ML20207L268

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Rev 3 to Sequoyah Nuclear Plant Element Rept, Corrective Maint
ML20207L268
Person / Time
Site: Sequoyah  Tennessee Valley Authority icon.png
Issue date: 12/30/1986
From: Gilmor C
TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20207K584 List:
References
OP-308.03-SQN-R03, OP-308.03-SQN-R3, NUDOCS 8701120058
Download: ML20207L268 (18)
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Text

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TVA RNPLOYEE CONCERNS REPORT NUMBER: OP 308.03-SQN SPECIAL PROGRAN REPORT TYPE: Sequoyah Nuclear Plant - Element REVISION NUMBERt 3 TITLE: Corrective l'.alntenance l

NEASON FOR REVISION: Revision 1 To incorporate 308.03, 308.03A. SRP comuments and TAS comunents To incorporate SRP comunents and SQN corrective action response Revision 2

' To incorporate additional evaluation due to new information received Revision 3 l

l PREPARATION PREPARED BY:

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C. H. Gilmor DATE SIGNATURE REVIEWS PEER:

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/rd:de DATE CONCURENCES

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3 abi/t DATE Ng NANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL, REPORT ON!!l)

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  • SHP Soerotary's sir, nature denotes SRP concurrences are in flies.

16867

TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT EMPLOYER CONCERNS TASE GROUP OPERATIONS CEG Subcategory: Maintenance Element: Corrective Maintenance Report Number 308.03-SQN Revision 3 XX-85 096-005 XX-85-096-N07 G88-45-001 DHT-85-003 2050162005 SQP-86-014-002 XX-85-071-003

. g Evaluator: _ C. H. Ollmor .31-04-86.

C. H. Gilmor Date Reviewed by: _ _ . _ . d{ ,_,ft-A M OPS C -

ber Date Approved by: M /2!/A

, W. R. Latergren Date 16867 A

l

R:visica 3 I. CORRECTIVE MAINTENANCE This report evaluates seven employos issues. Two of the issues are related to the incore instrumentation thimble tube ejection accident in April 1984 at Sequoyah Nuclear plant (SQN). One lasue is related to corrective maintenance of Aus111ery Building Secondary Containment Enclosure (ABSCE) Fire and Security doors at SQN; one issue is related to post-use calibration checking of torque wrenches at SQN; one issue involvos the performance of temporary leak repales and compilance with ASME code requirements: one lasue involves the performance of prework review of maintenance work packages, and the last issue questions the hardware ropale process. The overall element evaluation is related to tho adequacy of the corrective maintenance program and activities at SQN. >

II. SLECIJIC EVAL.UATION METHOD 01.0GY Concern XX-85-096-005 states: lR3 The Radiation Nonttor Tube problem (Thimble Guide Tube Incle. t) in Unit 1 in Apell 1985 could occur again, because the equipment is not properly designed to be fixed during plant operation.

According to a note written on the concern, a stallar concern XX-85-096-004 was transferred to XX-85-096-005 once additional information was obtained by Quality Technology Company (QTC) from the concorned Individual.

To ovaluato this issue Nucioar Safety Review Staff (NSRS) reports I-84-012-SQN dated August 1, 1984 (reference 1) and I-85-614-SQN dated Novombor 25, 1985 (reference 2) woro rovlewed to determino the depth of the investigation, the status of any recommendations mado, and Licensoo Event Reports SQRO-50-327/84030 (roference 3) and SQRO-50-321/84030 Rovlslon 1 (reference 4) were rovlowed.

The SQN procedures (roferences 5 through 7 and 9 through 11) governing incoro instrumontation thlmble guido assembly maintenance were reviewod to dotormino if they had been rovised as recommended in the NSRS reports.

The TVA procedure on ovaluation of special tools for reactor coolant syntom work (roforenco 8) was rovlowed to verify that it had toon written as committed in the rosponses to the NSRS report from line manatomont.

Additionally, SQN plant Compliance was contacted to determino the status of commitmunts mado in the two Licensoo Event Reports (1.ERs).

Concern XX-85-096-N07 status: lR3 NHC identiflod the following concern from revlow of QTC file. "As a rucult of the thimblo guido tubo incident about 34,000 gallons of radioactive water spilled but was misroprosented tu the NRC as no amount of loakaf,o and as a small instrumentation leak."

Pago 1 of 16

Revision 3 To ovaluate this issue, LERs SQRO-50-327/84030 (reference 3) and SQR0-50-327/84030 Revision 1 (reference 4) were reviewed to determine IR3 whether or not they accurately described the event. The Shift Engineer 1.og and Assistant Shift Engineer Log for the third shift on April 20, 1984, were reviewed to establish the sequence of ovents during the thimble guide tube incident and to determine what data had been available to the Shift Engineer for reporting to Nuclear Regulatory Commission. Additionally. NSRS report I-84-012-SQN (reference 1) was reviewed and the status of its recommendations concerning the LER were veriflod.

Concern GSB-85-001 statos:

Since wo do not check calibration of torque wrenches immediately after a job, we could have degraded bolting when we start-up and could contribute to nuclear safety problems, shutdown and increased doso duo to rework on more than one job.

To ovaluate this issue, a memorandum from J. B. Kroll to P. R. Wallace dated February 6, 1985 (reference 12), was reviewed to determine what actions the Maintenance Section supervision had recommended to be taken to rosolvo the concern and whether those actions had adequately addressed the concern. Additionally, the appilcablo SQN procedures (roforences 13 and 14) were reviewed to ensure they had been revised to IR3 requiro post-use calibration checking of torque wrenches and their implementation was verifled.

Concern DilT-85-003 statos:

CI is concerned that due to limited knowledge and understanding of requirements, and due to mechanical work being classified CSSC while electrical and instrument work is classified non-CSSC, the maintenance work performed on ABSCE, fire and security doors is inndoquate to moet the requirements applied to theso doors.

To ovaluato this issue, a memorandum from the cognizant supervisor to the concerned individus1 (CI) dated January 30, 1986 (referenc9 15), was reviewed to dotermine what actions the cognizant supervisor had committed to. These actions, according to the documantation, which included tho espurgated and sonaltive Employoo Concerns filo, resolved tho employous concerns. Additionally, the cognizant supervisor was contacted to datormino the status of implementation of the actions committod to in the memorandum and the appilcoble procedures (references 16 and 11) woro reviewed to ensure they had boon rovisod as committed.

A review was also conducted of firo door operability related LERs to determino the offect of implementation of the commitmonts.

SQN Genoric Opon Concern 2850162005 statos: IR3 TVA makos repairs to their nucioar plants which are not in accordance with ASHE codos, such as overlays, patches, and oven furmanito (sophisticated gluo).

Pago 2 of 16

. R vision 3 To evaluate this issue, cognizant maintenance engineering supervision were interviewed and referenced maintenance procedures covering temporary leak repairs were reviewed.

This issue (2850162005) is a shared concern. This report covers only the use of temporary leak repairs using viscous fluids (e.g.,

furmanite). The remaining portion of this issue is being addressed by the Welding Concerns Evaluation Group.

Concern SQP-86-014-002 states: lR3 Although the foremen are required to sign a document stating they have reviewed the work package with the craft assigned to the job, they in fact often do not review the work package at all with the applicable craft. Nuclear Power concern.

To ovaluate this issue, cognizant maintenance supervision was contacted and referenced maintenance procedures were reviewed.

Concern XX-85-071-003 states:

Sequoyah: CI has general questions about hardware repair process and requested that QTC investigate. Details known to QTC; withheld to maintain confidentiality.

The NRC expurgated file for this issue was reviewed and contained no additional information. Because of the lack of information, an evaluation of this issue was not possible. The SQN Site Director was notified by memorandum (reference 33).

III. FINDINGS l The baseline requirement for all the evaluated concerns is established l by Technical Specification 6.8.1 (reference 22) which states:

6.8 Procedures and Programs 6.8.1 Written procedures shall be established, implemented and maintained covering the activities referenced below:

l a. The applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33, Revision 2 February 1978.

NRC Regulatory Guide 1.33, Revision 2 (reference 23) February 1978 Appendix A states:

, a. Maintenance that can affect the performance of safety-related equipment should be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances.

l Page 3 of 16

Revision 3 These requirements are implemented through the Nuclear Quality Assurance Manual (NQAM), (reference 24), part II, section 2.1, which states in part:

This procedure provides control over maintenance activities which could affect the capability of critical structures, systems, and components (CSSC) to perform their intended safety function. . .

The requirements of this procedure apply to activities which are performed on CSSC items for the purpose of repairing, reworking, replacing or readjusting. - -

Maintenance which can affect the performance of CSSC items shall be preplanned and performed in accordance with written procedures or documented instruction appropriate to the circumstances and which conform to applicable codes, standards, specifications, and criteria.

A. Concern XX-85-096-005 The concern as documented by NSRS reports I-84-012-SQN and I-84-614-SQN (references 1 and 2) was substantiated in that the thimble guide tubes are not designed to be maintained during power operation. However, review of the NSRS reports I-C4-012-SQN and I-85-614-SQN; the recommendations included in the reports; Sequoyah Haintenance Insterctions SMI-0-94-1, SMI-0-94-3, SMI-1-94-5, MI 1.9, MI 1.10 and 1.11; and procedure SQM-63 (references 7, 9, 5, 10, 11, 6, and 8, respectively) demonstrates that the employee concern has been adequately addressed and appropriate corrective actions taken, i.e.,

the design of the thimble guide tube has not been changed, but the incident has been prevented from recurring by the establishment of controls which prohibit maintenance from being performed at any time when the reactor coolant system is above atmospheric pressure and 150*F.

Based upon the recommendation in NSRS report I-84-012-SQN (reference 1), the site provided specific commitments to the NRC by LER SQRO-50-327/84030 Revision 1, (reference 4).

These commitments included review and update of the applicable procedures, implementation of a special tool control program, and a prohibition on cleaning thimble guide tubes with the reactor coolant l system above atmospheric pressure. These commitments were entered l into the Commitment Action Tracking System (CATS). Review of the l CATS status on August 13, 1986, verified that each of these commitments has been closed.

B. Concern XX-85-096-N07 This concern is substantiated as documented in NSRS Report I-84-012-SQN (reference 1) III.L.1 and IV.P. The concern was subsequently closed by completion of the recommendation contained in I-84-012-SQN (reference 1),

specifically the issuance of LER SQRO-50-327/84030 Revision 1 (ruforenco 4)to SQRO-50-327/84030 on October 11, 1985.

Page 4 of 16

- Ravision 3 It should be noted that Employee Concern Task Group (ECTG) Operations Category Report 307.08-SQN dated August 4, 1986 (reference 18),

documents a general concern regarding improper reporting to the NRC and determined that the concern could not be substantiated on a general basis.

C. Concern GSB-85-001 The requirements for using calibrated measuring and test equipment (M&TE) are included in Regulatory Guide 1.33 February 1978 (reference 23) and implemented in TVA through NQAM, Revision 0 (reforence 24), part III, noction 3.1 which statos:

This procedure establishes a calibration program to control and verify the accuracy of Measuring and Test Equipment (M&TE) which is used to ensure that critical systems, structures, and components (CSSC) are in conformance with prescribed technical requirements and that data provided by testing, inspection, calibration, or maintenance is valid.

There is no written specific requirement to perform a recalibration or calibration check immediately following the use of M&TE.

However, an NRC audit (referred to in reference 12) during the week of January 21, 1985, resulted in the following findings:

1. It is difficult to ar.certain if any particular group is responsible for the handling of AI-31, attachment 5,
2. The present tracking program is cumbersome because it requires the Materials Unit personnel to "run around" to get these c1 cared.
3. Evaluations are sometimes difficult to make, and corrective action is hard to implement because a long period of time
elapses before we know the tool is out of calibration.

l l 4. Some people apparently do not respond quickly enough to make the

60-day limit on evaluations.

The findings were documented in a memorandum from J. B. Krell to P. R. Uallace dated February 6, 1985 (SS3850201910) (reference 12) and document that the typical method of M&TE control, i.e.,

maintenance of use records and periodic calibration with follow-up on instruments found out of calibration, was not working at SQN.

The concern was thus substantiated. To resolve the post-use calibration issue (item 3 above), recommendation 2 of the J. B. Krell memorandum stated:

Problem 3 could be reduced if the toolroom would check tools such as torque wrenches, torque multipliers, or other " problem" l instruments each time they are returned. If that check shows that the tool is out of tolerance, the engineer could take Page 5 of 16

. Revision 3 immediate corrective action but would not have to re-evaluate any job except the one it was just used on. The present system finds a problem (but it) may be months af ter a job is done and could cenceivably require an outage to take corrective action.

The Materials Unit would probably have to write an instruction and train people to do this checking.

This recommendation was implemented through a revision to Administrative Instruction AI-31 (Reference 13). Revision 5 of AI-31 (Reference 13), dated June 5, 1986, was reviewed and contains a requirement that upon return of torque wrenches to the toolroom a reference check shall be performed in accordance with Section Instructional Letter (SIL) SS/MU-3 to ensure the tool was in calibration at the required torque value and during the time it was used. This action effectively implements recommendation 2 of J. B. Krell's memorandum.

i l D. Concern DHT-85-003 The concern regarding maintenance of fire and security doors is substantiated as documented by LER SQRO-50-327/84073, which reported a total of 74 fire doors as being either nonfunctional or as not meeting Underwriters Laboratories' standards as the result of maintenance and modification activities performed...".

Additionally, 12 reportable occurrences documented on 5 LERs were issued because firewatches could not be performed because of inoperable fire doors preventing access to the areas to be checked.

[ The actions initiated and completed by SQN to resolve this concern i (reference 15) only address the mechanical maintenance activities.

l No documented action has been taken to resolve the concern regarding mechanical work being classified CSSC while electrical and Instrument work on the same door is classified as non-CSSC.

According to the cognizant supervisor, this portion of the concern was resolved during training. Specifically, it was explained that the mechanical work could affect the ability of the door to perform its intended function, i.e., protect an area or room from spread of l fire from another room or isolate it from the spread of l contamination.

The electrical and instrumentation work, on the other hand, affect door operators and operator indicators which, although important, are not CSSC functions assigned to fire or ABSCE doors.

Documentation of this explanation, however, is not included in the training records, nor could any other documentation be found for the evaluation of this portion of the employee's concern.

l l

Page 6 of 16

Revision 3 A review of LERs entered into the records management system for 1984 through July of 1986 showed a total of nineteen instances where door failure or inoperability directly or indirectly resulted in a reportable occurrence. However, the last incident reported occurred on Harch 18, 1986, which is about the time the dedicated door crew was established and began to function.

E. Concern 2850162005 The base line requirements delineated above, as well as the ASME l Boller and Pressure Vessel Code, section XI (reference 29) apply to l work on CSSC components. Although there is no portion of the code l which addresses temporary packing or gasket leak repair, holes l that are drilled into ASME III components should have an engineering l evaluation to address the effects of stress increases caused by the -lR3 removal of metal and the shif t in gasket loading caused by furmanite l injection. Up until mid-1986, furmanite repairs had been conducted on l CSSC in accordance with Plant Operations Review Committee (PORC) and l Plant Manager Approved Special Maintenance Instructions (SMIs); I however, engineering evaluations were not required. l In each case reviewed, the leak repair affected involved temporary l repair of a leaking bonnet-to-body or cover gasketed mechanical l joint or the temporary repair of a leaking packing gland. l The temporary leak repair method involves the pressure l injection of a small amount of viscous fluid into the leak area to lR3 re-establish the seal between the metal parts, and in the cases l reviewed the maintenance work order covering the repair was held l 1

open until plant conditions were such that a permanent repair, e.g., l repacking or gasket replacement, could be effected. l In a specific case involving the unit 1 turbine driven auxiliary l feedwater pump check valve 1-VLV-891 in 1984, the injection of l furmanite was accomplished by drilling small holes into the bonnet lR3 flange, cnd injecting furmanite through these holes. This ASME III l Class B component repair was reported to the NRC in letter l L44 860729 801. The following findings were identified: l

1. The valve is an ASME III Class B component as classified in the lR3 uorkplan. l
2. The drilling procedure involved metal removal from the bonnet l flange and possibly from the closure studs. Stresses can increase l due to metal removal and stress concentration factors. lR3
3. If Furmaniting is effective, there could be a shift in gasket lR3 loading and resultant stresses in the components of the valve. l
4. Neither ECN L6317 Unreviewed Safety Question Determination or the I workplan address the need for a stress analysis or otherwise dis- lR3 pose of this issue. Other ECNs authorizing Furmaniting have l included a stress analysis. l Page 7 of 16

. Revision 3 One other finding not identified, was that no evaluation was performed I on the compatibility of the Furmanite product with the component's lR3 material it was used on for identification of long term damaging l affects. l In a response to the NRC item D2.1-1 (reference 34), TVA responded lR3 with the following correction action to be performed: l

" Guidance in the use of temporary scalants is required. General l construction spec G-85 has been drafted to provide criteria for i the acceptable use (stress calculations for material removal, l allowable stresses for determining allowable number of lR3 applications, etc) and required repair / replacement during next l outage if sealant repair is used inservice. Furmanite will be IR3 used as required. It may be used with the full knowledge that 1 its use is temporary and full repair or replacement as defined in l G-85 will be required at the next outage. G-85 is tentatively l scheduled to be issued in January 1987. The use of sealants will l be placed on hold until G-85 is issued." l Effective in mid-1986, these repairs are to be handled in accordance with Administrative Instruction AI-19, Part IV (reference 31) as plant modifications and all previously issued SMI's have been cancelled.

F. Concern SQP-86-014-002 lR3 There is no baseline requirement for concern SQP-6-014-002.

However, there is a requirement, SQM-1 Appendix B paragraph 4.3.8 (reference 31) that maintenance instructions include prework briefing instructions. Additionally SQM-2, (reference 32) paragraph I.2.F states:

It shall be the responsibility of the foreman to review all WR packages for proper planning (See planning and review checklist Appendix D). For CSSC WR packages it is his responsibility to ensure that an instruction review sheet (attachment E) is attached, and that he and the craftsman have reviewed the WR package and all instructions attached.

The review sheet shall be signed by the foreman and the craftsman before work begins.

Interviews with cognizant maintenance supervision confirm that each l foreman is required to ensure completion of attachment E to SQM 2 by

! the craftsmen (reference 32) and that the completed form is returned

! to the cognizant maintenance supervisor. There is no requirement l for the supervisor to sit down with each craftsman to review the.WR j packago. When suggestions are made for improvement of the procedure on the instruction review sheet, it is retained until the procedure is revised to incorporate the suggestions, otherwise the cognizant maintenance supervisor discards the instruction review sheet when the job is completed.

Page 8 of 16

. Revision 3

Conclusions:

Concern XX-85-096-005 is substantiated. The actions committed to by SQN to the NRC have been closed out and although the letter of the concern, i.e. design of the thimble guide tube, has not been changed, actions have been taken to prevent maintenance from being performed when the reactor coolant system is above atnospheric pressure and 1500 F, thereby effectively preventing recurrence of the event.

Concern XX-85-096-N07 is substantiated. As shown in NSRS report I-84-012-SQN, LER SQRO-50-327/84030 (reference 1) was, by being incomplete, misleading. However, as documented in ECTG-Operations report 307.08 SQN (reference 18) this LER is the exception rather than the rule and was resolved by issuing a revision to LER SQRO-50-327/84030 (reference 4).

Concern GSB-85-001 is substantiated. The program in place at SQN met all regulatory requirements but was ineffective and cumbersome thereby inhibiting timely feedback to users when, during the periodic recalibration of a torque wrench, the wrench "as-found" data was determined to be out of tolerance. The actions taken and procedure changes implemented have effectively resolved both the concern and the user feed back problems of the earlier program by providing immediate post-use verification of torque wrench calibration.

Concern DhT-85-003 is substantiated by the number and frequency of reportable occurrences resulting from inoperable fire doors. The actions taken and in progress and the procedure changes implemented, have effectively resolved the concern with the exception of the following:

1 (1) The question pertaining to the CSSC designation of work activities needs to be addressed including the impact upon the access to potentially vital areas of the plant because of the non-CSSC work.

(2) Open Maintenance Action Tracking System (NATS) items 1294, 1295, and 1298 (reference 26) should be completed and closed out.

(3) The training activity conducted for the dedicated door crew appears to be a one time only class, without provision for periodic retraining or training of new personnel assigned to the dedicated door crew. The need for recurring training should be

-evaluated.

Note. Element report 306.01 also addresses problems related to fire doors.

l

[

l Page 9 of 16

Revision 3 Concern 2850162005 in regards to leak repair was substantiated. l Although there is no specific ASME code requirements which address- l temporary packing or gasket leak repair, metal removed from an ASME l code component during the furmanite process falls under code require- l ments. ASME section XI provides rules for weld repair of cavities lR3 created by removal of defects in order to restore the component to its I original strength and configuration. Since weld repairs to holes made I from the leak repair process is impractical, an engineering evaluation l should have been performed on the stress increases caused by these I holes.

Presently, the use of furmanite is considered a modification and must l have an engineering evaluation performed before its implementation. l However with the addition of the General Construction Specification lR3 G-85 currently being written, these requirements should be identified l in a procedure for controlling special processes. CATD 30803-SQN-02 l has been issued to track this activity. l Concern SQP-86-014-002 was not validated in that there is no lR3 requirement for craft supervision to review work packages with l

! craft personnel individually. The supervisor documents, by his signature on attachment E of SQM-2, that the craftsman have individually reviewed the work package and that any problems have been resolved.

Concern XX-85-071-003 could not be evaluated as noted in section II.

The Site Director was informed by memorandum (reference 33).

Of the concerns evaluated, XX-85-096-005, XX-85-096-N07, and GSB-85-001 were validated and are considered to be safety-related based upon the fact that they either involved safety-related equipment (i.e., thimble guide tube) or they involved safety-related activities (i.e., calibration of M&TE). Corrective actions for these deficiencies were already in place prior to this evaluation and no further corrective action is required. Concern DHT-85-003 regarding fire door maintenance does not meet the current TVA definition of safety-related, however, some deficiencies were noted which will require evaluation by SQN. Concern SQP-86-014-002 is lR3 not considered safety-related since it could not be validated l and no deficiencies were identified. l l

IV. ROOT CAUSE I

The common theme to the five concerns substantiated was a lack of lR3 adoquate procedural control over the specific activity being performed resulting from unclear, inadequate, or incomplete-procedures.

i The root cause is supported by the findings of the Nuclear Management Review Group review of maintenance activities as reported in the exit mooting report dated July 29, 1986 (SS3 860805 256), (reference 27,

, finding F-2) which states:

Somo instructions were not clear, were not concise, and did not contain the information necessary for users to understand and perform work activitios offectively."

Page 10 of 16

~

. Rsvision 3 A root cause for concern SQP-86-014-002 could not be established l since the concern could not be validated. lR3 V. GENERIC APPLICABILITY The issue of performing malotenance on the reactor coolant system (XX-85-096-005) should be evaluated at WBN to ensure procedures do not 2 allow this practice above atmospheric pressure and 1500F.

The issue of torque wrench calibrations (GSB-85-001) is considered generic and will be evaluated at all sites.

The issue of door maintenance (DHT-85-003) will be evaluated at WBN and BFN. Since BLN is in a construction phase, the issue is not considered generic at BLN.

The improper use of furmanite for temporary packing and gasket leak l repair was validated and is considered generic. The remaining l issues of 2850162005 will be addressed by the Welding Category Evaluation lR3

Group. l The issue that craft foreman do not review work packages with craftsman (SQP-86-014-002) was not validated and is not considered lR3 generic. No procedure violationt were noted by this evaluator.

VI. REFERENCES

1. NSRS Report I-84-012-SQN dated August 1, 1984
2. NSRS Report I-85-614-SQN dated November 25, 1985
3. Licensee Event Report SQRO-50-327/84030 dated May 18, 1984 f,
4. Licensee Event Report SQRO-50-327/84030 Revision 1, dated October 11, 1984

, 5. Sequoyah Maintenance Instruction SMI-1-94-5, Revision 1, " Thimble l Tube Installation," dated July 10, 1986 (Cancelled) l

6. Sequoyah Maintenance Instruction MI-1.ll, Revision 0, " Thimble Tube Installation " dated July 10, 1986 i
7. Sequoynh Maintenance Instruction SMI-0-94-1, Revision 1 "RPV Bottom l Mounted Instrument Thimble Tubes Cleaning and Flushing - Units 1 l and 2," dated October 9, 1984 (Cancelled) j 8. Sequoyah procedure SQM-63, Revision 0, "Special or Modified Tooling-Primary Systems," dated May 9, 1985
9. Sequoyah Maintenance Instruction SMI 0-94-3, Revision 2. " Seal Table liigh Prossure Seal Repair " dated June 27, 1986 Page 11 of 16

. Revision 3

10. Soquoyah Maintenance Instruction MI-1.9, Revision 7. " Bottom Mounted Instrument Thimble Tube Retraction and Reservation," dated June 27, 1986
11. Sequoyah Maintenance Instruction MI-1.10, Revision 3 "Incore Flux Thimble Cleaning and Lubrication"
12. Memorandum J. B. Krell to P. R. Wallace dated 6, 1985 (SS3 850201 910)
13. Sequoyah Administrative Instruction AI-31, Revision 5. " Control of Measuring and Test Equipment," dated June 5, 1986
14. Section Instructional Letter SS/MU-3, Revision 0, " Measuring and Test Equipment," dated March 5, 1986
15. Memorandum D. H. Tullis to CI dated January 30, 1986 (No RIMS Number) i 16. Sequoyah Surveillance Instruction SI-261, Revision 9. " Visual Inspection of Technical Specification Fire Doors on a Periodic Basics" dated July 16, 1986
17. Sequoyah Maintenance Instruction MI-16.1, Revision 0, "Repale and Maintenance of Fire Doors and Various Fire Door Hardware Units 1 and 2 " dated May 29, 1986
18. Employee Concerns Task Group-Operation Report 307.08 SQN dated August 4, 1986
19. NQAM Part II Section 2.1, Revision 0
20. Phy. SI-13, Revision 48, " Fire," May 5, 1986
21. NMRG Maintenance Review Exit Meeting at SQN July 29,1986 S53 860805 256
22. Sequoyah Technical Specifications Unit 1. Revision 48
23. NRC Regulatory Guide 1.33. Revision 2, February 1978
24. Nuclear Quality Assurance Manual Revision 1
25. Licensee Event Report SQRO-50-327/84073 Dated 12/26/84
26. Maintenance Action Tracking System Item 1294: Develop detailed drawing of each CSSC door Item 1295: Sct up doors in Power Stores on initial stock Item 1298: Revise PilYSI-3 to distinguish ABSCE/ fire door branch t
27. NMRG Review of Maintenance Exit Meeting Notes dated July 25, 1986 I (SS3860805256)

Page 12 of 16

r

. 28. NUREG 1369-CR, Revision 1, September 1982

29. American Society of Mechanical Engineers Boiler and Pressure Vessel Code,Section XI (1981)
30. Special Maintenance Instruction (SMI)

- SMI-2-62-4, Revision 1, dated May 4, 1983

- SMI-1-1-4, Revision 5, dated November 19, 1982

- SMI-1-3-5, Revision 3, dated S/24/82

- SMI-2-1-2, Revision 0, dated February 10, 1984

31. Sequoyah Standard Practice SQM-1, Revision 6
32. Sequoyah Standard Practice SQM-2, Revision 19
33. Memorandum to H. L. Abercrombie from W. R. Brown, " Element Reports 301.06-SQN and 308.03-SQN," dated August 22, 1986 (T25 860822 900)
34. Letter to NRC, L44 860729 801, response to NRC inspection report l 50-327/86-27 and 50-328/86-27, 7-28-86 1R3 VII. IMMEDIATE AND LONG-TERM CORRECTIVE ACTIONS A. General Construction Specification G-85 is tentatively scheduled l for issuance in January 1987 as per the TVA response in Inspection l Report 50-327/86-27 item D2.1-1. Closure of the item and IR3 implementation of G-85 is being tracked by CATD 30803-SQN-02. Plant l implementing procedures will need to be written after G-85 is issued. l l

B. SQN corrective action response is as follows (CATD 30803-SQN-01): lR3 The concern was substantiated and then resolved to the employee's l

satisfaction by Mechanical Maintenance by the following actions:

1. Vorified the ABSCE testing would ensure ABSCE doors were properly functioning as ABSCE boundary doors.

t 2. Revised SI-261, " Visual Inspection of Technical Specification Fire i Doors" to reflect requirements from applicable codes and standards as well as recommendations from the Safety Staff.

3. Implemented new MI-16.1, " Repair and Maintenance of Fire Doors and Various. Fire Door Hardware" which provides acceptable repair methods for nonfunctional fire doors or directs the craft to  !

appropriate engineering staff for decisions. This procedure ,

is PORC reviewed. l

4. Provided formal training to the door crew and other carpenters,  !

ongineers, and managers.

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5. Provided additional-training to the Mechanical Maintenance Engineering Section employee responsible for fire door program and procedures.
6. Placed orders for doors to replace deteriorating doors and began their installation.
7. Ensured previously identified deficiencies from the Appendix R walkdown assigned to Mechanical Maintenance have been completed.

' 8. Reviewed previous SI-261 performance data to ensure deficiencies identified have been corrected.

9. Established a dedicated door crew with a foreman to specifically work on doors.
10. Established an adequate inventory of door hardware.
11. Established a working relationship with the DNE Engineer, (name withheld) for problems which require an ECN to correct or for which his expertise is needed.

Three additional items, which are currently in the Mechanical Maintenance assignment tracking system,' remain open. The subject report 308.03 revision 1 recommends in section VII these items need to be completed to i resolve the concern. However, it is our position that numerous actions -

taken to date are adequate to resolve the employee concern. The remaining three Mechanical Maintenance assignment activities recommended by the report were items the line manager investigating the initial employee concern felt would be enhancements to the overall fire door program. They were not then and are not now considered relevant to resolution of the previously stated concerns.

Section VII of the report also recommends two additional activities:

documentation of the CSSC designation and retraining / qualification of the door crew / carpenters.

l All five of these recommendations (three Mechanical Maintenance assignments and two additional items) are addressed individually below for your information only.

MM 1294 - Fire Door Drawings This assignment was made to develop drawings of each fire door with enough information (such as hinge placement, hardware placement, exact dimensions, etc.) to determine which doors are interchangeable to allow

! initial stocking of spare doors.

Although we are progressing on this item, it is apparent from doors measured thus far that no two doors are alike. The tolerance on hinge placement as well as the uniqueness of TVA's location of hardware on the doors has virtually eliminated the possibility of 1.aterchangeability on CSSC fire doors. In all likelihood, this item will only be completed as replacement doors are ordered and will be removed from the tracking system.

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. Ravision 3 MM 1295 - Initial Stock of Fire Doors This item is a sister assignment to MM 1294. It was originally envisioned there was good interchangeability of fire doors since many are the same nominal size and swing. If this had been the case, which it is not, the plan was to set up spare doors in Power Stores which could fit a variety of locations and provide us good insurance against fire doors which fail to meet acceptance criteria. As explained above in MM 1294, this interchangeability does not exist. The only spare doors which we now plan to stock are those for which use is anticipated because of a deteriorating specific fire door in the plant. This item will also be dropped from our tracking system.

MM 1298 - Breach Permits This assignment was made to revise the breach permit form to readily distinguish between a breach for ABSCE reasons and a breach for fire barrier reasons.

Although this item was not a part of the employee concern, it was identified as an item which would improve the program when the concern was originally investigated by the line manager. The action will still be completed but is not relevant to closure of the employee concern.

CSSC Designation As explained to the ECTG Evaluator, the mechanical activities on fire doors are treated as CSSC as required by Sequoyah Standard Practice, SQA134 "CSSC List," Appendix A, Part II, Item 15. The reason for the CSSC designation is the doors provide fire protection by maintaining combustible products and gases in a confined area. In addition, many fire doors are also ABSCE or control building doors which serve the added CSSC function of pressure confinement. On the other hand, the electric strike plates, cardreaders, electric hinges, position indicators, etc., provide no barrier to fires or fire products nor do they provide for pressure confinement. Furthermore, they are not listed as CSSC in SQA134, and our maintenance planners plan the work requests accordingly.

The employee concern in this area stemmed from purely a lack of understanding which we specifically addressed to the concerned individual and generally addressed to carpenters attending the fire door training class at the POTC. the fire door crew foreman, the fire door engineer, and the Mechanical Maintenance Group Management are able to address this question adequately to any new employee who has the same question. For these reasons, no further action is planned.

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- Ravision 3 Retraining i

The question of retraining or requalification of door crew employees does need to be addressed, but not as a part of the employee concern.

Our thoughts right now are the door crew does not need additional formalized training but will need briefing on major rovisions to MI-16.1 or SI-261. This briefing will be conducted by the engineer, door crew foreman, or Engineering Section Supervisor.

We are considering providing fire door training to all nonfire door crew carpenters to elevate their understanding of the stringent requirements on fire doors in the event they have to work on them on an emergent basis.

Again, the question of retraining and qualification of carpenters who work on fire doors is a management decision which will be tracked within Mechanical Maintenance and addressed in a timely manner. It is not an activity considered to be essential to closing out the employee concern since the requirements on fire doors are now clearly outlined in PORC approved procedures (MI-16.1, SI-261, and Physi-13).

Activities 200050236 and 200050242 on the P2 schedule have been changed to Larry Bryant's name and will be closed out as "no action required" at the next update, i

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