ML20204J879
| ML20204J879 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Sequoyah |
| Issue date: | 03/16/1987 |
| From: | Murphy M, Russell J, Sutt R TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML082280289 | List: |
| References | |
| 1631T, 308.01-SQN, 308.01-SQN-R02, 308.01-SQN-R2, NUDOCS 8703270324 | |
| Download: ML20204J879 (13) | |
Text
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TVA EMPLOYEE CONCERNS REPORT NUMBER 308.01-SQN SPECIAL PROGRAM fx l
REPORT TYPE:
Sequoyah Nuclear Plant - Elernent REVISION NUMBER:
2 TITLE: Adequacy of Procedures REASON FOR REVISION:
Revised for incorporate SRP and TAS conunents Revision 1 Revised for incorporation of NRC conunents Revision 2 PREPARATION PREPARED BY:
- /I TURE~
Jf//f87 R. 3. Sutt d
' 4 ATE REVIEWS PEER:
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SIGNATURE
'DATE WY 3}z/h7 F
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SI'GNATURE
/DP/E CONCURRENCES CEG-H :t 4/4 SRP:
N 3'lh-8 7 SIGNATURE DATE SIGNATURE
- DATE APPROVED BY:
sA5@ C 3/4dsq N/A ECSP MANAGER DATE
MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)
- SRP Secretary's signature denotes SRP concurrences are in files.
1631T
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TENNESSEE VALLEY AUTHORITY SEQUOYAH BAR NUCLEAR PLANT EMPLOYEE CONCERNS TASK GROUP OPERATIONS CEG Subcategory: Maintenance Element: Adequacy of Procedures Report Number:
308.01 - SQN Revision 2 SQP-6-009-004 SQP-6-014-001 MAS-86-001 TAK-85-002 TAK-85-004 Evaluator:
M. D. Stutz 10/22/86 M.
. Stutz Date Evaluator:
ad J / f/
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' D6te Reviewed by:
4# 8//
J///!ff OP CE6 Mosber Date 4
Approved by:
W. R. Lagergren Date 1631T
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R;visics 2 I.
Title _ Adequacy of Procedures This report evaluates six concerns involving the adequacy of maintenance instructions at Sequoyah Nuclear Plant.
II.
Specific Evaluation Methodology Concern NAS-85-004 states:
" Adequacy of MI-10.48 (Motor Lubes)"
Concern MAS-86-001 states:
" Adequacy of MI-6.20" Concern TAK-85-002 states:
"M&AI-9 does not specify torque for screws less than #10" Concern TAK-85-004 states:
" Lubrication of geared limit switches on MOVs not properly inspected."
Concern SQP-86-009-004 states:
" Maintenance instructions are unclear
-and do not provide adequate instruction. Details known to QTC, withheld due to confidentiality. No further information may be released. Nuclear Power department concern."'
Concern SQP-86-014-001-states: " Foreman do not always support the craft in providing them with everything they need to do the job, e. g.
required prints. Nuclear Power concern. CI has no further information."
These concerns were evaluated by reviewing appropriate TVA oocuments and procedures, regulatory requirements, industry standards, and manufacturer instructions.
From the electrical maintenance section, one supervisor, two engineers, and two craftsman were interviewed. One mechanical maintenance engineer was interviewed.
III. Findings Evaluation Results A.
MAS-85-004 The procedures for lubrication of motors at Sequoyah are basically taken from vendor manuals. Electrical Maintenance was made aware that MI-10.40 was inadequate in that the procedure was generic and did not specifically address each motor manufacturer's requirements and a Discrepancy Report (SQ-DR-86-01-003R) was written on the procedut e.
The DR has been dispositioned in that the Maintenance
' l R2 instruction (MI) has bet-lR2 Page 1 of 9
'R:visica 2 rewritten and motor lubrication instructions are provided in
- NI-15.2.1'. 15.4.1, and 15.6.1 which were approved June 30, 1986..
The procedures now address the requirements of different motor-manufacturers specifically. NI-10.48 was cancelled on November 5,
~1986 after it was determined that all motor vendor requirements had been addressed.
'B.
NAS-86-0011 NQAN, Part II, Section 2.1 requires a means to_ control changes in design configuration during trouble shooting, MI-6.20 contains a-data sheet for logging changes in design configuration primarily during trouble shooting with signoffs and second party verification
(
for removal and return to normal. This data sheet is then' attached' to the Maintenance Request (NR) initiating the work. The NI lR2 contains instructions for filling out the data sheet and gives examples of the types of work which require entry into this data sheet. Additionally, MI-6.20 meets the guidelines' presented in INPO l Guideline 85-017 Conduct of Operations, chapter 13. " Control of IR2 Temporary Nodifications."
l C.
TAK-85-002 N&AI-9 was completely rewritten in revision 5 (December 17, 1985) to reflect the new electrical torquing and bolted connections requirements in.the newly revised G-38 specifications. Section 3.5.6 of G-38 states that screws size #10 or smaller used in cable splices and terminations shall be tightened to the point at which the lockwasher'is flattened. No torquing values are given for screws'in this category. NQAN, part II, section 2.1 states that the-plant maintenance program objective shall be to maintain each item of the CSSC to ensure quality at least equivalent to that specified_in the original design, material specifications, and inspection requirements.
Craft personnn. Interviewed did not express any problems with this section of the Modification and Additions Instructions (M&AI).
lR2 D.
TAK-85-004 Limitorque Corporation has experienced problems with the lubricant (Beacon 325) originally' furnished in the geared limit switches of their valve operators in high temperature environments. Sequoyah has encountered hardening of this lubricant in a few safety-related operators and has initiated a WR/MR to change out the grease in the geared limit switches of all safety-related Limitorque operators to Notil Grease 28, which is recommended by Limitorque as a replacement lubricaat. This is required to be complete before restart, however, Unit 2 is complete and only a few operators remain on Unit 1.
Page 2 of 9 j
-Ravisica 2'
'The'Sequoyah preventive maintenance program calls for inspection of the. lubricant in the geared limit switches for quantity, quality,-
and consistency atL18-month intervals as recommended by Limitorque.. Engineering personnel can be called in for evaluation. -
-if the craftsmen is unable to determine acceptability ofLthe lubricant.- Although the grease in the limit switch gears of the nonsafety-related operators ls not being. changed out-at-this time.
they are included in the PM program and have the same. inspection-requirements as the safety-related operators.
If' hardening is discovered during the inspection, the grease-in that particular.
-operator will be changed.
The procedure.used for inspecting the lubricant in the geared limit l.
switch is MI-10.46, Limitorque Motor. Operator / Control Valve. The l'
procedure'is:used for both inspection and maintenance of Limitorque-lR2 Actuators..This procedure specifically requires craft to inspect l
and touch grease to verify it is soft and buttery and free of l
contemination. If grease is hard, craft is instructed to inspect l
gears for damage. Grease must then be replaced with QC verification. l E.
SQP-86-009-004 A detailed review and reassessment of maintenance performance was l
performed in March of 1984 as stated In the Sequoyah Nuclear l
Performance Plan. This review included findings contained in l
Systematic Analysis of Licensing Performance (SALP) reports, Nuclear l Regulatory Commission (NRC) violations, Licensing Event Reports-l (LERS), Institute of Nuclear Power Operatione (INPO) evaluations,
-l and internal findings. This report concluded that several areas of l
maintenance were deficient. To further assess the maintenance l
programs, the Nuclear Hanager's Review Group (NMRG) was organized in l
April of 1986 to conduct a comprehensive assessment of maintenance l
practices at SQN.- This group of approximately 25 managers with l
experience in. maintenance, reviewed the' entire procedure program I
basing their evaluation from the INPO Guidelines for Evaluation of l
Maintenance Procedures. The results of this evaluation found that:
l Some instructions were not clear, were not concise and did i
not contain the information necessary for users to understand lR2 and perform work activities effectively.
l S. A. White responded to this report in a memorandum (001-86-1001-l 800) stating that he wants maintenance practices at TVA to be among l
the best in the nuclear industry. He has directed line management l
to followup and correct these problems as identified in the NMRG l
Report. The NMRG recommendations could be follcwed or alternate I
measures could be taken as appropriate. As a followup, the NMRr l
will review maintenance again in the future to check if problems l
have been corrected.
l
,!=
i Maintenance management at SQN has developed a program for maintenance i j
instruction enhancement which is currently ongoing. The procedures tol be enhanced have been prioritized as to their importance.
l Page 3 of 9 k --
Rtvisicn 2
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A writer's guide was developed for maintenance procedures using the.
l INPO Guideline 85-026 and NUREG-CR1369 as a base document. Upon
.I completion of each procedure, a walkdown will be performed and an l
Instruction Review Sheet will be completed by the craft indicating anyl problems encountered when working to these instructions.
l Maintenance has committed to completing this program in two phases as l documented in a letter to Licensing (S 53870/02926).. The first phase l is procedures that are considered in a high risk category as l
determined by Maintenance management.
Completion of this phase is lR2 scheduled for eight months after startup. The lower risk procedures l
in the second phase are scheduled for completion 21 months after' I
startup. This schedule is being tracked on the Management Action l-Tracking System (NATS).
-l A review was performed on a small sampling of procedures previously l
evaluated in the other concerns of this element-to determine the lR2 quality of the procedures currently being used.
l MI-10.48 was evaluated in concern NAS-85-004 and was determined by the cognizant section to be inadequate. This instruction has been rewritten to conform to vendor maintenance instructions.
MI-6.20 was evaluated in concern MAS-86-001 and meets the requirements of the NQAM.
M&AI-9 was evaluated in concern TAK-85-002 and meets the requirements of G-38.
MI-11.2 was evaluated because it was associated with concern TAK-85-004.
This MI was very detailed (more so than the vendor instruction manual) and included detailed sketches throughout the instruction to aid the craftsman in performing maintenance on the operator.
Craft personnel interviewed did not express any problems with these
. maintenance instructions. If problems do arise with a particular instruction, they felt the necessary changes would be made.
Craftsmen are provided a place on the Instruction Review sheet, Appendix E of SQM-2, to recommend changes to the instruction used to perform the work.
Also, the NQAM, Part III, Section 1.1 requires plant instructions be reviewed no less frequently than overy two years to determine if changes are necessary or desirable. The instructions evaluated had all been revised within the last six months.
Page 4 of 9
i R;visica 2 l
F.
SQP-86-014-001 SQM-2 controls the Work Request (WR) process at Sequoyah. Sequoyah utilizes planners (formerly craft personnel) to plan out the work requested by the WR/MR, which includes making up the WR package.
The responsible foreman ensures the WR package is complete and all necessary instructions are included. The foreman and the responsible craftsmen sign the Instruction Review Sheet verifying the instructions included are adequate for performing the work.
The inclusion of necessary drawings in the WR package is not addressed in SQM-2.
The planner only includes the required drawings in the WR package l
when he marks them up to provide instructions for that package I
(1.
e.,
showing craft where to cut pipe). Normally the planner lR2 will only provide the drawing number either in the work package or i
the work instructions. Craftsmen are responsible for acquiring the l
drawings necessary to perform the work.
l According to craft personnel interviewed, there were some problems with WR packages being incomplete when the planner concept was first initiated, but they felt WR packages now contain the correct material. No problems with foremen providing correct work material, ie, prints and drawings, were expressed.
Conclusions A.
MAS-85-004 The concern that MI-10.46 was inadequate was validated. However.
l the problem was identified via Discrepancy Report SQ-DR-86-01-003R l
and correcteo prior to this evaluation. New procedures were lR2 written (MI-15.2.1, 15.4.1, and 15.6.1) which address vendor l
requirements sp$cifically. MI-10.48 which was a generic i
procedure, has been cancelled.
Corrective action via l
SQ-DR-86-01-003R h3s been accomplished and this concern has no i
further safety significance.
I B.
MAS-86-001 The concern that MI-6.20 is inadequate was not validated. This MI meets the requirements of the NQAM. This also meets the guide-l lines of INPO 85-017, Conduct of Operations, chapter 13, Control lR2 of Temp Mods. A data sheet is provided in the instruction for l
entering configuration changes during trouble shooting and detailed instructions of how and when to fill out.the data rhest are provided.
Page 5 of 9
R3vicien 2' s -
C.
TAK-85-002 The concern was not validated because M&AI-9 not specifying torque for. screws less than #10 is in agreement with General Construction' Specification G-38, and being in line with G-38 meets the
, requirements.of-the maintenance program in the NQAM. The craft
-personnel interviewed did not express any problem with this item.
D.
TAK-85-004 The concern that the lubrication of geared limit switches on-NOVs-is not being properly inspected was not validated. Sequoyah is in the process of changing out the lubricant in the geared limit switches of all safety-related Limitorque operators because of problems with the original lubricant furnished. This is a required restart item and presently, unit 2 is complete and only a few operators are' remaining on unit 1.
The Sequoyah preventive maintenance program for Limitorque operators is in line with manufacturer's recommendations.
E.
SQP-86-009-004 The concern that maintenance instructions are unclear and do not I
provide adequate instructions was found valid based on the findings l
in the NMRG Report R-86-02-NPS.
SQN has begun a Maintenance Procedure l Enhancement Program that will ensure all upgraded Maintenance l
Procedures meet the requirements of their Writer's Guide which was l
based on INPO Guideline 85-026 and NUREG-CR 1369. Many of the l
procedures currently being used that have not.been upgraded are l
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being validated by Maintenance Management to ensure procedures are l
satisfactory, both technically and administratively for their lR2 current use.~
Those procedures will eventually be upgraded to the l
Writer's Guide according to the schedule. The schedule for phase I
one'(higher risk procedures) is to be completed eight months after l
startup. Phase two (lower risk procedures) is' scheduled for I
completion 21 months after startup. This schedule is being tracked l
on the Management Action Tracking System (MATS). CATD 30801-SQN-001 l
was written to track closure of this effort. If the craftsman l
q has a problem with any.of the procedures he is using, his means of l
recommanding changes to these instructions is by completing the i
3 j
Instruction Review Sheet and submitting it to his foreman.
l F.
SQP-86-014-001 The concern that foremen do not always support the craft in providing them with everything they need to do the job, e.g.,
i required prints, was not validated.
SQM-2 requires the planners to I
provide the needed material in the work package. SQM-2 r
specifically requires the needed instructions be included in the work package but does not address required prints. The planners I
are providing the correct material, for the craftsmen to perform the job specifically in the case of drawings, either the correct l
drawing or the drawing number is supplied, i
t Page 6 of 9 L
R;visicn 2 IV.
Root Cause The root cause of concern MAS-85-004 is that the procedure was written for the generic lubrication of motors and did not specifically address the lubrication requirements of each Sequoyah motor vendor.
In the past the basic philosophy for maintenance procedures (in l
reference to SQP-86-014-001) were to write them generically so I
they can be used for any situation that may occur or for several I
similar types of equipment. By writing them to these requirements, the l
performance of work is left up to the skill of the craftsmen. This lR2 philosophy does not give adequate direction to the craft and does not l
provide a method for sufficient documentation of the work completed to l
ensure it was performed correctly. Industry philosophy is changing to l
writing procedures that cover specific equipment with verifiable l
acceptance criteria.
l V.
Generic Applicability Concern MAS-85-004 is not applicable to the other plants. MI-10.48 has been rewritten from a generic lubrication procedure to one that addresses specific motors at SQN.
Concern NAS-86-001 is not applicable to the other plants.
MI-6.20 specifically addresses configuration control procedures at SQN.
Concern TAK-85-002 is not applicable to the other plants. M&AI-9 specifically addresses torquing requirements at SQN.
Concern TAK-85-004 is applicable to BFN, WBN, and BLN. These plants all have Limitorque operators and are subject to the same inspection requirements.
Concern SQP-86-009-004 will not be evaluated at the other sites because l
of the action already being taken. There is currently a Maintenance lR2 Procedure Enhancement Program being performed at all sites.
I Concern SQP-86-014-001 is not applicable to the other plants. The procedures for handling work packages at SQN are specific to this plant.
VI.
References 1.
NQAM, Part II, Sec. 2.1 RO 2.
NQAM, Part III, Sec. 1.1 RO 3.
10 CFR 50.49 Code of Federal Regulations - Environmental Qualification Revist4 January 1, 1985 4.
ANSI B31.7 1971 Addenda to Nuclear Power Piping Page 7 of 9
R;visics 2 5.
General Construction Specification G-38 Installing Insulated Cables Rated Up to 15,000 Volts R8 6.
SQM-2 Maintenance Management System R18 7.
UL 486A Standard For Wire Connectors And Soldering Lugs For Use With Copper Conductors Seventh Edition 8.
UL 4868 Standard For Wire ConneGors For Use With Aluminum Conductors First Edition 9.
M&AI-9 Inspection of Bolted Connections R7 6
10.
MI-11.2 Motor Operated Valve Adjustment Guidelines R18 11.
MI-10.48 Relubrication Of Motors R1 12.
MI-6.20 Configuration Control During Maintenance Activities R8 13.
MI-15.2.1 Lubrication Of Reliance Motors RO i
14.
MI-15.4.1 Lubrication Of Allis Chalmers/Siemens-Allis Motors R) 15.
MI-15.6.1 Lubrication of Westinghouse Motors R0 16.
Limitorque Type SMB Instruction And Maintenance Manual l
17.
Letter to L. N. Nobles from M. R. Harding, Schedule For
- l l
Maintenance Procedure Enhancement, dated February 10, 1987 l
(SS3870/02926) lR2 h
18.
NMRG Report R-86-02-NPS, dated September 30, 1986 l
j.
(001 860929 801) l l
19.
Sequoyah Nuclear Performance Plan, Section 4.0, Maintenance, dated l
1 July 7, 1986 l
t 20.
INPO 85-017, Chapter XIII Control of Temporary Modifications l
9 21.
Memorandum from S. A. White to W. T. Cottle, NMRG Report l
R-86-02-NPS, RIMS 001-1001-800, dated October 16, 1986 l
22.
MI-10.46, Limitorque, Motor Operator / Control Valve, Revision 3 l
June 26, 1986 l
F VII.
Immediate and Long-Term Corrective Actions The Maintenance Procedure Enhancement Program at SQN is scheduled for 1
completion in two phases:
l b
i 1.
8 months after startup (high risk procedures) l lR2 Page 8 of 9
R:visies 2 2.
21 months after startup (Iow risk procedures) l l
Procedure program progress is being tracked on the Management Action l
Tracking System (NATS). CATD 30801-SQN-01 was written to track l
completion of this commitment.
l
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l i
J s
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TENNESSEE VALLEY AUTN023TY PAGE 213 REFERENCE
- ECP5120J-ECPS121C OFFIC LEAR POWER RUN TIME - 12:19:
S CEQt;EMCY
- REQUEST EfrLOYEE PASSRAM SYSTEM (ECPS)
RUN SATE - 10/0 0:iP - 1555 - RwM LIST GF EIFL CSIICSAN INPGAMATION iTEGORY: OP PLANT OPER. SUPPORT SUSCATE00RTs 30401 SP PROCEDURES KEYMORS A S
GENERIC H
APPL STC/NSRS P
ggygggg g CONCERN SUB R PLT BB5N INVESTISATIGIl S
CONCERIl KEVIGOR9 C NUMBER CAT CAT D LOC FL0B REP 9RT R
DESCRIPTISII KEYMORS B 1A5-45-004 OP 30801 N SQN NNNN N3 ASEGUACY OF MI 10.44 (IISTOR LUS$)
K-FORM l
~k,is-86-001 OP 30801 N SQN NNNN NS ABE40ACY OF MI 6.20 j
K-FORM l
l
$$ MAINTEIIAIICE INSTRUCTISIS ARE UIICLEAR MAINTERIANCE AND DO NOT PROVIDE At WTE INSTRUC PRSCE0 GEES K-FORM T50273 TION. BETAILS KII0 lei I i GTC, MITIIIIEL -
SEIIERAL D BUE TO COIIFIDENTIAL ' Y.
IIS FURTNE 8FnFRAL R IIIFORMATIDII MAY SE LEASES. IIUCL EAR POIIER DEPARTMEIIT Cl 611.
10P-86-014-001 OP 30801 N SQN NNNN WS P9tSW 30 IIST ALMA TT K-FORM AFT N P90VISIIIS T TN EV N
T50276 8T TO 90
, E. 4. RES UIRES S. NUCL CeNCEmm.
CI IIAS AS FURTNER ISII.
TAK-85-002 OP 30801 N SQN NNNN
$$ M & Al-9 30ES IIOT'3PWIPY T0000E FOR K-FORM SCRENS LESS TNAN Stt M.K-85-004 OP 30801 N SQN YYYY SS LUSAICAT!sIl 0F GEARES LUIIT SMITCIIES REPORT 001 IIOV'S NOT PROPEEY IESPECTES 6 CONCERNS FOR CATEGORY OF SUBCATEGORY 30001 O
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- - - - ~.. _. _.
ECTG C.3 Attachment A Page 1 of 1 Revision 2 ECSP Corrective Action Tracking Document (CATD)
INITIATION Applicable ECSP Report No.:
308.01 SON 1.
Immediate Corrective Action Required: O Yes 5 No 2.
Stop Work Recommended: O Yes 00 No 3.
CATD No.
30801-SON-01 4.
INITIATION DATE 3-3-87
- 5., RESPONSIBLE ORGANIZATION:
Maintenance 6.
PROBLEM DESCRIPTION: 2 QR O NQR The Maintenance Procedure Enhancement Program at SON is scheduled for completion in two phases:
1.
8 months after startup (high risk procedures) 2.
21 months after startup (Iow risk procedures)
O ATTACHMENTS 7.
PREPARED BY: NAME M5;fdb a DATE:
7-f-87
- Thomas F. Huth_We /M DATE:
3-3-87 8.
CONCURRENCE: CEG-H 9.
APPROVAL: ECTG PROGRAM MGR. M&l[J4 AIn DATE:
J//z/37
(
/
CORRECTIVE ACTION 10.
PROPOSED CORRECTIVE ACTION PLAN:
Procedure program progress is being tracked on the Management Action Tracking System (NATS).
q f
1 O ATTACHMENTS I
11.
PROPOSED BY: DIRECTOR /MGR:
Tracking Dalt
.DATE:
3/3/87 12.
CONCURRENCE: CEG-H:
Thomas F. Hut W / / E DATE:
3/3/87 SRP:
DATE:
DATE:
l DATE:
l DATE:
(
ECTG PROGRAM MGR:
DATE:
i i
VERIFICATION AND CLOSE0UT l
13.
Approved corrective actions have been verified as satisfactorily l
implemented.
SIGNATURE TITLE DATE 1631T
.