IR 05000327/1993030
| ML20056E748 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 08/12/1993 |
| From: | Blake J, Crowley B, Hunt M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20056E740 | List: |
| References | |
| 50-327-93-30, 50-328-93-30, CAL, NUDOCS 9308250135 | |
| Download: ML20056E748 (29) | |
Text
l o UMTED STATES
/ g arc %, NUCLEAR REGULATORY COMMISSION l ye ' 'a REGloN U i Q )e E 101 MARIETTA STREET, N.W., SUITE 2930 '
% ' p ATLANTA, GEORGIA 303234199
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Report Nos.: 50-327/93-30 and 50-328/93-30 Licensee: Tennessee Valley Authority 6N 38A 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: July 13 - 16 and 19 - 23, 1993 Inspectors: .A m % /c/ 3 B. R. Crowley / Date Signed [
/
. Hunt Date Signed
Approved by: s # & !97
/f.Blake, Chief Da'te Signed terials and Processes Section E gineering Branch Division of Reactor Safety SUMMARY Scope:
This routine, announced inspection was conducted on site in the areas of:
(1) status of corrective actions for the Confirmation of Action Letter (CAL)
dated March 4, 1993, relative to the Unit 2 Extraction Steam pipe break and the resulting overvoltage condition, (2) status of the new Technical Programs and Performance (TP&P) Department, and (3) review of corrective actions for previous inspection finding Results:
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In the areas inspected, no violations were identifie The licensee appeared to be progressing toward completion of corrective actions identified in the CA Repair of Unit 2 piping damaged by Flow Accelerated Corrosion (FAC) was complete and repair of Unit 1 piping was in process. The overall FAC program had been improved substantially. The new Technical Programs and Performance 9308250135 930813 PDR ADOCK 05000327 G PDR
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Department was in place with 29 of the 35 positions filled, including the department manager and 2 of the 3 key section supervisors. The Site Standard Practice (SSP) and 4 of the 5 implementing procedures for the improved FAC program were issue The overall SSP describing the TP&P organization and overall responsibilities was issued on July 22, 1993. New procedures and existing procedural changes necessary for changing responsible organization names for TP&P individual programs had been complete However, a number of procedures needed more detail relative to responsibilities for organizations other than TP& In addition, one procedure, SSP-8.54 for Snubber testing was weak in details.
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I REPORT DETAILS ! Persons Contacted l Licensee Employees ;
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l B. Anderson, Erosion / Corrosion Project Manager
- L. Bryant, Maintenance Manager !
- M. Cooper, TVA Restart Manager ~
N. Dietrich, Carrosion Programs Supervisor ,
- R. Driscoll, u te Quality Manager ;
- R. Fenech, Vice President, Sequoyah i T. Gizzard, MOV Program Engineer i
- J. Hamilton, Inspection and Material Supervisor, I. Heatherly, Nuclear Engineering, Principle Mechanical Engineer
- Justice, ASME Section XI and Special Programs Supervisor
- Kent, RadChem Manager,
- Keuter, Vice President Nuclear Readiness !
- Lundy, Technical Support Manager l
- Poage, Acting Audit and Assessment Manager l B. Poole, MOV Engineer, Nuclear Engineering i
- K. Powers, Plant Manager !
- K. Meade, Licensing Engineer
- R. Shell, Site Licensing Manager
- M. Skarzinski, Technical Programs and Performance Manager :
- R. Thompson, Compliance Licensing Manager l
- P. Trudel, Manager Design Engineering {
- G. Wade, ISI/NDE Supervisor -
- J. Ward, Manager - Engineering and Modiftcations l L. Wheeler, Materials and Procurement Manager i
! *C. Whittemore, Licensing Engineer j Other licensee employees contacted during this inspection included engineers, QA/QC personnel, craft personnel, security force membcrs, technicians, and administrative personne i
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NRC Employees
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- A. Gibson, Division Director, DRS
- Holland, Senior Resident Inspector >
- P. Kellogg, Section Chief, Projects Section 4A i
- S. Shaeffer, Resident Inspector
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- Attended exit interview !
Acronyms and initialisms used throughout this report are listed in the last paragrap j l
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2. Corrective Actions For Confirmation of Action Letter (CAL) Relative to Unit 2 Extraction Steam Pipe Break (92703) i See NRC Inspections Reports 50-327,328/93-12 and 50-327,328/93-24 for !
documentation of previous inspections in this are ;
On March 1,1993, a 10-inch extraction steam line feeding the No. B2 feedwater heater ruptured resulting in steam being introduced into the ;
main generator instrumentation cabinet causing a voltage excursion in the l generator output and a manual operator trip of the reactor. The NRC '
performed a special Augmented Inspection Team (AIT) inspection of the 3 event. The inspection activities and findings are documented in NRC .
Inspection Report 50-327,328/93-10. A CAL was issued on March 4, 199 l Most of the corrective actions specified in the CAL were in process and ,
were inspected during the AIT inspection. Additional inspections of !
corrective actions are documented in NRC Inspection Reports identified i abov !
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During the current inspection, the inspector further evaluated actions ;
identified in the CAL including the status of inspections and replacement ;
of piping subject to FAC and the Technical Programs organization and 4 procedures. The following summarizes the inspector's review of the i status of the actions identified in the CAL and TVA referenced letter: !
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Review your E/C program to identify any weaknesses, including a !
third party evaluation of the E/C progra j
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The review to determine weaknesses is identified in TVA Incident !
Investigation (II) Report II-S-93-009. In general, the weaknesses !
identified correspond to those identified in the NRC AIT Repor !
The II Report also indicates the corrective actions to be taken, such as the forming of the technical programs organization to establish ownership of the FAC program. The technical programs :
organization, TP&P Department, has been formed and an improved FAC
, program is documented in a Site Standard Practices (SSP) and l implementing procedures. See paragraph 3. below for further details l of the TP&P organization and the new FAC program.
l The third party review is being performed by the Electric Power Research Institute (EPRI). TVA Engineering provided EPRI a package for review consisting of the Erosion / Corrosion Restart Program Manual and the first completed Engineering Closure Package. EPRI l has provided TVA a number of comments relative to the FAC progra At the time of the current inspection, TVA was attempting to resolve ihe EPRI comments. Many of the comments were editorial in nature I rather than technical. Some of the technical comments received were l
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general in nature and needed clarification in order for TVA to be able to respond to the comments. Issue of the Erosion / Corrosion Restart Program Manual is awaiting resolution of the EPRI comment l
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In addition to review of the Technical Programs organization and i procedures, the inspector reviewed the completed Engineering Closure ;
Packages for the following Unit 2 FAC affected piping: !
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Item 10 - 3", 4", and 8" Heater Drain piping
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Item 1 - 3", 6", 10", 14" and 20" #2 Extraction Steam piping i i
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Item 24 - 1-1/2", 2" and 4" High Pressure Reheater piping l
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Item 17 - 1-1/2", 2" and 4" Low Pressure Reheater piping :
The packages were found to contain detailed information relative to >
inspections that were performed on the system, the inspection results, the acceptance criteria, and a summary of. repair I This area will be reviewed further during future inspection i
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Conduct field measurements of piping to assess the state of piping ;
subject to E/C effect j r
Field measurements are essentially complete for Unit 2, but are !
still in progress on Unit 1. As noted in NRC AIT inspection Report t 50-327,328/93-10, in order to determine the extent of wall thinning 1 due to FAC, TVA developed a screening, ultrasonic (UT) thickness measurement program. Details and implementation of the program were inspected and are documented in the AIT report. The inspectors ;
reviewed the status of these inspections since the completion of the
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AIT inspection. The following is a summary of the inspections and the results through July 21, 1993:
INSPECTION POINTS INSPECTIONS INSPECTION POINTS !
PROJECTED COMPLETED REJECTED Small Bore I
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Unit 1 667 666 69 l
Unit 2 855 855 120
Laroe Bore Unit 1 398 357 69 l l
Unit 2 437 437 76 The " INSPECTION POINTS REJECTED" column is the number of inspection !
, areas that require repair or replacement because of being below i l minimum or close to minimum wall. The large majority of )
l significantly thinned piping is in the steam extraction systems.
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for piping replacements, Stainless Steel materials are being used l i
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i for large bore piping and Chromium - Molybdenum (CrMo) steel for small bore piping. For Unit 2, the screening thickness measurements and pipe replacements were complet In addition to the screening inspections, grid locations were being !
inspected for input into the CHECMATE program. The following is a-summary of these inspections current to July 21, 1993: !
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Unit 2 - 421 inspection grid locations identified, 421 inspections complete, 11 areas rejected
Unit 1 - 328 inspection grid locations identified, 324 inspections complete, 14 areas rejected
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Repair or replacement of all such piping and other hardware adversely impacted by the rupture or that were identified as needing ,
repair during the technical evaluations will be complete '
Pipe replacements are complete for Unit 2,- but are still in progress for Unit 1. Based on discussions with Modifications personnel, the following is a summary of the Unit 1 piping l replacement activity and the field work as of July 23, 1993: l l
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Approximately 300 feet of large bore Extraction Steam piping is being replace i
Approximately 1400 feet of small bore piping, primarily in i Moisture Separator Reheater (MSR) Operating and Startup Vents l is being replace *
All or a portion of piping and associated fittings for approximately 54 Target Tee assemblies is being replace *
Weld build-up and repair to inside of turbine cross-over/ cross-under piping is being accomplishe The following additional repair / replacements are planned:
Repair of welds at 8"X4" reducers downstream of valves 1-FCV-3-070 and 1-FCV-3-084 (Inspection Items 17K and 17L).
Replacement of approximately 2 feet of 20" Condensate piping at grid location 102FT013.
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Replacement of 4"X3" reducer adjacent to valve 1-FCV-6-147A i (Inspection Item 23A).
Replacement of Extraction Drain Piping to Valve 1-FCV-5-98 (Inspection Items 47F and 47H).
Replacement of Operating Vent Piping from #2 Feedwater Heaters of Condenser IC (Inspection Items 69A through 69Q).
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Replacement of Main feed Pump Turbine 1A Drain Piping downstream of Valve 1-FCV-46-14E (Inspection Items 102A through 102D).
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Replacement of Main Feed Pump Turbine IB Drain Piping downstream of Valve 1-FCV-46-41E (Inspection Item 1108).
Although piping replacements and repairs are not complete, it appears that a program is in place to ensure that replacements and repairs are completed. No further inspections are needed in this are The TVA letter referenced in the CAL indicated that insight gained from evaluation of the weaknesses in the FAC program would be used to evaluate the effectiveness of other programs that may directly affect the safe operation of the units. Two action items related to this issue are identified in TVA II Report II-S-93-00 Action item 7 covers performance of an independent review of other site programs to determine if weaknesses similar to those noted in the FAC program exist. Eight technical programs were
- chosen for this review. The review has been completed and a report, SQN - Technical Programs Review, dated March 31, 1993, l
issued. See paragraph 3. below for further inspection of this item.)
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Action item 10 of the 11 report covers establishment of an l organization for major programs that will ensure program focus '
is maintained and ownership established. A Technical Programs and Performance Organization has been formed. See paragraph below for further inspection of this are In the areas inspected, no violations were identified. The licensee appeared to be progressing toward completion of corrective actions identified in the CAL. Repair of Unit 2 piping damaged by Flow Accelerated Corrosion (FAC) was complete and repair of Unit 1 piping was in proces . Technical Programs Evaluation As noted in paragraph 2. above, TVA's corrective actions documented in II Report II-S-93-009 include establishment of a Technical Programs ;
organization to take site ownership of the various site technical !
programs. The organization has been established and staffed. TVA's ;
corrective actions also included performance of an independent review of l other site programs to determine if weaknesses similar to those noted in i the FAC program existed. This review has been completed for selected technical programs and a report, SQN - Technical Programs Review, dated March 31, 1993, issued. Also, all TVA Department Managers are assessing their site programs to determine readiness for restart and needs for improvement. During the current inspection, the inspector evaluated the status of selected Technical Programs at Sequoyah to assess their !
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adequacy for restart of plant operations. This evaluation included: (1)
review of NRC Inspections Reports for inspections performed for technical programs since the current shutdown, (2) review of the TP&P organization and procedures for selected programs, and (3) review of a sample of readiness for restart evaluations for departments other than TP& Previous NRC Inspections Prior to this inspection, a number of. NRC inspections were performed in the area of Technical Programs. The inspectors assessed these reports to determine if inspection findings have been adequately I addressed for restart of Unit 2. The following summarizes the l inspection effort and conclusions:
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Report Number 50-327,328/93-04 '
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This inspection covered evaluation of the FAC program. Major weaknesses were identified relative to inadequate program scope, failure to use plant history to supplement program, poor i expansion examinations based on findings, no second party ;
I review of data, fragmentad responsibilities, and minimal ASME piping in progra ,
After rupture of a Unit 2 10" Extraction Steam pipe, TVA l initiated a major effort to inspect piping susceptible to FAC, l repair / replace piping found degraded, and improve their FAC
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program. Inspection of these efforts are documented in NRC '
Inspection Reports 50-327,328/93-10,50-327,328/93-12,50-327,328/93-24, and the current repor ,
Based on these inspections, it appears that necessary actions have been taken (Unit 2) and are being taken (Unit 1) to identify affected piping and repair / replace as necessary. A new FAC program has been developed, including the latest EPRI CHECMATE modeling and inspection techniques. Responsibility for the long term FAC program is under the new Technical Programs Organization (see paragraph 3.b. below). A document (Erosion / Corrosion Program Restart Manual) is being issued to transition from the current restart effort into the long term progra Based on the above evaluation, issues raised by NRC Inspection Report 50-327,328/93-04 have been satisfactorily resolved for restar Inspection Report 50-327,328/93-10 After the Unit 2 extraction steam rupture, the NRC initiated an AIT inspection (documented in NRC Inspection Report 50-327,328/93-10). This inspection provided further evidence of the findings identified in NRC Inspection Report 50-327,328/93-04 and concluded that insufficient maintenance and surveillance
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of balance of plant (B0P) piping had resulted in significant degradation of the piping. The report identified the root l cause of the insufficient maintenance and surveillance as '
failure of management to clearly assign responsibilities and provide appropriate oversight and direction for monitoring and l maintaining B0P pipin j Prior to the pipe rupture, TVA management had recognized the j fragmented responsibilities and lack of ownership of many i technical programs. As a result of these recognized weaknesses I and weaknesses identified in the FAC program and other l technical programs as a result of the Unit 2 Extraction Steam l pipe rupture, management has formed a new Technical Programs j organization to take ownership and responsibility for technical i programs. In addition, as noted above, degraded piping has l been (Unit 2) or is being (Unit- 1) identified and .j replaced / repaired and a new FAC program is in plac Inspections of the piping examinations and repairs / replacements and the new Technical Programs organization are humented in i paragraphs 2. above and NRC Inspection Reports 50-327,328/93-12 ;
and 50-327,328/93-2 Based on the above evaluation, issues raised by NRC Inspection Report 50-327,328/93-10 have been satisfactorily resolved for restart.
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Inspection Report 50-327,328/93-12 i This report documented detailed inspections of the inservice inspection (ISI) program and status of corrective actions for the CAL dated March 4, relative to the Unit 2 Extracting Steam pipe break. This inspection resulted in the following findings:
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Relative to ISI, although one violation was identified, the overall program appeared to be working well. All responsibilities were defined, although somewhat fragmented and spread over several organizations.
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Relative to the CAL action items, including piping inspections and repairs / replacements and development of an improved FAC program, CAL items were being complete Weaknesses were identified in the ASME Section XI Repair / Replacement program. It appeared the weaknesses had been identified by a contractor as part of the technical programs assessment, but had not been acted upon. Corrective actions for this item were taken (see NRC Inspection Report 327,328/93-24).
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An Unresolved Item (URI) was identified relative to an i inadequate ASME Section XI Repair / Replacement suitability ,
evaluation of replacement feedwater piping component j This is addressed further under the discussion below-for i NRC Inspection Report 327,328/93-2 !
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There are no issues identified in this report that affect restar I
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Inspection Report 50-327,328/93-14 i This report documented inspections in the areas of Equipment Qualification (EQ) and Drawing Control. The inspection i resulted in the following findings:
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Responsibilities of the EQ program appeared defined and understood and the program appeared to be functioning )
adequate. The EQ program was being incorporated into the i new TP&P organization. One weakness relative to a backlog l of EQ information developing in Engineering was '
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identified. A violation was identified for another ;
weakness relative to performance of recommended equipment ;
maintenance. These weaknesses are not considered to l affect restar i
The drawing control responsibilities appeared adequately
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I defined and understood. The program was found to assure '
that only approved drawings and drawing change documents were issued for us However,- two violations were ;
identifie l The first violation (327,328/93-I4-02) identified errors on approved and issued Category 2 drawings. TVA II Report ;
II-S-93-037 was issued to document investigation and corrective actions for this violation. During the current inspection period, the NRC and TVA identified additional errors on an Instrument Control Category I drawing. As a result, II-S-93-050 was initiated to investigate this violation. TVA indicated that the findings of Report
, II-S-93-037 will be considered in the current II. Drawing
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control will require further review after completion of TVA's II and prior to restar The second violation (327,328/93-14-01) involved untimely updating Category 2 and 3 drawings. This violation is not considered to affect restar Drawing control needs further inspection prior to restar Inspection Report 50-327,328/93-15
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This report documented inspection of ISI activities and resulted in the following findings:
Relative to inspection of the reactor vessel, the contractor technicians were experienced, their computer system was user friendly, and their technology for under-clad cracking was very-good. TVA management and Level III examiners maintained close surveillance of the inspection activitie =
Relative to inspection of feedwater pipe cracking at the steam generator nozzles, the examiner's use of the )
enhanced detection and sizing techniques was excellen :
TVA's management was very proactive in every area examined by the inspecto I No restart issues were identified in this repor Inspection Report 50-327,328/93-18 i
This report documented inspections of the ASME Section XI Inservice Testing of Pumps and Valves and the Fire Protection l
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Programs. The inspection resulted in the following findings: '
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The TP&P group has actively assumed ownership and ,
oversight of the Pump and Valve Program, assessed program ,
status, and initiated action to maintain and enhance the !
program. A program strength was identified in regard to the development of a comprehensive program document which will define the design basis for pumps and valve No issues were identified that affect restar *
A weakness was identified in the lack of communications between onsite and corporate fire protection organizations
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concerning microbiological fouling and corrosion caused leaks in fire protection piping. This issue needs further inspection prior to restart.
! Further inspection of the Fire Protection Program is needed prior to restar Inspection Report 50-327,328/93-20 l l
This report documents inspection of the Raw Water Corrosion Programs including fire protection corrosion. The inspection resulted in the following findings:
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Two weaknesses were identified. One identified the failure of the licensee to have Operations personnel review the inspection population to ensure that essential l
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and/or non-isolable piping and components would be bounded by the sample selected. The other pertained to lack of ERCW piping and components inside the containment building in the selected sample. These weaknesses were corrected by the license At the time of the inspection, the licensee was radiographing ERCW welds and finding extensive MIC in several ERCW stainless steel welds. The inspector noted that this problem could potentially affect restart of Unit The TVA Raw Water Task Force Report dated July 19, 1993, after the 93-20 inspection, documents evaluation of the ERCW weld Fifty-five stainless steel welds were inspected. TVA concluded that this sample size resulted in a 95/95 confidence level that the remaining welds in the population will not contain MIC defects greater in length than that of the sampl There are no restart issues resulting from this repor Inspection Report 50-327,328/93-24 This report documented inspections in the area of status of CAL items, status of new TP&P organization, and corrective actions for previous inspection findings. The inspection resulted in the following findings:
The URI relative to an inadequate ASME Section XI suitability evaluation cracked feedwater piping component replacements in 1992, was upgraded to a violation. The replacement camponents were found to have cracked again sicxe the 1992 replacement The suitability evaluation has now been performed and is documented in TVA II Report II-S-93-027. During the
, current inspection, the inspectors reviewed the II report, which concludes that the installed components in question are acceptable for another cycle. The crack growth is dependant upon the number of cycles and the hours of operation of the Auxiliary Feedwater (AFW) system. Review of the II and discussions with responsible TVA personnel revealed that TVA has determined the baseline number of cycles and the hours of operation for both units. A l computerized program was being developed to track the l cycles and hours of operation of the AFW system and l calculate the crack growth to trigger the need for additional NDE inspections. At the time of the current l inspection, the software had been developed and was i undergoing revisions.
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Based on the above, this is not considered to be a restart l item, j
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Relative to status of the CAL items, all but two items had been completed to the point of not needing additional inspections. These two were (1) completion of development of the improved FAC program with a third part review and (2) establishment of the TP&P organization to take i ownership of major technical programs. The TP&P l organization is now in place (see paragraph 3.b. below for !
l details of reviews of programs assigned to TP&P). All '
- issues relative to the FAC restart program and a third party review have not been resolve This item will need further review prior to restar b. Technical Programs and Performance Organization and Procedures ;
The inspectors evaluated the status of implementation of the new l TP&P organization, including necessary technical procedures for the I organization to perform its functions. The following summarizes i this inspection effort: i
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Organization As noted above, the Technical Programs and Performance (TP&P) '
Department has been organized. The inspector interviewed the TP&P Manager and reviewed the overall organizational structur The department reports to the Engineering and Modifications ,
Manager and is divided into 3 sections as follows: (1) !
Inspections and Materials with responsibility for EQ, ISI/NDE, !
and Corrosion programs, (2)Section XI Special Programs with responsibility for the program aspects of Pumps and Valves, Pressure Testing, Snubbers, R&R, Motor Operated Valves (MOVs)
and Check Valves (CVs), and Appendix J, and (3) Performance Testing with responsibility for the performance testing in the areas of Predictive Monitoring, CVs, Appendix J, Pumps, and HVAC. Twenty-nine (29) of the planned 35 positions have been filled. Management is in the process of filling the other positions. Many of the positions are filled with individuals who previously performed the same tasks under another organizatio SSP-8.55, Revision 0, Conduct of Technical Programs and Performance was issued on July 22, 1993 and details the TP&P organization and responsibilitie Program Reviews TP&P personnel had completed an assessment of their assigned programs. These assessments included evaluation of ownership l
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and responsibilities, program health,_and readiness for .
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restar The ownership and health documents evaluated the past history of the individual programs relative % the results.of i self assessments, audits, NRC findings, etc. The inspectors
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reviewed the programs as detailed below. All of the programs .
listed were reviewed relative to ownership and responsibilities. _ In addition, some of the programs were ;
reviewed in more detail, as indicated ~
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ASME Pressure Test Program f
In addition to the Ownership and Health documents and the i
. restart evaluation, the inspectors reviewed SSP-8.5, l Revision 2, ASME Section XI System Pressure Test progra j Relative to the Ownership and Health document, TVA !
identified 4 assessments / audits that had been performed by ;
TVA/ Contractors since March of 1993. In addition, II ;
I Report II-S-92-098, rela. sve to missed ASME Section XI l l
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tests, was completed in January,1993 (See Violation ;
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327,328/92-36-04 and Licensee Event Report (LER) 327/92- i 026 below). The assessments / audits identified concerns relative to (1) documentation of ASME code class !
boundaries, and (2) performance of class 2 inservice l pressure tests on systems required to operate during i normal plant operation. Necessary corrective actions were
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l identified for these concerns. Based on the ;
assessment / audit findings, eight non-restart items program ,
improvements were identified. No restart items were '
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FINDINGS Relative to SSP-8.5, the inspectors identified the need-for procedural enhancements relative to:
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XI boundaries are obtained fro The body of the SSP needs more detail relative to the responsibilities of organizations other than TP& *
Flow Accelerated Corrosion Program In addition to the Ownership and Health document, the inspector reviewed the following SSP and implementing procedures:
SSP-9.54, Revision 0, Flow-Accelerated Corrosion Program 0-TI-DXX-000-001.0, Revision 0, CHECMATE Modeling, Analysis and Use l
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0-TI-DXX-000-002.0, Revision 0, Non-CHECMATE System Analysis and Tracking l l
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0-TI-DXX-000-003.0, Revision 0, Inspection Point Selection '
and Tracking
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0-TI-DXX-000-004.0, Revision 0, Inspection Data Handling and Analysis i The inspectors reviewed these documents in detail to l
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determine if an adequate inspection program, including j ownership and responsibilities, was define l l
Relative to Ownership and Health, TVA noted the program i weaknesses identified by the NRC in Inspection Reports l 50-327,328/93-04 and 93-10 and TVA II Reports II-S-93-003 j and II-S-93 009. In addition, a number of recommendations ;
by EPRI in July 1992 and March 1993 were identifie Also, the Corporate Corrosion Control Assessment and the Contractor Evaluation of the FAC Restart Program identified a number of recommendations. Based on these l findings and recommendations, a list of restart and non- i restart items were identifie I FINDINGS I
Relative to procedures, paragraph 3.1.8 of SSP-9.54 and paragraph 6.3.2 of TI 0-TI-DXX-000-003.0 need more details about responsibilities of and interface with the Inspection Services Organization (1S0). Paragraph 3.3.1 l of SSP-9.54 needs clarification relative to the meaning of l
"above 200 F". I Relative to the Ownership and Health of the program, the inspectors noted:
EPRI (provided third party review) made many comments l on the Erosion / Corrosion Restart Program Manua Many of the comments are editorial in natur ,
However, some comments question technical aspects of l the program and require resolution. At the i conclusion of the inspection, TVA was working to resolve these question A number of restart items identified by TP&P did not appear on the Site Restart Evaluation List, which is the list of issues reviewed by the Management Restart Review Committee (MRRC) and determined to require '
completion prior to restart of Unit TP&P personnel indicated that the items without restart item numbers were sub-parts of other items included on the Site Restart Evaluation List. However, at the i
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conclusion of the inspection, it was not clear which restart item (s) the questionable items were a part l of. It appeared that some items identified in the TP&P Department review might not be captured by the
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Site Restart Evaluation Lis The inspectors also noted that the Program Readiness Assessment Form was signed off by the Department l Manager as " Program is adequate for restart, but
! requires long-term improvements" with an identified 1 Restart Punch List. In addition, the Program Readiness Assessment Forms for other TP&P programs were signed off as " Program is ready for restart" even though there were outstanding restart item The licensee provided documentation of instructions, issued on July 18, 1993, by the Site Vice President, for Department Managers to remove their signatures from all Program Readiness Assessment Forms until all restart items for that program are complete On July 27, 1993, the licensee contacted the inspector by phone with the following explanation for the above questions relative to documentation of restart items: (1) all restart items questioned by the inspector because of not being on the restart list were being worked by Engineering as restart items and tracked in the Tracking of Open Items (TROI) data base. The items were a sub-part of Site Restart Evaluation List Item Number 450.013. (2) The department program reviews have Site Restart Item Numbers assigned and will not be signed off until the program reviews are completed. Since the Department Managers cannot sign off the program reviews as being ready for restart until all restart items identified by the departments are completed, restart items should aat be lost. Therefore, individual restart items identified by the departments that are within the department and are not a big ticket item or items that affect other departments, are not reviewed by MRRC and given Site Restart Item number *
Inservice Inspection / Augmented Inspection Program In addition to the Ownership and Health Document, the inspectors reviewed the following procedures:
SSP-6.10, Revision 0, ASME Section XI and Augmented Nondestructive Examinations SI-114.1, Revision 22, ASME Section XI Inservice Inspection Program - Unit 1
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Si-114.2, ASME Section XI Inservice Inspection Program - l Unit 2 ;
The inspectors reviewed these documents in detail to !
determine if an adequate inspection program, including !
ownership and responsibilities, was define ]
Findinos i
Relative to the Ownership and Health, TVA assessed this l program in March, 1993. Concerns were identified relative {
to code boundaries and scope of additional inspections ~
when rejectable conditions are found. The' code boundary 4 concern is being addressed by corrective action document !
SQFIR930026. The question about scope of inspection expansion is.being addressed with a Code Inquiry. The l Ownership and Health document identified no restart items l l
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and found the program ready for restar l
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, Relative to SSP-6.10 and implementing procedures, the ;
- inspectors identified the following: i i
The SSP and sis needed clarification and enhancement i relative to responsibilities of and relationship with the l ISO organizatio :
i Some QMP procedures need revision and so.ne may need !
replacement with new procedures since the ISI organization l is no longer part of the QA organization. TVA had ;
identified this need and had plans to revise these !
procedure I i
Raw Water Corrosion
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The licensee performed a comprehensive assessment'of the l Raw Water Corrosion Programs in March 1993. A lengthy report was issued on July 19, 1993. A significant number '
of restart and non-restart items were identified. TVA l concluded that the program is suitable for restart, after i completion of the restart items, but will require a number l of long term enhancement t
The inspectors reviewed SSP-956, Revision 0, Raw Water Fouling and Corrosion Control Progra j Findinas i
The controlling SSP defines a comprehensive program and Ownership and responsibilities are well define !
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- Protective Coating Program 3 l
The TVA Ownership and Health document identified 2 QA - l audits performed in 1991. Based on review of these. audits 1 and review of the program, a number of long-term non-restart items were identified. One' restart item was identified. TVA concluded that after completion of the restart item, the program will be satisfactory for l restar In addition to review of the Ownership and Health document, the inspectors reviewed the following controlling procedures: 1
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SSP-9.50, Revision 1, Protective Coatings Program for Coating Service Level I and II and Corrosive Environment Applications M&AI-5.3, Revision 0, Application and Repair of Protective-Coatings i
l MA&I -5.8, Revision 0, Qualification of Coating )
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Applicators The inspectors reviewed these documents in detail t determine if an adequate inspection program, including i ownership and responsibilities, was define l Findinas The inspectors identified the following relative to the above procedures:
Paragraph 3.0 of MA&I-5.3 appears very limited in the responsibilities listed. It is not clear why only a few
, responsibilities were identified. The paragraph needs to i
be expanded and clarified. The procedure is confusing
- regarding Verification / Monitoring responsibilities.
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Borated Water Corrosion Program l
l In addition to the Ownership and Health document, the inspectors reviewed the following SSP and implementing procedures:
SSP-9.55, Revision 0, Borated Water Corrosion Control Program
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0-TI-DXX-000-006.0, Revision 0, Evaluation of Borated l Water Leaks l
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The inspector reviewed these documents in detail to i determine if an adequate inspection program, including i ownership and responsibilities, was define ;
Relative to Ownership and Health, TVA has pe.-forned 2 h evaluations of the program since March 1993. One restart !
- item, issue of the above SSP, was identified. A number of r non-restart program improvement items were identified.
l Findings The SSP and implementing procedures provided a detailed program and ownership and responsibilities were well i define ;
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Motor Operated Valve (MOV) Program i l In addition to the Ownership and Health document, th l l inspectors reviewed the following controlling procedure- '
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l SSP-6.61, Revision 0, Motor Operated Valve Program / Generic Letter 89-10 l
The Ownership and Health document identified a licensee l l audit of the various valve programs conducted in March !
i 1993, which identified an over-torquing condition for '
, eight MOVs in the feedwater system (four in each unit). A t l problem evaluation report (PER) SQPER930079 was issued to recommend corrective actions. The audit also identified 3 issues related to the MOV program which were considered program improvements and a concern identified by a ,
consultant. These issues were not considered restart item The GL 89-10 program scope was reviewed during the audit to determine that there were no operability concerns basea on the completed testing. The results of differential
- pressure (dp) testing during the Unit 2, cycle 5 outage l were reviewed to determine whether adequate margin between l the thrust required to operate the valves and valve / actuator capability was available to insure continued operation when considering the long term effects such as stem lubrication and agin The licensee's GL 89-10 program had been evaluated during a NRC inspection (See NRC Report Nos. 50-327/328/91-18)
which identified two concerns. These were related to the fact that TVA did not appear able to complete the MOV testing in the time frame of the GL 89-10; and TVA's proposed grouping methodology. Neither of these concerns were related to the restart effor i
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The inspectors reviewed the documentation which identified #
the corrective actions required for 4 of the 8 MOVs which had- been identified as being over torqued. These valves ;
were identified as the ERCW to Motor Driven AFWP Isolation l
Valves. The four MOVs in Unit 2 were identified as !
restart item 207. The following MOVs were disassembled and !
visually inspected by the Work Requests (WR) indicated:
-l l 2 MV0P-003-0116A-A WR C129768 l 1 2 MV0P-003-0116B-A WR C129769 ;
l 2 MV0P-003-0126A-B WR C129770 l l 2 MV0P-003-0126B-B WR C129771- !
The disassembly and visual inspections were performed i under the requirements of SNP Maintenance Instruction ,
0-MI-EMV-317-112.0, Corrective Maintenance Procedure for ,
Limitorque Model SB-00,SMB-00, and SMB-000 Actuator ,
Maintenance Instruction. New torque switches were l installed in each of the ~ actuators. The cause of the l over-torquing was determined to be the result of the l removal of the torque switch limiter plates from the torque switches.
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These valves were then statically tested using MOVATS l diagnostic equipment as directed by SNP Maintenance l Instruction 0-MI-EMV-317-144.0, Procedure for Testing
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Motor Operated Valves Using M0 VATS Signature Analysis .
System. This procedure requires compensation for the overall setup and measuring equipment accuracy which incorporates the torque switch repeatability, and measuring equipment and calibration equipment accuracie The inspectors only review the static test results. To perform a dp test on these valves would result in introducing ERCW water into the feedwater system. The GL 89-10 calculations determined that the thrust limit was l 6000 lbs and a torque rating of 90 ft/lbs. Listed below are the results of the static tests for the four valves i liste VALVE N MEASURED LOWER THRUST TOTAL TOTAL TO LIMIT OTST THRUST 2-MV0P-003-t 116A-A 69 1703 2535 3504 l 116B-A 73 1912 2590 3767 126A-B 64 1703 1991 3213 126B-B 68 1912 2208 3380 The test results listed above indicate that the over torquing of these valves has now been corrected for the Unit 2 valves and should no longer be considered a restart item.
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The four non restart items were related to the need to review the thrust margins for MOVs in the SI system; revising the M0V dp test procedure to put additional emphasis on margin evaluation; expedite the dp testing scope for Cycle 7 outages, and addressing the need for dp ;
tests of 1/4 turn valves; and the cold closing and hot opening of valves. TVA has scheduled the closure of these items by December 31, 1993. The B0P MOVs will be included in the Technical Programs and Performance (TP&F) MOV program which is beyond the GL 89-10 program. The program will be owned by the TP&P MOV enginee During the examination of the licensee's actions in response to the audit and NRC inspection, various aspects of the M0V program were discussed and SSP-6.61 was reviewed. The SSP defines the organization of the personnel assigned to the Technical Program & Performance such that the functional levels are clearly defined. The duties of the MOV engineer, M0V coordinator, and the Site Training Manager are delineated for the site personne The Corporate Project Manager is assigned the task of coordinating activities that relate to all TVA plants to ensure that experienced from all other TVA plant and the industry are considered and implemented into the SNP M0V j progra Corporate engineering is responsible for the l design portions of the MOV program relating to GL 89-1 This group has the technical oversight responsibility for l the adequacy of the work performed under the design l standards and specification SSP-6.61 also sets the requirements for the technical 1 expertise of the various personnel involved in the MOV program by defining the training requirements for the engineers, maintenance personnel, and operations personnel i to insure that there is an understanding of the various component functions and actuators capabilities in order to l identify the systems conditions that could contribute to l degraded valve / actuator situation ,
This SSP defines the requirements for testing, by establishing the conditions that are necessary prior to testing, during testing and post maintenance testing. The l preventive maintenance activities and trending of l component failures and diagnostic test data are outlined
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in this SS During review of the restart item 207, the inspectors observed that the various personnel assigned to the tasks of MOV engineer, MOV coordinator, and MOV engineer were
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knowledgeable and exhibited ownership responsibilities for their designated areas.
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Findinas i
Based on the above review, the inspectors concluded that: !
If the MOV program is maintained in accordance with the guidelines established by SSP-6.61, the MOV program should meet the design basis as outlined in GL 98-1 The M0V program is acceptable and there are no conditions related to MOVs that should prevent restart of Unit * SOER 86-03 Check Valve Program In addition to review of the Ownership and Health document, the inspectors reviewed the following controlling procedure:
SSP-8.53, Revision 0, Check Valve Program )
l Relative to the Ownership and Health document, the j inspectors reviewed the licensee's actions taken as a result of three audits performed on the SOER Check Valve Program. . All of these audits were performed in the April a to March 1993, time frame. None of the findings for these i audits were determined to be restart item l
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The first audit was performed by Site QA organization and I identified weaknesses in the performance of monitoring and I trending, definition of management expectations, and the !
program scope. The corrective actions were incorporated i into SSP-8,5 l
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The second audit was a Technical Programs Review performed l by a corporate team. This audit covered valves in l general, including check valves. This audit recommended i the corrective actions needed to answer the QA audit and recommended that the program include certain B0P check valves that protect the main turbine from induction and overspeed.
l The third audit addressed specific industry problems and was instigated based on INP0 RSEN-93-094 involving failures of the diesel generator fuel supply check valve l The audit determined that these valves were incorporated into the Sequoyah ASME Section XI Valve Program and are tested quarterl SSP-8.53 defines requirements for the Sequoyah Check Valve Program.. It directs and defines the personnel positions responsibilities, establishes the basis for the database, defines the records that will be maintained, and outlines the acceptance criteria for check valve inspections.
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Findings The inspectors determined that the SSP-8.53 details the ownership responsibilities of the various personnel assigned to the check valve program. The list of systems addressed in the SSP appears to be complete. It appears that if the check valve program is administered in accordance with SSP-8.53, the check valve program should meet the intent of current guidelines and commitment Snubber Program l
In addition to the Ownership and Health document, the
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inspectors reviewed the following controlling procedure to determine if ownership and responsibilities were detailed:
SSP-8.54, Revision 0, Snubber Program Relative to the Ownership and Health document, TVA identified 2 audits. One concern was identified and documented as restart items 370, 371, 373, and 374 relative to the potential for missing surveillance inspections on safety related snubbers that may not have been identified via design outpu Findinos Relative to SSP-8.54, the inspectors found that, although overall responsibilities and ownership are defined, there is little detail on how the program works. More detail is needed to define how the program operate ASME Section XI Pump and Valve Test Program
, The inspectors reviewed SSP-8.6, Revision 1, Asme Section
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XI Inservice Testing of Pumps and Valves to determine if Ownership and responsibilities were define '
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Ownership and TP&P responsibilities were define However, there was little detail on responsibilities of ;
organizations other than TP& Safety Related Cooler and Heat Exchanger Program The inspectors reviewed the Ownership and Health documen TVA recognized that no one individual or group was responsible to follow cooler and heat exchanger problems and identify improvements and solutions to problem Therefore, the program was assigned to TP&P to establish a program and take ownership of the program. The program l
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and has a long-term action item to establish a progra :
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An evaluation of Coolers was made in May 1993, resulting in 7 recommendations for improvement in performance of .i safety-related coolers. The 7 recommendations will be i evaluated and entered into TROI for tracking completio ;
An assessment of safety-related heat exchangers is :
l scheduled to begin July 29, 199 .
I Findings
)l No long-term program has yet been established. TP&P has :
taken ownership and plans to develop a progra l l
Non-Code Safety Valve Program .;
i The inspectors reviewed the Ownership and Health documenc.
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The document identified 2 assessments that had been .
l completed. The assessments found that no program existed ;
l for periodic setpoint and leakage testing of safety valves !
I in B0P systems and other safety valves outside ASME.
i Section XI valves. Many of these valves have never been !
l tested. A long-term testing program is being develope i This is not considered to be a restart issu ,
Findinas ;
Although the long-term program is not yet in place, .TP&P I has taken ownership of this issue and is working to '
develop the program.
Containment Leak Rate Testing Program i In addition to the Ownership and Health document, the
! inspectors reviewed the following controlling procedure to determine if ownership and responsibilities were detailed:
SSP-8.7, Revision 1, Containment Leak Rate Programs Relative to the Ownership and Health document, TVA identified 2 Assessments performed since March 1993, one by TVA and another by a contractor. Eight recommendations for program improvement were identified. No restart items were identifie Findinas Ownership and TP&P responsibilities were define However, there was little detail on responsibilities of i organizations other than TP& In addition, the SSP needs !
to reference other procedures (sis) for performance of .l testin j l
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c. Program Assessments (Programs Other Than TP&P Programs)
Based on past problems with programs, resulting from unclear ;
ownership, excessive backlogs, process control weaknesses, and *
technical program breakdowns, the Site Vice President initiated an' l as.cessment of site programs. As part of the initial assessment,115 l programs were reviewed and high risk programs were identified for r further review. A team of corporate managers met and from the preliminary list, picked 8 programs for detailed assessments. The programs picked were based on programs with known or suspected weaknesses which could impact operations, cause a significant plant transient, or result in a high risk of violating requirement The 8 programs were: corrosion programs, ASME/ Regulatory programs, open issues and work, valve programs and predictive maintenance, environmental qualification , switchyard control, control of temporary repairs, and chemistry. A number of these programs are ;
included in the programs reviewed in paragraph b. above and assigned [
to TP&P. Some were reviewed and the review documented in previous t NRC Inspection Reports identified in paragraph a. abov In addition to the above assessments, as part of the restart effort, TVA identified approximately 150 individual programs and assigned the ownership department the responsibility for ownership and health assessment of each of the 150 programs. These assessments were still in process at the time of this inspection. The assessments included assessments of: (1) program ownership and definition including ownership, list of upper tier and site level procedures that define or implement the program, interfaces, and any procedural changes needed, (2) potential consequences of restart with l undetected weaknesses, (3) program health and effectiveness i including identification of performance indicators, backlogs, and program health, (4) list of actions recommended for restart and post
! restart, and (5) restart conclusion.
l The inspectors reviewed these assessments for the Chemistry l Department and the Materials and Procurement Department. In addition, QA overview and audit of this activity was reviewe Findinas i
The assessments appeared to be a conscientious effort to assess the ownership and health of the programs. For the two assessments reviewed, no restart items were identified. A number of post restart procedure enhancements and program improvements were identified. The QA overview and audit of the process appeared to be a good effort. Discussions with QA personnel indicated that 34 of the assessments were not finished. Although, much of the QA effort had been to verify completion of the assessment, the inspector pointed out that there should also be verification of quality of the assessments. QA noted that some of their reviews included i
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evaluation of quality of the assessments and now that more of the i assessments were complete, additional quality evaluations would be '!
performe Summary and Conclusions l
The new Technical Programs and Performance Department was in place with l 29 of the 35 positions filled, including the _ department manager and 2 of ,
the 3 key section supervisors. The Site Standard Practice (SSP) and 4 of :
the 5 implementing procedures for the improved FAC program were issue g The overall SSP describing the TP&P organization and overall i responsibilities was issued on July 22, 199 l In general, the TP&P programs reviewed were fo . to define ownership and j responsibilities. However, many of the new a 4 n /ised SSPs needed more I detail relative to responsibilities of organi h .ons other than TP& l The SSP for Snubbers provided little detail about how the program work ,
Also, a few minor procedure clarifications and enhancements were i'
identified. Responsible licensee personnel agreed with the need for procedural changes identified by the inspectors and stated that procedure i changes would be made. The type changes identified were not considered necessary before restar In general, the Health and Ownership documents appeared to be good l assessments of program status. However, a number of-discrepancies were !
identified in the Ownership and Health documents and the Program
! Readiness Assessments relative to the identification of restart items and I
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l the readiness for restart. Most of these discrepancies were cleared up by the end of the inspection. In a number of the programs, although restart items were identified, the programs were signed off as being :
ready for restar Further discussions revealed that the Site Vice l President had issued instructiors to Department Managers to discontinue '
this practice and remove their approval from Program Readiness !
Assessments previously approved with outstanding restart items. This had .
not yet been don i
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Although TVA has determined that all technical programs under the TP&P l organization have ownership defined and are ready for restart after correcting identified restart items, essentially all of the assessments
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identified a list of long-term actions needed. Therefore, it appears the l success of the programs and the new TP&P organization will depend on satisfactory completion of these long-term action items. The effectiveness of the TP&P programs under the new ownership cannot be l
fully assessed until after restart and a period of program t
implementation.
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l As noted above, the following areas will be inspected further by NRC prior to restart:
FAC Program l
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Within the areas inspected, no violations or deviations were identifie . Licensee Action on Previous Inspection Findings (92701, 92702) (Closed) VIO 327,328/92-36-04, Failure to Perform ASME Code l Surveillances as Required by TS 4. ,
i l This violation involved failure to perform ASME Section XI pressure ;
tests of portions of safety-related systems (containment spray, {
essential raw cooling water, auxiliary feedwater, safety injection and spent fuel) during the second inspection period of the first 10 l year interval. The licensee's letter of response dated February 16, !
1993 was reviewed and found to be acceptable. The corrective actions included: (1) performance of required testing, (2) review of
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the remaining pressure test activities required for the 1st 10 year 1 interval to ensure that all tests have been performed or are scheduled, (3) revision of SSP-8.5 to cover adequate scheduling and tracking of test to ensure compliance with code requirements, and (4) self-assessment of the pressure testing program to identify any other program weaknesse In addition to review of the self-assessment and actions planned as a result of the assessment (see paragraph 3.b. above), the inspector reviewed the following to verify licensee corrective actions:
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The following completed surveillances documenting completion of the required tests were reviewed:
1-SI-SXI-063-002.0 (10/30/91), -004.0 (10/25/91) and -00 (12/16/91)
2-SI-SXI-063-002.0 (4/2/92), -004.0 (4/2/92) and -00 (5/14/92)
0-SI-SXI-078-001.0 (1/10/93, -001.A (1/12/93) and -00 (1/6/93)
( l-SI-SXI-067-001.A (12/27/92), -002.A (12/27/92), and -00 !
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(12/23/92)
2-SI-SXI-067-001.A (12/27/92), -001.B (12/24/92), -00 (12/26/92), and -002.B (12/23/92)
SQN-SI-45.1 (12/27/92) and -45.3 (12/14/92)
0-SI-SXI-067-003.A (12/26/92), -003.B (12/23/92), -003.0
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(12/24/92), and -003.D (12/26/92)
1-SI SX1-072-001.A (12/24/92) and -001.B (12/23/92)
2-SI-SXI-072-001.A (12/23/92) and -001.B (12/23/92)
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SQN-SI-267.3.3 (12/24/92) )
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Changes to SSP-8,5 were reviewed. Although it-is not clear the !
changes made will enhance scheduling and tracking of test, the !
remaining test for the current interval have been identified j and scheduled. For the 2nd 10 year interval, a computer j program is planned to schedule and track test ;
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The inspector also reviewed ' documentation showing that the {
remaining tests for.the interval have been scheduled. In i addition, the inspector reviewed the results of the following l three licensee assessments / audits that verified required 1st i interval tests have been performed or, are scheduled: !
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Review by System Engineer and Corporate Test Engineer l
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QA Audit NA-SQ-93-001 l
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Contractor (United Energy Services' Corporation)-Audit of ERCW and RHR Systems Based on the above reviews, this item is close (Closed) LER 327/92-026, Failure to perform American Society of Mechanical Engineers (ASME)Section XI Pressure Tests This LER covers the same problem as identified above by VIO 327,328/93-36-04. Based on the above review, this LER is closed.
I (Closed) LER 328/93-001, Extraction Steam Line Rupture Causes High
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Generator Output Voltage' and Manual Reactor Trip
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This LER pertained to the March 1, 1993, Unit 2 extraction steam l leak and the subsequent reactor trip due to escaping steam from the rupture flowing into the nearby main generator voltage regulator
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cubicle resulting in regulator malfunction and voltage increas Corrective actions for this event were inspected during the current inspection and inspections documented in NRC Inspection Reports 50-i 327,328/93-10, 50-327,328/93-12 and 50-327,328/93-24. Based on l these inspections, this LER is closed.
l Exit Interview The inspection scope and results were summarized on July 23, 1993, with those persons indicated in paragraph 1. The inspector described the areas inspected and discussed in detail the inspection findings. Propri-eta c information is not contained in this report. Dissenting comments weie not received from the license j I
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6. Acronyms
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AIT Augmented Inspection Team AfW Auxiliary feedwater AFWP Auxiliary Feedwater Pump ASME American Society of Mechanical Engineers B0P Balance of Plant CAL Confirmation of Action Letter CrMo Chromium Molybdenum ,
CV Check Valve dp Differential Pressure ,
DRS Division of Reactor Safety '
E/C Erosion / Corrosion ,
EPRI Electric Power Research Institute '
EQ Environmental Qualification ERCW Emergency Raw Cooling Water FAC Flow Accelerated Corrosion FCV Flow Control Valve II Incident Investigation ;
ISI Inservice Inspection l IST Inservice Testing I LER Licensee Event Report MFW Main feedwater M0V Motor Operated Valve MRRC Management Restart Review Committee i MSR Moisture Separator Reheater i
NDE Nondestructive Examination NRC Nuclear Regulatory Commission PER Problem Investigation Report i QA Quality Assurance l QC Quality Control RII NRC Region II R&R Repair and Replacement SI Surveillance Instruction SQN Sequoyah Nuclear Plant SSP Site Standard Practice TI Technical Instruction TP&P Technical Programs and Performance i TQ Torque TROI Tracking of Open Items TST Torque Switch Trip TVA Tennessee Valley Authority URI Unresolved Item VIO Violation WO Work Order WR Work Request