ML20204G377
| ML20204G377 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 03/18/1987 |
| From: | Gardner G, Russell Gibbs, Russell J TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20204G202 | List: |
| References | |
| 303.05-SQN, 303.05-SQN-R04, 303.05-SQN-R4, NUDOCS 8703260386 | |
| Download: ML20204G377 (9) | |
Text
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- HA EMPLOYEE COECERNE EEPORT t'UhdER: 303.05-SQ.
,-
- SPECIAL PROGRAN REPORT TYPE: Sequoyah Nuclear Plant - Element REVISION NUMBER: 4 ,
TITLE: Reliability, Design and Maintenance of Radiation Monitoring Equipment REASON POR REVISION:
To include three additional concerns and incorporate TAS and Revision 1 SRP comunents.
To incorporate TAS and SRP cosaments Revision 2 To include one additional concern and incorporate SQN Corrective Revision 3 Acti,on Plan To include CAQR No SQP870178 and teseking Revision 4 PREPa** TION PREPARED BY:
G. Darrell Gardner 3// ~' f7 SIGNATURE DATE
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." SIGNATURE BATE ~
TAS:
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SIGNATURE ' IIATE M"** "*' ?*
hEG-HL we 7 SRP: .ae 4, / .me/( 3 N 7 SIGNATURE DATE SIGNATURE
- DATE APPROVED BY:
d i b .'N\b 3!nd@ N/A DATE RCSP MA$GER DATE MANAGER OF NUCLEAR POWER CONCURRENCE (FINAL REPORT ONLY)
- SRP Socrotary's signature donotes SRP concurronces are in files.
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C70321"O386 870319 PDR ADOCK 05000327 p PDR
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TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT EMPLOYEE CONCERNS TASE GROUP 0 OPERATIONS CEG L
Subcategory: Instrumentation and Radiation Monitoring Element: Reliability, Design and Maintenance of Radiation Monitoring Equipment Report Number: 303.05 SQN Revision 4 SQP-86-003-001 XX-85-044-001 CWL-85-001 XX-85-051-001 SQP-86-003-N04 SQP-86-003-N05 Evaluator: b. 8 2!87 B.NeersJf' ' Da'te Evaluator: G. Darrell Gardner J 2/f 7 G. Darrel Gar ner Ditte Reviewed by: /# ~ VW
' OPS E A r 3d&If Date Approved by: * /3 O W. R. Lagergren Date 1202T
- R visicn 4 I. Reliability Design, and Maintenance of Radiation Monitoring Equipment ,
This report evaluates a generic concern, three specific employee concerns, and two NRC identified concerns for Sequoyah Nuclear Plant (SQN), regarding radiation monitors, flow controls, and the improper installation of a unit 2 radiation monitor cable. These concerns were determined tc be potentially safety-related by the Employee Concerns Tast Group (ECTG) Technical Assistance Staff (TAS).
II. Specific Evaluation Methodology The employee concern identified to Quality Technology Company (QTC) for a lR4 unit 2 SQN radiation monitor cable is as listed below:
S0P-86-003-001 The radiation monitor cable is not installed properly.
Penetration 23, lower containment, unit 2, modifications. (Names / details known to QTC and withheld to maintain confidentiality). No further information may be released. This is a Nuclear Power concern. CI has no further information.
NRC identified the following issues which pertain to the above concern from review of the QTC file.
SOP-86-003-N04 "CI states more cables (in addition to the radiation monitor cable cited in SQP-86-003-001) may have a similar problem in penetration 23. Integrity of all connectors and associated heat shrink is in question."
This concern refers to cables in addition to the radiation monitor cable cited in SQP-6-003-001.
SOP-86-003-N05 "SQP-86-003-001 is potentially reportable" The issues above were reviewed and the scope was determined to be the adcquacy of cable installation in unit 2, penetration 23 at SQN.
The NRC expurgated file for SQP-86-003 was reviewed for additional information and it was determined that the area of concern was with the coaxial cable connectors being loose. The generic issue of the proper use of Raychem hoat shrink is being addressed by Operations Category Element Report 302.01-SQN and was not addrossed by this evaluation.
The ECN and workplans which performed the modifications to penetration 23 were reviewed and the cognizant modifications engineer was interviewed for details. The ovaluation was conducted at SQN.
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The employee concern identified to QTC fo.c a SQN radiktion monitor is as listed below: ,
KK-85-051-001 >~~ ,
t.
Sequoyah: The radiation monitor (1-RM-90-104) has not + ,
been maintained and is not always operable. Any further information would compromise confidentiality. -
This is a Nuclear Power concern.
The ECTG files were reviewed and a report by NSRS was found which addresses the identified concern.
The following concern was identified to the SQN Employee Concerns Program for air monitor flow controls and was assigned a concern number by ECTG.
CWL-85-001 ,
Why are the air monitor flow controla for 2-RE-90-100 '
a' not listed as either technical specification or ,
compliance instruments? ,
The ECTG files were reviewed and a SQN plant response was fohud which addresses the identified concern. The SQE instrument engineer who prepared the memorandum was contacted for clarifying informat19n.
The following concern identified to QTC for Browns Ferry Nue16er Plant (BFN) was determined generically applicable to SQN:
XX-85-044-001
At BFN there was an accident of Eadiation release on ,
the reactor refuel floor on June 26, 1985. The concern la that Continuous Air Monitors (CAMS) did not function f14 proporly and did not register radiation lovels accurato1y. CAMS are obsolote and~should be replaced -
by modern instruments such as particulate lodine noble gas (PINGS). CI has no'further'information. ' -
4 The concern was reviewed and the scope, with regard to'JQN, was ,
determined to be the adequacy,of airborgo. particulate monitors and whethor they should be replaced by more modarn instruments. These monitors are listed in SQN Final Safety Analysis Report (FSAR) Table 12.2.4-1.
7' The SQN FSAR and monthly Surveillance Instructions (SI) SI-204 were reviewed and informal interviews were coadpeted with per:sonnel in SQN- -
Instrument Maintenance and Division of Nuclear Engineering (DNE) <
Instrument and Control (I&C) Section. The evaluatler of this concern was conducted at SQN. (,
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. v-III. Fladians ,
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SOP-86-Og3-001. SOP-86 -003-N04 and SOP-86-003-N05 The'NRC expurgated file for SQP-86-003 was reviewed and it was IR4 dio' covered that the timeframe of the concern was approximately 3 months before the concornad individual's interview. Although the date of the
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'intnqview SeJ not given, it was assumed in late 1985 or early 1986. An enghneering. change potice (ECN) L6490 (Reference 1) was found which replaced penetratier.p 23 and 48 in late 1985 and early 1986; therefore, this modification was considered as the area of concern. A cognizant
! Modif!ceilona planner indicated that ECN L6490 was implemented by workhtans 11802, 11808, and 11959 for unit 2.
Thelacgnizant' Modifications engineer was contacted and confirmed o that there hdd been some problems with the cable connectors. The
- Jimaisions for trimming the coaxial cable insulation provided by
, the vendor were not adequate to allow proper connection installation.
/
These dimensions were modified by instruction chango (IC) 85-1513 on
! November 27, 1985, with QA concurrence. The engineer confirmed that on'a few occasions, connectors believed properly installed at the
qcd of a shif t were found loose the next day. These connectors had
/ it yet boen terminated and were reworked and inspected by QA before a.0ination and heat shrinking of the Raychem in-line protective The,ingi;oer stated that this only happened a few times
, ,a-i'e!98 h antionly to a y1w cables that could not be terminated before the end of $4e siilft. She normal process was to install the connector, pertirm maggar and continuity checks, and then apply the Raychem shrjniablecoveringbeforectartingthenextcable. QA inspections wore ;&rformed at each step of this process as indicated in the workplan. Any furthor tampering with the connectors would require the obvious removal of the Raychem covering and no cases such as this wore'eser identified. In addition to the megger and continuity checks for each cable, SI-686.2 was performed by instrument maintenance to" functionally check the radiation monitors and return them to operable dentus upon completion of the modification (Reference 3
> and 4). No deficiencies voro identified during performance of the SI oxcept for one monitor being out of calibration. This monitor was recalibrated before its return to operability.
(
Gop11tions adverse to Quality Report (CAQR) No. SQP870178 was issued l March 10, 1)87 because incorrect vendor instructions were identified. l
' Theoa instructions pertained.to installation of shields on Amphenol IR4
, connectors t. hat were being used during preparation for installation of I
/ the'cel.cactors at ponotrations 23 and 48 (Reference 12 and 13). I 1
P
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- > XX-85-051-001 ,
'; ' The NSRS report (Reference 5) on this employee concern was reviewed and adequately addresses the stated concern. The report stated that i 1-RM-90-104 is tagged "out-of-service," and the surveillance instructions are not being performed pending implementation of DCR 1596 to remove the monitor. The report also states that the specified radiation monitor performs no safety-related function and is not g! required to meet any technical specification requirements.
i CWL-85-001 A memorandum was found to the concerned individual from the SQN Instrument Maintenance Section (Reference 9) which stated that the controls in question were for the shield building stack airflow monitor sample pump. According to the SQN instrument engineer who prepared the memorandum, the airflow sample pump and controls are not required since the radiation monitor has its own sample pump and flow controls which are technical specification instruments.
Therefore, the airflow monitor sample pump and flow controls are not required for any technical specification requirements. r
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XX-85-044-001 The SQN /SAR states that continuous airborne radiation monitoring is performed,to comply with 10 CFR 50 Appendix A General Design Criterion 19, 63. 64 and 10 CFR 20.103 (Reference 10). However, these monitors are not required to meet any technical specification requirements.
The cegnizant supervisors in the DNE I&C Section both agreed that the equip?ent in place for airborne monitoring adequately meets the FSAR design t requirements although it is not state-of-the-art. The supervisors also stated that two PINGS are in place for effluent monitoring (condenser vacuum exhaust and shield building exhaust) and it was their understanding that instrument maintenance has had significant problems calibrating them. ;
A cognizant instrument maintenance engineer and an instrument mechanic foreman were contacted and confirmed problems with calibrating Eberline PINGS. The Eberline equipment is digital cnd the General Atomic CAME are much more reliable to operate and maintain.
They both stated that the CAMS were not technical specification instrumentation, however they'ere maintained by sis weekly, monthly, and on 18-month intervals as stated in the FSAR. They both agreed that the CAMS were adequate to meet the design requirements and believed that-changing to PINGS would reduce the reliability of the system. There has been discussion about replacing the Eberline PINGS because of the reliability / maintenance problems although no decisions have been made at this time.
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' #e b A ' spot check of SI-204 " Data Packages," from January through .
Yarch,1986, revealed no CAMS out of calibration (Reference 11).
L 10' L Conclusion
- 1. The issues presented by SQP-86-003-001, SQP-86-003-N04 and SQP-86-003-N05 were'not validated and no safety-related deficiencies were identified. RSome radiation monitor cablu connectors were found
/N loose during the modification, but were corrected and inspected by QA A. before termination. Megger and continuity checks and surveillance
- testing were performed be!' ore return to service to ensure pecper
- ' installation of the cables in penetration 23.
3 CAQR No. 'SQP870178:was issued March 10, 1987 because incorrect l vendor instructions'were identified during preparations for IR4 installation of Amphenol connectors at penetrations 23 and 48. l
- 2. The issue presented by concern XI-85-051-001 was validated by the NSRS reportg and this report; however, the monitor is not a IR4 technical specification instrument, nor is it a compliance instrument, nor is it used in any analysis to detect or mitigate an accident. In addition, the monitor performs no automatic safety function depecded upon during a fuel failure accident.
The monitor is currently scheduled to be removed by DCR 1596, t
therefore, failure to maintain the instrument is of no safety significance.
3.- The issue presented by concern CWL-85-001 was not validated and no safety-related deficiencies were identified. The airflow sample
- . pump controls are not required for operation of 2-RE-90-100. The radiation monitor has its own separate sample pump and controls
! _w hich are technical specification instruments.
- 4. 'The issue presented by concern XX-85-044-001 could not be validated for SQN and no safety-related deficiencies were identified.by this evaluation. The. personnel contacted in DNE and SQN Instrumont Maintenance were in agreement that i.
the CAMS are adequate to meet the design requirements for
~ airborne monitoring as discussed in the FSAR, and based on their experience, are more reliable than the PINGS used for
,- other opp 11 cations st SQN.
h i IV. Root-Cause I
llo deficiencies were identified by this evaluation, and thus root y
cause is not identified.
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V Generic Applicability .
Concern SQP-86-003-001, SQP-86-003-N04, and SQP-86-003-N05 were l l determined to be not valid regarding the concern specifics. The issue l identified regarding incorrect vendor instructions will be evaluated for lR4 generic applicability by CAQR SQP 870178 and tracked by CATD 30305-SQN-04. l IK-85-051-001, and CWL-85-001 are not considered generic to any other i plant because they identify specific concerns related to SQN. l XX-85-044-001 has been evaluated for BFN and SQN with no negative finding,s . Based on this, there is no reason to suspect a safety-related deficiency at either WBN or BLN. Therefore, this concern is not considered generic to WBN or BLN. l VI. References
- 1. Engineering Change Notice (ECN) L6490 (B25 860114 542)
- 2. Workplan 11802 and 11808
- 3. SI-686.2, R3 " Channel Calibration for High-Range Accident Radiation Monitors," November 1, 1985
- 4. SI-686.2, " Data Package," February 3, 1986 SRO Approved and Complete
- 5. Nuclear Safety Review Staff (NSRS) Investigation Report I-85-613-SQN, "Naintenance and Operability of Process Radiation Nonitor 1-RM-90-104 " November 26, 1985
- 6. Memorandum from H. L. Abercrombie to K. W. Whitt, Plant Response to NSRS Report I-85-613-SQN, dated December 20, 1935
- 7. Memorandum from K. W. Whitt to H. L. Abercrombie, Corrective Action Response Evaluation to NSRS Report I-85-613-SQN, dated February 13, 1986
- 8. Design Change Request (DCR) P-1596, September 15, 1983
- 9. Memorandum from H. D. Elkins to Marvin Phillips, Response to l Employee Concern, dated December 10, 1985
- 11. SQN SI-204, "Deta Packages." January 10, 1986 February 7, 1986, and March 8, 1986, " Functional Tests of Radiation Monitoring System Channels (No'i' bly)," Data Sheet 3
- 12. SQN CAQR No. SQP870178; dated March 10, 1987; Revision 0. lR4 l 13. Telephone Call and Visit Report (TVA form 5875) by Dan Ford, NRC l Inspector, "NRC Concerns or TVA Element Report 303.05," dated lR4 March 5, 1987. l Page 6 of 7 m
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- R3risics 4 y VII. 'Isumediate or Long-Term Corrective Action ,
Although no safety-related deficiencies were. identified by this evaluation _ report, the NSRS report conducted for XI-85-051-001 made some recosunendations -to SQN with regard to expediting DCR 1596 and revision to sis to clearly distinguish between nontechnical specification monitors-and technical specification monitors by locating'them within
-separate sis. The SQN response (Reference 6) stated that the current DCR implementation _ schedule was justifiable since the monitors performed no safety functions and that providing separate sis placed an undue burden on the plant staff. The NSRS accepted this response-(Reference
- 7) after SQN agreed to revise the sis to eletely denote technical specification and nontechnical specification monitors within-the SI.
This is indicated in the SQN Corrective Action Plan (CATD 30305-SQN-01) which states:
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sis associated with radiation monitors will be revised to clearly distinguish between Non-Tech Spec and Tech Spec monitors.
In response to problems with PINGS, (CATD 30305-SQN-02) the SQN Corrective Action Plan states:
Factory representative from Eberline Rad Nonitor will be requested to assist in correcting inherent problem with PING monitor control room control terminal and also provide IN with class-on
. troubleshooting techniques and system description.
CAQR No. SQP870178 was issued March 10, 1987 for deficiencies identified , l concerning Amphenol connector installation. CATD 30305-SQN-04 was issued lR4 to track this CAQR and associated corrective action. 1 t
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