ML20204G430

Rev 3 to TVA Employee Concerns Special Program Sequoyah Element Rept 309.01-SQN, Adequacy of Procedure

ML20204G430
Person / Time
Site:	Sequoyah
Issue date:	03/17/1987
From:	Elliott W, Russell Gibbs, Russell J TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20204G202	List: ML20204G199 ML20204G237 ML20204G282 ML20204G330 ML20204G377 ML20204G409 ML20204G430
References
309.01-SQN, 309.01-SQN-R03, 309.01-SQN-R3, NUDOCS 8703260395
Download: ML20204G430 (9)

Text

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.l, a TVA ERPIhYEE CONCERNS REPORT NUMBER: 309.01-SQN

. SPECIAL PROGRAN REPORT TYPE: Sequoyah Nuclear Plant - Element REVISION NUMBER: 3 ,

TITLE: Adequacy of Procedure REASON FOR REVISION:

To incorporate TAS and SRP Conunents Revision 1 To incorporate SQN Corrective Action Response Revision 2 To incorporate NRC Conunents Revision 3 PREPARATION PREPARED BY:

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SIGNATURE DATE REVIEWS

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~ SIGNATURE XbS/87

/ DtIE CONCURRENCES CEG-N: yfW C4 ]f/3/h1 SRP: W e '7-37 SIGNATURE DATE SIGNATURE

• DATE APPROVED BY:

5 Wh/ kd M N/A ECSP MANAGER $ [ ATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)

• SRP Secrotary's signature denotes SRP concurrences are in files.

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'4 TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT EMPLOYEE CONCERNS TASK GROUP OPERATIONS CEG Subcategory: Engineering Element: Adequacy of Procedure Report Humber: 309.01-SQN Revision 3 IN-85-977-001 4

Evaluator: Tim Massey M)D ._f "/3-87

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Tim Nassey Date '

Reviewed by: AMIN I /# S-Lf-f 7 Date OPS CEdf fidiber Approved by:

W. R. Lagergren Date

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• RIvisien 3 I. ADEQUACY OF PROCEDURE ,

This report evaluates the concern addressing the implementation of programs to identify and replace the teflon tape used on the reactor coolant system and those systems that return to the reactor coolant system at Sequoyah Nuclear Plant (SQN). The programs and procedures must identify the unacceptable locations of the teflon tape and stipulate replacement with another type of acceptable material where required. This program implementation has been generated by TVA management who stated that this tape replacement shall occur.

II. SPECIFIC EVALUATION METHODOLOGY Concern IN-85-977-001 states: "TVA management has stated that teflon tape which was used on the reactor coolant system must be identified and replaced with another type of tape, however, no program to accomplish this task has started."

A review was performed of the division and plant procedures, the Nuclear

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Safety Review Staff (NSRS) inspection report (I-85-383-WBN), the  ;

operating experience review, and associated memorandums. Supervisors, planners, and foreman were interviewed for knowledge of the use of teflon tape.

The above referenced NSRS report was reviewed to determine its adequacy and completeness with relation to the above stated SQN generic employee concern.

III. FINDINGS An employce at Watts Bar Nuclear Plant (WBN) expressed a concern that management had said teflon tape was not acceptable to use at the plant, but nothing was being done to correct the problem. An Operating Experience Review (OER), SQN850088001 was issued in February 1986, at SQN for the problem to be addressed.

A review of the documents governing use of teflon tape was conducted.

These are listed in the reference section of this report.

Type TFE teflon tape is generally used in applications where the temperature is less than 400*F. When the temperature exceeds this value, the properties begin to change, thus allowing the possibility of leakage. When TFE teflon is used where radiation doses exceed 10 4 RADS, flourine is released.

General Construction Specification, G-29 and Division Procedure Manuala l (DPM) N73E1 and N73M2 restrict the use of teflon tape to a maximum lR3 temperature of 300*F and a maximum radiation dose of 10 4 RADS. These procedures go on to say that this tape is not for use on lines that Page 1 of 5

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L. x . Rsvision 3 xFINDINGS (con't)' ,

re-enter the reactor system. Plant procedure.SQN SQA-160,, Revision 4 reflected the.same procedure. Grafoil tape is listed as acceptable for any circumstances; however, it is not practical for use in all situations.-

'The Chemical Engineering Section performed a walkdown of the' reactor coolant system chemical sampling lines, the chemical volume and control system sampling lines .and the post accident sampling lines on both units and discovered 26~ problem locations. Of the 26, two were determined to exist'in' locations where the temperature is greater than 300*F and the accident condition dose rate exceeds 104 RADS. Work.

requests B111371 and B113880 were. initiated and worked to remove the teflon' tape on the two locations identified above. The remaining 24, do

not violate the radiation dose requirement.or the temperature requirement;

however, they do violate the requirements that specify that the tape should not be used on lines'which re-enter the reactor system.

This is discussed in the evaluation of OER SQN850088001.

Nemorandum from' Metallurgical Engineering to Nuclear Engineering and OER

'SQN850088001, I-85-383-WBN Attachment Z references testing currently

- being performed to find an acceptable substitute for teflon tape. The -

testing. program being conducted by DNE, is being performed to retest existing thread sealants and qualify other sealants for use. This testing is to take from 6 to 12 months. When the testing is complete, a.

walkdown will be performed to identify the areas where teflon tape is installed but is outside the-scope of the experience review SQN 850088001, which was generated by the WBN concern. The target date at SQN for this work is the unit 2 cycle 4 refueling outage.

Interviews were conducted with planners, foremen, a general foreman and

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1 an engineer. The-planners, foremen and general foreman all indicated that they did not know that teflon tape had only certain acceptable applications before the areas were identified to have the tape removed.-

The engineer stated that he knew it was not acceptable for certain applications and that he felt implementing procedures were not adequate for controlling the tape. The planners, foreman and general foreman said that its use should be addressed in the planning of the work either i .by a working level instruction or in the planning of the work request.

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! The steamfitters have been instructed not to use teflon tape inside the j Reactor Buildings. A memorandum was issued to the general foreman to W direct his workers not to use the teflon tape in the Reactor Buildings.

OER SQN850088001 provides the means by which.the testing is being i conducted and tracked. When substitutes are found, this same OER will

]. be used as the implementing device. Currently, the Division of Nuclear Engineering (DNE) has Singleton Lab testing different thread sealants.

Subsequent to the initial evaluation and the Corrective Action Plan l (CAP), indicated in section VII, some questions were raised by the NRC. l Additional information was obtained in response to questions concerning IR3 g the proposed corrective action. I j

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- Rsvisicn 3 FINDINGS (con't) ,

It was determined that teflon tape is not a. problem if used within the- I environmental limits, regardless of which system it is used on. l Revision 5 of SQA-160 removed the restriction prohibiting use of l teflon tape on,any lines that.will reenter the reactor system. The ,

l removal of this requirement creates an inconsistency with the upper tier l requirements in G29, DPN N73E1 and N73N2. l l

The requirements in revision 5 of SQA-160 will over ride DPN N73E1 until l the DPM is revised to reflect the same requirements. This is allowed.by l plant procedure SQA-188 and a cover sheet is attached to revision 5 of l SQA-160 documenting headquarters endorsement in lieu of the upper-Lier l document indicated on the. cover sheet. The cover sheet indicates l DPN N73E1 but does not indicate G-29 or DPN N73N2. Therefore an l inconsistency still exists between SQA-160 and upper tier documents l G-29 and DPN N73N2. l l

The requirements of G-29 are applicable to SQA-160 since G-29 is a l Division of Nuclear Construction (DNC) Document and Modifications, l which is a branch of DNC, uses SQA-160. l lR3 The disposition of OER SQN 850088001 indicates an environmental l drawing prerequalte will be imposed on teflon tape usage. 'A1 discussion l with OER tracking personnel revealed that this prerequaite has not been l implemented and remains an open item on the OER. l I

A Condition Adverse to Quality Report, (CAQR) SQP 870155 was initiated l on March 9, 1987 which identifies the lack of a " consistent policy or i program to identify, control, and eliminate improper usage of l teflon tape". l l

CONCLUSIONS l l

The teflon tape on RCS related components which was unacceptable has l-been identified and replaced. However, a program to identify and l replace the tape'in all unacceptable locations and-to prevent it's use l in these areas has not been established. Although SQN has a standard l practice which specifies when teflon tape can be used, this has proven I ineffective. To prevent teflon tape reinstallation in the unacceptable l locations,' plant personnel must be familiar with its acceptable uses. l Implementing procedures should be initiated which address what thread I sealants and lubricants can be used and the application restrictions l of their use. It appears that an environmental drawing prerequalte is l essential since the usage criteria is based upon the environmental l conditions of components on which the tape is used. l Page 3 of 5

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R visica 3 CONCLUSION (con't) .

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The specific concern that no program has been established to identify l and replace teflon tape en the RCS is not valid. However, the issue of l preventing the use of teflon tape in all unacceptable locations is -l valid. The present approach by SQN in allowing limited, controlled lR3 use of teflon tape is not consistent with the WBN and BFN approach as l indicated in OER SQN 850088001. CATD 30901-SQN-02 has been written for l

{ tracking purposes concerning CAQR SQP 870155. I i

j IV. ROOT CAUSE j The absence of implementing procedures and unfamiliarity with j SQN/SQA-160 requirements aided in the misapplication of teflon tape.

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I V. GENERIC APPLICABILITY i

This concern has been determined to be applicable to all TVA nuclear plants. Because of the findings cited, these conditions could exist at

, other plants.

VI. References

1. DPM Division Procedure Manual N73M2, Section 4.M.1.1., Revision 9, January 24, 1985

2. SQN SQA Standard Practice 160, Revision 4, dated July 13,1986 k 3. NSRS Inspection Report I-85-383-WBN, dated October 10, 1985,

, contained in OER SQN 850088001 i

! 4. Operating Experience Review, OER SQN 850088001, dated

] February 18, 1986

5. Unimplemented Design Item Evaluation, from H. L. Jones, Nuclear Lead Engineer to SQEP Projecti Files dated June 2,1986, (B25 860620 002) 1 6. Memorandum from K.E. Cooper, Netallurgical Engineer to Nuclear j Engineering Branch Files Use of Pipe (" Teflon") Tape at TVA Nuclear j Plants, dated April 18, 1986, (B45 860418 251) f h 7. Memorandum from C.2. Belmer, Nanager Site, Services to B. M.

1 Patterson, Maintenance Superintendent, "Sequoyah Nuclear Plant -

p Justification for Continued Operation for Teflon Tape Presently J Installed," dated April 18,1986, (S01 860716 931) i 1

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8. Memorandum from C.R. Brimer, Manager Site Services to P. R. Wallace, '

Plant Manager " Watts Bar Nuclear Plant - Review of Operating Experience Review Item No. I-85-383-WBN " dated February 19, 1986 (S01 860219 834)

9. Memorandum from J. C. Standifer, Project Manager, Watts Bar Engineering Project to G. Wadewitz, Project Manager Watts Bar Nuclear Plant " Watts Bar Nuclear Plant Nonconformance Report (NCR)

.No. W-231-P, Revision 0 Inappropriate use of Teflon Sealant Tape,"

dated May 9, 1985, (B45 850509 254)

10. Memorandum from E.R. Ennis, Plant Manager, Watts Bar Nuclear Plant to Guenter Wadewitz, Project Manager, Watts Bar Nuclear Plant.

" Watts Bar Nuclear Plant-Nonconformance Report W-231-P, dated May 1, 1986, (T07 850426 894)

11. Memorandum from R. A. Sessoms, Project Manager Environmental Qualification Project to H. L. Abercrombie, Site Director, Sequoyah Nuclear Plant, " Thread Sealant / Lubricants for Use on Solenoid Valve Interface Connections with Airline," dated February 6, 1986 (B70 860206 004)

12. SQN Condition Adverse to Quality Report (CAQR) SQP 870155, IR3 March 9, 1987. I VII. IMMEDIATE AND LONG-TERM CORRECTIVE ACTION The SQN Corrective Action Plan states: (CATD-30901-SQN-01)

Revise SQN standard practice SQA 160 to clarify limitations of teflon tape. Also. issue memorandum to employees who may use teflon tape advising of the restrictions on teflon tape application. These two action items will be tracked by management action tracking system (MATS) assignment numbers 9357 and 9356 respectively.

CATD 309Cl-SQN-02 has been issued to track closure of CAQR SQP-870155. IR3 i;

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REFERENCE - ECPS120J-ECPS121C TENNESSEE VALLEY AUTHORITY RUN TIM'g'6-FREQUENCY - REGUEST OFFICE OF NUCLEAR POMR RUN DATC EW LOYEE CW CERN PROGRAM SYSTEM (ECPS) g DNP - IS$$ - RW LIST OF EWLSYEE CONCERN INFSAMATION t

. CATE00RY: OP PLANT OPER. SUPPORT SUSCATf00RYs 30901 ABE40ACY OF PROCEDURES

• KEYHORD A

! S OENERIC KEYHORD E Q. N APPL STC/NSRS P KEYHORD C i '

SUB R PLT BBSM INVESTIGATION- S CONCERN KEYHORD i

CONCERN REPORT R DESCRIPTION NUMBER CAT CAT D LOC FL45 NONCONFORMAt*C 30901 N NSN YYYY I-85-383-MSN NS TVA MANAGEMENT NAS STATED THAT TEFLO IN 977-001 OP REPORT N TAPE NNICH HAS USED ON THE REACTOR CORRECTIVE T50lI2 CONSTRUC7 i

' C90LANT SYSTEM (RCS) MUST BE IDENTI TUBIRG FIES AND REPLACES WITH ANOTHER TYPE 3 SF TAPE, MONEVER, NO PROGRAM TO ACCO i

W LISM TNIS TASK HAS STARTED. CI HA l

S NO ABBITIONAL INFORMATION. NO FOL L9N UP REGUIRES.

! y 1 1 CONCERNS FOR CATEGORY OP SUBCATEGORY 30901 l .

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INITIATION Applicable ECSP Report No 2 : 309.01 SON

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N 1., #I mmediate Corrective Action Required: O Yes  % No i 2'l Stop Work Recommended: O Yes pf No ri 3. g CATD No. 3090_1-SON-02 , 4. INITIATION DATE 3-12-87 3

% 5. RESPONSIBLE ORGANIZATION: JSequoyah -

'q 6. PROBLEN DESCRIPTION: d QRWNQR SON has no consistent program - _

V or policy to: identify.~ control and eliminate improper usage of teflon tape. This is identified in C&OR SOP-870155 and this CATD is issued to track the closure of-this item.

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i_ _ eL O ATTACHRENTS l s. ,7 . -i'REPARED BY: NAME ,,4/el 286 ZT , DATE: 3 -/3-8'7

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9. APPROVAL: ECTG PR0d KN'NGR. # g.#.(E 4- DATE: 7//4 /e 7

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CORRECTIVE ACTION L  :

LO 10. PROPOSED CORRECTIVE ACTION PLAN:

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13. Approved corrective actions have been verified as satisfactorily j implemented.

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