IR 05000327/1987015

Insp Repts 50-327/87-15 & 50-328/87-15 on 870302-06.One Violation Noted:Procedure M&AI-7 Re Mod of Cables Not Followed & Work Request for Replacement of Fire Coating Inadequate

ML20214W074
Person / Time
Site:	Sequoyah
Issue date:	05/15/1987
From:	Julian C, Linda Watson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20214W046	List: IR 05000327/1987015 ML20214W043 ML20214W052
References
50-327-87-15, 50-328-87-15, NUDOCS 8706150072
Download: ML20214W074 (32)

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UNITED STATES

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jo NUCLEAR REOULATORY COMMISSION g p REoloN il

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• : r 101 M ARIETTA STREET, N.W., SUITE 2900 o, [ ATLANTA, GEORGIA 30323

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Report Nos.: 50-327/87-15 and 50-328/87-15 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: March 2-6, 1987

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Lead Inspector: M Mhz[*A dL u f e7-/F-87 Date Signed L. J. Wats 6tf Accompanying Personnel: D. S. Brinkman A. R. Long D. r'. Loveless P. B. Moore G. L. Paulk D. J. Sullivan Approved by: C ' A'

C. A. Julian, Chfef 8//d[Q

'Date Signed Operations Branch Division of Reactor Safety _

SUMMARY Scope: This special, announced inspection was conducted in the area of maintenanc Results: One violation was identified; Inadequate work instructions for modification of cables (paragraph 5.c).

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REPORT' DETAILS Persons Contacted Licensee Employees

• L. M. Nobles, . Plant Manager

• B. M. Patterson, Maintenance Superintendent M. R. Harding, Site Licensing Manager

• G. B. Kirk, Compliance Licensing Supervisor

• H. D. Elkins, Instrument Maintenance Supervisor

.M. A. Skarzinski, Electrical Maintenance Supervisor

• G. S. Boles, Mechanical Maintenance Outage Supervisor L. S. Bryant, Mechanical Maintenance Engineering Supervisor R. K. Gladney, Instrument Engineer Supervisor R. M.-Mooney, Systems Engineer Section Supervisor

-*D. H. Tullis, Special Projects

• M.-A. Purcell, Licensing. Engineer

• C. E. 'Cantrell, Chief, Program Management Staff

• J. H. Sullivan, Supervisor, Plant Operations Review Staff

• R. Seiberling,- Director, Nuclear Manager's Review Group

• M. R. Sedlacik, Modifications Group A Supervisor

• M. A. Cooper, Licensing Engineer

-*J. G. Newman, Modifications Group A Craft Supervisor

• T. f.. Howard, Quality Surveillance Supervisor

• D. L. Love, Mechanical-Maintenance Craft Supervisor

• R.~Ramsey, Supervisor,' Maintenance Planning

• S. Wilburn, Assistant to Maintenance Superintendent-

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• E. F. Harwell, Staff Specialist, Program Management Staff

• A. H. Ritter, Engineering Assurance Enginee *J.'W. Kelly, Engineering Assurance Engineer

• R. H. Buchholtz, Site Representative, Office of Nuclear Power

• J.'T. Traffanstedt, Supervisor, Maintenance Planning

• H. B. Rankin, Manager of Projects

• D. L. Jeralds, Instrument Craft Supervisor

• R. N. Mays, Corporate Licensing Other licensee employees contacted included engineers, technicians, mechanics, and office personne NRC Resident Inspectors-

• K. M. Jenison

• D. P. Loveless

• Attended exit interview

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2 Exit Interview The inspection scope and findings were summarized on March 6,1987, with those persons indicated in paragraph I above. The inspector described the areas inspected and discussed in detail the following inspection findings:

(Closed) Violation 327/85-27-01, 328/85-28-01. Three Examples of Failure to Follow Procedures in MI-10.1. (Paragraph 3.c.)

(0 pen) Unresolved Item 327/85-17-09, 328/85-17-08. Review Licensee's Control of Sequence of Critical Steps in Procedure (Paragraph 3.b.)

(0 pen) Unresolved Item 327, 328/86-18-0 Vendor Recommended s Maintenance on Stored Equipmen (Paragraph 3.c.)

(Closed) Deviation 327, 328/86-48-01. Employee Performance Reports and Quarterly Evaluations. (Paragraph 3.d.)

(Closed) Inspector Followup Item 327, 328/85-08-01. Follow Continued Action Planned to Correct Leaking on Safety Relief and Power Operated Relief Valves. (Paragraph 6.a.)

(Closed) Inspector Followup Item 327, 328/85-45-C Review Completion of MRs Identified as Requiring Completion Prior to Unit Restart. (Paragraph 6.b.)

(Closed) Inspector Followup Item 327, 328/85-45-0 Maintenance History and Trending Progra (Paragraph 6.c.)

(0 pen) Inspector Followup Item 327, 328/86-18-05. Update Applicable Prccedures to Specify Torque Switch Settings for Applicable Motor Operated Valves (MOVs). (Paragraph 6.d.)

(0 pen) Inspector Followup Item 327,328/86-18-0 Review of Maintenance Instruction (MI) Rewrite Program. (Paragraph 6.e.)

(0 pen) Inspector Followup Item 327, 328/86-48-02. Technical Support Systems Engineering Section Implementation. (Paragraph 6.f.)

(Closed) Inspector Followup Item 327, 328/86-48-03. FSAR and Technical Specification Review for the Inclusion of Requirements and Commitments in PM Procedures. (Paragraph 6.g.)

(Closed) Inspector Followup Items 327, 328/86-48-04. Corrective Actions to the Deficiencies in the Measuring and Test Equipment .

Progra (Paragraph 6.h.)

(0 pen) Inspector Followup Item 327,328/87-15-01. No Followup Method to Ensure That the Safety Evaluation Report on M&TE Completed Within 14 Days. (Paragraph 6.h.)

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(0 pen) Violation 328/87-15-02. Failure to Follow Procedure M&AI-7 and the Failure to Provide Adequate Work Request for Replacement of Fire Retardant Coatings. (Paragraph 5.c.(1))

The following licensee identified items, documented in the Nuclear Manager's Review Group (NMRG) report of December 17, 1986, were reviewed:

Management and Corporate Involvement in the Maintenance Program Finding A-1 - Category 1 and 3 (Closed for Category 1 and Open for Category 3). Corporate Responsibilities. (Paragraph 5.a.(1))

Finding A-2 - Category 3 (0 pen). Performance Indicator (Paragraph 5.a.(2))

Finding A-4 - Category 3 (0 pen). Adequate Root Cause Analysi (Paragraph 5.a.(3))

Finding M-1 - Category 1 (Closed). Involvement of Management in Work Performanc (Paragraph 5.a.(4))

Planning and Scheduling Finding A-3 - Category 3 (0 pen). Corporate Guidance and Coordination of Maintenance Progra (Paragraph 5.b.(1))

Finding C-1 - Category 3 (0 pen). Training for Maintenance Planner (Paragraph 5.b.(2))

Finding G-2 - Category 1 (0 pen). Use of Current Revision of Rocedures and Drawings. (Paragraph 5.b.(3))

Finding G-4 - Category 3 (0 pen). Coordination of Maintenance to Minimize Downtime, Testing and Radiation Exposure. (Paragraph 5.b.(4))

Finding G-5 - Category 1 (0 pen). Lack of Equipment Qualifica-tion Lis (Paragraph 5.b.(5))

Finding N-1 - Category 3 (Closed). Useful and Complete Maintenance History and Trending Progra (Paragraph 5.b.(6))

Finding N-2 - Category 3 (0 pen). Provide Hardware to Implement Effective Maintenance History and Trending Program. (Paragraph 5.b.(7))

Maintenance Procedures and Review of Maintenance Work Request System Finding F-1 - Category 1 (0 pen). Failure to Follow Work Instructions and Procedures. (Paragraph 5.c.(1))

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Finding F-2 - Category 1 (0 pen). Finding H-7 - Category 1 (0 pen). Work Instructions Not Clear, Concise and Complet (Paragraph 5.c.(2))

Finding G-2 - Category 1 (0 pen). Work Completed Using Expired Drawing (Paragraph 5.c.(3))

Preventive Maintenance Finding E-1 - Category 1 (0 pen). Finding E-5 - Category 1 (0 pen). Inadequacies in Preventative Maintenance Progra (Paragraph 5.d.(1))

Finding E-3 - Category 1 (0 pen). Lack of Management Approval for Waiver, Extensior, and Defferals of Preventative Maintenanc (Paragraph 5.d.(2))

Measuring and Test Equipment Finding L-2 - Category 3 (Closed). Inventory and Accountability Mechanisms for Maintenance Tools and Equipment. (Paragraph 5.e.)

PostMaintenanceTesting(PMT)

Finding I-1 - Category 1 (0 pen). Adequate Definition and Perfonnance of Post Modification Testing. (Paragraph 5.f.)

Quality Assurance Finding 0-1 - Catec ory 1 (0 pen). Plant Quality Assurance Reviews Were Not Icentifying Significant Weaknesse (Paragraph 5.g.(1))

Finding 0-2 - Category 1 (0 pen). Corrective Action for Items Identified by QA Not Effective. (Paragraph 5.g.(2))

Finding 0-3 - Category 3 (0 pen). Inconsistencies in Nuclear Quality Assurance Manua (Paragraph 5.g.(3))

Temporary Alterations Finding H-1 - Category 1 (Closed). Timely Completion of Design Changes. (Paragraph 5.h.)

Deficiencies in the Rigging and Hoisting Program Finding L-4 - Category 1 (0 pen). Rigging Identified as Defective Not Segregate (Paragraph 5.i . )

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' Teflon Tape Usage

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Finding A-5 - Category-1 (0 pen). Unacceptable Usage of Teflon

: Tape as Thread Sealan (Paragraph '5.j . )

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No dissenting comments.were received from the licensee. The licensee did j not identify as proprietary any information reviewed by the inspectors.

[ ' Licensee Action on Previous Enforcement Matters

, (Closed) Violation 327/85-27-01, 328/85-28-01. Three Examples of i

Failure to Follow Procedures in MI-10.1. During the performance of MI-10.1, three instances of failure to follow procedures were

, identified involving: cleaning and inspection of the emergency diesel generator (EDG); cleaning the EDG collector with clean, bound end,

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lintless wiping cloths; and inspection of EDG frame hold down and .

L foundation bolts. In the first example, the licensee amended MI-1 to state that low-pressure. air was to be used to remove dust from the EDG collector rings and stator as needed. The requirement for use of bound end cloths was removed from MI-10.1 because lintless bound end cloths 'are no longer available from the licensee's supplier.

Finally, in the third example, signcffs were added to the procedure j to require that the bolts be properly inspected. In all of the above examples the personnel involved were counseled on the need to follow procedure Additionally, MI-10.1 has been rewritten to include signoffs on all steps and to break down the procedure to avoid

confusion between the electrical and maintenance technicians' respon-

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sibilities. This item is close It was noted that the NRC Resident

Inspectors are currently reviewing generic problems with failure- to follow procedures at Sequoyah under violation 327,328/87-02-12.

' (0 pen) Unresolved Item 327/85-17-09, 328/85-17-08. Review Licensee's Control of Sequence of Critical Steps in Procedures. The inspector

reviewed this item and the licensee's corrective action to date. The inspector determined that the current' surveillance instruction review

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program and the maintenance instruction writer's ' guide address the

-issue. This item remains open pending review of the correction of maintenance instructions for startup use prior to completion of the

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long term maintenance instruction enhancement progra (0 pen) Unresolved Item 327, 328/86-18-0 Vendor Recommended Maintenance on Stored Equipment. The licensee has generated a

[ Significant Corrective Action Report - (CAR), SQ-CAR-86-046. The

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corrective actions and actions to prevent recurrence that were identified included: (1) establishing preventative maintenance

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instructions for the specific deficiencies identified by the subject CAR, a documented evaluation for potential equipment

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degradation;including (2) a ~ review of all stock equipment in Power Stores 1 using a computerized listing or other documentation to identify materials and equipment that are potentially subject to special i

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storage . requirements in addition to those minimum requirements described in AI-36, Storage,. Handling, and Shipping of QA Material,

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including a documented evaluation for potential equipment degrada-

tion; (3) conducting a survey of all equipment in storage involved in i Engineering Change Notices (ECN) to identify items that are poten-tially subject to special storage requirements in addition to those

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, minimum requirements described in AI-3 To prevent recurrence. the licensee committed to: (1) establish a team consisting of representa-4 tives from each maintenance section, Modifications A and B, QA, and

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Power Stores to review'AI-36 for adequacy; (2) revise SQA-45, Quality Control of Materials and Parts and Services, to require purchase

[ requests to address known or potential storage requirements and to require suppliers to furnish those requirements prior to or. with '

shipment of material, as. applicable;:and, (3) revise AI-11, Receipt Inspection, Nonconforming Items, QA Level / Description Changes, and iubstitutions, to require receipt inspection to include an engineer-ing evaluation of identified special storage requirements in addition to those: required by AI-36. The site Materials organization will

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coordinate with the Division of Nuclear Engineering (DNE) to ensure that DNE procurement procedures contain a requirement for storage requirements to be addressed for each procurement initiate The licensee is establishing a preventative maintenance (PM) program i for power stores equipment to ensure that vendor recommended mainte-

nance for stored equipment is performed. This program is not yet

! fully implemented and lacks corporate guidance. The inspector i considers the establishment of a PM program for power stores equip-i ment essential to the closure of this ite The inspector verified that the licensee has established PM instruc-tions .for the pumps referenced in the original report. However, the corrective actions and the actions to prevent recurrence have not yet been completely undertaken and until these actions are implemented or

! commensurate measures have been taken to address this problem, unresolved item 327,328/86-18-07 will remain open, (Closed) Deviation 327, 328/86-48-01. Employee Performance Reports and Quarterly Evaluations. The inspector reviewed the licensee's

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employee performance reports and quarterly evaluations for the Mechanical Maintenance Section. The inspector determined that the

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quarterly evaluations are currently being performed as require The licensee combined the quarterly evaluations scheduled for

February - April 1986 and May - July 1986 into a single 6-month evaluation and then returned to the regular quarterly evaluations for August - October 1986. The inspector reviewed a sample of the

recently completed evaluations for the November 1986 - January 1987 quarter and noted that these evaluations were generally consistent with observations noted on the employee performance reports prepared

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during this time interval. The licensee has recently added a cover j sheet to the evaluation form This cover sheet provides for a

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review of the evaluations by the Craft Section Supervisor and Group Superviso The purpose of this review is to ensure better consistency is maintained in these evaluations. Employee performance reports generated between August 1986 and February 1987 were also reviewed by the inspector. This review disclosed that disciplinary action is now normally being taken within the stated target of two weeks. The only exceptions noted to the two-week target occurred when proposed disciplinary actions required extensive coordination with other departments. Based upon the above findings, this item is considered close . Unresolved Items Unresolved items were not identified during this inspectio . Review of Nuclear Manager's Review Group Audit of Maintenance Program The licensee stated in the Revised Corporate Nuclear Performance Plan, Revision 4, that actions would be taken to prevent recurring maintenance problems; to use predictive techniques such as equipment history analyses and the Nuclear Plant Reliability Data System to improve maintenance; and, to reduce maintenance backlogs. The licensee stated that predictive methods would be utilized to ensure that problems applicable to more than one unit or site are identified and corrected. The licensee stated that a corporate staff would monitor the performance of the improved maintenance programs and assess edequacy. The licensee has committed to upgrade the planning process for maintenance including defining the scope of mainte-nance and ensuring that proper procedures and resources are available and has also committed (1) to review and upgrade operations, maintenance and surveillance procedures and (2) to provide increased management emphasis on the adherence to procedure The licensee has conducted a comprehensive review of corrective and preventative maintenance at Browns Ferry, Sequoyah, and Watts Bar. This review was conducted by the the licensee's Nuclear Manager's Review Group (NMRG). The final report was issued on December 17, 198 The staff has reviewed the scope and findings of this study. The staff believes that the NMRG study was a comprehensive evaluation of the maintenance programs at the TVA sites and corporate offices. The performance areas reviewed were based on those identified in the Institute of Nuclear Power Operations (INP0) Guidelines for the Content of Mainte-nance at Nuclear Power Stations and include competent programmatic reviews and field observations of maintenance activities. The staff noted that the findings of the NMRG study closely paralleled those findings identified by NRC inspection . . _ . .. .

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The NMRG study states that the most significant improvement areas needed i included the aggressive correction and prevention of hardware problems, corporate involvement in nuclear maintenance , . and implementation of ,

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challenging goals and objectives for maintenance. -The finding on correc-

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tion and-prevention of hardware problems cites the diffusion of responsi-bility for maintenance controls and checks,' the lack of aggressive and coordinated efforts to solve problems and a lack of clear accountability for solving specific problems. Specific findings of the NMRG included deficiencies ~ in corporate involvement in the maintenance program, inadequate training and qualifications of planners, preventive maintenance program deficiencies, inadequate maintenance shops and office spaces, inadequacies in maintenance instructions and the performance of instruc -

tions and work requests, deficiencies in the planning and scheduling

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. of maintenance, inadequate testing, problems with materials suitability,

! inadequate control. of maintenance activities, failure to provide adequate

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post maintenance testing, inadequate control of maintenance. tools and

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equipment, lack of management involvement in ongoing maintenance activi-

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ties, incomplete maintenance history programs and failure to use trending

techniques to guide maintenance, ineffective quality assurance reviews -

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of maintenance and -lack of follow through on corrective action for

{ maintenance deficiencies.

. The inspectors' consider _ that the licensee should evaluate the actions i taken in response to the NMRG findings to verify timeliness and adequacy.

, To confirm that adequate corrective actions have been taken to correct the l= root causes of the findings identified by the NMRG in the initial review,

? the inspectors consider that the NMRG should conduct a followup review at-Sequoyah prior to restart. NMRG should clearly conclude that sufficient

. action has been taken prior to Sequoyah restart.

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. The corrective action for the NMRG findings were classified by the i

licensee into three categorie Category 1 findings are those- that

. will be resolved prior to Sequoyah restart. Category 2 are site specific findings that are addressed individually at the various sites. Category 3

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are long. term programmatic findings. The licensee is in the process

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of addressing the Category 1 items in preparation for restar The

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inspectors believe that the licensee should establish and document a i schedule for completion of corrective action for Category 2 and 3 items

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related to Sequoyah prior to Sequoysh restart.

The staff has inspected the licensee's corrective actions for the NMRG

, findings related to the restart of Sequoya The inspection included an evaluation of corporate involvement in the correction of maintenance program deficiencies at Sequoyah and tne implementation of the Corporate Nuclear Performance Plan commitment The inspection results, although

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directly related to the maintenance program at Sequoyah, are indications of the licensee's actions at the corporate leve The major areas reviewed and the status of corrective actions are discussed below, Management and Corporate Involvement in the Maintenance Program (1) Finding A-1 - Category 1 and 3 (Closed for Category 1 and Open for Category 3)

NMRG Report Finding A-1 noted that corporate responsibilities regarding maintenance lacked definition and direction. This finding also noted that a corporate policy for the conduct and support of maintenance at the sites had been drafted but had not yet been establishe In response to the NMRG findings, the licensee has issued a corporate policy statement on maintenance (ONP Policy No.10.3, Rev. 0). The policy statement states: "It is the policy of the Office of Nuclear Power that plant equipment be available and capable of performing its intended function with a high degree of reliability. Maintenance of plant equipment will have a high priority on a day-to-day, shift-to-shift basis." The policy statement was reviewed by the inspector and appears acceptable as a corporate policy statemen The licensee also informed the inspector that the licensee is preparing a corporate directive on maintenance as well as corporate standards on maintenance to implement the corporate policy statement. Although the corporate directive has not yet been approved, the inspector was provided with a draft copy dated November 20, 1986. A review of this draft directive showed it to be a comprehensive document which is expected to provide the necessary corporate direction when it is finally approve However, until the corporate directive and standards are approved, the Category 3 aspects of NMRG Report finding A-1 will remain ope The licensee has also implemented a corporate assessment of the Sequoyah maintenance program to determine the acceptability of the program for plant startu The licensee's assessment was based on the criteria for short-term acceptance of the program as specified in the licensee's Program Plan for SQN Equipment Condition Evaluation and Maintenance Program Assessment dated January 8, 1987. The licensee's review determined that the Sequoyah maintenance program is acceptable in the short term (acceptable for plant startup) since the program meets the intent of the program requirements identified in the corporate draft maintenance directive dated November 20, 1986 and the applicable portions of the Nuclear Quality Assurance Manual

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corrective maintenance and repair work. Guidance for priority

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levels for corrective maintenance and repair work is contained F in the licensee's Standard Practice SQM-2, Maintenance Manage-t ment-Syste SQM-2 provides that the priority level for a work request be assigned by the originator. The inspector

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was concerned that work requests may be assigned an improper i priority level; however, this concern was alleviated by the supervisor for the Maintenance Planners who explained that the Maintenance Planners are responsible for revising work request priority levels when improper priority levels are identified during the initial review of work request No violations or deviations were identifie (3) Finding A-4 - Category 3 (0 pen)

NMRG Report Finding A-4 noted that root cause analyses are not performed for some potentially significant failures. The report further noted that a policy or directive is needed to define appropriate criteria for requiring prompt failure evaluations of specific plant event Licensee Standard Practice SQM-58, Maintenance History and Trending, established the requirements for a maintenance history and trending program at Sequoyah. The inspector reviewed the implementation of this program for the only period for which the

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review has been completed (July 1984 to July 1985). Subsequent review periods are in work but are not yet complet The maintenance history and trending program established by SQM-58 established the following as threshold criteria for requiring further review and evaluation:

Repetitive - Any component within the data base that fails two or more times in a 12 month perio Generic -

By Model No. - Any manufacturers model no. component that has more than 3%, but not less than 2 failures, of its population in the data base being searched within a 12 month perio By Manufacturer - Any item of the same function code made by the same manufacturer that has more than 5%, but not less than 2 failures, of its population in the data being searched within a 12 month period.

Components which satisfy the above failure criteria are evaluated for failure trends and identification of root causes by the applicable maintenance enginee Upon confirmation of the failure trend and identiv. ation of the root causes of the failure, the maintenance engint ar proposes appropriate resolu-tions to preclude further fai' dres. The inspector reviewed this program and concluded ...at the licensee has established an adequate maintenance history and trending program. However, NMRG Report finding A-4 will be held open until further experi-ence is gained by the licensee with implementation of the progra Only limited results of the implementation were available and those results have not been fully acceptable. The inspector noted at least one example of a failure to adequately identify the root cause of an apparent repetitive generic failure. That example was reported in the July 1984 to July 1985 report and it involved eight bonnet gasket leaks of 4-inch Walworth (Model No. 5350 WE) feedwater swing check valve The maintenance engineer noted that a generic problem appears to exist and his resolution was to " Continue to monitor these valves to determine if generic problem exists and to identify root cause of failures." This resolution is considered unac-ceptable in that it provided no action to preclude additional failures nor did it identify the root cause of the noted failure No violations or deviations were identifie _ - - _

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(4) Finding M-1 - Category 1 (Closed)

NMRG Report Finding M-1 noted that the involvement of mainte-nance management and supervision in ongoing maintenance activities needed to be strengthened. The report also noted that most managers and supervisors recognized the value of increased field involvement with maintenance activities, but meetings, administrative duties, etc., were often permitted to interfer Over the past several months, the licensee has recognized the importance of having additional field involvement by members of its naintenance management and supervision personnel. The present, typical goals are for the craft foremen to visit two or three maintenance jobs per day, the general foreman to visit two jobs per day, the craft supervisor to visit one to two jobs per day, and the section supervisor to visit at least one job per day. These goals are considered appropriate and reasonabl The licensee has established documentation systems for use by the maintenance management and supervision personnel to acknowledge their visits to the job sites. The inspector reviewed a sample of these documents and confirmed that they were meeting the above goals. Discussions with the section supervisors and maintenance staff also confirmed that these goals were being satisfied. Therefore, NMRG Report Finding M-1 is considered close No violations or deviations were identifie b. Planning and Scheduling (1) Finding A-3 - Category 3 (0 pen)

The finding concerned overall corporate guidance and coordina-tion for maintenance program improvement efforts. It cites the development improvement of ofthe preventive planning maintenance and scheduling(PM) p(rograms P&S) functionsand the at all sites as examples of areas where stronger corporate direction is require The inspectors evaluated corporate guidance existing at Sequoyah in the areas of PM and P&S. The inspectors determined that no corporate guidance had been issued for the PM program with the exception of the ongoing activities noted for Finding A-1 regarding corporate responsibilities.

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) Under corporate direction, the licensee had made considerable

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progress in the correction of P&S problems identifie The

' licensee had established a maintenance planning.and scheduling section directly under the Maintenance Superintendent. This combined all craft planners into one sectio In addition, i partial implementation of the recommendations of the TVA Nuclear j' Plant Operational Support Systems (NPOSS) Review, Phase II,

Report No. 6.0, Routine Activity Planning and . Scheduling

. Functional Areas (Maintenance Management), dated June 1986, had been completed. For example, the supervisor of the maintenance planning and scheduling groups was a licensed senior reactor

operator (SRO); this was a specific recommendation of NPOSS i Phase II Report No. 6.0.

j This finding remains open pending review of the long term plan

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for . completion of these items. No violations or deviations were identifie (2) Finding C-1 - Category 3 (0 pen)

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This finding concerns the lack of structured training for maintenance planners and the contribution this makes to planning

- problem There was no structured training for the maintenance planning and scheduling group which would satisfy the recommendations of the 4 NMRG Repor This group received briefings, documents were routed, most planners received craft and Sequoyah systems training; but there was no effort underway to provide structured

< training in site-specific elements of the NMRG items important to restart, such as the determination of necessary post-maintenance

testing after the completion of maintenanc A TVA Memorandum from the Director, Division of Nuclear Training, j to the Acting Director of Nuclear Engineering, dated January 12,

! 1987, responded in detail to this finding. It listed near-term and long-range training efforts necessary to satisfy the NMRG l recommendations for Finding C-1. It also identified other

near-term training actions for Sequoyah restart relating to

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Findings F-1, H-6, H-7, I-1, and 0-1. The team considers that

! implementation of these actions would enhance the licensee's maintenance carabilities for restart. This item remains open.

No violations or deviations were identified.

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! (3) Finding G-2 - Category 1 (0 pen)

l This finding concerns delays in initiation of approved work i packages which may result in work not being performed to the i current revisions of maintenance instructions and drawings.

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The NMRG indicated that this situation existed because the work control system required the cognizant craft foreman, rather than maintenance planners, to ensure that work package contents were current prior to initiating wor The following corrective actions were taken:

(a) Administrative Instruction AI-42, Distribution and Control of Plant Instructions, had been revised to require that the planners verify by dated signature that the copy of the maintenance instruction in the work package was the latest issued revision (paragraph 5.2.3). Additionally, in paragraph 5.2.4, AI-42 required that, in cases where work is not initiated within 10 working days of the planners'

dated signature, the cognizant supervisor reverify that copies of included instructions were the latest revisio (b) Standard Practice SQM-2, Maintenance Management System, was being revised to include a verification by planners that the latest maintenance instructions were included in the work package prior to issuance; and, an additional verifi-cation if the work was delayed more than 10 day This item remains open pending confirmation of procedure revisions and review of field packages to verify implementatio No violations or deviations were identifie (4) Finding G-4 - Category 3 (0 pen)

This finding concerns the optimum scheduling and coordination of various types of maintenance to improve productivity and to minimize equipment downtime, post-maintenance testing and radiation exposure The establishment of the maintenance planning section as described in Finding A-3 improved coordination of various maintenance activities. The full-time assignment of a licensed SR0 from the Operations Department to the planning group also facilitated scheduling of work efforts. However, the inspectors found no evidence that a mechanized work planning system or maintenance management system was being implemented at the Sequoyah site. This item remains ope No violations or deviations were idertifie (5) Finding G-5 - Category 1 (0 pen)

This finding concerns the lack of a unified equipment classiff-cation list (Q-List) to permit maintenance planners to identify all safety-related components, systems, and structures. The thrust of the NMRG finding was that lack of a single equipment

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classification list caused time delays, unnecessary effort, and possible errors in the preparation of maintenance request Planners were required to use a variety of lists and documents to determine the safety-related status of specific equipmen To partially correct this problem and to provide administrative controls in the near term, the licensee issued a matrix identi--

fying the various equipment lists and provided guidance on utilizing the Licensee representatives stated that this matrix will be included in the next revision (Rev. 23) to SQM- The licensee also intends to conduct briefings for maintenance-planners on the matrix and on the revision to SQM-2.~ This action when completed is considered adequate to satisfy Finding G-5 for restart of the unit It should-be noted by the licensee that the December'10, 1986, ,1 memorandum from W. T. Cottle listing corrective actions for the-NMRG findings states that a combined list will be developed prior to restart. These plans have apparently change At the corporate level, the Department of Nuclear Engineering (DNE) had been assigned responsibility for development of a single Q-List. This action had been assigned a Category 3 'tyr the licensee (long term) and no completion date had been set. This part of Finding G-5 remains ope No violations or deviations were identifie ,

(6) Finding N-1 - Category 3 (Closed) <

' The finding noted that maintenance history programs do not provide meaningful, complete, and useful-information. Revisions 4 and 5 to Standard Practice SQM-58, Maintenance History and

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i Trending, established a maintenance histcry and trending program

! that satisfied the recommendations of the NMRG report. . Systems

! engineers were required to review completed maintenance requests and prepare maintenance history entries when appropriate. Man-

. hours expended on maintenance were reported. Informal-training I was provided for maintenance personnel to improve the quality of

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information noted on maintenance request forms. This item is I considered closed at Sequoyah.

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l No violations or deviations were identified.

i (7) Finding N-2 - Category 3 (0 pen)

This finding concerns the use of maintenance history and trending results for planning corrective and preventive

! maintenanc The thrust of the recommendations of Finding N-2 l was for the licensee to provide hardware (computer terminals,

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printers), . improved. records . (microfilm), procedures, and

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instructions .to improve the use of historical information in

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planning _and scheduling maintenanc These actions were partially implemented but the effort lacked corporate guidance and involvement. The item remains. open.

Note that. Inspector Followup Item 327, 328-85-45-07 was opened to track NRC concerns with the Maintenance History and Trending

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Progra This IFI is closed in paragraph 6.c and the actions to resolve the concerns in this area will be reviewed in the followup to Finding N- No violations or deviations were identified.

, Maintenance Procedures and Review of Maintenance Work Request System I (1)' Finding F-1 - Category 1 (0 pen)

Finding F-1 involved the failure to follow work instructions and 2-

- procedure The NMRG found that steps had been skipped, data

- sheets were not completely filled .out,-and second party verifi-cations ^ were not properly performed in the work reviewe The NMRG recommended that Sequoyah establish a policy for adherence to procedures, train maintenance personnel, increase

supervisory monitoring and provide assistance to procedure users in resolving problem The inspectors reviewed the policy documents which had been included in the training program for adherence to procedure These policy statements were adequate to assure that personnel were aware of the requirement to follow procedures. The state-ments were to be read after the training sessions and signed by the employees and supervisors to indicate understanding and the commitment to meet the policy. The training sessions had been initiated with a scheduled completion date of March 20, 198 The inspectors interviewed maintenance technicians and super-visors who indicated that they understood the requirement to follow procedures; however, during observation of work in i progress the inspectors noted several cases where procedures were not explicitly followed. The inspector noted that Instru-mentation and Control technicians replaced a fuse in instrumen- "

! tation panel -2-PX-72-34 without a work request. SQM-2 allows

operators to replace fuses without a work request but does not mention I&C technicians. The technicians were accompanied

by an operator and had obtained the proper fuses. The inspector also observed that the documentation associated with Work ,

Request (WR) 8222705 on the diesel generator battery, which i required torquing of a nut on a loose strap on cell #30, was not completed even though the torquing was performed. The technicians had concluded that the torquing procedure had not

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corrected the loose strap and decided not to indicate that it was satisfactorily completed. These incidents, while not safety significant, did indicate a lack of attention to detail in following procedure ;

In addition, the inspector . identified one safety significant incident where workers failed to follow procedures. On March 4, 1987, the inspector observed workers in the Unit 2 annulus removing a required fire retardant coating from the pigtails on the annulus side of containment penetration 30 with a srewdriver and heatgun when the procedure utilized for the work, M&AI-7, stated that cables should be cleaned using a " solvent approved by cable manufacturer." This work was being accomplished with a work request which did not assure that the coating would be replaced following the wor During a plant tour, the inspector observed two Electrical Modifications workers removing a fire retardant coating ("Flamastic") from the pigtails on the annulus side of penetra-tion 30. The workers were using a heat gun and a screwdriver to remove the coating from the connector box end of the cable tra The individuals stated that they had removed the flamastic from the connector box to the penetration. This was being accomplished in order to free cables that had been shortened during the removal of the cable splice The work observed was being done under WR B21726 This WR stated, " Replace splice for cable 2V1418A and cable 2V1419A if required at Penetration 30." Instruction Number 3 stated,

"Resplice cable listed on attached WR per M&AI-7, MI-6.20 and attached splice sketch." The specific work observed was being accomplished under M&AI-7, Cable Terminations, Splicing, and Repairing of Damaged Cables, which states in section 7.1.3,

" Clean and degrease cable jacket and wire insulation with a j solvent approved by cable manufacturer."

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The supervisor stated he believed that the individuals were only i cleaning the cables in the connector box and that this " slop" of Flamastic was not required and did not need to be replaced. The

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supervisor also stated that the procedure was being followed as hot water was being used to clean the cables in addition to the L, heat gun and srewdriver. The individuals and their supervisor I

stated that they believed that removing the entire coating was acceptable under their guidance. This practice was also being performed on other penetration An October 18, 1984 letter from TVA to NRC stated that, " cable coating will continue to be applied and maintained, in accord-ance with previous commitments, to all non-IEEE-383 qualified cables." The pigtails from the penetration to the connector box

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meet the criteria of these previous commitments and are required to be coated. The licensee confirmed that these pigtails were required to be recoated. The process of removing the Flamastic was not controlled to require this replacemen Technical Specification 6.8.1 states that, written procedures shall be established, implemented and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978. Regulatory Guide 1.33, Appendix A states that maintenance that can affect the perform-ance of safety-related equipment should be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstance The failure to follow procedure M&AI-7 and the failure to provide an adequate work request for replacement of fire retardant coatings is identified as violation 328/87-15-0 Finding F-1 remains ope (2) Finding F-2 - Category 1 (0 pen)

Finding H-7 - Category 1 (0 pen)

Finding F-2 concluded that some work instructions were not clear, concise nor cint?ined the necessary information for users to understand and perfo.'m work activities. Finding h-7 involved observations that maintenance request work instructions did not contain sufficient guidance and instructions to ensure the work was adequately performe The NMRG recommended that feedback mechanisms be established for procedure errors, technical support be provided to the craft, supervisory monitoring of work in progress be increased, improved procedures be developed and thoroughly checked (including dry runs of draf ts), and in the long term, a simplified procedure approval and revision process be establishe As stated in the discussion of Finding F-2, the inspectors'

field reviews of work in progress indicates that maintenance requests still lack clarity (Violation 328/87-15-02). The inspectors interviewed maintenance technicians and supervisors and determined that they had been instructed in the procedure change process; however, the inspection results indicate that improvement in this area is still neede Interviews and work package reviews also indicate that feedback mechanisms had been established for procedure errors including craft reviews of procedures and instructions prior to perform-ance of work. The inspec+or determined that the craft had not been provided details on d.e results of the evaluation of their comments in all case The licensee stated that measures had

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I been taken to provide results to the commenters, but committed to reinforce these efforts by discussions of comment resolution ,

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in craft section meetings. The training program discussed above in Finding F-1 covered the review with the maintenance craft and supervisors on the importance of providing feedback on errors and changing procedures prior to use when errors were detecte As stated, the goal for completion of the training was March 20, 198 The inspectors reviewed supervisory monitoring of work in progress and determined that significant improvements had been mad This review is discussed under Finding M-1 in this repor The inspectors reviewed the Maintenance Instruction Enhancement Program and interviewed maintenance supervisors in regard to the program. The program had prioritized the revision of procedures into two categories: Priority 1 (prior to July 30, 1987) and Priority 2 (prior to August,1988). The inspector determined that relatively few Priority 1 procedures had been complete The inspector determined that resources originally assigned to this program had been directed toward the surveillance instruc-tion review and other activitie The inspector reviewed an internal memorandum dated February 10, 1987 which indicated that the commitment in Sequoyah Nuclear Performance Plan,Section II.4.2, to prioritize and improve the procedural quality of maintenance procedures to reduce tiering and cumbersomeness by July 30, 1987 was to be revise The licensee stated that the original goals for high priority maintenance instruction updates of July 1987 and lower priority maintenance instruction updates of August 1988 were to be changed to 8 months and 21 months after startup of Unit 2, respectively. At the time of the inspection, the schedule for the enhancement program was under review by licensee managemen Review of the program remains open. It was noted that the NMRG recommended expediting the Maintenance Instruction Enhancement Progra (Also refer to the discussion of inspector followup item 327, 328/86-18-06 in paragraph 6.e of this report.)

Findings F-2 and H-7 remain ope (3) Finding G-2 - Category 1 (0 pen)

The finding involved observations that work was completed using expired drawings. The NMRG recommended that measures to ensure that work packages are updated be strengthened and that Sequoyah should consider using the planning and scheduling staff to update work packages.

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Review of work in progress indicated that work was being

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performed with the current revision of procedures and drawings.

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This-item is open pending review of the administrative controls

for assuring current documents are use No violations or deviations were identifie Preventive Maintenance

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(1) Finding E-1 - Category 1 (0 pen)

. Finding E-5 - Category 1 (0 pen)

l Finding E-1 identified the following specific concerns: the

< scope of PMs were not evaluated for adequacy and completeness; vendor manual PM recommendations had not been uniformly imple-mented, and variations had - not been documented; a reliable, useful master equipment list had not- been established; and,

- efforts ~ to improve the PM- program lacked corporate direction.

Finding E-5. involved the observation that no mechanisms existed a in the PM program to identify the individual PM's that are required by regulatory agencies, corporate policy or other commitments.

The NMRG report recommended the following actions for Finding

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E-1: assign responsibility for PM program development and improvement to a capable manager at the site; provide the resources to implement; review available lists of equipment and current lists of PM activities to identify appropriate equip-ment; establish PM based on vendor recommendations, equipment service history, and NPRDS; document deviations from vendor-manuals; develop corporate guidance; and, ensure that PM program is updated after modification packages are completed. The NMRG recommended that methods be-developed to identify PM activities constrained by regulations, policy, or commitment The licensee had recently assigned a manager for the PM program L under the Maintenance Superintendent. Allocation of resources i necessary for the program have been made., but a planned move into another office area and the full time attention of the new PM manager to the PM program had not occurred as of the dates of this inspection.

Each maintenance department conducted a review of FSAR and

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Technical Specification commitments to ensure that any PM

! activities constrained by regulation or commitments are being i performed properly. The inspector reviewed each of the depart-l ment studies and while- the methodology varied greatly, the

. reviews appeared to accomplish the comprehensive analysis that was recommended. A review of vendor manuals is to be performed by each responsible maintenance group prior to startup.

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Action on the remaining recommendations had not been -taken pending corporate guidance concerning the PM program. All of-the personnel are in place, but there was no formal document on the mission and details of-the PM program.

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Findings E-1 and E-5 remain open.- No violations or deviations r were identified.

-(2) Finding E-3 - Category 1 (0 pen)

The NMRG found that management approvals have not always been obtained for waivers, extensions or defferals of preventaitve

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maintenance activities past due for performance. . The NMRG recommended that measures be established to ensure that waivers and extensions or defferals are approved and reasons documented.

The inspector reviewed SQM-57 Preventive Maintenance Program, Rev. 5, which stated, "The completion due date may be extended for_ a maximum of 25% of the frequency rate by the general foreman or maintenance planner. This extension date should be

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added to the comments section of. the daily PM available _for work lis Deferrals or cancellations shall be approved by the

Maintenance Group Supervisor or Maintenance Engineering Section

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Supervisor. Authorization for deferrals or cancellations shall

be documented by signature and date and the reason for deferral or cancellation shall be documented on the PM package." This statement clarifies the procedural control and actions to be e -taken in the event of overdue PMs and it also assigns responsi-

!- bility to the appropriate personnel.

! Regarding the ~ past examples of a lack of management approval in i .this area, the inspector reviewed a QA audit that.was performed l on all CSSC PMs cancelled or postponed since November 1, 1986,

, as shown on the tracking system'as of February 9,198 There were two Deficiency Reports, generated as a result of this audit, requesting reviews to be performed by the maintenance supervisors to determine if any of the deferred PMs required

corrective action. In addition, several recommendations were

mad The recommendations included that the PM data coversheet

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be revised to aid in 'the deferral or cancellation and eventual rescheduling; and that PMs dispositioned due to material being i' out of stock have work requests written against them as well as

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placing steps in the PM procedure to assure that materials will

be available for the next PM performance. These changes appear to satisfactorily address the discrepancies and root causes.

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Finding E-3 will remain open pending review of the completion of

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the implementation of these corrective action No violations or deviations were identified.

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J 22 Measuring and Test Equipment Finding L-2 - Category 3 (Closed)

Finding L-2 involved inventory and accountability mechanisms for maintenance' tools and equipment. The NMRG recommendations were to:-

1) establish _ and implement uniform methods for inventory and account-

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ability of small tools and equipment at each of the sites to correct the problems noted, 2) consider implementation of the computerized bar code system, and 3) include in the system real time inventory and accountability for persons and places such as the hot tool room and the decontamination facility.

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The licensee has currently established a computerized system to control tools and equipment. Licensee personnel stated that this system was only established as an interim method until the computer-

) ized bar code system can be procured and implemented. Currently, the L ' licensee is bringing inventory'back to an appropriate level. This is indicative of the improvements brought about by the interim control proces Current accountability still has drawbacks inherent in the system.

- The tools are checked out to' individuals; however, should the tool be

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still the responsibility of the worker to inform the tools and equipment-personne Licensee personnel stated that.these drawbacks s would be further addressed in the new system. Note that inspector-

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followup item .327, 328/86-48-04, discussed in paragraph 6.h,- is related to this item.

. No violations or deviations were identifie PostMaintenanceTesting(PMT)

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Finding I-1 - Category 1 (0 pen)

The inspector reviewed actions taken by the licensee to assure PMT is

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adequately performed and defined as described in the NMRG Finding i 1- The inspector determined that Standard Practice SQM-2, Maintenance Management System, had not been fully upgraded to reflect all concerns in the NMRG report in that specific guidance for planners on items to be considered and evaluated for PMT have not been fully

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delineated. A current revision is in process which should address

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this concern when approve ; The training for planners for PMT is not formalized or structured.

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The licensee stated that training will be conducted in the future to address this concern as required by the NMRG action item.

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A licensee survey of 19 completed MR packages to ensure PMT require-ments were properly defined and followed was reviewed by the inspector.- The inspector's review indicated the following concerns -

related to the validity and adequacy of the survey proces (1)' Two MR package reviews conducted _by the inspector indicated the

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PMT requirements were inadequate to demonstCte system opera-bilit MR B209972 (ERCW Screen Wash Pump "C-B") replaced a i

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timer in the pump start circui The timer was not tested as a PMT requirement. MR 8216963 (Unit 2 Shield Bldg. Exhaust Damper B Flow Solenoid Valve 0650-046A) replaced a diode in the Surge Suppression Network. The only PMT required was a valve cycling test which does not verify Surge Suppression Network operabilit (2) Seven -of the MR packages were not representative of the NMRG concerns and not meaningful for a qualify revie Three of the MR packages involved door bolts / latch replacements. Two packages involved trivial non-CSSC items. Two packages involved lamp replacements. Related MRs are B216489, B220086, B214483, B129314, B216147, and B21464 Discussions with the plant personnel involved with the survey indicates that this survey should be re-conducted after the SQM-2 update and planner training process have been completed. The QA organization should be included in the re-survey to ensure consis-tency in future survey results.

( Finding I-1 remains ope No violations or deviations were identifie Quality Assurance (1) Finding 0-1 - Category 1 (0 pen)

l Finding 0-1 involved the detennination that the plant quality assurance reviews were not identifying significant weaknesses.

l The NMRG found that single quality assurance reviewers were L

used, the technical background of the reviewers was generally in one discipline while multidisciplinary reviews were required, and training in maintenance request related subjects was not-provided. The NMRG recomended that the licensee eliminate the Quality Assurance Section review and retrain plant personnel who already possess expertise in the appropriate disciplines to review the maintenance requests for quality assurance discrepancie _ _ _ _ _ _

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The licensee reviewed the NMRG finding and decided to implement actions other than those recommended. The licensee chose to staff the Quality Assurance Section with discipline engineers and train these engineers to conduct maintenance request reviews. Staffing for the new groups was almost complete at the time of. the inspectio Training of the engineers and supervisors was in progress with at least one phase of the

. training delayed pending completion of the revisions to SQM-2, Maintenance Management Syste This item will remain ope No violations or deviations were identifie (2) Finding 0-2 - Category 1 (0 pen)

The NMRG found that corrective actions for some problems identified by the plant Quality Assurance staff had not been effective. The NMRG recommended that management attention to corrective action for these items be increased; line management appreciation-for, and attention to, quality program requirements be strengthened; mechanisms for evaluation of the effectiveness of corrective actions be improved; and repetitive problems be escalate The inspector determined that the Nuclear Quality Assurance ,

Manual, Part 2, Section 2.16, had been revised to provide more rigorous requirements for followup on completion of corrective actions. The licensee implemented the new Condition Adverse to Quality Report (CAQR) procedure, AI-12, on February 23, 198 In addition, in response to QA audit report SQ-CAR-86-04-018, the licensee audited rejection rates from QA final maintenance request reviews and determined in October 1986 that the trend was decreasing indicating that corrective actions were effectiv This item remains open pending review of the implementation of the new CAQR process. No violations or deviations were identifie (3) Finding 0-3 - Category 3 (0 pen)

The NMRG found that inconsistencies in the Nuclear Quality Assurance Manual had created unnecessary delays in work and inconsistencies in site implementation of the quality assurance program. This item was not reviewed during this inspectio .

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h. Temporary Alterations Finding H-1 - Category 1 (Closed)

The inspector reviewed licensee corrective action to NMRG report Finding H-1. This item concerned minor. design changes needed to support plant maintenance and operation that were not being accomplished in a timely manner. The NMRG recommended that: (1) an expeditious process within DNE for approving and implementing minor design changes be established; (2) modifications be handled at the lowest qualified level; (3) the number of temporary alterations be reduced; and, (4) the results of the improvement efforts be monitore The inspector discussed with the licensee personnel the ongoing effort to revise the Sequoyah Design Change Notice (DCN) proces In conjunction with this the inspector reviewed a draft of SQEP-60, Handling of Modifications Using Design Change Notices. The process includes two new categories of design changes. These are minor changes and emergency changes. A minor change would require the issuance of a fully approved Minor DCN by the Division of Nuclear Engineerin An emergency design change follows two paths. An Emergency DCN is authorized and work proceeds. Concurrently a fully approved ECN package is developed. The process would not permit a system to be declared OPERABLE until the approved ECN is published and the work is completed in accordance with the associated work plans. The process is a work-at-risk method to be used only in emergency situations where delay is critica The inspector believes that with appropriate guidelines and clear guidance on when these methods are appropriate, the program could be of great benefit in smoothing out the design change process and in reducing the number of temporary alteration The inspector could not find licensee personnel responsible for assuring that the NMRG items on handling of the modifications at the lowest qualified engineer level and on monitoring the results of this program are addresse Finding H-1 remains ope In addition, the inspector verified that inspector followup item 327, 328/85-46-08 had been closed in the NRC Resident Inspector's Report 327, 328/87-08. This item was to follow a commitment made by the licensee to the INP0 to clear all temporary alterations made prior to January 1,1984, before startup following completion of Unit 1 Cycle 4 outage. The inspectors reviewed the reduction of the total number of TACF's; the program for long term reduction; and, the safety evaluation reports prepared by the licensee to evaluate the signifi-cance of all TACF's to be in place during Unit 2 startup and found these areas to be acceptabl .

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No violations or deviations were identified, Deficiencies in the Rigging and Hoisting Program Finding L-4 - Category 1 (0 pen)

The NMRG found that rigging identified as defective was not segre-gated from acceptable rigging. The inspector reviewed actions taken by the licensee to address and correct concerns presented in Finding L- Hazard Control Instruction HCI M-11, Rigging and Hoisting, was updated to require the immediate removal and segregation of defective rigging equipment as recommended in the NMRG report; however, no specific segregation location was designated or listed as would seem appropriate for adequate program implementation. Discussions with several plant supervisors indicated that they were not aware of any specific segregation point. Additionally, the inspector commented that it would be appropriate to list this requirement in the site standard practice for rigging, SQM-31, Inspection, Testing, Mainte-nance and Operations of Nuclear Plant Cranes and Hoists, Ref. DPM N74M15, since this is the site controlling document. Site briefings for plant crafts responsible for rigging had not been conducted to date as recommended in the NMRG report. It was noted that briefings were only planned to cover HCI-M11 change It would also be appropriate to include training in the area of SQM-31 review Segregated storage areas have not been established to date for defective rigging equipmen A review of the Rigging Fundamentals Course indicated that specific guidelines were not taught in the area of D/d requirements as described in Browns Ferry Inspection Report 259, 260, 296/86-32, paragraph 9. This item, noted as a generic training concern, was not known to the Plant Operations Training Center (P0TC) staff responsi-ble for rigging training for the site. TVA generic training problems should be more effectively coordinated between site SQM-31 did not list the current references in the reference section of the instructio Examples of out-of-date references include:

ANSI B30.9/ Slings, ANSI B30.16/0verhead Hoists, ANSI B30.2/0verhead and Gantry Cranes, etc. The topical report commits to the require-ments of Regulatory Guide 1.38; however, the licensee may consider updating these references to current standard Site rigger training was noted to be generally conducted by the skill-of-the-craft method with grandfathering for longtime licensee employee Rigger training records reviewed by the inspector indicated that of the 115 qualified riggers on site, only 25 have ever attended formal documented training at the P0TC for riggers (91 of these 115 are qualified to lift heavy loads). TVA will be instituting a new program to require all riggers to attend formal

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trainin This new course titled, " Criteria for Safe Operation of Cranes," appears adequate to address deficiencies in this area when fully implemented. A follow-up inspection will be conducted in this area when this course is fully approved and implemente A quality assurance audit was conducted related to the " Handling and Rigging" area in 1985 (21-85-P-010). The survey was thorough and noted deficiencies in the are Since new program requirements have been implemented since the date of the last QA survey, it would seem appropriate to conduct a follow-up surve This item remains open. No violations or deviations were identifie Teflon Tape Usage Finding A-5 - Category 1 (0 pen)

The inspector reviewed actions taken by the licensee to address concerns related to the unacceptable usage of Teflon tape as a thread sealant at Sequoyah and generically throughout TV The licensee revised Standard Practice SQA-160, Materials Which May Come in Contact with Reactor Coolant, to clarify approved uses of Teflon as a thread sealant and to include other approved thread sealants and the appropriate environmental usage requirements. The inspector reviewed a sampling of briefing attendance sheets for maintenance crafts to verify that the current site policy on Teflon tape usage has been disseminated adequately. Actions committed to be canpleted at the plant site are considered close The action to be completed by the DNE organization as discussed in the NMRG report had yet to be completed and thus will be reviewed at a later inspectio No violations or deviations were identifie . Inspector Followup Items (Closed) Inspector Followup Item 327, 328/85-08-01. Follow Continued Action Planned to Correct Leaking on Safety Relief and Power Operated Relief Valve The inspector reviewed the licensee action on problems with Power Operated Relief Valve (PORV) leakage. The licensee hired a representative from the valve vendor (Target Rock)

to oversee rebuilds of all the valves. This rework involved minor machining of the valves soft seat to decrease leakage. This was done on Unit 2 during the cycle 2 outag No detectable problems were noted during the last half of this cycl The Unit 1 valves were reworked in November 1985 after the shutdown of the unit. Therefore ,

no operation history exists on these valve .

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Following the problems noted by the inspectors in 327, 328/85-08, the licensee temporarily reinstituted a wet seal on the safety relief valves and heat traced it to 300 degrees to avoid pushing a slug of water through the valves. In Unit 1, new valve internals have been installed to support this modification. Unit 2 valves will have this permanent fix during the next refueling outage. Additionally, the licensee corrected some valve loading problems determined by testing done at Wyle laboratorie This work was done during the current outage in order to further correct leakage problem Licensee corrective action to date has shown vigorous attack of the pressu-rizer valve problems and is consistent with industry handling of the leakage problems. This item is close (Closed) Inspector Followup Item 327, 328/85-45-05. Review Comple-tion of MRs Identified as Requiring Completion Prior to Unit Restar Licensee action required to close this item involved adequately documenting the unreviewed safety question determination (USQD) for a partial modificatio Maintenance Request A521756 was initially written to resolve problems with motor operated valve clutch trippers by changing the gear ratio on ten valve This MR was cancelled because modifications are not performed on maintenance request Work was then reestablished as a modification package via Field Change Request (FCR) 4267, Engineering Change Notice (ECN) L6697, and Work Plan 12089. Two of the valves specified in the Work Plan had previously been modified during the Unit 1 Environmental Qualifica-tion (EQ) Program, so the licensee filed a Partial Modification Form with an attached Unreviewed Safety Question Determination (USQD)

form. The reason that the valves were not modified was not clearly stated on the USQD form, which therefore did not include sufficient information to determine the acceptability of the partial modifica-tion. The licensee stated that the USQD was presented to the Plant Operations Review Committee (PORC) by engineers who provided suffi-cient additional information for the PORC members to approve the partial modificatio To complete the required paper work to justify the partial modifica-tion, the licensee issued FCR No. 5090 documenting the previous modification of the valves and requesting a change to the ECN. The licensee stated that adequate information would be provided on future USQD forms, rather than relying on additional information to be presented to the PORC. This item is close (Closed) Inspector Followup Item 327, 328-85-45-07. Maintenance History and Trending Progra The inspectors reviewed the licensee's progress in developing and implementing an effective maintenance history and trending program. Revisions 4 and 5 to Standard Practice SQM-58, Maintenance History and Trending, were incorporated and provided a program that corrected the deficiencies noted in NRC Inspection Report 327, 328/85-45. The revisions established a trend analysis program which uses the Environmental Qualification Informa-tion System (EQIS) data base for NPRDS reportable maintenance items

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as well as maintenance associated with 10 CFR 50.49 equipment, Critical Systems, Structures, and Components (CSSC) equipment failures, and selected no1-CSSC equipment failures. There were provisions for trending groups of components with the same specific application but with different identification categories under CSSC or NPRDS. For example, a trending program had been initiated for all containment isolation valves, regardless of manufacturer or applica-

/{o Instrumentation out of calibration conditions were being Peptted as equipment failures and were being reviewed by special projec'tsqnd systems engineers as part of the trend analysis progra Informatiod'ftom the trend analystf program was being compared to other independe'Efailure data bases such as the Licensee Event Report and potential' Yep'ortable occurrence (PRO) data bases but with inconclusive result '

The trend analysis program was to'd' Ment to evaluate the reliability of the program as suggested in NRC Ini)qtion Report 327,328/84-4 Interviews established that informal trait.4q and briefings were adequate to prepare personnel for inplementation of the trend analysis program. Finally, through interviews and document review, the inspectors established that maintenance history and trending data was being fed back into the preventive maintenance (PM)'progrc However, it was too early in the inception of the program to evaluate the effectiveness of this feedback into the PM progra In conclusion, the inspectors considered that the licensee had initiated an adequate maintenance history and trending analysis program in Standard Practice SQM-58. It was, however, too soon to evaluate the overall effectiveness of the program as it affected plant maintenance. The evaluation was also difficult because of the many changes taking place in the Sequoyah maintenance program, such as the revision of maintenance instructions and the upgrade of the PM progra The maintenance history and trending program will be followed and evaluated in the future as part of NMRG Finding N-2 (reference paragraph 5.b.7); therefore, inspector followup item 327, 328-85-45-07 is close (0 pen) Inspector Followup Item 327, 328/86-18-05. Update Applicable Procedures to Specify Torque Switch Settings for Applicable Motor Operated Valves (MOVs). Procedure MI-11.2A, Limitorque Actuators Corrective Maintenance Procedure for SB-00, SMB-000 and SMB-000 Actuators, did not specify torque switch setting The procedure stated, "unless otherwise directed by cognizant engineer, set the open and close torque switches as found." Therefore, errors made when setting torque switches could be promulgate The licensee determined that thrust rather than torque switch settings should be controlled for the Limitorque valves. The torque switch setting should remain unchanged once it has been set for the required thrust load. Procedure MI-10.43 Procedure for Testing of

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Motor Operated Valves Using the MOVATS 2000 System, will be revised to include required thrust values, and procedures MI-11.2A and -11.2B will be revised to require M0 VATS testing to be repeated if a torque switch is replaced or the actuator is disassembled, (0 pen) Inspector Followup Item 327,328/86-18-06. Review of Mainte-nance Instruction- (MI) Rewrite Program. As discussed in paragraph 5.c.(2), the inspectors reviewed the long term Maintenance Instruc-tion Enhancement Program and determined that, while some . progress had been made, resources originally assigned to this program had been directed toward the surveillance instruction review and other activitie The licensee stated that 'the original commitment for high priority maintenance instruction updates of July 1987 and the goal for lower priority maintenance instruction updates of August f 1988 were to be changed to 8 months and 21 months after startup of Unit 2, respectively. . This item remains ope (0 pen) Inspector Followup Item 327, 328/86-48-02. Technical Support l Systems Engineering Section Implementatio Procedure SQA-168,

! Systems Engineering, had not been fully implemented at the time of

! the inspection. The Systems Engineering Program is being implemented in stages, and the status remained as described in Inspection Report 327,328/86-48. The licensee stated that walkdowns, trending techniques, draft guideline documents and preliminary system note-books will be implemented prior to the startup of Unit (Closed) Inspector Followup Item 327, 328/86-48-0 FSAR and Technical Specification Review for the Inclusion of Requirements and Commitments in PM Procedures. The inspector reviewed a draft copy of the FSAR and Technical Specification review report. This review appears to have been satisfactorily performed. The report is under review by management and will be issued in the near future. The licensee's actions in developing the cross reference list is essen-tially complete and this item is close (Closed) Inspector Followup Items 327, 328/86-48-04. Corrective Actions to the Deficiencies in the Measuring and Test Equipment Program. The inspector had determined that reviews and followup on Out of Calibration equipment have not been timely or comprehensiv Specifically, safety evaluations were not being performed. Correc-tion of the deficiencies was considered a plant startup issue. The inspector reviewed the licensee's corrective action to this item, to Discrepancy Report 87-064R and to ' Employee's Concern Task Group (ECTG) Report SWEC-SQN-22/29RI. The licensee revised AI-31, Control of Measuring and Test Equipment, to require timely initiation of out-of-tolerance investigations for damaged or suspect M&TE. The current licensee practice is to tag as " defective" and separate from stock any piece of M&TE that is suspected to be nonconforming. The tool room attendant is required to notify the M&TE clerk innediatel _ _ _ _ _ _ _

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An out-of-tolerance investigation is initiated immediately if noncon-forming M&TE was used in the field. AI-31 was also revised to require calibration reports and associated memoranda to be forwarded directly to the tool room and M&TE supervisor upon receipt at the site. This eliminated previous delays experienced in distributio The inspector evaluated the following out-of-tolerance investigation l reports and found them to be acceptable:

612 on EQ2603 Micrometer Depth Gauge 605 on EQ9809 Glass Thermometer 607 on 902146 Digital Stopwatch 142 on EQ2390 Torque Wrench 150 on E83909 Torque Multiplier {

145 on 471613 Tachometer 1 159 on 900707 Pressure Gauge The inspector reviewed the tool room and M&TE sections monthly report for December 1986 and January 1987. The report showed most of the investigation reporta to be on time. The inspector reviewed those that were overdue and determined that safety evaluations had been prepare The licensee's method for controlling timeliness utilizes a computer report of outstanding report This report is checked daily and any report greater than 10 days old is highlighted. The toolroom section then sends a memorandum to the section responsible for the out-of-tolerance report informing them of the requirement to have a safety evaluation completed on all investigation reports older than 10 days. This section hand carries the item to Plant Operations Review Staff (PORS) in order to have the evaluation performe The inspector noted one flaw in the proces Following the memo-randum, M&TE personnel have no followup method to ensure that the safety evaluation report is completed within 14 days. The licensee stated that a followup method would be addressed in an upcoming revision to AI-31. The NRC Resident Inspectors will follow this item

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for closure following the issuance of an appropriate revision to AI-31. This item will be tracked as inspector followup item IFI 327, i 328/87-15-0 Inspector Followup Item 327, 328/86-48-04 is close (0 pen) Inspector Followup Items 327, 328/85-45-1 Masoneilan Valve Failures. Corrective measures for failures of limit switch actuator arms and stem nuts for Masoneilan valves was reviewed. The licensee's actions to date appear acceptable; however, this item will remain open pending review of the results of the licensee's trend analysis program to assure that the corrective actions were effectiv I -

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