ML20214U473
| ML20214U473 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 11/18/1986 |
| From: | Aycock W, Murphy M, Russell J TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20214G966 | List:
|
| References | |
| 307.06-SQN, 307.06-SQN-R01, 307.06-SQN-R1, NUDOCS 8612090277 | |
| Download: ML20214U473 (11) | |
Text
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 307.06-SQN SPECIAL PROGRAN REPORT TYPE: Sequoyah Nuclear Plant Element REVISION NUMBER:
1 TITLE: Test Procedure / Programs REASON FOR REVISION:
To incorporate TAS and SRP and comments and add Corrective Action Tracking Document reference.
PREPARATION PREPARED BY:
W. L. Aycock 11/03/86 SIGNATURE DATE REVIEWS
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SIGNATURE DATE SIGNATURE
- DATE APPROVED BY:
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//-/846 NiA ECSP NANAGER DATE IiANAGER OF NUCLEAR POWER DATE CONCUdRENCE (FINAL REPORT ONLY)
- SRP Secretary's signature denotes SRP concurrences are in files.
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TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT EMPLOYEE CONCERNS TASK GROUP OPERATIONS CEG i'
Subcategory:
Site Program / Procedures Element: Test Procedure / Programs Report Number:
307.06 - SQN Revision 1 Concern: XX-85-001-001 SQM-86-004-017 WBN-233 XX-85-077-001 IN-86-209-Oll 1
l Evaluator:
- 'I4 W. L. A ock Date Reviewed by:
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Date Approved by:.
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R3visien 1 I.
Test Procedures / Programs This' Report will evaluate three Sequoyah Nuclear Plant (SQN) specific issues, one Watts Bar on-site concern determined generically applicable to SQN, and one generic issue. These issues encompass:
1.
Improper. testing of D-G Batteries 2.
Improper testing of fuel racks 3.
Improper testing of fire detection system 4.
Prerequisite requirements to ensure satisfactory test results 5.
System assignments cause fragmented testing II.
Specific Evaluation Nethodology I:
The following concerns provide the basis for the determination of this evaluation:
II-85-001-001 Sequoyah D-G batteries have been replaced without A
initial testing per IEEE-450. A Potentially Reportable-l l
Occurrence (PRO) was written and determined not lR1 reportable by the compliance section.
)
SQN-86-004-017 Certain safety equipment may not have been properly-tested. One of the items involved are some tubes on the fuel floor. Other items are not specifically known. Details known to Quality Technology Corporation l (QTC), withheld because of confidentiality. No further lR1 information may be released.
4 WBN-233 System 13, Fire Protection System, does not have enough approved manuals or prints for maintenance. The l
j concerned individual (CI) has indicated that a IR1
?
Surveillance Instruction (SI) does not exist to check l
system from the transmitter / receiver panel through to
)
the console computer. CI has indicated that an 3.
approved master list does not exist of printouts or modifications to the system.
Individual is also concerned that individus1s maintaining / operating the j
system are inadequately trained. CI requests that a check on availability of spare parts be made.
f XX-85-077-001 Sequoyah - early 1980 and middle of 1981. Unit 2.
The preoperation Pre-requisites are questionable.
Details known to QTC, withheld due to o
confidentiality. CI has no further information.
1 Construction Department concern.
IN-86-209-011 TVA fragments system responsibilities to minimize problems when an employee leaves. The overall result Page 1 of 8 i
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R3 vision 1 of this policy is that partial tests, partial reviews, and increased coordination efforts are required. This fragmented approach leads to misunderstandings, and mistakes. Trying to coordinate with several people leads to retesting, reworking, moving equipment. removal equipment, and removal and-reinstallation of piping systems. Systems may be broken up into several different tests, and you have several different engineers doing the tests. Interfaces are not always clear which leads to mistakes and misunderstandings. With these interface problems test results could potentially be incorrect or incomplete. CI has no additional information. nuclear power department concern.
These concerns were evaluated by reviewing appropriate TVA documents and procedures, Final Safety Analysis Report (FSAR), Regulatory and Code Requirements, expurgated files and one specific' Nuclear Safety
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Review Staff (NSRS) Report. Additionally, three informal interviews (R1 were held with personnel.from the system engineering section, post i
modification test section, and instrument engineering.
This evaluation was conducted in accordance with the Evaluation Plan for the Operations' Employee Concern Task Group.
III. Findings This section of the employees concern evaluation will address each issues findings in the same order previously described in Section II of this Report.
K1-85-001-001 has been adequately investigated by NSRS. The evaluation encompassed a review fram issuance of purchase order and transfer of batteries from another TVA site through installation and testing.
IEEE-450 requirements for performance test and service test had not been fully implemented. Additionally, lapses in documentation of cell installation and inadequate post modification testing prompted the NSRS recommended corrective and preventative actions.
Briefly stated these actions were:
f.
1.
Performance test the batteries presently installed I
2.
Review and reestablish traceabilty of cells 3.
Verify existence of or initiate an acceptance (baseline) test for the installed batteries.
4.
Service test the batteries 1
5.
Review battery programs at other TVA nuclear plants 6.
Write a policy statement defining interdepartmental responsibilities for the overall battery program.
Page 2 of 8
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i Ravision 1 11 These recommendations were based on IEEE 450-1972, to which SQN is committed per the Safety Evaluation Report (Reference 11). The i
NSRS conclusions are consistent with the standard.
IR1 The original Potentially Reportable Occurrence (PRO) was determined not reportable based on the assumption that SQN is not committed to
.IEEE-450..After issuance of the NSRS report, a re-evaluation was l
performed, and the issue was again determined nonreportable. According l
l to a representative of SQN compliance, the basis for this determination l
was an agreement made between Nuclear Regulatory Commission (NRC) and lR1 SQN that no commitment to I2EE-450 exists. No documentation of this l
agreement was available, and the SQN Safety Evaluation Report does in l
fact clearly make the commitment.
l After the issuance of the NSRS report, a SQN response was prepared to address each action item. The SQN director stated in a December 9, 1985 memorandum that a " deep-discharge capacity test" i
meeting the requirements of IEEE-450, had been performed. According to the memorandum, no original acceptance test was available, so the new capacity test satisfies recommendations for both the baseline and performance tests. SQN also committed to begin testing of all plant
.l batteries in accordance with IEEE-450-1980, which is compatible with l
and more conservative than the 1972 version. SQN has established a lR1 traceability program for the DG battery to comply with the NSRS
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recommendation.
Data from the periodic IEEE testing is being maintained in the SI and PN files, and serial number tracking is via section letter ENSL E-47 (Reference 17).
lR1 l
The NSRS recommendations called upon Division of Nuclear Engineering l
(DNE) to provide a policy statement to more clearly define the l
responsibilities for post-modification testing. The response from SQN l
Naintenance (Reference 16) stated that "the responsibility referenced l
in the NSRS recommendation already exists within these sections; l
therefore, no additional organizational. policy statement is considered l
l required." -Despite this assertion, a new program has been instituted l
under Sequoyah Engineering Procedure (SQEP)-13 whereby DNE will assume lR1 responsibility for all post-modification test preparation. It should l
l be noted that other factors contributed to this policy change, including l an NRC audit held in 1986 on the post-mod test program. Currently, this l
1 new program is in a transitional phase in which the systems group has l
assumed responsibility for reviewing all post-mod and functional tests l
until such time as DNE takes over. The three other TVA sites each l
filed a response (Reference 13, 14, 15) to the NSRS report justifying l
their individual battery maintenance programs. Based upon the regulatory I commitments made by the other plants, the responses were adequate.
I SQM-86-004-017 dealing with improper testing of some tubes on the Fuel Floor was determined to be specific to the post modification testing of the high density storage racks.
)
Work Plan 8861 documented the installation and testing for the Spent Fuel Pool Hi-density Storage Racks. This testing was contracted to National Nuclear Corporation (NNC). The test included Neutron
)
l Attenuation and Drag Tests for the purpose of ensuring proper i
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Page 3 of 8 l
9 Rsvision 1
- moderation of spent fuel assemblie and ability of assembly insertion / withdrawal. The documentation verifying that these objectives were met are provided in the workplan. Although this documentation varies from the initial rack preoperational test the requirements of Regulatory Glide 1.68 have been met. The workplan and associated test was reviewed and approved by the design organization. Fuel assemblies are currently being stored in these lR1 racks with no indication of the racks failing to perform as intended.
WBN-233' involves testing of the Fire Detection System. The CI i
expressed concern that no SI exists to check the system from the transmitter / receiver panel through to the console computer.
- At Sequoyah..SI-234 describes the testing of all Technical Specifications related detector loops. Four individual checks are made: a channel functional test of detectors, an operational test of alarms, a detector and alarm circuit supervisory operational check and an operational check of non-supervised circuits from the panels to operated equipment.
i In each test, the SI verifies appropriate indication at the local panel as well as the fire detection alarm console in the control room. The test-is broken into three parts to reduce the time required for completion,'but the period for testing all detectors is six months.
11-85-077-001 indicated that Preoperational prerequisites for Unit 2 l
l were questionable during the periods of.early 1980 and middle of 1981.
lR1 Regulatory Guide 1.68 requires that sufficient prerequisite tests and checks be performed to ensure satisfactory performance of the preoperational test. With this in mind a review of the test conduct log was made to determine those tests performed during the periods of interest.
For those' tests determined to have started during these intervals a review of test summaries, change sheets,' test deficiencies and exceptions was performed to assess the effects of questionable prerequisites. One test data package, Westinghouse (W) 9.01, could l
not be located. The remaining 32 test packages reviewed did not lR1 indicate that the tests were started prematurely nor that the l
pre-requisites were insufficiently satisfied to support the overall l
success of the preoperational tests in question.
IN-86-209-011 was evaluated to determine any lack of proper overlap between tested systems after modifications. Administration Instruction lR1 (AI)-19. Revision 17, Section 4-1-2-13d specifies that DNE will prepare a scoping document for post-modification tests. The scoping document
" outlines and determines the extent of the post modification testing required." To implement the test "the cognizant engineer in accordance j
with the DNE scoping document prepares the test instruction in a I
workplan." For less complicated changes, functional tests are to be prepared by the modifications engineer. AI-19 requires that " functional j
tests shall be comprehensive enough to ensure that the new components perform their intended function and that the work did not inadvertently affect an operating system or component."
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Ravisien 1 At present, changes mandated by the Sequoyah Nuclear Performance Plan l
(SNPP) are underway in the test preparation area. SQEP-13 makes the lR1-design organization responsible for issuance of a test procedure for i
each modification it makes. Since this new program is not fully implemented, an interim measure has been instituted in which the systems group is reviewing tests prepared for all modifications.
Another ongoing program at Sequoyah, under the auspices of SQEP-14, is reviewing all instrumentation and electrical features of the safety-related systems including modifications and subsequent testing.
This process is not complete, but as of the date of this report. 51 areas of concern have been identified in post-modification and functional testing.
Interviews with personnel supervising the preparation of tests revealed that, under the old program, the assigned engineer was responsible for establishing the test interface points and overlap with other test.
With the interim review program, another level of technical review is
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provided.
Conclusions Although the concern was valid at the time it was written, the Diesel l
Generator Battery Maintenance Program at SQN is now in compliance with-lR1 IEEE 450-1972. Significant measures have been taken at the site to establish a new program as well as to verify that the present installation is adequate to perform as designed in the event of a loss of offsite power. Only the reportability issue remains to be addressed.
The Spent Fuel Pool Hi-density Storage Racks have been adequately tested although the documentation appears minimal in that one set of initials are provided for more than one verification. However, the concern has been determined not valid.
SI-234 is sufficient to assure that the Fire Detection System will provide alarms at the control room console. Thus, this Watts Bar concern has been determined not valid for Sequoyah.
i Sequoyah Unit 2 preoperational prerequisites were adequately satisfied and a meaningful test program was carried out. Changes and exceptions made to the tests did not invalidate any of the test results.
I j
Concern II-85-077-001 is therefore not valid.
lR1 j
Testing interface and overlap has been loosely controlled at Sequoyah in the past. There was not any " double check" or post-review for modifications testing which were not defined by a DNE scoping i
document. At present, the new procedures defined by SQEP-13 provides adequate review for interface and overlap. Additionally, the review being conducted under SQEP-14 will identify weaknesses in past
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functional tests and a commitment is in place to retest as necessary Page 5 of 8 i
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l Ravisien 1 IV.
Root Cause The five concerns each reflect a distinct question and root causes were considered separately.
11-85-001-002:
Root cause was failure to incorporate commitment (IEEE-450) into plant instructions.
SQM-86-004-017: Root cause not determined.
Concern not valid.
l l
WBN-233:
Root cause not determined.
Concern not valid.
'lR1 l
j 11-86-077-011: Root cause not determined. Concern not valid.
I d
IN-86-209-011: Root cause not determined. Although the testing 5
program was deficient.no evidence was found to support the contention i
that any test was incomplete or incorrect.
I 5
Y.
Generic Applicability II-85-001-001: This concern was considered for generic applicability during the NSRS investigation. Justification was solicited and received from each site for battery maintenance programs.
Based on review of the justifications, this concern is limited to SQN.
SQN-86-004-017: This concern was determined not to have a valid basis, nor generically applicable.
WBN-233 concern not substantiated at SQN: Non-genet!-
lR1 II-85-077-001 concern not substantiated at SQN: Non-generic.
IN-86-209-011: This is a system-wide consideration, and major revisions to the program are underway.
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Page 6 of 8 I
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R:: vision 1 i
VI.
References l
1.
SQN AI-19. Revision 17. Part IV; Modifications After Licensing 2.
NQAN-II 4.1, Revision 0; Preoperational Testing 3.
U.S. NRC Regulatory Guide 1.68 l'
4.
SQN Surveillance Instruction SI-234-1, Revision 16; Technical Specifications Fire Detectors l
l l
S.
SQN Workplan 8861; Spent Fuel Pool Hi-density Storage Racks 6.
NSRS Report I-85-109-SQN; dated November 18, 1985 l
7.
IEEE Standard 450-1980, Recommended Practice for Maintenance, Testing, and Replacement of Large Lead Storage Batteries for l
Generating Stations and Substations
)
8.
SQN FSAR Section 8.3.2.1.1; Vital 125VDC System
-9.
Sequoyah Engineering Procedure SQEP-13. Revision 0; Procedure for i
Transitional Design Change Control 10.
Sequoyah Engineering Procedure SQEP-14, Revision 0; Assembly and Evaluation of Electrical Test Results I
11.
Safety Evaluation Report Related to Operation of Sequoyah Nuclear i
Plant, Units 1 and 2 - NUREG 0011, March 1979 1
12.
Potentially Reportable Occurrence (PRO) 185-129, dated April 17, 1985 l
- 13. Memorandum from W. C. Bibb, BFN, to John Hutton, Nuclear Services, I
}
dated December 23, 1985.
Subject:
Browns Ferry Nuclear Plant l
[
(BFN) - Investigation of Alleged Failure to Test Diesel Generator l
Replacement Batteries at Sequoyah Nuclear Plant (SQN) - Nuclear l
l Safety Review Staff Report Number I-85-109-SQN. RINS l
l Number Lol 851226 690 l
I i
l 14.
Memorandum from James P. Darling, BLN to John Hutton, Nuclear l
l Services, dated December 6, 1985.
Subject:
Bellefonte Nuclear i
j Plant (BLN) - Investigation of Alleged Failure to Test Diesel i
j Generator Replacement Batteries at Sequoyah Nuclear Plant i
j (SQN) - Nuclear Safety Review Staff Report Number IR1 j
I-85-109-SQN.
RIMS Number LO1 851209 051 l
1 1
15.
Memorandum from E. R. Ennis, WBN to John Hutton, Nuclear l
}
Services, dated December 3, 1985.
Subject:
Watts Bar Nuclear l
j Plant (WBN) - Investigation of Alleged Failure to Test Diesel I
Generator Replacement Batteries at Sequoyah Nuclear Plant l
'g (SQN) - Nuclear Safety Review Staff Report Number l
I-85-109-SQN. RINS Number Lol 851204 673 l
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.. - 14 16.
Memorandum from H. L. Abercrombie, SQN, to John Hutton, Nuclear l
Services, dated December 9, 1985.
Subject:
Investigation of l
Alleged Failure to Test Diesel Generator Replacement Batteries IR1 at Sequoyah Nuclear Plant (SQN) - Nuclear Safety Review Staff l
Report Number I-85-109-SQN l
17.
Sequoyah Electrical Maintenance Section, Instruction Letter I
i EMSL-E-47, Revision 1, Battery Unit Traceability lR1 VII.
Immediate and Long-Term Corrective Actions Sequoyah stated that the PRO had been reevaluated several times by l
TVA personnel and the NRC. The reason for nonceportability are well l
[.
documented. The initial evaluation is documented in PRO 1-85-129 and lR1 the Sequoyah final response to NSRS report 1-85-190-SQN (500 851118 800). l (CATD Number 30706-SQN-01). This item is closed l
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REFERENCE
- ECPS120J-ECPS121C TENNESSEE VALLEY AUTHORITY PAGE 208 FREQUENCY
- REQUEST OFFICE OF NUCLEAR POWER RUN TIME - 12:19:18 OUP - ISSS - RHM EMPLOYEE CONCERN PRDORAM. SYSTEM (ECPS)
RUN DATE - 10/05/86' LIST OF EMPLOYEE CONCERN INFORMATION iTECORY: OP PLANT OPER SUPPORT SUBCATEGORY: 30706 TEST PROCEDURES / PROGRAMS S
GENERIC KEYHORD A H
APPL QTC/NSRS P
KEYNORD R CONCERN SUB R PLT BBSH INVESTIGATION 5
CONCERN KEYNORD C 1
NUMBER CAT CAT D LOC FLQB REPORT R
DESCRIPTION KEYNORD D
.QM-86-004-017 OP 30706 N SQN NNNN SS CERTAIN SAFETY EQUIPMENT MAY NOT HAV NONCONFORMANCE T50272 K-FORM E BEEN PROPERLY TESTED. ONE OF THE TESTING ITEMS INVOLVED ARE SOME TUBES ON THE OPERATIONS FUEL FLOOR. OTHER ITEMS ARE NOT SP TUBING ECIFICALLY KNOHN. DETAILS KNOHN TO QTC, HITHHELD DUE TO CONFIDENTIALITY NO FURTHER INFORMATION MAY BE REL EASED.
it 50_C04 515 IH 00000 S SQN NNYH SS INDIVIDUALS' JOBS HERE THREATENED BY HARASSMENT T50272 Or
- 7:'
K-FORM PLANT MANAGEMENT (KNONN) TO CAUSE E TESTING (4
j QUIPMENT, HHICH HAD REPEATEDLY FAILE GENERAL ggb 'f[/W /E,269' p 8
D TESTING, TO PASS. DETAILS KN0HN T CONST MANAGEMENT O QTC, HITHHELD DUE TO CONFIDENTIALI TY.
NO FURTHER INFORMATION MAY BE R ELEASED. NUCLEAR P0HER DEPARTMENT C ONCERN.
BN-233 OP 30706 N HBN NNYN NS SYS.13, FIRE DETECTION SYSTEM, DOES REPORT NOT HAVE ENOUGH APPROVED MANUALS OR PRINTS FOR MAINTENANCE. CI HAS INDI CATED THAT AN SI DOES NOT EXIST TO C HECK SYSTEM FROM THE TRANSMITTER / REC EIVER PANEL THRU TO THE CONSOLE COMP UTER. CI HAS INDICATED THAT AN APPRO VED MASTER LIST DOES NOT EXIST OF PR INTOUTS OR MODIFICATIONS TO THE SYST i
EM. INDIVIDUAL IS ALSO CONCERNED THA i
T INDIVIDUALS MAINTAINING /0PERATING THE SYSTEM ARE INADEQUATELY TRAINED.
I CI REQUESTS THAT A CHECK ON AVAILAB ILITY OF SPARE PARTS BE MADE.
X 001-001 OP 30706 N SQN NNNN I-85-109-SQN SS SEQUDYAH D-G BATTERIES HAVE BEEN REP REHORK T50002 K-FORM LACED HITHOUT INITIAL TESTING PER IE TESTING EE-450.
A PRO HAS HRITTEN AND DETER ELECTRICAL MINED NOT REPORTABLE BY THE COMPLIAN DC P0HER CE SECTION X -8S-077-001 OP 30706 H SQN NNNN I-85-811-SQN SS SEQUDYAH - EARLY 1980 & MIDDLE OF 19 TESTING T50186 K-FORM 81.
UNIT 2.
THE PRE-OP PRE-REQUISI PROCEDURES TES ARE QUESTIONALBLE. DETAILS KNOH GENERAL N TO QTC, HITHHELD DUE TO CONFIDENTI GENERAL ALITY. CI HAS NO FURTHER INFORMATI0 N.
CONSTRUCTION DEPT. CONCERN.
I 5 CONCERNS FOR CATEGORY OP. SUBCATEGORY 30706 l
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