Text

Forwards Initial Repts Addressing Employees Concerns in Engineering & Welding Categories & Final Rept for 8 Elements Addressing Employee Concerns in Listed Categories,For Review.Listing of Rept Numbers Also Encl
	ML20213F507
Person / Time
Site:	Sequoyah
Issue date:	11/11/1986
From:	Mcdonald J; TENNESSEE VALLEY AUTHORITY
To:	Harold Denton; Office of Nuclear Reactor Regulation
References
	NUDOCS 8611140236
	Download: ML20213F507 (81)
	v • d • e

{{#Wiki_filter:7- ) TENNESSEE VALLEY AUTHORITY + = Watts Bar Nuclear Plant o P. O. Box 800 Spring City. Tennessee 37381 l November 11, 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 one initial report addressing Sequoyah Nuclear Plant employee concerns in the engineering category, and one initial report in the welding category. As has been previously discussed with your staff, the welding reports addressing employee concerns have been left in the format used by the Weld Task Group. (These reports have been reviewed and approved by the Senior Review Panel). transmits the final report for 8 elements addressing Sequoyah Nuclear Plant employee concerns in the following categories: Operations - 5 reports Stone & Webster Items - 3 reports 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. 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. The guidance of the Writer's Guide does not apply to the Stone and Webster reports. Enclosure 4 provides a listing of the report numbers, the related employee concerns, and the previous submittal dates if applicable. 8611140236 861111 n 1 PDR ADOCK 05000327 l P PDR 'l An Equal Opportunity Employer (

4 o Mr. Denton Please telephone Martha Martin at (615) 365-3587 (Watts Bar) if you have any questions. Very truly yours, TENNESSEE VALLEY AUTHORITY F A. ja J. A. Mcdonald Watts Bar Nuclear Plant Site Licensing Manager Enclosures cc (Enclosures): Mr. James N. 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 l Attn: Mr. Gary Zech i 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Mr. B. D. Liaw, Branch Chief U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue Room T-1132 Bethesda, Maryland 20814 l L

/ s9 ENCLOSURE 1

.1,0/14/86 TVA EMPLOYEE CONCERNS REPORT NUMBER: 232.3 (B) SPECIAL PROGRAM 4 REPORT TYPE: SEQUOYAH ELEMENT REVISION NUMBER: 0 TITLE: PIPING AND VALVE DESIGN Improper Piping Insulation Material PAGE 1 0F 8 REASON FOR REVISION: PREPARATION PREPARED 8 ./ b, lo //$ff[., / g ~ /F " SIGNATURE DATE REVIEWS N VIEW COMMITT kAr SIGNATURE / DATE TAS: SIGNATURE DATE CONCURRENCES /WI9//g' W CEG-H: d'/7 i SRP: SIGNATURE DATE SIGNATURE DATE APPROVED BY: l l ECSP MANAGER DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)

r t 10/14/86 TVA EMPLOYEE CONCERNS REPORT NUMBER: 232.3 (8) SPECIAL PROGRAM REVISION NUMBER: O PAGE 2 0F 8 1. CHARACTERIZATION OF ISSUE (S): Concern: Issue: EX-85-089-002 a. The physical durability of the soft "CI feels that improper insulation (rock wool) typ piping insulation materials were installed in many material widely used at WBNP and at aspects of W8NP construction. SQNP may not provide as satisfactory CI expressed that most of the a service life as would a " harder" insu~.ation installed was '50F' material. insulation (' Rock Wool'), covered by a metal sheath. CI stated that this type of insul-ation is easily damaged, and is subject to deterioration due to vibration over long periods of time. CI expressed that a ' Harder' type of insulation should have been used. NUC. POWER Dept. concern. CI has no further information." 2. HAVE ISSUES BEEN IDENTIFIED IN ANOTHER SYSTEMATIC ANALYSIS? YES NO X Identified by Not applicable Date Documentation Identifiers: None 3. DOCUMENT NOS.. TA6 NOS.. LOCATIONS OR OTHER SPECIFIC DESCRIPTIVE IDENTIFICATIONS STATED IN ELEMENT: Piping Insulation " Rock Wool" l 00820 1

10/14/86 TVA EMPLOYEE CONCERNS REPORT NUMBER: 232.3 (B) SPECIAL PROGRAM REVISION NUM8ER: 0 PAGE 3 0F 8 4. INTERVIEW FILES REVIEWED: EX-85-089-002 5. DOCUMENTS REVIEWED RELATED TO THE ELEMENT: See Appendix A. 6. WHAT REGULATIONS. LICENSING COMMITMENTS. DESIGN REQUIREMENTS OR OTHER APPLY OR CONTROL IN THIS AREA? See Appendix A. 7. LIST REQUESTS FOR INFORMATION. MEETINGS. TELEPHONE CALLS. AND OTHER DISCUSSIONS RELATED TO ELENENT. See Appendix A. 8. EVALUATION PROCESS: a. Reviewed TVA Mechanical Design Guide DG-M18.9.1 " Insulation for Piping and Equipment in Nuclear Power Plants." b. Reviewed TVA Sequoyah Design Criteria for insulation requirements inside and outside containment. c. Reviewed TVA specifications for Sequoyah insulation supply and installation inside and outside containnent, d. Reviewed manufacturer's product data sheets for the mineral fiber insulation materials installed at SQN and W8N Plants. i e. Reviewed related ASTM Standards for mineral fiber insulation materials. 00820

10/14/86 TVA EMPLOYEE CONCERNS REPORT NUMBER: 232.3 (B) SPECIAL PROGRAM REVISION NUMBER: O PAGE 4 0F 8 9. DISCUSSION. FINDINGS. AND CONCLUSIONS: Discussion: As stated, the concern is for the durability of the soft (rock wool) piping insulation installed at W8NP because of its alleged susceptibility to damage from abuse and long-term deterioration when exposed to vibration. Based on discussion with the insulation contractor, the term "SOF" (as quoted on the K-fonn) does not identify any type or brand name of insulation used at WBN. Therefore, it is interpreted to mean " Soft." Rock wool is one of several mineral substances used in the manufacture of the fibrous type of mass insulation. " Mineral Fiber" is the ASTM Standard generic term for insulation material composed principally of fibers manufactured from molten mineral substances such as rock, slag, or glass, with or without binders. The TVA Insulation Design Guide (App. A, 5.a) provides general and specific requirements, standards, and application guidelines for various types of insulation to be used in nuclear power plants including all metal reflective types for piping and equipment inside containment and mass types for other piping, equipment and ducts. The TVA insulation specifications (App. A, 5.d and 5.e) provide specific requirements for the procurement and installation of piping insulation at WBN and SQN Plants. At SQN plant the majority of installed insulation is molded calcium silicate. However, at SQN (and WBN) two forms of mineral fiber l insulation have been applied to some piping outside of containment only (excluding the mineral fiber block used in the main piping l containment penetrations): I a. Felted mineral fiber flexible blanket type manufactured from resilient refractory fibers, bonded with organic resin and supplied as a one piece, single layer, wrap-around pipe covering. b. Rigid prefonned mineral fiber type, manufactured from refractory fibers and with an organic resin binder molded into hollow cylinders, supplied in sections or segments l l suitable for single or multiple layer pipe covering. 1 ( Both forms of mineral fiber insulation are applied to straight pipe with metal wire or bands and covered with an.016-inch thick aluminum jacket. 00820 l

10/14/86 TVA EMPLOYEE CONCERNS REPORT NUMBER: 232.3 (8) SPECIAL PROGRAM REVISIDN NUM8ER: 0 PAGE 5 0F 8 l l These mineral fiber insulation forms can be characterized as soft because of their relatively low compressive strength compared to certain other types of commonly used pipe insulation such as molded calcium silicate. ASTM Standard C165, " Standard Method for Measuring Compressive Properties of Thermal Insulation" provides procedures for measuring thermal insulation mechanical behavior under compressive load. Another of the several mechanical properties which needs to be considered in the selection of insulating material is hardness. Hardness is defined as that property which measures a material's ability to resist penetration. It affects ease of application and is determined by ASTM Standard C569, " Standard Test Method for Indentation Hardness of Preformed Thermal Insulators." The resilience of the wrap-around blanket type is desirable in some piping applications covering small obstructions such as i heat-tracing. Insulations of all types commonly applied to piping are susceptible to some degree of damage if not handled carefully during installation and protected from abuse after installation. Mineral fiber type piping insulation has been widely used in industrial and power plant applications and has provided many years of satisfactory service. If damaged to the extent that thermal performance is unacceptable during installation or af ter, the damaged section of insulation can be economically and readily replaced. During installation, a reasonable amount of waste from i j abusive damage and other causes is anticipated and considered i acceptable. Mechanical vibration can cause deterioration of piping insulation thermal performance through wearing away, settling, or dusting of the insulation material. The resistance to vibration of mineral fiber type piping insulation is good, and there are applications where its mechanical perforrance can be superior to that of a harder material such as molded calcium silicate. Furthermore, because of the bonding of the fibers, settling is not a problem with rigid or semi-rigid insulations. Satisfactory service experience in widespread applications demonstrates the acceptability of mineral fiber as an economic, durable and maintainable piping insulation material. 00820

10/14/86 TVA EMPLOYEE CONCERNS REPORT NUM8ER: 232.3 (B) SPECIAL PROGRAM REVISION NUMBER: O e PAGE 6 0F 8 Findinas: a. The commercially available mineral fiber type piping insulations have appropriate and economic applications in the SON Plant. b. The general serviceability of mineral fiber piping insulations is satisfactory when installed and maintained with reasonable care. c. Mineral fiber piping insulations exposed to the usual vibration created by fluid flow in the insulated pipe will not experience a significant loss of thermal performance over the long term when installed and maintained in accordance with the manufacturer's instructions.

== Conclusion:== The concern is not valid for the mineral fiber types of piping insulation installed at SQN. l 00820

10/14/86 TVA EMPLOYEE CONCERNS REPORT NUM8ER: 232.3 (8) SPECIAL PROGRAM REVISION MUMBER: 0 PAGE 7 0F 8 APPENDIX A 5. DOCUMENTS REVIEWED RELATED TO THE ELEMENT: a. TVA Mechanical Design Guide 06-M18.9.1, " Insulation for Piping and Equipment in Nuclear Power Plants" b. TVA Design Criteria, SQN-DC-V-2.10, " Insulation used Within the Containment Vessel" c. TVA Design Criteria, SQN-DC-V-1.1.11.4, " Pipe Insulation Modifications for Pipe Rupture Protection Outside Containment" d. TVA Specification No.1475, " Thermal Insulation Materials for Piping and Equipment Inside the Containment for Sequoyah Nuclear Plant Units 1 and 2 and Thermal Insulation Materials for Piping, Equipment and Reactor Vessel Inside the Containment for Watts Bar Nuclear Plant Units 1 and 2' e. TVA Specification No. 2093, " Insulation for Piping and Equipment Including Installation, and Pipe and Equipment Insulation Installation Inside containment and the Main and Reheat Steam Piping to the Turbine Building, Sequoyah Nuclear Plant Units 1 and 2" f. TVA SQN Drawings 47W450-1E R1, -2E R1, -3E R1, -6E R2, -7E R1, -8E R1, -9E R1, -10E R1, -11E R1, -12E R1, -13E R1, -14E R1, -15E R1, -16E R1, -17E R1, -18E R1, -19E R1, and -28E R1 g. FIBREX Inc. Technical Data Sheet for "Epitherm 1200 Molded Pipe Insulation" h. Forty Eight Insulations Inc. Product Data Sheet for " Forty Eight MF Pipe Insulation" i. ASTM Standard Specification C547-77 for " Mineral Fiber Preformed Pipe Insulation" j. ASTM Standard Specification C592-80 for " Mineral Fiber Blanket Insulation and Blanket-Type Pipe Insulation (Metal-Mesh Covered) (Industrial Type)" k. Letter f rom L. M. Mills, TVA, to A. Schwencer, NRC, No. A27 800721 018, (07/21/80) 00820

10/14/86 TVA EMPLOYEE CONCERNS REPORT NUM8ER: 232.3 (8) SPECIAL PROGRAM REVISION NUMBER: 0 PAGE 8 0F 8 6. WHAT RESULATIONS. LICENSING COMMITMENTS. DESIGN REQUIREMENTS. OR OTHER APPLY OR CONTROL IN THIS AREA? a. SQN Plant Design Criteria Listed in 5.b above b. TVA Insulation Specifications Listed in 5.d and 5.e above c. TVA Drawings listed in 5.f above 7. LIST REQUESTS FOR INFORMATION. MEETINGS. TELEPHONE CALLS. AND OTHER DISCUSSIONS RELATED TO ELEMENT, a. TVA SQN Transmittal #100. (08/27/86) b. RFI SQN #562, (09/11/86) c. TVA SQN Transmittal #115, (09/19/86) d. Telecon between Mahlman and Mills, TVA Knoxville, and Griffith, Bechtel SF, (09/24/86) l 0082D

WELDING PROJECT EMPLOYEE CONCERN EVALUATION REPORT REPORT NUMBER: WP-21-SQN, R0 DATE: 8/;478Ms SUBJECT WELD MATERIAL SUBSTITUTION AND QUALITY CONCERN (S) CONSIDERED: DilT-85-001 O #Y'hd6 [44/, _ -e,, , OC, WP PREPARED BY REVIEWEDBY_bnyi>N 8/h 9/f/, , OC, WP uN REVIEWED DY w4Its-d!Z7db , QA, WP r \\ fj V/ M , CEG-il, WELDING _,M M,. REVIEWED BY /d' {fb h- [b , PROGRAM MANAGER APPROVED DY 1501T

EMPLOYEE CONCERN 7s

SUMMARY

SHEET Report Number: WP-21-SQN, RO Report

Title:

WELD MATERIAL SUBSTITUTION AND QUALITY I. CONCERN CONSIDERED: DHT-85-001 II. ISSUES INVOLVED 1. Weld procedures call for E70S-3 weld rod but only E70S-6 rods are onsito 2. E7018 electrodes are of poor quality III. STATEMENT OF CONCERN / ISSUE VALIDITY Validity: Y .N X , Substantiated: Y .N X l IV. EFFECT ON HARDWARE AND/OR PROGRAM / None (effects on hardware previously evaluated per S01851218 896) V. JUSTIFICATION: Investigation of the concern revealed that substitution of E70S-6 for E70S-3 is acceptable by DPM N73M2 Process Specification 1.M 1.2 (R3) and the 1983 Edition of Section IX of the ASME Code. Investigation of the E7018 electrode quality per Sol 851218 896 and WP-12-SQN did not substantiate weld quality problems related to electrode quality. VI. RECOMMENDATION AND/OR CORRECTIVE ACTION NEEDED None VII. REINSPECTION NEEDED: Y ,N X Page 1 of 2

s i i l Report Number: WP-21-SQN, RO VIII TISSUE CLOSURE Closure is based on this report. i IX. ATTACHMENTS 1. Text of Employee Concern 2. Report Number Sol E51218 896 (RIMS) 1 i / O h O 4 Page 2 of 2 e--

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EMPLOYEE CONCERN f s. Report Number: WP-21-SQN, RO Report

Title:

WELD MATERIAL SUBSTITUTION AND QUALITY I. SCOPE OF EVALUATION This engineering analysis covers the following SQN concern: DitT-85-OO1 II. ISSUE (S) ADDRESSED BY CONCERN The concern was analyzed to determine the issue (s) voiced by the concerned individual. This issue (s) is as follows: 1. Wold procedures call for E70S-3 weld rod but only E70S-6 rods are onsite. 2. E7018 electrodes are of poor quality. , / III. CONCERN VALIDITY OR SUBSTANTIATION The Welding Project (WP) has reviewed the investigation (RIMS No. S01 851218 896) of this concern performed at SQN and is in concurrence with the evaluation of the issues. The investigation of the first issue determined that E70S-6 can be purchased with chemical analysis which meets the A number limits of E70S-3. Requalification of the weld procedures is required only when essential variables of the qualified weld procedures are changed beyond the limits specified in Section IX of the ASME Code. TVA has purchased E70S-6 weld rod to meet the required A number chemistry there by eliminating the need to requalify the wold procedures. Page 1 of 2

Report Number: WP-21-SQN, RO f-~ Investigation of the second issue involving E7018 electrode determined that weld discontinuities had occurred; however, an insufficient quantity of the electrode was available at the site for the Site Welding Engineer to perform a meaningful sampling and determine if the discontinuities were attributable to electrode quality. Radiographic examination of welds made with the questionable electrode failed to identify any specific rejectable defects which could be attributed to the electrode weldability. The manufacturer and size electrode was Oerlikon - 3/32". This electrode is no longer in use at the TVA nuclear plants. Based on the investigation no specific violation of the specification or ASME Codo could be substantiated and no weld quality problem associated with electrode quality was identified. These issues are closed by this report. .m Page 2 of 2 m

e ATTACHMENT 1 Page 1 of 1 08/05/86 (EMPLOYEE CONCsRNS) PAGE: 1 09:51:01 CAT ISSUE PLANT PRIORITY ORG QTC EGG INSP SD RD GD 10 --------CONCERN-__----- WE S 581 SS DHT-85-001 KEYWORDS: WELD ROD PROCEDURE QUALITY WELDING RODS ARE OF POOR QUALITY. WELD PROCEDURES CALL FOR E70S-3 WELD ROD BUT ONLY E70S-6 WELD RODS ARE ONSITE. IR: STAT: RC: TECHNICAL COMMENTARY: Total For This Selection: 1 -m i i l' e i 4 -,rw- --,-----n--, .-.-----.,v------- ~ - - - - - - - - - - ~. - -. - -, - - - - -

Attachment 2 f, Page 1 of 3 -y M,vn er,- m 7 7,,_,.._. nut.PRhm5 ? *) 80 1 851218 896 e i> y s, c,,,..- 76 J i... s. c, ) DEC 18.55 l D. E. %:111s, l EUC PR, Sequoyah 6 l Sobject s SE@0TAE wrt man ytANT - EMPLOTEE CDUCEIE - WELD MATFBf AT. FEDCU2EiEINT AND USE - E7018 ELECTRODES AND E708-6 WELD EDD This memoraness is is reeponse to the employee coecerns stated on your Form 64A Beyly Neue to as and as diseassed with R. M. Rodge and J. L. Ads =a of the Site Codes and Standards Sectico on Dececher 12, 1985, regarding the procurement and use of welding filler material. i ~ One of the concerne the employee had was is reference to the use of E705-4 filler asterial dere the Detait uste Procedure spectries the use of E708-3. SfM 37M2 Process Specification 1.M 1.2 (R3), " General Welding Procedures 1,pecification," states in paragrapha 14.22.3 and 14.24 that E705-3 and E70S-4 filler materiale are interchangeable (see Att e =et A). Ibis is is accordance with the 1983 Edition of the A5ME Boiler and Pressere vessel (34P7) Code, Sectica II, "Qualificaciqa Standard for Helding and Braatag Procedures Welders, Brazers, and Welding and Beastas Operators." Seetime II elemeifies solding filler asterial by F member, ubick ta based essensially se their essability characteristics; and by A armher, edLich identif tas the sold metal by heat camposities. Each ev. ding process le saeigned specifie essential variables and is defined as a shmage la a =tdemy eMgian that will af fect the mechanical propertise (eeker than esteh tee @ mass) of the weldnent. A chsage is an essential variable der a gives solding process constitutes the need for requalificatico of precedures. The esamettal vertables applicable to this specific case i for the gas asegeten are soloing process are found is paragrapha 40404.4 and (p444.S ander Sectlos 11. Artisle IT, " Weld Deta" (see Attachment 3). Pasagraph (p406.4 states that a change from one F ainsber to any other F ammber listed in Table (p431 regelres a requalificaties of the procedure. i 5715-3 and Em welding rods are claaeffied under SFA 5.18. " Specification for Castes steel Filler Metals for Gas Shieldad Arc Weldiap " andar the t*- SLFT Code, Secties II, Part C, tetick meets the intent of the referenced Paragraph. 3

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At taclunent 2 Page 2 of 3 ,-,w. ~ - -- A i t O. E. Th111e SalpotAI BDCLEAR p1 ANT - BfFIDTEE CONCEWI - WELD MATERI AL PROCURDENT. ABD DIE - E7010 ELECTIODES AND E703-6 WELD EOD Paragraph (p404.5 states that a chasse in th'e chemical composition of the sold deposit from oes A samber to another A number specified la Table Nel requires a regnalificatica of the procedure. Although the

==8-limits for 3705-3 sed, E708-4 differ andar SFA5.18. TVA has limited the chemical analyste of E70$-4 weld rod to meet the requirements of A amber 1 (.15 percent

==8-carbon.1.60 percest mesimus manganese, and 1.00 percest==wt=== eilican) as stated in peregraph 14.24 of process specification 1.M.1.2 (R3). Therefore, ao requalificattoo of procedures is regstred. The other employee concera deals with TVA's policy of weld saterial precarement, especially E7018 electrodes. TVA to committed to purchasing umiding filler meterials to the latest edition of the AENE B&FV Cade. Section III. "teles for Ceestructico of Beclear Power pleet Campossets." and Section II. Fort C. " Material Specificattoes - Meldiot Beds. Electrodes, and Filler Metale." A list of approeed vendors for melding meterials is tototend by TTA bemed os A9tB certifIcatica and a weldability perfoemance test administered by TVA prior to acceptance of the centract. If a prehlse arises with a particular hast. type, or else of electrode or unld rod, as investigation to inittsteJ within the Of fice of resor and W=mertag to datermine if the probles is Justifiable. If there is jaetification for further tavestigattaa.

==* - tee resserah and teettag is perfemmed to deterates a resolution. The particular concers about 37018 electrodes==== factored by a specific sender imselving the estetenee of permetty at the start and stop pointe of the unld head una set bree$t to the atteettom of the Site Melding Begineer until it uns, tee,,hte to de seemingful sampling. At the time sf motificattaa there une not enough of the questionable brand electrode to de sufficient teettag. The umiding operettoes tetich involved the use of this partientar brand and stae electrode en the feedester heater endificatismo uma cissely meettored by the Site Uelding Englaser. priar to motificaties of this specific problem. Various problema solatad te sold discentimattiaa la the weld joint were identified, housvar as eyesific defects, rejectable by radiographic esaminatico. emeld be attributed to the electrode meldsbility. N

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9. E. Its111e SEppt&E MEI. EAR MANT - M CDEEEE - WELD ltATERIAI. PROCURMINT AND WE - E7018 M.KT30ERS AND E70S-4 WELD 300 Socid there be any questians regarding this resFease, plaaes contact J. L. Adame, at Segssyah Codes and Standarde, extension 7265.

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O O 4 ENCLOSURE 2

TVA EMPLOYEE CONCERNS REPORT NUMBER:302.04-SQN SPECIAL PROGRAM REPORT TYPE: Sequoyah Nuclear Plant-Element REVISION NUMBER:1 TITLE: Ground Detector Problem REASON FOR REVISION: Revised to incorporate SRP comments, and SQN corrective action response. Revision 1 PREPARATION PREPARED BY: /4/5/kd B. Meers, Jr SIGNATURE ' DATE / REVIEWS PEER: l$$ $ /fl5l h DATE / 'f IGNATURE b. 't /8 l0 / h l SIGNATURE DATE ~ l CONCURRENCES 'CEG-H:t ^ // 88 SRP: ma l SIGNATURE DATE SIGNATURE

DATE APPROVED BY-MG/d4L-

//-es, NiA l ECSP MANAGER DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)

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

1466T

.o TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT EMPLOYEE CONCERNS TASK GROUP OPERATIONS CEG Subcategory: Cable & Conduit Element: Ground Detector Problem Report Number: 302.04-SQN Revision 1 SQN-86-013-001 .i Evaluator: N-M Ad B Neer Date h-3d'fd M Reviewed by: OPS gBC ab'er Date k1 P. C O -30 8, Approved by: W.R. Liger (rn Date 1466T

l' .I., Ground Datector Problso This element report esaluates the concern of replacement bulbs in various ground fault detectors giving false indications. The scope of this report is limited to evaluation of replacement of bulbs in the ground fault detectors found on the various power distribution boards at Sequoyah Nuclear Plant. II. Specific Evaluation Nethodology This element is made up of one K-form: "SQM-86-013-001 - Changing out the Sylvannia bulbs in various ground detectors causes a resistance change which shows a ground between all three phases on the board when the test button is pushed. This false ground signal overshadows an actual ground on the board, since the bulb lights up 4 brighter than the other bulbs indicating a ground although an actual ground d may be on one of the other phases. Nuclear Power Department concern. Anonymous concern." The K-form was reviewed to determine the area of concern, requirements were researched, and cognizant individuals in Operations and Electrical Maintenance were interviewed. TVA schematic diagrams were reviewed to determine the wiring connections of the ground detectors. IR1 Cognizant individuals in Electrical Maintenance (an Electrical Engineer, I an Electrician-Foreman, and an Electrician) were interviewed to IR1 determine the action taken in response to a Work Request stating that l operations personnel had found indications of a ground on the 480-volt l Shutdown Boards. l The contract for the 480-volt Shutdown Boards was reviewed for the equipment requirements (Reference 1). Operations instruction letter OSL&99 was reviewed for the operations requirements (Reference 2). 4 i III. Findings r The contract files were reviewed to determine the required replacement l bulbs and TVA drawings were reviewed to determine the circuit lR1 configuration (References 1 and 3). The ccatract specifies 3 clear lights to indicate grounds when a test button is pressed. The TVA schematic diagrams agree with this configuration. A contract drawing i specifies the bulb and clear lens combination (Reference 1 and 4). No procedures or requirements for changing ground detector bulbs were found. Cognizant individuals in operations (Assistant Operations Supervisor, l an Assistant Shift Engineer and a Senior Reactor Operator) were lR1 interviewed to determine the action taken to detect grounds. Page 1 of 4

The following is a summary of the findings froa interviews: lR1 1. Operations Auxiliary Unit Operators (AUOs) are required by OSLA99 to check the condition of the 480-volt Shutdown Boards once per shift and document the check on Attachment F of OSLA99. Based on interviews with cognizant individuals in operations, part of this check is to press the test buttons of the ground detectors in order to identify any possible grounds. This checking process is not in procedure form but is part of the AUOs past training experience. If problems are identified, an ASE or SRO is called for assistance in evaluating the problem. 2. If a ground fault is identified, a work request is initiated to allow the electricians to determine and repair the'cause of the ground fault. Electricians are requested to check all three phases in evaluation of the problem. Based on interviews with cognizant individuals in Electrical Maintenance, a Work Request to troubleshoot and repair a ground on the 480-volt Shutdown Board is handled as follows: The electrician requests the help of an ASE to isolate the circuit causing the ground. This is done by opening circuit breakers and observing the ground detector when the test button is depressed. Absence of a ground indication when a breaker is opened identifies the associated circuit as the circuit causing the ground problem. The circuit breaker is left open and the electrician measures the resistance of each phase to ground with a calibrated ohn meter. A low resistance measurement on a phase indicates that phase is grounded. The electrician proceeds to locate and repair the. ground condition. 3. Operations personnel change the ground detector bulbs when they are broken or show unequal brightness with the other detector bulbs in a set of three. 4. There are two type (number) of bulbs that can be used as lR1 replacements in the ground detector circuit. 5. If bulbs of different type numbers are mixed in the same ground lR1 detector, false partial ground fault indications will occur when the test button is pushed. 6. No procedure for changing the ground detector bulbs could be identified. 7. No operations " night order" was identified that specifies ground detector bulb changing procedure. 8. The bulb type to use as replacement is not identified. The bulbs are replaced by bulbs of the same type number verified by inspection of the old and new bulbs. Page 2 of 4 f

,9. Th3 480-volt bozeds that cra equipp:d with ground detecters are also a equipped with overcurrent protection relays. Conclusions 1. Problems of false ground faults, partial and full, indications on the ground detectors have occurred in the past. 2. Operations personnel replace ground detector bulbs as necessary based on training and previous experience. No procedure was found that identifies the correct bulb type. 3. If a ground is identified on one of the phases, operations personnel write a work request to have the problem evaluated by the electricians. No procedure was found that describes the corrective maintenance. 4. Bulbs of different types could overshadow a partial ground problem on one of the phases. 5. The ground detector problem will not degrade equipment reliability because the 480-volt boards are equipped with overcurrent protective relays on all phases. The overcurrent relays will trip the breaker if a ground fault exists on two or more phases. A ground on one phase only will cause no equipment degradation, but should be identified and repaired. s i Based on the findings, employee concern SQM-86-013-001 is determined to e be valid. m IV. Root Cause Based on the findings, no procedure exists for ground detector bulb replacement and trouble shooting. [ V. Generic Applicability Based on the findings, this concern has been determined to be applicable to other TVA nuclear plants. 5 l VI. References l 1. TVA Contract Number 71C2-54523 for 480 volt boards. lR1 l 2. Operations Instruction Letter OSLA99, page 3, dated Ja9uary 10, l 1986 and page 61 (Attachment f) dated April 10, 1986. l l l l Page 3 of 4 L

. VL. R0forsncSs (continusd) 3. TVA Schematic Diagrams 45W760-212-1, 45W760-212-2, and 45W760-212-3. (All revisions show the ground detectors) 4. Contract Number 71C2-54523 Drawing Number 6846D35 R9 VII. Immediate or Long-term Corrective Action Sequoyah Nuclear Plant management will have plastic tags placed near l the ground detector bulbs on the Unit and Shutdown Boards. The tags l will read " REPLACE GROUND LIGHTS AS A SET OF THREE-SYL 120V BULBS ONLY" lR1 and " VERIFY ALL GROUND LIGHTS GOOD PRIOR TO SEARCHING FOR GROUNDS ON l EQUIP". l Tags will not be required by restart and will be installed in the next IR1 6 to 12 months. (CATD 30204-SQN-01) 4 I 4 Page 4 of 4 i

4 ~~ 15 REFERENCE - ECPS120J-ECPS121C TENNESSEE VALLEY AUTHORITY PAGE 'e FREQUEHCY - REQUEST OF.FICE OF NUCLEAR P0HER RUH TIME - 11:15 DNP - ISSS - RHM EMPLO(EE CONCERN PROGRAM SYSTEM CECPS) RUN DAT.E'- 10/02 LIST OF EMPLOYEE CONCERN INFORMATION CATEGORY: OP PLANT OPER. SUPPORT SUBCATEGORY: 30204 GROUND AND ELECTRICAL SHOOK PROBLEMS '9 S GENERIC KEYHORD A H APPL QTC/NSRS P KEYHORD B COHCERN SUB R PLT BBSH INVESTIGATION S COHCERN KEYHORD C

(

HUMBER CAT CAT D LOC FLQB REPORT R DESCRIPTION KEYHORD D SQM-86-013-001 OP 30204 N SQH NNNN I-86-103-SQN CHANGING OUT THE SYLVANNIA BULBS IN NONCCNFORMANCE T50268 REPORT VARIOUS GROUND DETECTORS CAUSES A RE CONST PROCESS SISTANCE CHANGE HHICH SH0HS A GROUND ELECTRICAL

g BETHEEN ALL THREE PHASES ON THE BOA LIGHTNING RD HHEN THE TEST BUTTON IS PUSHED.

THIS FALSE GROUND SIGHAL OVERSHADOHS AN ACTUAL GROUND ON THE BOARD SINCE 't THE BULB LIGHTS UP BRIGHTER THAN TH E OTHER BULBS INDICATING A GROUND AL THOUGH AN ACTUAL GROUND MAY BE ON OH E OF THE OTHER PHASES. HUCLEAR POWE

p' R DEPARTMENT CONCERN. ANONYMOUS CON CERN.

O 1 CONCERHS FOR CATEGORY OP SUBCATEGORY 30204 .c e

c

,G G

TVA EMPLOYEE CONCERNS REPORT NUMBER: 304.01 SQN SPECIAL PROGRAM REPORT TYPE: Sequoyah Nuclear Plant - Element REVISION NUMBER: 2 TITLE: Procedure Problems REASON FOR REVISION: To incorporate SRP comments and corrective action response. Revision 1 To incorporate SRP comments on revision 1. Revision 2 PREPARATION PREPARED BY: P. L. Shepherd 10-31-86 SIGNATURE DATE REVIEWS Y0 /// 7 / - $ h / [ SIGNATURE DATE TAS: $$b //' i /bi / h SIGNATURE DATE CONCURRENCES CEG-H: / SRP: c ma_e. M' b SIGNATURE DATE SIGNATURE

DATE APPROVED BY:

ht /Ah ffb"Y / N/A ECSP MANAGER DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)

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

1770T

i a TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT EMPLOYEE CONCERNS TASK GROUP OPERATIONS CEG Subcategory: Cable and Conduit Element: Procedure Problems Report Number: 304.01 SQN, Revision 2 TAK 86-005 IN-85-112-001 Evaluator: Paul L. Shepherd // -3/-f6 P. L. Shep er Date Reviewed by: g d'

-5/-fd OPS CF4 Mptfib e Date Approved by:

/# 7/ b W. R.'Lagergren ' D a t'e 1770T

Ravision 2 I. PROCEDURE PROBLEMS This report covers procedure problems addressed by two concerns. One concern addressed the misapplication of RTV 3140 on junction box terminal blocks. The other concern addressed cable pulling and bending requirments. II. SPECIFIC EVALUATION METHODOLOGY This element consists of two concerns. The first concern is specific to Sequoyah (SQN) and does not apply to any other plant. TAK-86-005 - "RTV applied to junction boxes on SMI-0-360-0 may not have been properly applied on all junction boxes. RTV used was not QA level and has exceeded it's shelf life was not a concern as he has verified that the RTV in question will in fact set up properly. The onsite employee concern file was reviewed to determine the specific areas of concern. In addition, the supervisor that documented the employee concern was interviewed to further clarify the specific areas of concern. Cognizant engineers in the Electrical Maintenance Section at SQN were interviewed. The second concern is specific to Watts Bar Nuclear (WBN) Plant and applies to all other nuclear plants. IN-85-ll2-001 "TVA Nuclear Power Department is not working in accordance with construction specifications when making modifications and additions. EG no maximum pull tension is specified when Nuclear Power Department pulls a new cable and minimum bend radius is also not specified". The Construction Category Evaluation Group (CEG) has issued an element i report No. C010900 SQN, dated August 7, 1986, for SQN that completely I addresses this concern. This report evaluated current ONP cable lR1 installation practices and procedures. Maximum pull tension, sidewall I pressure, and minimum bend radius cable issues are being actively I evaluated by DNE and final conclusions will not be available until l they complete their evaluations and responses to C010900 SQN. No l further evaluation of this concern is required. l l t III. FINDINGS Maintenance Request (MR) No. A554518 was written on August 18, 1985 (Reference 1) to coat junction box terminal blocks with 3140 RTV. The junction boxes to be coated were listed in Special Maintenance Instruction SMI-0-360-3 Revision 0 (Reference 2). The contract number that purchase the RTV 3140 used on this MR cannot be determined. (Discrepancy Report No. SQ-DR-85-08-lllR, Reference 3 and Nonconforming Item (NCI) tag No. N2-85-294, Reference 4). Page 1 of 4

m III.' FINDINGS (continued) Only one junction box, 3190, is required by the Environmental Qualification (EQ) Binder TB001 to be coated with QA RTV3140 but was coated with questionable coating on MR A-554518. The EQ Binder TB001 shows Reference 6 as documentation of the existence of terminal block coating in junction box 3190. Three other MR's which coated terminal blocks with RTV 3140 on SMIO-360-3 were reviewed. All three had proper material traceability. All Junction Box terminal blocks listed on SMI 0-360-4 (Reference 9) have been inspected on SS3 860103 810 (Reference 6) or replaced on S02 860728 898 (Reference 10). The material traceability practices of the Electrical Maintenance Tool l Room at the time the subject work, MR A-554518, was performed were not l consistant with the intent of SQA 45 Revision 17 dated September 27, 1985, lR2 (reference 7). This material traceability problem was later identified lR1 and investigated by NSRS. NERS Report No. I-86-165-SQN (reference 11) [ addresses their investigation, conclusions, and recommendations. l Corrective actions to clarify material traceability requirements were I started with the issue of Revision 18 of SQA 45 on November 21, 1985 l (reference 12) and continued through the issue of Revision 21 of SQA 45 l on June 3, 1986 (reference 13). Corrective action was taken by lR1 Electrical Maintenance on March 6, 1986 (Attachment A to reference 14). l H. L. Abercromble's responses (references 14 and 15) to the l recommendations in the NSRS Report, along with completed Discrepancy lR2 Reports SQ-DR-86-04-088R and SQ-DR-86-04-089R (references 16 and 17) I and completed CATS No. 86171 (reference 18), document completion of all lR2 recommended corrective actions. I Conclusions Based on the findings, concern TAK-86-003 was determined to be valid. Since the RTV 3140 that was used to coat the terminal blocks in junction box 3190 has now been marked "No-QA" (Reference 3), the qualification of the terminal block coating is questionable, it should be requalified or lR2 reapplied. This open item does constitute a potential safety-related lR1 issue. The additional issue of material traceability was completely addressed l by NSRS and the corrective actions taken will resolve the material lR1 traceability problems in the Electrical Maintenance Tool Room that I caused this concern. l IV. Root Cause The traceability of the RTV 3140 used on MR A-554518 was not correctly verified prior to use as required by SQA45, section 25.2 (Reference 7) and AI-11, Section 6.4.3.6.a (Reference 8). I Page 2 of 4

Ravision 2 s V. Generic Applicability Concern TAK-86-005 is an isolated incident and is not generically applicable to any other plant. VI. References 1. Maintenance Request (MR) Form no. A554518, " Coat Junction Box Terminal Blocks with 3140 RTV," dated August 18, 1985 (SMI-0-360-3 data sheets attached). 2. Special Maintenance Instruction SMI-0-360-3 " Coating of Junction Box Terminal Blocks", Revision 0, dated August 18, 1985. 3. Discrepancy Report No. SQ-DR-85-08-111R " Electrical Maintenance installed "No-QA" RTV-3140 on CSSC junction boxes and terminal strips on MR A-5544518," dated 8-28-85 reported by C. R. Stutz. 4. Nonconforming Item (NCI)' Tag No. N2-85-294 issued August 27, 1985 by Steve Campbell.

5. 0, AI-11. " Recommended Disposition of Nonconforming Items" submitted on August 26, 1985 by Steve L. West.

6. B. W. Hooper's memorandum to M. A. Skarzinski, "Sequoyah Nuclear Plant-NUREG 0588-Terminal Block Field Verification Sheets," dated January 3, 1986 (SS3 860103 810) (533 data sheets attached). 7. Standard Practice SQA45, " Quality Control of Material and Parts and Services," Revision 17 dated September 27, 1985, paragraph 25.2 " Material Traceability for MR/WR materials." 8. Administrative Instruction AI-11, " Receipt Inspection, Nonconforming Items, QA Level / Description Changes and Substitutions," Revision 33, dated August 6, 1985, paragraph 6.4.3.6.a Attachments 1 and 3, and Section 7. 9. Special Maintenance Instruction SMI 0-360-4 " Inspection of Junction Box Terminal Blocks," Revision 0, dated August 19, 1985. 10. R. W. 01 son's memorandum to D. W. Wilson, "Sequoyeh Nuclear Plant - Significant Condition Report SQNEQP8521 R -EQ Binder No. 2 SQNEQ-TB-001-Open Item Sheet 1 of SA," (S02 860728 898) dated July 28, 1986. 11. NSRS Report No. I-86-165-SQN, " Craftsmen Directed to Violate I Procedures, Use Tools Other Than Those Specified, and Use l Questionable QA Materials", dated March 17, 1986. I 12. Standard Practice SQA 45, " Quality Control of Material and Parts and l Services," Revision 18 dated November 21, 1985, Section 25.0 l " Material Traceability for MR Materials". IR1 Page 3 of 4

Revision 2 VI REFERENCES (continued) 13. Standard Practice SQA 45, " Quality Control of Material and Parts and l Services", Revision 21 dated June 3, 1986, Section 25.0 " Material l Traceability," Subsections 25.1 " Material Traceability After Issue l 25.2, " Material Traceability for MR/WR Materials", and 25.3 l " Material Traceability for Workplan Materials". l 14. H. L. Abercromble's memorandum to R. P. Denise, " Nuclear Safety l Review Staff (NSRS) Investigation Report No. I-86-165-SQN, l " Craftsmen Directed to Violate Procedures, Use Tools Other Than l Those Specified, and Use Questionable QA Material"", dated l May 21, 1986. 15. H. L. Abercrombie's memorandum to R. P. Denise, " Nuclear Safety l Review Staff (NSRS) Investigation Report No. I-86-165-SQN, lR1 " Craftsmen Directed to Violate Procedures, Use Tools Other Than l Those Specified, and Use Questionable QA Material"", dated l July 1, 1986. I 16. Discrepancy Report No. SQ-DR-86-04-088R dated April 16, 1986 l required a revision of AI-11 to adequately implement the NQAM. 1 Closed on June 16, 1986. I 17. Discrepancy Report No. SQ-DR-86-04-089R dated April 16, 1986, I required the revision of SQA 45 to adequately implement the NQAM. i Closed on July 1, 1986. l 18. Commitment Action Tracking System (CATS) Item No. 86171 l Response to NSRS Recommendation No. I-86-165-SQN-05 completed l September 8, 1986. I VII. Immediate or Long-Term Corrective Action Junction Box 3190 was recoated with RTV 3140 by WR B200741. lR1 (CATD //30401-SQN-01) lR1 i i Page 4 of 4

PAGE -199 TENNESSEE VALLEY AUTHORITY RUN TIME - 12:19:18 ECP3120J-ECPS121C OFFICE OF NUCLEAR P0HER RUN DATE - 10/05/86 .FERENCE EQUENCY - REQUEST EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS) lP - 1555 - RHM LIST OF EMPLOYEE CONCERN INFORMATION EGORY: OP PLANT OPER. SUPPORT SUBCATEGORY: 30401 PROCEDURE PROBLEMS KEYHORD A S GENERIC KEYHORD B H APPL QTC/NSRS P KEYHORD C l CONCERN SUB R PLT BBSH INVESTIGATION S CONCERN KEYHORD D NUMBER CAT CAT D LOC FLQB REPORT R DESCRIPTION .[d-85-112-001 OP 30401 N HBN YYYY SS TVA NUCLEAR POWER DEPARTMENT IS NOT SPECIFICATIONS HORKING IN ACCORDANCE HITH CONSTRUCT PROCEDURES K-FORM ION SPECIFICATIONS HHEN MAKING MODIF OPERATIONS T50020 ICATIONS AND ADDITIDHS. EG NO MAXIM GENERAL UM PULL TENSION IS SPECIFIED HHEN NU CLEAR P0HER DEPARTMENT PULLS A NEW C ABLE AND MINIMUM BEND RADIUS IS ALSO NOT SPECIFIED OP 30401 N SQN NNNN SS RTV APPLIED TO JUNCTION BOXES ON SMI 360-0 MAY NOT HAVE BEEN PROPERLY , ' A K-86-0 05 K-FORM APPLIED ON ALL JUNCTION BOXES. RTV USED HAS NOT QA LEVEL AND HAS EXCEED l ED IT'S SHELF LIFE. EMPLOYEE STATED i THAT SHELF LIFE HAS NOT A CONCERN A S HE HAS VERIFIED THAT THE RTV IN QU ESTION HILL IN FACT SET UP PROPERLY. i j 2 CONCERNS FOR CATEGORY OP SUBCATEGORY 30401 1 I 0 O e e 4

I' TVA EMPLOYEE CONCERNS REPORT NUMBER: 308.06-SQN SPECIAL PROGRAM REPORT TYPE: Sequoyah Nuclear Plant Element REVISION NUMBER: 2 TITLE: Subjourneyman/ Journeyman REASON FOR REVISION: Revised to incorporate SRP and TAS comments. Revision 1 Revised to incorporate SRP and TAS comments. Revision 2 PREPARATION PREPARED BY: W. L. Aycock 10/28/86 SIGNATURE DATE REVIEWS &Olsrsb -L,bi PEER: / [ SIGNATURE ' 6 ATE &' bl' disef itkb6 SIGNATURE DATE CONCURRENCES CEG-H:s / 3 l' '-{k Il-S-8f, SRP: M SIGNATURE DATE SIGNATURE

DATE APPROVED BY:

[# h N/A j ECSP MANAGER DATE MANAGER OF NUCLEAR POWER DATE l CONCURRENCE (FINAL REPORT ONLY)

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

I 2288T i

e i s TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT EMPLOYEE CONCERNS TASK GROUP OPERATIONS CEG Subcategory: Maintenance Element: Subjourneyman/ Journeyman Report Number: 308.06 SQN (Revision 2) IN-85-589-002 l I l Evaluator: William Aycock //IV.h4 William A cock Date I Reviewed by: /

/8/

/M8/[h4, l OPS CFg M p er Date Approved by:

1. /#1/86 W. R. Lagergren Date 1540T

~e+ - -. -

u. _. -,_

-m ._.--,.._..m_,,,,,,_,,_,,

Revision 2 I. Subjourneyman/ Journeyman This evaluation was performed to assess the concern on the use of l subjourneymen within the Office of Nuclear Power (ONP) at Sequoyah l Nuclear Plant (SQN). Similar concerns relating to the Office of Nuclear lR1 Construction (DNC) are addressed by the Management and Personnel CEG l Report 70100. l II. Specific Evaluation Methodology Concern IN-85-589-002 states, " Power division is using subjourneymen i level craft personnel to perform welding, wiring and other operations l which require a certified trained journeyman to perform properly. All lR1 crafts were alleged to be involved in this practice. No further details l available." l Evaluation of this concern centered on any possibility of adverse impact 1 on plant equipment resulting from use of unqualified personnel for i maintenance. Interviews were conducted with SQN maintenance supervisors I to determine the extent of their usage of subjourneymen and the work lR1 items assigned to them. Additional research was performed to verify l that critical work processes are governed by specific detailed l instructions. Note that in this report ONP is used to refer to the I maintenance organization in order to remain consistent with the I as-stated concern. l III. Findings Evaluation Results In 1982, an agreement was reached by TVA and the Tennessee Valley l Trades and Labor Council establishing the subjourneyman classifications l for construction. This agreement called for the subjourneymen to l perform " unskilled work" and not to use power tools. In 1983, a lR1 separate agreement was made to introduce subjourneyman categories into l ONP (Maintenance). Unlike the DNC agreement, it allows semi-skilled l work and use of power tools. " Semi-skilled" is a subjective term and l therefore it is difficult to determine what types of work are within the I subjourneyman's capabilities. SQN Maintenance supervisors stated that I subjourneymen are assigned such tasks as general shop cleanup, parts l retrieval, and assisting journeymen. The work that they perform in the lR2 category of assisting journeymen is under the direct supervision of the l journeyman and is signed for by the journeyman. l Any work performed by ONP maintenance is governed by procedures which l describe the necessary inspections and tests. Critical steps in any l maintenance activity are subject to independent verification, which is i itself controlled by Administration Instruction (AI-7) " Independent l Verification." The electrical section, the only SQN maintenance lR1 section, presently using subjourneymen, administers its signoff I procedures via Section Letter EMSL E-45, " Double Person Verification." l Page 1 of 2

Ravision 2 This document supports AI-7 and restricts signoff as verifier to l e journeymen, foremen, and engineers. Additional approvals may be l required by QC. Since there is no specific restriction placed on IR1 the tasks which subjourneymen are allowed to perform the verification l serves to assure that qualified craftsmen supervise all work. I Conclusions Although Sequoyah maintenance does employ subjourneymen at the present, I the agreements which authorized their use were not made until after I construction at the site was complete. The concern on the subject was l generated as a result of the difference between the ONP and DNC l agreements. The agreement does not place specific restrictions on the lR2 types of work to be performed by subjourneymen. There are, in place, I adequate procedural controls to prevent signoff by subjourneymen and lR1 to ensure that journeymen possess adequate qualifications. For these l reasons, this concern is considered not valid for SQN. l IV. Root Cause None identified. lR1 V. Generic Applicability The concern is not the result of a system-wide lack of commitments or IR1 procedures, and does not involve any hardware issues. l VI. References 1. QTC-ERT Investigation Report, Revision 3, Concerns PH-5-005-001, lR1 IN-85-589-002, and others l 2. SQN Administrative Instruction AI-7, Revision 2, " Independent lR2 Verification" l { 3. Sequoyah Nuclear Plant Electrical Maintenance Section Instruction lR1 Letter EMSL-E45, Revision 0, " Double Person Verification" l 4. TVA Employee Concerns Special Program Management and Personnel CEG lF1 Feport 70100 l VII. Immediate or Long-Term Corrective Action None required. lR1 l l Page 2 of 2

m

EFERENCE

- ECPS120J-ECPS121C TENNESSEE VALLEY AUTHORITY PAGE 221

REQUENCY

- REQUEST OFFICE OF NUCLEAR POWER RUN TIME - 12:19:18 EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS) RUN DATE - 10/03/86 NIP - ISSS - RUM LIST OF EMPLOYEE CONCERN INFORMATION sTEGORY: OP PLANT OPER. SUPPORT SUBCATEGORY: 30806 SUBJOURNEYMAN/ JOURNEYMAN KEYHORD A S GENERIC H APPL QTC/NSRS P KEYWORD B CONCERN SUB R PLT BBSH INVESTIGATION S CONCERN KEYWORD C NUMBER CAT CAT D LOC FLQB REPORT R DESCRIPTION KEYuORD D

N 589-002 OP 30806 N HBN NNY N IN-85-130-001 NS POWER DIVISION IS USING SUBJOURNEYMA INSTALLATION T50055 REPORT N LEVEL CRAFT PERSONNEL TO PERFORM H PERSONNEL FEELINGS ELDING, HIRING AND OTHER OPERATIONS QUALITY HHICH REQUIRE A CERTIFIED TRAINED JO EMPLOYEES URNEYMAN TO PERFORM PROPERLY. ALL C RAFTS HERE ALLEGED TO BE INVOLVED IN THIS PRACTICE. NO FURTHER DETAILS AVAILABLE.

1 CONCERHS FOR CATEGORY OP SUBCATEGORY 30806

TVA EMPIAYEE CONCERNS REPORT NUMBER: 310.03-SQN SPECIAL PROGRAN REPORT TYPE: Sequoyah Nuclear Plant Element REVISION NUNBER: 1 TITLE: Operations Procedures Need Clarification, Rewritten, and Used REASON FOR REVISION: Revised to SRP conuments and SQN corrective action response. Revision 1 i PREPARATION PREPARED BY: f& folE//% SIGNATURE DATE / REVIEWS PEER: Yf f$ $b [ SIGNATURE ' ITATE TAS XW Y ll ~ SIGNATURE DATE CONCURRENCES 3/86 CEG-H: w$MM ll-5-EC SRP: SIGNATURE DATE SIGNATURE

DATE APPROVED BY: e

/Afbf' lf* 'h N/A ECSP'MXNAGER DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)

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

1287T l

TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT EMPLOYEE CONCERNS TASK GROUP OPERATIONS CEG Subcategory: Operations / Operational (310) Element: Operations Procedures Need Clarification, Fewritten, and Used Report Number: 310.03 SQN Revision 1 IN-86-055-003 t /D!3/!Ib Evaluator: ( D. EP mith' Date Reviewed by: h## # //!$/ f4 OP CEG ber Dste

' 3 8[

Approved by: j W. R. Lagergren 'Date 1 1287T

Revision 1 I. Operations Procedures Need Clarification, Rewritten, and Used This repcrt contains only one Sequoyah generic concern that addresses a procedure revision / rewriting. The scope of this investigation was to review the Nuclear Safety Review Staff report I-85-415-WBN (attached) to verify its adequacy and completeness. II. Specific Evaluation Methodology One concern was reviewed and included in this element evaluation. IN-86-055-003 Hydrazine spill of 300 gallons in containment building. Implies concern with inadequacies in plant operations / procedure adherence / control of valve and systems operation. The methodology used for this evaluation was to review the NSRS report conducted on this WBN concern. The report recommendations were evaluated for their adequacy and completeness. The report recommendations were compared to the approved SQN procedures. SQN procedures were reviewed to ensure they incorporate the same type procedural or programmatic steps as the WBN recommendations. A review of the WBN generically related investigation and procedures was accomplished. Items reviewed are listed in the reference section of this report. Interviews with cognizant personnel were conducted to address the above listed concern. This report was completed in accordance with the Evaluation Plan for the Oparations Concern Evaluation Group and the Operations / Operational Subcategory Evaluation Plan. III. Findings Evaluation Results The spill occurred due to improper control of Steam Generator upper and lR1 lower tap-root valves to which temporary tygon tubing was attached. l l The tubing was installed for steam generator level indication while normal level indication was not available. The root valves were constantly open, instead of being opened only during the time a level reading was obtained. This set the conditions which allowed the tygon tubing to blow off the fitting when a leaky valve pressurized the steam generators. This occurrence was the second of this type within four days. I Page 1 of 4

e o

Revision 1 III. Findings (Continued) There were two recommendations identified in NSRS Report I-85-415-WBN: 1. Delayed Recurrence Control Execution, which states that management should emphasize to the plant staff that a recurrence control program is in place (CAR /DR system) that should be promptly used without hesitation to analyze events to determine root cause and generic applicability and to assure that decisive corrective action is taken to prevent recurrence. 2. Inadequate Procedural Controls, which states requirements should be clearly established and delineated in writing which provide criteria for the selection, installation, and use of tygon tubing in abnormal configurations for water level measurement. Specifically, a caution order should be issued to control the root , valves to which the tubing is attached. The above corrective action recommendations have been only partially addressed at SQN, as stated below: 1. There currently are programs and procedures which allow for assessment of corrective action, root cause, and generic applicability after a problem has been identified. These procedures are AI-12 Adverse Conditions and Corrective Actions; AI-18, Plant Reporting Requirements; SQN-84, Reportable Occurrences; and SQN-94, 10 CFR 21 Evaluation and Reporting Requirements. The plant reporting requirements instruction has recently been presented to all licensed operators in requalification training. 2. SQN presently has procedures (FHI-08, SOI-68.1B, SOI-74.lC, and SI-673) stipulating the use of tygon tubing for reactor coolant system level monitoring during RCS filling and draining in Mode 6 operation. However, there are no procedures or instructions to control the root valves associated w8.th the tygon tubing configuration allowed by the above procedures. There are no SQN administrative controls that address any other abnormal tygon l tubing configuration. Conclusion This concern, as addressed by NSRS Report I-85-415-WBN, generically involves root cause assessment of plant problems and procedural controls to assure proper selection, irstallation, and use of tygon tubing. Page 2 of 4 m-_-, ~ --__-m- ~,-----m-_

Revision 1 Conclusion (continued) It is important to note that the incident occurred at WBN, not SQN, and the NSRS report was issued to WBN and not SQN. On that basis, this concern is substantiated for SQN in that there are no procedural controls for the proper selection, installation, and use of tygon tubing outside of those procedures listed above. SQN has adequate procedures for root cause assessment and the plant reporting requirement-instruction has recently been presented to licensed operators in classroom training and will be presented in the future during requalification training. SQN Operations Group is planning on performing the corrective actions lR1 identified in Section VII of this report prior to plant startup. l However, it is not a restart requirement. l IV. Root Cause There is no identifiable SQN root cause because the event addressed by lR1 this concern has not occurred at SQN. This report has been written I because of generic applications to SQN from the WBN element report. l V. Generic Applicability This concern (IN-86-055-003) was identified as generically applicable to SQN from the WBN concern. Because of the fact that there is an identified procedural deficiency at both Watts Bar and Sequoyah Nuclear Plants, this concern is deemed generically applicable to Browns Ferry and Bellefonte Nuclear Plants. VI. References 1. NSRS Investigation Report I-85-415-WBN, dated September 19. - October 9, 1985, subject - Hydrazine Spill (Attached) 2. AI-12, Adverse Conditions and Corrective Actions, Revision 22, dated April 2, 1986 3. AI-18, Plant Reporting Requirements, Revision 43, dated March 14, 1986 i l l Page 3 of 4

Ravision 1 VI. References (Continued) 4. SQN-84, Reportable Occurrences, Revision 3, dated January 28, 1984 5. FHI-08, Recovery from Refueling, Revision 8 dated January 9, 1986 6. SOI-68.1B, Reactor Coolant System Filling and Venting, Revision 36, dated June 24, 1986 7. SOI-74.1C RHR Filling Reactor Cavity for Refueling, Revision 33, dated June 18, 1986 8. SI-673, Reactor Coolant System Level Verification Using Sight Glass or Tygon Hose, Revision 1, dated October 12, 1984 VII. Immediate or Long-Term Corrective Action Sequoyah Nuclear Plant Corrective Action Response: lR1 (CATD No. 31003-SQN-01) l 1. SOI-68.1B and SOI-74.1C and SI-673, concerning use of tygon i tubing on RCS system during MODE 5 or 6 operation, is adequate I since the level is monitored at all times. l 2. SOI-67-1 ERCW system concerning laying up the CS heat exchanger, I will be revised to add a note or caution to isolate the tygon l tubing when it is not being monitored. l 3. A CAUTION ORDER will be added to EHC tank to isolate the tygon l tubing when the level is not being locally monitored. l 4. A memorandum will be written to Plant Maintenance to cover any l use of tygon tubing not in Operations instructions such as WRs l and their instructions. l Page 4 of 4

TENNESSEE VALLEY AUTHORITY . NUCLEAR SAFETY REVIEW STAFF NSRS INVESTIGATION REPORT NO. I-85-415-WBN EMPLOYEE CONCERN IN-86-055-OO3 MILEST.ONE 1

SUBJECT:

HYDRAZINE SPILL DATES OF INVESTIGATION: Sectember 19-October 9. 1985 INVESTIGATOR: -\\0 M 86 g I i /o - f l_ffi REVIEWED BY: G. G. Brantley Date AhPROVED BY: ' _, ________ W _ _m_ 20 GT [2 M A. Harrison D te - ee 1 i ,-.-sy-_. ~ - --.4 = ..-_p.g m e ,-,._.g-Sc-._, ,.-_.y-_,

7 7 I.' BACKGROUND NSES has investigated Emolovee Concern No. IN-86-055-OOC which was communicated to the Quality Technology Comoany (OTC) in recconse to the Watts Ear Emolovee Concern Procram. The soecific concern analyced and discussec in this report was encressed to OTC ac follows: "1984 300 gallons of hydra:ine spilled in RBl. lower containment." OTC relaved to the NSRS that the individual who submitted this concern had no further information on the i nci dent. However, the. concern imolies inadequacies related to plant ocerations, procedure adherence, and/or control of valve and systems operation. ~ II. SCOPE The stooe of the investigation was. directed at verification of the event occurrence. determination of the root cause of the event if substantiated. assessment of the i ndustri al safety and health controls and actions associated with handling the hydra:ine scill, and review of the actions taken to prevent recurrence of the incident. During the conduct of the inquiry, enaminations were made of WBN Operations Section daily journals f or 1.123. as well as activity log books of the WBN ~ Building Services and Industrial Safety and Fire Pr_otection Engineering Sections. Ee7~1ews were also made of the procedures and records re15ted to the event occurrence to include the WEli Ha:ar_d Control In st ru c t i_on s, Operati nns Instructi ons. Admi ni st r ati ve Instructions. 1984 CAR /DR Logs, Clearance Sheets (f orm TVA 7C95), and Temporary Alteration Control Forms (form TVA 6C66). Additionally, interviews were conducted with cognicant NUC PR management and implement.ing personnel from the following WBN sections: Building S ervi _c es. Industrial Safety and Fire Protec* ion Engineering. Ocerat;cns. Instrument Maintenance, Quality Assurance, and Eny1neer ng. III.

SUMMARY

OF FINDINGS A. Based on the results of record reviews $nd personnel interviews. it was substantiated that on 7/21/84, a soill of steam generator layup water to the Unit i lower containment occurred. The voldme of the ~ scill was documented as being between C50 and 350 gallons and contained appronimately 160 parts per million (ppm) hydra:ine. The source of the spill was a burst tygon tube which was attached to steam generator No. I upper and lower tap-root valves f or the urpose of measuring layup-water levels due to inoperable normal-level monitoring instrumentation. It was verified that in accordance with the criteria of WBN Administrative Instruction A 3 15. "Temocracy Alterations." the Ocerations Section processed a Temocrary Altata*lon Control Fotm (No. 1-84-36-0) on 4/1/84 to document installation of the tygon tubing on all four steam i generators. B. By procedure, hydra:Ine is employed in the secondary side of the steam generator at concentrations of appronimatelv 150 ppm as an oxygen-scavenging agent. During the timeframe of the incident, the hydra:Ine solution was introduced into the steam generator from the i Unit 1 hydra ine supply tank via the chemical feed pumps and the l condensate feedwater system. There is no source of pumping concentrated hydra:ine directly into the containment building. The Industrial Safety Supervisor states that there is no known potential

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] ] C. Cleanuo of the spilled lavuo water by the Building Services personnel was initiated by the Ocerations Shift Engineer after termi nat i on of the leak source. blocking off the area with caution signs, and analysis of the hydra:Ine concentration by Engineering Section chemistry technicians. Actual cleanuo did not commence until the Industrial Safety Staff had been contacted for specific guidance. Building Services workers were advised as a purely precautionary measure to dilute the spill with DI water to below 100 ppm hydra:Ine and to wear protective clothing (rain suits and respirators) during the cleanuo. Records indicate that after dilution of the spill the hydra:ine concentration was only 60 pom. ~ Interviews with the cleanup personnel and a review of the Building ~ - Services Supervisor's activity. log book indicated that al'1 Industri al Safety Staff recommendations were properly imolemented. D. As previously discussed. the direct cause of the lavuo-water spill was due to the ructure of a tygon tube being utill:ed to measure the steam generator (S/G) No. I water l evel. Cognizant Operations and Engineering Section personnel indicate that the use of tygon tubing in this " abnormal configuration" is an acceptable practice for determining the fluid level in any tank when normal level-monitoring instrumentation is not available. From the unit operator's daily journal. it was noted that on 7/15/84 S/G No. 1 was filled with layuo water and nitrogen placed en it. No other Operations' daily journal entries regarding S/G No. I were made prior to the 7/21/85 entry on the tygon-tube rupture. Analysis of the coerational activities during this timeframe indicates that the S/G No. 1 f eedwater isolation valve was slowly leaking c,ausing a pressure j buildup in the S/G and tygon tube f rom the f eedwater system that ultimately resulted in the :tygon tube's rupture. Leakage of the feedwater isolation valve was also indicated by the Cogn1: ant Engineering Section personnel due to changes in S/G chemical l evel s and layuo water levels. However, rupture of the tygon tube would not have occurred if the tap-root valves to which the tygon was attached had been isolated. E. The review of Operations' daily journals also revealed that on 7/17/84 the tygon tube attached to measure layuc-water levels in the l No. 2 S/G blew off and caused a water leak which required isolation. Even though a similar event occurred just four days later (the 7/21/94 spill). reviews of the ICS4 CAR /DR log books verified that no long-term corrective actions were initiated to assure continued prevention of the event's recurrence.

However, records do Indicate that as a result of the 7/21/84 lavup-water spill. the on-duty,0cerations Shift Engineer issued a Caution Order l

(No. 10523) on the S/G tygon tubes which recuired isolation of the l upper and lower tap-root valves e:: cept when checking lavup-water levels. This Caution Order was kept in effect until. removal of the l tygon tubing from the four S/Gs on 8/10/84: and as stipulated in WBN Administrative Instruction AI-2.12. " Clearance Procedure." issuance l of the Caution Order was an appropriate immediate corrective action j for handling the " abnormal configuration." It should be noted that the clearance procedure is the method used in NUC PR for the i protection of personnel and ecuioment; and, specifically, the l caution orcer is utill:ed where ha:Grdous or abnormal conditions l e:: i st. I L

F l 3} IV. CONCLUS:CNS AND RECCMMENDATICNS A. Conclusions 1. The emolovee concern as stated was substantiated. Specifically, e conduct of this NSRS investigation verified that an accro::1 mate COO-gallon spill of S/G layup water containing hydra:Ine did in fact occur in 1984. However, the hydra:Ine conce,ntration of the layup water was at such small levels that there were no potenti al health hazards associated with the event. Cleanuo of the spill was appropriately managed under the cogni:ance of the ~ WBN Industrial Safety Staff, and the actions of the Operations ~ Section in handling the indicent (i. e.. isolating leak, posting area. obtaining chemical analysis of hydra:Ine concentration, initiating cleanup, and issuing a Caution Order on the S/G tygon tubing to orevent any additional spills of this nature during the remaining timef rame of the temporary system alteration) were satisfactory. 2. It was verified tnat S/G lavuo water was soilled on at least two I seoarate occasions (7/17/84, S/G No. 2: and 7/21/84, S/G No. 1) e due to problems with use of the tygon tubing. Even though the similar precursor event occurred, no immediate corrective actions were taken to prevent the second incident which resulted in the 3OO-gallon layuc-water spill. As a result of the 7/17/84 spill incident, actions should have been initiated to assess root cause and cengric applicability and st.e_;ts taken to as_jnMre e that futyre occurrences of this nature wer,e pronibited. rna-3. It was assessed that the use of tygon tubing fcr obtaining - visual indications of c=ntainer fluid levels is an acceotable temocrary configuration when normal level-monitoring instrumentation is not available. However, there were no established procedural controls identified which would succort ~ or assure procer selection. installation, and u,se of the tttbing.. E. Recommendations ICEE2315 WEU 91_I_EEla'Ed_BREMCCEDER_C901C91_EUEEM119D l WBN management should emphasize to the plant staff that a recurrence control program is in place (CAR /DR system) that should be promptly usec without hesitation to analyte events of this nature to determine root cause and generic apolicability and to assure that j decisive corrective action is taken to prevent recurrence. 1:EE: dis: WEN;Q2_ _lngdggggig_Ecgeggycal_Cgg$tgis l l Recu1rements should be clearly established and delineatec in writing I whicn crovide criteria for the selection. installation. and use of tvgen tubing in abnormal configurations for water-level measurement. In particular. the criteria should stipulate that any time tygon tubing is utill:ed. the root valves to which the tubing is attached must be controlled by an issued Caution Order which recuires that the, valves be opened.only while actually monitoring the fluid levels.

l 3 REFERENCE - ECPS120J-ECPS121C TENNESSEE VALLEY AUTHORITY PAGE 9 FREQUEllCY - REQUEST OFFICE OF NUCLEAR POWER RUti TJME - 12: ONP - ISSS - RUM EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS) RUli DATE - 10/ LIST OF EMPLOYEE CONCERi1 INFORMATI0!1 CATEGORY: OP PLANT OPER. SUPPORT SUBCATEGORY: 31003 OPR PROCEDURES NEED CLARIFICATION REWRITTEN & USED ~ S GEllERIC KEYWORD A H APPL QTC/NSRS P KEYWORD B CONCERil SUB R PLT BBSH INVESTIGATION S CONCERN KEYHORD C NUf1BER CAT CAT D LOC FLQB REPORT R DESCRIPTION KEYWORD D IN 05S-003 OP 31003 N HBN YYYN I-85-415-HBN NS 1984. 300 GALLONS OF HYDR 7.INE SPILL NONCONFORMANCE T50114 REPORT ED IN RB 81, LOWER CollTAINMENT. THI CORRECTIVE ACTIO S IMPLIES CONCERil HITH INADEQUACIES OPERATIOilS IN PLANT OPERATIONS / PROCEDURE ADHERE INDUSTRIAL S NCE/ CONTROL OF VALVE & SYSTEMS OPERA TION. CI HAS NO FURTHER INFORMATION NUCLEAR POWER CONCERN. i 1 CONCERNS FOR CATEGORY OP SUBCATEGORY 31003 I i ) D M W* w_w.gggg,ggg) Dg . tg,3p y.,. y, g,y,,,,, %,..ma wv. u= u.i s m aa a Tas a n n m s -. gegyppp h,h;ACF!P/,W see RUH DATP. J 10/8 % w'o n e s,,,e r n a u r ~? l'. +.,n ~~ - i F Oy'EEaCONCERNAPROGRAM45YSTEM CECPS)p m - 1555*- Run 4

x IST F EMPLOYEE ' CONCERN 'INFORMATION

I / / TVA EMPLOYEE CONCERNS REPORT NUMBER: 311.03-SQN SPECIAL PROGRAM REPORT TTPE: Sequoyah Nuclear Plant Element REVISION NUMBER: 1 TITLE: Expose Limits and Records REASON FOR REVISION: Revised to incorporate SRP comments and Sequoyah corrective action response. Revision 1 PREPARATION PREPARED BY: D. C. Hall, Jr. 10/17/86 l SIGNATURE DATE REVIEWS OY l$ Mlf/7 b SIGNATURE ' VATE oaf $ d /adi46 M i SIGNATURE DATE CONCURRENCES l0 3/ T& tCEG-Ht w SRP: e //.3-84 SIGNATURE DATE SIGNATURE

DATE APPROVED BY-MG/dA&b

+5 a/A ECSP MANAdER DATE MANAGER OF NdCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)

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

2288T l i

TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT EMPLOYEE CONCERNS TASK GROUP OPERATIONS CEG Subcategory: Health Physics Element: Exposure Limits and Records Report Number: 311.03-SQN, Revision 1 XX-85-007-001 XX-85-028-001 XX-85-048-003 Evaluator: D. C. Hall. Jr. 10/13/86 D. C. Hall Jr. Date Reviewed by: I / //// [ /A//5(( OPS C mb[ 6 ate' /Oh 3/8l. c% % # Approved by: W.R. Lager)r(n 'Dat6 I 1662T

4 I. Title Exposure Limits and Records, 311.03-SQN The scope of the evaluation consisted of the investigation of 3 previously investigated concerns and confirmation of the validity and completeness of those previous investigations. The concerns involved questions and/or allegations with regard to the following: - daily exposure limits - over-exposed employees being laid-off due to their exposure levels. - H.P. authority to change exposure authorization - Unmonitored exposure to radiographic operations. The evaluation of the concerns and previous investigations consisted of a retica of the concerns and investigation methodology, review of applicable regulatory and TVA requirements and procedures, and interviews with cognizant SQN personnel. The concerns evaluated herein IR1 are assigned solely to the Operations CEG. II. Specific Evaluation Nethodology Concern XI-85-007-001 states: Question daily limits of acceptable radiation exposure at Sequoyah and wonders if they will be the same here at Watts Bar? TVA does not have daily dosage limits; it has quarterly and yearly dosage limits. There were numerous cases of over-exposure about 2-3 yeses ago. When over-exposed, employee will be laid off. This is the corrective action TVA uses for over-exposure at Sequoyah. C/I has no further information. Concern XX-85-028-001 states: While at another TVA facility individual was exposed to the maximum amount of radiation. RWP was adjusted by Health Physics to reflect an increase in radiation allowance. (name and j details known by QTC). Concern XX-85-048-003 states: At Sequoyah, C/I was exposed to radiation l during X-ray of pipe weld since neither TLDs nor other types of I dosimeters were required to be worn during this time period 2, 1978/1979. C/I is concerned over dosages C/I, or other employees there may have received during RT of pipe welds. No follow-up required. The evaluations of the concerns assigned to element 311.03-SQN were l performed in accordance with the Operations CEG Evaluation Plan and the lR1 Health Physics Subcategory Evaluation Plan. l All K-Forms and previous reports and investigations assigned to element 311.03-SQN were evaluated. Page 1 of 6

The evaluations of the concerns consisted primarily of a review of previously conducted NSRS, QTC, and/or line investigations. The validity of the previous investigations was verified by interviews and reviews of applicable procedures and regulatory requirements. As part of the evaluation of concern XX-85-007-001, the previous line management investigation of Watts Bar specific concern IN-85-301-006 was also evaluated. IN-85-301-006, in part, raises the same concern as XX-85-007-001, specifically the question of daily dose limits of SQN and WBN; therefore both concerns and the applicable previous investigations were evaluated. The findings and conclusions associated with the evaluation of XX-85-007-001 should be considered as fully adequate to address and resolve concern IN-85-301-006. III. Findings Evaluation Results A. XX-85-007-001 raises concerns regarding the daily limits of lR1 acceptable radiation exposure at Sequoyah and raises the question, "Will the limits be the same at Watts Bar?" In addition, XX-85-007-001 raises a concern about numerous over-exposures at Sequoyah and states that over-exposed employees are " laid-off." Line management investigations were performed regarding these concerns (Re: memo dated 1/22/86, E. A. Belvin to W.H. Thompson, L61-860121-805, and memo dated 2/12/86. E. A. Belvin to W. H. Thompson, L61-860204-803.) Federal regulations do not require daily dose limits. Title 10 Code IR1 of Federal Regulation Part 20.101 (10 CFR 20.101) establishes l quarterly dose limits and guidelines for total lifetime dose limits. TVA implements the 10 CFR 20 requirements through the TVA Radiological Protection Plan (RPP). The RPP only establishes quarterly and yearly dose limits. These requirements apply to all TVA plants. Dose limits are established at SQN in Sequoyah Radiological Control Instruction 1 (RCI-1). As with the RPP, no requirement for daily dose limits lR1 exists. The only reference to a daily limit is in regard to Radiation Work Permit (RWP) requirements, and states that personnel exceeding lR1 50 mrem per day must have an RWP. Regarding the concern that there were numerous cases of over-exposures at SQN about 2-3 years ago, the line investigation indicated that there have been no cases of personnel over-exposure in excess of regulatory limits at SQN. This was confirmed by SQN Health Physics on 8/13/86. It was also stated by the line report and confirmed that at SQN, as lR1 well as all other TVA facilities, it is possible for an employee to i l be laid-off or terminated if they exceed or come close to established l exposure limits. When an employee is over-exposed or is close enough i to his/her exposure limit to preclude any further exposure, plant l policy is to find work for that employee for the remainder of the calendar quarter in an area where additional exposure to radiation is not possible. In rare cases, when no work in the employees particular skills exists outside of the radiologically controlled areas, the plant has no recourse other than layoff or termination of IR1 Page 2 of 6 l l i

c the employee. This action, though regrettable, is necessary to meet regulatory requirements and serve the best health and safety interests of the employee. Health Physics management at SQN indicated that, to their knowledge, no permanent TVA employee at SQN has ever been terminated or laid-off due to high exposure. This evaluation I determined that the SQN line report adequately addresses the scope of l the concern as stated, and concurs with the findings and conclusions lR1 of the report. l B. XX-85-028-001: This concern regarding an employee receiving the " maximum amount of radiation" was previously investigated by ERT (re: memorandum from K. W. Whitt to H. L. Abercrombie dated 12/23/85, Nuclear Safety Review Staff Investigation Report Transmittal). In addition to investigation of the concern, the ERT report brought to l attention several deficiencies with 1984 SQN RWP time sheets. NSRS and SQN addressed these in follow-up investigations (Re: NSRS lR1 report #XX-85-028-001 & Sequoyah responses memorandums from K. W. Whitt to H. L. Abercrombie dated 1/16/86 and 3/3/86). With regard to the concern that the CI was exposed to the maximum IR1 amount of radiation, the ERT investigation reviewed RWP time sheets I and could not substantiate that the CI or any other individual had been exposed to radiation in excess of established limits. Additional interviews with the CI indicated his concern centered on item 2 of the RWP time sheet special instructions. This item states "Do not exceed (blank) MREM per entry or 50% of RAD" (remaining allowable dose). One of the applicable RWP time sheets did show that this amount had been changed by the H.P. section. The CI was made aware that the amount shown in item 2 is just a guideline based on what the H.P. determines necessary to accomplish the job. The procedural l requirements of SQN RCI-14 do not prohibit the cognizant H.P. l representative from revising the exposure allowance if it is so IR1 dictated by changing work conditions. Although the change was made to I the timesheet the CI was not put in a situation which would have l allowed him to exceed his RAD. When presented with this information lR1 the CI agreed that Health Physics had not acted improperly in changing i the RWP time sheet. During the course of the investigation ERT did note discrepancies in l handling time sheets. The discrepancies consisted of several apparent lR1 violations of QA record requirements and included: - inaccurate / incomplete or missing information - improperly made corrections - inconsistencies in handling of records IR1 ^ - accountability errors - procedural noncompliance Sequoyah's response to NSRS regarding the discrepancies included a commitment to revise appropriate HP procedures regarding QA record requirements. Revision to SQN HP ASIL-4 to accomplish this was confirmed. The following should also be noted: Page 3 of 6

- NRC has no requirement stating that RWP time sheets should be QA records. (per SQN HP section) - Current SQN procedures do not require all RWP time sheets be maintained as QA records (HPSIL-7 and ASIL-4) lR1 - Regulatory Guide 1.16 requires that at least 80% of site dose (man-rem) be assigned to specific functions. The 1984 SQN RWP timesheet total accounted for 98.9% of the total site dose. - RWP time sheet doses are not used as official dose records. TLD data is the official record. In an interview with SQN Health Physics management personnel it was l stated that QA record requirements regarding RWP timesheets are not I clearly defined in plant procedures and that there seems to be a lR1 conflict of opinions between NRC, TVA Central Office QA, and SQN l plant management as to what extent QA record requirements should l apply to RWP timesheets. l The NSRS & ERT evaluations were confirmed and this evaluation concurs with their findings. C. XX-85-048-003: This concern was previously investigated (RE: memorandum from J. W. Hufham to W. H. Thompson, dated lR1 September 27, 1985, L05-850926-803). Based on information provided l by QTC, the CI was not present within the regulated area set up by the radiographers during any radiographic operations. The boundaries are set up such that the maximum exposure rate at the boundaries is less than 2.0 mr/hr, in accordance with the requirements for lR1 10 CFR 20.105. In addition, radiographers are trained in controlling radiographic operations according to the requirements of 10 CFR 34. Based on the above information, no dosimetry outside the regulated area boundary was necessary. Anticipated doses at the boundary, even if the CI had been continually present there, would have been below the levels where monitoring is required. This evaluation concurs with the findings of the previous investigation. Conclusions With the exception of one item in concern number XX-85-007-001, none of the concerns assigned to element 311.03-SQN was validated. The item in XX-85-007-001 was validated, in that the plant does have the authority l j and ability to lay-off or terminate an employee who is close to or has l exceeded his/her exposure limit when no work in his/her skill exists l outside of the radiologically controlled areas. No permanent TVA lR1 employee at SQN has ever been subjected to this action, but the plant I has and will continue to have this option in order to ensure regulatory compliance and to maintain the health and safety interests of its employees. The authority to take this action is completely legal, justified, proper, and warrants no corrective action. l l Page 4 of 6

r In addition to validation of the item in XX-85-007-001, this evaluation lR1 also concludes that the possibility of deficiencies in the control and handling of RWP time sheets exists. The deficiencies identified by the l ERT report have, in part, been resolved by revisions to SQN ASIL-4, l specifically those deficiencies pertaining to transcription of RWP l timesheets. There still remains the lack of a clear definition of QA l record requirements for RWP timesheets and the problem of plant employees l not entering data on timesheets according to QA record requirements. l Employees do receive training in QA record procedures (GET-4) and are lR1 instructed that RWP timesheets must be used according to QA record I requirements (GET-2.2); however, the frequency of improper entries of RWP l timesheets indicates a need to identify the cause of this problem, I including an evaluation of the existing training program. It should also i be noted that the deficiencies identified in the ERT report are not I within the scope of concern XX-85-028-001 as stated and do not, l - therefore, constitute validation of the concern. This evaluation fully concurs with the findings and conclusions of all previous investigations. No additional problems or concerns other than those already discussed were identified. None of the concerns evaluated in this report affect the safe operation lR1 of the plant. l IV. Root Cause Concern XX-85-028-001: The root cause of the QA record problems identified by ERT with regard to RWP time sheets appears to be, primarily, a lack of knowledge of or disregard for the QA requirements lR1 governing the maintenance of QA documents. The problem is compounded by l the fact that not all time sheets are required to be maintained as QA documents, a fact which may cause confusion among plant workers and HP personnel responsible for the time sheets. No other concerns were validated which require root cause evaluation. V. Generic Applicability Within the scope of the concerns stated herein, the findings of this l evaluation indicate that the concerns pertain to isolated events specific to l SQN. No evidence was four' that similar situations exist at other plants. i Regarding the findings of the ERT report it is concluded that the deficiencies identified constitute a weakness in QA record requirements and should be evaluated for generic applicability at other TVA facilities utilizing RWP timesheets. Operations CEG report 311.04-SQN also addresses l generic applicability of RWP timesheet deficiencies. Page 5 of 6 l L

References A. Title 10 Code of Federal Regulation Part 20 B. Title 10 Code of Federal Regulation Part 34 C. Sequoyah Nuclear Plant, Radiological Control Instruction 1 (RCI-1) D. Sequoyah Nuclear Plant, Radiological Control Instruction 14 (RCI-14) E. TVA Radiological Protection Plan (RPP) section 3.0 F. Sequoyah Administrative Instruction 7 (AI-7) G. Sequoyah Health Physics Administrative Section Instruction Letter 4 (ASIL-4) H. Memorandum to W. H. Thompson from E. A. Belvin dated 1/22/86 (L61 860121 805) I. Memorandum to W. H. Thompson from E. A. Belvin dated 2/12/86 (L61 860204 803) J. Memorandum to K. W. Whitt from H. L. Abercrombie dated 1/16/86 K. Memorandum to H. L. Abercrombie from K. W. Whitt dated 3/3/86 L. Memorandum to H. L. Abercrombie from K. W. Whitt dated 12/23/85 (ERT report XX-85-028-001 attached) M. Memorandum to W. H. Thompson from J. W. Hufham dated 9/27/85 (LOS 850926 803) VII. Immediate or Long-Term Corrective Action Sequoyah's response is as follows: The QA record requirements for RWP timesheets is disseminated to all l personnel utilizing the timesheets via the General Employee l Training (GET) course GET-002.2 Level II IIealth Physics Training. I During the practical factors portion of the class, all personnel I must utilize the RWP timesheet and are evaluated on proper timesheet l sign-in and sign-out. They are also instructed in the required l method for making corrections to a QA document. lR1 1 Health Physics management response regarding RWP timesheet requirements l will be included in their response to 311.04. I Page 6 of 6

~ REFERENCE - ECPS120J-ECPS121C TENNESSEE VALLEY AUTHORITY PAGE 9234. FREQUENCY - REQUEST OFFICE OF NUCLEAR POWER RUN TIME - 12:19: ONP - ISSS - RHM EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS) RUN DATE - 10/05/ LIST OF EMPLOYEE CONCERN INFORMATION l :ATEGORY: OP PLANT OPER. SUPPORT SUBCATEGORY: 31103 EXPOSURE LIMITS AND RECORD 5 S GENERIC KEYHORD A j H APPL QTC/NSRS P KEYHORD B CONCERN SUB R PLT BBSH INVESTIGATION S CONCERN KEYHORD C NUMBER CAT CAT D LOC FLQB REPORT R DESCRIPTION KEYHORD D XX 007-001 OP 31103 N SQN NNNY QUESTION DAILY LIMITS OF ACCEPTABLE HEALTH PHYSICS .i T50086 REPORT RADIATION EXPOSURE AT SEQUOYAH AND H SAFETY CONDITION ONDERS IF THEY HILL BE SAME HERE AT OPERATIONS HATTS BART TVA DOES NOT HAVE DAILY RADIATION PROTC i DOSAGE LIMITS; IT HAS QUARTERLY AND YEARLY DOSAGE LIMITS. THERE HERE NU MEROUS CASES OF OVER EXPOSURE ABOUT 2-3 YEATS AGO. WHEN OVER-EXPOSURED, EMPLOYEE HILL BE LAID OFF. THIS IS 3* THE CORRECTIVE ACTION TVA USES FOR OVER-EXPOSURE AT SEQUOYAH. CI HAS N O FURTHER INFORMATION j XX 028-001 OP 31103 N SQN NNNN NS WHILE AT ANOTHER TVA FACILITY INDIVI HEALTH PHYSICS j T50036 K-FORM DUAL HAS EXPOSED TO THE MAXIMUM AMOU HEALTH PHYSICS NT OF RADIATION. RHP HAS ADJUSTED B HEALTH PHYSICS Y HEALTH PHYSICS TO REFLECT AN INCRE EMPLOYEES ASE IN RADIATION ALL0 HANCE. (NAME A i ND DETAILS KNOHN BY QTC) XX 048-003 OP 31103 N SQN NNYN XX-85-048-003 NS AT SEQUDYAH, C/I HAS EXPOSED TO RADI HEALTH PHYSICS T50073 REPORT ATION DURING X-RAY OF PIPE HELD. SI NONCONFORMANCE NCE NEITHER TLD'S NOR OTHER TYPES OF OPERATIONS DOSIMETERS HERE REQUIRED TO BE HORN GENERAL DURING THIS TIME PERIOD, 1978-EARLY 1979, C/I IS CONCERNED OVER DOSAGES C/I, OR ANY OTHER EMPLOYEES THERE M AY HAVE RECEIVED DURING R T OF PIPE HELDS. NO FOLLOH-UP REQUIRED. j 3 CONCERNS FOR CATEGORY OP SUBCATEGORY 31103 1 i i 1 l

TVA EMPLOYEE CONCERNS REPORT NUMBER: SWEC-SQN-05 SPECIAL PROGRAM REPORT TYPE: Sequoyah Nuclear Plant Element REVISION NUMBER: 0 TITLE: Testing and Event Documentation REASON FOR REVISION: N/A SWEC

SUMMARY

STATEMENT: The items in this report were identified by the Nuclear Regulatory Commission (NRC) and were included in the Stone & Webster Engineering Corporation (SWEC) systematic analysis. All items evaluated within this report were verified to be adequately addressed and were closed by the NRC. PREPARATION PREPARED BY: ibf3{fffC SIGNATUR$ DATE REVIEWS PEER: WE R Jo -?/- % SIGNATURE DATE l l l AG SIGNATURE DATE CONCURRENCES CEG-H: M

/=t/ f 6

//~ 3

85 SRP:

m SIGNATURE DATE SIGNATURE

DATE APPROVED BY-W/(/ flk

/l-5-E(o NiA ECSP MANAGER DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)

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

2242T

TENNESSEE VALLEY AUTHORITY WATTS BAR NUCLEAR PLANT EMPLOYEE CONCERNS TASK GROUP OTHER SITES CEG Element

Title:

Testing and Event Documentation SWEC Concerns: A02841018005-001 A02841018005-002 Source Document: NRC Inspection Report 50-327, 328/84-25 Report Number: SWEC-SQN-OS Evaluator: W 9! b J. J. Knightly Date Reviewed by: '/My 9//2/ f(, A. G. Debbi bat'e 9!/MM Approved by: W D' te R. C. Sauer a 1760T l l L

Rsport SWEC-SQN-05 NRC Report 50-327/84-25 and 50-328/84-25 I. Introduction During a routine inspection of August 6 to September 5 and October 4-5, 1984, the Nuclear Regulatory Commission (NRC) identified several violations (327, 328/84-25-01, -02, and -03) which were included in the Stone & Webster Engineering Corporation (SWEC) systematic analysis: (A) A02841018005-001 - Testing of the Residual Heat Removal (RHR) Pump (B) A02841010005-002 - Inadequate review of a reportable occurrence Information on the background, the corrective actions taken, the verification methodology, the verification analysis, the completion status, and any pertinent references for these two violations is included in this report. II. Verification of the SWEC Issues A. A02841018005-001, Testing of the RHR Pump 1. Background - The NRC inspector determined that on July 10, 1984, the 2A-A RHR pump was started for test purposes before the establishment of the correct valve lineup as required by Surveillance Instruction (SI) 267.74.2, " Inservice Pressure Testing of RHR System - Outside Containment." This was identified as violation 84-25-03. 2. Corrective Actions Taken - Sequoyah Nuclear Plant (SQN) stated that corrective actions were immediately taken by stopping the RHR pump, completing the valve lineup required by SI 267.74.2, and restarting the pump for the test on July 10, 1984. SQN also stated that priority sheets, which are issued daily to inform plant sections of work scheduled so that coordination between plant sections can be maintained, will be more specific in the requirements for the performance of future surveillance tests. 3. Verification Methodoloqv - The SWEC concern identified for Employee Concerns Task Group (ECTG) verification was stated as follows: RIMS Number Issue RIMS Item A02841018005 Failure to properly implement RIMS-001 operational requirements (correct valve lineup not established, technical specification requirements violated several times) Page 1 of 3

+ ECTG reviewed applicable procedure and the SQN Compliance Licensing files for internal and external correspondence related to this issue. This review of the pertinent documentation formed the basis for this verification activity. 4. Verification Analysis - The ECTG review of the pertinent documents indicated that the NRC item was adequately resolved. The incorrect valve lineup occurred at a time when the 4 surveillance instruction (SI) was a new instruction which required a valve lineup somewhat different than that of the usual system operating instructions. The SI was revised to i state clearly to align the RHR system and start the RHR pump in accordance with the surveillance instruction. Af ter correcting the value lineup, the RHR pump was restarted without incident. NRC closed the violation December 1984 (reference D). 5. Completion Status - Based on the SQN corrective actions, compliance with requirements, and NRC closure of the item, no further action on this item is required. This item is closed. B. A02841010005-002, Inadequate Review of a Reportable Occurrence I 1. Background - The NRC inspector noted than an Licensee Event Report (LER) (50-327/84055) concerning breaches of the Auxiliary Building Secondary Containment Enclosure (ABSCE) was inadequate in that the Licensee's investigation of the LER was incomplete. A breach of the enclosure which had occurred on August 17, 1984, was not identified by SQN during their investigation of tho identical event occurring on August 20, 1984. Subsequently, a third identical breach was identified September 5,1984, resulting in an additional LER (50-327/84053). NRC found that j SQN corrections to the formal controls were not instituted until af ter the third event and three weeks after the initial event, i Failure to maintain integrity of the ABSCE and to conduct an adequate review of a reportable occurrence were NRC violations 84-25-01 and 84-25-02. l 2. Corrective Actions Taken - SQN outlined management actions and controls which had been implemented before the initial event described in the NRC violation, and additional controls implemented September 1984 including revisions to Plant Technical Instruction TI-77 (Reference E) to list all ABSCE I doors and to document all fire barrier breaches and ABSCC breaches on the same form. SQN stated that the events leading up to the LER were examined and reported in a revised LER 84055, l and that the Compliance Staff will continue to perform l investigations for reportable conditions in a professional and conscientious manner. This violation was considered to be an isolated case. e l Page 2 of 3 1 9y.-, ,,wi ---,w ,,,.,.m., _---e,.,~ yr.,,,w-. m.-. ..-m.- .-w,. ,,,..mw., c,,-e-gr,

i \\ 3. Verification Methodology - The SWEC concern identified for ECTG verification was stated as follows: RIMS Number Issue RIMS Item A02841010005 Failure to conduct adequate RIMS-OO2 review of a reportable occurrence and inadequate management attention to ensure prompt effective corrective action ECTG reviewed the SQN Compliance Licensing files for internal and external correspondence related to this issue, LER files, and NRC statusing and closure files. This review of the pertinent documentation formed the basis for this verification activity. 4. Verification Analysis - The ECTG review of the pertinent documents indicated that the NRC items were adequately resolved. A revised LER 84055 clarified the events leading to the inadequate LER, and described the management actions and controls implemented before the initial event described in the NRC violation. Corrective actions were accomplished as described in II-8.2 above. NRC found the SQN responses to be acceptable and corrective action complete. Violation 84-25-02 was closed in Report 85-26, dated September 6, 1985. At this time, NRC also noted "an improvement in the quality of SQN's LER submittals" [ Reference C, page 2], Violation 84-25-01, Failure to maintain integrity of the ABSCE, was closed December 1984 [ Reference D]. 5. Completion Status - Based on the SQN corrective actions, compliance with requirements, and NRC closure of the violations, no further action on this item is required. This item is closed. III. References A. NRC Inspection Report 50-327/84-25 and 50-328/84-25, dated October 17, 1984, from R. C. Lewis to H. G. Parris B. "SQN Nuclear Plant, Units 1 and 2 - NRC-OIE Region II Inspection Report 50-327/84-25 and 50-328/84 Response to Violations," dated November 23, 1984, from J. A. Domer to J. P. O'Reilly C. NRC Inspection Report Nos. 50-327/85-26 and 50-328/05-26, dated September 6, 1985, from R. D. Walker to H. G. Parris D. NRC Inspection Report Numbers 50-327/84-35 and 50-328/84-35, dated December 28, 1984, from D.M. Verrelli to H. G. Parris. E. SQN Technical Instruction TI-77, Breaching the Shield Building, ABSCE, or Control Building Boundaries. t Page 3 of 3 l

TVA EMPLOYEE CONCERNS REPORT NUMBER: SWEC-SQN-18 SPECIAL PROGRAM REPORT TYPE: Sequoyah Nuclear Plant Element REVISION NUMBER: 0 TITLE: Documentation of Inspection REASON FOR REVISION: N/A SWEC

SUMMARY

STATEMENT: The items in this report were identified by the Nuclear Regulatory Commission (NRC) and were included in the Stone & Webster Engineering Corporation (SWEC) systematic analysis. All items evaluated within this report were verified to be adequately addressed and were closed by the NRC. PREPARATION PREPARED BY: %cl 4^ cu%WPu io/n/t6 SIGNATURE I DATE REVIEWS PEER: W P >% n-n- n SIGNATURE DATE TAS: $$N /M ll l h r SIGNATURE DATE ~' CONCURRENCES CEG-H: &v !!l2ltfe //~ 86 SRP: W SIGNATURE DATE SIGNATURE

DATE APPROVEDBg

/ / [P/hl /[*6'8b N/A ECSP MANAGER DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)

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

2242T

e b o TENNESSEE VALLEY AUTHORITY WAITS BAR NUCLEAR PLANT EMPLOYEE CONCERNS TASK GROUP OTHER SITES CEG Element

Title:

Documentation of Inspection SWEC Concerns: A07841217002-001 A02841217002-002 Source Document: NRC Inspection Report 50-327, 328/84-33 Report Number: SWEC-SQN-18 T!M[N Evaluator: J. J. Knightly Date 9/J 3/((, Reviewed by: n A. G. DebbagS 'Dath Approved by: 9[JJ/g6 R. C. Saue /Dat4 1758T

O Report SWEC-SQN-18 NRC Report 50-327/84-33 and 50-328/84-33 I. Introduction During a routine Nuclear Regulatory Commission (NRC) inspection in the area of worker concerns, October 30-31, 1984, the inspector identified two violations (327, 328/84-33-01 and -02) which were included in the Stone & Webster Engineering Corporation (SWEC) systematic analysis: (A) A02841217002-001 - Inadequate inspections on Fifth Emergency Diesel Generator batteries (B) A02841217002-002 - Inadequate documentation of the Megger Daily Calibration Information on the background, the corrective actions taken, the verification methodology, the verification analysis, the completion status, and any pertinent references for both of these violations is included in this report. II. Verification of SWEC Issues A. A02841217002-001, Inadequate Inspections on Fif th Emergency Diesel Generator Batteries l 1. Background - The NRC inspector determined (reference A) that the batteries for the Fif th Emergency Diesel Generator were not inspected in accordance with Inspection Instruction II-19, " Battery Inspections", from January to June of 1982. During this time period, Sequoyah Nuclear plant (SQN) acknowledged that inspections were not performed and stated (reference B) that it was because the specific gravity of the batteries was being j changed with the assistance of a vendor to satisfy NCR 2003 (closed July 5, 1983). However, the batteries were on charge during this period and were to have been inspected in accordance with II-19. The instruction II-19 was in an inactive status until March 1982, and not implemented until June. NRC wrote violation 327, 328/84-33-01 as a result. 2. Corrective Actions Taken - SQN stated (reference B) that inspections by a certified inspector have been performed and properly documented since June 1, 1982, and that the stored equipment will continue to be inspected in accordance with procedure. The delays in activation of the procedure had been tolerated because (1) specific gravity not changed until January 29, 1982; (2) no inspections possible for six week period while electrolyte mixed properly; and (3) certified inspector not available until May 25, 1982. t Page 1 of 3

e b 3. Verification Methodology - The SWEC concern identified for Employee Concerns Task Group (ECTG) verification was stated as follows: RIMS Number Issue RIMS Item A02841217002 Inspection Instruction RIMS-OO1 II-19 was issued too late to assure batteries are placed on charge within 60 days of delivery ECTG reviewed the Sequoyah Compliance Licensing files for internal and external correspondence related to this issue. This review of the pertinent documentation formed the basis for this verification activity. 4. Verification Analysis - The ECTG review indicated that the NRC item was adequately resolved as follows: The training / certification records of QC inspectors and inspection records for the batteries were examined during a later NRC inspection (reference C) and were considered acceptable. The batteries had been transferred from storage to nuclear power and were being maintained and inspected under the nuclear power surveillance program during this NRC verification inspection. The NRC found the overall SQN rosponse and corrective actions to be acceptable and closed the violation in Report 86-21 (Reference C). 5. Completion Status - Based on the SQN corrective actions, compliance with reqJirements, and NRC closure of the item, no further action on this item is required. This item is closed. B. A02841217002-002, Inadequate Documentation of the Meqqer Daily Calibration 1. Background - The NRC inspector determined that the "Megger Daily Calibration Log" had not been signed by the QC inspector as required by SQN Construction Procedure CP-P4, Appendix A, "Megger Daily Calibration Log.' The QC incpector had signed a j related form from II-32 " Inspections of Materials in Storage and Housekeeping Conditions" to document the inspection performance. Failure to have signed the CP-P4 Megger Daily Calibration Log was identified as violation 84-33-02. i 2. Corrective Actions Taken - SQN stated (reference B) that the staff member had received instructions in the proper completion of the "Megger Daily Calibration Log" from CP-P4, Appendix A. SQN Construction Procedure CP-P4 was revised on January 23, 1985, to clarify the daily comparison checks and to require annual calibration of the megger instruments. I l l Page 2 of 3

3. V ritication Methodoloov - The SWEC concern identified for ECTG verification was stated as follows: RIMS Number Issue RIMS Item A02841217002 Failure to sign the RIMS-OO2 Megger Daily Calibration Log. Issue was failure to document proper Calibration of megger. ECTG reviewed the Sequoyah Compliance Licensing files for internal and external correspondence related to this issue. This review of the pertinent documentation cnd verification of the revision to Construction Procedure CP-P4 formed the basis for this verification activity. 4. Verificacion Analysis - The ECTG review of the pertinent documents indicated that the SQN corrective actions for this NRC item were acceptable. The NRC verified (reference C) that the training of the QC inspectors had been accomplished and that Construction Procedure CP-P4 had been revised to clarify the daily checks and to require a yearly calibration of megger instruments. The NRC found the SQN actions to be acceptable and closed the violation in Report 86-21, dated May 1986 (reference C). 5. Completion Status - Based on the SQN corrective actions, compliance with requirements, and NRC closure of the item, no further action: on this item is required. This item is closed. III. References A. NRC Inspection Report Nos. 50-327/84-33 ana 50-328/84-33, dated December 13, 1984 from C. M. Verrelli to H. G. Parris B. TVA Memorandum "Sequoyah Nuclear Plant, Units 1 and 2 - NRC-OIE Region II Inspection Response to Violations," dated January 18, 1985, from D. L. Lambert to J. P. O'Reilly C. NRC Inspection Report Nos. 50-327, 328/86-21, dated May 1986 i l l Page 3 of 3 i

TVA EMPLOYEE CONCERNS REPORT NUMBER: SWEC-SQN-31 SPECIAL PROGRAM i REPORT TYPE: Sequoyah Nuclear Plant Element REVISION NUMBER: 0 TITLE: Nonconformance Reporting REASON FOR REVISION: N/A SWEC

SUMMARY

STATEMENT: The item in this report was identified by the Nuclear Regulatory Commission (NRC) and was included in the Stone & Webster Engineering Corporation (SWEC) systematic analysis. The item evaluated within this report was verified to be adequately addressed and will be ready for NRC closure following implementation of the corrective action documented in the TVA Nuclear Performance Plan. PREPARATION PREPARED BY: &Q( ( &'c){t.kj /Ch9f$Y SIGNATUR$ DATE REVIEWS PEER: Wf /NM /O-N-9 L SIGNATURE DATE TAS: SY)Ih ffY d t t SIGNATURE DATE CONCURRENCES CEG-H: !h-is to/Jo/g g, SRP: ( aute /

3d N SIGNATURE DATE SIGNATURE
DATE APPROVED BY-Y llS~tY&

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

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

2242T i i I

~

y b TENNESSEE VALLEY AUTHORITY WATTS BAR NUCLEAR PLANT EMPLOYEE CONCERNS TASK GROUP l OTHER SITES CEG Element

Title:

Nonconformance Reporting SWEC Concerns: A02850606005-001 Source Document: NRC Inspection Report 327, 328/84-38 Report Number: SWEC-SQN-31 9fkN Evaluator: D Q J. J. Knightly Date l Reviewed by: 9ff[f[,_ A. G. Debbac 'Date Approved by: MW 9i R. C. Sauer Date 1783T ~

Nonconformance Reporting I. Introduction During an inspection covering the period of March 6 - April 5,

1985, (reference 1), the Nuclear Regulatory Commission (NRC) resident inspector identified one area of concern related to a previously identified violt.sion (327, 328/84-38) which was included in the Stone &

Webster Engineering Corporation (SWEC) systematic analysis: A02050606005-001 Inadequate bandling of nonconformance reports. Information on the background, the corrective actions taken, the verification methodology, the verification analysis, the completion status, and any portinent references for the area of concern is included in this report. II. Verification of A02850606005-001, Nonconformance Reporting A. Bac kg round. The NRC inspection determined that a Sequoyah Nuclear Plant (SQN) Nuclear Engineering Branch (NEB) nonconformance. report SQN NEB 8501 was not handled in accordance with Office of Engineering procedure EP 1.26 (reference 2) and did not receive timely management escalation or timely notification of site management. These deficiencies were related to those cited in a previous violation (327, 328/84-38-02). An additional violation was not assigned for the recurrence. TVA attributed this violation to a lack of management control and employee awareness. B. Corrective Actions Taken. The corrective action for violation 327,328/84-38-02 is applicabla to this SWEC concern. SQN stated (reference 3) in the response to the violation that appropriate staff will be instructed in the timeliness of reporting potential nonconformances and the requirement for immediately assessing the impact of the potential nonconformance. This training was to be accomplished by April 12, 1985. Additionally, memorandums (references 4 and 5) were distributed to appropriate managers and employees on April 9, 1985, providing instructions for reporting nonconformances. C. Verification Method. ology. The SWEC concern identified for Employee Concerns Task Group (ECTG) verification was stated as follows: RIMS # ISSUE RIMS ITEM A02850606005 An NCR with TVA highest category RIMS-001 of significance did not receive timely management escalation or site management notification per procedure. Page 1 of 2

o ECTG reviewed the Sequoyah Compliance Licensing Files for internal and external correspondence related to this issue, applicable i procedures, and NRC status and closure files. This review of the pertinent documentation formed the basis for this verification activity. O. Verification Analysis. The ECTG review of the pertinent documents indicated that the corrective actions for this concern and the violation have been completed. Documented training on handling of conditions adverse to quality was accomplished in October 1985 for OE and ONp site personnel. However, NRC continued to indicate concern with the timeliness and handling of corrective actions and, again, communicated this concern in reference 6. An extensive program to improve SQN's and TVA's corrective action performance is outlined in the Sequoyah Nuclear Performance Plan which was submitted to the NRC in July 1986. E. Completion Status. The SWEC issue is being adequately addressed by TVA and SQN. Upon implementation of the corrective actions in this area documented in the Nuclear Performance Plan, the SWEC issue will be complete and ready for NRC closure. III. References 1. NRC Inspection Report Numbers 50-327/85-10 and 50/328/85-10, dated May 31, 1985, from J. N. Grace to H. G. Parris. 2. Office of Engineering Procedure EP 1.26, Nonconformance - Handling and Reporting. 3. "Rosponse to NRC Inspection Report Numbers 50-327/84-38 and 50-328/84-38", dated March 15, 1985, from J. A. Domer to J. N. Grace. 4. TVA memorandum " Timeliness in Reporting Potential Nonconformances," dated April 9, 1985, from J. A. Raulston to NEB managers. 5. TVA memorandum " Timeliness and Responsiveness - Conditions Affecting Quality," dated April 9, 1985, from J. P. Vineyard to all Sequoyah Engineering Project Employees. 6. NRC Inspection Report Numbers 50-327/85-45 and 50-328/85-45, dated February 18, 1986, from J. A. Olshinski to S. A. White. Page 2 of 2 l l

EIcissIra 3 ECTG WRITER'S GUIDE NSRS/ERT* WELD PROJECT (WP) REPORTS NOTES /CORRENTS 1.0 Issue Background Info Issues Addressed j Characterization (Section I) By Concerns (Section II) 2.0 List Of Concerns Background Info Scope of Evaluation (Section I) (Section I and Att-1) 3.0 Evaluators Coversheet Coversheet 4.0 Evaluation Scope Not Delineated As Part Process (Section II) Of The WP Reports however it is addressed as part of the Weld Projects Program Nanual

5.0 Findings

Findings Validity or (Section III) Substantiation (Section III)

- - Note that recommendations 6.0 Root Cause**

Conclusion and Yalidity or are not included in element reports under the current ECTG program, and Conclusion Recommendations Substantiation Overall Root Cause will (Section IV)*** (Section III) not be considered at this report level.

The Weld Project has endorsed a number of ERT Reports and general issue level reports as adequately addressing the concerns at this level for SQN.

OPERATIONS CATEGORY 9 / ECTG WRITER'S GUIDE OPERATIONS (OP) ELEMENT REPORTS NOTES / COMMENTS 1.0 Issue I. Title The brief introduction Characterization Very brief introduction touches on the source of the concerns. I 2.0 Sununary I. Title

1. The Conclusions are Very brief introduction towards the end of the findings.

III. Finding (Conclusions)

2. The Conclusions services as a summary of the findings.

3.0 Evaluators Cover Sheet

1. The printed name of the original evaluator (s) appears on the cover sheet.

2. The peer reviewer and CEG-H approval signa-tures are also on the cover sheet.

4.0 Evaluation II. Specific Evaluation Process Methodology

5.0 Findings

III. Findings l 1880T

Enclesura 3 e ECTG WRITER'S GUIDE OPERATIONS (OP) ELMENT REPORTS NOTES /CONMENTS 6.0 Root Cause IV. Root Cause

1. At the element level (Collective Significance) the Root Cause is often not identifible.

2. Collective significance is not addressed at the element report level.

7.0 Attachments / II. Specific Eva'luation

1. A list of the concerns List of Concerns Methodology with text are included within this section.

2. Other reports are sometimes attached.

,g ENGINEERING CATEGORY Enclosurs 3 Page 1 of 2 ECTG WRITER'S GUIDE ELEMENT REPORT FORMAT 1.0 Issue 1. Characterization of Issue (s) Characterization 2.0 Summary 9. Discussion, Findings and Conclusions 3.0 Evaluators Cover Sheet Information 4.0 Evaluation 8. Evaluation Process Process

5.0 Findings

9. Discussion, Findings, and Conclusions 6.0 Root Cause (Collective Significance)MM MW Overall Root Cause will not be considered at this report level. 7.0 Attachments / Attachments as required List of Concerns Other items included 2. Have issue (s) been identified in Engineering Element in another systematic Reports analysis? 3. Document nos., tag nos., locations or other specific descriptive identifications stated in element. 4. Interview files reviewed 5. Documents reviewed related to the element 1992T

e . b ENGINEERING CATEGORY Page 2 of 2 ECTG WRITER'S GUIDE ELEMENT REPORT FORMAT Other items included in Engineering Element 6. What regulations, licensing Reports commitments, design require-(cont'd) ments, or other apply or control in this area? 7. List requests for information, meetings, telephone calls, and other discussions related to element. l l 4

r

4 Encicsura 4 Page 1 of 2 EMPLOYEE SEQUOYAH CONCERN ELEMENT REPORT NUMBER ISSUE Engineering 23203 EX-85-089-002 Piping and Valve (Initial)

Design Welding WP-21-SQN, R0 DHT-85-001 (WE50800)* Weld Material (Initial) Substitution and Quality

Database subcategory as shown on 9/26/86 printout.

Operations 30204 SQM-86-013-001 Ground Detector (Final) Problem Note: Initial report transmitted 9/15/86 Operations 30401 TAK-86-005 Procedure Problems (Final) IN-85-112-001 Note: An Initial report transmitted 11/4/86 Operations 30806 IN-85-589-002 Subjourneyman/ (Final) Journeyman Note: Initial report transmitted 10/22/86 Operations 31003 IN-85-055-003 Operations Procedure (Final) Need Clarification, Rewritten, and Used Note: Initial report transmitted 11/4/86

4 Enc 1csura 4 Page 2 of 2 5

EMPLOYEE SEQUOYAH CONCERN ELEMENT REPORT NUMBER ISSUE Operations 31103 XX-85-007-001 Exposure Limits and (final) XX-85-028-001 Records XX-85-048-003 Note: Initial report transmitted 9/23/86 SWEC-05 A02-84108-005-001 Testing and Event (Final) A02-84018-005-002 Documentation Note: An initial report was not necessary. This will be the only submittal for SWEC-05. SWEC-18 A02-841217-002-001 Documentation of (Final) A02-841217-002-002 Inspection Note: An initial report was not necessary. This will be the only submittal for SWEC-18. SWEC-31 A02-850606-005-001 Nonconformance (Final) Reporting Note: An initial report was not necessary. This will be the only submittal for SWEC-31. l t i l 2468T ._}}

ML20213F507

Contents

Text

Dear Mr. Denton:

SUBJECT:

SUMMARY

Title:

Title:

SUBJECT:

SUMMARY

SUMMARY

Title:

SUMMARY

Title:

SUMMARY

Title:

5.0 Findings

5.0 Findings

5.0 Findings

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ML20213F507

Text

Dear Mr. Denton:

SUBJECT:

SUMMARY

Title:

Title:

SUBJECT:

SUMMARY

SUMMARY

Title:

SUMMARY

Title:

SUMMARY

Title:

5.0 Findings

5.0 Findings

5.0 Findings

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