ML20209C365
| ML20209C365 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 01/23/1987 |
| From: | TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20209C049 | List: |
| References | |
| 223.3-(B), 223.3-(B)-R01, 223.3-(B)-R1, NUDOCS 8702040253 | |
| Download: ML20209C365 (21) | |
Text
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TVA EMPLOYEE CONCERNS REPORT NIMBER: 223.3 (B)
SPECIAL PROGRAM REPORT TYPE:
SEQUOYAH ELEMENT REVISION NUMBER: 1 TITLE:
INSTRUMENT SUPPORT DESIGN Local Instrument Seismic Qualification PAGE 1 0F 20 REASON FOR REVISION:
1.
Revised to incorporate SRP and TAS comunents; to add chronology and Section 10, Corrective Action.
PREPARATION PREPARED BY:
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MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)
- SRP Secretary's signature denotes SRP concurrences are in files.
TVA EMPLOYEE CONCERNS REPORT NUMBER: 223.3 (B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 2 0F 20 1.
CHARACTERIZATION OF ISSUE (S):
Concern:
Issues:
IN-85-886-N04 a.
Local instruments were installed NRC identified the following based on " Good Engineering Judgment."
concern related to IN-85-886-001 from review of QTC file.
b.
No seismic analysis was done for dif-ferent types of installation of local "On unit 1, local instruments instruments.
were installed using ' Good Eng. Judgment' and no seismic c.
No seismic analysis was done for analysis was done."
local instruments.
2.
HAVE ISSUES BEEN IDENTIFIED IN ANOTHER SYSTEMATIC ANALYSIS? YES x NO Identified by Gilbert / Commonwealth (G/C)
Date 03/03/86 Documentation Identifiers:
G/C Report No. 2614,
" Final Report Technical Review of SQN Modifications, Technical Issues No. 4, 9, 10, 14 & 19" 3.
DOCUMENT NOS., TAG NOS., LOCATIONS OR OTHER SPECIFIC DESCRIPTIVE IDENTIFICATIONS STAltu IN ELEMENT:
Local instruments; no specific tag numbers identified 4
INTERVIEW FILES REVIEWED:
File IN-85-886-N04 was reviewed and no additional unreviewed information for Sequoyah regarding this concern was identified.
5.
DOCUMENTS REVIEWED RELATED TO THE ELEMENT:
See Appendix A.
I 010?D - 01/15/87
TVA EMPLOYEE CONCERNS REPORT NUMBER: 223.3 (B)
SPECIAL PROGRAM REVISION NLMBER: 1 PAGE 3 0F 20 6
WHAT REGULATIONS, LICENSING COPWITNENTS, DESIGN REQUIREMENTS OR OTHER APPLY OR CONTROL IN THIS AREA?
See Appendix A.
7.
LIST REQUESTS FOR INFORMATION, MEETINGS, TELEPHONE CALLS, AND OTHER DISCUSSIONS RELAltD TO ELEMENT.
See Appendix A.
8.
EVALUATION PROCESS:
Reviewed Environmental Qualification (EQ) program comitments l
a.
(general program for environmental qualification) in SQN Nuclear Performance Plan, Volume II.
b.
Obtained results of Seismic Qualification Review Team (SQRT) l audit by NRC.
Detemined which instrumentation items were covered by SQRT c.
audit.
d.
Reviewed FSAR for SQN comitment for instrument seismic qualifications.
Reviewed Safety Evaluation Report (SER) in l
the same sections for results of NRC review.
Reviewed SON design criteria and other comitments regarding e.
qualification requirements.
f.
Selected and reviewed appropriate samples of qualification documentation.
g.
Obtained and reviewed drawings that show mounting details.
9.
DISCUSSION, FINDINGS, AND CONCLUSIONS:
Chronolog:
09/76:
NRC - SQRT audit of class lE instrumentation 03/86:
G/C reviews SQN modifications of class lE instrumentation 06/86:
TVA-SQN Generic Concern Task Force investigates installations of local instruments 08/86:
K-fonn provided to TVA 0103D - 01/15/87
TVA EMPLOYEE CONCERNS REPORT NilMBER: 223.3 (B)
SPECIAL PROGRAM REVISION NLDSER: 1 PAGE 4 0F 20 Discussion:
A. Background The issues relate to a concern that the installation of local instruments was based on good engineering judgment only, without any seismic analysis.
Good engineering judgment has been, and will continue to be, an inherent part of the engineering process.
In current practice in the nuclear industry, requirements have been established for documentation of such judgment by providing technical justification.
B. Criteria and Commitments NRC General Design Criterion 2 requires Category I structures, systems, and components to be designed to withstand the effects of natural phenomena such as earthquakes.
Sequoyah commitment to comply with this criterion is stated in SNP FSAR Section 3.1.
The seismic design bases of Category I items are described in FSAR Sections 2.5 and 3.7.
Specific application of these bases for Category I instrumentation is contained in FSAR Section 3.10 and Appendix F of Sequoyah Nuclear Power Plant Quality Assurance Manual, which is presently included in SQN design criteria manual, (App. A, 6.b).
C. Methods of Qualification The seismic qualification of equipment should demonstrate the equipment's ability to perfonn its required function during and after the time it is subjected to the forces resulting from a I
seismic event. One of four alternate techniques may be used to qualify equipment: analysis, testing, a combination of both, or similarity with supporting documentation.
l Analytical methods are adequate if an appropriate mathematical model can be constructed, the structural integrity can assure equipment functionality, and aging influences are insignificant.
Testing methods may be used to verify equipment's functional operability.
Examples of equipment generally requiring testing are valves, complex dampers, devices for electrical cabinets, and instrumentation and control equipment.
Extremely large and/or complex equipment would generally be qualified by a combination of testing and analysis.
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TVA EMPLOYEE CONCERNS REPORT Nt##ER: 223.3(B)
SPECIAL PROGRAM REVISION NiteER: 1 PAGE 5 0F 20 Equipment that is similar in fom, fit, and function to previously qualified equipment may be qualified on a " generic" or similar-equipment basis if the prototype test can be applied to the similar equipment to be qualified. To justify qualification by similarity, differences in mass distribution, equipment geometry, interior and exterior structural supports, mounting conditions, and externally applied loads should be considered. When applicable, the location of devices within assemblies and the function and method of operation of electrical and/or mechanical devices and the design basis condition should also be considered.
In addition, qualifications by similarity should be accompanied by supporting documentation.
D. NRC Seismic Audit In late September 1976, the NRC perfomed a seismic audit of TVA equipment.
The seismic audit report was attached to NRC letter from Varga to Williams ( App. A, 5.o; 11/16/76). The NRC seismic team had requested documentation on seismic qualification for several selected items of Balance of Plant (B0P) class 1E l
instrumentation, control, and electrical equipment. Radiation monitors were among the selected items audited.
The NRC concluded that the function of the selected items was acceptable during and after seismic testing, according to infomation submitted by TVA.
This conclusion was reflected in Sections 3.10 and 7.8 of Safety Evaluation Report (SER) by NRC. During the seismic audit, TVA staff indicated that they endorse updated IEEE 344-1975 standard and Regulatory Guide 1.100 for equipment seismic qualification.
However, TVA was very explicit in stating that their seismic qualification program requirements and licensing comitments for Sequoyah were based on IEEE 344-1971. FSAR Section 3.10.1 contains the following commitments for the seismic qualification of seismic Category I instrumentation:
a.
Both BOP and Nuclear Steam Supply System (NSSS) l instrumentation satisfy the requirements of IEEE 344-1971.
b.
BOP (TVA supplied) instrumentation is qualified per TVA SQN Quality Assurance Manual Appendix F with a minimum test frequency range of 1 to 25 hertz.
c.
The instruments are capable of performing their functions l
during and following a Safe Shutdown Earthquake (SSE). They are qualified to withstand the peak response acceleration detemined from the appropriate response spectrum, d.
Any instrumentation used for plant upgrade purchased after 05/23/80 will be qualified to the requirements of IEEE 344-1975.
l 0103D - 01/15/87
TVA EMPLOYEE CONCERNS REPORT Nt#EER: 223.3 (B)
SPECIAL PROGRAM REVISION NIMBER: 1 PAGE 6 0F 20 Although SQN criteria were not updated (the bulk of the equipment was already under contract), it was TVA's intent that IEEE 344-1975 be implemented to the fullest extent reasonably possible, as stated in a TVA letter from Gilleland to Varga ( App. A, 5.p; 02/07/77).
E. Seismic Oualification Documentation A review of SQN Nuclear Perfomance Plan, Volume II, Revision 1 (final draft) attached to a memo from Gridley to Those Listed ( App.
A, 5.w; 07/14/86), identsified that the current rework EQ program for Sequoyah is connitted to environmental qualification of equipment only and does not address seismic qualification of equipment.
This was confirmed in discussions with TVA on 08/19-24/86 at the Sequoyah plant.
During the investigation, the evaluation team experienced difficulty in retrieving documentation of seismic qualification of instrumentation.
This difficulty may cause problems in demonstrating the acceptability of TVA seismic qualification of instrumentation.
A similar retrievability concern was identified in NRC I&E Report Nos. 50-327/86-27 and 50-328/86-27, attached to an NRC letter from Taylor to White ( App. A, 5.x; 04/22/86), based on a special inspection of TVA's Design Baseline and Verification Program for design activities since receipt of SQN operating license.
The NRC conducted an additional inspection of procurement and quality assurance records on 09/15-19/86 and 09/29/86 through 10/03/86 as indicated by an NRC letter from Taylor to White ( App. A, 5.ee; 10/21/86).
This letter expressed the NRC's concern regarding TVA's inability to retrieve quality assurance records for seismic and environmental qualifications of previously qualified equipment.
Similar issues are evaluated on a broader base in the element reports of Subcategory 205.
F. Sample Instrument and Installation Review To establish baseline infomation to review seismic qualification of instrumentation, the evaluation team independently selected three samples of " Local Instruments" from the " Mechanical Instrument Tabulation," Drawing 478601 series.
The selection was based on the following criteria:
0103D - 01/15/87 rt-
TVA EMPLOYEE CONCERNS REPORT NLSSER: 223.3(B)
SPECIAL PROGRAM REVISION NiseER: 1 PAGE 7 0F 20 a.
The instruments are safety-related b.
The instruments were procured before fuel load of Unit 1 (i.e., pre-1980 contract)
The instruments were procured under different contracts c.
t d.
One instrument is mounted on a floor panel; the second one on a wall panel; and the third one process mounted TVA personnel were requested to compile complete seismic qualification documentation for the three selected samples of instrumentation listed below:
Force balance pressure transmitter (1-PT-1-30) for the main a.
steam system, procured under contract no. 68C60-91934 (NSSS contract). This transmitter is located in the Unit 1 auxiliary building, elevation 690 feet, and is mounted on a local floor panel.
b.
Pressure transmitter (1-PT-1-26C) for the main steam system, procured under contract no. 73C3-92784 (BOP contract).
This transmitter is located in the Unit 1 auxiliary building, elevation 735 feet, and is mounted on a local wall panel, Temperature switch (1-TS-30-103) for the ventilating system, c.
procured under contract no. 75K13-86835 (BOP contract).
This temperature switch is located in the Unit 1 auxiliary building, elevation 713 feet, and is process mounted.
Force Balance Pressure Transmitter.
This transmitter (1-PT-1-30) is a Foxboro Model No. E1199, supplied by Westinghouse.
It underwent seismic testing by Acton Environmental Testing Corporation, and the test results were documented in Test Report No. T3-1091 ( App. A, 5.g; 12/73), which was attached to Westinghouse Topical Report, " Seismic and Environmental Testing of Foxboro Transmitters," WCAP-8541 (App. A, 5.f; 07/75).
This test I
report was approved by TVA as documented by TVA memo from Coleman t
to CEB files ( App. A, 5.h; 09/03/81) for Foxboro Model No. E10 series transmitters on WBN contract 828973.
The memo stated that this approval qualifies the devices for installation in any of j
TVA's nuclear plants.
The location of the transmitter is shown on i
j Drawing 47W600-31, R17.
This Foxboro transmitter was mounted on a l
local floor panel 1-L-102; panel detail is shown on Drawing 47W600-14, R4.
The transmitter mounting plate and bracket are detailed on Detail B19 of Drawing 47W600-19, R13.
The evaluation i
team walkdown during 09/16-20/86 found that the bracket installed l
on 1-PT-1-30 is the approximately 1-inch deep bracket shown on I
Section A-A of Detail B-19.
(
01030 - 01/15/87 l
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TVA EMPLOYEE CONCERNS REPORT MER: 223.3 (B) i SPECIAL PROGRAM l
REVISION MER: 1 j
PAGE 8 0F 20 l
The local floor panel is an instrumentation rack procured under I
contract no. 72C33-92800 and manufactured by The Wolfe and Mann i
Manufacturing Company.
It was tested by Wyle Laboratories, and
)
documented in Test Report No. 42377-1 ( App.. A, 5.m), which was j
reviewed and approved by TVA in a letter from Weaver to Keith (App.
A, 5.q; 04/17/73).
The tested mounting bracket shown in photograph i
i 9 of Wyle Test Report 42377-1 appears to be different from the mounting bracket shown on Detail B19 of Drawing 47W600-19.
j However, in an evaluation team discussion on 10/24/86 with TVA personnel (App. A, 7.n), TVA personnel stated that the issue detail j
shown on the design drawing had approval signatures or initials i
indicating that adequate review and approval had been perfonned by i
TVA personnel in early 1970s.
The evaluation team noted that this I
was consistent with nuclear industry practice in that time frame.
~
In later discussion on 10/25/86 ( App. A, 7.m), TVA personnel j
indicated that the bracket shown in photograph 9 of Wyle Test Report 42377-1 was supplied by Foxboro. Because of TVA concerns regarding the stiffness identified from its review of test results, 1
a stiffer bracket was designed, as shown on drawing 47W600-19.
I Subsequent qualification tests of the pressure transmitters for WBN applications were perfonned by Wyle Labs and included in Wyle Test Report 42807-1 ( App. A, 5.j ; 08/26/74) using the bracket shown on l
drawing 47W600-19 and the enveloping WBN required response i
spectra. This latter Wyle test report was approved by TVA as documented by letter from Chandler to Salisbury ( App. A, 5.1; j
11/19/74).
After considering all the above infonnation, the evaluation team finds that adequate documentation exists to demonstrate that i
pressure transmitter 1-PT-1-30 meets TVA licensing constitments of FSAR Section 3.10.
During evaluation team investigations, it was j
noted that alternate Section Al-Al of Detail B19, Drawing i
47W600-19, provides a bracket 2-1/2 inches deep which is more flexible than the qualified approximately 1-inch deep bracket.
The evaluation team performed a qualification calculation for alternate Section Al-Al and detennined that this detail is adequate.
Therefore, the engineering judgement was adequate and this is no longer a relevant issue.
Pressure Transmitter. This transmitter (1-PT-1-26C) is a GE-MAC i
Type 556 transmitter, supplied by General Electric Company.
It was seismic tested by Utility System Engineering of Bailey Meter i
Company, revised Test Report No. 507 ( App. A, 5.k; 05/25/73),
i attached to a vendor letter from Henrichsen to Weaver ( App. A, 5.r; I
05/25/73).
The test was made in accordance with TVA Specification l
1499, Appendix C, attached to contract 73C3-92784.
The revised 4
l test report was reviewed and approved by TVA in a letter from l
01030 - 01/15/87
TVA EMPLOYEE CONCERNS REPORT NUMBER: 223.3 (B)
SPECIAL PROGRAM REVISION NtMBER: 1 FAGE 9 0F 20 Patterson to Henrichsen ( App. A, 5.t; 06/28/73).
The location of the transmitter is shown on Drawing 47W600-92, R6.
This GE-MAC transmitter is mounted on a local wall panel 1-L-251, whose detail is shown on Drawing 47W600-23, R11.
The transmitter mounting plate is detailed on Detail B21 of Drawing 47W600-21, R8.
The wall mounted panel and the mounting plate were analytically detemined to be rigid by TVA, and the calculation was attached to the TVA memo from Givens to Pierce ( App. A, 5.s; 01/09/73). This calculation was entered into the TVA Records Information Management System (RIMS) on 10/02/86 to facilitate document retrieval for future evaluations.
The evaluation team has reviewed this calculation and considers that it adequately demonstrates acceptable mounting of transmitter 1-PT-1-26C. All of the above infomation leads the evaluation team to consider that adequate documentation exists to demonstrate that pressure transmitter 1-PT-1-26C meets the TVA licensing comitments of FSAR Section 3.10.
Temperature Switch.
This switch (1-TS-30-103) is a Fenwal Model No. 18003-7, supplied by Fenwal Incorporated, and procured under contract 75K13-86835 (06/06/75). Seismic test requirements for the temperature switch were waived by TVA for procurement of the switch as delineated in the contract.
This was also indicated in a memo from Chandler to Wilson ( App. A, 5.u; 06/13/75) with instruction not to obtain seismic testing of the Fenwal switch because previous seismic qualification had been established by TVA for this device.
TVA judged the temperature switch seismically qualified in May 1975 on the basis of similarity to other temperature switches (Fenwal Model No. 17002-40) qualified by General Electric seismic test report No. 225A6290 ( App. A, 5.aa; 12/14/69) for another nuclear plant application. This was confimed by TVA personnel in a telephone call on 10/24/86 with the evaluation team ( App. A, 7.n).
Upon review of the GE seismic test, the evaluation team noted that this testing was perfomed prior to issue of IEEE 344-1971.
The test on the temperature switch only covered a test frequency range of 5 to 33 hertz and did not include 1 to 5 hertz whereas the commitment of SNP FSAR Section 3.10.1 stated that the test frequency range in all cases covered 1 to 25 hertz as a minimum.
In addition, the test did not give the sweep rate of change and duration of the sweep during vibration endurance test of the temperature switch, and the mounting detail of the tested switch was not completely shown.
Such data would be required to assess the technical adequacy of the test report.
However, additional temperature switches were procured under contract 81PN1-829261 (06/18/81) during 1981.
Fenwal Model No. 18003-7 was one of the items requested.
Fenwal Inc. informed TVA in a letter from Murphy 0103D - 01/15/87
TVA EMPLOYEE CONCERNS REPORT NLMBER: 223.3 (B)
SPECIAL PROGRAM REVISION NLSEER: 1 PAGE 10 0F 20 to Hannah ( App. A, 5.v; 06/04/81) that Fenwal Model 18003-7 was obsolete and had been replaced by 18023-7 which was the same in form, fit, and function.
This new model 18023-7 was tested by Wyle Laboratories and documented in Report No. 17509-1, Rev. C, (App. A, 5.1 ; 05/07/82).
The new switch was rigidly mounted on a fixture during the test, which was in accordance with TVA's prescribed seismic requirement in Purchase Order No. TV-56071A.
The Wyle test report 17509-1 was approved by TVA as documented by memo from Huie to CEB files ( App. A, 5.ff; 07/26/83).
The evaluation team has reviewed this report and considers it acceptable and applicable to temperature switch 1-TS-30-103.
The temperature switch (1-TS-30-103) is used in the ventilation system to monitor changes in ambient temperature.
The location of the switch (Fenwal Model 18003-7) is shown on Drawing 47W920-5, R30, which has a note instructing the field to mount the switch under the grating floor.
No mounting detail is called out on the drawing.
The configuration of the switch is shown on Fenwal Drawing 18003-7, Rev. B/7 dated 06/21/68.
The switch is about 5 inches long,1/2-inch in diameter, and made of stainless steel.
One end of the switch is double threaded.
A walkdown by the evaluation team found that the junction of the double threaded portion of the switch is connected to two condulets with the main body of the switch (about 3-1/2 inches long) housed inside the first condulet.
The condulet is about 6 inches long.
The other end of the first condulet is bolted to a wall-4nounted Unistrut using a single round head machine screw about 1/4-inch in diameter located along the axis and ahead of the switch and approximately 6 inches from the double threaded end. The other end of the second condulet is connected to a conduit.
The distance between the point-cf-support of the first condulet and the next support, the conduit, is about 2 feet 6 inches.
Such mounting is different from that ',ed in qualification testing. The switch did not have TVA's Instrument Tag (No.1-TS-30-103) on it; however, an adjacent instrument has a Tag No.1-TS-30-103A on it.
Since the locations of instruments 1-TS-30-103 and 1-TS-30-103A are the same on Drawing 47W920-5, the unidentified switch is inferred by the evaluation team to be temperature switch 1-TS-30-103.
In an evaluation team discussion on 10/24/86 with TVA personnel (App. A, 7.n), TVA acknowledged that there are no design mounting details or current evaluations of the existing detail for temperature switch 1-TS-30-103 and stated that it plans to evaluate the mounting as corrective action for this employee concern.
TVA stated that a cursory field evaluation of the switch finds that the installation appears to be adequate.
TVA also indicated that it 0103D - 01/15/87
TVA EMPLOYEE CONCERNS REPORT NIMBER: 223.3 (B)
SPECIAL PROGRAM REVISION NLMBER: 1 PAGE 11 0F 20 will file a Problem Identification Report (PIR) to detemine j
appropriate corrective action in conjunction with on-going configuration control efforts and corrective actions for other Significant Condition Report (SCR)/PIRs.
l A later evaluation of the as-built mounting detail of the switch was perfomed by TVA (App. A, 5.bb) on 10/31/86.
The as-built installation of the line-mounted switch has been analytically detemined to be rigid by TVA. Upon review of TVA's evaluation, the evaluation team observed that TVA assmed that the area moment of inertia of the 1/2-inch diameter threaded switch is the same as the 1-inch diameter in-line conduit in calculating the natural frequency of the line-mounted switch installation. The analytical model assmed a simply supported beam with a constant area moment of inertia of the 1-inch diameter conduit. Although this asseption is not appropriate, the evaluation team considers the i
frequency calculated by TVA to have adequate margin to qualify the line-mounted switch installation as rigid; therefore, the i
installation of this switch is adequate.
The lack of an appropriato design mounting detail or evaluation prior to this investigation indicates a need for TVA review of other field-mounted local instruents.
G. Gilbert / Commonwealth Report In January 1986, TVA asked Gilbert / Commonwealth, Inc. (G/C) to review the technical adequacy of design changes perfomed for the Sequoyah Nuclear Plant, Units 1 and 2, between issuance of the operating license and June 1985. Some of the technical issues identified by G/C during the review were related to seismic qualification of instrumentation. For example, Technical Issue Data Sheet No. 4 of G/C Report No. 2614 (App. A, 5.n) addresses the specific qualification issue for the pnematic quick exhauster, the i
generic issue of seismic qualification of accessortes mounted on equipment, and the lack of engineering detail in design output docuents leading to unacceptable installations.
In response to these concerns, TVA has cormnitted to improving the content of Engineering Change Notice (ECN) packages to include more design details, to an improved method of seismic evaluation for Instruent i
and Control (IAC) accessories, and to a sampling and review plan to determine the acceptability of accessories installed since issue of SQN's operating license.
NRC perfomed a special inspection of the G/C review and found it thorough and appropriate as indicated in a letter from Taylor to White ( App. A, 5.x; 04/22/86). The NRC also indicated that the technical and generic issues appear valid. The issue of the i
1 l
01030 - 01 /15/87
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l TVA EMPLOYEE CONCERNS REPORT NWBER: 223.3 (B)
SPECIAL PROGRAM REVISION NW8ER: 1 PAGE 12 0F 20 pnetsnatic quick exhauster installation was classified as Deficiency Item D3.1-1 on NRC I&E Report Nos. 50-327/86-27 and 50-328/86-27.
TVA responded on this item in a letter from Gridley to Grace (App.
A, 5.y; 07/28/86). The TVA corrective action response stated that seismic adequacy of the existing pnetsnatic exhauster installation has now been adequately documented, and no hardware deficiencies were found by the seismic analysis.
Similar issues are also addressed in another NRC letter from Taylor to White (App. A, 5.ee; 10/21/86) regarding possible degradation of the seismic qualification of TVA's previously qualified equipment.
H. TVA SQN Generic Concern Task Force Review & Element Report No.
80501 - SQN In June 1986, TVA SQN Generic Concerns Task Force (GCTF) reviewed employee concern IN-85-463-006 regarding " typical drawings for instrument installation" (App. A, 5.cc).
This concern was recently addressed in Element Report 80501-SQN (App. A, 5.dd). Both reports concluded that there were no " typical" drawings for locally mounted safety-related instruments before the early 1980s; that the instrianent qualification for harsh environnent "walkdowns" showed problems with instrisnent mountings; and that the Gilbert / Commonwealth report found that inadequate design drawings had led to discrepancies with instrianent mountings.
Findings:
a.
The local panel-mounted pressure transmitters (1-PT-1-30 and 1-PT-1-26C) were installed in accordance with the design drawing, which is based on documented engineering calculations and evaluations.
The local field-mounted temperature switch 1-TS-30-103 was installed without a design drawing mounting detail or doctanented evidence of application of good engineering judgnent which is integral to the engineering process industry-wide.
Current requirements in i
the nuclear industry are to justify such judgnent with technical documentation.
Based on review of the recent calculation by the evaluation team, the temperature switch has now been detennined to be adequate (App. A, 5.bb).
0103D - 01/15/87
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TVA EMPLOYEE CONCERNS REPORT NLMBER: 223.3 (B)
SPECIAL PROGRAM REVISION NLMBER: 1 PAGE 13 0F 20 b.
The local panels where both pressure transmitters were mounted were qualified by testing and/or analysis.
The as-built installation of local fieldwnounted temperature switch 1-TS-30-103 lacked seismic analysis or other evaluation at the start of this report investigation as indicated in finding a. above.
The design mounting bracket of the Foxboro transmitter shown on alternate Section Al-Al of Detail B19, Drawing 47W600-19 is more flexible than the qualified approximately 1-inch deep bracket. The evaluation team perfomed a qualification calculation for alternate l
Section Al-Al and detemined that this detail is adequate.
c.
Instrianents may be acceptably qualified to meet seismic requirement by analysis, testing, a combination of both, or i
similarity.
Both pressure transmitters,1-PT-1-30 and 1-PT-1-26C, were seismically qualified by testing.
The function of the transmitters was acceptable during and after i
seismic testing, according to dactmented infomation provided l
by TVA.
Temperature switch 1-TS-30-103 (Fenwal Model 18003-7) was judged seismically qualified by TVA in 1975 based on similarity to another temperature switch (Fenwal Model 17002-40) tested by General Electric (App. A, 5.aa). A 1982 test report by Wyle Labs (App. A, 5.1) indicated that the I
function of the temperature switch was acceptable during and l
after seismic testing. The test results indicate adequate seismic qualification for temperature switch Fenwal Model 3
{
18023-7.
Since Fenwal Model 18003-7 is the same in form, fit, and function as Model 18023-7, temperature switch 1-TS-30-103 is seismically qualified by similarity.
l
==
Conclusions:==
Based on current infomation, the evaluation tean concludes that adequate doctmentation has been provided for the three instrtsnents to demonstrate seismic qualification to the requirements of FSAR Section 3.10.
In addition, the panel mountings for the two transmitters similarly meet the requirements of FSAR Section 3.10; however, there was a lack of design mounting detail for the field-mounted temperature switch.
Based on review of the recent calculation by the evaluation team, the temperature switch has now i
been detemined to be adequate.
l l
l i
l 01030 - 01 /15/87
TVA EMPLOYEE CONCERNS REPORT NUMBER: 223.3(B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 14 0F 20 The lack of an appropriate design mounting detail or evaluation prior to this investigation for the temperature switch indicates a need for TVA review of other field-mounted local instruments.
The documentation of seismic qualification of local instruments reviewed generally meets TVA commitments in SNP FSAR Section 3.10 for the instruments reviewed, but weaknesses exist in the seismic documentation retrieval systems.
Conclusions regarding the specific issues raised by this employee concern are:
a.
The issue that local instruments are installed using good engineering judgment is valid.
b.
The issue that no seismic analysis was performed for the installation of local panel-mounted instruments is not valid; however, this issue is valid for installation of local field-mounted instruments, c.
The issue that no seismic analysis was performed for local instruments is not valid since proper qualification tests were performed.
10.
CORRECTIVE ACTION To comply with the design requirements, TVA has committed to the following corrective action plan (CAP) (TCAB-020, App. A, 5 99),
which is the same CAP for Element Report 80501-SQN. TVA will prepare a walkdown procedure to facilitate a field walkdown.
SQN-DNE will perform the walkdown to establish completeness of design and verify as-built installations of all safety-related instruments required for safe shutdown, mitigate core damage or to prevent releases in excess of 10CFR100 limits (FSAR Chapter 15 events) before plant restart; all other safety-related instruments will be subjected to the same walkdown process after plant restart.
Corrective actions will be initiated as required for each incompletely documented or nonconforming installation.
Engineering Change Notice (ECN) will also be generated to provide adequate installation details.
Further, TVA is committed to issue similar ECNs, as required, for future installation of instruments.
TVA's CAP as described meets its FSAR commitment for the Category I instrumentation at SQN.
The evaluation team, therefore, concludes that the stated CAP is an acceptable resolution of the concern and should also preclude recurrence of the problem.
01030 - 01/15/87
TVA EMPLOYEE CONCERNS REPORT NIMBER: 223,3 (B)
SPECIAL PROGRAM REVISION NLMBER: 1 PAGE 15 0F 20 APPENDIX A 5.
DOCLMENTS REVIEWED RELATED TO THE ELEMENT:
a.
TVA Drawings:
" Mechanical Instruent Tabulation" 478601 18, RS2 47B601-1-21, RS2
" Mechanical Instruent Tabulation" 47B601-30-28, R53 -
" Mechanical Instrument Tabulation" 47W600-31, R17
" Mechanical Instruments and Control"
" Mechanical Instruents and Control" 47W600-14, R4 47W600-19, R13
" Mechanical Instruents and Control" 47W600-92, R6
" Mechanical Instruents and Control"
" Mechanical Instruents and Control" 47W600-23, Ril 47W600-21, R8
" Mechanical Instruments and Control" 47W920-5, R30
" Mechanical Heating, Ventilating and Air Conditioning" 47W352-3, R0
" Mechanical Instruents and Controls Panel - Seismic Test" b.
TVA Procurement Contract:
68C60-91934 Nuclear Steam Supply System for Undetennined Nuclear Plant (s) (04/26/68) 73C3-92784 Pressure Switches (08/01/72) 75K13-86835 Temperature Switches (06/06/75) 72C33-92800 Fabrication of Local Panels and Installation of Instruments (04/14/72) 81PN1-829261 Temperature Switches (06/18/81) c.
TVA Specifications:
9382 Nuclear Steam Supply System 1569 Controls and Metering 1499 Controls and Metering d.
TVA Calculations:
Seismic Analysis of Instruentation Rack Frame of Drawing 47W352 (06/29/72)
Seismic Qualification of Wall Mounted Panels of Drawing 47W600-23 [B25 861002 801] (10/02/86) e.
Vendor Drawing:
Fenwal Drawing 18003-7, Rev. B/7 (06/21/68) f.
Westinghouse Topical Report, " Seismic and Environmental Testing of Foxboro Transmitters," WCAP-8541, (07/75) 0103D - 01/15/87
TVA EMPLOYEE CONCERNS REPORT NLM8ER: 223.3 (B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 16 0F 20 APPENDIX A (Cont'd) g.
Acton Enviromental Testing Corp. Test Report No. T3-1091,
" Seismic Vibration Test of E10 Series Transmitters," (12B3) h.
TVA memo from F. H. Coleman to CEB files, " Seismic Qualification of Foxboro Series E10 Transmitters" for WBN Contract 828973, [CEB 810903 252), (09/03/81) 1.
TVA letter to Wolfe and Mann Manufacturing Company, dated November 19, 1974 from F. W. Chandler to D. M. Salisbury on TVA contract 72033-92800 transmitting approval of Wyle Laboratories Test Report No. 42807-1.
j.
Wyle Laboratories Test Report No. 42807-1, " Seismic Simulation Test Program on an Instrumentation Rack,"
(08/26/74) k.
Bailey Meter Company Test Report No. 507, " Seismic Vibration Tests on GE-MAC Type 555 D/P Transmitters and Type 556 Pressure Transmitters," (revised 05/25B3) 1.
Wyle Laboratories Report No. 17509-1, " Qualification Plan for Fenwal Temperature Switches," Rev. C, (05/07/82) m.
Wyle Laboratories Test Report No. 42377-1, " Seismic Simulation Test Program on Instrumentation Rack," (11/08B2) n.
Gilbert /Consnonwealth Report No. 2614 " Final Report Technical Review of Sequoyah Nuclear Plant Modifications for TVA,"
(03/03/86) o.
Letter from S. A. Varga, NRC, to G. Williams, Jr., TVA,
[0ES 761122 022] (11/16/76) p.
Letter from J. E. Gilleland, TVA, to S. A. Varga, NRC,
[ DES 770209 016] (02/07/77) q.
Letter from D. B. Weaver, TVA, to R. L. Keith, Wolfe and Mann Manufacturing Company, (04/17/73) r.
Letter from K. A. Henrichsen, Bailey Meter Co., to D. B.
Weaver, TVA, (05/25B3) s.
TVA memo from J. I. Givens to R. M. Pierce (01/09B3) 01030 - 01 /15/87
TVA ENPLOYEE CONCERNS REPORT NLM8ER: 223.3 (B)
SPECIAL PROGRAM REVISION NLMBER: 1 PAGE 17 0F 20 APPENDIX A (Cont'd) t.
Letter from D. R. Patterson, TVA, to K. A. Henrichsen, Bailey Meter Co., (06/28/73) u.
TVA memo from F. W. Chandler to W. S. Wilson, (06/03/75) v.
Letter from E. T. Murphy, Fenwal Inc., to F. Hannah, TVA, (06/09/81) w.
TVA memo from R. L. Gridley to Those Listed, "Sequoyah Nuclear Performance Plan - Volurne II - Final Concurrence,"
[L44 860714 800] (07/14/86) x.
Letter from J. M. Taylor, NRC, Director of Office of Inspection and Enforcement, to S. A. White, TVA, Manager of Nuclear Power, "NRC Reports 50-327/86-27 and 50-328/86-27," [L44 860506 542],
(04/22/86) y.
Letter from R. L. Gridley, TVA, Director of Nuclear Safety and l
Liunsir; to J. N. Grace, NRC, Region II Adninistrator,
" Inspection Reports 50-327/86-27 and 50-328/86-27.
Response to Deficiencies and Unresolved Items," [L44 860729 801], (07/28/86) z.
NRC's NUREG-0011, Safety Evaluation Report related to operation of Sequoyah Nuclear Plant Units 1 and 2, March 1979 aa.
TVA memo from F. W. Chandler to R. G. Damer with attached, "GE Seismic Test Results, 225AG290, on Fenwal Switch 17002-40,"
(06/24/75) bb.
TVA DNE Calculation, " Temperature Switch Mount Evaluation,"
[B25 861031800]
cc.
TVA SQN GCTF Report on Employee Concern No. IN-85-463-006, R1,
" Typical Drawings for Instrurnentation," (06/04/86) dd.
TVA Employee Concerns Report No. 80501-SQN, " Engineering Doctanent Quality," R0, (09/24/86); R3, (12/17/86) l ee.
Letter from J. M. Taylor, NRC, Director of Office of Inspection and Enforcement, to S. A. White, TVA, Manager of Nuclear Power, "SQN Units 1 and 2, Procurement Insgection, September 15-19, 1986, September 29-October 3,1986,
[A02 861023 019),
(10/21/86) ff.
TVA memo from J. T. Huie to CEB files, " Seismic Qualification of Temperature Switches, Wyle Test Report 17509-1" for TVA Contract TV-56071 A, [CEB 830726 254), (07/26/83) 01030 - 01/15/87
TVA EMPLOYEE CONCERNS REPORT NLMBER: 223.3 (B)
SPECIAL PROGRAM REVISION MlMBER: 1 PAGE 18 0F 20 APPENDIX A (Cont'd) gg.
TVA letter from G. R. McNutt to G. L. Parkinson, " Employee Concern Evaluation Program - SQN Restart Program - Corrective Action Plan," TCAB-020, (12/05/86) 6.
WHAT REGULATIONS, LICENSING COM ITMENTS, DESIGN REQUIREMENTS OR OTHER APPLY OR CONTROL IN THIS AREA 7 a.
SNP FSAR Update through Amendnent 3 Section 2.5, " Geology and Seismology" Section 3.1, "Confonnance with NRC General Design Criteria" Section 3.7, " Seismic Design" Section 3.10, " Seismic Design of Category I Instrumentation and Electrical Equipment" I
b.
Appendix F of Sequoyah Nuclear Plant Quality Assurance Manual, " Design Criteria for Qualification of Seismic Class I and Class II Mechanical and Electrical Equipment," R2 (01 /24/73) c.
IEEE 344-1971, "IEEE Trial-Use Guide for Seismic Qualification of Class I Electric Equipment for Nuclear Power Generating Stations" d.
IEEE 344-1975, "IEEE Recommended Practices for Seismic Qualification of Class 1E Equipment for Nuclear Power Generating Stations" 7.
LIST REQUESTS FOR INFORMATION, MEETINGS, TELEPHONE CALLS, AND OTHER DISCUSSION 5 RELAILD TO ELugt.NT.
a.
RFI SQN #621, (10/06/86) 01030 - 01 /15/87 i
TVA EMPLOYEE CONCERNS REPORT NUM8ER: 223.3 (B)
SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 19 0F 20 APPENDIX A (Cont'd) e.
TVA Transmittal #116, Item 15 (09/22/86) h.
TVA Transmittal #120, Item 5 (09/26/86) 1.
TVA Transmittal #117 Item 3 (09/23/86) j.
TVA Transmittal #123, Items 5 and 7 (10/01/86) k.
TVA Transmittal #122 Iten 9 (09/30/86) 1.
TVA Transmittal #141, Iten 6 (10/29/86) m.
Telephone call from J. W. Benkert, Bechtel, to J. K.
Rochelle, TVA, ION 337 (10/25/86) n.
Telephone call from J. K. Rochelle, et al., TVA, to J. W.
Benkert, et al., Bechtel, IOM 352, (10/24/86) 01030 - 01 /15/87 1
TVA EMPLOYEE CONCERNS REPORT NLMBER: 223.3 (B)
SPECIAL PROGRAM REVISION NLMBER: 1 PAGE 20 0F 20 CATD LIST The following CATD identifies and provides corrective actions for the findings included in this report:
223.03 SQN 01 (12/04/86) 1 01030 - 01 /15/87
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