ML20214V447
| ML20214V447 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 12/26/1986 |
| From: | Debbage A, Gass K, Knightly J TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20214T770 | List: |
| References | |
| SWEC-SQN-24, SWEC-SQN-24-R, SWEC-SQN-24-R00, NUDOCS 8612090688 | |
| Download: ML20214V447 (10) | |
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TENNESSEE VALLEY AUTHORITY WATTS BAR NUCLEAR PLANT EMPLOYEE CONCERNS TASK GROUP OTHER SITES CEG
=
Element
Title:
Thimble Tube Ejection Event SWEC Concerns: A02850311001-001 A02850311001-002 A02850311001-003 A02850509002-001 Source Document: NRC Inspection Report Number 327/84-24 Report Number: SWEC-SQN-24 Evaluator: (( d /O - A /- E b K. R. Gass Date Reviewed By: Y b I
/O ' 13-8b J. J. Knightly Date Approved By: _N* /*/ad/f6
- A.G.Debbag Okte '
1138T 8612070688 861120 PDR ADOCK 05000327 P PDR ,
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Report SWEC-SQN-24 NRC Report 327/84-24 4
I. INTRODUCTION A special Nuclear Regulatory Commission (NRC) safety inspection conducted during the periods August 27 - 31 and October 4 - 5, 1984, included.a review of circumstances surrounding the unit 1 thimble tube ejection event which occurred on April 19, 1984. As a result of this inspection, significant failures to comply with NRC regulatory requirements were identified. Some of these were addressed as issues in the Stone & Webster Engineering Corporation (SWEC) systematic analysis, as follows:
A02850311001-001 (Violation 50-327/84-24-02) Inadeyeate Review of Thimble Cleaning Procedure A02850311001-002 (Violation 50-327/84-24-01) Procedure Inadequate / Violated for Thimble Cleaning A02859311001-003 (Violation 50-327/84-24-03) Inadequate Control of Special Tools A02850509002-001 (IFI-327/84-24-04) Management Control of Safety-Related Maintenance Activities II. VERIFICATION OF SWEC ISSUES A. A02850311001-001 - Inadequate Review of Thimble Cleaning Procedure
- 1. Background Technical Specification 6.5.1.6 requires that the Plant Operations Review Committee (PORC) review unit operations to detect potential nuclear safety hazards and review all procedures required by Technical Specification 6.8.1.
, NRC stated that, contrary to the above, these requirements were not implemented in that the Plant Operations Review Committee:
- did not meet and review the operational hazards associated with thimble tube cleaning activities to be conducted in containment with the unit at power on April 19, 1984.
- did not adequately review maintenance procedure SMI-0-94-1 for thimble tube cleaning and flushing on July 10, 1981.
This was identified as NRC violation 50-327/84-24-02 i
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- 2. CorrSctive Actiens Teken - Tha corrsctiva ections for violation 327/84-24-02 were stated (references 2 and 4) as follows:
- a. The PORC is performing more indepth detailed reviews of procedures and activities to ensure compliance with established plant requirements. Additionally, plant management personnel who serve as members of PORC have reviewed the duties and responsibilities of PORC, as identified in Technical Specification Section 6.5.1.6 and Sequoyah Standard Practice SQA-21, "Onsite Independent Review (Plant Operations Review Committee)."
- b. AI-4, " Requirements for PORC Review of Plant Instructions",
will be followed for plant activities.
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- 3. Verification Methodology - The SWEC concern identified for Employee Concerns Task Group (ECTG) verification was stated as follows:
RIMS NO. ISSUE RIMS ITEM j A02850311001 Plant OP Review Committee RIMS-OO1 l conducted inadequate review of thimble cleaning procedure and i failed to review hazards associated with cleaning during plant operations ECTG reviewed the Sequoyah Compliance Licensing files for internal and external correspondence related to this issue, and the NRC status and tracking system for the 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 corrective actions have been completed and are adequate. The violation was closed by the NRC
, October 1, 1985 (reference 5). The closure report stated:
L This violation concerned onsite review committee reviews. The r inspector reviewed licensee responses dated June 6 and July 22, 1985 and onsite review committee meeting minutes 3415-3429. Licensee management reviewed the requirements for onsite reviews as delineated in Technical Specifications and procedure SQA-21. No discrepancies were identified, and licensee corrective actions appeared complete.
- 5. Completion Status - Based on SQN corrective actions and NRC t closure of the item no further action is required. This SWEC concern is closed.
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B. A02850311001-002 - precedurn Inadiquetv/Violeted for Thirble Cle ning
- 1. Background Following their review of the thimble tube event, NRC identified as violation 327/84-24-01 that Sequoyah failed to establish and
(' implement adequate procedures for the conduct of equipment I control, procedure review and approval, performance of maintenance, radiation work permit access control, and access to containment.
- 2. Corrective Actions Taken - The corrective actions (references 2
- and 4) for violation 50-327/84-24-01 included the following
I a. Special Maintenance Instruction (SMI)-O-94-1 has been
, cancelled and replaced with Maintenance Instruction (MI)-1.10 "Incore Flux Thimble Cleaning and Lubrication" incorporating lessons learned in thimble tube cleaning incident.
- b. MI-1.10 contains the applicable initial conditions to be met, postmaintenance inspections to be done, and quality assurance requirements (hold point) for the thimble tube high pressure seals. In addition, the incore thimble tube i maintenance has been included in the outage scheduling process.
- c. A review of the maintenance request (MR) process and QA review process has been performed to ensure they meet the requirements of SQM-2 " Maintenance Management System." As a result of this review the following adjustments have been made to upgrade the QA review program:
(1) Initial MR review has been restricted to QA engineers, management personnel (M-3 or above), or individuals designated by the section supervisors. Designated individuals must contact a QA engineer for concurrence prior to approving an MR.
(2) Additional training has been provided to those personnel authorized to review MRs. The training included the following:
- a. Review of SQM-2 requirements for MR reviews.
- b. Review of requirements for identifying postmaintenance testing for each MR.
- i. c. Review of Quality Assurance Section Instruction
! Letter detailing MR review process (QA-SIL 5.3).
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(3) Tha Quality Assurance Ssction Instruction Lettsr, which provides guidelines for review of maintenance requests, was revised to update systems and components requiring postmaintenance testing,
- d. Administrative Instruction (AI)-8, " Access to Containment,"
, has been revised to clarify hold order requirements for maintenance on the moveable detector system and to ensure operability of personnel airlock communications,
- e. Sequoyah Nuclear Plant (SQN) personnel have been instructed to ensure the person responsible for work is on the clearance (hold order) prior to commencing work per AI-3,
" Clearance Procedure," requirements. This has been accomplished by including the AI-3 requirements in pre-outage briefing, periodic management safety meetings, and by use of the existing clearance procedure training classes.
- 3. Verification Methodoloav - The SWEC concern identified for ECTG verification was stated as follows:
RIMS NO. ISSUE RIMS ITEM A02850311001 Adequate procedures were not RIMS-002 established nor existing procedures fully followed to control cleaning of in-core thimbles at power ECTG reviewed the Sequoyah Compliance Licensing files for internal and external correspondence related to this issue, ,
applicable procedures, and the NRC status and tracking system for the 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 corrective actions for this concern have been completed. The NRC closed the violation in Inspection Report 85-27 (reference 5). The closure report stated:
This violation concerned several examples of failure to establish or implement adequate procedures. The licensee responded to the violation in letters dated June 6 and July 22, 1985. The inspector reviewed the responses and the
- following procedures and held discussions with cognizant licenseo personnel
l Maintenance Instruction MI-1.9, Revision 6, Bottom Mounted i Instrument Thimble Tube Retraction and Reinsertion.
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Administrative Instruction AI-8, Revision 14, Access to Containment Quality Assurance Section Instruction Letter 5.3, Revision 11 Radiation Work Permit 02-1-85-110 Sequoyah has cancelled the original maintenance procedures, MI-0-94-1 and -2. A review of MI-1.9 identified several deficiencies with respect to unincorporated vendor recommendations for inspection and measurement of components during high pressure seal reassembly. SQN personnel provided a draft revision which was awaiting approval. This revision incorporated the vendor recommendations. These revisions are to be in place prior to thimble cleaning activities during the unit i refueling outage. Other revisions to procedures appeared adequate. The inspector reviewed the list of quality assurance reviewers authorized to review maintenance requests and the documented training held. No discrepancies were identified. A sample of active hold orders was also reviewed to determine if hold orders were being issued to personnel responsible for maintenance activities. No discrepancies were identified, and SQN corrective actions were complete with the exception of the revisions to MI 1.9.
ECTG verified that the MI 1.9 revisions were issued (reference 6).
- 5. Completion Status - Based upon SQN corrective actions and NRC closure of the violation, no further action is required on this item. This SWEC concern is closed.
C. A02850311001-003 - Inadequate Control of Special Tools
- 1. Background - Violation 50-327/84-24-03 10CFR Part 50, Appendix B, Criterion II requires that activities affecting quality shall be accomplished under suitably controlled conditions which includes the use of appropriate equipment. In addition, Criterion III requires that appropriate measures be established for the selection and review for suitability of equipment.
NRC stated (reference 7) that:
Contrary to the above, as of April 19, 1984, the modified incore flux monitoring system thimble cleaning tool used for thimble cleaning activities at power was not appropriate equipment for use on the reactor coolant pressure boundary in that excessive stresses were transferred to the high pressure seal on incore thimble D-12. This resulted in a breach of the reactor coolant pressure boundary. In addition, management controls for and reviews of modifications to the original vendor-supplied cleaning tool were inadequate to prevent inappropriate modification of the
- tool and subsequent use.
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i h The violation occured due to inadequata management controls being established to ensure that modifications to special tools received appropriate reviews and approvals.
- 2. Correc,tive Actions Taken - SQN's Response (reference 4) stated that:
Sequcyah Nuclear Plant has evaluated the need for establishing a program to control the use and modification of special tools. As a result of this evaluation, SQN Standard Practice SQM 63, "Special or Modified Tooling-Primary System," has been issued outlining the requirements to be followed for the use and redification of special tools. In general, special tools used on equipment fitting the following criteria fall within the scope of SQM 63:
- a. Components which are in service, pressurized or ere rgized .
- b. Components which, if the tool caused failure of the component, could cause loss of primary coolant or the loss of uncontrollable amounts of radioactive contaminated water during the use of the tool.
- c. Components which, if the tool caused failure of the
' component, could cause the loss of a safety function while the tool is being used.
This instruction may also be used to document evaluations of other tools as requested for reasons such as industrial safety considerations.
- 3. Verification Methodoloav - The SWEC concern identified for ECTG verification was stated as follows:
RIMS NO. ISSUE RIMS ITEM A02850311001 No formal program exists RIMS-OO3 for control of special tools or evaluation of modifications made to these tools ECTG reviewed the Sequoyah Compliance Licensing files for internal and external correspondence related to this issue and the NRC status and tracking system for the issue. This review of the pertinont documentation formed the basis for this verification activity.
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- 4. Verification Analysis - The ECTG review of the pertinent documents indicated that the corrective actions for this concern and the violation have been completed and are adequate. The violation was closed by the NRC (reference 5). The closure report stated:
This violation concerned use of a modified cleaning tool and lack of appropriate controls. The inspector reviewed licensee responses dated June 6 and July 22, 1985. SQN has implemented an inspector reviewed procedure SQM-63, "Special or Modified Tooling," Revision 0 and two in-progress tool evaluations. SQN corrective action appeared edequate.
- 5. Completion Status - Based upon SQN corrective actions, and NRC closure of the violation, no further action is required on this item. This SWEC concern is closed.
D. A028505C9002-001 - Management Controls of Safety-Related Maintenance Activities
- 1. Background During NRC's review of the unit 1 thimble tube ejection event, '
significant failures to comply with NRC regulatory requirements were identified. This resulted in a civil penalty of $112,500 for violations of management controls (reference 2).
- 2. Corrective Actions Taken - The corrective actions for the violations (reference 2 and 4) as described in Sections II A, B, and C of this report are applicable to this SWEC concern. A civil penalty of $112,500 was the total for violations 50-327/84-24-01,-02, and -03. The three violations are closed and the assessed penalty has been paid.
- 3. Verification Methodoloey - The SWEC concern identified for ECTG verification was stated as follows:
RIMS NO. ISSUE RIMS ITEM A02850509002 Proposed civil penalty $112,500 RIMS-001 for violations. Management controls weak for safety-relat(d maintenance activities ECTG reviewed the Sequoyah Compliance Licensing files for internal and external correspondence and the NRC status tracking system related to this issue. This review of the pertinent documentation formed the basis for this verification activity.
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- 4. Verification Analysis - The ECTG review of the portinent documents indicated that the corrective actions for this concern and the violations have been completed. At the time of this ECTG verification, the NRC violations are closed (reference 5).
- 5. Completion Status - Based on SQN corrective action, compliance with requirements, and NRC closure of the issue this concern is considered closed.
III. REFERENCES
- 1. NRC Inspection Report 50-327/84-24, dated August 2, 1985, J. Nelson Grace to H. G Parris
, 2. TVA letter, " Response to Notice of Violation and Proposed Imposition of Civil Penalties - Inspection Report 50-327/84-24", dated June 6, 1985, J. A. Domer to J. M. Taylor
- 3. TVA Memorandum 'lequoyah Nuclear Plant - OIE Inspection Report No. 50-327/S4-24, dated June 10, 1985, H. L. Abercrombie to J. W. Hufham
- 4. TVA letter, " Revised Response to Notice of Violation and Proposed I
Imposition of Civil Penalties: EA-119 Unit 1 Seal Table Leak and Thimble Tube Ejection Event - Inspection Report 50-327/84-24," dated July 22, 1985, J. A. Domer to J. M. Taylor
- 5. NRC Inspection Reports 50/32/05-27, dated October 1, 1985, R. D. Walker to H. G. Parris
- 6. Maintenance Instruction MI-1.9, Revision 7, dated September 9,1985,
" Bottom Mounted Instrument Thimble Tube Retraction and Reinsertion"
- 7. NRC Inspection Report No. 50-327/84-24, dated March 7, 1985, J. N. Grace to H. G. Parris I
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TVA EMPI4YEE CONCERNS REPORT NUMBER: SWEC-SQN-24 SPECIAL PROGRAN REPORT TYPE: Sequoyah Nuclear Plant Element REVISION NUMBER: 0 f TITLE: Thimble Tube Ejection Event i
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 l Corporation (SWEC) systematic analysis. All items evaluated within this report I were verified to be adequately addressed and were closed by the NRC.
PREPARATION PREPARED BY:
W f 54 J/-)/- 9L SIGNATURE DATE 1
REVIEWS PEER:
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5 44, N/A ECSP MAlfAGER DATE __NANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)
- SRP Secretary's signature denotes SRP concurrences are in files.
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