Text

Forwards Repts Addressing Plant Employee Concerns Re Const. Listing of Rept Numbers & Related Employee Concerns Encl
	ML20211D473
Person / Time
Site:	Sequoyah
Issue date:	10/15/1986
From:	Mcdonald J; TENNESSEE VALLEY AUTHORITY
To:	Harold Denton; Office of Nuclear Reactor Regulation
References
	NUDOCS 8610220202
	Download: ML20211D473 (160)
	v • d • e

{{#Wiki_filter:y 4 TENNESSEE VALLEY AUTHORITY Watts Dar Nuclear Plant F. O. Box 800 Spring City. Tennessee 37381 October 15, 1986 Mr. Harold Denton Director of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue Bethesda. Maryland 20814

Dear Mr. Denton:

In the Matter of the Application of ) Docket Nos. 50-327 Tennessee Valley Authority ) 50-328

SUBJECT:

EMPLOYEE CONCERNS TASK GROUP (ECTG) to this letter transmits for NRC's review five initial reports addressing Sequoyah Nuclear Plant employee concerns in the construction category. (These reports have been reviewed and approved by the Senior Review Panel). transmits the final report for 13 elements addressing Sequoyah Nuclear Plant employee concerns in the construction category. As indicated by the report cover sheets, these reports have completed final review by the Senior Review Panel and the Employee Concern Task Group management. These particular reports did not require any corrective actions by the line organization as a result of the employee concerns. This is indicated in Section VI of the report. With these final reports, all employee concerns related to Sequoyah have been addressed for construction subcategories 10100 Soils and 10500, Damage. To assist you in your review of these reports, Enclosure 3 provides a comparison between the ECTG Writer's Guide recommended report format and the transmitted reports. Enclosure 4 provides a listing of the report numbers, the related employee concerns, and the previous submittal dates if applicable. Please telephone Martha Martin at 365-3587 (Watts Bar) if you have any questions. Very truly yours, TENNESSEE VALLEY AUTHORITY Yh ~ 8' J. A. Mcdonald 7 Watts Bar Nuclear Plant 8610220202 861015 3 Site Licensing Manager hDR ADOCK 0500 7 o g-l Enclosures An Equal Opportunity Employer

l o a 2 Nr. Denton cc (Enclosures): Mr. James M. Taylor, Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Nr. B. J. Youngblood, Project Director PWR Project Directorate #4 Division of PWR Licensing - A U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue Room 440, 5 Story Phillips Bethesda, Maryland 20814 U.S. Nuclear Regulatory Commission Region II Attn: Mr. Gary Zech 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 l 1 i ,w,

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~ Y TVA EMPLOYEE CONCERNS REPORT NUMBER: C019201-SQN SPECIAL PROGRAM REPORT TYPE: Sequoyah Nuclear Plant Element REVISION NUMBER: 2 TITLE: Conduit PAGE 1 0F 10 REASON FOR REVISION: REVISION 2 - Revised to include Technical Assistance Staff and Senior Review Panel comments. (Major revision) PREPARATION PREPARED BY: N$ W1 9 (zsles SIGNATURE ' DATE REVIEWS PEER: ' Jyt Y f k f-Z-5-8G SIGNATURk DATE TAS: SIGNATURE DATE CONCURRENCES. CEG-H 0$~Al'Ab sr SIGNATURE DATE SIGNATURE DATE APPROVED BY: ECSP MANAGER DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY) 1317T k

-+. TVA EMPLOYEE CONCERNS REPORT NUMBER: C019201-SQN SPECIAL Ph0 GRAM REVISION NUMBER: 2 PAGE 2 0F 10 I. Introduction Eight concerns (categorized below) were evaluated at Sequoyah Nuclear l Plant (SQN) as a result of the generic applicability determination lR2 resulting from the Watts Bar Nuclear Plant (WBN) Employee Concern l Task Group (ECTG) Element Report Conduit, C019201, within the l Construction Category. l 'IN-85-512-003 Quality of Conduit Materials 'IN-85-512-002 l IN-85-341-001 Torquing of Flexible Conduit Couplings <0W-85-007-008 /IN-85-138-001 Condulet Cover Installation 'IN-85-201-003 Excessive Conduit Bends "IN-85-856-004 <EX-85-066-002 No related sita specific concerns were identified. Additionally. l due to the Browns Ferry Nuclear Plant (BFN) evaluation, flexible lR2 conduit installation deficiencies resulting from the generic l Implication of Significant Condition Report (SCR BFNEEB 8632) are l addressed. l II. Summary of Perceived Problems a) Quality of conduit material may not be assured at the time of receipt and maintained through proper storage techniques, b) Site procedures for the installation of flexible conduit may not require proper tightening of the couplings; therefore, attributing to loose and damaged flexible conduit. Additionally site procedures may not have adequately addressed flexible conduit installations related to seismic movement consideration, c) Control methods may not be in place to prevent dirt and debris from entering conduit bodies while condulet and pull box covers, etc., are removed, d) Allowable cable side wall pressures may have been exceeded resulting from excessive conduit bends.

.I 2 _c M TVA EMPLOYEE CONCERNS REPORT NUMBER: C019201-SQN SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 3 0F 10 III. Methodology a) Reviewed Quality Technology Company (QTC expurgated files, as I well as other flies for additional pertinent information. l reports and any corrective action recommendations available lR2 on concerns. l b) Reviewed the WBN 2 CTG Element Report Conduit (C019201), applicable sections, to determine the applicability to SQN. c) Sequoyah Standard Practice SQA.45 was reviewed to determine the procedures implemented for receipt inspection and storage requirements of permanent plant material. d) Reviewed Administrative Instruction AI-11 (Receipt Inspection, [ Nonconforming Items QA Level / Description Changes and l Substitutions).. Revision 37, to determine the inspection IR2 requirements specifically for non-critical systems, structures l and components (non-CSSC) itema. l e) Reviewed Administrative Instruction AI-36, (Storage. Handling, l and Shipping of QA Material), Revision 9-to determine the l storage requirements related to conduit material and ensure l compliance with American National Standard Institute lR2 (ANSI) 45.2.2-1978. l f) Discussions were held with cognizant Power Stores Unit (PSU) I supervision personnel to identify any related quality problems lR2 associated with condulet materials. l g) Walkdowns were conducted with (PSU) warehouse personnel to I observe actual storage facilities. lR2 h) Cognizant Office of Nuclear Power Quality Assurance (ONP-QA) { personnel were interviewed to determine receipt lR2 inspection and surveillance requirements for conduit mate, rials. l i) M&AI-6, (Installation of Conduit and Junction Boxes), Revision 6 was reviewed to determine the tightening requirements for flexible conduit couplings. j) Discussion was held with c<gnizant Modifications and Additions [ Unit Engineering personnel related to tightening of flexible lR2 conduit couplings. l l )

e -= %. TVA EMPLOYEE CONCERNS REPORT NUMBER: C019201-SQN SPECIAL PROGRAM REVISION NUMBER: ? PAGE 4 0F 10 III. Methodology (continued) k) Discussion was held with ccanizant Divlsion'of Engineering (DNE) l Central staff personnel to discuss the generic application of I SCR BFNEEB8632 and the adequacy of the policy memorandum from lR2 W. S. Raughley to those listed, dated May 14, 1986. I

1) Discussion was held with cognizant DNE-Electrical Engineering (EE) i personnel to discuss the movement requirement for flexible conduit IR2 installations for floor mounted equipment.

l l m) Discussion was held with cognizant DNE (site) Electrical l Engineering (EE) personnel to discuss the minimum length procedure requirements of flexible conduit connections for lR2 floor mounted equipment. l n) Reviewed Modification and Addition Instruction (M&AI-6), Revision l 6 to determine the procedure. requirements related to condulet IR2 cover installations. l o) Discussions were held with cognizant Modifications and Additions l Unit Engineering and Craft personnel pertaining to condulet cover l l Installation and procedure clarifications related to excessive IR2 conduit bends. 1 i p) Discussions were held with cognizant DNE Electrical Engineering l l (site) group leader personnel to determine what actions SQN had lR2 i taken to identify and resolve problems associated with excessive l . conduit bends. ) ] IV. Summary of Findings a) Review of the Quality Technology Company (QTC) Expurgated files l and other flies revealed no additional pertinent information than IR2 is discussed in findings below. l b) Review of the WBN ECTG Element Report Conduit (C019201) revealed sections of the report related to material problems, loose j j flexible couplings, fish tape and debris, and excessive conduit bends were pertinent to the SQN evaluation. c) Review of Sequoyah Standard Practice SQA-45, Revision 21 stated "The power stores and QA staff supervisor are responsible i for the receipt and receipt inspection as defined in AI-ll." i Reference paragraph 17.D Page-59. Additionally, paragraph, 19.D l page 59 states " Handling, Storage, and Shipping shall be in accordance with the requirements of AI-36." i L

2 TVA EMPLOYEE CONCERNS REPORT NUMBER: C019201-SQN SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 5 0F 10 IV. Summary of Findings (continued) d) ReviewofAdministrativeInstructionsAb-11, Revision 37 ~ l revealed "PSU clerks shall receive non-QA, and/or non-CSSC l items", however, no guidelines are established to describe what lR2 constitutes acceptable material nor what actions are to be l performed if defective materials etc., are delivered i.e.; [ over, short, substitute, damaged, or defective (OSSD or D) l items. l e) Review of Administrative Instructions AI-36. Revision 9, indicated the storage levels as specified are in compliance with the appropriate ANSI Standard (ANSI 45.2.2-1978) and conduit bodies are stored as Tubular products which require level D storage, f) Discussions with cognizant PSU supervision personnel indicated I no quality problems had been discovered or identified with lR2 conduit or conduit fittings. l g) Walkdowns with PSU personnel of Level D storage areas for conduit bodies revealed scattered surface oxidation (rust) on some conduit bodies with more severe rusting at the threaded area. Approximately 1 to 2 percent of the conduit bodies were judged not acceptable for installations - assuming the entire length would be installed. The storcge area and placement of material were in compliance with the requirements of Level D storage as specified by ANSI 45.2.2-1978. h) Discussion with cognizant ONP-QA personnel indicated receipt l Inspection was performed per the requirements of AI-11 and I surveillance activities were in accordance with the frequencies I specified in Surveillance Instruction Letter (SIL-181). Level D lR2 storage areas were subject to surveillance activities performed I by ONP-QA. Additionally, no known quality problems with conduit l or fittings had been identified. l

1) Review of M&AI-6, Revision 6, revealed installation of conduit and conduit systems were performed per the National Electric Code and flexible metal conduits were installed per the specific instructions included in paragraph 3.2.6, which adequately addresses the tightening requirements of the flexible conduit coupling. Verification is performed by ONP-QA personnel.

(Reference paragraph 4.0 item E) No deficiency was noted. j) Discussions with cognizant Modifications and Additions l Electrical Unit supervision personnel revesled problems had not lR2 been encountered where flexible conduit couplings were installed I and not appropriately tightened and verified by ONP-QA personnel. l

c TVA EMPLOYEE CONCERNS REPORT NUMBER: C019201-SQN SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 6 OF 10 IV. Summary of Findings (continued) e k) Discussions with cognizant Central Staff personnel revealed l BFNEEB8632 to be potentially generically applicable to SQN as l 'related to the lack of guidelines for flex conduit installations l contained within General Construction Specification G-3. The IR2 policy memorandum from W. S. Raughley to those listed, dated May l 14, 1986, was determined to be fully adequate to address the l flexible conduit issues related to The Code of Federal Regulation l Section (10CFR50.49) pipe mounted devices, and all 10CFR50.49 l equipment, such as motors and chillers, at a point six-feet or. -[ greater above the floor level. However, floor mounted ICCFR50.49 l equipment at a point less than 6 feet above the floor level I was not addressed and is considered inadequate in this respect l since a minimum length of 18 inches is required for flexible IR2 conduit to provide a one inch movement. No objective evidence l was found which ensures this 18 inch cel'teria was met during i flexible conduit' installations. l .1 ) Discussions with cognizant DNE-Electrical Engineering (EE) l personnel revealed 10CFR50.49 floor mounted equipment below l a point six-feet above the floor level would be acceptable, IR2 provided the flexible conduit minimum length is 18 inches, to I accomodate one inch movement during a seismic event. l -m) Discussions with cognizant DNE-Electrical Engineering (EE) l (site) personnel revealed that prior to the issue of G.C.S-G40, l Revision 0, dated August 6, 1975, no minimum length criteria had l been established for flex conduit installations. It was noted; lR2 however, that N2E-860, Revision 0, issued November 6, 1973 required l a one inch movement with no minimum length given. Prior to this I date, G.C.S. G-3 was utilized and consequently could have resulted l in flexible conduit installations which do not conform to the I requirements of G.C.S. G-40 nor the 18 inch minimum length l criteria for floor mounted 10CFR50.49 equipment. l n) M&AI-6, Revision 6, does not address the installation of dondulet or pull box covers to prevent dirt and debris from entering the conduit between cable pull activities, nor for the initial installations of conduit bodies, o) Discussions with cognizant Modifications and Additions Unit engineering and craft supervision indicated recognition of the need for procedural clarification 1n regard to covering all ~ openings in the conduit run by either permanent and/or temporary Additionally, it was recognized that paragraph 3.1.1 of means. M&AI-6 should contain a precaution to the installer not to exceed 360 degree accumulation of bends between pull points in the conduit body, and verification should be performed by ONP-QA personnel at the time of acceptance.

TVA EMPLOYEE CONCERNS REPORT NUMBER: C019201-SQN SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 7 0F 10 IV. Summary of Findings (continued) p p) Discussion with cognizant DNE Electrical Engineering Unit Conduit l and Grounding Group Leader personnel revealed the actions to be l performed by SQN related to excessive conduit bends had not lR2 been determined by DNE (Knoxville). The actions required will l be determined fecm DNE's evaluation of side wall pressure l testing conducted at the Central Laboratory. Their testing l appears to address the issue of excessive conduit bends, as l well as, over crowding and maximum pull tension, as related to l maximum side wall pressure calcylations. l

== Conclusions:== a) In order to adequately assure the quality of non-QA and non-CSSC l items, such as conduits. AI-11 should include or describe what l constitutes acceptable materials or explain OSSD or D items, and l PSU clerks should utilize these guidelines when performing l receiving inspections. These guidelines should include l examinations for burrs, sharp edges, flattened threads or lR2 Irregularities which would be detrimental to the installation l of conduit or cables during pulling activities. Storage and l surveillance activities are adequate to ensure compliance with l ANSI 45.2.2. Due to the deficiency noted above, the generic l applicability determination of the perceived problem for i employee concerns IN-85-512-002 and 003 was valid. l b) M&AI-6, Revision 6, is fully adequate with regard to the 1 installation of flexible conduits in that the proper tightening l requirements are specified and verification is performed by ONP-QA l personnel. However, due to deficiencies in G.C.S. G-3 and the lR2 inadequate minimum length criteria specified in N2E-860 for l flexible conduit installation, the movements of all devices are in l question. Steps should be taken to corcect the generic l applicability determination of Significant Condition Report (SCR), l number BFN EEB 8632 and to implement the requirements of the l policy memorandum to Those Listed from W. S. Raughley, l dated May 14, 1986. The policy memorandum should be revised l to address the criteria to be utilized for qualification of floor i mounted 10CFR50.49 equipment. Since torquing requirements l of flexible conduit couplings were adequate, the issue raised l by employee concerns IN-85-341-001 and OW-85-007-008 was not l valid. However, this evaluation revealed a quality related issue l pertaining to configuration control of flexible conduits as noted I above. l

-. -.- g. TVA EMPLOYEE CONCERNS REPORT NUMBER: C019201-SQN 'SPECIAL PROGRAN REVISION NUMBER: 2 PAGE 8 0F 10 Conclusions (continued) c) M&AI-6,-Revision 6 does not include provisio'ns to cover all openings in the conduit runs, by either permanent or temporary-means, to prevent dirt and debris from antering the conduit body' and is considered inadequate in this area. Additionally, no precautions to the installer of the conduit run exist which prevents exceeding 360 degree accumulations of bends between pull points ~ within the conduit body. No quality assurance inspection exists which ensures excessive bend criteria is not violated. Employee Concerns IN-85-138-001, IN-85-201-003, IN-85-856-004-l and EX-85-066-002 are valid due to the implementing procedure lR2 deficiencies noted above. l d) A review of DNE's. evaluation of the maximum side wall pressure testing presently underway for WBN, is c'equired at SQN and no further evaluation.can be performed at this time. V. Root Cause a) AI-11 was inadequate, in that non-safety-relatsd (non-QA, non-CSSC) l items were being received by non-technical personnel without I guidelines established to require the technical examinations which l would detect burrs, sharp edges, flattened threads or irregularities I detrimental ~to the installation of cables during pulling activities. l The apparent cause of this deficiency is management oversight lR2 resulting from the lack of awareness that the receipt of I "non-safety-related" items such as conduits and fittings may I have a direct impact on plant operation or safety-related features I such as cables. This detrimental effect is compounded due to the I lack of separation control after receipt or issue to prohibit non-l safety-related items from being used in safety-related installations. I b) Due to an oversight by the DNE preparer / reviewer or the lack of I consideration to the required Safe Shutdown Earthquake and l interface movement criteria, General Construction Specification. l G-3 did not provide'guidanco for installing flexible conduit l offsets, lengths and thermal / seismic movement allowances. In I addition, the attempt to correct the movement criteria for floor l mounted equipment as contained in Sequoyah Specific Construction IR2 Specification N2E-860 was inadequate in that the movement criteria i i i for this floor mounted equipment was established by DNE, however, l 1 insufficient qualifying instructions were supplied to DNC for l utilization during the installation process. In conclusion, the l i design criteria was not established nor conveyed to the responsible i construction organization in a manner which would ensure the proper l Installation of flexible conduit assemblies. l 1 ~.

TVA EMPLOYEE CONCERNS REPORT NUMBER: C019201-SQN SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 9 0F 10 V. Root Cause (continued) b) (continued) The need for establishment of this specific criteria may not I have been recognized by DNE personnel. It should also be noted l that the established program for generic applicability lR2 determination is deficient or weak in that significant conditions l such as those identified on SCR BFN EEB 8632 (related to this I issue) remained unidentified at other plants largely due to I this generic applicability dete,rmination being performed by the l initiating organization with limited knowledge related to the l generic implications. l c) DNE management personnel had not recognized the importance l of establishing a procedural control program to prevent dirt lR2 and debris from, entering the conduit or to ensure good. l workmanship practices were utilized during conduit installation. l This lack of consideration may have resulted from the generally I accepted practice of considering conduit not important to plant l operation. l d) Due to the lack of consideration of/or an oversight by the l preparer and reviewer, General Construction Specification G-40 l issued by DNE did not restrict conduit bends in excess of 360 1 degrees between cable pull points as required by the National lR2 Electric Code. This action resulted in inadequate installation l criteria supplied to DNC and subsequent violations of the l National Electric Code during conduit system installation. l VI. Corrective Action 8 (To be prov Aed by the line organization.) VII. Generic Applicability Violations in cable side wall pressure because of excessive conduit bends are potentially generic to BLN and BFN. Additionally, the lack of inspection requirements related to condulet cover installations, flexible conduit couplings, and quality of conduit materials are potentially generic to BLN and BFN. Icaues pertaining to Flexible Cohdult Configuration as described in SCR lR2 BFN EEB 8632 may be generically applicable to WBN. l

TVA EMPLOYEE CONCERNS REPORT NUMBER: C019201-SQN SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 10 0F 10 VIII. Attachments A. SCR BFNEEB 8632 l 1 l B. Policy memorandum from W. S. Raughley to those listed, dated lR2 May 14, 1986 l l 1 C. Listing of concerns indicating Safety Relationships and Generic l Applicability l'

y-m_ 20/Lw-ssv-7c z &rrn u m a r-c ~ EX 066-002 CD 19200 N HBN YYYY flS THERE'ARE NOT ENOUGH CONDUILETTS IN REPORT CONDUIT RUlls. AUXILIARY AND REACTOR T50183 BUILDINGS. CONSTRUCTION DEPT. CON CERN. CI HAS NO ADDITIONAL INFORMAT ION. IN 138-001 CO 19200 N HBH YYYY NS DURING CABLE PULLS, FISH TAPE, HUD, T50039 REPORT DIRT CHATER) IS LEFT IN THE CONDUIT. PULLING HOOKS GET JAMMED AND ARE L EFT IN CONDUIT. QC & CRAFT SUPERVIS OR ARE INVOLVED. IN 201-003 CD 19200 N HBN YYYY NS TOO MAHf BENDS IN la CONDUIT RUN IN T50157 REPORT UllIT 1 REVERSE OSMOSIS ROOM ELEV. 75 7' AT 4-V. THERE HERE NO FITTINGS U SED TO RUN THIS CONDUIT MAKING IT EX TREMELY DIFFICULT AND TIME CONSUMING TO' PULL CABLE THROUGH THIS CONDUIT. CI STATED THAT FITTINGS IN LIEU OF BENDS SHOULD HAVE BEEN USED TO FACI [ LITATE CABLE PULLS. CONSTR. DEPT. C ONCERN. NO FOLLON UP REQUIRED. Ill 341-001 CD 19200 N HB'N YYYY NS FLEXIBLE STAINLESS STEEL CONDUIT FR0 T50189 REPORT M VARIOUS EQUIPMENT AND PENETRATIONS INSIDE THE CONTAINMENT IS NOT TORQU ED Ell 0 UGH AT THE FLEX AND FITTING AT TACHMENT POIllTS. QC ACCEPTED THE HD RK. STAIllLESS STEEL FLEXIBLE CONDUI T CAN BE PULLED APART AFTER BEIllG AC CEPTED BY QC. ALL PENETRATIONS AND ELECTRICAL EQUIPMENT INSIDE CONTAINM EllT. UllIT 1 & 2 ARE AFFECTED. CONS TRUCTI0tl CONCERN. CI HAS t10 ADDITIO NAL INFORMATION. IN 512-002 'CO 19200NHBli YYYY NS UNIT 2 CONDUIT FITTINGS RECENTLY ISS T50046 REPORT UED TO THE FIELD (TRADE NAME "ERICKS ONS'") ARE OF IllFERIOR MATERIAL (SIM ILAR TO PENTER). INFERIORITY IS PAR TICULARY EVIDENT IN THE INTERNAL THR EADED AREA, HHERE THREADS ARE ROUGH AND FLATTENED. PER DIRECTION OF FOR EMAN (NAME KN0llN) CRAFT (DISCIPLINE KNOHN) ARE REQUIRED TO UNDERCUT EXTE RNAL THREADS ON CONDUIT TO ALLOH USE EXPRESSED ON 3/4", 1" AND 1 1/2" SIZES. NO FURTHER SPECIFICS ARE AVA ILABLE. IN 512-003 CO 19200 N HBN YYYY NS CONDUIT RECENTLY ISSUED TO FIELD FOR T50046_ REPORT USE OH UNIT 2 EXHIBIT A HUMBER OF P IECES HITH RIDGES AND BURilS IN THE I j NSIDE DIAMETER. THE POTENTIAL EXIST S FOR HIRES TO BE DAMAGED, IF CRAFT PERSONilEL HAD NOT NOTED THESE DISCRE PANCIES. NO SPECIFIC SIZES OR LOCAT IONS ARE AVAILABLE. IN 856-004 CO 19200 N HBN YYYY NS CONDUIT HAS AS MANY AS FIVE 90 BENDS T50094 REPORT IN SOME INSTAllCES AIID CABLE CANNOT BE PULLED. (NAMES KNOHN TO QTC AIID RELEASE OF THIS IllFORMATION HOULD JE OPARDIZE CI'S CONFIDENTIALITY)... NO MORE DETAILS AVAILABLE. HD FOLLOW U P REQUIRED. OH 007-008 'C0 151'00 S HBN YYYY NS HATTS BAR HAS HAD TOO MANY INSTANCES T50224 CD 19200 REPORT OF UNCRAFTSMAN-LIKE ELECTRICAL HORK IllCLUDING POORLY BENT AND INCOMPLE TELY SCREHED TOGETHER C0tIDUIT (AUXIL IARY BLDG), AND CABLES DAMAGED DUE T 0 SLAG FROM HELDING OPERATIONS OVERH EAD (TURBINE BLDG, ELEV. 729'). NO SPECIFIC LOCATIONS OR UNIT NUMBERS K N 0Hil. CONSTRUCTION DEPT. CONCERTI. CI HAS NO FURTHER INFORMATION. NO F OLLOH UP REQUIRED.

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CONCURRENCE: CEG-1 4W 7-WW DATE: _yhi/#4 9. APPROVAL: ECTG 6 RAM MGR. DATE: CORRECTIVE ACTION 10. PROPOSED CORRECTIt2 ACTION PLAN: t i O ATTACHMENTS 11. PROPOSED BY: DIRECTOR /HGR: DATE: 12. CONCURRENCE: CEG-II:, r,- DATE: SRP: .DATE: DATE: DATE: DATE: ECTG PROGRAM MGR: DATE: VERIFICATION AND CLOSE00T i

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

SIGNATURE TITLE DATE

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.g- t t i '. 12 f ECTG C.3 Attachment A Page 1 of 1 ( Revision 2 - A i ECSP Corrective Action Tracking Document I (CATD) W { ,I [ 'I } INITIATION Applicable ECSP Report NO: 1. Immediate Corrective Action Required: 0 Yes R ' No 2. Stop Work Recommended: O Yes M No 3. CATD No. cm oros _sma-v4 4. INITIATION DATE 5. RESPONSIBLE ORGANIZATION: M At w - s t rP_ muerrmt 6. PROBLEM DESCRIPTION: H QR O NQR[ re e vi se u A Ar-4 TD su n d nt-PR P # A M-finw < 46 r e-iu<vAtten o s: v u st mw n u sy a n u - ta u s t,4 r Pa w v i w v$ t iJ <-t-A t t A M1 md n 5: RE.M O T t ea EMM M ts 3 to n n EA n u s-A ce A4 na 14 LA-rind Ar-cw nEu P11 t 1 " PM t W ~1"_4

AWh ' To R E E nA i10 E A> A.

vs:st 59 %e ATgm1{ Ar T H tr n u vr nc i w _4 p E r_.Ts 2>t4 O ATTACHHENTS 7. PREPARED BY: NAHE &JML DATE: 912(1e4 8. CONCURRENCE: CEG-il M (/ Z/. f, ' N DATE: f/2i/J4 ECTGP%RAMMGR. '~ 9. APPROVAL: DATE: CORRECTIVE ACTION i 10. PROPOSED CORRECTIVE ACTION PLAN: O ATTACillfENTS 11. PROPOSED BY: DIRECTOR /MGR: DATE: 12. CONCURRENCE: CEG-il:l 8** DATE: 5 SRP: 'DATE: DATE: DATE: DATE: ECTG PROGRAM MGR: DATE: ' VERIFICATION AND CLOSE00T i 13. Approved corrective actions have been verified as satisfactorily implemented. I SIGNATURE TITLE DATE I

R .m- ' g. k U o. ECTG C.3 Attachment A Page 1 of 1 l Revision 2 - A j' ECSP Corrective Act'lon Tracking Document g. (CATD) g '1 I INITIATION Applicable ECSP Report NO: 1. Immediate Corrective. Action Required: O Yes H No 2. Stop Work Recommended: O Yes M No 3. CAID No. cmonon-sow-oc 4. INITIATION DATE e lz g jet, 5. RESPONSIBLE ORGANIZATION: So w - < n-e o i nue_ ron '6. PROBLEM DESCRIPTION: S QR O NQN e .< m w To es<pogn -r o n w s_*5 MVALMAriou 'aG fAnLE _T i n M 1AA A LL A R F__ <<14 e 9 v t hL A*T i n M 4 AEn ' f3G eronu THE wr o uin en e -vi e w e m onown rn A n n ants < -c u s. MT T LIT 1 AL UinLMT*tDLR MF P_ v f R_4 4 i V E f BW D u 1 T R Et hi n C R9 L ATFLM

v 5 P A %"T" 1M*f At L ATi M sJ f.

O ATTACHifENTS 7. PREPARED BY: NA!!E #A2fM, DATE: _91zar M A 8. CONCURRENCE: CEG-il A 9-

1 W DATE: V/x7/#4 9.

APPROVAL: ECTG P RAM HGR. DATE: CORRECTIVE ACTION 10. PROPOSED CORRECTIVE ACTION PLAN: I O ATTACll!!ENTS 11. "NOPOSED BY: DIRECTOR /l!GR: DATE: 12. C0tlCURRENCE: CEG-II: I DATE: 8 SRP: DATE: DATE: DAIE: DATE: ECTG PROGRAM HGR: DATE: VERIFICATION AND Ct.0SE00T i 13. Approved corrective actions have been verified.as satisfactorily implemented. SIGNATURE TITLE DATE 9 4

ATTACHMENT 4 Ah """" U Q.. A. Record ~{ "'s 7 0' l 0 N ' ~~1 SIGNIFICAt'T CONDITION REPORT e Acc o @ Projec[ Plant and Unit L.2,j 0.ie 1 l.]SCR. Number and Rev. BEN /Cc=^r ()w'.tx

1. 2. 3 oi> >/3/e (,

6/27/86 SCRBFNEEB8632 @ Preparer and Organization Lit 2.J NU CON NCR NoJDeficiency Report W ASME Code (For NU CON Use Only) NA O Yes S No m Valter J.~Dembosty, @ Contract Number Lfr]V*ador "a..B/A_ M c .c naq sirement violated h..EEI.ibl3._ conduit._teLuit arui_ thermal taarertant cnnderatinns Source of Haquirement g

i. Geagral_Constrnctinn_Sdec.lfication_G-40f31.3)

) E @ Description of Condition

e 8

The installation of flexible conduit wm not specifically addressed in General ji construction Specification.G. -L. The Isck. of' guidance for installing flexible d conduit offsets, lengths and thermal /scismic movement allowances creates 5 uncertainty as to whether installed flexible conduit can perform it's safety j function. ,7 e E B 8 - @UNID/ Component Code (For DNE Use Only) y f System M/A v a r t_ gi_t e 0 e>ti=>ted' O Actuai rinnoric Tmolications Review urrence 3 lintnnun 5 @ Significant Condition pe?%/3/6 [._9,_jorganization t'a Determine Corrective Action l 5 Adverse to Quality X s N BFEP/EEB [L_] D to L10c_] Contacted by @ if significant, NEBfdLS Contset 7 b W. J. Dembosky 4 T-C- chanman @ la a Porential Generic Co,ndition if yes, initiate Attachment 5 of NEP 9.1 and [_QJ Branch Chief / Pro [ect Engineer /DNOA Quality Site l Evaluation Required? O Yes list Attachment 5 RIMS Accetston No. Manager (Dist ute se required--eee block 3.) k, yg _k If no, describe in blocit 28. @ No ,, j A yp @ Hoot Cause ~- 5 6 8 's e 14e Corrective Action bd W ~ ~ c .9 114 .5II E 6 O {@ Coordination Heview of DNE Work (Provide initials) $ Schedufed Date of Completion o (M Action Required to Prennt RecurTence (ABPR) cd (cont on p. 2) J ulblL TV A 10700 (DN E 6 861

o b* SCR Number end Revisfori.-SCR5n!Er48632 ~," uhaj ARPR (continued) ~ ' ' " ' '

- N m.. q..

.. ;;g g.q g, @ Scheduled Completion Date of DNE Work g Does the 'correctJve action devlete from a design criterie requirement? - Yes . O no " o' g L1LJ Design Criteria Docurnent Number Llij Exception Request Number e ,sg 3 5 LdJ la en ECN required? L21]I npag.onhhegule?a y g g,m wa g..g f 5 $/ Yes l If'yes', ECN number "Affects project completion schedule U D l c tu No I Affects schedule of related act!'it'les ~ v 't o Z l

s o

C No Irnpact ..i .? <t: C e o @ Verification of Adequacy and Accuracy of Sianature and Date Lt. Blocks 13 20 Above ab.

'***I' g

w @ Approval Signature and Date (Distribute as required. RIMS Accession Number O See block 30.) .e-O c 0

G

@ is it a generic condition? g x Yes No if yes, describe. eJ U Lu O m D m Z o O @ Preparer and Date L2ij Supervisor and Det. O i Z c @ ARPR Roccmmended By and Date L26 J ARPR Approved By and D, ate o LL. @ Concurrence of Designated Quality Reviewer for ARPR and Data RIMS Accession Number (Distribute as appropriate-See block 30.) @ Remark s The generic review for this condition was handled as a result of SCR's for other projects. O See Continuation Sheet @ All DNE/NU CON Action Complete W Signature, Crganlaation, and Date (Attach Completion Venfication Sheet) "a vu .9 @(if needed, attach a separate sheet for edditional distribution.) U 2 RIMS. SL 26 C K [ NRC Resident inspector O 3 NU CON Site Dedicated Data Base Director of NU CON r Ei NMRG Records Storage Facility ti j,x h DNE Project Engineer [ ANI (For ASME Code Iterns Only) $5 NU CON Project Manager DNOA S'te Quality Manager lj ] Manager, Engineering Assurance [ Preparer Dirimtor of DNE RIMS Accession Number Q NED CMS (for ASME Code items) } [ Director of DNOA B l l l s

~ .E

W^

l' a.. _ [ * '. ' _ c ' ~ ~ Part 8 (Continued) e.

Page 2 of 4 ER Rev.

O CAO Report No.and Rev. 9FnRFNFFRAAu 1. Tabulate Data on. All Failed and/or* Affected Components. Structures, and Systems: Give descriptions, model and manufacturers' numbers, and original and revised design criteria and/or specifications. (See Note 5.) - ..s... ....c ~ .e. ( 2 Failure Mechanisms of Affected Components, Structures, and Systems: State whether each affected component,, structure, and system became open or closed, inoperative, or shorte,d; or had shortened life, reduced accuracy, increased drift, reduced capacity, etc. (See Note 6.) u i. a 3. Alternate Uses and Generic Implications: Identify alternate uses of the components, structures, and systems in the plant. Discuss generic implications. (See Note 7.) l ~ 4. Component, Structure, and/or System Failure Mode (s): Give description and extent of effects of failures on each component, structure, and/or system involved. (See Note 8.) o e ~ _,e, n, _.,,, - - _ -. - _, - - _ _..,,,,,,, _ _., ~ _ _., ,,,.w,,

go. v

p. a.

RIMS Accession Number }> 'o N' ENGINEERING REPORT (By DNE for CP Plant) ER Rev* 0 (sy Site Director's . L N Organization for OL Plant) Plant and Unit t L,3 Site Director's Contact and Date Notilled (OL Nuc Plants Onlyl CAO Report No. and Rev g BFN/C^"" QT//gl. Steve Willard 7/7/86 gg SCRBFNEEB8632~ 53 Definitive Statement of CAO (See Note 1.).

gtg The installation of flexible conduit was not specifically addressed in

-Ei General Construction Specification G-3. The lack of guidance for 93 installing flexible conduit. offsets, lengths and thermal / seismic jd movement allowances creates uncertainty as to' whether installed flexible conduit can, perform it's safety function. f* *3

See Note 2 on page 4 for completing Part B.Part 8 continued on pages 2 and 3' Due Date of Failure Evaluation Yes (OL Nuclear Plants Only)

Preparation of Failure 0"o eve' e'ioni r a iedi FSaa aevisiea aeauireer o vos No Conclusions (See Note 3.) ( c .g v. $3 =3 A 3m QZ

u. O l

Recommendations (See Note 4.) t' E p Suggested Corrective Action Date Failure Evaluation Received Date Management Notified Operational Limitations / Actions Justification For Continued Operation c O RN sTo 3 $B Conclusions at.!! a u t3 03

oa t*
Indeterminate itemi Yes No g

Yes No Po t en t isif y R e por t able t o N n c ?.................................................................... Deficiency Adwesely Affects Safe Operation of Plant?................................................Ovet "o DNE Contact Approved By and Date Prepared By and Date TVA 1082tl(DNE486) cc: HIMS. ISut nit to RIMS as standalone document.)

qggy,

u i R n n u r m r """ o EH Hev._ u t.au nepui s e,w....u e ne. S.' Cause e f th7 CAO:l. Discuss w6at the CAO w:s due ti, e.g., a program breakdown, new regu!'ation. analysis or design trror, test results sh wing a deficiency, and/Jr failure to meet design, criteria and/ar purchise specifications. Include calculations, analysis results, test results, and/or purchase requirements not met, or other bases. (See Note 9.) Discuss, ffects of failures on all involved component's, structure's. and 6. Consequences on Plant Design Functions: e system's ability to perform their plant design functions. (See Note 10.) 4 n.. f. i *- 7. Justification for Conclusions in Failure Evaluation: Discuss the reasoning based on the information above whichleads to the conclusions stated. (See Note 11.) Prepared By and Date Coordinated in Site Director's organization with: Verified By and Date Discipline Lead Engineer (s) and Date Approved By and Date h I

y Of y. m rAcmwee B SCA? i j '-[ 5 y [ D I ] y,. Those listed j ] W. S. Raughley, W8 C126 C-K ' [.4 i f I j m$,p May 14,"1986 s I8.' '

$ Eb ELECTRICAL ISSUES - FLEXIBLE CONDUIT: us i
d: d,.

'i.- The purpose of this ' memorandum is to provide guidance for each Le'a'd Engineer to determine the adequacy of flexible conduit lengths for thermal and seismic movement for installed Class 1E equipment and devices on the ICCFR50.49 lists. ~ 5 General Construction Specification / -40, presently defines the minimum G flexible conduit length for thermal movement based on conduit size (Section .3.2.6.3) and seismic movement (Section 3.2.6.2). incorporated into C-40 as outlined in Attachment 1.These requirements were In January 1986, it was discovered that some flexible conduit'at WBN was not installed in accordance with the requirements of C-40. Further study has revealed that thermal movements for pipe-mounted devices and seismic movement for certain floor-mounted equipment was not based on worst-case conditions. The Civil. Engineering Branch has issued a. calculation package, " Seismic / Thermal'.Hovecents,- Class :1E, Electrical Conduit" (B41 260428 001) l" fdefining the maximum',vorseicaselseismic/ thermal movements'for all plants V (Attachment No. 2). ' may be used to eva1uate mov2ments for each plant,The values in this c ~ or specific movements for each piece of equipment or device may be obtained. The seismic and thermal movements for pipe-mounted devices are shown in load tabulations and isometric drawings which can be obtained from DNE - Civil Engineering Branch and can be used to identify seismic / thermal pipe movements which exceed the 1-inch criteria for evaluating devices on a case by case basis. The original scope of this item was to only look at devices on mechanical systems which had not been thermally exercised to their limit; however, t since the plants have not experienced a seismic event, movements for all devices are in question. y 3 L Based on preliminary information from VBNP, the problem of short flexible ,' conduit lengths for pipe-mounted devices or floor-mounted equipment does not appear to be extensive. The following course of action shall be taken to resolve the flexible conduit issue:

1. experience movementAll 10CFR50.49, electrically-operated, pipe-mounted device be inspected per the flexible conduit requirements of SRN-C.

(Attachment 3). 2. A random sample of 10CFR50.49 electrically-operated, pipe-mounted devices that expeEience movident;of 1 inch or less shall be inspected

per HIL STD 105D based on a 96% confidence factor.

I

.e. v ,,_a. i .} ' ',e ~. 7 'y t. 1 4 ' t,... f, ,. ' ';. 2 [ ~~ t 5,'i ": ' sii.. '\\:? '

.y (90*^5h't.h' Those listed

'.[.j b[ Hay 14, 1986 f' ELECTRICAL ISSUES - FLEXIBLE CONDUIT b e

'n

=

3.. All flexible conduit connected to floor-mounted cast or forged

'. 3. 10CFR50.49 equipmen't, such as motors and chillers, at a point six feet 1 'T or greater above' floor level shall be inspected to assure that.the I' flexible conduits meet the requirements of SRN-G-40-11. p. ( If the inspections reveal unacceptable installations, the flexible conduits shall be documented and reworked, replaced, or referred to DNE for a l dispositi'on on a case-by-case basis. f The fragnet for resolving the flexible conduit issue.is Attachment No. 4. This effort should be started immediately to expedite completion of the I flexible conduit issue." \\ ) MDt W. S. Raughley b J. D. Collins, P-110 SB-K G. T. Hall, DNE, DSC-A, Sequoy'ah H. C. Rutherford. A7-BFN ENG \\ J. L. Springer, 9-111 SB-K DLL:BB .2t L 076120.09 f b D q o. a.

s;- 4.: :-... TABLE A ~. SEISMIC / THERMAL MOVEMENT FLOOR-MOUNTED EQUIPMENT AND DEVICES PIPE-MOUNTED DEVICES"v. -: PROJECT SHEET METAL CONST. CAST OR FORCED EQUIPMENT MOVEMENT IN ALU HORIZ MOVEMENT (IN.) CONNECTION HEIGHT 'HORIZ VERT DIRECIONS (INCHES)- e BFN 15 5 3 Feet 10.75" 10.15" 13.6 i 5 6 Feet _1.25".+0.31" + ,r < 9 Feet 12.0" 10.5"- ' 5: SQN 15 Same as BFN 14.0 ~ WBN 15 Same as BFN ~ 14.0 ) e BLN i.5 Same as BFN 13.7 m e O e =.

e ?: [WAcHMEMT 0 1. i ]'[,l. Page 1 of 2 s ..v- ' jV i SQN (CP 5-27-70), WBN (CP l-23-73), and BLN (CP 12-24-74) i Electrical Cable Issues i t ?. I Is s u'e : Flexible Conduit Connections to Class IE Equipment

DNE Document Time Frame (Section)

DNE Reauirement i 11/6/73 H2E-860 (SQN only) Use length of flex, conduit (Section 2.5) to allov 1-inch movement in f all directions connecting to Class 1E equipment. and 8/6/75 G-40 RO thru R2 Use minimum 18-inch length I to 10/21/80 (Section 3.2.6) of flex connecting to Class 1E equipment. 10/21/80 to G-40 R3 thru G-38 R9 Above plus addressed 1/15/86 (Sect. 3.2.6) fler.ible conduit connections to thermal (pipe) movements. ~ I s 066120.03 CUS: 4-30-86 4

eJa.. g T 1 Page l of 1 / 3.1/. ',. ' ' BFH (CP 5-10-67) Electrical Cable Issues I i, F'lexible Conduit Connections to Class IN Equipment Issue: DHE Document Tier Frame .'DNE (Section) Reauirement i '5/10/67 to f G-3 issued ,,.b' 1/15/86 12/17/62 and Provide flexible.' conduit connections later revisions f (Section B.10) to equipment (such as motors, valves. lighting fixtures). /~'" No specific require-ment for min. lengths of flexible conduit relative to seismic and thermal (pipe) movements. 1/15/86 to G-40 R9 Addresses type of 3/17/86 (sect. 2.3 flexible conduit and 3.2.6) and lengths (per size conduit) relative to seismic and thermal (pipe) ' ~ movements. f 066120.03 .5'- /.3. - f(, CilS : P30-8tr

r

,,.s', A fotg7 (CE 448) OE CALCULATIONS, 77MCNMh7 2 giSM C /D4ERtAAL Mo9EMEMTS - CLA551E ELECTBtCAL conDutT YLNAMTS PREPARING ORGANIZATION KEY NOUNS (Consutt RIMS DESCRIPTCRS LIST) - G. GEB -M A 2 FLE%IBLE cow DutT, 0.t. ASS T.E, 6-40 sa ANCH/ PROJECT loENTIFIERS Esc I calculationa are leswed, properors rnurt enwre that the original (ROI RIMS accom:en Rrw (for RIMS

use)

RIMS' accession number ees-M/n -006 5 B41 '860428 001 aa APPLICAsLE des!GN DOCUMENT ($1 R_ ~ ~ R $AR SECTION15) UNIO SYSTEMts) R_ Revision O R1 R2 R3 Statement of Problem ECN No. Ilndicate il Not Apoli, ablel c This Wculniion is needed 40 P,,,,,,,2/A4 8d/a ' documed ike yne%rnum '"*% fy,$[j se'ismic / 4hermal rno0cmenls of Glass IE eiedrical ettspued M*

"/"

where fhsW conduil is R aie*

M d /.._,. m allached 40 aipe mounted devices on fhermally moiing APR 2 s 1988 SySkcWS QOd 30 floor Wuded List all page sdded by this revision,

<.3 g {' 7 jh "Ik'i,l"flon"d situdur es. d 3gj Ust all p+ae: changed - by this r6 vision. Does this revision contain any unverified asstmptions? (YES or NO) NO ^batract Ebnd cakulations,. shake inble iesi results and pipin analysis resulb were used 4o provide conservdive mawmuw)g 4kermal / seiswnc movemeal.s for class IE etuipment w%. Redbie conduil allacked. Madrnum rnc9ements of pipe-mded devices on 4kerrnally vneving systems and floor vnouniccl etuipraent in colegory I.stradures are provided. This calculatica is used is.suppor4 revision 10 do 4be General Const rudion Spedficabu C,-40 o.nd corredi9e action for WCR 6529 anJ M cR (c569. Also used io dommerrt 4hc Setsynic. Simulation Ted Program on Motor Conhol Ceder " m he TVA MEDS document retrival systent. WcroN cmd reiurw oriainal to G.C. Gale 31 c.e7 c.-K. %fR W 5OV oc RIMS. $L26 CJC ~-T' # ~ ]

= 3 m j i.... _u. .u, o, '.5 Seismic.J.Ibeha) Hovevank - Clan TE Flesbje._fonddi-- dh :.' ' i pYq,,'f" IMFORMAT10h) OhlLN - NO CHECKIM REGulED cow *utto cast i p,'G'~ Table oT Contents y gon e.

t. o Purpose i

4 2.0 Scope i 3.0 Pipe MounYed E uipdd 7. t i. 3.1 Grown 3 Feh Nudear Pla'w f i' 3. 0. Belle h te. Nudear Plaaf 3 3.'S Wah Ba r Nudear. Pkd 4 3.4 Squoy A Wudear Pbn 4 4.0 Flwr %need E uipmec 5 t 4.1 Cast or Forged E uipmer 5 t

4. '2.

E uiprnen-l-Using Sheet MekL ConstrucHion ~I t F.o Flenble Condui-: t0in &% Ends AHod4c4 to -) o Sam e ' Rig d S4ructu r-e-6.o Sum man / 11 7.0 Refere ces ' 12. A ppendix A Hayimum Mourneds Gr Belle &de Mudear Pk[ A pendh B Seismic Simbdion Test Pqrom 7 Mob Codrol Ceder on l 6 l 2 0

6 {.*~ 1 I'& . ha / rwa %u - cum nau, ceau- ,, u, $2 aj t ' C0tspuf to . Daft

h y r' !

r-e u.a A W..,a 4-M -f t l.O Pa? M

E ose af 4 bis cchuldien PoAe is Tle P

P lo prodicle ww. mum inouam at\\s b r bibie coulu'dr' C(,Meh10ns - %.k Me dudked 4o 0.{055 lb guipM(( a+& =aQeck w%ch\\ da seuie vnenaieat Tbs cdlculation is. used W su p eri -lh e weww movemeds cjuau a hison 1.0 4e 6enered (cadruc{ low SpeU&cchen G - 40 2.0 Lope _ l c&hab 40 dass IE py, reounded deuwes. on eenally wou'ing sybenes ed abhews to %r mun-)d cgtpmod in ceqon i ~ c4tue\\ures.. 2 E 5 0

1 a 2 / 3- ,Seiswi,/ Therrrxtl. Mov.twerim_- 0.l ass U FletiW,. Cnndu'r sntti or_ . ', ~. -

.: '\\'

v. R W.oAtt N 3* __ courutto .,t 3 -u sa .....t. F 0 pipe. Manfe</ Equiomnif - 4 .J i.I % E'& mi Nuenc Plan + A pq angsb survey was made ivt rehreuxe 7.1 4o clct.er esae radiuum Ikemal ed selsa6c i memees for%4toi air V\\qw hose a7ficnidas on de Main Giew Sddy RebeT \\a\\ges (Hssef) cd be Fury. These rgresed inahm %emd ppe movemahs is %e p63 due u 4e 3ip b,peaiure of N ynaivi siam Un e.1(s is also coi ewelbp'n3 seismic. cordi4iovi due b ~ 4be long ey!r-evided ebdare oF 4be MSS R\\]. i The ewe \\op'ing memed for comb'id emd ond seismic loc4hv; is

3. 4,O 'm.

iu o anY dicechon bi Me kri embt \\ 7 a n e. and

1. 25 m. up in %

gec4.ua\\ clireck. .$ NOer p'sp'm3 ctvedyi'5 e.arvey Wa5 mad e i 0 d

Ib s a, av . h.i.nic./ Wew>l Moveweg4 -Olea IE Finible CnniuPL ~' a...,aah08..anL-b-9l .a :.J 'c ....... A s r..., + u. - e y.i... bi rPeretce 7.1 -lo dehrmine insimum tnovemer.s '. -Tor 'pa tocuded devices on 'p'ipn3 qs <nts i I' aflodsed io % e +orus.'wak3 hible covduir ~ oEachnies. The enudopiny movemed for combined Bermd,..seimic a d -lor a.s loading 'ts 1.0 in. in each direchn. s S.2 Be1\\eFode H adenr-T\\an+ A surny of 4he ppn3 udys'is oY he enfin steam \\ine ( rd'ernte 7. N was vape. Er h caiculation. %e end o-r %o exrendecJ va\\qe. s\\tudaces on %e mim deam syskm ya\\9es were used for two muwi 'hermal chd sehnsc nvr ion by Oc.same reasonin3 used '~ for 6rovans Fctry. Tabu \\x4 ed voovemah. os e douan in A ppenohv A. 'h cedop g s il: b >=

6 .:- 'avgeMi@ny.mx

q.y: y,_ f ~.

. fi.s@ c y'" ':.. ....c, = ".... '4' CH(C t $#M9+n-T' Mty#MS. . ', [yy,,,

.y inal@ter for hetM and sindic loodn$ t.s ~,d,[.{

[' r

.: .2 3.70 in, 'm any divedioY),

i,O.M 3.3 Wah h Adeur Plun:

J 47 I.nIorrno,l consulta.iion uhn 4he super \\/tsor oT .j, %e rigoron pip'in3 am\\ysis secHem wac made P "S 3* '6* "' "rd M*

I 4o deltr mi ne eni(I I

.y

.] movemeds for pipe wcuvrfed clevices WIN hdthk p cordud ghoched, 'The (nain sie>om sydtm was L used '-as 4 ke basis Xor ms. A consordMe. erNiwMec, enelope 05 4.00 ivi, in cstly diR'Chd WOS ONeu -[0f 00Mb'ined brma anc S41.5mic, o Th0% hoi'. B,4 Seguayab Mudeur Piad Sosed on the SmiLorify bebcH Nats Mr e and 6cguoy Ah, 4he some tombined Se'tSNit, OM Sermal (60WfAf>b enieb C WI\\I bt " Sed-P

~~ r fg, 3, as. ag;.s.y:My,94ggs: ' ; 1.', , c .?j:4.fyfs4 Q ,Q.' '.')$<- (i ' . 'fs9Nm;.'.u. : ~ ggg ' eg } Q'fMpg_ Cl %Wm.q x: Moiwierd. for %etE and simsc loadng is Ni

4 3.70 in

'm any cliredlon, ' "9p r , A... 3.3 Wahs % kludeur Plaw, a; l_.nIormal Cons 4No.kion uith 4he sypervisor oY . j %e riprous pipig am\\yss secHow wac mode 4o dehrm'ine enciop'ing seiswnc ad %emi j i .~ rnowmabs. For pipe wounfed clevices aaifh he&ie p e cordu,+ nhched. The (na'm sdeom sysb was [ uwd'as De basis Xor 4Ws. A consordMe. e:Nidec, enelope os 4.00 la, in 'any 4recied Was oWen b comb'ned rma am se'tsmic, o WCY1W. s,4 seguayab udeur Piad 130 ed on 4he cimiLorify behocen Wahs Bar and Gaqyoy4, he some combined seism'ie, [g aM hiermal toowner enie\\cpe mi\\i be used. l i 1 i ~ i ? E ~ -.-_-_-_--_,--m_

s' 13 ..m. o, 5dionsc_/_hrm hvemecs Clow IE Flesble Gneh/c' cast d - U k k co wotto .c : _....*u.-w c.... l 4.0

Fle r Moun4e4 Equipmem-i 4l btSr hrg ed E(ui pmenk

, br oli phnts where : Cast or Erged I Obss IE quipmed is grodect io ne br, i emperalure = b50 *F fo r' crubon shee I hei6ht T fle condui F abh me ab ve Elecr ts cl V t.. a.nd hori zon hl clis t-a nc e. From s (.. cektr ine of etuipmer suppor 40 condu.'d aSochmed is 4 R, 4herma) movmen = AX dere; coeiricient oY %erun) esponsion = = = 7.33xioin/in/'*F

cana,

(.ycso -w) p s(*9 s i t)in =o.459 in. -c a)(y = 7. 33 y 10 in x in

F and,-

x [4 x I 2) i n = 0,7.04-in. A)(n = x Mnimum Tbtrnal heuen4- (in) vertico bor'rzonfa L i/2. 2/4 s 4 g i Linear 'inferedason may be used for g-smder values Lsee su mmu ry ), 4

2 a y 1.' 6 /3 vismic / Theh &cmed. -C 155 IE Fle9ble PnMui-- ..u, y

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s-SEN-G-40-11 ~ QQ) MlQ pg Page 1 of 10 i TABLE '0F CONTENTS - Change the titles of sections 1.4, 3.2.6.2, 3.2.6.3, and ~ 4.0 to rhad: j ., 4 1.4 Definitions ~ 3.2.6.2 Floor-Mounted Eauinment and Devices. Seismic Movement Consideratiobs in Seismic Category I (Clr.as I at BFN) Structures t 3.2.6.3 Pipe-Mounted Devices. Therns1/ Seismic Movement Considerations 4.0 DIVISI0N OF NUCLEAR CONSTRUCTION /0FFICE OF NUCLEAR POWER QULLITY CONTROL r PREFACE - Change the first paragraph to read: ... future nuclear plants. This specification also applies to. future 1 I modifications and their subsequent maintenance activities at Browns Ferry Nuclear Plant (BFN) in accordance with N. R. Beasley's memorandum to G. R. Hall dated January 15,1986 (B22 860115 015). This specification may be used. Section 1.2. Page 1 Change first paragraph, first sentence to read: N It is the responsibility of the Division of Nuclear Engineering (DNE) to prepare. Section 1.2. Pace 1 Change last paragraph, first sentence to read: l It aball be the joint responsibility of DNE and the Division of Nuclear Construction (NU CON)/ Office of Nuclear Power (ONP) to record... Section 1.3. Pace 1-2 ' Change to read: The DNE Electrical Engineering Branch (EEB) Central Staff is responsible for the contents of this construction specification. NU CON or the ONP site director is responsible for enforcing the requirements of this general construction specification. Section 1.4. Page 1 Change title and add definitions. 1.4 Definitions Seismic CateRory I (Class I at BFN). Those structures, systems, or i i components which perform primary safety functions. They are designed and constructed to assure achievement of their primary safety functiona at all tid,esincludingaconcurrentSafeShutdownEarthquake(SSE), t-I I a 066104.03

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I ..v ' s' SEN-G-40-11 Page 2 of 10 Sefsmic Category I(1,)(Class II at BFN). Those portions of structuras, a syste'ms, or components which perform secondary safety functions to the s exteEt

7 that only limited structural integrity is required. They are designe'd and constructed to assure achievement of their limited structural integrity at all times including a concurrent SSE.

I Safe Shutdown Earthauske. An earthquake which produces the max'imum i i vibratory ground motion for which structures, systems, and components which perform a primary safety funciton are designed to remain functional. Section 2.2. Page 2 Change to read: Major materials and those of a special nature used.in the installation shall' be designated on DNE detailed design. .y i 1 Section 2.3 Pare 2-1 ~ Change first paragraph, last sentence to read: ... flexible conduit, and other minor materials necessary for installation but not requisitioned by DNE. Section 2.3. Psee 2 Change first paragraph, last sentence to read: DNE approval for their use is contingent upon the following: Section 2.3. Page 2 Change third paragraph, second sentence to read: The following types of stainless steel flexible conduit are acceptable for these applications: ServicAir Company SS60, SS63, or SS63C series, or' American Boa, Inc/, type HB1-0 or HB1,-1 series, or equal.- Section 2.3 Page 2 Change first' paragraph, first sentence to read: Pressure-tight stainless steel flexible conduit (ServicAir SS63C extra flexible stainless steel) as defined on the respective project's deaign drawings and as approved for use by DNE, shall be used for installations where an equipment seal is required. Section 2.3. Page 2 Change last paragraph to read: B If additional restrictions or limitations are required on miscellaneous materials to be purchased by NU CON /0NP, these restrictions... Section 3.1.1. Page 3 Change to read: P. Installition of conduit, boxes, fittings, and accessories shall conform to I the respective sections of the latest edition of the National Electric Code (NEC), and the design drawings. 9 066104.03

s I J l S RN-G-40-Il .l,'.,'. Page 3 of 10 e Section Y.1.2. Pane 3 Change to read: g ~, - Ifinterfafeneenoccur,theNUCON/0NPelectricalengineershall... .= Section 3.1.3. Pare 3 Change first sentence to read: ...promptly, the DNE project shall be consulted for concurrence af ter NU CON /0NP has coordinated... _Section 3.1.2.3 Page 3 Section is incorrectly numbered. I Change to' read 3.2.1.3. l I Section 3.2.2.2'. Pare 3 Change second' paragraph to read: In seismic Category I (C1' ass I at BFN) structures, exposed conduits shall... Section 3.2.2.4. Page 3 Change first sentence to read: In nonseismic Category I (Class I at BFN) structures, galvanized steel members ~ may... 'N . Section 3.2.2.8. Page 3 Change second sentence to read: .The conduit interconnecting.the two conduit bodies shall be sized by NU CON /0NP in accordance with DS-E13.1.4. Section 3.2.4.2. Pare 3 Change last rentence to read: An electrically conductive, antiseize compound for metal surfaces (Thomas and Betts Company "Kopr-Shield"; Jet -Lube, Incorporated "SS-30"; Burndy "Penetrox E"; or equivalent) shall be applied to the male conduit threads. Section 3.2.4.4. Paee 3 Change first sentence to read: .. embedded applications in nonseismic Category I (Class I at BFN) office and service buildings. Section 3.2.6.1. Page 3 Change first paragraph, first sente6ce to read: ... equipment and devices that rotate, vibrate, are subject to. Section 3.2.6.1. Pare 3 Change first paragraph, second sentence to read: ...funktioningastheequipmentordevicegroundingconductor,... I e 4 066104.03

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i i .(, SEN-G-40-11 Page 4 of 10 Section 3.2.6.1. Page 3 Change second paragraph to read: .a I Flexible' tonduit shall be insta'11ed between conduit fittings in exposed lengths' not exceeding, 72 inches, except as noted on design' drawings. (For exceptions not noted on design drawings contact DNE project for resolution.) Rigid conduit shall be located as near the equipment and device as practicul. The flexible conduit shall be prepared, assembled, and installed ic accordance.with. manufacturer's instructions, including any torquing requirements where spplicable. The minimum recommended bend radii given in Table 3.2.6-1 shall not be violated. Flexible conduit shall be installed without twist and should be oriented away from heat radiating sources, such as a hot pipe and its insulation; After installation, the flexible conduit stretchdd between flexible conduit fittings. shall not be tight or Section-3.2.6.2. Pace 3 Change the title of section 3.2.'6.2 to read: l l 3.2.6.2 Floor-Mounted Eauipment and Devices. Seismic Movement Considerations in Seismic Category I (Class I at BFN) Structures Section 3.2.6.2.1. Pace 3 Remove section number "3.2.6.2.1" and change the first paragraph to read: W During. . allow for relative displacement of equipment or devices and a rigid conduit system. To ensure. (such as motors. . floor-mounted equipment and devices Section 3.2.6.2.1(a). Pares 3-12 and 3 Change to read: ~ (a) When cond'aits connect to the top of seismic Category I (Class I at BFN) or Category I(L) (Class II at BFN) floor-mounted equipment and de. vices, an 18-inch minimum exposed length of flexible conduit shall be installed betwe the flexible conduit fittings installed at en the rigid conduit coupling and the equipment or device. The actual minimum conduit length required for a particular installation shall be as specified on design drawings or as calculated by NU CON /0NP using the equation in Figure 3.2.6-1. This minimum length of flexible conduit vill insure that floor-mounted equipment devices are capable of sufficient movement and in any direction. The minimum bend radii for flexible conduit given in Table 3.2.6-1 shall not be violated. Where physical limitations. requirements, the NU CON /0NP electrical engineer shall be notified for resolution (by established procedures) with DNE project. Figure 3.2.6-1. Pace 3 Delete figure and note. t Section :3.2.6.2.l(b). Pare 3 Change to read: h. (b) ... floor-mounted equipment, such as control panels,. l 066104.03

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4 = ~ l 9' SRN-G-40-11 Page 5 of 10 Section 3.-2.6.2.1(c). Page 3 Change to read: ,1 (c) .. Ifloor-mounted devices, such as motors, ..to accommodate its . minimum bend radius. (See Table 3.2.6-1.), Section3'.2.6.2.l(d)\\Psee3-13-Replacewiththefollowing: (d) In cases where f1exible conduit is used for alignment purposes only and' both ends of the flexible conduit are rigidly attached to the same seismic structure, the relative displacement between ends is zero and therefore exempt from thermal / seismic considerations. ~ f Section 3.2.6.2.1(e). Pare 3 Add ned section. (e) Conduit connections.to cable trays should be avoided; however, if conduits i are connected to seismic Category I (Class I at BFN) cable trays, an 18-inch minimum length of flexible sonduit shall be installed as in (a) above. Section 3.2.6.3 Psees 3-13 and 3 Replace (existing text, Table 3.2.6-1 and Figure 3.2.6-2) with the following: 'N 3.2.6.3 Pipe-Mounted Devices. Thermal / Seismic Movement ~ Considerations Where electrical connections must be made to devices (such as motor-operated valves, solenoid-operated valves, and temperature switches) which are attached to a mechanical flow system designed for thermal movements, flexible conduit shall be used .to compensate for any expansion / contraction and seismic movement. Typically, f'lexib"le conduit connected to pipe-mounted electrical devices which are subject to thermal movements are in the 1/2-inch through 1-1/2-inch range. Excessive lengths in smaller flexible t conduit sizes shall be avoided to decrease stress and prevent pull-out at flexible conduit fittings. 3.2.6.3.1 Seismic Category I (Class I at BFN) Structures Flexible conduit to pipe-mounted devices in seismic Category I (Cless I at BFN) structures shall be installed to compensate for combined thermal / seismic movements. The minimum length of flexible conduit shall be as specified on design drawings or as calculated using the equation in Figure 3.2.6-1. This minimum t length of flexible conduit will insure that pipe-mounteddevicesafe-y s i 4 9 066104.03

. ~.. _. -g.. t .l ,s, 1 g SEN-G-40-Il ~- Page 6 of 10 i. 3.2.6.3 :1.'- Se ismic Cat egory I (Class I at BFN) Structuras (Continued) I r + capable of sufficient movement in any. direction. The minimum bend. . radii for flexible conduit given in Table 3.2.6-1 shall not be' violated. t 3.2.6.3.2 _Nonseismic Category I (Class I at BFN) Structures Flexible conduit to pipe-mounted devices in nonseismic Category I (Class I at BFN) structures shall be installed to compensate - for thernal ~ movements only. However, installing conduit per the given equation for seismic Category I (Class I at BFN) structures will provide adequate compensation for nonseismic Category I (Class I at BFN) thermal movements. l l -as e 4 D i l t I t l h h 0 l 066104.03

3 ~ 1 l ' l ' ;. l* SEN-G-40-11 ' n. Page gof 10 7 ~ Section 3.3.3. Pare 3 Change first sentence'to resd: f .boxeI located in seisinic Category.I (Class I at BFN) structures shall.., Section 3.3.4. Page 3 Change second paragraph, second sentence to read: The size lettering shall be determined by NU CON /0NP, depending,on the box size. Section 4.0 Pare 4 Change title to read: DIVISION OF NUCLEAR CONSTRUCTION /0FFICE OF NUCLEAR POWER QUAI.ITY CONTROL I Section 4.0. Page 4 Change to read: NU CON /0NP has the responsibility... 1 e -e l [ l t .p* s s I l 066104.03 l

1 n 3 i . i f.. j SEN-G-40-11 (' Page g of.10 Figure 3.2.6-1 8 1 Rigid Conduit t u s y / f , Rigid Conduit Support / N Coupling r ~ Flexible Conduit Fitting jjj Rigid Conduit Support Exposed Flexible fFlexible Conduit Fitting " "'E [ Exposed Flexible r Conduit I e Coupl.ing Ri id Conduit R l l y Flexible Conduit pggg Flexible Conduit Fitting - j +--Top of Floor-Mounted Equipment or Device ' Device f N.g Typical Arrangement of Floor-Mounted Ecuipment or Device and Pipe-Mounted Device Tbc equation for calculating the minimum length of exposed flexible conduit required between flexible conduit fittings installed at rigid conduit couplings and flexible conduit fittings installed at the floor-mounted equipment or device or pipe-counted device is as follova: FL = SD + K

Where, FL = Minimum exposed flexible conduit length between flexible conduit fittin (See Note 1.)

SD = Field measured straight (When an obstacle prevents a straightline distance between flexible conduit fit flexible conduit route shall be determined and that distance shall b for SD.) K = 1 inch or 4 inches (1-inch flexible conduit length is required for _ maximum, - seismic movement in any direction at all nuclear plants; 4-inch flexible coriduit length is required for ciaximum combined seismic / thermal movement {in any direction at all nuclear plants.) s 4 066104.03

~ 1 I. )l s ' I i ',i. SEN-G-40-11 Page M of.10 4 .l Note '1:~- Tor flexible conduit cut length, the field shall add to the minimum l "<alculated length (FL), the flexible conduit length required for .k:onduit fittings and any additional length required for bend radii. The minimum bend radii for flexible conduit given in Table 3.2.6-1 shall not be violated. Any exceptions 'to minimum calculated lengths -(FL) and/or minimum bend radii shall be approved by DNE for Class IE installations. s Note 2: Exposed flexible conduit lengths shall not exceed 72 inches or be less than 18 inches, installations. except as noted on design drawings, for Class IE 'DNE engineering project for,rresolution.For exceptions not noted o l l e 6 e t h 1 066104.03

,3 1. 1.. ~ , j s i SEN-G-40-11 Page/of 10 i i /0 Table 3.2.6-1 i .s Flexible or .I Liquidtight Connector- ~ DJ f / 4%#1 s ~ { a t I I s -z! OD Hinimum Bend Radii for Flexible Metal Conduit Dimensions-Inches .g Anaconda Type U.A.lServicAir SS63 American Boa B1-0 Trade Size I (Inches) I A (Hin.) OD (Nom.) A (Hin.) OD (Nom.) I 2 A (Hin.) A (Hin.) OD (Nom.) 1/2 3.5 .84 2.5 .69 2.7 1.17 .67 3/4 5 1.05 3.8 .94 4.5 1.23 1.04 1 6 1.'32 5 1.25 5.9 1.38 1.24 1-1/2 5.5 1.90 7.5 1.75 8.6 2.55 1.91 2 7 2.38 10 2.28 9.8 3.81 2.38 2-1/2 9.5 2.88 12 2.78 11 4.54 2.93 3 11.5-3.50 15 3.28 12.8 5.27 3.47 i 4 14 4.50 20 4.50 19.7 8.74 4.53 5 20 5.57 25 5.56 26.2 12.20 5.61 I I' 6 t 30 6.63 30 6.63 31.7 14.71 6.59 1. Installations where seismic and/or thermal movement considerations are applicable. 2. Installations where ~ seismic and/or cliermal movement considerations are not applicable. 066104.03

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i L TVA EMPLOYEE CONCERNS REPORT NUMBER: C017301 SPECIAL PROGRAM SQN REPORT TYPE: Sequoyah Nuclear Plant Element REVISION NUMBER: 2 TITLE: Slope PAGE 1 0F 7 1 REASON FOR REVISION: Revision 1 Incorporate changes based on TAS and SRP comments and discussions. Revision 2 Add (2) additional concerns to this element and make editorial and typographical changes PREPARATION PREPARED BY: / O - lo - [L w-DATE G SIGNATURE REVIEWS PEER: $k /c)-6-8G Mf SIGNATURE DATE TAS: SIGNATURE DATE CONCURRENCES ff.G-H:, /8-#f"/[ v SIGNATURE DATE SIGNATURE

DATE APPROVED BY:

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

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

1665T

c TVA EMPLOYEE CONCERNS REPORT NUMBER: C017301 SPECIAL PROGRAM SQN REVISION NUMBER: 2 PAGE 2 0F 7 SUPPLEMENT FOR SEQUOYAH NUCLEAR PLANT I. INTRODUCTION Ten concerns involving instrument line slope have been evaluated in lR2 this report: d IN-85-68-N07 lR2 / IN-86-222-001 / JIN-85-119-001 JIN-85-197-001 JIN-85-218-001 JIN-85-982-002 JIN-85-985-001 lR2 4PH-85-001-002 XX-85-046-001 SQP-6-001-001 II.

SUMMARY

OF PERCEIVED PROBLEMS Installed instrument sensing lines do not comply with the minimum slope requirements of TVA drawing 47W-600-24 and are susceptible to air / gas entrapment which can affect instrument accuracy and reliability. III. EVALUATION METHODOLOGY Categorizing the above employee concerns as a generic issue, a review was performed to determine whether previous evaluations performed by NSRS, DNE, and the Sequoyah Generic Concern Task Force (GCTF) have adequately addressed and resolved employee concerns related to instrument line slope. A. Interviewed 3 individuals (Project Manager and (2) Lead' Engineers) lR2 from the Watts Bar Instrument Project to determine if the results of their evaluation and the corrective action taken were potentially applicable to Sequoyah. B. Interviewed the Supervisor of Electrical Engineering I&C (SQEP) to determine the history of the sensing line slope issue, including prevluus evaluation results and documentation. C. Reviewed letter from Wohld to MEB files, dated November 17, 1978 (RIMS MEB 78_1120352), titled " Instrument Sensing Line Problems - Report of October 17, 1978 - Field Trip Findings," concerning pre-op test deficiencies caused by air entrapment in instrument sensing lines.

.g. TVA EMPLOYEE CONCERNS REPORT NUMBER: C017301 SPECIAL PROGRAM SQN ' REVISION NUMBER: 2 PAGE 3 0F 7 D. Reviewed letter from Pierce to Pattersoq, dated December 5, 1978 i (RIMS SWP 781205011), titled " Instrument Sensing Line Problems," which was the Design Projects Manager's response to reference III C. l E. Reviewed letter from Whitt to Parris, dated December 27, 1985 (NSRS Report No. I-85-590-SQN), titled "NSRS Investigation Report," which covered the results of the NSRS evaluation of instrument sensing line slope at SQN for Employee Concern XX-85-046-001. I F. Reviewed letter from Vineyard to Rankin, dated December 20, 1985 (RIMS B2585120003), titled " Sense Line_ Slope' Employee Concern," which summarizes the evaluation by OE of the sensing line slope issue requested by NSRS in reference III E. G. Reviewed letter.from Abercrombie to Wilson, dated Apell 18, 1986 (RIMS S53 860417988), titled " Sense Line Slope Employee Concern I-85-590-SQN." which responds to reference III F. H. Reviewed letter from Whitt to Abercrombie, dated February 25, 1986 (NSRS Report No. I-86-128-SQN), titled "NSRS Investigation Report." which covered the results of the NSRS evaluation of instrument sensing line slope at SQN for Employee Concern SQP-6-001-001. I. Reviewed letter.from Mason to Whitt, dated January 28, 1986 (RIMS S53 860113843), titled "NSRS Investigation Report No. I-85-590-SQN," which responds to reference III E. J. Reviewed letter from Whitt to Mason, dated April 16, 1986, titled " Corrective Action Response Evaluation," which responded to and accepted reference III I. K. Reviewed Sequoyah Generic Concern Task Force evaluation report covering Employee Concerns IN-86-222-001 and IN-85-197-001. L. Interviewed 2 individuals (Maintenance Supervisor and assistant) lR2 from Sequoyah Nuclear Power Instrument Maintenance Section to discuss i instrument maintenance and calibration techniques related to entrapped air in sensing lines. Discussed backfill procedure minimum flow rates j and restrictions on backfilling cold demineralized water back to a hot process nozzle. M. Reviewed maintenance and work requests associated with units I and II feedwater flow transmitters, steam generator Aur level transmitters and RCS flow transmitters to determine if, based on a sample, there were any indications of maintenance problems related to potential air entrapment. 4 a

I ~ TVA EMPLOYEE CONCERhS REPORT NUMBER: 0017301 SPECIAL PROGRAM SQN REVISION NUMBER: 2 PAGE 4 0F 7 N. Reviewed Norris Test Lab reports WR28-1,85-107, 109, 110, 113, 116, 120, and 121 related to air babble migration in sensing lines and the effects of entrapped air on transmitter output signals. O. Reviewed Reg Guide 1.97, Rev 3, dated May, 1983, WBN " Draft," calculation number WBPEVAR8603010 WBN and calculation number WBPEVAR 8511002 to develope n sample scope of post accident monitoring (PAM) instruments required to function during and after a Design Basis Accident (DBA). [ IV.

SUMMARY

OF FINDINGS The following summary of findings, paragraphs IV, A through 0, I correspond to the evaluation methodology which is detailed in - l R1 paragraphs III A through 0. l A. The Watts Bar Project handled the sensing line slope employee concerns by creating the Instrument Project which performed a case by case evaluation of selected safety related and sensitive instrument sensing lines. A significant amount of rework has been identified as a result of these evaluations. This approach differs from Sequoyah's in that Sequoyah is utilizing several years of successful operating experience as their basis for acceptability of installed sensing line slopes. B. Based on discussions with the Supervisor of Electrical Engineering I&C (SQEP), evaluations have been performed by NSRS, OE, and GCTF concerning instrument sensing line slope adequacy. All reports lR2 issued as a result of these evaluations (reference paragraph IV E. H, F & K), basically agree that, based on several years of operating experience utilizing enhanced maintenance and calibration procedures, the installed configurations of sensing lines are technically and functionally acceptable. Maintenance / work requests do not reflect the existence of any operational problems which can, be attributed to sensing line slopes. C. The letter from Wohld to the MEB files provides solutions to pre-op test deficiencies which were attributed to air entrapment. D. The letter from Pierce to Patterson acknowledges implementation of recommended corrective actions provided in paragraph IV C. This letter also mentioned that SQN would discuss with the Electrical Engineering Branch the need for a construction specification to prevent recurrence of slope problems on later plants.

.g y _ % =- TVA EMPLOYEE CONCERNS REPORT NUMBER: C017301 SPECIAL PROGRAM SQN REVISION NUMBER: 2 PAGE 5 0F 7 E. NSRS Report No. I-85-590-SQN concludes that even though the employee concerns were substantiated, there is no history of functional problems which would require further action. The NSRS report makes five recommendations related to closing this Isabe: 1. Engineering Evaluation of Instrument Sensing Line Slopes 2. High Point Vent Valves 3. Returning RCS Flow Transm16ters to Service 4. Sensing Line Installation Procedure 5. NCR 6172 Evaluation for Generic Applicability to other TVA Facilities. F. The Vineyard to Rankin letter documents the results of OE's evaluation of instrument sensing line slope, as requested by NSRS and SQN management. This letter summarizes corrective actions taken during pre-op testing and during normal plant operation for problems caused by inadequate sensing line slope. Included in this evaluation were the results of an OE & Maintenance walkdown of sensing lines, a revise of maintenance histories and a review of maintenance procedures. This report concluded that no plant safety problem exists at SQN based on successful operating experience, current and planned instrument maintenance practices and administrative detection methods for entrapped air in sensing lines. G. The Abercrombie to Wilson memorandum responds to the OE evaluation l report (reference IV F), basically agreeing with recommendations to l monitor maintenance / work request trends. This memorandum states that programs are already in place to do trending and that the Instrument Maittenance Section is responsible for performing this function. l H. NSRS Report No. I-86-128-SQN is very similar to the report issued in reference IV E. Three recommendations were made related to closing this issue: 1. Engineering evaluation of instrument sensing line slopes 2. Returning transmitters to service 3. NCR 6172 evaluation for generic applicability to other TVA facilities. l I. The Mason to Whitt memorandum responded to NSRS Report No. I-85-590-SQN recommendations made in reference IV E.

s 6 .IVA EMPLOYEE CONCERNS REPORT NUMBER: C017301 SPECIAL PROGRAM SQN REVISION NUMBER: 2 PAGE 6 0F 7 J. The Whitt to Mason memorandum accepted a}1 responses made in reference IV I. K. The SQN Generic Concern Task Force (GCTF) evaluation report reiterates the results of previous NSRS and OE evaluations. The GCTF endorses the recommendations made in the NSRS report (reference IV E) and makes no further conclusions or recommendations. L. Individuals from the SQN Instrudent Maintenance Section discussed existing maintenance and calibration techniques being applied to sensing lines and instruments with. associated'high points and low points in the line routings. Sensing lines susceptible to air entrapment have been identified and are adequately covered by procedures. Maintenance histories do not reflect any recurring problems in this. area. M. An independent review of maintenance / work requests (MRs and WRs) for a portion of safety-related instruments was performed, looking specifically for problems caused by possible air entrapment in sensing lines. Two hundred twenty two (222) records were reviewed, with approximately seven potentially related to air entrapment. Further review found that these MRs and WRs were issued in a timeframe when system maintenar.ce involving numerous pump starts and stops were occurring. N. A general review cf various Norris Lab test reports was performed to determine the total effects of entrapped gas or air bubbles on an instrument's accuracy and performance. These reports validate the potential problems caused by gas or air bubble entrapment. The reports also establish minimum flow rates for backfilling of sensing lines. O. Evaluation reports issued by NSRS, CE, and GCTF all basically concluded that there was no safety problem at SQN involving sensing. line slope, based largely on several years of operating experience. Since this operating experience does not include experience during and after a design-basis accident (DBA), the calculated effects of a DBA on sensing lines associated with post accident monitoring (PAM) instruments must be determined. Reg Guide 1.97 was reviewed for any special conditions or criterion applicable to PAM instrument sensing lines. TVA's commitment to Reg. Guide 1.97 implementation at Sequoyah is currently l September, 1987. lR1

L. 3 7 l l TVA EMPLOYEE CONCERNS REPORT NUMBER: C017301 SPECIAL PROGRAM SQN REVISION NUMBER: 2 PAGE 7 0F 7 CONCLUSIONS A. All specific and generic concerns related to instrument sensing l line slopes not conforming to the installation requirements of. lR1 drawing 47W-600-24 are valid. l B. For " Normal" operating conditions, the installed configurations of sensing lines do not create an operating or safety concern. C. Evaluations performed by NSRS, dE, and GCTF do not address the acceptability of sensing line slopes during abnormal or accident conditions.. Engineering design criteria is inadequate in this area. (R1 D. Based on the results of Norris Lab testing, the SQN backfilling procedure for sensing lines should specify a minimum flow rate to assure that entrapped air or gas is purged from the line. E. SQN Backfilling procedures should be evaluatud to determine if restrictions are required on backfilling cold demineralized lR2 water into potential hot process nozzles. V. ROOT CAUSE A single root cause for this condition has not been determined. This evaluation concludes the following: Installation requirements from design output drawings were inadequate and not restrictive enough. Engineering design criteria which covers all modes of lR1 plant operating conditions is inadequate. ( Installation practices were inadequate. Inspection. techniques were inadequate. VI. CORRECTIVE ACTION (To be provided by Line Management) VII. GENERIC APPLICABILITY All employee concerns listed in Section I of this report have already been deemed generic for all TVA nuclear facilities. VIII. ATTACHMENTS Attachment A - Listing of concerns indicating Safety Relationship and l Generic Applicability. lR2

. J; ~ SLOPE ATTACHMENT A GENERIC APPL QTC/NSR$ P C0!aCERN SUS PLT 5B5H INVESTIGATION CONCERN NUMBER CAT CAT LOC FLQB REP 0RT R DESCRIPTION e PH 001-002 CD 173 H8N YYYN PH-85-001-002 $$ SLOPE PROBLEM HITN INSTRUMENT LINES T50001 K-FORM IN SYS 68. PAFELS 224.227,228. PRE VIOUS NCR ONLY ADORESSES 4 0F 28 SPE CIFIC LINES FROM THESE PANELS. MORE SPECIFICS MAY BE AVAILABLE LATER AS INDIVIDUAL CLAIMS TO HAVE A DIARY, H0HEVER CONTACT IS NOT PRESENTLY POS SIBLE. IN 068-N07 CO 173 H8N NNNN NS NRC IDENTIFIED THE FOLLOHING CONCERN K-FORM ' FROM REVIEW OF QTC FILE. " FAILURE TO CORRECT THO ERRORS ON A LINE MAY RESULT IN REACTOR SHUTDOHN." REVIEW OF FILE INDICATED THAT NRC 15 REFER RING TO AN INSTRUMENT LINE. IN 119-001 CO 173 HBN YYYY IN-85-119-001 SS DRAHING 47H600 REQUIRES 1/8" PER FT. 750065 REPORT SLOPE. CONTRARY TO THE ABOVE, SYSTE M 68 (REACTOR TRIP) UNIT 1, 702' ELE

== V. IN CONTAINMENT. INST. LINES LAYI NG IN RACEHAYS DO NOT HAVE 1/8" PER FT. "$ LOPE". SPECIFIC AREAS NOT AVA ILASLE, BUT C/I INDICATED THAT A TOU R OF THE ELEVATION HOULD PROVIDE SEV ,f ERAL EXAMPLES. IN 197-001 CO 173 H5N YYYY SS SYSTEM 68 IN UNIT I REACTOR BLDO. RA T50156 K-FORM CEHAY AREA INSTRtIMENTATICH SENSING L INES HAVE NEGATIVE SLOPE IN SOME ARE AS HHICH COULD TRIP REACTOR. THIS S ITUATION HAS LOOKED AT BY ENDES IN K N0XVILLE AND THEY STATED ON NCR 5750 TO USE-AS-IS. CONSTRUCTION DE?T. C ONC ERil. C1 HAS NO FURTHER INFORMATI ON. NO FOLLDH UP REQUIRED. IN ?!S-G01 CO 173 HBN YYYY IN-85-218-001 SS INSTRUMENTATION LINE, SYSTEM 68. IS T50908 REPORT NOT PROPERLY SLOPED ON UNIT 81. DESp IGN/ENG RECEIVED THE AS-BUILT CONDIT ION BUT MAY NOT HAVE APPROVED CONDIT ION IN 982-002 CO 173 HBN YYYY NS OVERALL' MINIMUM S' LOPE REQUIREMENTS C DULD NOT BE METS BUT DRAIN LINE HAD REPORT T50111 TO BE REHORKED TO ESTABLISH 1/2" SLO PE OVER PART OF LINE (PREVIOUS INSTA LL ATIOfl HAD 1/8" SLOPE IN SAME AREA = -BOTH LINES ENDED IN UP-HILL VERTICA L RUN OF SEVERAL FEET TO ROOT VALVE) 737 DOHN 71 LOCATIONS GO FROM AUX.BY SECURITY FEN 3' ELEV. LVE IS AT CORNER HHERE FCNCE TURNS L EFT. LINE RUNS APPROXIMATELY 14' AL ONG LEFT LEG OF FENCE IIITO SECURITY FENCE AND INTO PANEL AGAINST FENCE. C1 HAS NO FURTHER INFORMATION. ~ STRUMENTATION ENGINEERING IS NOT H P45 '"LD RESPONSISLE FOR ISTAKES THEY CAU IN 985-001 C0 173 HBN NNNN T50112 MP 712 REPORT E SE. EXAMPLE: (1) " INSTRUMENTATION L QA 802 INCS HITH INCORRECT LOPE. (APPROVED BY ENG.). THESE ARE NOH BEING ADDRE $$ED BY NCR'S.

2) THE ENGINEERING D ELETION OF STAINLESS STEEL CLEANLINE SS REQUIREMENTS UNIT J1) HHICH IS A*

QC REQUIREMENT. CI HAS NO ADDITIONA L INFORMATION. NO FOLLOH UP REQUIRE D. IN 222-001 CO 173 HBN YYYY SS INSTRUMENT LINES ON AUXILIARY FEECHA T50194 REPORT TER. STEAM GENERATOR BLOHDOWN, AND $ TEAM GENERATOR LEVEL a POS$!BLY DO NO T MEET MINIMUM SLOPE REQUIREMENTS AS SH0HN ON 47H600 DRAHINGS, SHEET 0. UNIT 1 8 2. CONSTRUCTION INSTR. ALL SYSTEMS. CONSTRUCTION DEPT. CONCERs N. CI HAS NO FURTHER INFORMATION. SQP-86-001-001 C0 173 SQN YYYY I-86-128-SQN $$ DRAHINGS REQUIRE AN 1/8" PER FOOT SL 750240 REPORT OPE AND CONTR ARY TO THIS THE INSTRUM ENTATION LINES DO NOT COMPLY HITH DR AHING REQUIREMENTS. CONSTRUCTION DE PT. CONCERN. CI HAS NO FURTHER INFO RMATION. NO FOLLOH UP REQUIRED. XX 046-001 C0 173 SQN YYYY I-85-590-SQN $$ INSTRUMENT SENSING LINES FOR SYSTEM T50143 REPORT 68 AT SEQUOYAH MAY HAVE SLOPE DEFICI ENCIES. DETAILS KH0HN TO QTC, HITHH EL D DUE TO CONFIDENTI ALITY. C0tlSTRU CTION DEPT. CONCERN. C/1 HAS NO FUR THER INFORMATION.

.I TVA EMPLOYEE CONCERNS REPORT NUMBER: C019203-SQN SPECIAL PROGRAM REPORT TYPE: SEQUOYAH NUCLEAR PLANT ELEMENT REVISION NUMBER: 1 TITLE: Conduit and Cable Tray PAGE 10F 5 t REASON FOR REVISION: Revision 1 - General revision. (Incorporate TAS and SRP comments) PREPARATION PREPARED BY: N)> '~A ID\\W 6h SIGNATURE 'DATE REVIEWS PEER: McY f keh /O 8(= SIGNATURE DATE TAS: SIGNATURE DATE CONCURRENCES lf'N'$b CEG- / SIGNATURE DATE SIGNATURE

DATE

~ APPROVED BY: ECSP MANAGER DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)

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

030lT

TVA EMPLOYEE CONCERNS REPORT NUMBER: C019203-SQN SPECIAL PE0 GRAM REVISION NUMBER: 1 PAGE 2 0F 5 I. INTRODUCTION i Employee Concern IN-85-374-002 has been evaluated at Sequoyah Nuclear Plant (SQN) because of the generic applicability determination of the Watts Bar Nuclear Plant (WBN), ECTG Element Report - Conduit Fittings (C019203) within the Construction category. No related site-specific concerns were identified. I II.

SUMMARY

OF PERCEIVED PROBLEM Die cast zine materials (conduit fittings) may have been procured and installed inside containment without being included in the appropriate calculation package for the percent hydrogen build-up inside containment following a L.O.C.A. or a Design Basis Event. III. EVALUATION METHODOLOGY A. Reviewed expurgated' Quality Technology Company (QTC) files for additional relevant information. B. Reviewed WBN ECTG Element Report C019203 Condulets (Conduit Fittings) lR1 dated May 10, 1986, for application to SQN. C. Discussions were held with cognizant Divisionaof Nuclear Engineering (DNE) Electrical Engineering Unit procurement personnel to determine the procurement specifications for conduit and accessories. D. Discussions were conducted with cognizant DNE Chemical Engineering personnel to determine how light metal inventories lR1 inside containment were maintained and/or conducted. E. Discussions were' held with cognizant DNE-EE. conduit and grounding personnel to determine General Construction Specification (GCS) G-40 requirements related to the control of die cast zine materials and light metals inside lR1 containment. IV.

SUMMARY

OF FINDINGS A. No additional relevant information was obtained from the QTC expurgated files.

~ - - y 9 4 TVA EMPLOYEE CONCERNS REPORT NUMBER: C019203-SQN SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 3 0F 5 B. Review of the WBN-ECTG Element Report - Conduit Fittings (C019203) l indicated that conduit fittings thought to be aluminum were i determined to be die cast zine material and installed at WBN. Since l light metals such as-aluminum and zine react with borated water to I form hydrogen, calculations had been established based on' inventories l of aluminum, zine coatings, and galvanized surfaces within the l confines of the containment. The die cast zine materials had not lR1 been included in the base calculation package and resulted in a l revision to the base line data. Since General Construction l Specification G-40 applies to SQN and was determined to be i deficient in that no controls had been established relating to l the addition of zine materials withLa the containment, the l potential for this condition to be present exist at SQN. l' C. Discussions with cognizant SQN DNE-EE site procurement l (supervision and, group leader) personnel revealed TVA Standard l' Procurement Specification for Rigid Steel Conduit (zinc coated) l Number 21.001, dated February 2, 1981 was utilized for procurement l of conduits and accessories such as couplings, elbows, and fittings. l Detail requirement of this specifications ensure slid steel l construction with galvanized (zine) coatings and compliance with the l requirements of Underwriters Laboratories, Incorporated, Standard l UL 6,'and the American National Standards Institute C80.1.

However, l

further discussion and review of applicable purchase requisitions l revealed that fittings such as elbows (LBs and LRs, etc.) were lR1 procured as non-QA and not subject to the requirements of TVA l Specification 21.001 (See Purchase Requisition 837493, dated l March 11, 1985, Schedule II). Since these and similiar fittings i are commercial grade materials, manufactured to industry standards l (including die cast zine), the potential exist for non-coated i materials (reactive metals) to have been procured and installed l within the confines of containment. l D. Discussion with cognizant DNE chemical engineering personnel l revealed an inventory was performed in October, 1985, and had been l included in calculations package B45851028551 for SQN. This update 1 of inventory was performed by a review of applicable Engineering lR1 Change Notices (ECNs) issued since 1979, to determine any aluminum l or zinc materials which had been specified to be installed inside l containment. Updates to the calculation ^ package will be performed l in this manner on at least a yearly basis. In addition, this review l assumed all fittings were zine coated similiar to the conduit run l and did not include non-coated (zine) materials. l E. Discussions with cognizant DNE-EE conduit and grounding personne1' indicated no controls had been established by GCS G-40 related to the addition of zine coated or die cast zine materials within lR1 containment.

c. y TVA EMPLOYEE CONCERNS REPORT NUMBER: ' C019203-SQN SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 4 0F 5 Conclusion Employee concern IN-85-374-002 which stated aluminum fittings were-l being installed at WBN was not factual, in that the fittings were I later determined to be ole cast zinc. Since die cast zine can react lR1 with-borated water to form hydrogen, design basis calculations for l hydrogen build-up should include this material in the inventory of l hydrogen sources. l The potential exists for die cast z%nc materials to have been received I and installed within the confines of containment at SQN based on the l lack of controls and/or inspection requirements related to purchasing and I installing conduit fittings such as elbows, couplings, etc., without i being included in the appropriate Design Basis calculations. Since the l Design Basis depends on the inventory of reactive metals and assumes lR1 total consumption of all reactive metals, st'eps should be taken to ensure l accurate inventories are established for the current plant configuration I and futurc updates also include the additions of " die cast zinc l materials" as required - consistant with the requirements and intent of l the Preliminary Safety Analysis Report. It is suggested that G-40 l section 2.3 be revised to establish control of zine materials inside l containment and that TVA Specification 21.001 be utilized during all l procurements of conduit and conduit fittings where possible. l V. kOOT CAUSE General Construction Specifications G-40 (issued by DNE) did not l adequately address the control of reactive metals within the confines l of containment in that only aluminum was controlled and it also allowed l DNC to purchase miscellaneous materials such as conduit bodies and l covers, conduit fittings, joints and terminations, etc., with no lR1 restraints or consideration given to zine materials. Additionally, l TVA Specification 21.001 was not utilized by site DNE personnel to l procure conduit fittings such as elbows, couplings, etc., to prevent l an indeterminate amount of zine addition within the containment. l l The above mentioned deficiencies resulted from violations of the l l PSAR requirements and the accopted practice of procuring conouit l fittings with no quality ase,urance required. l VI. CORRECTIVE ACTION (To be provided by line organization.) l l

3 .g TVA EMPLOYEE CONCERNS REPORT NUMBER: C019203-SQN SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 5 0F 5 VII. GENERIC APPLICABILITY Die cast zine materials may be present and should be controlled at WBN lR1 and BLN and included in the appropriate calculations package for the percent hydrogen build-up inside containment. This concern is not generic t0 BFN since the containment atmosphere is nitrogen and no boric acid spray system is utilized during a design basis event. VIII. ATTACHMENTS Attachment A Listing of concerns indicating Safety Relationship l and Generic Applicability lR1

-r v- - =. ,3 4 ^ ~ eo/9203-sod-K I Tib$$$YY ~~ , IN 374-002 CO 19200 N HBN NYYY HS APPROX. 500 ERICKSON CONNECTORSIF'ITT T50015 REPORT INGS FOR CONDUIT HAD BEEN INSTALLED AND DISCOVERED TO BE ALUMINUM AND NO T MAGNETIC. THESE-ARE IN PROCESS OF BEING REMOVED SINCE ERICKSON CONNECT ORS ARE NOT REQUISITIONED OUT TO THE CRAFT,HOW CAN THEY BE IDENTIFIED AH D REMOVED HITH CONFIDENCE THAT ALL H AVE BEEN REPLACEDT HBNP 82. I t 1) O g i4 e i e e

,_.y. s: : '~ ' hj k, j_ g g-e,< e . 2: L ECTC C 3 8! V .h' Attachment A Ut . "w Pagd 1 of l' Revision 2 - A i-ECSP Corrective f, Action Tracking Document (CATD) Iv { .l i INITIATION Applicable ECSP Report NO: ,1. Immediate Corrective Action Required: O Tes M No 2. Stop Work Recoemended: 0 Yes R No 3. CATD No. C01920.9.5/4/- / 4. INITIATION DATE 9 /z. t_. ls h 5. RESPONSIBLE ORGANIZATION: $&1/iOa-rr vr r,inse,,,n ' ~ 6.. PROBLEM DESCRIPTION: K QR O NQR nasu nn Acan_x re, w v e b r> m< MF'Llf,HT M P -r AL4 ,/1kstt_i. ant M N A kl Y n t 9_ - t_A MT E 114 t* r n r4 nu l'f" M M n t P_ C) ARE P <fAM L t < W E n A hl h

Mot u nEn tM"rHE APPR n DmAQ nE< law' RAM < 2A trut ATi n hl FBR HYnnart p u AutLn MP I ki 41 hF rMNTAtk.th4EU T:

O ATTACHilENTS 7. PREPARED BY: NAME _/fAF A h _ a i DATE: 9 fz.2 A fr L. _. 8. CONCURRENCE: CEG-il J{/R fr 9. APPROVAL: ECTG Py@ffAM MGR. ~ 'Atr1r'u~rf DATE: _M15J14 DATE: CORRECTIVE ACTION 10. PROPOSED CORRECTIV'E ACTION PLAN: 0 e i f O ATTACilHENTS 11. PROPOSED BY: DIRECIOR/MGR: DATE: 12. GNCURRENCE: CEG-il:, s.* DATE: SRP: DATE: i DATE: DATE: DATE: ECTG PROURAM HGR: DATE: VERIFICATION AND CI.0SE00T i 13. Approved corrective actions have been verified as satisfactorily implemented. ~ -t SIGNATURE TITLE DATE %8 e 'a g g a

y ECTG C.3 Attachment A Pagd 1 of 1 (..., ! 'I Revision 2 - A lf ECSP Corrective j. Action Trackinr, Document ~ l (CATD) W { i1 i INITIATION k Appilcable ECSP Report NO: 1. Immediate Corrective Action Requirid: 0 Yes M' No 2. Stop Work Recommended: O Yes E No 3. CATD lio, eolez os -sew-m 4. INITIATION DATE 9 /sz /s 5. RESPONSIBLE ORGANIZATION: m "#Lif s'. ref-s iv e. et n ul ro h 6. PROBLEM DESCRIPTION: B QR O NQR R F VtT E

d. r. M - A 4D f rd Pn u 2.9 "fD M CTAR LiMH z o w -r san t a s-F # As e MA r1L f41 AL_S 1 N s t n G-doWT And tMEMT

/n u r t u n inn NaviricA f tok *fo VHE edE M id At AM ALV f ts cuAiusuntwo-men xo u si tt von it p n Am op -r a e n e< sa y 19A 4 t T Z AL CM L ATt DM 'Fn R HVnnAAEM 19 M I L n - M P ) O ATTACilllENTS 7. PREPARED BY: NAME M%Pl#4 DATE: 9/sr lv L - a 8. CONCURRENCE: CEG-il 14/ f% h d DATE: #z37/4 9. APPROVAL: ECTG OffAM ' GR. ' M DATE: . CORRECTIVE ACTION I 10. PROPOSED CORRECTIVE ACTION PLAN: e O ATTACllMENTS 11. PROPOSED BY: DIRECTOR /MGR: DATE: ? 12. CONCURRENCE: CEG-il ; s-DATE: SRP: DATE: DATE: DATE: DATE: ECIG PROGRAM MGR: DATE: VERIFICATION AND CLOSEOUT i 13. Approved corrective actions have been verlfled as satisfactorily Implemented. SIGNATURE IIILE DATE

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.t ECTG C.3-Attachment A ( Page 1 of 1 Revision 2 - A 4 f .i ECSP Corrective Action Trackinr. Document l (CATD) j h j ',i INITIATION } Applicable ECSP Report NO: ' 1. Imediate Corrective Action Required: 0 Yes,)( No 2. Stop Work. Recommended: 0 Yes A( No 3. CATD No. e o lo z o thro w - 9 4. INITIATION DATE o fz 1 bc 5. RESPONSIBLE ORGANIZATION: n n / m m !e n F 'U d. lei., cia.nTM Df Rat YpN 6. PROBLEM DESCRIPTION: )( QR O NQR + . T At4 ti A9 E P rahrM ste_ MEkt-v" u riLt&F rVA g r* Er e FleAT te)( s w et R i A i r, ernst e-> w nu i i- /mi we enx-e n t% w u u nt a >$ li r>si l MATOn F Ef1R14 A nt Y 2 IGAl F/> 52 ' IL L i j Awn A centssa n a x dpMnuty M l.".; O ATTACHNENTS ~ 7. PREPARED BY: NAME M y 9 ff ftf *. DATE:,,2 fre le/o 8. CONCURRENCE: CEG-MV g h DATE: __ f/z-ip /44 9. APPROVAL: ECTG RAM MGR. ' DATE: CORRECTIVE ACTION 10. PROPOSED CORRECTIVE ACTION PLAN: !j .P.

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, ii, e 1 .t-i i O ATTACllMENTS 11. PROPOSED BY: DIRECTOR /MGR: DATE: { 12. CONCURRENCE: CEG-il:, s.- DATE: SRP; DATE: DATE: DATE: DATE: ECIG PROGRAM MGR: DATE: VERIFICATION AND CLOSE00T i 13. Approved corrective actions have been verified as satisfactorily implemented. SIGNATURE TITLE DATE

- ~ - TVA EMPLOYEE CONCERNS REPORT NUMBER: C017303-SQN SPECIAL PROGRAM REPORT TYPE: Sequoyah Nuclear Plant Element REVISION NUMBER: 1 TITLE: Instrument Line Clamps PAGE 1 0F 5 REASON FOR REVISION: Incorporat6 TAS and ERP comments. I' PREPARATION PREPARED BY: l W 'ItK* }Q-2 -8(o s SIGNATURE DATE 2EVIEWS PEER: $ kY~ ' M //7 - o 2.. B C. SIGNATURE DATE TAS: SIGNATURE DATE CONCURRENCES. CEG-H: / lQ l$#0}~$h S SIGNATURE DATE SIGNATURE DATE APPROVED BY: i ECSP MANAGER DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY) 1437T i

TVA EMPLOYEE CONCERNS REPORT NUMBER: C017303-SQN SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 2 0F 5 I. Introduction The concerns evaluated are related to instrumsnt line clamps which were improperly installed (IN-85-016-003) and substituted (EX-85-047-001). These concerns were evaluated at Watts Bar Nuclear Plant (WBN) and determined to be potentially generic to SQN during the WBN evaluation. II. Summary of Perceived Problems ~ Instrument line clamps were either improperly installed and/or damaged [ during or after installation. Some instrument line clamps are l altogether missing. Unacceptable clamp substitutions were made in local lR1 instrument panel applications. l. III. Evaluation Methodology A. Reviewed Significant Condition Report, SCR SQNCEB8612, to determine if it is applicable to the areas of concern. B. Reviewed the preliminary findings of the Bolt Torque Survey and interviewed the responsible Division of Nuclear Engineering (DNE) coordinator to determine if the work adequately addresses the areas of concern. C. Reviewed Special Maintenance Instruction, SMI-0-317-25 RO, " Inspection and Corrective Maintenance of Small Diameter Instrument and Sensing Lines," and interviewed the responsible mechanical maintenance coordinator to determine if work adequately addressed the areas of concern. D. Reviewed Construction Specification N2C-946, " Requirements for Tightening of Non-High Strength Bcits in Friction-Type Connections," to determine if this specification was adequate and addressed the areas of concern. E. Reviewed Modification and Additions Instruction, M&AI 09, " Inspection of Bolted Connections," to determine if future work would adequately address the areas of concern. IV. Summary of Findings A. Significant Condition Report, SCR SQNCEB8612, identified a potential problem related to bolt tightening instructions. Sequoyah Construction Procedures; SQN Inspection Instruction No.~1, " Inspection of Bolted Connections," dated August 8, 1973, and SQN Inspection Instruction No. 66, and " Inspection of Supports," dated January 7, 1977, both gave tightening instructions for hangers,

TVA EMPLOYEE CONCERNS REPORT NUMBER: C017303-SQN SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 3 0F 5 IV. Summary of Findings (Continued) supports, and miscellaneous steel which w'ere' vague; i.e., "show no slack and handtight." The lack of specific tightening instructions could cause non-high strength bolt connections to be unqualified. B. In response to SCR SQNCh88612, DNE onsite coordinated a sample l program which reviewed the bolt torque on a number of installed l supports. This program specifically identified that forty-nine l percent of the 302 clamps sampled were loose (i.e., undertorqued). l l Over fifty-three percent of the A83 instrument line clamps sampled lR1 l were found loose. In addition, this sample program inadvertently l l identified an unspecified number of missing clamps (especially-l l instrument line clamps). When these missing clamps were identified, I a work request was issued to correct the discrepancy. l C. Special Maintenance Instruction, SMI-0-317-25 RO, was initiated on .l March 27, 1986 to walkdown all accessible unit 1 and 2 instrument lR1 lines. Ihis included all instrument sensing lines, sampling lines, and radiation monitoring lines, as well as,- any associated drain lines. The work instructions and acceptance criteria were as follows: 1. Check supports for any loose (i.e., without slack and as a minimum, handtight) bolting or missing clamps. 2. Install new clamps, bolts, nuts, spring nut, and etc., when determined to be missing. Tighten all such items found to be loose. 3. Inspect maintenance work performed. 4. Document all work performed. According to the responsible coordinator, the scope of this SMI l includes verification that the appropriate size clamp was used on IR1 the instrument lines. Local instrument panel applications were also. l included within the scope of this SMI. l The responsible coordinator estimated that this SMI was approximately lR1 95-percent complete outside containment and only just begun inside containment, when terminated. The reason for termination was knowledge of the changing torque requirements, as defined in Construction Specification N2C-946,.for bolted connections in supports for piping and tubing. Therefore, either a new SMI or a revision to the existing SMI will be initiated to incorporate the new torque requirements.

TVA EMPLOYEE CONCERNS REPORT NUMBER: C017303-SQN SPECIAL PROGRAM LL'ISION NUMBER: 1 6 4 3 4 0F 5 IV. Summary of Findings (Continued) D. Construction Specification N2C-946, dated' June 25, 1986, defines the requirements for reinspection and correction of certain friction-type bolted connections using non-high strength bolts in supports for piping and tubing. This specification applies to unistrut-type clamps supporting safety-related piping and tubing. Safety-related covers systems under the Appendix B, QA program including category 1(L) seismic supports. The construction or installation restart requirements are as follows: 1. Tightening or reinspection of clamps on tubing is not required before restart of the units. This work shall be complete for unit 2 and common supports before the return to service from the unit 2, cycle 4 outage and for unit 1 and common supports before the return to service from the unit 1 cycle 5 outage. 2. Before plant restart, all unistrut-type clamps on critical supports, on all piping systems required for safe shutdown, shall be inspected and corrected. 3. At the discretion of the Sequoyah Power Plant Superintendent (Maintenance), the inspection and ccreection of all clamps in some plant areas or all of a certain type clamp may be lR1 implemented before restart. The construction quality control for unistrut-type clamps assures that unistrut-type clamps shall be inspected in accordance with note 60 on drawings 47A050-18 and-18A. Clamps which require corrections shall be-reinstalled in accordance with note 58 on drawing 47A050-17. E. Modification and Additions Instruction, M&AI 09, was revised on June 26, 1986 to incorporate the change in design requirements mentioned in Construction Specification N2C-946. M&AI 09 governs the installation and inspection on all future bolted connections and adequately addresses the areas of concern. Conclusion Based on the sample program and the documentation from the Special Maintenance Instruction, SMI-0-317-25, R0, the concerns are substantiated. However, both the ongoing Special Maintenance Instruction, (SMI-0-317-25 R1 or similar instruction) and the Modification and Addition Instruction, M&AI 09, will ensure that all the instrument line clamps ace adequately installed and inspected. lR1

x. TVA EMPLOYEE CONCERNS REPORT NUMBER: C017303-SQN SPECIAL PROGRAN REVISION NUMBER: 1 PAGE 5 0F 5 The schedule for the construction or installation restart requirements, I per Construction Specification N2C-946, has only been partially l justified..DNE onsite has justified (by piping analysis) the use of IR1 loose instrument line clamps, but no justification exists for.the I altogether missing instrument line clamps. Therefore, the schedule for i the restart requirements has not been totally justified. l V. Root Cause The root cause of these employee concerns (IN-85-016-003 and l EX-85-047-001) is a combination of inadequate installation / inspection lR1 procedures and changing design requibements. l l VI. Corrective Actions To be provided by line management. lR1 VII. Generic Applicability These employee concerns are potentially generic'to all TVA nuclear. lR1 facilities. l VIII. Attachments Attachment A Listing of concerns indicating Safety Relationship l and Generic Applicability lR1 l

-- -g ,7, l'o/7303-sod-R 1 A-rrae.iimat-r-A EX 047-001 CD 17300 N HBN YYYY NS UNIT I, ELEVATION 676, 3/4" PIPE CLA T50162 REPORT MPS HAVE BEEN USED IN PLACE OF THE R EQUIRED 1/2" PIPE CLAMPS, IN INSRUME NT PANEL APPLICATIONS. CI HAD BEEN TOLD BY OTHER PERSONNEL THAT THIS TY PE OF-SUBSTITUTION HAD BEEN DONE THR OUGHOUT THE PLANT. CONSTRUCTION DEP T CONCERN. CI HAS NO FURTHER INFORM ATION. OLLOHUP REQUIRED. IN 016-003 CO 173bbHHBN YYYY I-85-165-HBH SS TUBING NOT CE MPED' PROPERLY. THIS I ~ T50030 REPORT S A SITEHIDE CONDITION. TUBE 3/8" O S.S. INSTRUMENT LINES. UNIT 1. CLA MPS ARE BENT, CROOKED, TIGHT OR LOOSE. CONDITION HAS NOTICED ABOUT A YEA R A00. l s e e h e e

m _v ',4 - i,g .p 7 . pg i s s ECTG C.3 Attachment A ^ Page 1 of 1 Revision 2 - A 'i ECSP Corrective I Action Tracking Document A l (CATD) w 'y j y INITIATION 'I Applicable ECSP Report NO: 1. Immediate Corrective Action Required: Yes O No 2. Stop llock Recommended: O Yes g No 3. CATD No. 40 /9]fv_sf-SPA /- / 4. INITIATION DATE 9-2-4-84 5. RESPONSIBLE ORGANIZATION: S##voyA>/ A4 A -- S/74-B>R M70A 6. PROBLEM DESCRIPTION:.W QR O NQJt Id5TROMGHT tide CA AMPb WERG' EiTlW12-IMPPc PEPul 145TAttEb. DAMAGED 3 7106 cR AFTFit. t 45 tat L ArtOd ; AUTOCEToEV-MWSWV1. Cil W ACCGPTABW SO65TITOTEb. T M scE cote fcR. WC coE9FcTion op THe5F TMCitE PMICIES. Et Ocastromna Specir< Arion H2C-94b. uAs ouw eeeg DAeTsAus Ssimen.~bME On StTE uAs mTi Ae6 nw itE of t.neM iuSTro rggT UM Ct AMP 5. Bur 40 7)STt RCATION EKbTS fcA Ttie Att0C,Etutit. M6sn16 IOSTf usteNT ude' ct AMN.Demte.oc scueoaE' Ett RESTAltT n AS Hot BEEN 'T9TA LW 'N TTw RO. O ATTACHHENTS 7. PREPARED BY: NAME _ fl M. C LEMNER._.. DATE: 9 74 PJo 8. CONCURRENCE: CEG-IL. --/At# % '4/+-rW DATE: 9-2.4 -#4 9. APPROVAL: ECTG IQLM MGR. " DATE: CORRECTIVE ACTION 10. PROPOSED CORRECTIVE ACTION PLAN: e O ATTACHMENTS 11. PROPOSED BY: DIRECTOR /MGR: DATE: 12. CONCURRENCE: CEG-lis, i.- DATE: SRP: DATE: DATE: DATE: DATE: ECTG PROGRAM MGR: DATE: VERIFICATION AND CLOSEQUT i 13. Approved corrective actions have been verlfled as satisfactorily implemented. SIGNATURE TITLE DATE

TVA EMPLOYEE CONCERNS REPORT NUMBER: CC11203-SQN SPECIAL PROGRAM REPORT TYPE: Sequoyah Nuclear Plant Element REVISION NUMBER: 2 TITLE: Poor Planning and Coordination As Related PAGE 1 0F 3 To Construction REASON FOR REVISION: To incorporate Technical Assistance Staff coments Revision 1 To incorporat,e SRP coments Revision 2 PREPARATION PREPARED BY: /O ~ i~ hh SIGNATURE # # DATE REVIEWS PEER: [h // - 9 86 ps a SIGNAT4RE DATE TAS: SIGNATURE DATE CONCURRENCES II //-0V"$N CEG-H WA - ir SIGNATURE DATE SIGNATURE

DATE APPROVED BY:

ECSP MANAGER DATE ~ MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)

SRP Secretary's si6 nature denotes SRP concurrences are in files.

1297T

-. - _ _ _ _ - _ =. TVA EMPLOYER CONCERNS REPORT NUMBER: Coll 2O3-SQN o SPECIAL PROGRAN REVISION NUMBER: 2 i PAGE 2 0F 3 L SUPPLEMENT FOR SEQUOYAH NUCLEAR PLANT (SQN) I. Introduction This report addresses one concern (MAS-86-003) dealing with the adequacy of work being done.by construction concerning fuse identi,fication workplans. II. Summary of Perceived Problem The concerned individual apparently felt no action was being taken to resolve the fuse discrepancies noted between the design drawing and the installed configuration, as stated in workplan number 10512. III. Evaluation Methodology f A. Discussed this concern with knowledgeable electrical maintenance personnel to determine the extent and specifics of the concern. B. Reviewed Workplan Number 10512 to determine the content of the plan and the areas covered. IV. Summary of Findings A. The discussions with electrical maintenance personnel revealed this was a concern received under the "old" Employee Concern Program and a resolution had been discussed with the concerned individual. j This resolution would involve the Office of Engineering Design, the l Inspector General, the Office of Construction Engineering, and an assistant unit operator. The design engineer will authorize any I changes in fuse size and nanufacture type and Field Change Requests i (FCRs) will be submitted to correct any drawing discrepancies. Drawings will be marked up showing the correct configuration prior j to workplan closure. This discussion also revealed that the I concerned individual agreed that these corrective steps should f resolve any problems that exist, and would also satisfy any concerns he may have. B. A review of Workplan Number 10512 revealed the work was to install j nameplates or similar means of unique identifiers to all control i fuses. Identification will consist of a unique identifier, 1 manufactures code and fuse rating. i h i t -,~..______-_,,.-...._,..y.,__,-_._..

I IVA EMPLOYEE CONCERNS REPORT NUMBER: C011203-SQN SPECIAL PROGRAN REVISION NUMBER: 2 PAGE 3 0F 3 Supplement for Sequoyah Nuclear Plant (SQN) Conclusion Discussion of this concern with knowledgeable engineers indicated this concern was factual. However, the problem has now been resolved to the satisfaction of the concerned individual and will fulfill the requirements of work instructions. V. Root Cause A failure to follow work instructions by keeping as constructed drawings up-to-date. VI. Corrective Actions l lR1 Corrective actions to be supplied by the line organization. I VII. Generic Applicability None VIII. Attachments Attachment A - Listing of Concerns Indicating Safety Relationship and l Generic Applicability. lR2 i

r-l 20//203-30H-R.2 A-rracement1-A MAS-86-003 CD 11200 11 SQti il il Y ti liS ADEQUACYOkWORKBEIllGD0llEBYCONST REPORT RUCTION C0tiCERflING FUSE INDEllTIFICAT 10ti HORK PLANS s IIJ t

ECTG C.3 Attachment A l Page 1 of 1 Revision 2 ECSP Corrective Action Tracking Document (CATD) INITIATION Appilcable ECSP Report No: 1. Irenediate Corrective Action Required: O Yes do 2. Stop Work Recommended: O Yes /No 3. CATD No. //2O3 - Sd//-o/ 4. INITIATION DATE /O-8-86 5. RESPONSIBLE ORGANIZATION: J'irr

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PROBLEM DESCRIPTION: O QR W9QR 7 %ere a/e re. d/'scre m w h s .br lAssed lbe de s ioW n lr A ul/ N O S Add /d /d3 lle fnMficarA//oW n A fle Suses 'bvx 7~A //e el b n/ Wor l 2/4 W A,nbAe /M/2. 7. PREPARED BY: NAME ha 8 *g%4.. O ATTACHMENTS /> / DATE: /O-8-B6 8. CONCURRENCE: CEG-H /d 7 ' 'J/4$sW DATE: 10 / 4 9. APPROVAL: ECTG P RAM IfGR.' DATE: CORRECTIVE ACTION 10. PROPOSED CORRECTIVE ACTION PLAN: 7M'e de.5/ae/ eNo/a/cer ////// Aa/Jer/2e Aks! L'A4 m es /N fu.s e S /2 C b>d /MNdukel Ore, bfPt And fif fd CAJeaa. Te eues/s >>;// da sahxNhd Jo . deree/ Asv dr' nssino '/nen laveles. DrAufmds u/>// b e. . Marka ) u's rAnim'a JAe t'errech now/%arldiod Drier- +o wsefsh./ eAsurd. .i O ATTACHMENTS 11. PROPOSED BY: DIRECTOR /MGR: DATE: 12. CONCURRENCE: CEG-H: DATE: SRP: DATE: DATE: DATE: DATE: ECTG PROGRAM MGR: DATE: VERIFICATION AND CLOSEOUT 13. Approved corrective actions have been verified as satisfactorily Irnplemented. SIGNATURE TITLE DATE

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l TVA EMPLOYEE CONCERNS REPORT NUMBER: C017101-SQN SPECIAL PROGRAM REPORT TYPE: Sequoyah Nuclear Plant Element REVISION NUMBER: 2 (Final Report) TITLE: Valves PAGE 1 OF 10 REASON FOR REVISION: Incorporate the evaluation of SQN concern IN-85-055-N04 into this report. I Revision 1 Finalize Report Revision 2 PREPARATION PREPARED BY: N' Y /0 b l26 M_._. ' [/' SIGNATURE / DATE REVIEWS PEER: />rk' f kh jo 86 SIGNATURE DATE TAS : u (J /#-T'F id o ..s .s /Ok / '.IIGNATURE / /DATE CONCURRENCES lYVf$b CEG-H: SR w /d 26 SIGNATURE DATE SIGNATURE

DATE A

APPROVED / f n V TCSP MANAGER \\ 1)ATl MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)

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

1258T

TVA EMPLOYEE CONCERNS REPORT NUMBER: C017101 SPECIAL PROGRAM -SQN REVISION NUMBER: 2 PAGE 2 0F 10 I. Introduction Two concerns were addressed by this evaluation. One concern was identified at Bellefonte Nuclear Plant (BLN) relative to the proper storage, orientation, and maintenance of Limitorque valves. This BLN concern was IX-85-094-007. Initial review of this concern indicated it was potentially generic to all TVA nuclear sites. The other concern, IN-85-055-N04, was identified by NRC following their review of the QTC files. It related that an " Emergency hand valve" was incorrectly installed. This evaluation will address concerns XX-85-094-007 and IN-85-055-N04 at Sequoyah Nuclear Plant (SQN). II. Summary of Perceived Problems A. The stated areas of concern were Limitorque valves at BLN were not stored nor installed in the correct attitude, nor were they maintained properly. The potential exists for the valves to have been installed in the wrong orientation, not being maintained, and spares not being stored properly at SQN. B. An emergency hand valve was incorrectly installed at SQN. III. Evaluation Methodology A. Concern XX-85-094-007 1. The employee concerns files and other files, including expurgated QTC files, were reviewed for more detailed information, reports, and/or recommendations. 2. The Watts Bar Nuclear Plant (WBN) Valve Element Report C017101 of Enployee Concerns Task Group (ECTG) Subcategory C017100 (Mechanical) was reviewed to determine if evaluation results were applicable to SQN. 3. Limitorque Vendor Manual 826695 1603 and Limitorque vendor correspondence between WBN, SQN, and vendor were reviewed to determine vendor requirements for valve operator storage, Installation orientation, and preventative maintenance. l 4. Applicable operations maintenance instructions and/or l procedures were reviewed to determine the types of maintenance, inspections, and documentation that was required on Limitorque l valves, and if the SQN requirements satisfied the vendor's recommendations. The documents reviewed were:

r-TVA RMPLOYRE CONCERNS REPORT NUMBERS C017101 SPECIAL PROGRAM -SQN REVISION NUMBER: 2 ) I PAGE 3 0F 10 l i a. Administrative Instruction AI-36. R9; " Storage, Handling, j and Shipping of QA Material." i b. Maintenance Instruction MI-10.46, R3; "Limitorque, Motor Operator / Control Valve." Maintenance Instruction MI-11.2A, R1; "Limitorque Operators c. Corrective Maintenance Procedure for SB-00, SMB-000, and SMB-00 Actuators." d. MI-11.2B, R1; "Limitorque Operators Corrective Maintenance Procedure for SMB-0 thru SMB-4, and SB-0 thru SB-4 Actuators." e. SQM-62. R2; "10 CFR 50.49 Program: Qualification Maintenance Data Sheets (QMDS) Implementation Environmental Qualification Deviation Report and Category II Upgrade Control." f. SMI-0-317-16. R2; "Special Maintenance Instruction; Field Verification of Limitorque Electric Motor Operated Data." g. SMI-0-317-19. R2; "Limitorque Motor Operator / Control Valve." h. Surveillance Instructions SI-166 R10; " Summary cf Valve Tssts for ASME Osction II Units 1 and 2." i. Surveillance Instructions SI-166.6, R21; " Post naintenance Testing of Category "A" and "B" Valves Unit 1 and 2." j. Technical Instruction TI-69 R10; " Summary of Pre-and Post-Maintenance Valve Tests for ASME Section II and 10 CFR 50 Appendix J, Units 1 and 2, R10." k. SQN Standard Practice SQA-122, R0; "non-CSSC Equipment Performance Assurance Program." 1. Administrative Instruction AI-19 (part II), R17; " Plant Modifications After Licensing." m. SQN Standard Practice SQM-1, R5; "Sequoyah Nuclear Plant Maintenance Program." n. Standard Practice SQM-2, R18; " Maintenance Managemer,t System." 5. a. Cognizant engineers in the SQN Mechanical Maintenance Unit - ONP were interviewed to determine the qualifications of the craftsman performing maintenance and to discuss maintenance of Limitorque valves in general.

TVA EMPLOYEE CONCERNS REPORT NUMBER: C017101 SPECIAL PROGRAN -SQN REVISION NUMBER: 2 j PAGE 4 0F 10 b. Cognizant engineers in the SQN Nechanical Test Unit - ONP were interviewed relative to Limitorque maintenance. l c.- Cognizant engineer in the SQN mechanical QA/QC organizstion was interviewed relative to Limitorque maintenance. 6. The cognizant engineer that performed one of two previous evaluations of this Limitorque concern at SQN was interviewed for additional information. 7. The SQN Generic Concerns Task Force employee concern XX-85-094-007 report and the associated case file information were reviewed for concurrence with evaluation and conclusion. B. Concern IN-85-055-N04 1. The expurgated QTC file, IN-85-055, was reviewed for additional relevant information. 2. The SQN Compliance Licensing Supervisor was interviewed for information to support additional pertinent statements found in the expurgated file. 3. Experienced SQN Reactor Operators were interviewed for supporting information. The WBN Assistant Operations Suparvisor end a wBN Reactor Operator were also interviewed for additional information. 4. WBN OSLA-27 R18; Operations Section Letter, AUO Work Stations; was reviewed for documentation. IV. Summary of Findings A. Concern IX-85-094-007 l 1. The files provided no information other than was already stated in the concern, and no additional reports or recommendations other than was indicated below. 2. The WBN Valve Element Report C017100 of ECTG contained the evaluation of Limitorque storage, installation, and maintenance at WBN. WBN has both construction and operations type programs, due to the status of the plant. This required that both organizations' procedures and programs be evaluated for I meeting requirements with regard to Limitorque valve operators. SQN was an operating plant that allowed the evaluation to address the specific issue of valve operator installation orientation and then address the issues of storage and maintenance from ONP procedures and program perspective.

TVA EMPI4TER CONCERNS REPORT NUMBER: C017101 ~ SPECIAL PROGRAM -SQN REVISION NUMBER: 2 PAGE 5 0F 10 The WBN Valve Element Report C017100 of ECTG quoted DNE's position on Limitorque valve operator orientation as, "It has always been an EN DES policy to position the valve as recommended. However, due to space limitation and many other variables, it is not.always possible to meet the recommendations." TVA has not written instructions to prohibit this, since Limitorque Engineering has stated that the operator can function in any orientation. A preferred operator orientation was specified by the vendor to minimize grease / oil leakage into the limit switch and motor compartments from the gearbox. Specific preventative maintenance activities were specified for all Limitorque operators. The WBN ONP Limitorque Preventive Maintenance Program was evaluated and found deficient in the following areas: 1) the meggering of CSSC operator motors was not being performed according to the QMDS requirements and 2) non-CSSC operators were not being exercised according to vendor and DNE recommendations. These deficiencies and reported requirements were addressed at SQN for applicability. The WBN Element Valve Report of ECTG identified the Limitorque valve operator concern as potentially Reneric to all pro.jects. 3. The Limitorque Vendor Manual and associated correspondence resulted in requirements for orientation, storage, and maintenance as follows: a. Orientation - Whenever possible, the actuator should be installed with the motor horizontal and the limit switch compartment vertical-up or horizontal to prevent a head of grease against the motor or switch seals. However, other installation orientations do not disqualify the actuator. Limitorque engineering stated that the operator can function in any orientation. b. Storage - Limitorque Vendor Manual listed several items as storage recommendations. These storage items included: 1. Store crated units under shelter. 2. Store motors on horizontal plane. 3. Connect space heaters if unit is to be stored in a damp place before installation. j 4. Do not attempt to lift the valve assembly by lifting lugs secured on the motor operator.

TVA EMPLOYEE CONCERNS REPORT NUMBER 8 C017101 SPECIAL PROGRAN -SQN REVISION NUMBER: 2 PAGE 6 0F 10 c. Maintenance . Specific preventative maintenance activities were specified for all Limitorque operators on a routine basis. The maintenance items included: 1. Remove limit switch compartment and/or control cover. Should moisture be evident, dry the compartment and components. 2. Inspect and clean all electrical controls and contacts in the limit switch compartment and/or control cabinet. 3. Check all terminal connections for tightness. 4. Clean gasketed surfaces on limit switch compartment and/or control cabinet cover. Replace all damaged gaskets or seals for weatherproof or submersible units. 5. Inspect lubricant according to lubricant procedure. Visually check shaft penetrations for indications of seal leakage. 6. Megger the motor. 7. Exercise the valves on a periodic basis. 4. The review of the maintenance procedures identified a series of instructions and procedures that met all the vendor requirements for Limitorque valve operator storage and maintenance that will keep the actuators in good working condition. AI-36 defines the storage requirements and recommended practices for safety-related material and equipment (CSSC) in order to ensure that the quality of items was not degraded as a result of improper storage. The requirements of this instruction applied to the Power Stores Unit - ONP. The instruction gave general requirements for all equipment storage and had specific storage instructions, paragraph S.11.27, for Limitorque valve operators. These stortre requirements were l equal to those of the vendor. Procedure MI-10.46 contained a data package with explicit instructions, inspections, and verifications incorporating the l manufacturer's requirements for valve operators maintenance in j various installed orientations. Technical Instruction TI-69 and Surveillance Instruction SI-166 and SI-166.6 gave the i requirements for cycling the valves. The maintenance of the Limitorque valves are documented. Site Procedure SQM-62 provides the instructions for implementation of the l Qualifications Maintenance Data Sheets (QMDS) requirements. i

TVA EMPLOYEE CONCERNS REPORT NUMBER: C017101 SPECIAL PROGRAN -SQN REVISION NUMBER: 2 PAGE 7 0F 10 5. Cognizant engineers of the SQN Nechanical Maintenance Unit stated that craftsmen have to go through an ONP training program, MNT-16, before being allowed to perform maintenance on Limitorque valves. The formal training course is very thorough and deals with specifics of Limiterque valve maintenance. The Nechanical Maintenance Unit keeps a matrix listing of those craftsmen that are qualified. The valves are maintained the same with respect to non-CSSC or CSSC valves. The only i variance is the interval, and this has been determined by a case-by-case engineering evaluation of the valve that has established the interval. In addition to the storage and maintenance programs in place, program standard practice SQM-64 has been drafted and was out for site review at the time of evaluation. This will be a SQN comprehensive safety-related Motor Operator Valve (NOV) Program for visual inspection, lubrication, and testing. The standard practice SQM-64 guidelines were expected to be in place before the restart of the unit 2, cycle 3 outage. The cognizant QA engineer interviewed by the ECTG evaluator was very satisfied with the present Limitorque valve maintenance program. SQN has many Limitorque valves installed in various orientations. 6. The cognizant SQN evaluator was knowledgeable of the problem and explained his evaluation and conclusions. He had actually observed a maintenance activity for a Limitorque valve. In i addition, his sample of the maintenance records for Limitorque valves confirmed that the required items were checked on non-CSSC, as well as CSSC valves. 7. The SQN Generic Concern Task Force Employee Concern Report was accurate with regard to their conclusions that: l a. There is a preferred orientation of Limitorque valve i operators, but it is acceptable for the valve operator to { be installed / mounted in any position. 1 b. SQN has an effective maintenance program in use that properly implements the supplier's requirements and will i ) have a program to ensure equipment qualification. The report was thorough in their evaluation and its documentation. ..,-.-,---.--,,m,_._m.. ---wm, -,_,_my- ,_yv_ ,-.r- ,,,-c--.,,,,----

TVA IMPIAYEI CONCERNS REPORT NUMBER: C017101 i SPECIAL PROGRAN -SQN REVISION NUMBER: 2 PAGE 8 0F 10 B. Concern IN-85-055-N04 4 1. A review of expurgated file IN-85-055 revealed the following: tha. Concerned Individual (CI) was told by a fitter that an " emergency hand valve" was installed under a grating at SQN, such that it couldn't be manually operated. The CI went on to say, "They done this at Sequoyah and they got fined. I think it was $50,000.00 for doing that". He added that the problem was identified at SQN as noted above and probably corrected. The CI stated the fitter then showed him where the same questionable valve installation had occurred at WBN. No other valve description or location information was given. 2. The SQN Compliance licensing supervisor stated that no fine as 4 described in (1) had been issued against SQN. 3. A conversation with two experienced SQN Reactor Operators-revealed that no " emergency hand valve" existed at SQN as described by the CI. Conversations with both the WBN Assistant Operations Supervisor and a WBN Reactor Operator revealed the same was true at WBN. The Assistant Operations Supervisor also stated that Operations Section Letter; OSLA-27. AUO Work Stations; specifies responsibilities of Assistant Unit Operators during routine equipment / system inspections. He stated that the inspections are conducted during every shift and the inspection checklists incorporate a space for " equipment not accessible". The supervisor went on to say that any deficiencies such as the one specified by the CI would have been corrected under this instruction if not earlier.' 4. A review of OSLA-27. R28, proved the statements of the WBN Assistant Operations Supervisor to be correct. The Checklist or Routine Log for each " Routine" provides blanks for each shift to list " Equipment which is not accessible". Also, note (1) of the Instructions portion of OSLA-27 stated "Any problems discovered will be noted in the remarks section of the... AUO Routine Sheet, reported on an MR, and to the Unit Operator. f Conclusions I i A. Concern II-85-094-007 The Limitorque valve operators do have a preferred orientation. I However, the equipment operation / qualification was not compromised by the installation position. Therefore, it was acceptable for the valve operators to be installed / mounted in any position. SQN has Limitorque valves mounted in all positions. l 9---- -,w-,wewege-am,n--~.w--,-,.,,.-.7 -%c-p,-

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TVA EMPLOYEE CONCERNS REPORT NUMBER: C017101 SPECIAL PROGRAN -SQN REVISION NUMBER: 2 PAGE 9 0F 10 SQN has an effective storage and maintenance program in use that properly implements the manufacturer's requirements. The procedures, instructions, and trained craftsmen combined to maintain the actuators in good working condition, regardless of the mounting position or other adverse conditions. B. Concern IN-85-055-N04 Based on a review of expurgated file IN-85-055, conversations with both the SQN Compliance Licensing Supervisor and two SQN Reactor Operators, and interviews with both the WBN Assistant Operations Supervisor and a WBN Reactor Operator; the concern citing " Emergency hand valve incorrectly installed" was found to be not factual. Contrary to a relevant statement the CI made during his interview with QTC, no fine was ever levied against SQN for the cited reason or anything similar. The cognizant personnel interviewed at both SQN and WBN stated that no valve installation as described exists at those sites. V. Root Cause a. None b. None VI. Corrective Action A. No Corrective Action Required l lR2 B. No Corrective Action Required l VII. Generic Applicability A. Concern 11-85-094-007 The concern was evaluated to be potentially generically applicable to WBN, SQN, BFN, AND BLN as a result of the VEN ECTO ovaluation. The WBN ECTG evaluation of concern at SQN has not altered that determination. BLN and BFN use Limitorque Valves, and the question needs to be addressed at these plants to confirm whether the problem exists or not. l

TVA EMPI4YEE CONCERNS REPORT NUMBER: C017101 SPECIAL PROGRAM -SQN REVISION NUMBER: 2 PAGE 10 0F 10 B. Concern IN-85-055-N04 None, since the concern was found not factual. VIII. Attachments Attachment A Listing of concerns indicating Safety Relationship I and Generic Applicability lR2 1 kY i 9

00/7/0/- Soni-R 2 ~ nrremar-n XX 094-007 CD 17100 N BLN YYYY I-85-595-BLN NS BELLEFONTE: LIMITORQUE VALVES NERE S TORED AND INSTALLED HITH HRONG ALTIT T50150 REPORT UDE (UPSIDE DOHN) AND HERE NOT MAINT AINED (STROKED, ETC). CONSTRUCTION DEPT. CONCERN. CI HAS NO FURTHER INF ORMATION. NO FOLLOW UP REQUIRED- ..... ~ IN 055-N04 CO 17100NShN NNNN NS NRC IDENTIFIED THE FOLLONING CONCERN K-FORM FROM REVIEW OF QTC FILE. "EMER0 ENC Y HAND VALVE INCORRECTLY INSTALLED." D t 0 D b a f 4 V n.

TVA EMPLOYEE CONCERNS REPORT NUMBER: C015109-SQN SPECIAL PROGRAN REPORT TYPE: Sequoyah Nuclear Plant Element REVISION NUMBER: 1 (Final Report) TITLE: Instrumentation Tubing Instruments As PAGE 1 0F 3 To Construction REASON FOR REVISION: To Incorporate Technical Assistance Staff Conunents and to Finalize Report PREPARATION PREPARED BY l0 ~l'$$ SIGNATUR7 # DATE REVIEWS PEER: Msl [k /0"2 - N SIGNATURE DATE TAS:J ek) ^'* f

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ECSP MANAGER \\ j)AT E MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)

SRP Secretary's signature denotes SPR concurrences are in flies.

1295T

TVA EMPLOYER CONCERNS REPORT NUMBER:C015109-SQN SPECIAL PROGRAN REVISION NUNBER: 1 PAGE 2 0F 3 1 I. Introduction This report addresses three concerns (IN-80-200-006, IN-85-119-002, IN-85-618-004) that related to damaged instrumentation tubing. II. Summary of Perceived Problem Instrumentation Tubing line damage may be occurring during construction. lR1 III. Evaluation Methodology A. Reviewed WBN ECTG Element Report Instrumentation Tubing / Instruments (C015109) for applicability to SQN. B. Interviewed cognizant SQN Instrumentation Maintenance Unit personnel about damage to tubing and/or about programs to prevent this damage. C. A walkdown of Auxiliary Building elevations 669, 690, and 734 instrument lines was performed to assess the condition of the lines. D. Reviewed Standard Practice SQMZ, Maintenance Management System. Revision 18, to identify pertinent procedural requirements. IV. Summary of Findings i A. The review of WBN ECTG Element Report, Instrumentation Tubing / Instruments (C015109), revealed that Division of Nuclear Construction (NU CON) had initiated programs to limit instrument line damage, but the Division of Nuclear Power (DNP) at WBN did not l have a program that addressed this issue. The need for a program to lR1 communicate to employees the need to eliminate instrument l line damage was what made these concerns generic to SQN. B. The interviews with knowledgeable SQN Instrumentation Maintenance Unit personnel revealed that instrument line damage was not a problem. These discussions also revealed that there was not a specific training program in place to address instrument line damage. C. Walkdown tours were made on elevations 669, 690, and 734 of the Auxiliary Building observing approximately 800 instrument tubes. None of the instrument tubes observed showed any damage. D. The review of Standard Practice SQMZ, Maintenance Management System. Revision 18, revealed that any plant personnel may report the need for plant corrective maintenance or repair work. This may be done by filling out a Maintenance Request (MR) form.

TVA IMPLOYEE CONCERNS REPORT NUMBER:C015109-SQN SPECIAL PROGRAN REVISION NUMBER: 1 PAGE 3 0F 3 Conclusion The observations of instrument lines at SQN did not reveal a problem l with instrument line damage nor did the interviews reveal a problem. l There was not a specific training program in place at SQN to prevent lR1 damage to instrument lines and a need for such a program was not l necessary at this time. l V. Root Cause No problem exists at SQN; therefore, there was no root cause. VI. Corrective Actions No corrective action required. VII. Generic Applicability None VIII. Attachments lR1 i Attachment A - Listing of concerns indicating Safety l Relat!onship and Generic Applicability lR1 i l .. ~

e 00/5/09-SM-R 1 f&d WWYY ~~ IN 200-006 CO 15100 N HBN YYYY NS COPPER AND STAINLESS INSTRUMENTATION ~ T50130 REPORT TUBING IS UNPROTECTED. TUBING SPAN $ BETWEEN HANGERS ARE BENT. OCCURS THROUGHOUT UNITS 1 AND 2. CONST. DE PT. CONCERN. CI HAS NO ADDITIONAL I NIFORMATION. NO FOLLOH UP REQUIRED. [ IN 119-002 CO 15100 N HBN YYYY 'NS' INSTRUMENTITION Li ES" DAMAGED, BENT, ~ ( T50065 REPORT FLATTENED AND TOUCHING. THEY ARE L OCATED IN ELECTRICAL RACEWAY IN THE REACTOR BUILDING AT EL. 702 UNIT 1. C/I STATED "JUST WALK THROUGH THE POWER BLOCK AND YOU CAN SEE ALL TYPE S OF DAMAGED INST. TUBING". IN 418-004 CO 15100 N HBN YYYN I-85-212-NBN HS INSTRUMENT TUBING, UNIT 2. ACCUMULAT T50059 REPORT OR 84 AREA, IS BEING SEVERELY DAMAGE D BY CRAFT PERSONNEL AS THE RESULT 0 F SUBSEQUENT CONTRUCTION ACTIVITIES. SOME FORM OF TUBING PROTECTION SHO l'LD BE PROVIDED. l l l l i J t s f O N ,_._________-__________.___-_____h_____---____-.-

TVA EMPLOYEE CONCERNS REPORT NUMBER: C015105-SQN SPECIAL PROGRAN REPORT TYPE: Sequoyah Nuclear Plant Element REVISION NUMBER: 2 (Final Report) TITLE: Flex Hose Connections PAGE 1 0F 3 REASON FOR REVISION: Revised To Incorporate SRP Comuments Revision 1 Revised to incorporete NRC Corunents and Finalize Report Revision 2 PREPARATION PREPARED BY: Jo 86 zw-[ SIGNATGRp// DATE REVIEWS PEER: /rtYb kh /0-3-8G SIGNATURE DATE TAS: /0 Y Ad ~ SIGNATURE / 4 ATE CONCURRENCES CEG- /# -+ ~8[ $w /O 8b SIGNATURE DATE SIGNATUREA DATE APPROVED if b IIM l@ U ECD RANAGER t'ATI( NANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)

SRP Secretary's Signature denotes SRP Concurrences are in flies 1296T

TVA EMPLOYEE CONCEENS REPORT NUMBER: C015105-8QN SPECIAL PROGRAN REVISION NUMBER: 2 PAGE 2 OF 3 I. Introduction i One concern IN-85-449-001 was evaluated that addressed the need for training of employees with regard to protection of flex hose. II. Summary of Perceived Problems Personnel may need training on the protection of flex hose l connections. IR1 l l III. Evaluation Methodology A. Cognizant Instrumentation Maintenance Unit personnel were interviewed about damage to flex hose and about programs to prevent damage. B. A walkdown of Auxiliary Building elevations 669, 690, and 734 was performed looking at flex hose and flex hose connections for damage. C. Standard Practice SQMZ, Maintenance Management System, Revision 18 was reviewed. D. Reviewed Maintenance Requests (MR's) dealing with damaged flex hose. lR2 IV. Summary of Findings A. The interviews with knowledgeable SQN Instrumentation Maintenance Unit personnel revealed no problem, with damaged flex hose, existed at this time. The interviews also revealed that there was not a formal training program in place for the prevention of damage to flex hose. B. During the walkdown of the Auxiliary Building, approximately 150 flex hoses were observed--none of which was found to be damaged or in need of repair. C. The review of Standard Practice SQMZ, Maintenance Management System. Revision 18, revealed that any plant personnel may report the need for plant corrective maintenance or repair work. Anyone noticing any damage or other degradation may fill out a Maintenance Request (MR). D. The review of MRs did not reveal a problem with damage to flex hose. lR2 Conclusion During plant tours, damage to fler hose was not observed and discussions with maintenance personnel did not reveal damage to flex hose to be a problem. SQN did not have a formal training session to address flex hose damage, nor could the need for one be seen at this time.

TVA EMPLOYER CONCIENS REPORT NUMBERS C015105-SQN SPECIAL PROGRAN REVISION NUMBER: 2 PAGE 3 0F 3 V. Root Cause There was no problem with damage; therefore, no root cause exists. VI. Corrective Action No Corrective Action Required lR2 VII. Generic Applicability None VIII. Attachments Attachment A - Listing of Concerns indicating safety Relation and l Generic Applicability. lR2

80/5/05-Sod-7C 2 L Arrneumahr-A IN 449-001 CO 15100 N H5N YYYY gj ' LL CRAFTS 8 ENG. PER. SHOULD BE TRA T50034 REPORT INED ON THE PROTECTION OF FLEX HOSE CONNECTIONS. AFTER INSTRUMENTATION FITTERS INSTALL AND INSPECTION BY-OF F, OTHER PER50NNEL HALK, CLIMB 4 DIS FIGURE THE ASSY. THIS AFFECTS THE A BILITY THE FLEX,TO OPERATE AS REQUIR ED PER DESIGN. EXAMPLE SYS 963 ELE. 717' 4' E OF ALL 108 5 0F W IT IS P OSSIBLE THAT REPAIRS HAVE BEEN MADE BUT NOT VERIFIED. h 9 6 ) 6 6 0 9 e 0

l TVA EMPLOYEE CONCERNS REPORT NUMBER: C015102-SQN SPECIAL PROGRAM ) REPORT TYPE: Sequoyah Nuclear Plant Element REVISION NUMBER: 2 (Final Report) TITLE: Electrical Penetrations PAGE 1 OF 3 REASON FOR REVISION: Revised to Incorporate TAS and SRP Comments. Revision 1 Finalize Report Revision 2 PREPARATION PREPARED BY: /0~$~$6 SIGNATUltE/# DATE REVIEWS PEER: svY$ f /O&eV= SIGNATURE DATE l TAS:) eld /0-f *$'6 /0 k l n SIGNATURE / / BATE l CONCURRENCES ll~ 0$~8 N { CEG-S ld& N SIGNATURE DATE SIGNATURE' DATE i APPROVED B

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TLCSP MANAGER l }ATl MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)

SRP Secretary's signature denotes SRP concurrences are in flies.

1299T

TVA IMPIAYEE CONCERMS REPORT NURBEtt C015102-SQN SPECIAL PROGRAM 4* REVISION NUMBER: 2 PAGE 2 0F 3 I. Introduction This report addresses one concern (IN-85-346-002) which was determined to be potentially generic to Sequoyah (SQN) at the "K" Form level and was subsequently evaluated by the TVA SQN Generic Concern Task Force (GCTF). II. Summary of Perceived Problem The electrical penetrations entering the Reactor Building are not strong enough and have been damaged because of being walked on. III. Evaluation Methodology A. Reviewed WBN Element Report Electrical Penetrations (C015102), to obtain information applicable to SQN. B. Reviewed the SQN GCTF Report, " Electrical Penetrations to Containment," for informstion applicable to evaluation and -determine adequacy of findings and conclusions. IV. Summary of Findings A. Review of the WBN Element Report C015102 indicated the sheetmetal covers were damaged at WBN during the construction phase. This damage was being identified and corrected through the process of transfer to the Office of Nuclear Power (ONP) control. The review also revealed that, even though the sheetmetal covers were damaged, the electrical penetrations themselves were not damaged. The covers were vendor supplied, and new covers would require another seismic analysis; therefore, revising the covers design was not as practical as repairing the existing covers. B. Review of the SQN GCTF report revealed the SQN compliance section had performed a review of potential reportable occurrences from 1984 to early 1986. Their review showed no cases of electrical penetration damage. The GCTF report revealed that the SQN penetrations were purchased from Westinghouse Electrical Corporation on contract 72C61-75146 while the WBN electricc1 penetrations were purchased from Conar Corporation on contract 76K61-87064. Interviews with responsible personnel indicated that Westinghouse supplied electrical penetration junction boxes at SQN were of a stronger design than those used at WBN.

TVA EMPIAYEE CONCERNS REP 0tf NUMBER: C015102-SQN SPECIAL PROGRAN REVISION NUMBER: 2 PAGE 3 0F 3 Conclusion The damage to electrical penetrations covers was a construction related problem at WBN and is not a problem at SQN. i V. Root Cause No problem exists at Sequoyah Nuclear Plant; therefore, there was no root cause. VI. Corrective Actions No problem exists. No corrective Action Required. lR2 VII. Generic Applicability None VIII. Attachments Listing of Cc=cerne Indiccting Cafety Eslationship and IR1 att uh..., a* Generic Applicability l 4 4 f i

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TVA EMPLOYEE CONCERNS REPORT NUMBER: C015101-SQN / SPECIAL PROGRAN REPORT TYPE: Sequoyah Nuclear Plant Element REVISION NUMBER: 2 (Final Report) TITLE: Floor Drains PAGE 10F 4 REASON FOR REVISION: Revised To Incorporate TAS And SRP Comuments Revision 1 Revised To Incorporate NRC Comuments and Finalize Report Revision 2 PREP *** TION PREPARED BY: /d-7~ AS [ SIGNATtIRE/d DATE REVIEWS PEER: YA Y $ Yh fo 9 & SIGNAttfRE DATE TAS:jd">/M*Fk lO Y SIGNATURE / DATE CONCURRENCE 3 CEG d WW* N"/f'$b usa.$'LOS l0 ' 9' h SR SIGNATURE DATE SIGNATURE

DATE APPROVED BY'

~ ~ b b ECS) tiNAGER InTE' ' NANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)

SRP Secretary's stEnature denotes SRP concurrences are in flies.

1290T

TVA ENPLOYEE CONCERNS REPORT NUMBER: C015101-SQN / SPECIAL PROGRAM l REVISION NUMBER: 2 PAGE 2 0F 4 I. Introduction This report addresses one issue determined to be potentially generic to SQN by the Watts Bar Nuclear Plant (WBN) evaluation. The issue was identified during the evaluation of concern IN-86-158-005, although not specifically part of the perceived problem, as stated by the concerned individual. II. Summary of Perceived Problem The evaluation of concern IN-86-158-005, related to floor dealns at WBN, revealed that level transmitters were damaged during construction. It was determined that an evaluation at SQN was needed to determine the type of level transmitters used and the potential for damage because of personnel access to the area. III. Evaluation Methodology A. Reviewed WBN Element Report Floor Drains (C015101) to determine applicability to SQN. B. Reviewed the Nuclear Safety Review Staff (NSRS) Report I-85-509-WBN to determine applicability to SQN. C. Interviewed knowledgeabic inctru=cntation maintenance personnel on the subject of level transmitters to determine if damage to subject level transmitters has resulted from personnel having access to the area. IV. Summary of Findings A. The review of WBN Element Report Floor Drains (C015101) revealed the problem stated in the concern to be the result of failure of the level transmitters in the pocket sump to alarm. Subsequent Investigation revealed the transmitters to be damaged by personnel working in the area. This report showed these level transmitters were scheduled to be replaced by a different type less susceptible to damage. There was no other relevant information obtained from the WBN ECTG element report. 5 f

TVA EMPLOYEE CONCERNS REPORT NUMBER C015101-SQN SPECIAL PROGRAN REVISION NUMBER: 2 PAGE 3 0F 4 IV. Summary of Findings (Continued) B. The review of NSRS Report I-85-509-WBN for WBN concern IN-86-158-005 revealed that the problem stated by the concern centered around the damage to the pocket sump level transmitters. This report also stated that new ultrasonic level transmitters were being ordered to replace the damaged units at WBN. C. The interviews with knowledgeable SQN instrumentation maintenance l personnel revealed numerous malfunctions of the present level l transmitters at SQN, although none of these were related to i damage. The present level transmitters are not readily available for replacement and spare parts are no longer manufactured. A design change request (DCR) number SQ-DCR-P-2242, was initiated on l December 12, 1985, to replace existing level transmitters l LT-77-125, 126, 410 and 411 with Delta Controls Corporation type l 851 ultrasonic level transmitters considered to be more reliable. Failure of the level transmitters will only allow water to backup in the sumps and no nuclear safety equipment would be compromised. These same transmitters have also been ordered for the WBN replacements. D. A interview with knowledgeable SQN instrumentation maintenance engineering personnel on October 3, 1986 revealed a letter had been written the week of September 22, 1986 to the Change Control Board. This letter asked that DCR Number SQ-DCR-P-2242 be approved for the next plant cutagc. Tha timing of this outagw all depomis or. the restart time for SQN. Conclusion Damage to level transmitters at SQN due to personnel damage was not a problem but other problems with these transmitters has warranted their replacement. The type transmitters being installed are identical to those being used at WBN and will decrease the potential for any future damage due to personnel in the area. V. Root Cause There was no problem with damage; therefore, no root cause exists. VI. Corrective Action No Corrective Action Required for concern issue. lR2 The side issue raised during this evaluation was with the level transmitters in the pocket sumps and these level transmitters will be replaced during the next outage Dy DCR Wumber SQ-DCR-P-2242.

TVA EMPLOYEE CONCERNS REPORT NUMBER 8 C015101-SQN SPECIAL PROGRAN REVISION NUMBER: 2 PAGE 4 0F 4 VII. Generic Applicability None Note: This concern was made generic to Sequoyah by Watts Bar Element Report Floor Drains (C015101) because of the similarity of plant design and not generic to other plants because of differences in plant design. VIII. Attachments Attachment A - Listing of Concerns Indicating Safety Relationship and Generic Appilcability d 9 l i 9 _m- -e__.____ r .._-..__-y-

l'Ol5/01-Sotf- & L ~fVA6NNl(YY ~~ 33 158-005 CO 15100 N HBN NNYN I-85-509-H5N NS ON THE REACTOR BUILDINO FLOOR, THERE 750129 REPORT ARE CONDUITS THAT ARE NOT PLUGOED, YET THERE IS ALWAYS HATER. BACKED UP DN THIS FLOOR. CONSTRUCTION CONCERN CI HAS NO ADDITIONAL INFORMATION. e b e O f 11 e b s' e

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TVA iNPLOYEE CONCERNS REPORT NUMBER: C011302 SPECIAL PROGRAN -SQN REPORT TYPE: Sequoyah Nuclear Plant Element REVISION NUMBER: 1 (Final Report) TITLE: Design Of Anchors As Related To Construction PAGE 1 0F 4 REASON FOR REVISION: Finalize Report Revision 1 i PREPARATION PREPARED B - ml. nNa [ [ [ SIGNA ' DlTE REVIEWS PEER: mk[h /0-8~84 SIdNATURE DATE TAS:j M '#+ 4 M Ys S ~ SIGNATURE / )6 ATE CONCURRENCES CEG-M'#I~ lb' $~ S S m SIGNATURE DATE SIGNATURE

DATE APPROVED BY:

Iti w D l N / ECST MIN'AGElf DATit ~ NANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)

SRP Secretary's signature denotes SRP concurrences are files.

1428T

l TVA EMPLOYEE CONCERNS REPORT NUMBER: C011302 SPECIAL PROGRAN -SQN REVISION NUMBER: 1 PAGE 2 0F 4 I. Introduction This report addresses the element of anchor design as expressed in employee concerns PH-85-002-009 and IN-86-200-003. II. Summary of Perceived Problem The use of redhead type concrete anchors is unsuitable at TVA nuclear sites. III. Evaluation Methodology A. Reviewed NSRS investigation report I-85-440-WBN on the subject concern to determine applicability to SQN, B. Reviewed Sequoyah Nuclear Plant (SQN) Generic Concerns Task Force (GCTF) report to determine the methodology employed and the conclusions reached with respect to anchor design suitability. C. Reviewed Watts Bar Nuclear Plant (WBN) Employee Concerns Task Group (ECTG) Element Report (C011302) on the subject concern to determine the parameters of the evaluation methodology, the conclusions reached, and its applicability to SQN. Also, determined if the findings of this evaluation were in agreement with the findings of the reports in sections A and B. VI. Summary of Findings A. The NSRS Investigation Report I-85-440-WBN addressed a concern at WBN (IN-86-200-003) which also questioned the " suitability" of redhead type concrete anchors. This report referenced TVA General Construction Specification G-32 requirements for anchor qualification at each nuclear plant site. Random proof loading of anchors, test result evaluations, and anchor installation inspections were reviewed as well as site Quality Control Procedures (QCPs) to ensure that the upper-tier criteria of G-32 had been fully implemented. The conclusion of this report was that no existing evidence of redhead type concrete anchor inadequacy could be verified, and the concern was determined to be unsubstantiated.

i TVA IMPIAYER CONCERNS REPORT NUNBER: C011302 SPECIAL PROGRAN -SQN REVISION NUMBER: 1 PAGE 3 0F 4 VI. Summary of Findings (Continued) B. The SQN-GCTF report did not address directly the subject of anchor design or redhead type anchor suitability for nuclear plant use. However, the report proved the suitability and adequacy of redhead type concrete anchors by referencing the sampling program done in response to NRC IE Bulletin 79-02. The positive results of this sampling program supported the adequacy of the TVA Anchor Program. In addition, failure rates of less than 2 percent were noted during in-process production tests where TVA General Construction Specification G-32 acceptance criteria was employed. The report concluded by referencing historical information (i.e., construction pull test data, 79-02 responses and sampling program results) as additional supportive evidence to the adequacy of Sequoyah's i concrete anchor program. C. The WBN-ECTG element report addressed the unsuitability of redhead type concrete anchors by evaluating the same criteria reviewed in the NSRS report I-85-440-WBN. Specifically, the adequacy of TVA General Construction Specification G-32 was emphasized with respect to the qualification requirements of redhead type concrete anchors at each plant site. This report also referenced nuclear industry experience, and NRC allowed practices to further support the suitability of redhead type anchors. Conclusion l l Three independent reviews have been performed, the findings / conclusions of each being basically the same with respect to redhead type concrete anchor suitability in nuclear plant applications. Therefore, this evaluation concludes that the concerns, as stated by the concerned individuals, are not valid. V. Root Cause No root cause is assigned since the concerns were determined to be not valid. VI. Corrective Action No corrective Action Required lR1

1 TVA ERPIAYEE CONCERNS REPORT NUMBER: C011302 SPECIAL PROGRAN -SQN REVISION NUMBER: 1 PAGE 4 0F 4 VII. Generic Applicability None VIII. Attachments IR1 Attachment A - Listing of Concerns Indicating Safety l Relationship and Generic Applicability lR1 / l l l

f l -90//302 - So, nf- )(1 ~ / e fib $$$$YY ~ PH 002-009 CO 11300 N H5N YYYY HS C/I IS CONCERNED ABOUT THE USAGE OF 750165 REPORT PHILIIPS REDHEAD ANCHOR BOLTS FOR AT TACHING ITEMS TO CONCRETE, DUE TO RE DHEADS HAVING BEEN DECLARED UNSUITAB LE FOR USE AND REPLACED AT A NUMBER 0F OTHER NON-TVA NUCLEAR SITES. CONS T. DEPT. CONCERN. C/I HAS NO FURTHE R INFORMATION. IN 200-003 CD 11300 N HBN YYYY I-85-440-HBH NS THE USE OF " RED HEADS" FOR SUPPORT I S NOT SAFE IN THAT THE CONCRETE COUL T50130 REPORT D BE HONEYCOMBED AROUND THE " RED HEA D". CONST. DEPT. CONCERN. CI HAS N O ADDITIONAL INFORMATION. NO FOLLOW UP REQUIRED. O / '\\ 5 e 1*'. h9 s' s e

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l TVA EMPIAYEE CONCERNS REPORT NUMBER: C011207-SQN SPECIAL PROGRAN REPORT TYPE: Sequoyah Nuclear Plant Element REVISION NUMBER: 1 1 TITLE: Improper Installation as Related to PAGE 1 0F 2 Construction REASON FOR REVISION: Revised to incorporate SRP comments and finalize report. Revision 1 PREPARATION PREPARED BT: JD $$ , ~ SIGNATUR7 // DATE REVIEWS PEER: YmN f* gh /'-2-84 SIGNAItJRE DATE TAS: Y$ h l96 ~ SIGNATURE / /DATE f CONCURRENCES I i l0~l'$b CEG- /0 14 m DATE SIGNATURE DATE y SIGNATURE j f APPf0VED IIh hAIDYN MI6% " "EChP EARAGER \\ ' l'ATij ' HANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLT)

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

1484T

TVA EEPIAYEE CONCERES REPORT Enann: C011207-SQN SPECIAL PROGRAE REVISION EUEBER: 1 PAGE 2 0F 2 b SUPPLINENT FOR SEQUDYAR NUCLEAR PLANT (SqE) d I. Introduction This report addresses one concern II-85-101-002 that' states: " Improper installation of non-nuclear system could adversely affect public health and safety." J I II. Summary of Perceived Problems il ~ The concerned individual felt that the improper installation of the non-nuclear system could adversely affect public health and safety. lR1 III. Evaluation Nethodology l Reviewed expurgated files and other available files to gain additional information regarding this concern. This concern was very vague and [ needed additional definition for a meaningful evaluation. l IV. Sunmary of Findings e f Review of ECTG files at Watts Bar Nuclear Plant which included the QTC l expurgated files revealed no additional information to help-better i define this concern. The concern is relative to non-nuclear system. lR1 Therefore, improper installation of the system would not ncrually l constitute a safety-related problem. The evaluation of the other element reports of subcategory workplan/ work control did not reveal a problem with improper installation or work control. Conclusion This concern cannot be evaluated due to the broadness of scope and lack of definition of the concern. The other specific evaluations within this l l subcategory involving concerns about improper installation or work control IR1 i did not reveal a problem; therefore, no-further evaluation was necessary. l [ i V. Root Cause None VI. Corrective Actions None VII. Generic Applicability None VIII. Attachments Attachment A - Listing of Concerns Indicating Safety Relationship and Generic Applicability.

00//207-SQM-R i l Tib$$$$YY ~ XX 101-002 b0 11200 N SSN NYNN NS SEQUOYAH-IMPROPER INSTALLATI0r 0F N T50162 REPORT OH-NUCLEAR SYSTEM COULD ADVERSELY AF FECT PUBLIC HEALTH AND SAFETY, DETA ILS KNOWN TO QTC, HITHELD DUE TO CON FIDENTIALITY. CONSTRUCTION DEPT CON CERN. CI HAS NO FURTHER INFORMATION HD FOLLOHUP REQUIRED. 6 j JJ 6 9 i e t t f

J TVa RWPLOYEE CONCERNS REPORT NUMBER: C011202-SQN SPECIAL PROGRAN REPORT TYPE: Sequoyah Nuclear Plant Element REVISION NUMBER: 2 (Final Report) ~ TITLE: Craft Designed Hangers as Related to PAGE 1 0F 4 Construction REASON FOR REVISION: Revised to correct report number and to incorporate TAS and SRP comments. Revision 1 Revised to incorporate NRC Comments and Finalize Report. Revision 2 PREPARATION PREPARED BY: /0-J-86 m[ SIGNATURE / u DATE REVIEWS PEER: mY f. Y /0-0 3-8 G SIGNATURE DATE TAS:) W /#+ f4 /ph / 4 SIGNATURE ' DA'IE CONCURRENCES l0 WN CEG-H 1 S /d - T-Bf SIGNATURE DATE SIGNATURE DATE APPROVEDB:[ ~lTL 1m yc, lo E EC5P MANAGER DLTE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)

SRP Secretary's Signature denotes SRP Concurrences are in files.

1483T

TVA EMPWYER CONCERNS REPORT NUMBER: C011202-SQN SPECIAL PROGRAN REVISION NUMBER: 2 PAGE 2 0F 4 I. Introduction This report addresses two concerns that relate to the subject of craft designed hangers. Concern IN-86-261-002 was determined to be potentially generic to SQN by the Watts Bar Nuclear Plant (WBN) evaluation. Concern 11-85-120-006 was Sequoyah Specific. II. Summary of Perceived Problem i Hangers were being installed by craftsmen, and engineering would then i do the as-constructed drawings. The perceived problem was not about IR2 the Fabrication of hangers prior to installation which was I addressed in Construction Category Element Report C011102. l III. Evaluation Nethodology i A. Reviewed QTC expurgated files for the concerns this evaluation plan addressed for additional information. B. Interviewed knowledgeable personnel who were involved in installation of pipe supports to verify or disprove concerns about lR2 craft designed hangers and improper installation of hangers. C. Reviewed WBN ECTG Element Report C012002, of Subcategory C01200 - Work Control for information that may be applied to the SQN evaluation. D. Reviewed NSRS Reports I-86-194-SQN and I-85-925-SQN.to determine if they adequately addressed the perceived problem of craft designed hangers. j IV. Summary of Findings 1 A. No further information was found in the QTC expurgated files. i B. Interviews with knowledgeable personnel revealed that some hangers were installed at SQN prior to the issue of design drawings for lR2 4 these hangers. These hangers were installed with the anticipation l { of their becoming permanent with every design requirement being incorporated. These hangers could become permanent only after the ) as-constructed drawings had been submitted to Design, and analyzed i and issued. The hangers were then inspected against the drawings and if they met all the qualifications, they became permanent. The larger majority of these were typical hangers. 1 l 4 s'

TVA EMPLOYEE CONCERNS REPORT NUMBER: C011202-SQN SPECIAL PROGRAN REVISION NUMBER: 2 PAGE 3 0F 4 IV. Summary of Findings (continued) C. Review of the WBN ECTG Element Report, Craft Designed Hangers, (C012002) revealed that all current work was required to have a workplan, and this does not allow the practice of installing hangers without a drawing to occur. Sequoyah requires a workplan for all work, and installation of hangers without drawings should l not occur there either. This was~all the information obtained from lR2 the review of the WBN ECTG Element Report. l D. Review of NSRS Reports I-86-194-SQN and I-85-925-SQN revealed that hangers were installed prior to the issue of design drawing. This review also revealed there was no safety concern, since the procedures recognized that field changes were sometimes required and established a method of obtaining necessary engineerins approval and documentation. It was also revealed there was no evidence that the hangers were currently being installed without drawings or engineering control. The evaluator agrees with the findings of these two NSRS reports. lR2 Conclusion During the construction phase of SQN, some hangers were installed by craftsmen, and engineering would then as-construct the drawings. However, this was not a condition adverse to quality. 'The hanger inspections were always verified and documented to meet final design configuration. There was no evidence of this practice currently occurring, and with all work requiring a workplan, this should not occur in the future. V. Root Cause None VI. Corrective Actions No Corrective Action Required lR2 VII. Generic Applicability This evaluation did not change the generic applicability to Bellefonte Nuclear Plant as stated in the Watts Bar Subcategory Report C011200 for workplan/ work control.

TVA EMPIAYEE CONCERNS REPORT. NUMBER: C011202-SQN SPECIAL PROGRAN REVISION NUMBER: 2 PAGE 4 0F 4 VIII. Attachments Attachment A - Listing of Concerns indicating safety Relation and lR2 Generic Applicability. l 4 1

20/190p-Sod-R 2 \\ A-rraeumdr-A IN 261-002 CO 11200 N HBN NYhY NS DUE TO HCRK REQUIRED BY FCR'S/ECN'S T59230 REPORT NOT BEING PERFORMED PROMPTLY, THE CR AFT MANY TIMES ARE WORKING TO AN OBS DLETE DRAHING. AFTER REQUESTING INS PECTION FOR COMPLETED HORK, QC MAY I { NFORM CRAFT THAT COMPLETED HORK IS N OT ACCEPTABLE AS A PREVIOUS FCR/ECN l REQUIREMENT HAS INCORPORATED IN THE i DRANING, BUT THE WORK HAS NOT BEEN P ERFORMED. EXAMPLE: PANELS IN THE UN IT 2 RELAY ROOM. CONSTRUCTION DEPAR TMENT CONCERN. CI HAS NO ADDITIONAL INFORMATION. NO FOLLOH UP REQUIRED XX 120-006 CD 11200 N SQN NYYY I-86-194-SQN SS SEQUOYAH - HANGER CRENS HERE INSTRUC T50247 REPORT TED (SUPERVISOR KNOWN) TO GO AHEAD A ND BUILD HANGERS HITHOUT DRAHINGS, A ND ENGINEERING HOULD DRAW THE HANGER UP LATER. MANY OF THESE HANGERS HE RE SUBSEQUENTLY RCJECTED AND REHORKE D. CONSTRUCTION DEPARTMENT CONCERN. CI HAS NO FURTHER INFORMATION. I J t f h p._

s TVA EMPIAYEE CONCERNS REPORT NUMBER: C011102 SPECIAL PROGRAN - SQN REPORT TfPE: Sequoyah Nuclear Plant Element REVISION NUMBER: 2 (Final Report) TITLE: Design Output PAGE 1 0F 3 REASON FOR REVISION: Revised To Incorporate TAS and SRP Comments. Revision 1 Finalize Report Revision 2 PREPARATION PREPARED BY: m > lb 40-4u / O/9/8A SIGNATURE DAfE REVIEWS PEER: MY b fo.9-86 SIGBfdTURE DATE TAS: l0f7//$ SIGNATURE ' DATE CONCURRENCES /P -0$-/A CEG-H i SM R R. -n to+sc SIGNATURE DATE SIGNATURE

DATE APPROVED BY:

A lh lO b ECSP MA' NAGER ' \\ DhTI' NANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)

Secretary's signature denotes SRP concurrences are in files.

1436T

TVA EMPLOYEE CONCERNS REPORT NUMBER: C011102 SPECIAL PROGRAN -SQN REVISION NUMBER: 2 PAGE 2 0F 3 I. Introduction During the evaluation of employee concern WI-85-091-013 at Watts Bar Nuclear Plant (WBN) the 47A050 Hanger Drawing General Notes (050's) were found to contain some notes that were ambiguous, with respect to field fabrication of support components. The generic applicability of this ambiguity is addressed in this evaluation as it relates to SQN. II. Summary of Perceived Problems The perceived problem of this element is that the hanger drawing general notes at SQN were not clear with respect to field fabricating support components. III. Evaluation Methodology The evaluation methodology used for this element involved reviewing the current, as well as superseded 050's, to determine if any notes were ever applied at SQN that did not clearly define the requirements for field fabricated support components, if applicable. Also, discussions were held with individuals knowledgable of the fabrication practices during construction. IV. Summary of Findings The review of the 050 Notes did not reveal any notes addressing field fabrication of support components. Discussions with personnel involved with support fabrication during construction revealed that support components were not fabricated in the fleid. The ambiguity mentioned in the introduction of this report does not exist at SQN. Conclusion No condition adverse to quality exists with regard to the ambiguity of 050 Notes relative to field fabricated support components. V. Root Cause There is no problem and therefore no root cause.

TVA EMPIAYER CONCERNS REIORT NUMBER: C011102 SPECIAL PROGRAM -SQN REVISION NUMBER: 2 PAGE 3 0F 3 VI. Corrective Actions No Corrective Action Required lR2 VII. Generic Applicability The SQN evaluation determined the concern to be not generic to SQN. It lR2 had been deemed potentially generic by the WBN evaluation. l VIII. Attachments Attachment A: Listing of Concerns Indicating Safety Relationship lR2 and Generic Applicability l --...m

RO///02-SON-R 2-Arruumwr-A WI 091-015 CD 11100 N HBN NNYN HS TVA IS FABRICATING BERGEN PATTERSON TSO197 REPORT PARTS TO A BERGEN PATTERSON DRAHINGs ESPECIALLY PIPE CLAMPS. IT IS HOH DIFFICULT OR IMPOSSIBLE TO DETERMINE HHICH PIPE CLAMPS, AND OTHER PARTS, HERE MADE BY BERGEN PATTERSON OR FA ~ BRICATED BY TVA. CI HAS NO FURTHER INFORMATION. CONSTRUCTION DEPT. CON CERN. i. 11 9 = ).

TVA EMPIAYER CONCERNS REPORT NUMBER: C010505-SQN SPECIAL PROGRAM REPORT TYPE: Sequoyah Nuclear Plant Element REVISION NUMBER: 2 (Final Report) TITLE: Electrical Control Cabinets as Related PAGE 1 0F 4 to Construction REASON FOR REVISION: ) Revised to incorporate TAS and SRP comuments. Revision 1 Revised to incorporate NRC Revision 2 Comuments and Finalize Report PREPARATION PREPARED BY: /0-2-86 [ SIGNATU57/ DATE REVIEWS PEER: YmN S kh /O 8 G SIGNATURE DATE TAS:j oIJ /0-184 knIl$$1 m/vAV SIGNATURE //DATE CONCURRENCES lO " Y'lb CEG-H: i S /d-i- E SIGNATURE DATE SIGNATURE

DATE APPROVED BY:

/ h b K4 Ib '~ECSiP lliNAGER 11ATi t MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)

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

1304T

1 TVA EMPIAYER CONCERNS REPORT NUEBER: C010505-SQN SPECIAL PROGRAN REVISION NUMBER: 2 PAGE 2 0F 4 I. Introduction An evaluation of concern OW-85-007-010 was conducted. This concern.was associated with the contamination of control cabinets from a heavy buildup of dust and metal grindings. II. Summary of Perceived Problem The concerned individual apparently felt that the electrical control cabinets were contaminated by excessive dust and metal grindings, were not being properly protected nor cleaned, and the dust would adversely affect plant operation by causing contactors and other electrical components to blow out or become inoperative. III. Evaluation Nethodology l A. Reviewed WBN Element Report Electrical Control Cabinets (C010505), to l determine applicability to SQN. i B. Walkdown tours were performed in the Auxiliary, Turbine and Control l Buildings observing internal and external portions of electrical lR2 cabinets for dust and metal grindings. l C. Reviewed Standard Practice SQA66 Plant Housekeeping, Revision 9. D. Interviewed knowledgable electrical maintenance personnel, both lR2 craftsmen and engineers, in regard to dust and metal grindings i building up on or inside electrical control cabinets. IR2 i E. Reviewed the Maintenance Request (NR's) related to the repair of l electrical control cabinets to determine if dust and/or metal 1R2 grinding contamination had caused problems. l IV. Summary of Findings A. The review of WBN Element Report, Electrical Control Cabinets (C010505) revealed WBN did not have a problem at present with dust or metal grindings building up on or inside electrical cabinets. lR2 The generic application to SQN was in regard to the need for employee involvement in reporting deterioration and any lack of cleanliness conditions. B. A walkdown tour was made of electrical control cabinets in the Turbine, Auxiliary, and Control Buildings. Some dust was found on the outside of some of the cabinets. No metal grindings were t observed. No dust or metal grindings were observed inside the l cabinets. The amount of dust observed was minor and was not lR2 enough to be detrimental to cabinet functions. l i

TVA EMPLOYEE CONCERNS REPORT NUMBER: C010505-SQN SPECIAL PROGRAN REVISION NUMBER: 2 PAGE 3 0F 4 C. Review of Standard Practice SQA66, Plant Housekeeping, Revision 9, revealed in paragraphs 4.0.6 and 4.0.7 that plant operations personnel will clean the front of electrical distribution boards, control boards, I and control panels. In general, everyone engaged in a work activity is ] responsible for maintaining proper cleanlinese during the activity and j for cleanup following completion of the activity. Also, in paragraph 4.2, Sections E and F, this procedure states "special care shall be taken when opening or disassembling sensitive i electrical equipment which may be damaged by dust or moisture. Such work shall be performed in an area which has been cleaned of excess litter, dirt, and dust." " Barriers, screens, shields, restricted access, or other protection shall be.provided as necessary for isolation of areas where dust, inclement weather, or other conditions exist that may affect the quality of work being performed." The housekeeping checklist also has specific electrical check items such as "there is no accumulation of foreign materials around the exterior of electrical boards and panels." D. Interviews with knowledgeable electrical maintenance personnel revealed they do not feel dust and metal grindings on or inside lR2 the electrical control cabinets to be a problem. The interviews revealed the electrical maintenance personnel were very much aware of the need for cleanliness of these cabinets. E. Review of the Maintenace Requests (MR's) did not reveal any direct l evidence that dust or metal grindings in control cabinets having l caused a problem. However, the NR's are not written in such a l manner that would necessarily indicate what specifically lR2 necessitated the repairs. The NR review findings, coupled with the I i interviews and other evaluations indicated there has not been a l 1 { problem with dust and/or metal grindings contaminating the control l l cabinets at SQN. l Conclusion There is not a problem with dust and metal grindings contaminating the control cabinets at SQN. There are procedures in place at SQN to prevent this from becoming a problem. V. Root Cause i Not a problem at SQN; therefore, no root cause exists. VI. Corrective Action No Corrective Action Required lR2

TVA EMPIAYEE CONCERNS RRPORT NUMBER 8 C010505-SQN SPECIAL PROGRAN REVISION NUMBER: 2 e PAGE 4 0F 4 VII. Generic Applicability None VIII. Attachments l Attachment A - Listing of concerns indicating safety relationship and lR2 generic applicability. l l n- - n-.

f0/0$$$-$&k~ f [ Arrne.itmestr-A ON 007-010 CO 10500 N HBN YYYY NS ELECTRICALCONTR0[CABINETSHAVEBEE T50225 REPORT N CONTAMINATED BY CONSTRUCTION DIRT AND METAL GRINDINGS. THIS CONTAMINA TION ENTERED THE PANELS THROUGH THE COOLING VENTS ON THE TOPS OF THE PAN ELS. THIS IS A PLANT-HIDE PROBLEM, BECAUSE OF THE HEAVY BUILD-UPS OF DU 1 ST AND METAL PARTICLES THAT HAVE ALL ONED TO ACCUMULATE ON TOP OF EQUIPME NT. THIS COULD CAUSE THE CONTACTOR$ 1 OR OTHER COMPONENTS TO DETERIORATE AND BLOOUT OR BECOME INOPERATIVE. A SPECIFIC LOCATION GIVEN IS AUX. BLD O, 757' EL UNIT NOT KNOHN. CI H. ll ,e l ~~

TVA INPI4YIE CONCERNS REPORT NUMBER: C010504 SPECIAL PROGRAN SQN REPORT TYPE: Sequoyah Nuclear Plant Element REVISION NUMBER: 2 (Final Report) TITLE: Conduit as Related to Construction PAGE 1 0F 4 REASON FOR REVISION: Revised to incorpo~ rate SRP comunents. Revision 1 Finalize Report Revision 2 PREPARATION PREPARED BY: l$~ ?~hb im ~ SIGNATURE ~ [ // DATE REVIEWS PEER: Jy1 /0# ?-bl( SIGNATURE DATE TAS: ge(d 8 t-J' k /0 9' S SIGNATURE / AATE CONCURRENCES CEG-l/"Y'N SRP W lO ~ 9'El. SIGNATURE DATE SIGNATURE * ~ DATE APPROVED 1 ( l E ECSP MANAGER $ATl ; ' MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)

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

1301T

TVA EMPIAYEE CONCERNS REPORT NUMBER: C010504-SPECIAL PROGRAN SQN REVISION NUdBER: 2 PAGE 2 0F 4 I. Introduction Sequoyah concern 00-85-005-010 addressing the rusting of exposed threadr at conduit fittings in the Auxiliary Building was evaluated. II. Summary of Perceived Problem The concerned individual apparently felt that conduit thread rust was not being corrected and could affect the plant adversely. III. Evaluation Nethodology A. A walkdown of the conduit in the area of the Auxiliary Building that was stated in the concern, as well as other areas in the Auxiliary Building, was conducted to evaluate conduit for rust. I B. Discussions were held with knowledgeable electrical personnel from the maintenance and modification groups. These discussions were to determine if rust on conduit was a problem at SQN. C. Reviewed Standard Practice SQA66, Plant Housekeeping, Revision 9, to determine if the housekeeping tours would identify rust on conduit if it existed. D. Reviewed Standard Practice SQN2, Maintenance Management System, Revision 18, to determine if avenues were available to get corrections made when identified. E. Reviewed Nodifications and Additions Instruction, M&AI-6, Revision j 6, dated February 18, 1986, to determine what should be done to prohibit rust on conduit. IV. Summary of Findings A. The walkdown of the Auxiliary Building, elevations 669, 690, and 734, areas of the turbine and yard areas revealed only minor surface conduit thread and fitting rust which would require no corrective action. A great deal of outside and turbine area had i aluminum conduit, as well as some areas of the Auxiliary Building. I Aluminum conduit would not have the rusting problem. B. Galvanized conduit is used at SQN which prohibits rust but is not rust resistant. The discussion with electrical personnel from maintenance and modification groups did not reveal a problem with rust on any of the conduit. These discussions also revealed that i rust normally forms on the surfaces then seals off the oxygen flow and will slow dramatically unless there is constant moisture present.

TVA EMPIAYEE CONCERNS REPORT NUMBER: C010504-i SPECIAL PROGRAN SQN REVISION NUMBER: 2 PAGE 3 0F 4 i C. The review of Standard Practice SQA66, Plant Housekeeping, i Revision 9. revealed the housekeeping checklist contained items to assist the identification of rust on conduit. There is no indication of damage or deterioration of installed items due'to imprope'r housekeeping. Adequate protection from fire, weather, and movement of equipment has been provided. D. A review of Standard Practice SQN2, Maintenance Nanagement System. Revision 18 showed that any plant personnel may report the need for plant corrective maintenance or repair work by filling out a Naintenance Request (MR) form. This would include rusty condult. l E. A review of Nodification and Additions Instruction, N&AI-6, Revision 6 dated February 18, 1986, revealed in paragraph 3.2.4.2 that steel and INC conduit joints and connections shall be made i watertight and rustproof by means of application of a thread compound which will not insulate the joint. This shall be done on any conduit being installed by the modification unit. An example i of this compound was given as *Kopr-Shield. Paragraph 3.2.4.3, stated rigid aluminum conduit installed outdoors or in wet locations shall preferably be provided with aluminum fittings and supports. Galvanized fittings and supports may be used in special i cases. Care must be taken to prevent the contact of aluminum conduit with corrosive materials in places where moisture can I accumulate. j Conclusion l The concern for conduit rust at SQN was found to be only a minor problem with no corrective action required. There are effective programs in place at SQN to identify excessive conduit rust if it occurs and ways for anyone to get corrections made should they ever be needed. i IV. Root Cause None VI. Corrective Actions 1 No Corrective Action Required IR2 l-l / )

TVA IMPIhYEE CONCERNS REPORT NUMBER: C010504-SPECIAL PROGEAR SQN REVISION NUMBER: 2 PAGE 4 0F 4 VII. Generic Applicability None VIII. Attachments' lR2 Attachment A - Listing of concerns indicating Safoty l Relationship and Generic Applicability lR2

1 - ~ Com90+ - Sp+ R 2 Arrnaymesir-A 00 005-010 CO 10500 N SQN NYYY NS SEQUDYAHi EXPOSED THREADS ON ALL-THR T50224 REPORT EAD 3-4" DIAHETER' CONDUIT ARE RUSTIN G. THIS OCCURRED HHERE SHORT NIPPLE S OF ALL-THREAD CONDUIT JOIN FITTING S 12-30" BELON CEILING PENETRATIONS, AB0VE THE 710' ELEVATION, SOUTH PAR ~ T OF AUXILIARY BUILDING. CONDITION EXISTED AT LEAST UNTIL 1977, AND MAY STILL EXIST. CONST. DEPT. CONCERN. CI HAS NO FURTHER INFORMATION. NO FOLLOH UP REQUIRED. e 6 11 O e D 8 e 4 Y I N

TVA EMPLOYEE CONCERNS REPORT NUMBER: C010501-SQN SPECIAL PROGRAM .? REPORT TYPE: Sequoyah Nuclear Plant Element' REVISION NUMBER: 1 (Finel Report) TITLE: Caulking as Related to Construction PAGE 1 0F 3 REASON FOR REVISION: To incorporate Technical Assistance comments and finalize report. PREPARATION PREPARED BY: /8-8-80 [ SIGNATURF/ # DATE REVIEWS PEER: /71k$ k /0- 8-86 SIGNATURE DATE TAS: /0YS ~ SIGNATURE '/ DATE CONCURRENCES CEG-As l$ ~ 0$~$h Sfd R. M to+x SIGNATURE DATE p SIGNATURE

DATE APPROVED Y

[D l b ECfP MANAGER \\ JATi MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)

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

1303T

TVA EMPLOYER CONCERNS REPORT NUMBER: C010501-SQN SPECIAL PROGRAN REVISION NUMBER: 1 PAGE 2 0F 3 I. Introduction This report addresses one concern, IN-85-231-003, which was determined to be poter.tially generic to Sequoyah Nuclear Plant (SQN) by the Watts Bar Nucleet Plant (WBN) Employee Concerns Issk Group (ECTG) evaluation. lR1 II. Summary of Perceived Problem "In the Fifth Diesel Generator Building the caulking (Nova Caulk) in l the missile shields have turned loose and bubbled up." The evaluator i determined this to mean because this caulking was exposed to the IR1 elements, the temperature changes and moisture will cause the caulking l to separate from the concrete and become loose. l III. Evaluation Methodology A. Inspected the Fifth Diesel Building missile shields and caulking to determine current condition. B. Reviewed WBN ECTG Element Report, Caulking (C010501), to determine applicability to SQN. C. Reviewed TVA drawing 10W331-16 Revision 2 to determine what caulking was required at SQN. IV. Summary of Findings A. Inspection of the SQN Fifth Diesel Building revealed the top missile l shield to have two recesses approximately eight inches deep to l accommodate lLfting eyes. A review of TVA drawing 10W331-16 R2 l showed that eight inches of polysulfide caulking would fill the lR1 recesses, of the top shield only, to seal out water. Construction of l the SQN Fifth Diesel Building is not completed. Therefore the l lifting eye recesses do not have caulking in them at this time. l B. The review of WBN ECTG Element Report, Caulking (C010501), revealed l the concern was factual at WBN but was not safety-related. This l review also revealed that a Field Change Request (FCR) is to be lR1 initiated by WBN Hechanical Maintenance to modify the note on TVA l~ drawing 10W331-16 to eliminate the requirement to " fill the recess l with cault." f I

TVA EMPLOYEE CONCERNS REPORT NUMBER: C010501-SQN SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 3 0F 3 Conclusion Cault has not been placed in the SQN missile shield lifting eye recesses I at this time. IR1 V. Root Cause None lR1 VI. Corrective Actions No corrective action required. lR1 VII. Generic Applicability None VIII. Attachments Attachment A: Listing of Concerns Indicating Safety Relationship and lR1 Generic Applicability l l l

CO/050/-SOW-RI Armemrar-A IN 231-003 CO 10500 N HBN NNYN NS IN THE 5TH DIESEL GENERATOR BUILDING T50149 REPORT THE CAULKING (NOVA CAULK) IN THE M ISSILE SHIELDS HAVE TURNED LOOSE AND BUBBLED UP. THIS CAULKING MAS POUR ED LAST HINTER IN THE STH DIESEL GEN ERATOR BUILDING. CONSTRUCTION DEPAR TMENT CONCERN. C/I COULD HOT PROVID E ANY ADDITIONAL DETAILS / SPECIFICS. NO FOLLDH-UP REQUIRED. m i1 k e bd_ a

TVA EMPLOYEE CONCERNS REPORT NUMBER: C010107-SQN SPECIAL PROGRAM REPORT TYPE: Sequoyah Nuclear Plant Element REVISION NUMBER: 2 (Final Report) TITLE: Dry Active Waste Building Foundatica PAGE 1 0F 4 REASON FOR REVISION: TAS And SRP Comment Incorporation Revision 1 Finalize Report Revision 2 PREPARATION PREPARED Y: / / 0 - 0 7 " S 4" SIGNATURE / DATE REVIEWS PEER: mN[k /0-7-94 SIGRATURE DATE TAS:gcy so-f" e AJMMA1 d& \\ SIGNATURE / 4 ATE CONCURRENCES CEG-H: httk% e 3 h w W \\ D 'l~ % SRP: ld 8( SIGNATURE DATE p SIGNATURE

DATE APPROVED B k

I U 7 CEP MANAGER \\ NATf MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)

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

1270T

i i TVA EMPLOYEE CONCERNS REPORT NUMBER: C010107-SQN SPECIAL PROGRAN REVISION NUMBER: 2 PAGE 2 0F 4 I. Introduction The concern identified at Sequoyah Nuclear Plant (SQN) relative to the Dry Active Waste (DAW) Building foundation within the soils area was evaluated as a SQN site-specific concern. The evaluation addressed concern JAN-86-002. II. Summary of Perceived Problems The area of concern was that the SQN DAW Building foundation was being constructed on unsuitable backfill material, that could result in uneven settlement of the building. This was a SQN site-specific concern. III. Evaluation Nethodology A. Employee Concerns flies and other files, including QTC expurgated files, were reviewed for additional information and reports related to this concern. B. Cognizant engineers of the SQN Nodifications Unit were interviewed to determine the construction detafis of the DAW Euilding foundation, inspection methods used, and documentation available on backfill operation. C. Memorandum - Project Manager, Sequoyah Engineering Project to Design Services Manager, Sequoyah Nuclear Plant, dated February 3, 1986.

Subject:

SQN-Dry Active Waste Building - Inspection of Foundation Excavation (B25 860203 020) was reviewed to determine problems and outlined course of action by site. D. Drawing IMPELL CORP. C-01 was reviewed to determine foundation requirements. IV. Summary of Findings A. The Employee Concerns files and other files did not provide any additional information reports or recommendations pertaining to the concern. 4 -., _, ~ _

TVA EMPLOYEE CONCERNS REPORT NUMBER: C010107-SQN SPECIAL PROGRAM REVISION NUMBER: 2 7 PAGE 3 0F 4 B. The area that the DAW Building was to be built on had been previously built up, using waste backfill material, during the early stages of the plant construction. The material was randon 1 backfill and not compacted. The area was originally intended as a storage yard, and controlled fill was not considered necessary. The DAW Building was non-QA. The material was not inspected at the time of the original backfill placement. The concern was evaluated at the site on January 21, 1986, by cognizant engineers from SQN Modifications Unit DNC Nuclear Services Branch (NSB), and DNE Civil Engineering Branch (CEB). The decision was made that the material needed to be removed prior to building the foundation of the building, and backfilled with 1032-crushed stone material. The decision being made due to the existing material was unacceptable foundation material. The material was to be removed and areas excavated to approximately 12 to 18 inches below in situ soil for all column footings, grade beams, and under the compactor area of the DAW Building. The work was performed by the DNC NSB Unit. The areas were actually overezcavated beyond the original guidelines. The foundation area was backfilled with compacted 1032-crushed stone in 4-inch layers to the required elevation, before placing the concrete building foundation. The material was inspected randomly by cognizant engineers from DNC NSB Unit, not QC-Inspectors, and no documentation was recorded, since the DAW Building was non-QA. The concerned individual had been contacted by the SQN Nodifications Unit supervisor, in charge of the DAW Building j construction, and he was satisfied with the corrective action taken. This fact was revealed by SQN Modifications Unit supervisor, and was documented in his note to file on his investigation. C. The memorandum referenced in III.C. summarized the January 22, 1986 site meeting to discuss the DAW Building backfill material concern and appropriate course of action. The conclusions of the rite inspection were that: 1. The random fill was not an acceptable foundation for the footings. 2. An overezcavation of approximately 3-feet would reach in situ soils. i e 9 ,,----,-------r- = " ' ' ' ~ ' ' ' ~ ~ ' ~ ' ' ' ~ ~ ~ ~ " * ~ ~ ' ~'

TVA IMPIAYEE CONCERNS REPORT NUMBER: C010107-SQN SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 4 0F 4 The corrective action recommendations made as a result of findings were: 1. Overezcavate the footings to the buff-colored in situ soils. Replace the excavated material with 1032-crushed stone in approximate 4-inch lifts and compact with approximately 10 passes of the Bomag roller or power tampers (in footings). 2. Advise IMPELL (the building designer) of the problem with the random fill. D. The IMPELL design drawing C-01 for the DAW Building was reviewed. It called for building to be non-QA and did not call for anything special with regard to foundation material requirements. Conclusion The concern was valid with regard to unsuitable backfill material. However, the situation has been corrected to the concerned individual's satisfaction by removal of the material beneath the DAW Building and backfilling with compacted 1032-crushed stone. V. Root Cause The specifications and/or drawings failed to initially define the foundation requirements. VI. Corrective Action None. The necessary corrective action has already been performed. VII. Generic Applicability The concern was evaluated to be site specific to Sequoyah Nuclear Plant. VIII. Attachments lR2 Attachment A - Listing of concerns indicating Safety l Relationship and Generic Applicability lR2

CDlnto7-son'- R.2 fib 6N$$YY ~~ ' .JAN-84-002 CO 10100 N SQN NNNN

p OEEMPLOYEEEXPRkSSEDHISCONCERNTN REPORT AT EXCAVATION FOR DAW BUILDING FOUND ATION REVEALING RED CLAY, VARIOUS SI ZE ROCKS, ETC. THAT HAS USED AS A BA CKFILL MATERIAL FOR THE STORAGE YARD IF BUILDING FOUNDATION IS CONSTRU CTED HITHOUT REMOVING BACKFILLED MAT ERIAL AN UNEVEN SETTLEMENT OF THE BU ILDING COULD OCCUR.

e } .n )

c CONSTRUCTION CATEGORY Elc1cstro 3 2* ECTG WRITER'S GUIDE ELEMENT REPORT FORMAT 1.0 Issue I. Introduction-Characterization II. Summary of Perceived Problem 2.0 Summary IV. Summary of Findings Conclusions (Portion) 3.0 Evaluators Cover Sheet Information i 4.0 Evaluation III. Evaluation Process Methodology l

5.0 Findings

IV. Summary of Findings 1 6.0 Root Cause V. Root cause (Collective Significance)**

- Overall Root Cause will not be considered at this report level.

7.0 Attachments / VIII. Attachments List of Concerns Other items included VI. Corrective Actions in Construction Element (To be provided by Reports line orgainzations) VII. Generic Applicability 1905T

l Page 1 of 4 -SEQUOYAH EMPLOYEE OPERATIONS CATGORY CONCERN ELEMENT REPORT NUMBER ISSUE Construction 19201 EX-85-066-002 Conduit (initial) IN-85-138-001 IN-85-201-003 IN-85-341-001 IN-85-512-002 IN-85-512-003 IN-85-856-004 OW-85-007-008 Construction 17301 IN-85-068-N07* Slope (initial) IN-85-119-001 IN-85-197-001 IN-85-218-001 IN-85-982-002 IN-85-985-001* IN-86-222-001 PH-85-001-002 SQP-6-001-001 XI-85-046-001

These concerns were added to the Sequoyah list after 9/26/86.

Construction 19203 IN-85-374-002 Conduit and (initial) Cable Tray Construction 17303 EX-85-047-001 Instrument Line (initial) IN-85-016-003 Clamps Construction 11203 MAS-86-003 Poor Planning and (initial) Coordination As Re-lated to Construction

r Page 2 of 4 SEQUOYAH EMPLOYEE OPERATIONS CATGORY CONCERN ELEMENT REPORT NUMBER ISSUE Construction 17101 IN-85-055-N04 Valves (final) XX-85-094-007 Note: An initial report was not necessary. This will be the only submittal for 17101. Construction 15109 IN-85-119-002 Instrumentation (final) IN-85-618-004 Tubing IN-86-200-006 Instruments As To Construction Note: An initial report was not necessary. This will be the only submittal for 15109. Construction 15105 IN-85-449-001 Flex Hose (final) Connections Note: Initial report transmitted 9/11/86. Construction 15102 IN-85-346-002 Electrical (final) Penetrations i Note: Initial report j transmitted 9/11/86. Construction 15101 IN-86-158-005 Floor Drains I (final) i l Note: Initial reports transmitted 9/11/86.

Page 3 of 4 SEQUOYAH EMPLOYEE OPERATIONS CATGORY CONCERN ELEMENT REPORT NUMBER ISSUE Construction 11302 IN-86-200-003* Design of Anchors (final) PH-85-002-009 As Related to Construction Note: Initial Report Transmitted 9/11/86.

This concern was added to Sequoyah list after 9/26/86.

Construction 11207 XX-85-101-002 Improper Installation (final) As Related to Construction Note: Initial Report transmitted 9/17/86. Construction 11202 IN-86-261-002 Craft Designed (final) XX-85-120-006 Handers As Related to Construction Note: Initial report transmitted 9/11/86. i Construction 11102 WI-85-091-013 Design Output (final) Note: Initial report transmitted 9/11/86. i i

e Page 4 of 4 SEQUOYAH EMPLOYEE OPERATIONS CATGORY -CONCERN ELEMENT REPORT NUMBER ISSUE Construction 10505 OW-85-007-010 Electrical Control (final) Cabinets As Related to Construction Note: Initial report transmitted 9/11/86. Construction 10504 00-85-005-010 Conduit As Related (final) to Construction Note: Initial report transmitted 9/11/86. Construction 10501 IN-85-231-003 Caulking As Related (final) to Construction Note: An initial report was not necessary. This will be the only submittal for 10501. Construction 10107 JAN-86-002 Dry Active Waste (final) Building Foundation Note: Initial report transmittad 9/11/86.}}

ML20211D473

Text

Dear Mr. Denton:

SUBJECT:

SUMMARY

SUMMARY

SUMMARY

SUMMARY

Subject:

5.0 Findings

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