ML19325E996

Discusses Util Completion of Commitments Re Replacement Items Project for Warehouse Inventory & Seismically Sensitive Electrical Devices.Encl Provides Status of Util Efforts to Date

ML19325E996
Person / Time
Site:	Sequoyah
Issue date:	11/06/1989
From:	Michael Ray TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 8911130163
Download: ML19325E996 (14)

Text

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%_ q TENNESSEE VALLEY AUTHORITY

,, CH ATTANOOGA. TENNESSEE 37401

, 5N 157B Lookout Place

. NOV 061989 .

! U.S. Nuclear Regulatory Commission

( ATTN: Document Control Desk b ' Washington, D.C. 20555 ,

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[ Gentlemen:

I In the Matter of ) Docket Nos. 50-327

Tennessee Valley Authority ) 50-328 SEQUOYAH NUCLEAR PLANT (SQN) - REPLACEMENT ITEMS PROJECT (RIP) ,

This letter is:being provided.to describe how TVA completed its commitments associated with the.SQN RIP.for the warehouse inventory and seismically sensitive electrical devices, t

c The RIP was organized in November 1986 to address identified deficiencies in i i <

TVA's practices,for the procurement of safety-related replacement items.

Specifically, TVA's procuremer.t program could allow previously qualified

. equipment to be degraded by purchasing replacement components and parts as commercial grade without qualification documentation and without adequate dedication of the items by TVA. While TVA was taking corrective action to t: -

improve the procurement- program, TVA lacked programmatic. requirements for the dedication of commercial-grade >1tems and had not addressed the effect that past procurement practices may have had on the qualification of installed i

. equipment. As a result, RIP was established to develop and implement a ,

corrective action plan. The primary objectives of RIP were (1) to verify that

.previously quallfled equipment (selsmic and environmental) has not been 1

- degraded through the use of spare parts and replacement items, and (2) to t establish programs and practices that will ensure that prevloesly qualified

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, equipment (seismic and environmental) will not be degraded in the future through the use of spare and replacement parts.

TVA has completed its. review of the warehouse inventory and seismically ,

sensitive electrical devices. The enclosure provides the status of what TVA has accomplished. Also included is the justification of how TVA applied ,

generic evaluations to a percentage of the safety-related items in the warehouse to be dedicated. SQN's program and processes have not been revised from those previously described to NRC; TVA has only identified a more efficient manner to support dedication of certain groups of items. SQN l i , intends to initiate phased implementation of the generic dedications on November 27, 1989. Based on the activities performed and program requirements in place, TVA considers the commitments to evaluate the warehouse inventory and seismically-sensitive electrical devices complete.

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8911130163 891106 7 DR ADOCK 0500 An Equal Opportunity Employer

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2-ll .U.S. Nuclear Regulatory Commission NOV 06 B89 li, p

( If you have any questions concerning this submittal, please' telephone i L M. A. Cooper at '615) 843-6651.

L L Very truly yours, f

f TENNESSEE VALLEY AUTHORITY

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Manage 9,Nuclea k.bensingand Regulatory Affairs cc (Enclosure):

[- Ms. S. C. Black, Assistant Director

" for Projects TVA Projects Division U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Mr. B. A. Wilson, Assistant Director for Inspection Programs TVA Projects Division U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NH, Suite 2900

Atlanta, Georgia 30323 NRC Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road  !

Soddy Daisy, Tennessee 37379 j i

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. ENCLOSURE 1 k Page 1 of 4

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SQN Replacement Items Project (RIP) i Program Purpose The primary objectives of the RIP were.(1) to verify that previously quallfted equipment'.(selsmic and environmental) has not been degraded through the use of

spare parts and replacement items, and (2) to establish programs and practices p that will ensure that previously quallfled equipment (seismic and h environmental) will not be degraded in the future through the use of spare and replacement. parts.

~ Restart Program fu Installed equipment was initially. targeted in activities necessary to support the restart of Unit 2'. The restart scope included an evaluation of 10 CFR 50.49 equipment, seismic evaluation for maintenance of Institute of Electrical and Electronics Engineers (IEEE) 344-1975 qualification within the e Phase I Design Baseline and Verification Program (DBVP) boundary, and n

conditional release controls for items issued to the plant. The m environmentally quallfled equipment program was reviewed and accepted by NRC in Reference 3. To address NRC's questions on seismically sensitive,

. electrically active devices, a detailed evaluation was performed on these

devices in the warehouse inventory and installed items from those inventory bins. As stated.in Reference 4, the results of the program were reviewed by NRC and found acceptable for the restart of SQN Unit 2. The~ environmentally L ' qualified equipment program and the seismic evaluetion for installed and seismically sensitive, electrically active devices were completed for Unit 2 prior to restart in May 1988.

. Building on the success of the Unit 2 program, TVA demonstrated that SQN Unit I also remained qualified to IEEE 344-1975 and that the installation of ,

commercial-grade items during normal maintenance activities governed by controlled site-specific maintenance procedures did not degrade that qualification. This was accomplished by applying Unit 2 and common equipment

. evaluation to Unit I as defined in Reference 2. Additional Unit i evaluations a were only performed for identified Unit-2 deficiencies.

Postrestart Programs To address selsmically sensitive warehouse items beyond the Phase I j OBVP boundary, TVA performed a seismic screen of the Quality Assurance  ;

(QA) II items in accordance with References 1 and 2 and subsequent dedication. This was accomplished by review of procurement reco.ds, equipment

, qualification, maintenance history, industry experience, and recent industry ,

problems. The seismica'ly sensitive items that could not be dedicated were l positively identified by inventory bin location for those located in the l warehouse and by unique aquipment identifier and location for those items that i were installed. Installed equipment will be replaced with qualified material  !

'by the end of the Cycle 4 outages in accorlance with previous commitments. '

l Since entering Mode 4 on Unit E in Febr uary 1988, TVA has perfor med an ,

evaluation of intended service application and a detailed engloeeH ng evaluation of commercial-grade items in the warehouse inventory intended for L safety-related applications. The detelled evaluation documented critical ,

x characteristics and verification methods of those characteristics in ,

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. ENCLOSURE 1

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' accordance with plant procedures. As of January 1989, the SQN warehouse ,

pj contained approximately-12,000 items that were considered commercial grade (QAfII) with a potential safety-related application. To date, the review has

consisted of a detailed technical evaluation of approximately 3,500 of these items.  ;

The evaluations revealed that approximately half of the QA II items had been

misclassified as safety'related and have been downgraded to QA III (nonsafety related). Approximately 15 percent of the QA II items evaluated have been determined to have been procured as nuclear-grade items and have therefore F been revised to reflect a QA I classification. The technical rejection rate of the remaining items for warehouse inventory, excluding seismically -

s sensitive items, is approximately 1.2 percent, of which a large portien is ,

(~ rejections of material that did not have contract traceability or were not economically feasible.to evaluate. Addltional detailed evaluations of QA II

! Items-have been performed for window issue or stock reorder and totai

,g over 1,300_ items to date, ,

Generic Methodology i

Based upon experience gained from completed dedications, TVA determined that generic methodology could be applied to certain warehouse items and would provide:a high degree of confidence that the material could be covered with adequate verification methods for defined critical characteristics. The SQN program and processes have not been revised from that previously described to NRC; TVA has onlyJidentified a more efficient manner in which to support t

, dedications of-certain groups of items. (This' methodology is applied to items already in the warehouse, i.e., not to new procurement items.)

The experience obtained in the completed reviews of the warehouse inventory  :

was evaluated'for possible application to the remaining inventory.

Acceptability of a generic evaluation application to inventory items considered as a minimum potential installed applications, technical requirements, technical rejection experience, seismic considerations, and vendor performance. Additionally, industry problems, components, and replacement parts that are the subject of regulatory or industry notifications were reviewed, and associated items were excluded from the scope of the

' generic evaluations. A review of dedication methodologies utilized by RIP on warehouse inventory was performed. The primary acceptance method was based on the< industry consensus guidelines method of special tests and inspections.

Verification methods included augmented receipt inspection and specification of a postinstallation test, but the normal baseline method utilized existing

-receipt inspection, maintenance requirements of like-for-like replacement, and the standard postmaintenance test (PMT) as defined in plant procedures.

The compilation of experience further defined critical characteristics of commodity groups of functionally similar components and the standard verification methods for those critical characteristics. An evaluation was conducted to review inventory line items for inclusion in generic evaluations. This process was developed based on previous procurement l

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ENCLOSURE 1 l- Page 3 of 4'

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[ substation packages, generic evaluation work packages, or contract engineering n 1 group-evaluated material determined to be acceptable. This process for each

~s: stock item provided a' correlation of an evaluation to its applied population and thus gave:a high degree of confidence that an acceptable technical

. evaluation and dedication of inventory line items had been performed. . Iterns L for which generic application.could not be supported will receive specific evaluations in accordance with the established ongoing RIP process. A list of i

the safety-related items for which application of generic evaluation has been determined acceptable is provided in Attachraent 3.

!' , The evaluation summaries were documented for each generic grouping. System classification for functional requirements was defined to provide the basis r .for selection of critical characteristics. Critical-characteristics and verification methods are summarized as well as seismic considerations. -Two p examples of generic evaluations are included in Attachments I and 2.

F Implementation of a generic evaluation to a component or commodity group will L constitute dedication for all items within that group. Documentation _will consist of the generic dedication package of the warehouse inventory and the ,

work request package (including any required PMTs) for item installation. 1 Not.all warehouse items.could be considered appropriate for inclusion to generic evaluation. These items were, however, screened for potential Impact on plant operations, economics, material delivery time, and inventory review experience. These items were placed in a hold status and will not be issued for safety-related application without specific evaluation in accordance with

.the established RIP. process.

Specific Evaluations

.Those items in hold status have administrative procedural controls in place to prevent issue for potential safety-related applications without specific evaluations. . Issuance of inventory for safety-related applications will be l'

performed in accordance with the established RIP process, i.e., warehouse inventory dedication or window issue dedication.

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Controls In order to estab'?sh stronger control on the use of commercial-grade items, r TVA revised the Nuclear Quality Assurance Manual. Nuclear Engineering (NE) '

procedures, and site procedures to control installation and precurement of items intended for safety-related application. TVA has incorporated into its procedures the methodology that is used to evaluate commercial-grade items for use in safety-related applications. This program is consistent with Generic Letter 89-02 guidelines. Additionally, as industry problems are identified, those-problem components will be reviewed to ensure that these items do not degrade the safety-related application.

NE will continue to provide technical specifications for soare and replacement parts through the procurement engineering function to aid in ensuring that safety-related equipment is not degraded by the procurement procen. To enhance the procurement process, TVA deseloped an automated process +o

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8 electronically incorporate procurement specifications into the materials l p management system. To further enhance the program, TVA is developing a corporate standard for the process, and software uploads should begin by the i'

K h end of 1989. .

L Summary- ,

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TVA has completed the evaluation of seismically sensitive, electrically active devices with documentation in place to track replacement of nonquallfled i s installed items by the end of each unit's Cycle 4 refueling outage. TVA has i implemented engineering support to the procurement process as the foundation for this program. ,

Evaluation of the warehouse inventory has been completed on approximately  ;

4,800 ltems to date with a very low technical rejection rate. Detailed >

[ evaluation experience has been expanded and applied to certain commodity or ji . functionally similar generic groups where appropriate. This more efficiently utilized the existing RIP process and program to support item dedication. .

i The remaining warehouse commercial-grade inventory (i.e., items in hold b

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status) will be evaluated in accordance with RIP. Additional efforts by TVA in the. area of inventory consolidation and engineering evaluation toward the l' goal.of an engineered operating inventory will further promote efficiency.

This evaluation closes the RIP corrective action at SQN with the exception of seismically sensitive, electrically active device replacement. Acceptability  ;

of new procurement items will be ensured through implementation of TVA's .

Upgraded procurement process. NE support of that procurement process serves '

as the long-term action for procurement of spare and replacement parts that

, maintain the design basis of the plant.

References

1. TVA letter to NRC dated' April 1, 1987, "Sequoyah Nuclear Plant (SQN) - l Program Plan for Replacement Items Project"

2. TVA letter to NRC dated February 10, 1988, "Sequoyah Nuclear Plant'(SQN) -

Replacement' Items Program (RIP) Supplemental Program Plan"

3. NUREG-1232, Volume 2, " Safety Evaluation Report on Tennessee Valley ,

Authority: Sequoyah Nuclear Performance Plan," May 1988

4. Letter from S. D. Richardson to TVA dated April 13, 1988, " Follow-up Inspection for Piece Parts Procurement (50-327/88-07 and 50-328/88-07)"

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-EXAMPLE Of A CENERIC. DEDICATION EVALUATION '!

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g -ITEM DESCRIPTION WP002 i L .

I I , Motor and Parts r Y ,

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1. _ Motors are used on equipment that is. required to turn, drive, pump, or blow a ,

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multitude of devices or' mediums. Many of these devices are located in im safety-related systems'and perform a safety function. The reliability of 4 l

these motors must be so that they will operate in'a wide.-range of conditions h'

L ' essential to plant. operations or safe shutdown of the plant.  !

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' CRITICAL CHARACTERISTICS Part number, ratings (temperature, speed, amps, voltage, power, alternating ,l current / direct current enclosure, flow), function, fit, and seismic

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p s EVALUATION CLARIFICATIONS AND JUSTIFICATION '

t i Part Number. Rating' J M, Motors'and parts are ordered from ver. dor' catalogs by part number or model if

-number and. technical descriptlon. Ordering the item by a manufacturer's part  !

, number ensures-the proper specifications'and ratings apply. In addition, the i n receipt inspection:is performed in accordance with SQN procedures. This  !

inspect!on ensures'that the item is the same as specified by the purchasing ~1 contract. ,

. Function'. J l' ,

Functional testing of the motor is confirmed by continuous operation of the  !

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' motor during normal operation of.the plant. Instrumentation installed within

,the parameters of the system monitor medium flow rate and pressure or motor

' current and temperature. Instrument readings that are not within the .

acceptable.Ilmits would indicate' potential failure and require investigative l fl: r  : action. Safety-related systems require additional PMTs for motors that are  ;

i used as, basic' components. Vibration checks after installation are examples of

.these PMT requirements.

O Fit' Trained maintenance personnel and approved plant maintenance procedures ensure ,

the proper fit of the motor. Misalignments and improper fit are also checked  ;

and corrected through functional testing.  ;

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4 ATTAC4 MENT 1 Page 2 of 4 Seismic Qualification 1 Design practicality and current motor desigin theory establish a high degree of confidence in the size and mass comparability of seismically significant parts. A given motor application will have several output requirements including torque and horsepc.4er. In motor design, these output requirements dictate the sizes of motor windings, armatures, etc., for a highest efficiency combination. Thus, major motor parts and their associated fittings and housings for a given applicat'aon are going to be similar for most manufacturers. The only exceptions to this logic involve more exotic applications and technologies not common to the motor usage in the nuclear power Industry. In addition, most replacement parts are ordered from suppliers of the original equipment manufacturer. This confidence in the similar mass and size of the motors yleids a high assurance that they will not affect the overall seismic qualification of the host.

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'. -81 in' generic evaluation count n~ 7 45'withTissue history'in:last six years

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4: reject)ons .

p& Re.iection Evaluations 4,e The four rejections were for lack of certification for metallic,

- environmentally nonsensitive (i.e., not 10 CFR'50.49) items. -These were:

' conservatively assumed as 50.49 early in the program. 8ased on the environmentally nonsensitive nature of the parts and associated exclusion from 50.49, evaluation'showed that dedication could.be readily performed and thus Lwould not be rejected'at the' current experience level.

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'1 iIndustry/Reaulatory Experience Review a . Inspection and enforcement (IE) notices and-bulletins reviewed for generic appilcability:

a IE Notice 86-03 IE Notice 82-52

.IE Notice 87-08 IE Notice 86-71 IE Notice.86-02

"'- Environmenta'11y: sensitive Limitorque parts.were covered in the RIP.

No other; generic' problems were identified.

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Conclusion-The RIP had evaluated environnentally sensitive 50.49 inventory, which is complete.; Detailed evaluation's on metellic piece parts intended for

safety-related.50.49 applications showed that items were normally purchased 0 - ,

from the equipment manufacturer. Therefore, dedication will be considered complete at. receipt by taking credit for maintenance like-for-like '

o requirements for fit and functional test for functionality and operability.

$>, Reasonable assurance of form is based on normal procurement from the equipment manufacturer and adequate receipt inspection.

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CEG'- Contract Engineer.ing Group

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• Containment' Air Lock. Door Parts '

l ff- . FUNCT'!ONAL REQUIREMENTS ,

? Proper functioning of these. doors is necessary to maintain the integrity of i 3 f- .the' reactor building primary containment pressure boundary. l

...,  ; CRITICAL. CHARACTERISTICS ,

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' Dimensions and Function p Newly ~ mounted doors and repaired doors are required to be-inspected in M i L'accordancewithSQNmaintenanceproceduresensuringaproperfitand: adequate h  : function. Pressure-retaining adequacy.and overall operability are tested

• every 31 days in~accordance with standard SQN procedures.

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Door parts.are small and are affixed to the door in stable configurations so

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thatethe' seismic integrity of the door is not compromised as a result of its

.. replacement or: repair. Seismic loading was.also included as a part of the design. basis for.the doors.

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' 3 i NoLadverse problem,s'were'ident1 fled that would impact this generic evaluation.

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ATTACHMENT'3  !

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' SAFETY-RELATED GENERIC EVALUATIONS '.,

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. Evaluation Number Title 1 m  ;

., WP001 Valve Operator and Actuator Parts [

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WP002 Motors.and Parts'. '

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HP005 ' Olesel: Generator Parts d h M ,q'l . [

. WP006' Bulk Electrical _ Commodities i WP015 Filters (hlgh-efficiency particulate air). .

? WP016 - Door Parts (Auxiliary Building Secondary. t A Containment Enclosure and Fire)' '

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, WP021 ' Instrumentation and Parts i WPO40 ,

Couplings-  ;

WP052 Grout '

t M, . H .WP054- Bushings, Rings, and Spacers h', WP055 Auxiliary Feedwater Pump Parts ,e i WP060 Valve'Positioners, Controllers, and Parts b Op . , WP063~ , Radiation Monttoring Equipment-i-  ; 'WP074 Snubbers and Snubber Parts  !

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