Conduit Support - Stitch weld center to center dimension was not per drawing (50-327, 328/86-33) (Closed)
Duct Support - Welds undersized and not per drawing (50-327, 328/86-33) (Closed)
Pipe Su port - Underfilled flare-bevel (50-327, 328/86-13-03)
(Closed
Pipe Support - Welds not shown on as-built drawings (50-327, 328/86-13-03, 86-33) (Closed)
Protection Barrier - No calculations for welds N1, AA, and CC(50-327,328/86-13-03,86-33)(Closed)
Cable Tray Support - Missing calculations for undersized welds C1, 2, 3, 4 on detail D (50-327, 328/86-13-03, 86-33)
(0 pen)
Pipe Support - Undersize welds (50-327, 328/86-13-03, 86-33)
(Closed)
1A Instrument Support - Incomplete fusion and undercut (50-327, 328/86-13-03,86-33)(Closed)
6A Instrument Support - Weld had unacceptable craters and contained porosity (50-327, 328/86-13-03, 86-33) (Closed)
8A Instrument Support - Length of the intermittent welds to short (50-327, 328/86-13-03, 86-33) (Closed)
AIS Dwg. No. 47A055-93 Duct Support - Spacina on skip fillet weldsdidnotmeetdrawingrequirements(50-327,328/86-13-03, 86-33) (Closed)
Dwg. No. 47A054-2B Pipe Support - Welds not per drawing and undercut of welds (50-327, 328/86-13)(Closed)
Dwg. No. 47A055 - 170 Duct Support - Welding does not meet drawing requirements for spacing (50-327, 328/86-13)
f~1osed)
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