ML20209G398

Rev 2 to TVA Employee Concerns Special Program Element Rept, Test Procedure/Programs

ML20209G398
Person / Time
Site:	Sequoyah
Issue date:	04/22/1987
From:	Aycock W, Russell Gibbs, Murphy M TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20209G315	List: ML20209G310 ML20209G354 ML20209G375 ML20209G398 ML20209G423 ML20209G438
References
307.06-SQN, 307.06-SQN-R02, 307.06-SQN-R2, NUDOCS 8704300539
Download: ML20209G398 (12)

Text

d e-m. -- _

TVA EMPLOYEE CONCERNS REPORT NUMBER: 307.06-SQN SPECIAL PROGRAM REPORT TYPE: Sequoyah Nuclear Plant Element REVISION NUMBER: 2 TITLE: Test Procedure / Programs REASON FOR REVISION:

To incorporate TAS and SRP and conunents and add Corrective Action Tracking Document reference.

[R1 To incorporate NRC comments.

lR2 t

PREPARATION PREPARED BY:

W. L. Aycock

//-d-f'f SIGNATURE DATE REVIEWS PEER:

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SIGNATURE DATE TAS:

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SIGNATURE

/ YATE CONCURRENCES

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SIGNATURE DATE

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SIGNATU[*[

DATE APPROVED BY:

A. 6,Mb-2M81 N/A CSP MAN'AGER

'DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)

• SRP Secretary's signature denotes SRP concurrences are in files.

1RORT 8704300539 870427 PDR ADOCK 05000327 p

PDR

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TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT EMPLOYEE CONCERNS TASK GROUP OPERATIONS CEG Subcategory: Site Program / Procedures Element: Test Procedure / Programs Report Number: 307.06 - SQN Revision 2 Concern: XI-85-001-001 SQM-86-004-017 WBN-233 XX-85-077-001 IN-86-209-011 Evaluator:

/M 9-6-47 W. L. Aycafck Date Reviewed by:

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. Mper Date OPS C Approved by:

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I.

Test Procedures / Programs i_ _ _

This Report will evaluate three Sequoyah Nuclear Plant (SQN) specific issues, one Watts Bar on-site concern determined generically applicable to SQN, and one generic issue. These issues are evaluated:

1.

Improper testing of D-G Batteries 2.

Improper testing of spent fuel storage racks i

I 3.

Lack of surveillance testing of the fire detection system l

IR2 4.

Failure to complete prerequisite requirements for pre-operational I

tests l

l S.

Fragmented testing resulting from lack of single point system I

responsibilities.

1 II.

Specific Evaluation Methodology This element consists of the following concerns:

XX-85-001-001 Sequoyah D-G batteries have been replaced without initial testing per IEEE-450. A Potentially Reportable Occurrence (PRO) was written and determined not reportable by the compliance section.

SQM-86-004-017 Certain safety equipment may not have been properly tested. One of the items involved are some tubes on the fuel floor. Other items are not specifically known. Details known to Quality Technology Corporation (QTC), withheld because of confidentiality. No further information may be released.

WBN-233 System 13, Fire Protection System, does not have enough approved manuals or prints for maintenance.

The concerned individual (CI) has indicated that a Surveillance Instruction (SI) does not exist to check system from the transmitter / receiver panel through to the console computer. CI has indicated that an approved master list does not exist of printouts or modifications to the system.

Individual is also concerned that individuals maintaining / operating the system are inadequately trained. CI requests that a check on availability of spare parts be made.

XX-85-077-001 Sequoyah - early 1980 and middle of 1981. Unit 2.

The preoperation Pre-requisites are questionable.

Details known to QTC, withheld due to confidentiality. CI has no further information.

Construction Department concern.

Page 1 of 10

j R;visien 2 IN-86-209-011 TVA fragments system responsibilities to minimize

~

problems when an employee leaves. The overall result of this policy is that partial tests, partial reviews, and increased coordination efforts are required. This fragmented approach leads to misunderstandings, and mistakes. Trying to coordinate with several people leads to retesting, reworking, moving equipment, removal equipment, and removal and reinstallation of piping systems.

Systems may be broken up into several different tests, and you have several different engineers doing the tests. Interfaces are not always clear which leads to nistakes and misunderstandings. With these interface problems test results could potentially be incorrect or incomplete. CI has no additional information. nuclear power department concern.

c These concerns were evaluated by reviewing appropriate TVA documents and procedures, Final Safety Analysis Report (FSAR), Regulatory and Code Requirements, expurgated files and one specific Nuclear Safety Review Staff (NSRS) Report. Additionally, informal interviews lR2 were held with personnel from the system engineering section, post modification test section, instrument engineering, health physics, and IR2 industrial safety.

l This evaluation was conducted in accordance with the Evaluation Plan for the Operations category of the Employee Concern Task Group.

III.

Findings This section of the employee concern evaluation will address findings I

related to the concerns in the same order described in Section II of lR2 this Report.

l Findings XX-85-001-001 Concern XX-85-001-001 states:

"Sequoyah diesel generator batteries I

have been replaced without testing per Institute of Electrical and l

Electronic Engineers Standard (IEEE)-450" and further questions the I

resulting reportability evaluation which was performed by the l

compliance section. This evaluation found that the IA-A battery was l

replaced in 1980 under workplan (WP) 8798 and the 1B-B, 2A-A, and 2B-B l

batteries were replaced in 1982 under WP 9119. The work involved I

removing the existing, obsolete Exide batteries and installing new C&D l

type 3DCU-9 batteries and racks. WP 8798 initially required a i

functional test to verify the batteries' ability to flash the generator lR2 field on diesel startup. This test was deleted and replaced with a l

requirement to run SI-238. SI-238 is a periodic test to verify l

compliance with the SQN Technical Specifications. The test results I

were satisfactory. WP 9119 initially required maintenance to perform l

SI-238.2, a full battery performance test, but was revised to require l

only SI-238 and a diesel start operability check. Note that these two l

Page 2 of 10

R visien 2 tests were completed on all the battery banks including 1A-A.

Test i

results were satisfactory. The SQN Electrical Maintenance Supervisor l

stated that the diesel generator batteries had not been considered l

"large storage batteries" and were thus not tested in accordance with l

IEEE-450.

In support of his contention, he noted that the diesel I

generator batteries were physically much smaller than the plant vital I

batteries and that their application was for a very short (10 see) duty I

cycle. The Potential Reportable Occurrence (PRO-I-85-129) to which the l

CI refers stated that the plant is not committed to IEEE-450 with l

respect to diesel generator batteries. This statement was made after a l

review of the FSAR, Technical Specifications and 10 CFR 50, 1

Appendix A.

The SQN Safety Evaluation Report (SER) states that l

Class 1E batteries will be tested according to the requirements of l

IEEE-450-1972. This commitment, however, is now interpreted to exclude l

the diesel generator batteries since the SER section refers specifically l to 125Vdc batteries which " provide uninterruptible power for control, 1

instrumentation, annunciation, and emergency lighting" and does not I

mention the diesel batteries.

l l

In August, 1985, NSRS investigated the concern. The resulting report l

chronicled the history of each DG battery and any testing which had I

been performed. The report questioned the validity of the PRO and l

recommended six actions to upgrade the battery maintenance and testing l

program:

l l

1.

Review and re-establish traceability of cells.

IR2 1

2.

Verify existence of or initiate an acceptance test for the l

installed batteries.

l l

3.

Performance test the batteries.

l l

4.

Service test the batteries.

l l

5.

Review the battery programs at other TVA sites.

l l

6.

Write a policy statement defining interdepartmental l

responsibilities for the overall battery program.

l l

The recommendations were met by the following:

l l

1.

Electrical Maintenance Section Letter (EMSL) E-47 was initiated to l

track the cells by serial number.

l l

2.

SQN found that no acceptance test wss available, so a full l

3.

performance test was run per SI-238. This test meets the IEEE 450 l

4.

requirements.

Since the performance test parameters envelop the l

service test requirements, the response stated that the performance I

test results would be used in lieu of a separate service test.

l I

5.

The three other TVA sites each filed a response to NSRS justifying l

l their individual battery progtsms. Based on the regulatory l

requirements cited, the responses were adequate.

l Page 3 of 10

7....

7 R;visics 2 6.

DNE responded to this item by citing Sequoyah Engineering Procedure l

(SQEP) 13 which makes DNE responsible for all post-modification i

test preparation. This resolves the NSRS concern over.the split of I

responsibility between the plant and DNE.

I I

The present diesel generator maintenance and testing program at SQN is IR2 carried out per the IEEE-450 guidelines. The Electrical Maintenance i

Supervisor stated that although this is not a commitment, a recent INPO l

audit found the program generally in compliance with the standard. A l

review of the performance of SI-238.2 and SI-238 revealed that the l

batteries have been tested appropriately and the test results show that I

the batteries are performing at acceptable levels.

l l

Conclusion Based on the findings, the concern is not valid. Although the plant is l

not specifically committed to testing of the diesel generator batteries I

per IEEE-450, Naintenance has heeded the NSRS and Institute of Nuclear l

Power Operations (INPO) testing recommendations and the resultant program I is adequate. The batteries presently installed have been proven capable, I cells are being tracked to ensure traceability and the ongoing IR2 surveillance program demonstrates adequate performance levels and tech I

l spec compliance.

l Findings SON-85-004-017_

Concern SQN-86-004-017 reads:

"Certain safety equipment may not have i

been properly tested. One of the items involved are some tubes on the I

I fuel floor".

l A review of the expurgated file for this concern did not reveal any l

information to define the affected system or equipment. Informal I

discussions were held with personnel from instrument maintenance, I

industrial safety, pre-operational test, and health physics in an I

attempt to determine the equipment. None of the individuals could I

offer anything move than an " educated guess", but the items offered IR2 included the fuel transfer tube, spent fuel racks, service air piping.

l and electrical conduit. Of the items, conduit was dismissed since it l

is not actually tubing and is not usually subject to any testing. The i

service air piping is not safety related and thus does not undergo l

formal testing. The fuel transfer tube and the spent fuel racks

(

appeared to be the most likely items, and further investigation l

l revealed that the fuel racks were tested in a manner which was l

out-of-the ordinary for SQN. Por this reason, the fuel racks were l

assumed to be the referenced equipment and an evaluation of testing i

associated with them was undertaken.

I i

f Work Plan 8861 documented the installation and testing for the Spent Fuel Pool Hi-density Storage Racks. Unlike the original racks which were tested under the TVA preoperational test program, this testing was l

contracted to National Nuclear Corporation (NNC). The test included Neutron Attenuation and Dras Tests for the purpose of ensuring proper l

i Page 4 of 10

1

-- - : r rr-R3risica 2 moderation of spent fuel assemblies and ability of assembly l

insertion / withdrawal. The documentation verifying that these lR2 objectives were met are provided in the workplan. Although this i

documentation varies from the initial rack preoperational test the i

requirements of Regulatory Guide 1.68 have been met. The test was l

witnessed by TVA Quality Assurance personnel and the workplan I

and associated test was reviewed and approved by the design 1

organization.

Fuel assemblies are currently being stored in these i

racks with no indication of the racks failing to perform as intended.

I conclusion Although the test documentation is not in a format similar to standard i

TVA pre-operational tests, the results prove that the fuel racks are lR2 capable of performing as designed.

Further, the test was approved by l

TVA DNE, conducted under TVA Quality Assurance procedures and the 1

resulting data were reviewed and approved by DNE. For these reasons I

1 the concern is determined not valid.

Findings-WBN-233 I

Concern WBN-233 states:

l

" System 13. fire detection system, does not have enough approved l

manuals or prints for maintenance. CI has indicated that an SI I

does not exist to check system from the transmitter / receiver panel I

thru to the console computer. CI has indicated that an approved lR2 master list does not exist to printouts or Modifications to the i

system. Individual is also concerned that individuals I

maintaining / operating the system are inadequately trained."

l This concern was generated at Watts Bar and evaluated as a generic l

issue for Sequoyah due to the similarity of the fire detection i

systems at the two plants. Of the five issues noted in the concern; I

however, only one has a direct bearing on the SQN hardware:

that of the I

lack of a surveillance instruction to check the system from the I

transmitter / receiver panel through to the console computer. The i

remaining issues in the concern are related to training, spare parts.

l drawings and manuals for the fire detection system at Watts Bar.

In I

the evaluation " console computer" was taken to refer to the fire i

detection alarm console in the main control room.

I lR2 At Sequoyah, SI-234 describes testing of all Technical Specifications l

related fire detection loops. Four separate checks are made on each l

l a channel functional test of detectors, an operational test of I

loop:

l alarms, a detector and alarm circuit supervisory operational test, and l

an operational test of non-supervised circuits from the panels to

(

operated egulpment. Each of these tests includes specific instructions I

to verify proper indication at the local panel as well as the control l

room alarm console. This instruction is required to be performed on i

six-month intervals.

Page 5 of 10

l

-.<~. R2Visien 2 m- -

1 Conclusion Concern WBN-233 is not valid for Sequoyah. Existing plant instructions I

mandate verification of operability of the fire detection system IR2 l

including the control room alarm console.

Findings-KK-85-077-001 Concern XX-85-077-001 states that during "early 1980 and mid-1981 the i

Since the i

preoperational test prerequisites (were) questionable."

tests were written in accordance with DNE scope documents and were l

lR2 approved by the plant and DNE, this evaluation only attempted to determine if an excessive number of exceptions, deficiencies or changes l

to test prerequisites had been taken. These factors indicate whether I

l the pre-operational staff began a test prematurely.

The review consisted of 33 data packages identified on the test conduct l

This l

los as having begun or ended during the stated timeframe.

I population is deemed adequate to encompass the tests which may have caused the concern. The review did not produce any evidence of I

excessive prerequisite test exceptions, nor changes or deficiencies lR2 which would indicate that the systems were not complete and ready to l

Signoff of test prerequisites at SQN is in compliance with l

test.

I Regulatory Guide 1.68.

Conclusions The concern is not valid. A review of the tests run during the I

l specified time periods indicated adequate fulfillment of the prerequisites. Since the tests are written in accordance with DNE lR2 l

scope documents and approved by DNE the prerequisite requirements are l

judged adequate.

Findings IN-86-209-011 l

Concern IN-86-209-111 states:

l "TVA fragments system responsibilities to minimize problems when an i

employee leaves. The overall result of this policy is that partial I

lR2 tests, partial reviews, and increased coordination efforts are required. This fragmented approach leads to misunderstandings, l

and mistakes. Trying to coordinate with several people leads to l

retesting, reworking, moving equipment, removal and reinstallation l

of piping systems. Systems may be broken up into several different l

l tests, and you have have several different engineers doing the l

t l

tests.

1 l

I i

Page 6 of 10

R3risica 2 Concern IN-86-209-011 was evaluated to assess the methods by which

'l technical responsibility for plant systems is assigned. Previously, I

testing was performed as part of a modification per DNE scoping i

documents if the change was considered large 'or complex, or per a l

workplan engineer-originated test if less complex. This approach could l

1ead to fragmentation as stated by the CI due to several factors.

lR2 First, the definition of a large or complex modification is open to I

interpretation. Secondly, the workplan engineer-originated l

(functional) tests did not receive a review outside the modifications I

Finally, the fact that several modification workplans may be

(

group.

underway on a particular system simultaneously created the possibility l

l of multiple engineers running tests on the system.

As a result of the Post-Modification Test (PMT) Task Force efforts I

coupled with the recovery from the April, 1984 thimble tube ejection I

incident, SQN implemented a Systems Engineering Section (SES) under the l

Technical Support Group. This section's function as defined by the l

Sequoyah Nuclear Performance Plan (SNPP) is to " provide a point of focus I

for the system history, status, special testing, and resolution of major i I

system problems... Systems' engineers will coordinate across organizational lines (i.e. DNE, Operations, Maintenance, and Technical l

Support) to determine the root cause and corrective actions of problems I

involving egulpment/ system interfaces." Discussion with the SES manager IR2 revealed that the section has been implemented under Standard Practice i

SQA-168. This document further defines responsibilities for members of l

In the testing area, System Engineers are required to direct l

the group.

pre-modification and post-modification tests to ensure conformance with I

test requirements. The SES is currently in the review cycle for I

modification workplans to ensure completeness and adequacy of the i

post-mod tests. Note that under SQEP-13 the responsibility for i

~

This move, I

preparation of all post-mod tests is being shifted to DNE.

coupled with the assignment of a dedicated System Engineer is intended I

I to provide a consistent approach to testing.

Conclusion The creation of the SES and the assignment of DNE as the sole l

originating entity for post-mod tests has solved what the SNPP l

described as a " lack of a clear focus for systems problems which l

involve many components..." The concern was valid pelor to these IR2 j

The new organization represents an acceptable l

program improvements.

l corrective action.

IV.

Root Cause l

The five concerns each reflect a distinct guestion and root causes were considered separately, XX-85-001-002: Root cause not determined. Concern not valid.

lR2 SQM-86-004-017: Root cause not determined. Concern not valid.

i i

i 1

e

[

Page 7 of 10 6

i

R:visica 2 WBN-233: Root cause not determined. Concern not valid.

XX-86-077-011: Root cause not determined. Concern not valid.

IN-86-209-011: Root cause was failure to define specific lR2 I

responsibilities.

V.

Generic Appilcability XX-85-001-001: This concern was considered for generic applicability during the NSRS investigation. Justification was solicited and received from each site for battery maintenance programs. Based on review of the justifications, this concern is limited to SQN.

SQM-86-004-017: This concern was determined not to have a valid basis, nor generic appilcability.

WBN-233 concern not substantiated at SQN: Non-generic XX-85-077-001 concern not substantiated at SQN: Non-generic.

IN-86-209-011: This is a system-wide consideration, and major revisions to the program are underway.

VI.

References SQN AI-19. Revision 17. Part IV; Nodifications After Licensing 1.

2.

NQAM-II 4.1 Revision 0; Prooperational Testing 3.

U.S. NRC Regulatory Guide 1.68 SQN Surveillance Instruction SI-234-1. Revision 16; Technical 4.

Specifications Fire Detectors 5.

SQN Workplan 8861; Spent Fuel Pool Hi-density Storage Racks 6.

NSRS Report I-85-109-SQN; dated November 18, 1985 7.

IEEE Standard 450-1980, Recomunended Practice for Maintenance, Testing, and Replacement of Large Lead Storage Batteries for Generating Stations and Substations 8.

SQN FSAR Section 8.3.2.1.1; Vital 125VDC System 9.

Sequoyah Engineering Procedure. SQEP-13. Revision 0; Procedure for Transitional Design Change Control 10.

Sequoyah Engineering Procedure SQEP-14 Revision 0; Assembly and Evaluation of Electrical Test Results i

Page 8 of 10 I

..~.

R:visica 2 Safety Evaluation Report Related to Operation of Sequoyah Nuclear 11.

Plant, Units 1 and 2 - NUREG 0011 March 1979 12.

Potentially Reportable Occurrence (PRO) 185-129, dated April 17, 1985 Memorandum from W. C. Bibb, BFN, to John Hutton, Nuclear Services, 13.

dated December 23, 1985.

Subject:

Browns Ferry Nuclear Plant (BFN) - Investigation of Alleged Failure to Test Diesel Generator Replacement Batteries at Sequoyah Nuclear Plant (SQN) -

Nuclear Safety Review Staff Report Number I-85-109-SQN. RIMS Number Lol 851226 690 Memorandum from James P. Darling, BLN to John Hutton, Nuclear 14.

Services, dated December 6, 1985.

Subject:

Bellefonte Nuclear Plant (BLN) - Investigation of Alleged Failure to Test Diesel Generator Replacement Batteries at Sequoyah Nuclear Plant (SQN) -

Nuclear Safety Review Staff Report Number I-85-109-SQN. RIMS Number Lol 851209 051 Memorandum from E. R. Ennis, WBN to John Hutton, Nuclear Services, 15.

dated December 3, 1985.

Subject:

Watts Bar Nuclear Plant (WBN) -

Investigation of Alleged Failure to Test Diesel Generator Replacement Batteries at Sequoyah Nuclear Plant (SQN) - Nuclear Safety Review Staff Report Number I-85-109-SQN. RIMS Number Lol 851204 673 Memorandum from H. L. Abercrombie, SQN, to John Hutton, Nuclear 16.

Services, dated December 9, 1985.

Subject:

Investigation of Alleged Failure to Test Diesel Generator Replacement Batteries at Sequoyah Nuclear Plant (SQN) - Nuclear Safety Review Staff Report Number I-85-109-SQN (RIMS LO1 851210 116)

Sequoyah Electrical Maintenance Section, Instruction Letter 17.

EMSL-E-47, Revision 1. Battery Unit Traceability Sequoyah Engineering Procedure SQEP-14, Revision 2. Assembly and l

18.

l Evaluation of Electrical Test Results i

l 19.

Surveillance Instruction SI-238.2 Data Shoots:

l l

10-18-85 l

9-13-85 lR2 10-19-85 l

20.

NRC Inspection Report 50-327/86-20 and 50-328/86-20 dated l

l April 23, 1986 (RIMS A0Z-860425-010) t l

21.

NRC Inspection Report 50-327/86-43 and 50-328/86-43 dated l

l September 12, 1986 (no RIMS numbor) l Page 9 of 10

R:visica 2 l

SQN Surveillance Instruction SI-238, Revision 17. Diesel Generator 22.

l Battery System Inspection l

23.

SQN Workplan 8798, dated August 14, 1980 l

l 24.

SQN Workplan 9119. Revision 1. dated April 23, 1982 l

1 l

25.

SQN Surveillance Instruction SI-238 Data Sheet, dated l

January 28, 1986 l

i 26.

SQN Maintenance Instruction MI-10.33. Revision 0. Diesel Generator l

Battery Cell Removal and Replacement 1

IR2 SQN Surveillance Instruction SI-238.2, Revision 7. Diesel Generator 27.

l Battery Capacity Test I

Memorandum from H. G. Parris, P&E Nuclear, to K. W. Whitt, NSRS, l

28.

19, 1985. Subject Investigation of Alleged Failure l

dated November to Test Diesel Generator Replacement Batteries at Sequoyah Nuclear l

Plant-Nuclear Safety Review Staff Report No. I-85-109-SQN, l

l (RIMS Number 500-851118-800) l 1

l VII.

Immediate and Long-Term Corrective Actions I

l CATD 30706-SQN-01 was issued to request re-evaluation of the The fact that SQN is not committed to l

reportability of PRO-I-85-129.

I test the diesel generator batteries per IEEE-450 was clarified by the response to the NSRS report (S00-851118-800). This is the basis on I

l which SQN determined the PRO not reportable and ECTG considers the determination acceptable. This item is closed.

l t

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