ML20210E310
| ML20210E310 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 08/26/1986 |
| From: | Branch M, Carroll R, Debs B, Mathis J, Paulk G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20210E303 | List: |
| References | |
| 50-327-86-43, 50-328-86-43, NUDOCS 8609220243 | |
| Download: ML20210E310 (11) | |
See also: IR 05000327/1986043
Text
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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REGloN 11
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101 MARIETTA STREET, N.W.
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ATLANT A. GEORGI A 30323
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Report Nos.:
50-327/86-43 and 50-328/86-43
Licensee: Tennessee Valley Authority
6N38 A Lookout Place
1101 Market Street
Chattanooga, TN 37401
Docket Nos.: 50-327 and 50-328
License Nos.: DPR-77 and DPR-79
Facility Name:
Sequoyah Units 1 and 2
Inspection Conducted: July 28, 1986 - August 1, 1986
Inspectors:
~ Date' Signed
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M. W. Braren, InspectpliE TKm Leader
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R. E. Carroll, Jr. , Projecf/ffgfiieer
'Date Signed
G. Paul k, L. , ;#iM'/ $_
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Date Signed
W
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I g ec V (Browns Ferry)
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J. Mathi W KeacL~r inspg#Cor 7
Tate Signed
Approved by:
__
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B. Debs, Section Chief
D4te Signed
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Division of Reactor Projects
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SUMMARY
Scope:
This special, announced inspection was conducted in the area of
Modification Testing (MT) with a concentration on testing associated with
Environmentally Qualified (EQ) equipment modifications. This inspection involved
a review of major or complicated Post Modification Tests (PMT), as well as a
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review of Post Modification Functional Tests (PMFT). Additionally, a followup of
associated Inspector Identified Items, discussed in paragraph 9 of Inspection
Report 327, 328/86-20, was performed.
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Results:
In the areas inspected, two violations were identified.
The first
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violation, discussed in paragraph 6, involved multiple examples of
failure to
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properly implement the requirements of Administrative Instruction (AI)-19,
Part IV, " Plant Modifications After Licensing" and Surveillance Instruction
(51)-166.6, " Post Maintenance Testing of Category A and B Valves." The second
violation, also discussed in paragraph 6, involved a failure to properly change
plant approved procedures.
8609220243 860912
ADOCK 05000327
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REPORT DETAILS
1.
Licensee Employee Contacted
- P. R. Wallace, Plant Manager
L. M. Nobles, Operations and Engineering Superintendent
- B. M. Patterson, Maintenance Superintendeot
- N. E. Andrews, Site Quality Manager
- D. C. Craven, Quality Assurance Manager
- G. B. Kirk, Compliance Licensing Supervisor
- R. W. Olson, Modifications Branch Manager
- M. R. .Sedlacik, Electrical Section Manager, Modifications Branch
- R. M. Mooney, Systems Engineering Supervisor
- J. A. McPherson, Mechanical Test Supervisor
- R. W. Fortenberry, Technical Support Supervisor
- R. V. Pierce, Mechanical Maintenance Supervisor
- H. D. Elkins Jr., Instrument Maintenance Supervisor
- M. A. Skarzinski, Electrical Maintenance Supervisor
- R. H. Smith, Project Management
- J. H. Sullivan, Regulatory Engineering Supervisor
- P. H. Buckholz, Sequoyah Site Representative
S. D. Gilley, Modification Engineer
E. L. Legg, Modification Engineer
J. Edwards, Instrument Maintenance
T. L. Rutledge, Modification Engineer
D._R. Branham, Modification Engineer
Other licensee employees contacted included technicians, operators, shift
engineers and maintenance personnel.
- Attended exit interview
2.
Exit Interview
The inspection scope and findings were summarized on August 1,1986, with
those persons indicated by an asterisk in paragraph one above.
The
following new items were discussed:
a.
Violation for failure to properly implement the requirements of AI-19,
Part IV and SI-166.6 in the area of functional testing.
b.
Violation for failure to properly change plant approved procedures.
This item was initially categorized as an unresolved item then upgraded
after additional discussion with NRC personnel.
The licensee acknowledged the inspection findings.
The licensee did not
identify as proprietary any material provided to the inspectors during the
inspection. At no time during the inspection period did the inspectors
provide written material to the licensee.
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3.
Followup On Inspector Identified Items
a.
(Closed) IFI 327, 328/86-20-03; Review of modifications to Limitorque
Valves to determine effect, if any, of improper wiring. The issue was
. originally addressed in paragraph nine of inspection report 327,
328/86-20 and dealt with the rewiring of approximately 214 Limitorque
Operators to establish EQ qualifications as well as simplifying and
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correcting limit and/or torque switch discrepancies. The inspector was
concerned with the possibility-that the improper wiring of limit / torque
switches could have had an effect on valve operation.
During the review of Work Plan (WP) 11866 (unit 1) and WP 11853
(unit 2), which rewired the limitorque valves, the inspector's concern
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was re-addressed.
It was determined that some of the previous
torque / limit switch combinations did, under certain circumstances, have
the potential of preventing the fulfillment of valve function.
However, the inspector determined that these valves are part of the
ASME Section XI Article IWV valve test program and are tested for
operability on a routine basis per that program.
b.
(Closed) IFI 327, 328/86-20-11; Use of terminology of " perform the
applicable portions of a Plant Operations Review Committee (PORC)
approved procedure". This item is being combined with a related item
associated with changes to approved procedures.
Both items will be
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resolved as part of that issue which is identified as Violation 327,
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328/86-43-02 and discussed in detail in Paragraph 6 of this report.
4.
Unresolved Items
No Unresolved Items were identified during this inspection.
5.
Design, Design Changes, and Modifications (37700)
Although the major objective of this inspection was to determine the
adequacy of Modification Testing, the inspectors did review several of the
modification Work Plans (WPs) for technical adequacy, proper review and
approval, adequacy of safety evaluation as well as drawing and procedure
updates. Work Plans reviewed as well as inspection findings are as follow:
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a.
Containment Pressure Transmitter Modifications
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Engineering Change Notice (ECN) 6554 and WP 11912 replaces the existing
containment pressure transmitters 1 & 2-PDT-30-42 and 1 & 2-PDT-30-43
with qualified Foxboro transmitters per NUREG 0588. These transmitters
provide input to containment isolation and containment spray logic.
The replacement transmitters are functionally and electrically
equivalent. All functional and operability tests were performed with
revised
Surveillance
Instructions
and
Instrument
Maintenance
Instructions (IMI).
An error in documentation was noted on IMI-135
(Foxboro Instrument N-E130M Assembly Instruction) Appendix C data sheet
page 1 of
4,
Rev. 5 for 2-PDT-30-42 instrument.
The work plan
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documentation indicated that lubricant (P/N N0114AA) was used whereas
the correct lubricant should have been P/N X0114AA. A review of power
store procurement records indicated that P/N X0114AA was used for the
assembly installation. The cognizant engineer was made aware of this
documentation error.
The inspector further reviewed all greases,
sealants, and lubricants used in Work Plan 11912 for traceability and
proper usage. No deficiencies were noted other than this documentation
error.
The inspector reviewed Work Plan 11912 closecut package for adequacy
with regulatory requirements and commitments.
The work ' plan
subsections reviewed included a sampling of the work plan control
section, the work plan specification section,
the modification
authorization section, the data inspection sheet section, the material
traceability section, and the vendor information section.
No
deficiencies were noted.
b.
Reactor Coolant System Transmitters Removal to Outside the Crane Wall
ECN L6439
and WP 11750 moves existing reactor coolant system
transmitters 1 & 2 LT-68-320,1 & 2 PT-68-522 and 1 & 2 PT-68-523 to
outside the polar crane wall. The work plan was reviewed to determine
if regulatory requirements were being met.
The work plan status
currently was under the implementation and closecut phases.
Some
portions of the work plan documentation was not yet complete.
Work
instructions and in process signoffs were adequate as completed. The
Accountability of Modification Material forms, required for level I and
II materials (AI-19, Part IV, Attachment 16), were missing from the work
package. - This traceability form is required when material ordered for
one ECN is used instead for another ECN.
Material ordered for ECN
6533, 6550 was used on this work package, ECN 6439. The cognizant
engineer noted that the required forms will be included when the work
plan is closed out. No other deficiencies were noted during the sample
review.
c.
Instrument Setpoint Changes . Due to Environmental Consideration in
Various Systems
ECN L6551 and WP 11916 revises setpoints for various - safety-related
instruments to allow for instrument inaccuracies due to harsh
environments resulting from a high energy line break. The work plan
documentation was reviewed for regulatory adherence and completeness
All instruments in the work plan are 10 CFR Part 50.49 devices. .The
setpoints were
changed
using
existing plant procedures.
No
deficiencies were noted.
d.
Upper Head Injection Water Tank Level Switch Replacement
ECN L6359 and WP 11751 replaces the four Barton Model 288A level
switches on the upper head injection water tank with more reliable
switches. The switches function to close the UHI isolation valves on
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low level in the tank.
The closure of these valves preven.ts
introduction of nitrogen gas into the RCS following the injection of
borated water into the RCS. Under the ECN, the Barton level switches
were replaced with functionally equivalent switches.
After the. initial completion of work on this work plan it was noted
that a design error existed in the connection wiring drawings. A field
change request (FCR4335) was initiated to rework the design errors and
this rework has not been completed to date; therefore, this work plan
is still in the implementation work phase. The work plan, procedural
step 15, related to plant housekeeping after maintenance was not signed
off as complete although the
initial work was completed ~in
September 1985.
The signoff for the foreman to verify cleanliness
should occur after each work phase to assure adequate work controls and
plant housekeeping. No other comments can be currently made about this
work plan since it is still in process. The cognizant engineer was
informed of all inspector concerns.
6.
Modification Testing (72701)
The inspectors selected for review several WPs in the areas of Mechanical
Modification, Electrical Modification and Instrument Modification. The WPs
selected were those initiated between August 1985 and present, with an
attempt to concentrate on modifications in the area of EQ upgrade. The WPs
selected, including those discussed in paragraph five, included the
following:
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11750 (Relocate level transmitter 1 & 2-LT-68-320 & 1 & 2-PT-68-522 &
523), Units 1 & 2
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11751 (Replace Barton level switch on UHI tank), Unit 1
11762 (PMT 52), Unit 1
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11773 (Replace bolted bonnet valves), Unit 1
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11834 (Install flange on various component cooling lines), Unit 2
11853 (Replace wiring on limitorque operators), Unit 2
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11866 (Replace wiring on limitorque operators), Unit 1
11890 (PMT 74 Auto Shut Trip), Unit 2
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11893 (Relocate PT-68-322 & 323 & LT-68-320), Unit 2
11897 (Replace solenoid vivs), Units 1 & 2
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11906 (Replace motors on FCV-2-074-001 & 002), Unit 2
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11912 (Replace 1, 2-PDT-30-42 & 43), Units 1 & 2
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11916 (Change setpoints on various safety-related WST), Unit 2
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11928 (Replace NAMCO limit switches sys 30, 63, 77, 81 & 68), Units
1&2
12040 (Replace Rework & Reroute PP-7118 power feed for DG 2BB),
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Unit 2
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12074 (Replace Nozzles on Steam generators), Unit 2
The review of the above work plans concentrated on the MT aspects of the
Modification Packages. A brief description of the Sequoyah MT program, as
previously discussed in Inspection Report 327, 328/86-20, is provided to
clarify the licensee's terminology and program description. AI-19, Part IV,
Revision 18, is the controling document and specifies the MT process.
This
instruction requires a PiiT if the modification was major and the Division
of Nuclear Engineering (DNE) required it through issuance of a test scoping
document. However, the majority of testing associated with modifications
falls into the category of post modification functional test (PMFT). When a
PMFT is required, AI-19, Part IV requires this test be specified in the WP.
The WP that requires a PMFT must list all checks or tests necessary to be
performed before returning the equipment to service.
This functional test
is required to be comprehensive enough to ensure that the new components
perform their intended function and that the work did not inadvertently
degrade an operating system or component.
Specifics of the Work Plans reviewed and the inspectors' findings are
provided as follows:
a.
Main Steam and Feedwater Root Valves Replacement
ECN 6183 and WP 11773 replaced Hancock 5500 valves with Voght 300 in
portions of Main Steam and Main Auxiliary Feedwater System where design
temperature and pressure caused leakage.
This work (replacement) was
exempt from ASME Section XI, hydrostatic testing since all piping,
valves and fittings were one-inch or smaller. As a matter of prudence,
the cognizant engineer indicated that the affected valves and piping
would be inspected for leaks. Inspection will be either at hydrostatic
or operating conditions.
No deficiencies were identified.
b.
Installation of Flanges
ECN 6499 and WP 11834 install flanges in the component cooling water
inlet, outlet and relief valve lines to' the vent . condenser heat
exchanger associated with the Boric Acid Evaporator, Package
"B".
Functional testing consisted of a hydrostatic test per SI-265,
" Hydrostatic Testing Following Repairs and Modifications".
The
purpose of the Hydro was to test the newly installed flanges and
Test pressure was 165 psig.
In addition to a visible
examination of the welds, a liquid penetrant examination was performed
by the licensee.
No deficiencies were identified.
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c.
Pressurizer Level Transmitter Relocation
ECN 6439 and WP 11893 relocates level transmitters from inside the
crane wall to outside the crane wall in the incore instrument room.
The location was changed to the outside crane wall so maintenance can
be performed in mode 1, 2 and 3.
This will also. reduce radiation
exposure when working on the transmitters in modes 4-6.
Functional
testing consisted of calibration of. level transmitters and Non
Destructive Examination (NDE) of the welds.
No problems were
identified with this modification.
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d.
Steam Generator J-Nozzles Replacement
NCR 2215 and WP 12074 removes and replace original carbon steel
J-nozzles with new Inconel J-Nozzles. The subject work activities were
performed under the cognizance of the onsite Combustion Engineering -
(CE) Task Manager. QC visually examined "J" Nozzle Welds repairs per
OP-9.1, Rev. 5.
A final inspection of cleanliness was performed by QC.
No post modification testing nor functional testing were required for
this modification. No deficiencies were identified.
e.
Limit Switch Replacements
ECN 6556 and WP 11928 replaced existing limit switches on various air
operated valves in systems 30, 63, 77, 81, and 68 with environmentally
qualified NAMCO brand limit switches to meet 10 CFR Part 50.49
requirements.
Specified functional tests consisted of cycling the
valves to ensure proper limit switch adjustment / valve position
indication and stroke timing per SI-166.6. No problems were identified
with this modification.
f.
Limitorque Valve Modifications
ECN L6544 and WPs 11866 (Unit 1) and 11853 (Unit 2) replaced all wiring
within the limit switch compartment of approximately 214 limitorque
valve
operators with
environmentally qualified wiring.
This
Modification involved valves contained in systems 1, 3, 26, 62, 63, 67,
68, 70 and 74. Appropriate drawings were changed as part of this wire
replacement effort, such that previously jumpered out limit / torque
switches were eliminated 'from control circuits altogether in order to
simplify the circuits and their rewiring. Additionally, in the case of
16 valves, wiring changes were made to eliminate a limit switch that
was effectively making an existing torque swite:h in their respective
control circuit non-functional.
The functional tests specified in the work plans consisted of a hand
cycling of the valve actuators with a check on limit switches, closing
and opening contractors.
The valves were ther cycled open and closed
electrically. Excluding the 16 valves that were modified to include an
existing torque switch as a functional part of their control circuit,
the majority of these limitorque valves are containment isolation
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valves and are therefore subject to the surveillance requirements of TS 3.6.3.
Accordingly, TS Surveillance 4.6.3.1 requires that containment
isolation valves be cycled and timed to demonstrate them operable prior
to returning them to service after maintenance, repair or replacement
work is performed on the valve or its associated actuator, control or
power circuit.
The stroke timing test associated with these
containment isolation valves i s SI-166.6.
As for the 16 excluded
valves, section 6.8 of Technical Instruction (TI) -69, " Summary of
Pre-and Post-Maintenance Valve Tests For ASME Section XI and 10 CFR 50
Appendix
J,"
requires that a stroke timing test be performed per
SI-166.6 whenever maintenance of this nature is performed on a valve
control system. Consequently, the stroke timing test of each valve per
SI-166.6 would be required to be performed in order to prove valve
operability; however, SI-166.6 was not specified in either work plan as
a test to be performed.
Section 4.1.1.13.d (2) of Administrative
Instruction (AI)-19, Part IV, requires that any checks or tests
necessary -to return equipment back to service be specified in the WP.
The omission of SI-166.6 from the WPs is considered a violation of
AI-19, Part-IV (327, 328/86-43-01).
It should be noted that ongoing
MOVATS Testing of these valves, although not specified in the subject
work plans, will include a stroke test per SI-166.6.
g.
Residual Heat Removal (RHR) Loop Isolation Valves
ECN 6540 and WP 11906 replaced the existing motors on valves 2-FCV-74-1
and 2-FCV-74-2 with environmentally qualified motors.
These valves are the RHR suction isolation valves off of reactor
coolant loop 4 and are considered necessary to mitigate an RHR line
break.
Specified functional tests included megger, grease, and
rotational checks of the motors, and the performance of a stroke timing
test of the valves per SI-166.6. TS Surveilla"ce 4.4.6.2.2.c requires
that these valves be demonstrated operable by verifying leakage to be
within its limits prior to returning the valve (s) to service following
maintenance, repair or replacement work on the valve (s). Additionally,
TI-69 requires a Post-Maintenance Leak Test be performed on a motor
operated valve when motors are not replaced with identical motors. A
Leak Rate Test would be indicated in this case since the existing
motors were rated at 2.6 HP, whereas the replacement motors were rated
at 4~0 HP.
The Leak Test associated with these valves is SI-166.18,
.
"RHR Return Valve Leak Rate Test". The omission of SI-166.18 from the
WP as a specified test to be performed prior to returning the valves to
service is not in accordance with AI-19, Part IV. This is considered
another example of Violation 327,328/86-43-01 identified in paragraph f
above.
It is recognized that due to the duration of this outage,
SI-166.18 would have also been required to be performed by TS 4.4.6.2.2.c prior to entering mode 2.
This would be verified in
General Operating Instruction (GOI)-1, " Unit Heat Up From Cold
Shutdown to Hot Standby."
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h.
Replace Solenoid Valves With New EQ Valves
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ECN 6552 and WP 11897 replaced existing solenoid control valves with
new EQ valves required to meet the requirements of NUREG 0552. The WP
reviewed replaced 12 valves; three in system 43, six in system 62, one
in system 63, and two in system 87. The new valves were Automatic
Switch Co (ASCO) model #206-381 and model'#8316-54E.
Per the vendor
installation and maintenance instruction manual, the model #206-381
valves were required to be mounted with the solenoid vertical and
upright.
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The inspectors review of the above WP verified that inspection records
,
were included.
These records indicated that the solenoid on valves
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2-FSV-43-(202, 207 and 208), model #206-381, were oriented vertical .
However, when the inspector reviewed the installation and inspection
step of the WP, Step 8.2a of Vertical was defined as, " Vertical i 45 .
The inspector requested TVA provide justification for the 45
allowance.
The modification engineer eventually produced a letter
dated April 29, 1985, where an ASCO sales manager indicated that the
model 206 series valves could function with a solenoid orientation up
to 45
from vertical .
However, the letter went on to state that
seismic qualification for the 206 series was performed in the vertical
position only and the effects of mounting in the other orientation
would have to be evaluated. The inspector requested the seismic test
data for other vertical orientation and received (from TVA) Seismic
Simulation Test Report #17746-1.
This report documented the Wyle
Laboratories test performed June 9 and 10, 1986, for TVA under Purchase
Order TV-56071A. The test concluded that for the seismic event the
valves continued to function and maintain their structural integrity.
The inspector was satisfied with the information provided by TVA.
However, since TVA had installed the valves in April 1986, several
months before qualification testing, the modifications supervisor was
cautioned about the use of equipment in a manner not recommended or
qualified by the manufacturer without prior testing or qualification by
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TVA.
Additionally, if the installation was conditioned to seismic
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qualification af ter installation it sFould have been specified in the
WP. The functional testing review for this WP indicated that testing
was performed, however, cross referencing of the testing performed back
to the WP was not always documented.
Specifically, WP 11897 was not
referenced on a SI-166.6 test package or master list reference for
eight of the twelve valves. The inspector did, however, locate a valve
functional tet t performed on the same date indicated in the WP but no
reference back to the WP could be produced by the licensee.
SI-166.6
specifically required a test data package or master list notation to
tie the specific test to the work plan.
This failure to follow the
requirements of SI-166.6 is considered another example of Violation
327, 328/86-43-01 identified in paragraph f. above.
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1.
Replacement of Cable PP711B in Cable. Tray AS-B1, Emergency Supply
Breaker Feeder From 6.9KV Shutdown Board 2B-B
ECN 6627 and WP 12040 replaced a section of cable identified as PP711B.
This work plan specified functional testing per SI-7 which was
accompitshed on June 17, 1986. No problems were identified with this
modification.
J.
PMT-74 Automatic Shunt Trip Modification Test (Unit 2)
ECN 6233 and WP 11890 specified the testing associated with the
Automatic Shunt Trip Modification on Unit
2.
This procedure had
several changes written prior to the completion of testing.
Change
- 86-488 modified the expected voltage values at a specific test point.
This' change was processed using a change form (Appendix G of AI-4) and
handled as an expeditious change.
To understand the temporary change
process as'used by TVA, the following is provided:
TS 6.8.3 allows temporary changes to plant committee approved
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procedures under certain restrictions.
ANSI 18.7-1976, to which TVA is committed, also makes allowance
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(paragraph 5.2.2) for the licensee to make temporary changes to a
procedure providing certain conditions are met.
This ANSI also
requires this procedure change program to be described in writing
by the licensee.
Document Control", is the plant
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AI-4, " Plant Instructions
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procedure TVA used to describe this Procedure Change Program.
Section 13 of this procedure discusses the actual change process.
The method of changing a Plant Operation Review Committee (PORC)
approved procedure in an expeditious manner is described in
paragraph 13.1.
AI-4 only allows expeditious changes under the
following two conditions:
(1) To make changes which will remain in effect for only a limited
number of instruction performances (e.g., an SI needs to be
performed differently this one time because the plant is in an
abnormal configuration).
(2) To make urgently needed revisions when there is not time to go
through the original type of review / approval cycle (e.g., an NRC
inspection identifies a serious deficiency in an instruction'which
must be corrected immediately).
In this case, the plant
instruction change form (Appendix G of AI-4) authorizes an
expeditious change practice until a permanent instruction change
can be issued.
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As part of the Post Modification and Post Maintenance Testing
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program, plant engineers routinely specify in the WP or on the
maintenance form to " accomplish the applicable portions" of
approved procedure.
This method appears to circumvent the
procedure change process as described in TS 6.8.3 and AI-4.
Additionally, if the user omits certain steps or picks and chooses
steps of the approved procedure he has in fact changed the intent
of the original procedure. In this case, TS 6.8.3 requires that a
change with the same level of review and approval be executed
prior to use.
The specific example of changing a committee approved procedure (ie.,
changes to WP 11890) in an-expeditious manner as well as the improper
changing of committee approved procedures
(i.e.,
" accomplish the
applicable portions") is considered a violation of TS 6.8.3
(327,
328/86-43-02).