ML20207K776
| ML20207K776 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 12/18/1986 |
| From: | Gardner G TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20207K578 | List: |
| References | |
| 303.05-SQN, 303.05-SQN-R03, 303.05-SQN-R3, NUDOCS 8701090517 | |
| Download: ML20207K776 (11) | |
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-TVA EMPLOYEE CONCERNS REPORT NUMBER: 303.05-SQN
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SPECIAL PROGRAM T~
REPORT TYPE: Sequoyah Nuclear Plant - Element REVISION NUMBER: 3 TITLE: Reliability, Design and Maintenance of Radiation Monitoring Equipment REASON FOR REVISION:
To include three additionti concerns and incorporate TAS and Revision 1 SRP conuments.
To incorporate TAS and SRP comments Revision 2 To include one additional concern and incorporate SQN Corrective Revision 3 -
Action Plan PREPARATION PREPARED BY:
G. Darrell Gardner /E/f 8d SIGNATURE dATE REVIEWS PEER:
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SIGNATURE DATE CONCURRENCES K O h27 CEG-H:q re <1 /2d SRP:
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[ SIGNATUR 7 [/ DATE APPROVED BY-(4)bi $-/$'$b N/A ECSP MANfGER DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)
- SRP Secretary's signature denotes SRP concurrences are in files.
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W TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT EMPLOYEE CONCERNS TASK GROUP OPERATIONS CEG t
Subcategory: Instrumentation and Radiation Monitoring Element: Reliability, Design and Maintenance of Radiation Monitoring Equipment
. Report Number: 303.05 SQN Revision 3 SQP-86-003-001 XX-85-044-001 ,
CWL-85-001 XX-85-051-001 SQP-86-003-N04 SQP-86-003-N05 i ,
Evaluator: G. Darrell Gardner /s/5 fd G. Darrell ardn e 'Dite Revlowed by: /// Adi/// /th/f4
, ~0PS CEG N'ej(er bate M!$
Approved by:
W. R. Lag'ergren Date
- 1202T
Revision 3 "I. ' Reliability, Design, and Maintenance of Radiation Monitoring Equipment concerns, and two NRC identified concerns for Sequoyah Nuclear Plant lR3 (SQN), regarding radiation monitors, flow controls, and the improper installation of a unit 2 radiation monitor cable. These concerns were determined to be potentially safety-related by the Employee Concerns Task Group (ECTG) Technical Assistance Staff (TAS).
II. Specific Evaluation Methodology The employee issue identified to Quality Technology Company (QTC) for a unit 2 SQN radiation monitor cable is as listed below: .
SOP-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 l lR3 "SQP-86-003-001 is potentially reportable' l The issues above were reviewed and the scope was determined to be the adequacy 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 l proper use of Raychem heat shrink is being addressed by Operations lR2 Category Element Report 302.01-SQM and was not addressed by this l evaluation. l-The ECN and workplans which performed the modifications to penetration 23 were reviewed and the cognizant modifications engineer was interviewed for details. The evaluation was conducted at SQN.
Page 1 of 7
Revision 3
'The employee concern identified to QTC for a SQN radiation monitor is as
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__ __ lis.ted below:
2: K1-85-051-001 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 l addresses the identified concern. lR2 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 controls for 2-RE-90-100 not listed as either technical specification or 1 complistice instruments?
The ECTG files were reviewed and a SQN plant response was found which
. addresses the identified concern. The SQN instrument engineer who prepared the memorandum was contacted for clarifying information.
The following concern identified to QTC for Browns Ferry Nuclear Plant (BFN).was determined generically applicable to SQN:
XI-85-044-001 At BFN there was an accident of radiation release on the reactor refuel floor on June 26, 1985. The concern is that CAMS did not function properly and did not
, register radiation levels accurately. CAMS are obsolete and should be replaced by modern instruments such as particulate iodine noble gas (PINGS). CI has no further information.
The concern was reviewed and the scope, with regard to SQN, was determined to be the adequacy of airborne particulate monitors and whether they should be replaced by more modern instruments. These monitors are listed in SQN Final Safety Analysis Report (FSAR) Table 12.2.4-1.
The SQN FSAR and monthly Surveillance Instructions (SI) SI-204 were reviewed and informal interviews were conducted with personnel in SQN
- Instrument Maintenance and Division of Nuclear Engineering (DNE)
Instrument and Control (I&C) Section. The evaluation of this concern was conducted at SQN.
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IIII " Findings
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SQP-86-003-001. SOP-86-003-N04 and SOP-86-003-N05 lR3
_. _ The NRC expurgated file for SQP-6-003 was reviewed and it was discovered
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that the timeframe of the concern was approximately 3 months before the concerned individual's interview. Although the date of the interview was not given, it was assumed in late 1985 or early 1986. An engineering change notice (ECN) L6490_(Reference 1) was found which replaced penetrations 23 and 48 in late 1985 and early 1986; therefore, this wodification was considered as the area of concern. A cognizant Modifications planner indicated that ECN L6490 was implemented by workplans 11802, 11808, and 11959 for unit 2.
The cognizant Modifications engineer was contacted and confirmed -
that there had been some problems with the cable connectors. The dimensions for trimming the coaxial cable insulation provided by the vendor were not adequate to allow proper connection installation.
These dimensions were modified by instruction change (IC) 85-1513 on November 27, 1985, with QA cincurrence. The engineer confirmed that on a few occasions, connectors believed properly installed at the end of a shift were found loose the next day. These connectors had not yet been terminated and were reworked and inspected by QA before termination and heat shrinking of the Raychem in-line protective l covering.- The engineer stated that this only happened a few times l and only to a few cables that could not be terminated before the end l of the. shift. The normal process was to install the connector. l perform megger and continuity checks, and then apply the Raychem lR2 shrinkable covering before starting the next cable. QA inspections l were performed at each step of this process as indicated in the l workplan. Any further tampering with the connectors would require j the obvious removal of the Raychem covering and no cases,such as l this were ever 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 status upon completion of the modification (Reference 3 and,4). No deficiencies were identified during performance of the SI except for one monitor being out of calibration. This monitor was recalibrated before its return to operability.
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 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 required to meet any technical specification requirements.
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i Revision 3
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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
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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 aample pump c- -and flow controls which are technical specification instruments. lR2 Therefore, the airflow monitor sample pump and flow controls are not required for any technical specification requirements.
II-85-044-001 The SQN FSAR states that continuous airborne radiation monitoring is ;
performed to comply with 10 CFR 50 Appendix A, General Design Criterion 19, 63, 64 and 10 CPR 20.103 (Reference 10). However, these monitors are not required to meet any technical specification requirements.
The cognizant supervisors in the DNE I&C Section both agreed that the equipment in place for airborne monitoring adequately meets the FSAR design 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 and the General Atomic CAMS are much more reliable to operate and maintain.
They both stated that the CAMS were not technical specif'ication instrumentation, however they are 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 dealgn requirements and believed that chapging 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.
A spot check of SI-204, " Data Packages," from January through lR2
- March 1986, revealed no CAMS out of calibration (Reference 11). l Conclusion
- 1. The issues presented by SQP-86-003-001, SQP-86-003-N04 and lR3 SQP-86-003-N05 were not validated and no safety-related deficiencies l were identified. Some radiation monitor cable connectors were found lR2 loose during the modification, but were corrected and inspected by QA l before termination. Megger and continuity checks and surveillance testing were performed before return to service to ensure proper installation of the cables in penetration 23.
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~ 2. The issue presented by concern XX-85-051-001 was validated by the NSRS report; however, the monitor is not a 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 depended upon during a fuel failure accident.
The monitor is currently scheduled to be removed by DCR 1596, I therefore, failure to maintain the instrument is of no safety IR2 significance. 1
- 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 sAsple pump and controls which 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 l DNE and SQN Instrument Maintenance were in agreement that I the CAMS are adequate to meet the design requirements for l airborne monitoring as discussed in the FSAR, and based on IR2 their experience, are more reliable than the PINGS used for l other applications at SQN.
IV. Root Cause No deficiencies were identified by this evaluation, and thus root I cause is not identified. lR2 V. Generic Applicability ,
Concern SQP-86-003-001, SQP-86-003-N04, SQP-86-003-N05, XX-85-051-001, lR3 and CWL-85-001 are not considered generic to-any other plant because they identify specific concerns related to SQN.
XX-85-044-001 has been evaluated for BFN and SQN with ne negative l findings. Based on this, there is no reason to suspect a lR2 safety-related deficiency at either WBN or BLN. Therefore, this l concern is not considered generic to WBN or BLN. l Page 5 of 7
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Revision 3 N^^
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l VI. References
- 2. Workplan 11802 and 11808
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- 3. SI-686.2, R3 " Channel Calibration for High-Range Accident Radiation Monitors," November 1, 1985
-~ 5. Nucisar Safety Review Staff (NSRS) Investigation Report i I-85-613-SQN, " Maintenance and Operability of Process Radiation Monitor 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, 1985
- 7. Memorandum from K. W. Whitt to H. L. Abercrombie, Corrective Action
) Response Evaluation to NSRS Report I-85-613-SQN, dated r February 13, 1986
- 8. Design Change Request (DCR) P-1596, September 15, 1983 l 9. Memorandum from H. D. Elkins to Harvin Phillips Response to
- Employee Concern, dated December 10, 1985 l
- 11. SQN SI-204, " Data Packages." January 10, 1986, February 7, 1986, g and March 8, 1986, " Functional Tests of Radiation Monitoring System a Channels (Monthly)," Data Sheet 3
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Revision 3
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VII. 'Iamediate or Long-Term Corrective Action
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Although no safety-related deficiencies were identified by this evaluation report, the NSRS report conducted for XX-85-051-001 made some recommendations to SQN with regard to expediting DCR 1596 and revision to sis to clearly distinguish between nontechnical specification sonitors 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 clearly denote technical specification and nontechnical specification monitors within the SI.
This is indicated in the SQN Corrective Action Plan (CATD 30305-SQN-01) l which states: I-I sis associated with radiation monitors will be revised to clearly lR3 distinguish between Non-Tech Spec and Tech Spec monitors. l ,
I In response to problems with PINGS, (CATD 30305-SQN-01) the SQN l Corrective Action Plan states: l l
Factory representative from Eberline Rad Monitor will be requested I to assist in correcting inherent problem with PING monitor control l room control terminal and also provide IM with class on l troubleshooting techniques and system description. l l
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RLt LRLt1CL - ECPS120J-ECPS121C TENNESSEE VALLEY AUTHORITY I PAGE -
FREQUEt4CY - REQUEST OFFICE OF HUCLEAR P0HER RUN TIME -
() OllP - ISSS - RUM EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS)
RUN DATE -
LIST OF EMPLOYEE CONCERN INFORMATION CATEGORY: (P PLArlT OPER. SUPPORT SUBCATEGORY: 30305 RELIABILITY AND MAINT RADIATION M0ilITORING EQUIP
() S H
GENERIC APPL QTC/NSRS P KEYHORD A KEYHORD B CarlCERt3 SUB R PLT BBSH INVESTIGATION S CONCERN KEYHORD C flUMLER CAT CAT D LOC FLQB REPORT R DESCRIPTI0tl ' KEYHORD O 5 CHL-85b01 30305 il SQN NNNN OP NS HNY ARE THE AIR MONITOR FLOW CONTROL K-FORM S FOR 2-RE-90-IO0 NOT LISTED AS EITH ER TECH SPEC OR COMPLIANCE INSTRUMEN
() TSt SCF-S6-003-N04 OP 30305 N SQN NNNN NS NRC IDENTIFirD THE 10tLONINO CONCINN K-FORM NHICH PERTAINS 10 SQP-86-003-001 PN 3 DM REVIEH OF QTC FILE. "CI STATES H ORE CABLES (IN ADDITION TO THE RADIA TION MONITOR CABLE CITED Ill SQP-86-0 03-001) MAY HAVE A SIMILAR PROBLEM I 3 N PENETRATION 823. IllTEGRITY OF ALL CONNECTORS AND ASSOCIATED HEAT SHRI flK IS IN QUESTION. THIS C0flCERN REF ERS TO CABLES IN ADDITION TO 1HE RAD
) I ATION MONITOR CABLE CITED Ill SQP-86
-003-001.
SQP-86-003-fl05 OP 30305 N SQN N fl N tl NS tlRC IDENTIFIED THE FOLLOHING CutlCERN
) K-FORM FROM REVIEH OF QTC FILE. "SQP-86-0 03-001 IS POTENTIALLY REPORTABLE."
30305 fl SQti I-86-205-SQN SS THE RADIATION MONITOR CABLE IS NOT I fl0 tlc 0tlFORMANCE D SQP-86-003-001 OP il N !! il NSTALLED PROPERLY. PENETRATION 23, CORRECTIVE At T50246 K-FORM LOWER CONTAINMENT, UNIT 82, MODIFICA OPERATI0tlS TIONS. (FLAMES / DETAILS KNOHN TO QTC RADIATIO!
) AtlD HITHHELD TO MAINTAIN CONFIDENTIA LITY). NO FURTHER INFORMATI0!1 MAY B E RELEASED. IlUCLEAR P0HER CONCERil.
CI HAS 110 FURTHER INFORMATI0tl.
> HEALTH PHYSICS XX 044-001 OP 30305 !! BFN 11 N Y tl I-85-557-BFN NS AT BROWN'S FERRY THERE HAS AN ACCIDE SAFETY CollDI-T50153 REPORT tlT OF RADIATION RELEASE Oil THE REACT
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OR REFUEL FLOOR ON 6/26/85. C0tlCERil DPERATI0flS IS THAT CONTINU0US AIR MONITORS (CA DEVICES
) MS) DID NOT FUNCTION PROPERLY AtlD DI D NOT REGISTER RADIATION LEVELS ACCU RATELY. CAM'S ARE OBSOLETE AND SHOU LD BE REPLACED BY MODERN INSTRUMENTS
) SUCH AS PARTICULATE 10DIrlE fl0BLE GA S (PING'S). tI HAS NO FURTHER IllFOR MATION. NO FOLLOH UP REQUIRED.
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REFERENCE - ECPS120J-ECPS121C TENNESSEE VALLEY AUTHORITY l PAGE --
FREQUENCY - REQUEST OFFICE OF NUCLEAR P0HER' j RUM TIME - -
{} ONP - ISSS - RHM EMPLOYEE CONCERN PRDORAM SYSTEM (ECPS) ; RUN DATE - /
LIST OF EMPLOYEE CONCERN INFORMATION
{
CATEGORY: OP PLANT OPER. SUPPORT SUBCATEGORY: 30385 RELIABILITY AND MAINT RADIATION MONITORING EQUIP-i
. 'i g 3 GENERIC KEYWORD A H APPL QTC/NSRS P , KEYNORD B CONCERN SUB R PLT BBSH ' INVESTIGATION S CONCERN KEYNORD C NUMBER, CAT CAT D LOC FLQB REPORT. R DESCRIPTION KEYHORD I i XX 051-001 OP 30305 N SQN NNYN I-85-613-SQN SS SEQUOYAH THE RADIATION MONITOR (1-R NONCONFORMANCE T50153 K-FORM M-90-104) HAS NOT BEEN MAINTAINED AN HEALTH PHYSIt D IS NOT ALHAYS OPERABLE. ANY FURTH OPERATIONS g ER INFORMATION HOULD COMPROMISE CONF RADIATI0t i IDENTIALITY. NUC. POWER DEPT. CONCE RN. FOLLDH UP NOT REQUIRED.
) 6 CONCERNS FOR CATEGORY OP SUBCATEGORY 30305
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