IR 05000327/1993018
| ML20046B704 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 07/09/1993 |
| From: | Julian C, Whitener H, Wiseman G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20046B699 | List: |
| References | |
| 50-327-93-18, 50-328-93-18, NUDOCS 9308060092 | |
| Download: ML20046B704 (9) | |
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Dg UNITED STATES o
NUCLEAR REGULATORY COMMISslON
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'E o REGION 11
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101 M ARIETTA STREET, N.W.
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- ' 4" ATLANTA, GEORGI A 30323
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Report Nos.:
50-327/93-18 and 50-328/93-18
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Licensee: Tennessee Valley Authority 6N 38A Lookout place
1101 Market Street Chattanooga, TN 37402-2801
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Docket Nos.:
50-327 and 50-328 License Nos.: DPR-77 and DPR-19 Facility Name: Sequoyah Units 1 and 2
Inspection Conducted: May 24 - 28, 1993 and June 7 - 11, 1993
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Inspectors:
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' H.L. Whitener
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Date Signsd i
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h 1' Y D G.'R. Wiseman Date Signed Approved by:
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C. A. Julia G Acting Chief pate/ Signed Test Programs Section Engineering Branch
Division of Reactor Safety SUMMARY l
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Scope:
This routine announced inspection was con /
.eo. -ite in the area of Inservice Testing (IST) of plant pues ans nives.
During the performance of
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this inspection, the inspectors conoucted a.:.. a 3,
the fire protection system leakage problems and a review of management oversight and ownership of
the Section XI Pump and Valve Program.
I Results:
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'In the areas inspected, violations or deviations were not identified.
A weakness was identified in the lack of communications between onsite and corporate fire protection organizations concerning microbiological biofouling i
and corrosion caused leaks in fire protection piping.
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The.IST program was consistent with the Safety Evaluatiot. (SER),theintentof
Generic Letter (GL) 89-04, and Relief Requests.
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9308060092 930709 i
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The Pump and Valve Test program was procedure driven and implemented through a strong surveillance control program.
Technical Programs and Performance has assessed the technical programs status to identify Restart issues.
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-The development of a stand - alone comprehensive IST program document is l
considered a program strength.
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REPORT DETAILS
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1.
Persons Contacted Licensee Employees
- L. Alexander, Technical Programs And Performance
- J. Baumstark, Operations Manager
- R. Driscol, Site Quality Manager
- R. Fenech, Vice President, SQN
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- C. Fulwider, Site Engineering
- J. Hamilton, Technical Programs And Performance
- W. Justice, Technical Programs And Performance
- N. Lehberger, Technical Support
- K. Meade, Licensing Engineer l
- G. Pitzl, Corporate Engineer
- J. Proffitt, Licensing Engineer
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- R. Shell, Site Licensing Manager i
- R. Thompson, Compliance Licensing Manager j
- J. Ward, Manager, Engineering And Modifications Other Licensee employees contacted included engineers, technicians and Administrative personnel.
NRC Resident Inspectors
- W. Holland, Senior Resident Inspector
- S. Shaeffer, Resident Inspector
- Attended Exit Interview Acronyms and initialisms used throughout this report are listed in the last paragraph.
2.
Inservice Testing of Pumps and Valves (T12515/Il4)
Technical Specification Surveillance Requirement 4.0.5 and 10 CFR 50.55a(g) require that ASME Code Class 1, 2, and 3 pumps and valves be inservice tested in accordance with Section XI of the ASME Boiler and Pressure Vessel Code to assess operational readiness.
During this inspection, the inspectors reviewed the licensee's IST Program to determine whether regulatory requirements and licensee commitments were
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being met.
In accordance with 10 CFR 50.55a(g), the applicable code of record for Sequoyah Nuclear Station is the ASME B&PV Code,Section XI,
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1974 Edition, S75 Addenda for Unit I and 1977 Edition S78 Addenda for i
Unit 2.
Based on TVA's IST Program submittal, dated March 3,1982,-as revised in November 4, 1982, the NRC issued a Safety Evaluation Report
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(SER), dated April 5, 1985. On August 16, 1985 and June 6, 1986, TVA i
issued additional revisions to the IST program previously reviewed by the NRC. Other TVA submittals and relief requests were issued in 1987 i
and 1988. NRC provided SERs and/or approvals of relief requests in
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letters dated October 23, 1987, January 19, 1988, March 14, 1988, and September 15, 1988.
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Program Review The inspectors reviewed portions of the above documents in
conjunction with the licensee's program for Section XI Pump and i
Valve Testing and concluded, based on the sample review, that the
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program is consistent with the intent of Generic Letter 89-04 except where relief has been granted. -Two minor anomalies were identified which the licensee has agreed to resolve.
In one case the FSAR 6.8.2.9 states that any testing not corrrleted by the end of one cold shutdown will be performed during the next cold shut -
j down.
It is not intended that a plant be maintained in cold
shutdown to complete all cold shutdown tests. The work control group has controlled the test process by issuing a copy of the
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previous cold shutdown test to the field to identify the valves
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not tested in the previous cold shutdown.
The licensee has agreed to establish a program control for tracking the valves tested at cold shutdown. The second case involves a relief from IWV 3427(b)
trending requirements. The relief appears to have been granted on i
the basis that the licensee has established a very conservative reference leak rate limit and if exceeded a valve is repaired.
l FSAR 6.8.2.1 allows repair of valves which exceed the reference leak rate, but are within an administrative leak rate of 20% of 0.6La, to be deferred until a future outage. The licensee agreed to clarify the intent of the relief request.
Documents examined in full or in part during the program review included but was not limited to those listed below:
Final Safety Analysis Report, Section 6.8, Amendment 8, Pump
and Valve Inservice Testing Program
Site Standard Practice, SSP-8.6, Revision 0, dated 3/10/92, ASME Section XI Inservice Testing of Pumps and Valves.
q Site Standard, STD-8.6, Revision 0, dated 3/8/91, ASME
Section XI Inservice Testing of Pumps and Valves.
Nuclear Quality Assurance Plan, TVA-NQA-PLN 89-A, Revision
3, dated 1/18/93, Section_9.4, Test Control.
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Action Plan for Work Requests (WRs) C082958, Cl34165, C052701, Repair of through wall leaks in the Unit 1 fire protection system header in the auxiliary building.
Action Plan for (WRs) C051177, C079498, C013536, Repair of
through wall leaks in the Unit 2 fire protection system header in the auxiliary building.
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l Drawings 47W850-2, R6 and -10, R20, Flow Diagram Fire
Protection & Raw Service Water.
i Drawing 47W839-1,R19, Flow Diagram Diesel Starting Air
System
Drawing 47W803-2,R20, Flow Diagrams Auxiliary Feedwater Drawing 47W801-1, R24, Flow Diagrams Main & Reheat Steam
Safety Evaluation Report (SER) on Sequoyah Inservice Test
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Program for Pumps and Valves (IST), April 5,1985, Request For Relief From ASME Boiler and Pressure Vessel Code
Section XI (IST), October 23, 1987.
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Review of IST Program for Management Oversight and Ownership From investigation of past events at the Sequoyah Plant the licensee determined that in some cases contributing factors to the
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events included lack of ownership and centralized program direction; lack of clear assignment of responsibility; and, in some cases, lack of a well defined, program, i.e., fragmented programs. As a result, the Technical Programs and Performance Group (TPP) was organized. The TPP group contains three principal sections which are (1) Inspections and Materials, (2)Section XI
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and Special Programs, and (3) Performance Testing. The inspectors reviewed certain activities of the Section XI and Special Programs
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Section in relation to the Purrp and Valve Test program. This i
section was staffed with seven program engineers and was
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functional.
A mission statement has been issued by the manager of TPP which assumes ownership of the defined programs under one on-site manager and assumes responsibility for controlling, directing, and monitoring the programs including intra - departmental implementation of the programs. Additionally, the supervisor of
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the ASME Section XI and Special Programs Section issued a memorandum to the Technical Programs staff which specified management expectations for the Section. The memo highlighted
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program ownership and oversight; responsibility to direct and control program activity; responsibility to maintain current
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knowledge of regulatory requirements and industry issues; and, the
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responsibility to identify issues to enhance the quality of the
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Sequoyah programs.
The ASME Section XI And Special Programs Section became functional
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on April 26, 1993. Consequently, the Section has been active as
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an organization capable of impacting TVA programs for only a few months. The inspectors held discussions with TPP management and
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reviewed a number of documents to ascertain the emerging direction of group activities relative to the ASME Section XI Pump and Valve
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Test Program. While it is too early to evaluate the effectiveness of TPP as a program management group, the inspectors found that several positiva steps have been initiated by this group. These included but were not limited to the following:
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Re-calculation of code boundaries to obtain a conservative test and inspection configuration with a documented basis.
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Performance of Program Assessments by QA, Corporate ASME Section XI Specialists, and independent technical reviewers to identify current status of programs, procedures and implementation.
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Identification of Restart /Non-Restart issues based on program assessments.
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Development of a comprehensive program document to replace the current Pump and Valve Test Program in the FSAR.
Relative to the Pump and Valve Test Program the assessments showed that the program conformed to GL 89-04 except for approved reliefs.
The procedures were acceptable and testing was properly implemented. Additionally, the inspectors considered the development of a stand alone comprehensive IST program document as a program strength. Although still in the process of development, the licensee indicated that the document will describe the applicable ASME Codes, identify TVA applications, expand system code boundaries, provide comprehensive matrix of Pump and Valve Tests and relief requests, incorporate non-code systems important to safety into the program, and document the basis for including or excluding components in the program.
Documents or applicable portions reviewed in the evaluation of the fragmented program issue relative to Pump and Valve Tests included:
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Technical Programs And Performance Organization Chart / Staffing.
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Technical Programs And Performance mission Statement (Issued by Manager).
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Memo to Section XI And Special Programs Staff delineating Management Expectations, Assignments and Responsibilities.
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Generic Letter 89-04 Review of ASME Section XI, Pump and Valve Test Program, April 26, 1993.
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Assessment of ASME/ Regulatory Programs.
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Non-Code Safety Valve Restart Review.
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Re-evaluation of Technical Program Reviews.
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Re-evaluation of SQN ASME/ Regulatory Programs Assessment,
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Restart Issues, and Industry Consultant Comments.
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Calculations-ASME Section XI Inservice Code Class Boundaries.
i Based on this preliminary evaluation, the inspectors concluded I
that the TPP Group has actively assumed ownership and oversight of I
the Pump and Valve Test program, assessed program status, and
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initiated action to maintain and enhance the program.
A program
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strength was identified in regard to the development of a comprehensive program document which will define the design basis for the pumps and valves.
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Program Implementation (Testing)
The inspectors reviewed the licensee's Inservice Test Program, l
l implementing procedures and test results for portions of the
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Section XI Pump and Valve Test Program.
Performance was verified
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by review of procedures, test results, and/or the surveillance
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performance records. The surveillance performance records are maintained by the work control group who schedule and issue the
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i test procedures to the field and track the successfully completed
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I test performance for close out in the tracking system.
For selected pumps and valves the inspectors verified check valve partial flow, full flow and reverse flow testing was performed in j
accordance with Section XI, subsection IWV 3520 and approved
relief requests.
For power operated valves the inspectors I
verified that stroke time testing and position indicator
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I verification was performed as required by Section XI, subsection i
IWV 3400 (exercising) and IWV 3300 (valve position) and approved relief requests. Test data and trending of test results for motor i
and steam driven auxiliary feed water pumps were reviewed to l
verify test performance at the required frequency and conformance
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with acceptance criteria for test parameters and ranges in
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accordance with approved relief requests. Systems and components reviewed for conformances with certain aspects of Section XI,
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subsection IWV and IWP included:
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Main Steam Isolation Valve Partial Stroke Tests 1-4
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Steam Supply to Turbine Drive AFW Pump Stroke Test
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1-15
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1-16 1-17 1-18 1-51
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Auxiliary Feedwater System Power Operated Valves
3-171, 3-171A, 3-172, 3-173, 3-ll6A, 3-116B, 3-126A, 3-1268, 3-136A, 3-136B i
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Auxiliary Feedwater System Pumps Motor Driven AFW Pump 2B-B Turbine Driven AFW Pump 2A-S
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Diesel Air Starting System 82-220,82-221 Stroke Time 82-502-2A1, 82-529-2A2 backflow
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Fire Protection System Stroke Time
!26-241 26-242 26-240 26-243 The inspectors concluded that test frequency and results were satisfactory. The licensee has developed procedures to implement the pump and valve program.
Procedure performance has been satisfactorily I
controlled by the surveillance tracking system.
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Fire Protection System Concerns
The inspectors reviewed the computer list of maintenance and problem
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trending for the fire protection (system 26) valves and piping. Based on the review, the inspectors discovered that the licensee had identified a number of through wall leaks in the carbon steel fire protection piping located in the auxiliary building, turbine building and CCW pumping station. These leaks are the result of microbiological biofouling and corrosion within the raw water fire system. Similar problems in the fire protection system have been identified at the TVA Browns Ferry facility.
Discussions with engineering and fire protection operations personnel indicated that communications on this issue between Sequoyah site and the other TVA sites and corporate fire protection had been minimal. This was corsidered a weakness.
Some of the identified fire protection wkter leaks had been temporarily patched and others were still dripping. The inspectors considered most significant a piping leak located in the auxiliary building on elevation 690 in the Unit 2 penetration room on a fire header to the control stations and containment isolation valves to the Unit 2 reactor
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containment building. Should this leak have become severe during plant operation, isolation of the leak would have disabled the water supply to-
all required fire suppression systems for the Unit 2 reactor building.
l The licensee had scheduled in the outage plan (items #356 and #357 of I
the outage schedule).the repair / replacement of the leaking fire
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protection system piping identified in the WR Action Plans prior to plant startup. The fire protection compensatory measures for this work
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are extensive.
Scheduling delays in the delivery of special new
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components for backfeeding hose stations and flow control stations required by the fire protection compensatory actions have been critical in the implementation of the WRs.
In addition to the leak repairs, the licensee has initiated an inspection and evaluation program for
microbiological corrosion of the raw water fire system.
NRC review of the adequacy of this program is addressed in NRC Inspection Report 50-
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327/93-20 and 50-328/93-20.
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4.
Acronyms and Initialises ASME American Society of Mechanical Engineers B & PV Boiler and Pressure Vessel FSAR Final Safety Analysis Report GL Generic Letter IST Inservice Testing
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IWP Subsection of ASME Section XI for Pump Tests IWV Subsection of ASME Section XI for Valve Tests SER Safety Evaluation Report
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TPP Technical Programs and Performance
WR Work Requests
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