ML20207K861

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Rev 1 to Sequoyah Element Rept, Electrical Protection Design,Thermal Overload Bypass & Indication Problems
ML20207K861
Person / Time
Site: Sequoyah  Tennessee Valley Authority icon.png
Issue date: 12/13/1986
From: Jordan A
TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20207K584 List:
References
237.1-(B), 237.1-(B)-R01, 237.1-(B)-R1, NUDOCS 8701090547
Download: ML20207K861 (15)
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Text

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l .

TVA EMPLOYEE CONCERNS REPORT NUMBER: 237.1 (B)

SPECIAL PROGRAM REPORT TYPE: SEQUOYAH ELEMENT REVISION NUMBER: 1 TITLE: ELECTRICAL PROTECTION DESIGN Thermal Overload Bypass and Indication Problems PAGE 10F 11 REASON FOR REVISION:

Revised per Senior Review Panel and Technical Assistance Staff comments. Added CATD #237.1-SQN-4. Revised to meet the recommended format for SQN element report.

PREPARATION PREP RED BY:

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SIGNATURE DATE CONCURRENCES s -

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0 SRP:

SIGNATURE DATE SIGNATURE DATE APPROVED BY:

ECSP MANAGER DATE MANAGER OF NUCLEAR POWER DATE 8701090547 87010,>

DR p ADOCK 05000327 .

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. TVA EMPLOYEE CONCERNS REPORT NUMBER: 237.1 (B)

SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 2 0F 11

1. CHARACTERIZATION OF ISSUE (S):

. Concern: .Lssue:

XX-85-122-024, 025, 026 a. Inadequate design compliance with WI-85-100-008 NRC Regulatory Guides 1.97. (This "Sequoyah - Thermal overload is being interpreted as inadequate bypass and indication problems compliance with Regulatory Guide involving Regulatory 1.106, which deals with thermal Guide 1.97. CI has no further overload bypass for motor operated information. Anonymous concern valves.)

via letter."

2. HAVE ISSUE (S) BEEN IDENTIFIED IN ANOTHER SYSTEMATIC ANALYSIS? YES_X N0 o Identified by B_ lack and Veatch (B&V1 Date . 0g_t_ob_er 27, 1982 and October- 28,.198.2 Watts Bar Nuclear Plant, B&V Findings No. F-108 (10/27/82)

{p and No. F-122 (10/28/82) o Identified by IVA Task Force _for R_eview of B&V Findin_gs_

Date ._Ap_ri_L2h 1983 Task Force Category 38 for Sequoyah Nuclear Plant - Units 1 and 2, Evaluation Sheet Rev. 0 (04/20/83) o Identified by TVA Nu_cl_ ear Safety Review Staff [NSRS)

Date . _F_

e _br_u.a r_y 3. _ _1986 - Februa ry 7. 1986 NSRS Investigation Report No. I-85-129-SQN for Employee l Concern XX-85-122-024 Thermal Overload Bypass and Indication Problems (dates of investigation 02/03/86 through 02/07/86) l

3. . DOCUMENT NOS., TAG NOS., LOCATIONS. OR OTHER SPECIFIC DESCRIPTIVE IDENTIFICATIONS STATED IN ELEMENT.

Concerns apply to all safety-related motor operated valves (MOVs). l l 1 .

106td (11/13/86)

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TVA EMPLOYEE CONCERNS REPORT NUMBER: 237.1 (B)

SPECIAL PROGRAM REVISION NUMBER: 1 f PAGE 3 0F 11

4. INTERVIEW FILES REVIEWED:

Files WI-85-100 and XX-85-122 were reviewed and no additional unreviewed information for Sequoyah was identified for the concerns addressed in this report,

b. DOCUMENTS REVIEWED RELATED TO THE ELEMENT:

See Appendix A.

6. WHAT REGULATIONS. LICENSING COMMITMENTS. DESIGN REQUIREMENTS. OR OTHER APPLY OR CONTROL IN THIS AREA?

See Appendix A.

7. LIST REQUESTS FOR INFORMATION. MEETINGS. TELEPHONE CALLS. AND OTHER DISCUSSIONS RELATED TO ELEMENT.

See Appendix A.

8. EVALUATION PROCESS:
a. Reviewed available transcripts of NRC investigative interviews for additional information on the concerns.
b. Determined applicability to SQN of NRC Regulatory Guides 1.106 and 1.97 for thermal overload bypass and indication.
c. Reviewed the extent of SQN commitment regarding compliance to l these guides and the method of compliance.
d. Reviewed existing reports (e.g., NSRS Report I-85-129-SQN), l findings, and responses to the findings to assess their l adequacy and the extent to which they satisfy the employee concerns,
e. Reviewed existing TVA Construction, QA/QC, Operations, and Material Control reports for the Employee Concern Evaluation
Program for applicability to the concerns discussed in this report.

(x l 1061d (11/13/86)

TVA EMPLOYEE CONCERNS REPORT NUMBER: 237.1 (B)

SPECIAL PROGRAM REVISION NUMBER: 1

~ h,- PAGE 4 0F 11

f. Reviewed other documents (e.g., Tech. Spec. for MOV thermal l overload protection, sample schematics for safety related MOVs, and criteria for selecting and testing thermal overload elements for MOVs) to verify adequacy of compliance to the Regulatory Guides.
g. Assessed overall compliance to the Regulatory Guides and identified findings as applicable.
9. DISCUSSION. FINDINGS AND CONCLUSIONS Discussion:

Although Regulatory Guide 1.97 is referenced in the concerns, the applicable reference as interpreted by the evaluator is Regulatory Guide 1.106. Regulatory Guide 1.97 deals with instrumentation to assess plant and environs conditions during and following an accident, whereas Regulatory Guide 1.106 addresses thermal overload prctection for motor operated valves. The thermal overload bypass and indication concerns bring out a plant safety-related issue, because improper implementation of the NRC Regulatory Guide 1.106 requirements could result in an ensafe condition.

NRC Regulatory Guide 1.106 is primarily directed at ensuring a reliable operation of motor operated valves used in safety systems and in their auxiliary supporting systems. The intent of this guide is to ensure that safety-related MOVs whose motors are equipped with thermal overload protection devices integral with the motor starter will perform their safety functions. To achieve this, the following two alternate regulatory positions are presented in the guide:

Position 1: "(a) The thermal overload protection devices should t

be continuously bypassed and temporarily placed in force only when the valve motors are undergoing periodic or maintenance testing or (b) those thermal overload protection devices that are normally in l force during plant operation should be bypassed under i accident conditions," or Position 2: "The trip setpoint of the thermal overload protection devices should be established with all uncertainties resolved in favor of completing the safety related action. With respect to those uncertainties, 1061d (11/13/86)

TVA EMPLOYEE CONCERNS REPORT NUMBER: 237.1 (B)

SPECIAL PROGRAM REVISION NUMBER: 1 1

, I

(.' PAGE 5 0F 11 consideration should be given to (a) variations in the ambient temperature at the installed location of the overload protection devices and the valve motors, (b) inaccuracies in motor heating data and the overload protection device trip characteristics and the matching of these two items, and (c) setpoint drift. In order to ensure continued functional reliability and the accuracy of the trip point, the thernial overload protection device should be periodically tested."

. The current design indicates that the Sequoyah Nuclear Plant adopted Position 2 to satisfy the regulatory requirements. The following information was used to supplement the review of the concerns:

a. TVA Task Force for review of Black and Veatch findings evaluated Watts Bar Nuclear Plant B&V findings F-108 and F-122 for the Sequoyah Nuclear Plant to detennine whether the design met the requirements of NRC Regulatory Guide 1.106 and IEEE Standard 279-1971. The Task Force Report (04/23/83) l C concluded that Position 2 of the regulatory requirement was implemented and, therefore, the Sequoyah Nuclear Plant was in full compliance with NRC Regulatory Guide 1.106 and no further action was required. The report indicated that the 16 to 30 seconds locked rotor current setting of the overload relays as well as their periodic testing per Technical Specifications fully satisfied the regulatory position for vital motor operated valves.
b. The Nuclear Safety Review Staff (NSRS) also conducted an l

investigation on this subject (from 02/03/86 through 02/07/86), specifically to determine the validity of the employee concern of this report. The NSRS, based on the same considerations described in "a" above, concluded in its report (I-85-129-SQN) that the Sequoyah Nuclear Plant conformed to regulatory Position 2 and, therefore, the concern was not substantiated.

c. A memo, Chandler to Pierce (05/08/74) contains guidelines for l t selecting MCC overload elements. This document specifies that the thermal overload relays for motor operated valves that are vital for reactor safety must be set to trip between 16 and 30 seconds at locked rotor current with an optimum j setting of 20 seconds. The design basis for the settings is, 1061d (11/13/86) l

TVA EMPLOYEE CONCERNS REPORT NUMBER: 237.1 (8)

SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 6 0F 11 however, not documented and is unclear how this setting satisfies Position 2 of the regulatory requirement (i.e.,

correlation with stroke times for valves).

d. Amendments to Technical Specifications for Units 1 and 2 (both dated 03/29/84) stipulate the surveillance requirements for periodically testing (calibrating) the overload

, protection devices and provide the listing of valves to be J

tested under this program.

e. Surveillance Instructions SI-251.1 and SI-251.2 implement the Technical Specification requirements for periodic calibration of the overload protection devices for the valves listed in the Technical Specifications.

. f. Technical Instruction TI-76 outlines the post-maintenance testing required on equipment listed in the instruction.

Table 1 lists valves that must be tested per SI-251.1 and SI-251.2. Although the lists in these do:uments should be the same, valves 1-FCV-63-6 and 1-FCV-63-7 are listed in SI-251.1 but not in TI-76.

( g. Maintenance Instruction MI-10.52 contains work instructions for selecting overload heaters. Specifically for MOVs, this document provides instructions for sizing overload heaters to meet SI-251.1 and SI-251.2 requirements.

h. Sequoyah Nuclear Plant FSAR, Appendix 6.8c lists all the valves that are under the Sequoyah Nuclear Plant Inservice Valve Testing Program. A memo, Abercrombie to Seiberling implies that this list of valves is intended to be equivalent to the list of active valves in the Watts Bar FSAR Tables 3.9-17 and 3.9-25 with the exception of valves listed in Attachment 1 to this memo. In view of this, and although no requirements exist for SQN to maintain a record of active valves, this memo also implies that the valves covered in Appendix 6.8c must remain active following an accident.

However, not all the valves in this appendix are currently listed in the Sequoyah Technical Specifications.

Furthermore, no justification is provided in the memo for not including Watts Bar active valves 0-FCV-67-151,1-FCV-67-147, 2-FCV-67-223, and 1-FCV-67-478 in Appendix 6.8c. (Note that although this memo addressed only torque switch bypass requirements, because of their similarities with the thermal overload bypass it is assumed that Appendix 6.8c is equally applicable to this design.)

106ld (11/13/86)

TVA EMPLOYEE CONCERNS REPORT NUMBER: 237.1 (B)

SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 7 0F 11 None of the documents described in "c" through'"h" above were issued or revised as a result of corrective actions occurring subsequent to the concerns. In fact, since the concerns were not substantiated as indicated above, no corrective actions were deemed necessary.

fj!Ldj_ng:

a. No formal records were identified for the Sequoyah Nuclear Plant documenting licensing comitments for the extent of compliance to NRC Regulatory Guide 1.106. It should be noted, however, that comitment to comply with Regulatory Position 2 is implied in the response to the B&V findings and the NSRS conclusions,
b. No design basis for compliance with NRC Regulatory Guide 1.106 has been established through design criteria or other design basis documents. This results in an unclear definition of the valves that must meet the regulatory position which, in turn, results in inconsistencies among the

(".. "f," and "h" of the discussion.

c. No design basis has been documented which supports the motor' operated valve thermal overload settings of 16 to 30 seconds at locked rotor current and demonstrates that they satisfy Position 2 requirements of NRC Regulatory Guide 1.106.

Conclusion Based on the above, it is concluded that the concerns as they apply to Sequoyah are valid. Although some documents imply SQN comitment to comply with Regulatory Position 2 of NRC Regulatory Guide 1.106, no licensing documents currently reflect this comitment. Furthermore, in view of the unavailability of design bases establishing the methods of compliance with this guide, it is not possible to determine to what extent the existing design satisfies the intent of this guide. This also leads to inconsistencies among the different valve lists included in site procedures and in the SNP FSAR, Appendix 6.8c.

(

1061d (11/13/86)

TVA EMPLOYEE CONCERNS REPORT NUMBER: 237.1 (B)

SPECIAL PROGRAM REVISION NUM8ER: 1 PAGE 8 0F 11 APPENDIX A S. DOCUMENTS REVIEWED RELATED TO THE ELEMENT:

a. Sequoya_h Nuclear Plant FSAR, Chapters 7 and 8
b. S_e_quoyah Nuclear Plant FSAR_, Appendix 6.8c revised by Amendment 3. "Sequoyah Nuclear Plant Valve Program"-
c. NRC Regulatory Guide 1.47 (05/73), " Bypass and Inoperable Status Indication for Nuclear Power Plant Safety Systems;"

NRC Regulatory Guide 1.97, R3 (05/83), " Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident;" and NCR Regulatory Guide 1.106, R1 (03/77), " Thermal Overload Protection for Electric Motors on Motor-operated Valves"

d. IEEE Standard 279-1971, " Criteria for Protection Systems for Nuclear Power Generating Stations"
e. Sequoyah Nuclear Plant Technical Specifications for Units 1 and 2, Sections 3.8.3.2 and 4.8.3.2, and Table 3.8-2 (Amendment No. 33, 03/29/84 for Unit 1 and Amendment No. 25, 03/29/84 for Unit 2)
f. Watts Bar Nuclear Plant Black and Veatch Findings F-108 (10/27/82) and F-122 (10/28/82)
g. TVA memo from Chandler to Jones, (EEB'840110 906), "Sequoyah Nuclear Plant Units 1 and 2 - Black and Veatch Findings -

Task Force rategory 38," (01/11/84) and attached " Evaluation Sheet Rev. 0 (04/23/83) of the TVA Task Force for Review of Black and Veatch Findings - Task Force Category 38 for Sequoyah Nuclear Plant - Units 1 and 2"

h. TVA memo f rom Whitt to Aberc rombie, " Nuclear Safety Review Staff Investigation Report Transmittal," (03/07/86) and attached NSRS Investigation Report No. I-85-129-SQN " Thermal Overload Bypass and Indication Problems," dates of investigation 02/03/86 through 02/07/86
i. Sequoyah Nuclear Plant Surveillance Instructions SI-2Sl.1, R3 (05/31/85) for Unit 1 and 51-251.2, R3 (10/09/85) for Unit 2,

" Channel Calibration of Class lE Motor Operated Valve Overload Relay Heaters" 1061d (11/13/86)

TVA EMPLOYEE CONCERNS REPORT NUMBER: 237.1 (B)

SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 9 0F 11 4

. j. Sequoyah Nuclear Plant Maintenance Instruction MI-10.52, R0,

" Control of Overload Heaters in Apper. dix R Circuits,"

(07/30/86)

k. Sequoyah Nuclear Plant Technical Instruction TI-76 R4,

" Electrical Maintenance Post-Maintenance Testing," (11/01/85)

1. TVA memo f rom Chandler to Pierce, "Sequoyah Nuclear Plant -

Selecting and Testing of MCC Overload Elements," (05/08/74)

m. Sequoyah Nuclear Plant Schematics E-45N779-31, R18 and

, . E-45N779-15, R21

n. Watts Bar Nuclear Plant FSAR Tables 3.9-17 and 3.9-25
o. Letter from Shell, TVA, to Grace, NRC, " Office of Inspection and Enforcement Bulletin 85 Motor Operated Valve Common Mode Failures During Plant Transients Due to Improper Switch I Settings - Sequoyah Nuclear Plant," (05/12/86),

(L44 860512 803), and attached enclosure 1, Sequoyah Nuclear Plant (SQN), Response to IE Bulletin 85-03 C p. TVA memo from Abercrombie to Seiberling, " Nuclear Safety Review Staff (NSRS) Report No. I-85-612-SQN, RCS Pressurizer Relief Flow Control Valves - Failure to Make Torque Switch Bypass Modifications," (05/05/86) and attached response to this report

q. Letter f rom B. J. Youngblood, NRC, to S. A. White, TVA, (6/25/86), with the attached transcript of the investigative interview conducted by the NRC on 02/21/86 at the First Tennessee Bank Building in Knoxville, TN

?

6. WHAT REGULATIONS. LICENSING COMMITMENTS. DESIGN REQUIREMENTS OR OTHER l

APPLY OR CONTROL IN THIS AREA?

l NRC Regulatory Guide 1.106, " Thermal Overload Protection for Electric Motors on Motor Operated Valves" l

1

\

l 1061d (11/13/86) i l _. - - , - . . _ - . - - - - , - - , - - - . .- _

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TVA EMPLOYEE CONCERNS REPORT NUMBER: 237.1 (B)

SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 10 0F 11

7. LIST REQUESTS FOR INFORMATION. MEETINGS. TELEPHONE CALLS. AND OTHER DISCUSSIONS RELATED TO ELEMENT.
a. Nesbitt, Purcell, Romine, TVA/ Don-Doncow, Hegyi, Bechtel, meeting at Sequoyah jobsite (08/20/86)
b. Nesbitt, Brush, TVA/ Don-Doncow, Bechtel meeting in Knoxville (08/21/86) 1 1061d (11/13/86)

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TVA EMPLOYEE CONCERNS REPORT NUMBER: 237.1 (8)

SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 110F 11 CATD LIST The following CATO forms are included as part of this report:

237.01-SQN-1 237.01-SQN-2 237.01-SQN-3 237.01-SQN-4 (added 11/04/86) p*-,

C 1061d (11/13/86)

ECTG C.3

.' Attachment A

( Page 1 of 1 Revision 2 - A ECSP CORRECTIVE Actico Tracting Document (CATD)

INITIATION

1. Inunediate Corrective Action Required: M Tes O No
2. Stop Wort Reconumended: O Tes E No 3.

5.

CATD No. 2 'a l.0\ - < d N-1 4 INITIATIONDATEkfIk '

b RESPONSIBLE ORGANIZATION: 1 ME._ #

6. PROBLEM DESCRIPTION: tKQR O NQR CD H H \f(% 6tJ T* tbl G&YGM O F- t*D M ** L \ %d E

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7. PREPARED BT* NAME ll h. R DATE: 9 /19 64
8. CONCURRENCE - pEGY H ' hs. R NW C DATE: fti is JrL
9. APPRQVAL: EcIG PROGRAM'MGR. DATE:

.: I CORRECTIVE ACTION

10. PROPOSED CORRECTIVE ACTION PLAN:

O ATTACHMENTS

11. PROPOSED BY: DIRECTOR /MtR: DATE:
12. CONCUFRENCE: CEG-H: DATE:

SRP: DATE:

ECTG PROGRAM MGR: DATE:

VERIFICATION AND CLOSEOUT

13. Approved corrective actions have been verified as satisf actorily implemented.

SIGNATURE TITLE DATE

ECTG.C.3 Attaciuneet A I. Fue 1 of 1 tevision 2 - A

,,. ECSP CORRECTIVE Action Tracting Document (CATD)

INITIATION

1. Inunediate Corrective Action Required: G Yes O No
2. Stop Wort Reconena nded: 0 Yes S- No
3. CATD No. 3 D.0 - san-2 4 INITIATION DATE 1bi 88
5. RESPONSIBLE ORGANIZATION: it4 E. '
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11. PROPOSED BY: DIRECTOR /MGR: DATE:
12. CONCURRENCE: CEG-H: DATE:

SRP: DATE:

ECTG PROGRAM MGR: DATE:

VERIFICATION AND CLO5EOUT

13. Approved corrective actions have been verifled as satistsetorily implemented.

SIGNATURE TITLE DATE 1

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ECTG C.3 Attactuneet A I Fage 1 of 1 Revision 2 - A

+

ECSP CORRECTIVE Action Tra-ting Document (C&TD)

INITIATION

1. Isumediate Corrective Action Required: n Tes O No
2. Stop Wort Reconumended: O Tes  % No
3. CAID No. 2 M . U-5(A N "h a. INITIATION DATE /Y 8
5. RESPONSIBLE ORGANIZATION: }# E.
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9. APPAOVAL: SC PROGRAM MGR.u DATE:

,1 CORRECTIVE ACTION

\, 10. PROPOSED CORRECTIVE ACTION PLAN:

i O ATTACHMENTS

11. PROPOSED BY: DIRECTOR /MGR: DATE:

i 12. CONCURRENCE: CEG-H: DATE:

I SRP: DATE:

ECTG PROGRAM MGR: DATE:

VERIFICATION AND CLOSEOUT

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

SIGNATURE TITLE DATE

., ~ . . ,

o ECTG C.3  ;

Attachment A l Page 1 of 1

p. Revision 2 - A

(' ECSP CORRECTIVE Action Tracting Document 1 (CATD)

INITIATION

1. Immediate Corrective Action Required: 5 Yes O No
2. Stop Work Reconenended: O Yes a No '
3. CATD No. 23'I01- 6t9td -4 4 IuITIATION DATEll/04/B4
5. RESPONSIBLE ORGANIZATION: #NP I
6. PROBLEM DESCRIPTION: E QR O NQR f WAMSI5 T' E M Ca e _T F_ix 1 5 T A M0t46 ~fft2. blf*F(GAB N T- La s Y < lNCLUb2h iM S Ii-G.

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7. PREPARED BY: NAME 'l N 623 DATE: 11/4 f f 4
8. CONCURRENCE %Mr.u-n

. h _a___ R. w 6 '# DATE: 12 L 12-fr L

9. APPROVAL: ECTG PROGRAM MGR.o DATE:

CORRECTIVE ACTION

10. PROPOSED CORRECTIVE ACTION PLAN:

l

! O ATTACHMENTS l

11. PROPOSED BY: DIRECTOR /MGR: DATE:
12. CONCURRENCE: CEG-H: DATE:

SRP: DATE:

ECTG PROGRAM MGR: DATE:

VERIFICATION AND CLOSEOUT l 13. Approved corrective actions have been verified as satisfactorily

( implemented. ,

SIGNATURE TITLE DATE l

l , _ _ ._ - - - _ _ ,

- - - - -- _

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