ML20215A775

Rev 2 to Sequoyah Element Rept 223.3(B), Instrument Support Design, TVA Employee Concerns Special Program

ML20215A775
Person / Time
Site:	Sequoyah
Issue date:	05/14/1987
From:	Russell Gibbs, Jordan L, Russell J TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20215A652	List: ML20215A649 ML20215A738 ML20215A775 ML20215A797 ML20215A813 ML20215A837 ML20215A851
References
223.3(B), 223.3(B)-R02, 223.3(B)-R2, NUDOCS 8706170078
Download: ML20215A775 (23)

Text

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,/ 'TVA EMPLOYEE CONCERNS ~ REPORT NUMBER: 223.3 (B)

SPECIAL PROGRAM REPORT TYPE: SEQUOYAH ELEMENT REVISION NUMBER: 2 TITLE: INSTRUMENT SUPPORT DESIGN Local Instrument Seismic Qualification PAGE 1 0F 22 REASON F6R REVISION:

1. Revised to incorporate SRP and TAS comments; to add chronology and Section 10, Corrective Action.

2. Revised Section 10, Corrective Action; to add references to Appendix A.

PREPARATION PPsEPARED BY:

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REVIEW 5 n n _

^::^ REVIEW COMMITT -

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/ DATE CONCURRENCE 5 M t% - w_L3 &f/k}-

CEG-H: Nd E-20ifl SIGNATURE DATE SRP: Q R M 6-2-87 SIGNATURE

• DATE

, APPROVED BY:

, @.bM%h P MANAGER M

'DATE) 14 A

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

• SRP Secretary's signature denotes SRP concurrences are in files. 1 1 8706170078 870605 I DR ADOCK 050 7 t i

'6 ~ i

.TVA EMPLOYEE CONCERNS REPORT NUMBER: 223.3 (B) ,

SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 2 0F 22 <

1. CHARACTERIZATION OF ISSUE (S):

Issues:

Concer_n:

a. Local instruments were installed f

.IN-85-886-N04 ' based on " Good Engineering Judgment." I NRC identified the following concern related to IN-85-886- No seismic ani,/ sis was done for dif-001 from review of QTC file. b.

ferent types of installation of local "On unit .1, local instruments instruments'. ,

were installed using ' Good Eng. Judgment' and no seismic c. No seismic analysis was done for analysis was done." local instruments.

2. HAVE ISSUES BEEN IDENTIFIED IN ANOTHER SYSTEMATIC ANALYSIS? YES x NO Identified by Gilbert / Commonwealth (G/C)

Date 03/03/86 Documentation Identifiers:

G/C Report No. 2614, " Final Report Technical Review of SQN Modifications, Technical Issu;. No. 4, 9, 10, 14 & 19"

3. DOCUMENT NOS., TAG NOS., LOCATIONS OR OTHER SPECIFIC DESCRIPTIVE IDENTIFICATION 5 STATED IN ELEMENT:

Local instruments; no specific tag numbers identified j l

4. INTERVIEW FILES REVIEWED:

1 File IN-85-886-N04 was reviewed and no additional unreviewed information for Sequoyah regarding this concern was identified.

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5. DOCUMENTS REVIEWED RELATED TO THE ELEMENT:

See Appendix A.

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. t I TVA EMPLOYEE CONCERNS REPORT NUMBER: '223.3.(B).

L SPECIAL PROGRAM l

[ REVISION NUMB'ER: 2' PAGE 3 0F 22 3

6. WHAT REGULATIONS, LICENSING COMMITMENTS, DESIGN REQUIREMENTS OR OTHER APPLY OR CONTROL TN THIS AREA?

See Appendix A.

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7.- LIST REQUESTS FOR INFORMATION, MEETINGS, TELEPHONE CALLS, - AND OTHER '

DISCUSSIONS RELATED TO ELEMENT.

See Appendix A.

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8. EVALUATION PROCESS:

1

a. Reviewed Environmental Qualification -(EQ) program commitments (general program for environmental qualification) in SQN  !

Nuclear Performance Plan, Volume II.

b. Obtained results of Seismic Qualification Review Team (SQRT) audit by NRC.

A.,

j c. Determined which instrumentation items were covered by SQRT.

audit.

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d. Reviewed FSAR for SQN commitment for instrument seismic qualifications. Reviewed Safety Evaluation Report (SER) in the same sections for results of NRC review,

e. Reviewed SQN design criteria and other commitments regarding ]

qualification requirements.

f. Selected and reviewed appropriate samples of qualification i I

documentation.

g. Obtained and reviewed drawings that show mounting details.

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9. DISCUSSION, FINDINGS, AND CONCLUSIONS: ,

^

Chronology:

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09/76: NRC - SQRT audit of class lE instrumentation 03/86: G/C reviews SQN modifications of class lE instrumentation 06/86: TVA-SQN Generic Concern Task Force investigates installations of local instruments 08/86: X-form provided to TVA 0103D-3 (0S/14/87) .

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. .TVA EMPLOYEE CONCERNS . REPORT NUMBER: 223.3 (B)'

SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 4 0F 22 Discussion:

A. Backaround

.The issues relate to a concern that the installation of local-instruments was based on good engineering judgment only, without sny seismic analysis.

Good engineering judgment has been, and will continue to be, an inherent part of the engineering process. In current practice in the nuclear industry, requirements have been established for documentation of such judgment by providing technical justification.

B. Criteria and Commitments NRC General Design Criterion 2 requir_es Category I structures, systems, and components to be designed to withstand the effects of natural phenomena such as earthquakes. Sequoyah commitment to i comply with this criterion is stated in SNP FSAR Section 3.1. The-seismic design bases of Category I . items are described in FSAR

-.. Sections 2.5 and 3.7. Specific application of these bases for ,

\ Category I instrumentation is contained in FSAR Section 3.10 and Appendix F of Sequoyah Nuclear Power Plant Quality Assurance Manual, which is presently included in SQN design criteria manual, (App. A, 6.b).

C. Methods of Qualification i The seismic qualification of equipment should-demonstrate the equipment's ability to perform its required function during and after the time it is subjected to the forces resulting from a seismic event. One of four alternate techniques may be used to qualify equipment: analysis, testing, a combination of both, or similarity with supporting documentation.

Analytical methods are adequate if an appropriate mathematical model can be constructed, the structural integrity can assure

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equipment functionality, and aging influences, are. insignificant.

Testing methods may be used to verify equipment's functional operability. Examples of equipment generally requiring testing are valves, complex dampers, devices for electrical cabinets, and instrumentation and control equipment.

i Extremely large and/or complex equipment would generally be qualified by a combination of testing and analysis.

0103D-3 (05/14/87.) ,

TVA EMPLOYEE CONCERNS REPORT NUMBERi 223.3 (B).

SPECIAL PROGRAM REVISION NUMBER: 2, l PAGE 5 0F 22  ;

Equipment that is similar in form, fit', and function to previously-qualified equipment may be qualified on a " generic" or similar-equipment basis if the prototype test can be applied to_the similar equipment to be qualified. To justify qualification by 1 similarity, differences in mass distribution, equipment geometry, l interior and exterior structural supports, mounting conditions, and {

J externally applied loads should be considered. When applicable, the location of' devices within assemblies and the function and method of operation of electrical and/or mechanical devices and the 4 i

design basis condition should also be considered. In addition, qualifications by similarity should be accompanied by supporting l documentation. ,

D. NRC Seismic Audit In late September 1976, the NRC performed a seismic audit of TVA {

equipment. The seismic audit report was attached to NRC letter from Varga to Williams ( App. A, 5.o; 11/16/76). The NRC seismic ,

team had requested documentation on seismic qualification for  :

several selected items of Balance of Plant (BOP) class lE instrumentation, control, and electrical equipment. Radiation j monitors were among the selected items audited. The NRC concluded

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a that the function of the selected items was acceptable during and

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after seismic testing, according to information submitted by TVA. 1 This conclusion was reflected in Sections 3.10 and.7.8 of. Safety l Evaluation Report (SER) by NRC. During the seismic audit, TVA staff indicated that they endorse updated.IEEE 344-1975 standard and Regulatory Guide 1.100 for equipment seismic qualification.

However, TVA was very explicit.in stating that their seismic qualification program requirements and licensing commitments for i

Sequoyah were based on IEEE 344-1971. FSAR Section 3.10 ! contains  !

the following commitmente ist the seismic qualification cf Hismic Category I instrumentatior:

a. Both BOP and Nuclear Steam Supply System (NSSS) instrumentation satisfy the requirements of IEEE 344-1971.

b. B0P (TVA supplied) instrumentation is qualified per TVA SQN Quality Assurance Manual Appendix F with a minimum test frequency range of 1 to 25 hertz.

c. The instruments are capable of performing their functions during and following a Safe Shutdown Earthquake (SSE). They are qualified to withstand the peak response acceleration

' determined from the appropriate response spectrum,

d. Any instrumentation used for plant upgrade purchased after 05/23/80 will be qualified to the requirements of IEEE 344-1975.

0103D-3 (05/14/87)

TVA EMPLOYEE CONCERNS REPORT NUMBER: 223 0 3 (B)-

'SPECIAL PROGRAM REVISION NUMBER: 2 i PAGE 6 0F 22 Although SQN criteria were not updated (the bulk of the equipment was already under contract), it was TVA's intent that IEEE 344-1975 l be implemented to the fullest extent reasonably possible,'as stated

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l in a TVA letter from Gilleland to Varga.( App. A, 5.p; 02/07/77)..

E. Seismic Qualification Documentation' i A review of SQN Nuclear Performance Plan, Volume II,~ Revision.1 (final draft) attached to a memo from Gridley to Those Listed'(App. i A, 5.w; 07/14/86), identified that the current rework EQ program H for Sequoyah is comitted to environmental qualification of equipment only and does not address seismic qualification'of equipment. This was confirmed in discussions with TVA on 08/19-24/86 at the Sequoyah plant.

During the investigation, the evaluation team experienced difficulty in retrieving documentation of seismic qualification of instrumentation. This difficulty may cause problems in demonstrating the acceptability of TVA seismic qualification of instrumentation.

D A similar retrievability concern was identified in NRC I&E Report Nos. 50-327/86-27 and 50-328/86-27, attached to an NRC letter from Q/ Taylor to White (App. A, 5.x; 04/22/86), based on a special.

inspection of TVA's Design Baseline and Verification Program for design activities since receipt of SQN operating' license. The NRC .

conducted an additional inspection of' procurement and quality i assurance records on 09/15-19/86 and 09/29/86 through 10/03/86 as I indicated by an NRC letter from Taylor to White (App. A, 5.ee; l 10/21/86). This letter expressed the NRC's. concern regarding TVA's i inability to retrieve quality assurance records for seismic and- l environmental qualifications of previously qualified equipment.

Similar issues are evaluated on a broader base in the element reports of Subcategory 205.

4 F. , Sample Instrument and Installation Review To establish baseline information to review s'eismic qualification of instrumentation, the evaluation team independently selected three samples of " Local Instruments" from the " Mechanical Instrument Tabulation," Drawing 47B601 series. The selection was  ;

based on the following criteria:  ;

i 0103D-3 (05/14/87) .

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, ty TVA EMPLOYEE CONCERNS- REPORT NUMBER: 223.3 (B)

.SPECIAL PROGRAM'

. REVISION NUMBER: 2

-PAGE.7 0F.22 y

a. The instruments are safety-related l

b. .The instruments were procured before. fuel load of Unit 1- l (i.e. , pre-1980 contract)

The instruments were procured under different contracts

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c.

d. One instrument is mounted on a floor panel; the second one"on 1

a wall panel; and the third one process mounted  :)

h TVA personnel were requested to compile complete seismic qualification documentation for the three selected samples of 1

instrumentation listed below:

a. Force balance pressure transmitter (1-PT-1-30) for the main steam system, procured under contract no. 68C60-91934 (NSSS l '

contract). This transmitter is located in the Unit 1 auxiliary building, elevation 690 feet, and is mounted on a local floor panel. l

b. Pressure transmitter (1-PT-1-26C) for the main steam system, j

..5, procured under contract no. 73C3-92784 (BOP contract). This 1 j

transmitter is located .in the Unit 1 auxiliary building, elevation 735 feet, and is mounted on a local wall panel.

c. Temperature switch (1-TS-30-103) for the ventilating system, procured under contract no. 75K13-86835 (B0P contract). This  ;

temperature switch is located. in the Unit 1 auxiliary  ;

building, elevation 714 feet, and.is process mounted. l Force Balance Pressure Transmitter. This transmitter (1-PT-1-30) is a Foxboro Model No. EllGM, supplied by Westinghouse, It l underwent seismic testing by Acton Environmental Testing Corporation, and the test results were documented in Test Report No. T3-1091 ( App. A, 5.g; 12/73), which was attached to j Westinghouse Topical Report, " Seismic and Environmental Testing of Foxboro Transmitters," WCAP-8541 ( App. A, 5.f; 07/75). This test i

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report to CEBwas files app App.(roved A, 5.h; by TVA asfordocumented 09/03/81) r oxboro Modelby No.TVA E10 memo fromj series transmitters on WBN contract 828973. The memo stated that  !

this approval qualifies the devices for installation in any of l TVA's nuclear plants. The location of the transmitter is shown on (

Drawing 47W600-31, R17. This Foxboro transmitter was mounted on a i local floor panel-1-L-102; panel detail is shown on Drawing

' 47W600-14, R4. The transmitter mounting plate and bracket are detailed on Detail B19. of Drawing 47W600-19, R13. The evaluation team walkdown during 09/16-20/86 found that the bracket installed on 1-PT-1-30 is the approximately 1-inch deep bracket shown .on-Section A-A of Detail B-19.

0103D-3 (05/14/87) l

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TVA EMPLOYEE CONCERNS REP' ORT NUMBER: 223.3 (B)

SPECIAL PROGRAM REVISION NUMBER: 2

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PAGE 8 0F 22 The local floor panel is an instrumentation rack procured under contract no. 72C33-92800 and manufactured by The Wolfe and Mann Manufacturing Company. It was tested by Wyle Laboratories, and documented in Test Report No. 42377-1 (App. A, 5.m), which was J reviewed and approved by TVA in a letter from Weaver to Keith (App.

A,.5.q; 04/17/73). The tested mounting bracket shown in photograph 9 of Wyle Test Report 42377-1 appears to be different from the mounting bracket shown on Detail B19 of Drawing 47W600-19.

However, in an evaluation team discussion on 10/24/86 with TVA personnel (App. A, 7.n), TVA personnel stated that the issue detail shown on the design drawing had approval signatures or initials indicating that adequate review and approval had been performed by TVA personnel in early 1970s. The evaluation team noted that this was consistent with nuclear industry practice in that time frame.

In later discussion on 10/25/86 (App. A, 7.m), TVA personnel indicated that the bracket shown in photograph 9 of Wyle Test Report 42377-1 was supplied by Foxboro. Because of TVA concerns {

regarding the stiffness identified from its review of test results, l a stiffer bracket was designed, as shown on drawing 47W600-19. l s

Subsequent qualification tests of the pressure transmitters for WBN 1 j

) applications were performed by Wyle Labs and included in Wyle Test v Report 42807-1 ( App. A, 5.j; 08/26/74) using the bracket shown on l drawing 47W600-19 and the enveloping WBN required response i spectra. This latter Wyle test report was approved by TVA as documented by letter from Chandler to Salisbury (App. A, 5.1; 11/19/74).

After considering all the above information, the evaluation team finds that adequate documentation exists to demonstrate that pressure transmitter 1-PT-1-30 meets TVA licensing commitments of FSAR Section 3.10. During evaluation team investigations, it was noted that alternate Section Al-Al of Detail B19, Drawing 47W600-19, provides a bracket 2-1/2 inches deep which is more flexible than the qualified approximately 1-inch deep bracket. The evaluation team performed a qualification calculation for alternate Section Al-Al and determined that this detail is adequate.

Therefore, the engineering judgement was adequate and this is no longer a relevant issue.

Pressure Transmitter. This transmitter (1-PT-1-26C) is a GE-MAC Type 556 transmitter, supplied by General Electric Company. It was seismic tested by Utility System Engineering of Bailey Meter Company, revised Test Report No. 507 (App. A, 5.k; 05/25/73),

attached to a vendor letter from Henrichsen to Weaver ( App. A, 5.r; 05/25/73). The test was made in accordance with TVA Specification 1499, Appendix C, attached to contract 73C3-92784. The revised test report was reviewed and approved by TVA in a letter from 0103D-3 (05/14/87)

L 1 l .

TVA EMPLOYEE CONCERN $ REPORT NUMBER: 223.3 (B)

! SPECIAL PROGRAM l

REVISION NUMBER: 2 PAGE 9 0F 22 j Patterson to Henrichsen (App. A, 5.t; 06/28/73). The location of the transmitter is shown on Drawing 47W600-92, R6. This GE-MAC transmitter is mounted on a local wall panel 1-L-251, whose detail is shown on Drawing 47W600-23, R11. The transmitter mounting plate is detailed on Detail B21 of Drawing 47W600-21, R8.

The wall mounted panel and the mounting plate were analytically determined to be rigid by TVA, and the calculation was attached to the TVA memo from Givens to Pierce ( App. A, 5.s; 01/09/73). This calculation was entered into the TVA Records Information Management System (RIMS) on 10/02/86 to facilitate document retrieval for future evaluations. The evaluation team has reviewed this calculation and considers that it adequately demonstrates acceptable mounting of transmitter 1-PT-1-26C. All of the above information leads the evaluation team to consider that adequate documentation exifcs to demonstrate that pressure transmitter 1-PT-1-26C meets the TVA licensing commitments of FSAR Section 3.10.

Temperature Switch. This switch ~TS-30-103) is a Fenwal Model No. 18003-7, supplied by Fenwal Incorporated, and procured under contract 75K13-86835 (06/06/75). Seismic test requirements for the temperature switch were waived by TVA for procurement of the switch  !

as delineated in the contract. This was also indicated in a memo  ;

from Chandler to Wilson ( App. A, 5.u; 06/13/75) with instruction not to obtain seismic testing of the Fenwal switch because previous seismic qualification had been established by TVA for this device. 1 TVA judged the temperature switch seismically qualified in May 1975 on the basis of similarity to other temperature switches (Fenwal Model No. 17002-40) qualified by General Electric seismic test l report No. 225A6290 ( App. A, 5.aa; 12/14/69) for another nuclear ,

plant application. This was confirmed by TVA personnel in a (

telephone call on 10/24/86 with the evaluation team ( App. A, 7.n). l Upon review of the GE seismic test, the evaluation team noted that this testing was performed prior to issue of IEEE 344-1971. The test on the temperature switch only covered a test frequency range of 5 to 33 hertz and did not include 1 to 5 hertz whereas the commitment of SNP FSAR Section 3.10.1 stated that the test frequency range in all cases covered 1 to 25 hertz as a minimum.

In addition, the test did not give the sweep rate 'of change and duration of the sweep during vibration endurance test of the temperature switch, and the mounting detail of the tested switch was not completely shown. Such data would be required to assess the technical adequacy of the test report. However, additional temperature switches were procured under contract 81PN1-829261 (06/18/81) during 1981. Fenwal Model No. 18003-7 was one of the items requested. Fenwal Inc. informed TVA in a letter from Murphy 0103D-3 (05/14/87)

4 c TVA EMPLOYEE CONCERN $ REPORT NUMBER: 223.3 (B)

SPECIAL' PROGRAM REVISION' NUMBER: 2 i PAGE 10 0F 22 to Hannah (App. A, 5.v; 06/04/81) that Fenwal' Mod'el 18003-7 was obsolete and had been replaced by 18023-7 which was the same in form, fit, and function. This new model 18023-7 was tested by Wyle Laboratories and documented in Report No. 17509-1, Rev. C, (App. A, 5.1; 05/07/82).. The new switch was rigidly mounted.on a fixture during the test, which was in accordance with TVA's prescribed seismic requirement in Purchase Order No. TV-56071A. The Wyle-test report 17509-1 was approved by TVA as. documented by memo from Huie - .l to CEB files (App. A, 5.ff; 07/26/83). The evaluation team has reviewed this report and considers it acceptable and applicable to temperature switch 1-TS-30-103.

The temperature switch (1-TS-30-103) is used in the ventilation.

system to monitor changes in ambient temperature. The location of the switch (Fenwal Model 18003-7) is shown on Drawing 47W920-5, R30, which has a note instructing the field to mount the switch under the grating floor. No mounting detail is called out on the drawing. The configuration of the switch is shown on Fenwal Drawing 18003-7, Rev. B/7 dated 06/21/68. The switch is about 5 inches long, 1/2-inch in diameter, and made of stainless steel,

g. One end of the switch is double threaded.

c.. A walkdown by the evaluation team found that the junction of the double threaded portion of the switch is connected to two condulets with the main body of the switch (about 3-1/2 inches long) housed inside the first condulet. The condulet is about 6 inches long.

The other end of the first condulet is bolted to a wall-mounted i Unistrut using a single round head machine screw about 1/4-inch in diameter located along the axis and ahead of.the switch and approximately 6 inches from the double threaded end. The other end of the second condulet is connected to a conduit.

The distance between the point-of-support of the first condulet and the next support, the conduit, is about 2 feet 6 inches. Such The <

mounting switch did is different not from Instrument have TVA's that used in q(ualification testing.No.1-TS-30-103) on Tag however, an adjacent instrument has a Tag No.1-TS-30-103A on it, i Since the locations' of instruments 1-TS-30-103 and 1-TS-30-103A are the same on Drawing 47W920-5, the unidentified switch is inferred by the evaluation team to be temperature switch 1-TS-30-103. j In an evaluation team discussion on 10/24/86 with TVA personnel '

(App. A, 7.n), TVA acknowledged that.there are no design mounting details or current evaluations of the existing detail for

' temperature switch 1-TS-30-103 and stated-that it plans to evaluate the mounting as corrective action for this employee concern. TVA  !

stated that a cursory field evaluation of the switch finds that the  !

l installation appears to be adequate. TVA also indicated that it 0103D-3 (05/14/87)

b TVA EMPLOYEE CONCERNS REPORT NUMBER: 223.3 (B)

SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 11 0F 22 1

will file a Problem Identification Report (PIR) to determine <

appropriate corrective action in conjunction with on-going configuration control efforts and corrective actions for other l Significant Condition Report (SCR)/PIRs.  !

A later evaluation of the as-built mounting detail of the switch was performed by TVA ( App. A, 5.bb) on 10/31/86. The as-built installation of the_line-mounted switch has been analytically determined to be rigid by TVA. Upon review of TVA's evaluation, {

the evaluation team observed that TVA assumed that the area moment of inertia of the 1/2-inch diameter threaded switch is the same as the 1-inch diameter in-line conduit in calculating the natural frequency of the line-mounted switch installation. The analytical model assumed a simply supported beam with a constant area moment of inertia of the 1-inch diameter conduit. Although this '

assumption is not appropriate, the evaluation team considers the frequency calculated by TVA to have adequate margin to qualify the line-mounted switch installation as rigid; therefore, the '

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installation of this switch is adequate. The lack of an appropriate design mounting detail or evaluation prior to this

-~., investigation indicates a need for TVA review of other

field-mounted local instruments. i k

w .. l G. Gilbert / Commonwealth Report In January 1986, TVA asked Gilbert / Commonwealth, Inc. (G/C) to review the technical adequacy of design changes performed for the Sequoyah Nuclear Plant, Units 1 and 2, between issuance of the i operating license and June 1985. Some of the technical issues identified by G/C during the review were related to seismic qualification of instrumentation. For example, Technical Issue Data Sheet No. 4 of G/C Report No. 2614 (App. A, 5.n) eddresses the specific qualification issue for the pneumatic quick exhauster, the generic issue of seismic qualification of accessories mounted on equipment, and the lack of engineering detail in design output documents leading to unacceptable installations. In response to these concerns, TVA has committed to improving the content of Engineering Change Notice (ECN) packages to include more design details, to an improved method of seismic evaluation for Instrument and Control (I&C) accessories, and to a sampling and review plan to determine the acceptability of accessories installed since issue of SQN's operating license.

NRC performed a special inspection of the G/C review and found it

' thorough and appropriate as indicated in a letter from Taylor to White (App. A, 5.x; 04/22/86). The NRC also indicated that the technical and generic issues appear valid. The issue of the 0103D-3 (05/14/87)

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TVA EMPLOYEE. CONCERNS' REPORT l NUMBER: 223.3 (B).

SPECIAL PROGRAM REVISION NUMBER: 2  ;

PAGE 12 0F 22 l pneumatic quick exhauster installation was classified as Deficiency item D3.1-1 on NRC I&E Report Nos. 50-327/86-27 and 50-328/86-27.- .c TVA responded on this item in a letter from GriJ1ey to Grace (App. i A, 5 3 07/28/86). The TVA corrective action re gonse stated that l seismic adequacy of the existing pneumatic'exhauster installation has'now been. adequately documented,'and no hardware-deficiencies .;

were found by the-seismic analysis.

Similar issues are also addressed in another NRC letter from Taylor ,

to White (App. A, 5.ee; 10/21/86) regarding possible degradation.of  !

j the seismic qualification of TVA's previously qualified equipment.

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H. TVA SON Generic Concern Task. Force Review & Element Report No.

80501 - 50N i

In June 1986, TVA SQN Generic Concerns Task Force (GCTF) reviewed employee concern IN-85-463-006 regarding " typical drawings for-instrument installation" ( App'. A, 5.cc). This concern was recently addressed in Element Report 80501-SQN (App. A, 5.dd). Both reports concluded that there were no " typical" drawings for-locally mounted y - safety-related instruments before the early 1980s; .that the

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l instrument qualification for harsh environment "walkdowns" showed problems with instrument mountings; and that the vi' Gilbert / Commonwealth report found that inadequate design drawings-had led to discrepancies with instrument mountings'.

I Findings: j 1'

a. The local panel-mounted pressure transmitters (1-PT-1-30 and 1-PT-1-26C) were installed in accordance'with the design drawing, which is based on documented engineering calculations and evaluations. Tne local field-mounted temperature switch 1-TS-30-103 was installed without a design l drawing mounting detail or documented evidence of application I of good engineering judgment which is integral to the engineering process industry-wide. Current requirements in the nuclear industry are to justify such judgment with l technical documentation. Based on review of-the recent calculation by the evaluation team, the temperature switch has now been determined to be adequate (App. A, 5.bb).

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0103D-3 (05/14/87)

i TVA EMPLOYEE CONCERNS- REPORT NUMBER: 223.3-(B)

SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 13 0F 22 1

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b. The local panels where both pressure transmitters were 1 mounted were qualified by testing and/or analysis. The as-built installation of local field-mounted temperature i switch 1-TS-30-103 lacked seismic analysis or other evaluation at the start of this report investigation as indicated in finding a. above. The design mounting bracket of the Foxboro transmitter shown on alternate Section Al-Al of Detail B19, Drawing _47W600-19 is more flexible than the qualified approximately 1-inch deep bracket. The evaluation team performed a qualification calculation for alternate Section Al-Al and determined that this detail is adequate.

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c. Instruments may be acceptably qualified to meet seismic requirement by analysis, testing, a combination of both, or '

similarity. Both pressure transmitters, 1-PT-1-30 and l-PT-1-26C, were seismically qualified by testing. The function of the transmitters was acceptable during and after  ;

seismic testing, according to documented information provided by TVA.

Temperature switch 1-TS-30-103 (Fenwal Model 18003-7) was

'N judged seismically qualified by TVA in 1975 based on similarity to another temperature switch (Fenwal Model [

17002-40) tested by General Electric (App. A, 5.aa). A 1982 i test report by Wyle Labs (App. A, 5.1) indicated that the function of the temperature switch was acceptable during and after seismic testing. The test results indicate adequate '

seismic qualification for temperature switch Fenwal.Model 18023-7. Since Fenwal Model 18003-7 is the same in form, fit, and function as Model 18023-7, temperature switch 1-TS-30-103 is seismically qualified by similarity.

Conclusions _:

Based on currer,t information, the evaluation team concludes that adequate documentation has been provided for the three instruments to demonstrate seismic qualification to the requirements of FSAR 1 Section 3.10. In addition, the panel mountings for the two transmitters similarly meet the requirements of FSAR Section 3.10; however, there was a lack of design mounting detail for the field-mounted temperature switch. Based on review of the recent calculation by the evaluation team, the temperature switch has now 3 been determined to be adequate. j i

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0103D-3 (05/14/87) k

TVA EMPLOYEETCONCERNS' ' REPORT NUMBER: :223.3 (B).

'SPECIAL PROGRAM REVISION NUMBER: 2~

PAGE.14 0F 22 The lack of an appropriate design mounting detail or evaluation prior to this investigation for the temperature switch _' indicates _a need for TVA review of' other field-mounted. local ' instruments. The -

documentation of seismic qualification of local instruments reviewed generally' meets TVA commitments in SNP FSAR Section 3.10 for the instruments reviewed, but weaknesses exist in.the. seismic documentation retrieval systems.'

Conclusion., regarding the specific issues raised by this employee concern are:

a. The issue that local ' instruments are' installed using good engineering judgment is valid.-

b. The issue that no seismic analysis'was performed for the installation of local panel-mounted instruments is not valid; however, this issue is valid for installation of local field-mounted instruments.

c. The issue that no seismic analysis was. performed for local

, _ _ , instruments is not' valid since proper qualification tests

~,}

,w were performed.

10. CORRECTIVE ACTION To comply with the design requirements, TVA has committed to the I following revised corrective action' plan (CAP) (TCAB-094; App.: A, I 5.hh). This revised CAP supersedes the previous CAP for Element.

Report 223.3(B) (TCAB-020; App. A, 5 99).

TVA will obtain a list of SQN Units 1 and 2 safety-related instruments from Sequoyah Critical. Structure, Systems, and Components (CSSC) List. The list will'be evaluated against TVA commitments made in Element Report 209.l(B).

TVA will perform a drawing search and field inspection as well as a seismic qualification documentation search.- This, process will establish completeness of design, verify.as-built installations, and ensure the existence of adequate seismic qualification documentation of all Unit 2 safety-related instruments required for safe shutdown, to mitigate core damage, or to prevent releases.in excess of 10CFR100 limits (FSAR Chapter 15 events) before Unit 2 restart. All other Unit 2 safety-related instruments and al.1 i Unit 1 safety-related instruments will .be subjected to the same-document search and field inspection process after Unit 2 restart.

0103D-3 (05/14/87)

1 1

TVA EMPLOYEE CONCERNS ~ REPORT NUMBER: ' 223.3 (B)

SPECIAL PROGRAM )

REVISION NUMBER: 2  :]

PAGE 15 0F 22 j

_These post Unit 2. restart activities will.be performed before restart of Unit l~, as confirmed by TVA in IOM 980(05/14/87; i App.A,7.w).

The field inspection will be. performed in accordance with procedures approved by Plant Operation Review Committee (PORC), or  ;

generic procedures that cover walkdowns,' surveys, and field' '

inspections, or procedures endorsed by Quality Assurance'(QA). .A l condition adverse to quality report-(CAQR) will be initiated and  !

corrective' actions will be provided for each incompletely documented or nonconforming -installation.- In addition, TVA j

indicated that_other design change audits have resulted in the following' actions that would preclude recurrence of the findings-  !

o TVA design interface document, CEB-DI 121.03, " Seismic.

Design, Review and Control" (App. A, 6.e), has been recently revised (05/86) to refine and strengthen the seismic design review process to ensure adequate seismic design qualification of instruments and their installations. SQN seismic review process of instruments is in accordance with J CEB-DI 121.03.

v' o Revision 2 of Sequoyah Engineering Procedure SQEP-13 issued in 12/86 and current revision 3 (03/87; App. A, 5.ii) require walkdowns before initiating an engineering change notice (ECN). This procedure provides a mechanism to identify potential installation problems in the design of mounting detail for future installation of instruments.

TVA's CAP, as described, meets its FSAR commitment for the Category I instrumentation at SQN. The evaluation team, therefore,  ;

concludes that the stated CAP is an acceptable resolution of.the concern and should also preclude recurrence of the findings.

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$ i V

01030-3 (05/14/87) i

i d

TVA EMPLOYEE CONCERNS-' REPORT' NUMB'ER: 223.'3 (B) 1 SPECIAL PROGRAM l REVISION NUMBER: 2- .

1 PAGE 16 0F-22 -!

l f

a APPENDIX A

5. DOCUMENTS REVIEWED RELATED T0-THE ELEMENT:

a. TVA Drawings:

'47B601-1-18, R52 - " Mechanical Instrument-Tabulation" 47B601-1-21, RS2 -

" Mechanical Instrument Tabulation" 47B601-30-28, R53 - " Mechanical' Instrument Tabulation" 47W600-31, R17- -

" Mechanical Instruments and Control" l 47W600-14, R4 -

" Mechanical Instruments and Control" 47W600-19, R13 .- Mechanical Instruments and Control"

(

47W600-92, R6 - " Mechanical Instruments and Control" 47W600-23, Rll -

" Mechanical Instruments and Control" 1 47W600-21, R8 - " Mechanical Instruments and Control" ]

47W920-5, R30 " Mechanical Heating, Ventilating and

. Air Conditioning" 47W352-3, R0 -

" Mechanical Instruments and Controls Panel - Seismic-Test"

b. TVA Procurement Contract:

~ 68C60-91934 Nuclear Steam Supply System for

"^

Undetermined Nuclear Plant (s)- (04/26/68)-

% 73C3-92784 ~ Pressure Switches (08/01/72) 75K13-86835 Temperature Switches (06/06/75) 72C33-92800 Fabrication of Local Panels and Installation of Instruments (04/14/72) 81PN1-829261 Temperature Switches (06/18/81)

c. TVA Specifications:

9382 Nuclear Steam Supply System-1569 Controls and Metering 1499 Controls and Metering

d. TVA Calculations:

Seismic Analysis of Instrumentation Rack Frame of Drawing 47W352 (06/29/72)

Seismic Qualification of Wall Mounted Panelssof Drawing 47W600-23 [B25 861002 801] (10/02/86)

e. Vendor Drawing:

Fenwal Drawing 18003-7, Rev. B/7 (06/21/68)

f. Westinghouse Topical Report, " Seismic and Environmental.

s Testing of Foxboro Transmitters," WCAP-8541, (07/75) .

01030-3 (05/14/87) t i

TVA EMPLOYEE CONCERNS- REPORT NUMBER: 223.3 (B) , ',

SPECIAL PROGRAM REVISION NutGER: 2 1

PAGE 17 0F 22

.o APPENDIX A (Cont'd)

g. Action Environmental Testing Corp. Test Report No. T3-1091,

" Seismic Vibration Test of E10 Series. Transmitters," (12/73)

h. TVA memo from F. H. Coleman to CEB files, " Seismic Qualification of Foxboro Series E10 Transmitters" for WBN Contract 828973,.[CEB810903252],(09/03/81)

1. TVA letter to Wolfe and Mann Manuf acturing' Company, dated November 19, 1974 from F. W. Chandler to D. M. Salisbury'on TVA contract 72C33-92800 transmitting approval-of Wyle Laboratories Test Report No. 42807-1.

j. Wyle Laboratories Test Report No. 42807-1, " Seismic Simulation Test Program on an Instrumentation Rack,"

(08/26/74)

k. Bailey Meter Company Test Report No. 507, " Seismic Vibration  !

Tests on GE-MAC Type 555 D/P Transmitters and Type 556 Pressure Transmitters," (revised 05/25/73)

~.

1. Wyle Laboratories Report No. 17509-1, " Qualification Plan for Fenwal Temperature Switches," Rev. C,'(05/07/82)

m. Wyle Laboratories Test Report No. 42377-1, " Seismic Simulation Test Program on Instrumentation Rack," (11/08/72)

n. Gilbert / Commonwealth Report No. 2614, " Final Report Technical Review of Sequoyah Nuclear Plant Modifications for TVA," i (03/03/86)

o. Letter from S. A. Varga, NRC, to G. Williams, Jr., TVA,

[ DES 761122 022] (11/16/76)

p. Letter from J. E. Gilleland, TVA, to S. A. Varga, NRC, ,

[ DES 770209 016] (02/07/77) l l

q. Letter from D. B. Weaver, TVA, to R. L. Keit'h, Wolfe and Mann l' Manufacturing Company, (04/17/73)

r. Letter from K. A. Henrichsen, Bailey Meter Co., to D. B.

Weaver,TVA,(05/25/73) i s. TVA memo from J. I. Givens to R. M. Pierce (01/09/73) l

'i 0103D-3 (05/14/87) j

TVA EMPLOYEE CONCERNC - REPORT NUMBEP: 223.3 (B) 1 SPECIAL PROGRAM 4 REVISION NUMBER: 2 i PAGE 18 0F 22 4 l

l ei APPENDIX A (Cont'd)

t. Letter from D. R. Patterson, TVA, to K. A. Henrichsen, Bailey j Meter Co., (06/28/73)

u. TVA memo from F. W. Chandler to W. S. Wilson, (06/03/75)  !

v. Letter from E. T. Murphy, Fenwal Inc., to F. Hannah, TVA. j (06/04/81)

{

w. TVA memo from R. L. Gridley to Those Listed, "Sequoyah Nuclear ]

Performance Plan - Volume II - Final Concurrence,"  !

l

[L44 860714 800] (07/14/86) )

x. Letter from J. M. Taylor, NRC, Director of Office of Infrection and Enforcement, to S. A. White, TVA, Manager of Nuclear Power,  !

"NRC Reports 50-327/86-27and50-328/86-27,"[L44860506542], I (04/22/86) i i

y. Letter from R. L. Gridley, TVA, Director of Nuclear Safety and l

r. . Licensing to J. N. Grace, NRC, Region II Administrator,  ;

-T " Inspection Reports 50-327/86-27 and 50-328/86-27. Response to i

( ,,. Deficiencies and Unresolved Items," [L44 860729 801], (07/28/86)

2. NRC's NUREG-00ll, Safety Evaluation Report related to operation  !

of Sequoyah Nuclear Plant Units 1 and 2, March 1979 l aa. TVA memo from F. W. Chandler to R. G. Domer with attached, "GE 1 Seismic Test Results, 225A6290, on Fenwal Switch 17002-40,"

(06/24/75) bb. TVA DNE Calculation, " Temperature Switch Mount Evaluation,"

[B25 861031 800]

cc. TVA SQN GCTF Report on Employee Concern No. IN-85-463-006, R1,

" Typical Drawings for Instrumentation," (06/04/86) dd. TVA Employee Concerns Report No. 80501-SQN, " Engineering Document Quality," R0, (09/24/86); R3, (12/17/86) ee4 Letter from J. M. Taylor, NRC, Director of Office of Inspection and Enforcement, to S. A. White, TVA, Manager of Nuclear Power, "SQN Units 1 and 2, Procurement Inspection, September 15-19, j

1986, September 29-October 3,1986," [ A02 861023 019),

e , (10/21/86) ff. TVA memo from J. T. Huie to CEB files, " Seismic Qualification of Temperature Switches, Wyle Test Report 17509-1" for TVA Contract TV-56071 A, [CEB 830726 254], (07/26/83) 0103D-3 (05/14/87) ,

e

TVA EMPLOYEE CONCERNS ~ REPORT NUMBER: 223.3 (B)

SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 19 0F 22 APPENDIX A (Cond) gg. TVA letter from G. R. McNutt to G. L. Parkinson, " Employee Concern Evaluation Program - SQN Restart Program - Corrective Action Plan," TCAB-020, (12/05/86) hh. TVA letter from G. R. McNutt to G. L. Parkinson, " Employee Concern Evaluation Program - SQN Restart Program - Corrective Action Plan," TCAB-094, (05/12/87) ii. Sequoyah Engineering Procedure SQEP-13, R3, " Procedure for Transitional Design Change Control," (03/05/87) jj. TVA memo from J. P. Vineyard to Those Listed, "Sequoyah Nuclear Plant - Seismic Design, Review, and Control -

CEB-DI 121.03," [B25 860317 005], (03/17/86)

6. WHAT REGULATIONS, LICENSING COMMITMENTS, DESIGN REQUIREMENTS OR OTHER APPLY OR CONTROL IN THIS AREA? I

, a. SNP FSAR Update through Amendment 3 Section 2.5, " Geology and Seismology" Section 3.1, "Conformance with NRC General Design Criteria" 1

Section 3.7, " Seismic Design" Section 3.10. " Seismic Design of Category I Instrumentation and Electrical Equipment"

b. Appendix F of Sequoyah Nuclear Plant Quality Assurance Manual, " Design Criteria for Qualification of Seismic Class I and Class II Mechanical and Electrical Equipment," R2 (01/24/73)

c. IEEE 344-1971, "IEEE Trial-Use Guide for Seismic  ;

Qualification of Class I Electric Equipment for Nuclear Power Generating Stations"

d. IEEE 344-1975 "IEEE Recommended Practices for Seismic Qualific6 tics of Class lE Equipment for Nuclear Power Generating S utions"

e. TVA Design Interface Document CEB-DI 121.03, R1, " Seismic Design, Review, and Control," (05/16/86) t 0103D-3 (05/14/87) t

TVA _MPLOYEE CONCERNS- REPORT NUMBER: 223.3 (B)

SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 20 0F 22 APPENDIX A (Cont'd)

7. LIST PEQUESTS FOR INFORMATION, MEETINGS, TELEPHONE CALLS, AND OTHER DISCUSSIONS RELATED TO ELEMENT.  ;

a. RFI SQN 557,(09/11/86)

b. RFI SQN 591,(09/24/86)

c. RFI SQN 610,(10/03/86)

d. RFI SQN 621,(10/06/86)

e. RFI SQN 690,(11/05/86)

f. RFI SQN 702,(11/08/86)

g. TVA Transmittal 116, Item 15 (09/22/86)

h. TVA Transmittal 120, Item 5 (09/26/86) .

1

i. TVA Transmittal 117, Item 3 (09/23/86)

I

~

j. TVA Transmittal 123, Items 5 and 7 (10/01/ff) '

k. TVA Transmittal 122, Item 9 (09/30/86)

1. TVA Transmittal 141, Item 6 (10/29/86)

m. Telephone call from L W. Benkert, Bechtel, to J. K.

Rochelle, TVA, IOM 'a37 (10/25/86)

n. Telephone call from J. K. Rochelle, et al., TVA, to J. W.

Senkert, et al., Bechtel, IOM 352, (10/24/86) )

o. TVA Transmittal 118 Item 6 (09/24/86) i

p. TVA Transmittal 124, Item 4 (10/' /86) ,

q. TVA Transmittal 150, Item 3 (11/12/86)

r. TVA Transmittal 149, Item 4 (11/10/86) l 0103D-3 (05/14/87) l

R

,I . TVA EMPLOYEE CONCERNS

• REPORT NUMBER: 223.3 (B) ,

SPECIAL PROGRAM f REVISION NUMBER: 2 j

=

a PAGE 21 0F 22 )

APPENDIX A (Cont'd)

s. TVA Transmittal 185, Item 2 (12/29/86) i I

t. Sequoyah Trip Report for September 19 and 20, 1986, IOM 563 ]

u. RFI SQN 622 (10/08/86)

v. Letter from G. L. Parkinson, Bechtel, to G. R. McNutt, TVA.

Subject:

" Document Request - SQN," BLT 037,(09/05/86) i

w. Telephone call from Y. K. Hui, Bechtel, to R.'D. Gish, TVA, IOM 980, (05/14/87)

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i 9

h 0103D-3 (05/14/87)

P

,- TVA EMPLOYEE CONCERNS - REPORT NUMBER: 223.3 (B) l l

SPECIAL PROGRAM REVISION NUMBER:.2 PAGE 22 0F 22 CATO LIST The following CATD identifies and provides corrective actions for the findings included in this report:

223 03 SQN 01 (Issues "a" and "b"; 12/04/86; CAP revised 05/13/87)  !

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