ML20133N290
| 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: |
| References | |
| 50-327-85-24, 50-328-85-24, NUDOCS 8508130440 | |
| Download: ML20133N290 (7) | |
See also: IR 05000327/1985024
Text
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UNITED STATE 3
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NUCLEAR REGULATORY COMMISSION
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R EGION 11
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101 MARIETTA STREET.N.W.
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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:
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B. Debs
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H. Christensen
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Approved by:M - 91
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Date' Signed
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B. Debs, Acting Section Chief 4
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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
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maintenance testing and for lacking post maintenance determination
criteria.
Violation 328/85-24-03
Failure to monitor ice condenser bed
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temperatures at the required periodicity
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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
- J. Krell, Plant Superintendent (Maintenance)
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- 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
maintenance requests, and interviews with various maintenance personnel.
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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
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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.
The maintenance planners assemble the maintenance request work packages
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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.
SQM-2, Maintenance Management System Procedure, lacks procedural
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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.
The inspectors noted several cases of priority down grading of MRs that
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lacked middle to upper management inputs into the decision process.
The
maintenance
request
system
appears
overburdened
with
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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
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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
inspector identified MR-A-526113 which had been available for work
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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.
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
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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.
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Section B.3, QA Review, states, in part, that the FQE section
shall review required ' entries for orginator and planner sections
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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
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post maintenance testing, and where applicable, reference the
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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
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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 'also appears as a 1010 time entry in the AU0 daily journal
buildup
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
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at an apparent depth of one-eighth to one quarter inch. The area
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of greatest icing appeared below a location where insulating tape
was torn overhead on the upper ice condenser doors allowing humid
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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.
Additionally, with one or more ice condenser doors inoperable,
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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
bed temperature is maintained less than or equal to 27 F.
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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
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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
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
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place. When questioned by the inspector, the licensee indicated
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that the as left hanger was not analyzed regarding its potential
for being a missile hazard. The inspector expressed concern that
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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
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auxiliary feed system. Licensee Maintenance personnel volunteered
to analyze the hanger's missile hazard potential.
The inspector
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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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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
maintaining the master PM schedule.
Finally, the general foreman of each
maintenance section is responsible for the performance of the PM and
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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
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the requirements and commitments made in Technical
Specifications,
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applicable regulatory guides, and industry standards.
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