IR 05000327/1986070

Insp Repts 50-327/86-70 & 50-328/86-70 on 861208-12.No Programmatic Deficiencies W/Regard to Facility Maint of Environmentally Qualified Equipment Identified.Major Areas Inspected:Maint Program & Previous Insp Items

ML20207S524
Person / Time
Site:	Sequoyah
Issue date:	03/03/1987
From:	Hubbard G, Potapovs U NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:
Shared Package
ML20207S519	List: IR 05000327/1986070 ML20207S518
References
50-327-86-70, 50-328-86-70, NUDOCS 8703190606
Download: ML20207S524 (9)

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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTIOM AND ENFORCEMENT Report Nos: 50-327/86-70; 50-328/86-70 Docket Nos: 50-327/320 License Nos: OPR-77, OPR-79 Licensee: Tennessee Valley Authority 6N 3PA Lookout Place 1101 Parket Street Chattanooga, Tenressee 37400-2801 Facility Name: Segunyah Nuclear Plant, Units 1 and 2 Inspection At: Chattancoga, Tennessee ,

Inspection Conducted: December S-12, 1986 Inspector: N.7.$s Yb }/2/Yf G. T. Hubbard, Equipment Qualification & Test ' Date -

Engineer (EQ&TE)

Also participating in the inspection and contributing to the report were:

0. P. Gormley, EQATE, IE A. B. Ruff, Poactor Inspector, RII K. M. Jennison, Resident Inspector Approved by: Njh- -

3- 3 - d'7 U. Potopovs. Chief, Equipment Qualification Date Inspection Section. :E B703190606 870309 PDR ADOCK 05000327 PDR G

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INSPECTION SUMMARY Inspection on Decemter 8-17, 1986 (Inspection Report Nos. 50-327/86-70; 50-328/

86-70)

Areas Inspected: Announced inspection to review the licensee's maintenance program for ensuring that as installed and as maintained 10 CFR 50.49 c,ualified equipment is in accordance with qualification documentatior. The inspection also concentrated on maintenance related issues for qualified equipment iden-tified during previous NRC inspection Results: The inspection identified no programatic deficiencies with regard to the SON maintenance of environmentally qualified equiprect. Open Item 50-327, 3?8/86-01-05 and Unresolved Item 50-377,328/86-42-02 from previnus NRC inspec-tion reports were resolved. Additionally, the concerns identified in Mr. J. M. Taylor's letter to Mr. S. 'A. White dated July 31, 1986, are resolve Adequate corrective action on Potential Enforcement / Unresolved Item 50-328/ .

E6-01-15 was confirme The inspection determined that the " piece part" procurement vir.lation identified in Inspection Report 50-327,328/86-61, dated November 14, 1086, affected envi-ronmentally qualified equipnent. Since qualified equipment is affected, the EO '

inspection team will follow the resolution of the " piece part" issue to assure adequate resolution relative to qualified equipment prior to restart. Prime responsibility fcr resolution of the overall issue will remain with the inspection team identifying the violatio Items remaining urresolved from Inspecticn Report Nos. 50-327,328/86-01:

Name Item Number Potential Enfercement/ Unresolved Items: Raychem Splices / Breakouts 50-3?7/86-01-15; 50-328/86-01-16 Open Items: Completion of EQ Trainino 50-327/06-01-01; 50-328/86-01-01 Completion of Audit Corrective Actions 50-327/06-01-02; 50-328/86-01-0? Revision To Me.intenance Procedure SCM 62 50-327/86-01-03; 50-328/86-01-03 Completion of Maintenance Program 50-327/86-01-04; 50-328/86-01-04-2-

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DETAILS PERSONS CONTACTED:

1.1 Tennessee Valley Authority (TVA)

• H. L. Abercombie, Sequoyah Site Director D. W. Wilson, Project Engineer

. *V. L. Elliot, EQ Project Manaaer

• L. M. Nobles, Plant Superintendent

• T. E. Spinks, Replacement Items Procram Manager

• S. W. Littrell, EQ Coordinator *

• R. Harding, Site Licensing Manager P. R. Wallace, Plant Harager

• B. M. Patterson, Maintenance Superintendent

• B. W. Hooper, Electrical Engineer

• M. A. Skarzinski, Electrical Maintenance Supervisor

• L. P. Woodley, Jr. , EQ Section Supervisor

• A. E. Ives, EQ Maintencnce -

• M. A. Cooper, Compliance Licen. sing Engineer

• J. Blankenship, Manager Information Office

• W. E. Andrews, Site Quality Manager

• L. D. Alexander, Modificaticn Section B Supervisor

• R. A. Stockton, Modification Section A Engineering Supervisor -

• S. Wilburn, Maintenance

• L. Jeralds, Maintecance

• L. Bruce, Maintenance-Special Projects Supervisor

• J. Wheeler, Methods and Procurement Services Supervisor

• D. Elkins, Instrument Maintenance Supervisor

• S. D. Scott Instrument Engineer

• J. W. Kelly, Engineering Assurance Engineer

• A. H. Ritter, Engineering Assurance Engineer

• J. H. Sullivan, Supervisor, Plant Operations Peview Staff (PORS)

. R. H. Smith, Supervisor Quality Implementation M. R. Sedlacik, Supervisor Modification Section A R. W. Olson, Modification Supervisor W. H. Deen, EQ Section Supervisor J. D. Smith, P0RS J. M. Anthony, Operations Grcup Manager

G. B. Kirk, Compliarce Licensing Supervisor R. H. Buchhol::, Site Representative 1.2 Consultants B. J. Crane, Westac Services, In .3 NRC T K. Grimes, Director, Division of Quality Assurance, Vendor and Technical Training Center, IE

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• G. Zech, Director, Division of TVA Projects, RII

• Denotes those present at the exit meeting

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-. PURPOSE:

The purpose of this inspection was to continue the review of the licensee's implementation of a program to neet the recuirements of 10 CFR 50.49 for Sequoyah Nuclear Plant (SON), Units 1 and . BACKGROUND:

On August 21-??, 1985, TVA shutdown both units at SON due to concerns that documentation at TVA nuclear sites right be inadequate for environmantal cualification of electric ecuipment within the scope of 10 CFR 50.4 Since that time, TVA has initiated an indepth program to ensure that environmental qualification of all electric equipment within the scope of 10 CFR 50.49 is established at SQN prior to restar In order to evaluate the new program at SQN, the NRC/IE has conducted three inspections of the SON procram and has documented the results in NRC inspection report 50-327,328/86-01, dated August 15, 1906. This inspection is a continuation of the NRC evaluation of the SON equipment ovalification (EQ) prograr and its implementation.' This inspection focused on nainten-ance activities for environmentally cualified equipnent with special emphasis on SON's approach for assuring that as installed and as naintained equipment is in accordance with qualification documentation. Durina tha inspection, reviews were also conducted on sore of SQN'S corrective actions on EQ related findings identified in previous NRC inspection ' FINDINGS: Followup of Previous inspection Findings The NRC inspectors reviewed SQN's corrective actions relative to some of the unresolved findirgs identified during tbr three previous EQ inspections. . Status of the unresolved items is discussed in the following paragraph Open Items:

(1) (0 pen) Completion of EQ Training (50-307,3E8/86-01-0?1 No review of this item was performed during the inspection; therefore, it remains ope .

(2) (0 pen) Correction of Audit Corrective Actions (E0-327,328/ .

86-01-02)

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No review of this item was perforned during the irspection; therefore, it remains ope (3) (0 pen) Revision of Maintenance Procedure SCM 62 (50-3?7,3?8/

86-01-03)

No review of this iten was perforced during tha inspection; therefore, it remains ope _ _ _. _

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(4) (0 pen) Completion of Maintenance Program (50-327,328/86-01-04)

At the time of the inspection SON had not completed all renuired maintenance activities for qualified equipment; therefore, main-tenance program status was not part of the inspection. This item remains ope (5) (Closed) Equiprent Maintenance History effects on Qualificatien (50-327,328/86-01-05)

See discussion in paragraphs Potential Enforcement /Unresolvad Items:

(1) (Closed) Barton Transmitter, Lot 7-764(50-??8/86-01-15) During the June 1986 EQ inspectien it was determined that Barton level ,

transmitters 2-LT-3-43 and 2-LT-3-56 were installed in the plant such that the conduit fittings tn the transmitters were at or below finod level. Sirce conduit fittings belnw flood level is not allowed by the licensee's cualification criteria, tha fittings were required to be moved. During the plant welkdown of this inspection, the NPC inspectors determined that the conduit fit-

. tings for the two transmitters had been relocated abnve flood leve (2) (Oper) Raychem Splices / Breakouts (50-327/86-01-15; 50-328/

86-01-16)

No review of this item was perforred during the inspection; therefore, it renains ope Unresolved Iten 50-327,328/86 42-02 from NRC inspectice report 50-327,328/86-42, dated September 26, 1986 was reviewed and closed. This item is discussed in paragraph Equipment Installation and Maintenance Durirg previous NRC inspections of SQN concerns were raised regarding whether installation and maintenance activities on qualified equipment have been sufficiently controlled and/or verified by SQN to ensure that installed eouipment is in accordarce with qualification documen-tation. One concern pertained to whether past plent'ectivities might have invalidated oualificatinn of installed equipment. Also of concern was whether vendor requirements and recommendations for qualified equipment have been followed or adequate evaluations have been per-forced tn .iustify not followira them. Concerns with equipment

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installation and maintenance have been described in the following documents:

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NRC Inspection Report Nos. 50-327,328/85 45, dated February 18, 1986 Letter from J. M. Taylor, Director, IE to S. A. White, Manager of Nuclear Power, TVA, dated July 31, 1986 NRC Inspection Report Nos. 50-327,328/86-01, dated August 15, 19 U NRC Inspection Report Nos. 50-327,328/R6-42, dated September 26, 1986 Due to the corcerns idertified in the above documents relative to installation and raintenance of qualified equipment, this inspection

'fecused on reviewing SQN's activities in these areas to deternine the validity of the concern The inspectors' review determined that the EQ Project (EOP) defines maintenance requirements for qualified equipment in Qualification Maintenance Data Sheets (QMDSs) which are located in Tab G of tha respective qualification binders. The OMDSs specify the required maintenance to ensure continued qualification and list recommendad maintenance and/or surveillance activities. The QMDSs are then reviewed by the plant to ensure that all requirements and recornend-ations are accounted for in plant maintenance and surveillance pro-grams. Documentation of compliarre with OMDS data is documented per Appendix C of procedure SQP 62, "10 CFR 50.49 Prograr, Qualifi-

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cation Maintenance Data Sheets Implementation."

The inspectors determined that verification of compliance with CPDS information is accomplished by review of work authorizations, main-tenance records, modification records, physical inspection of equip-ment, and other dorurentation determined to be appropriate. It was further deternired that QMDS requirements rust be complied with or approval for noncompliance rust be obtained fren E0P. OFDS recom-nendations must be met or justification for not doing so rust be documented. Approval from E0P for noncompliance with QMDS recommend-ations is not require Special installation requirements for cualified equipnent are identi-fied on field verification sheets developed by E0P and/or QMDS If field verification sheets are used then compliance with the require-rents is docunented by the plant in quality information releases (OIRs) which are reviewed and accepted by EQP. Compliance with installation requirements identified in the CPDSs is documented per Appendix C of SQM 62 as for mainterance renuirements and recommend-ation The NRC inspectors evaluation of SQN's EQ progran included reviews of:

(1) vendor manuals to determina vendor renuirements and recommerda-tiens for the equipment; (2) qualification binders to evaluate the adequacy (of the ations; 3) work OMDSs implementing authorizations vendor and maintenance requirements records to establishand rernnme compliance with QMDSs; (4) procurerent racords; and (5) physical-6-

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i inspection of installed equipment to determine SQN's compliance with l' installation requirements and preservation of the installed ouelified configuration The inspectors selected 16 qualification binders and reviewed their associated installation and naintenance records. The 16' binders represent one. third of the ecuipment binders which were considered

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to be the most susceptible to installation and maintenance problem Considerations for determining susceptibility included equipment complexity and/or whether the equipment was involved in other mafor

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SQN progran verification activities which would identify installation and maintenance problams. Of the eouipment selected, 11 transmitters selected from 4 equipnent binders and 2 motors were selected for equipment walkdow Based on the documentation reviewed and the equipment, the inspectors identified no programatic deficiencies in SQN's approach te assuring that as installed end as maintained environmentally qualified equip-

. ment is in accordance with oualification documentation. No eouipment deficiencies were identified during the equipment walkdown.

i While no programatic deficiencies were identified, the inspectors

' determined that the " piece part" procurement violation identified in Inspection Report 50-327,328/86-61, dated November 14, 1986, affected environmentally cualified equipment. Since qualified equipment is affected, the EQ inspection team will follow the resolution of the l

" piece part" issue to ensure adequate resolutien relative to qualified l equipment prior to restart. Prime responsibility for resolution of the l overall issue will remain with the inspection team identifying the violatio (1) While the inspection team did not find any programatic deficien-cies, the inspectors made suggestions to SQN for improvements to the program. One suggestion dealt with the basis for establishing QMDS requirements and recomendations. Normal preventative maintenance (maintenance that would be performed regardless of whether the equipment was ,10 CFR 50.49 qualified or not) on qualified equipment is not included in the QMDSs ur.less it has a direct effect on cualification. SCH stated that it was not intended that the QMDSs would drive the entire plant maintenance progra Of particular concern to the inspectors was that paragraph 7. of

' inspection raport 50-3:'7,328/85-45 identified that administrative requirements make it easier to cancel preventative maintenance rather than defer it. The report further stated that late or cancelled preventative maintenance activities are normally only reviewed by the general foreman with regard to effect on equip-ment. It also stated that engineering evaluation is normally not accomplished and higher managerent reviaw of late or cancelled preventative maintenance is minima .. ..

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While the inspectors did not identify any specific prcblems with deferred or cancelled normal preventative maintenance on the equipment reviewed, the inspectors suggested that the maintenance program should have some means to ensure that any deferrals or cancelling of preventative maintenance on qualified ecuipment dees not affect its cualified statu .

(2) Another suggestion pertained to includirp in the E0 and/or main-tenance program some means of-evaluating the effect of abnormal operating occurences and/or changes in unit status, on the

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qualified life or qualification status of qualified equipmen The inspectors cited as an example that the qualified life of the residual heat removal (RHR) pumps was based on the assumption that they .were operated approximately 727 hours0.00841 days <br />0.202 hours <br />0.0012 weeks <br />2.766235e-4 months <br /> per year; however, during the current extended outage they have been operating more thar-the assumed 727 hours0.00841 days <br />0.202 hours <br />0.0012 weeks <br />2.766235e-4 months <br />. Phile SQN was able to satisfy the inspectors concerns for the RHR pumps, the inspectors suggested

that SQN establish some methods of considering the effect of abnormal operating occurences and/or changes in unit status on the qualification of qualified equipmen (3) During the inspectors' review of electric r.oter qualification binder MOT-1, the inspectors noted the following statement for

" Essential Equipment Maintenance Requirements" on page G14 of'

the binder; " motor 1ubricant shall be a STO-2 lubricant procured

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in accordance with TVA specification 18.009. Different manu-facturers lubricants shall not be mixed." This requirement was established so that lubricant trending analysis could be performed on the lubricant during the equipments' lifetime; thus, allowing evaluations of eouipment condition based on analysis of the lubrican Since TVA procurement specification 18.009 does not prevent different manufacturers from supplying STO-2 lubricant and does not provide for the separation cf ST0-2 lubricants by ranu-facturers, the inspectors questioned the validity of the trending

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data. SON stated that they had recently replaced the motor lubricant and they recorded the manufacturar of the lubricant; however, they acknowledged the problem with retaining lubricant identity throughout the equipments plant life and stated they were evaluating whether to retain the lubricant trending require-ment. SQN also stated that a vibration check is run on the motors every quarter and this information along with other maintenance activities would provide information on notor condition durirg installation in the plant. The inspectors recommended that a decision be nade regarding whether to use only one manufacturers lubricant in a motor and either elininate the reouirement or establish means to ensure a lubricant's manufacturer's identit .

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The above suggestions for improvements in SQN's EQ and/or maintenance programs should be considered during future program revisions and are not considered necessary for restar Rased on the results of the inspection, Open Item (50-327,328/86-01-05)

concerning equipment maintenance history effects on qualified equip-ment is closed; however, future NRC inspections will evaluate this area for continued program implementation and compliance with NRC regula-

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tions over the life of the plan Open Item (50-327,328/86-42-02) concerning incorporation of vendor requirements in the E0 program was reviewed by the inspectors. Within the scope of the vendor documentation and SQN EQ documentation reviewed, the inspectors determined that appropriate vendor requi.ements, recommendations, and/or suggestions were being properly accounted for in the SON EQ program. No deficiencies were identified and this item is considered closed. As in the case above, future NRC inspections will evaluate this area for continued program implementation and compliance with NRC regulations over the life of the plan .

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