ML20133N290

Insp Repts 50-327/85-24 & 50-328/85-24 on 850617-21. Violations Noted:Failure to Perform post-maint Testing, Lack of post-maint Criteria & Failure to Monitor Ice Condenser Bed Temps as Required

ML20133N290
Person / Time
Site:	Sequoyah
Issue date:	07/31/1985
From:	Christensen H, Debs B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20133N278	List: ML20133N276 ML20133N281 ML20133N290
References
50-327-85-24, 50-328-85-24, NUDOCS 8508130440
Download: ML20133N290 (7)

See also: IR 05000327/1985024

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UNITED STATE 3

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o NUCLEAR REGULATORY COMMISSION

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3 R EGION 11

j 101 MARIETTA STREET.N.W.

• ' s ATLANTA. GEORGIA 3o323

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Report Nos.: 50-327/85-24 and 50-328/85-24

. Licensee: Tennessee Valley Authority

500A Chestnut Street

Chattanooga, TN 37401

Docket Nos.: 50-327 and 50-328 License Nos.: DPR-77 and DPR-79

. Facility Name: Sequoyah 1 and 2

Inspection Conducted: June 17-21, 1985

Inspectors: Mdk hMm h

B. Debs \

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Data Signed

M -, b m - '7 % i M-

H. Christensen h~ Dato SLgned

Approved by:M - 91 CA L, ,~ 9158 OS'

B. Debs, Acting Section Chief 4 ( Date' Signed

Division of Reactor Safety

SUMMARY

Scope: This routine, unannounced inspection entailed 68 inspector-hours on site

in the areas of maintenance programs.

Results: Two violations were identified:

Violation 328/85-24-02 -

Failure to perform appropriate post

maintenance testing and for lacking post maintenance determination

criteria.

Violation 328/85-24-03 -

Failure to monitor ice condenser bed

temperatures at the required periodicity

B508130440 85080f

gDR ADOCK 05000327

PDR

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REPORT DETAILS

1. Persons Contacted

Licensee Employees

• P. Wallace, Plant Manager

• G. Boles, Mechanical Maintenance Engineer Supervisor

• C. Chmielewski, Nuclear Engineer

• H. Elkins, Instrumentation Maintenance Group Head

• R. Gladney, Instrumentation Maintenance Engineer Supervisor

• J. Hamilton, Quality Engineer / Quality Control Supervisor

• G. Kirk, Compliance Supervisor

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• J. Krell, Plant Superintendent (Maintenance)

• D. Love, Mechanical Maintenance Engineer Supervisor

• B. Patterson, Plant Superintendent (Maintenance), Acting

• M. Skarzinski, Electrical Maintenance Supervisor

• C. Wilson, Nuclear Engineer

• G. Wilson, Assistant Operations Group Supervisor

Other licensee employees contacted included engineers, technicians,

operators, mechanics, security force members, and office personnel.

NRC Resident Inspectors

K. Jenison, Senior Resident Inspector

• L. Watson, Resident Inspector

• Attended exit interview

2. Exit Interview

The inspection scope and findings were summarized on June 21, 1985, with

those persons indicated in paragraph 1 above. The inspector described the

areas inspected and discussed in detail the inspection findings listed

below. The licensee commented on being unsure of the validity of the ice

condenser door violation (VIO 328/85-24-03). Additionally, the licensee was

notified by telephone that lack of appropriate post maintenance testing of

the EGTS damper was a violation.

The licensee did not identify as proprietary any of the materials provided

to or reviewed by the inspector during this inspection.

3. Licensee Action on Previous Enforcement Matters

This subject was not addressed in the inspection.

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4. -Unresolved Items

Unresolved items are matters about which more information is required to

determine whether they are acceptable or may involve violations or

deviations. New unresolved items identified during this inspection are

discussed in paragraph 5.d.

5. Corrective Maintenance (62702)

The inspectors reviewed the licensee corrective maintenance program to

verify that the program had been established in accordance with regulatory

requirements, industry guides and standards, and Technical Specifications.

The review consisted of reviewing the licensee procedures, numerous

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maintenance requests, and interviews with various maintenance personnel.

Sequoyah's Standard Practice SQM-2, Maintenance Management System,

establishes the method and responsibilities for managing the initiation,

planning, scheduling, execution, status tracking, and documentation of  ;

maintenance work. The inspectors had the following concerns: '

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SQM-2, Maintenance Management System Procedure, has no timeliness

requirements for post work review. The inspectors noted several

maintenance requests (MRs) that were performed in 1981 but had recently

received post maintenance reviews. The licensee had identified these

MRs and approximately 2000 other MRs as lacking a timely review.

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The maintenance planners assemble the maintenance request work packages

using verified procedures and instructions. The foreman or craf tsmen

performing the work have no procedural requirement to verify that these

procedures are still correct and are the latest revisions, even if the

job is worked months after the package is assembled. This is of

concern due to the large backlog of MRs that are in the

available-to-work category.

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SQM-2, Maintenance Management System Procedure, lacks procedural

guidance in the prioritization of routine maintenance. SQM-2 divides

routine maintenance into three categories, P1, P2 and P3, but does not

define the significance or urgency associated with these priorities.

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The inspectors noted several cases of priority down grading of MRs that

lacked middle to upper management inputs into the decision process.

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The maintenance request system appears overburdened with

non-maintenance work activities. An example is an MR for manufacturing

a plexi glass desk top.

The licensee was informed that the above concerns will be an inspector i

followup item (IFI 327,328/85-24-01). The licensee stated that they would

address and take corrective action on the listed concerns, but could not

give a firm commitment date for completion. The licensee stated that the

concerns should be addressed within a year.

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.The inspectors reviewed several-MRs in detail and identified the following:

a. The review of MR ' A-089626, Containment Spray Pump Motor IB,

revealed that the . licensee has developed a vibration trending

. program. The vibration analysis data for the containment spray

pump showed that the inboard motor bearing .was getting

progressively worse. From this data, the licensee generated a MR

to replace this bearing before the pump failed. The vibrational

analysis of major equipment and the preventive maintenance that

results will allow the licensee to maintain vital equipment in a

higher condition of readiness and should prevent major failures of

this equipment.

b. A review of outstanding routine maintenance requests by the

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inspector identified MR-A-526113 which had been available for work

since May 20, 1985. This MR stated that Emergency Gas Treatment

System (EGTS) damper, 0-65-525, operates extremely sluggishly and

binds. The maintenance performed to correct this situation was

reported completed on June 18, 1985. The maintenance consisted of

adjusting the counter balance on the damper.

The inspector observed that the aforementioned MR superceded

MR-A-526473 which had been written on May 16, 1985. This MR had

been assigned an "Immediate Attention" priority and requested that

the system flow rate be verified as adequate and that damper

operability be determined.

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Licensee personnel indicated that an-informal flow rate test was

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performed by the individual who wrote the original MR which

determined that the flow rate was barely adequate. This statement

of flow adequacy appears as an attachment to the original MR;

however, no quantitative data had been procedurally do.cumented.

Additionally, post maintenance test requirements did not include a

L flow rate test.

SQM2, Maintenance Management System, section B.2.2, QA Post

Maintenance Test Requirements, states, in part, that the planner

or cognizant engineer shall identify any pre or post maintenance

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testing requirements by listing both the test number and the

section responsible for the test. Should a special test be '

required, the planner shall state the specifics of this test.

Section B.3, QA Review, states, in part, that the FQE section

, shall review required ' entries for orginator and planner sections

L of the MR to assure the format and content are in compliance with

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quality assurance requirements and that the items of Appendix C

have been considered. SQM2, Appendix C, Preparation / Initial

Planning Guidelines for MRs, item 5, states, "Specify appropriate

i post maintenance testing, and where applicable, reference the

I proper plant instruction". Item 15, states, " Consider compliance

with plant technical specifications". Specifically: (a) will

removal of equipment from service for this maintenance violate any

limiting conditions for operations and (b) are adequate post

maintenance tests (sis) specified to ensure the equipment

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readiness for' operation"? Technical Specification 6.8.la states

that written procedures shall be established, implemented and

maintained covering the activities referenced below:

The applicable procedures recommended in Appendix A of

Regulatory Guide 1.33, Revision 2, February 1978

Regulatory Guide 1.33, Revision 2, Appendix A, section 9.a,

Procedures for Performing Maintenance, states, in part, that

maintenance that can - af fect the performance of safety-related

equipment should be properly pre planned and performed in

accordance with written procedures, documented instructions, or

drawings appropriate to the circumstances.

10 CFR 50 Appendix B, criteria V, states, in part, that instruc-

tions, procedures, or drawings shall include appropriate

quantitative or qualitative acceptance criteria for determining

that important activities have been satisfactorily accomplished.

After further review following the inspection, the licensee

management was telephonically notified that, contrary to Technical

Specification 6.8.la, and 10 CFR 50, Appendix, B, criteria V, the

licensee failed to properly preplan and perform post maintenance

testing on safety-related equipment, the EGTS system, due to the

lack of appropriate acceptance criteria for - determining post

maintenance testing of safety-related equipment. This is

Violation (328/85-24-02).

c. The inspector noted that on June 10, 1985, one of the licensee

Auxiliary Unit Operators (AU0) generated two MRs (A553689 and

A553690) to investigate and repair or replace paper and/or tape

l above the intermediate ice condenser doors for Units 1 and 2.

These MRs had also been downgraded from immediate action., This

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condition was resulting in moisture in the upper plenum area

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ice buildup on the intermediate doors. The observed ice

causing

buildup 'also appears as a 1010 time entry in the AU0 daily journal

for June 10, 1985. On June 16, 1985, an Qntry was made into the

Unit 2 containment to perform MR-A-553690. The inspector

accompanied the detailed maintenance group into containment and

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observed some general icing on several intermediate doors. This

icing appeared to cover a half to two thirds of the door's surface

l at an apparent depth of one-eighth to one quarter inch. The area

l of greatest icing appeared below a location where insulating tape

. was torn overhead on the upper ice condenser doors allowing humid

air to enter the bays. A member of the labor force indicated to

the inspector that he routinely (nearly daily) enters the Unit 2

Ice Condenser and removes ice from the intermediate doors. He

indicated that his work is accomplished ether by a MR or solely on

a housekeeping Radiation Work Permit (RWP).

The laborer stated that the ice is removed from the intermediate

doors by chipping any ice away from the door gasket, opening the

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door, and hitting the underside of door with a hammer to break

free the ice accumulation. The ice is then removed from

containment and placed in a 55 gallon drum for waste disposition.

Approximately one-half to two thirds of the drum is filled in a

five day period.

Licensee Technical Specification 3.6.5.3 states that the ice

condenser inlet doors, intermediate deck doors, and top deck doors

shall be closed and operable for modes 4 through 1.

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Additionally, with one or more ice condenser doors inoperable,

power operations may continue for up to 14 days provided the ice

bed temperature is monitored once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and the maximum ice

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bed temperature is maintained less than or equal to 27 F.

Technical Specification Surveillance Requirement 4.6.5.3.2 states,

in part, that each intermediate deck door shall be verified closed

and free of frost accumulation by visual inspection at least once

per 7 days.

The licensees operations management indicated that although ice

was observed on the intermediate doors, ice bed temperatures were

recorded once per eight hour shift rather than the required once

i per four hours. The inspector informed licensee management that

this situation represents a violation of TS 3.6.5.3 (VIO

328/85-24-03).

d. While reviewing open MRs, the inspector noted that an MR had been

written to investigate concrete cracking of the polar crane wall

for Units 1 and 2. The inspector was informed by licensee

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maintenance personnel that the concrete cracking was associated

i with feedwater hanger 1-FDH-282 which was anchored to the concrete

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where the cracking was observed. As a result of an engineering

analysis, the licensee relieved the hanger of its load and

distributed that load between adjacent hangers. For Unit 2, the

approximately four feet of horizontal "I" beam hanger was left in

l place. When questioned by the inspector, the licensee indicated

that the as left hanger was not analyzed regarding its potential

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for being a missile hazard. The inspector expressed concern that

! the hanger was attached to the concrete in a degraded manner and

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was located above a main feed line downstream of the tie-in by the

l auxiliary feed system. Licensee Maintenance personnel volunteered

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to analyze the hanger's missile hazard potential. The inspector

informed licensee management that this issue remains an unresolved

item until both the licensee and the NRC had evaluated this

condition (URI 328/85-24-04).

6. Preventive Maintenance Program (PM)

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l The inspector conducted a review of the licensee's implemented preventive

maintenance program (FM). This review consisted of reviewing the licensee's

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administrative, quality and maintenance department procedures, observing a

PM being performed and interviewing selected individuals who were

responsible for planning, scheduling, tracking, developing and working PMs.

Additionally, the inspector ascertained whether the licensee's program is in

conformance with Technical Specification and connitments made to applicable

regulatory guides and industry standards.

Sequoyah's PM program is implemented by SQM-57, Preventive Maintenance

Program. This procedure requires the mechanical, electrical and instrument

departments to establish the types and frequencies of PMs to be perform and

adjust the PM frequencies as equipment operating experience is gained.

Additionally, the plant services supervisor is responsible for the

assembling of work packages, tracking, scheduling, backlog reporting and

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maintaining the master PM schedule. Finally, the general foreman of each

maintenance section is responsible for the performance of the PM and

returning of the completed package to the appropriate maintenance supervisor

for review.

The PM program, as implemented at Sequoyah appears tc be adequate in meeting

i the requirements and commitments made in Technical Specifications,

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applicable regulatory guides, and industry standards.

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