ML20236P010
| ML20236P010 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 11/10/1987 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8711170102 | |
| Download: ML20236P010 (55) | |
Text
.,,.
p' TENNESSEE VALLEY AUTHORITY -
CH ATTANOOGA. TENNESSEE 37401 SN 157B Lookout Place NOV 101987 U.S.. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.C.
20555 Gentlemen:
In the Matter of
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Docket Nos. 50-327 Tennessee Valley Authority
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50-328 SEQUOYAH NUCLEAR PLANT (SQN) UNITS 1 AND 2 - NRC INSPECTION REPORT NOS. 50-327/87-52 AND 50-328/87-52, SQN ESSENTIAL RAW COOLING WATER (ERCW)
SYSTEM AS-BUILT VERIFICATION INSPECTION - RESPONSE TO VIOLATIONS Enclosed is our response to Steward D. Ebneter's September 25, 1987 letter to S. A. White that transmitted a notice of three violations, two unresolved items, and four weaknesses for SQN. contains the response to the subject violations; enclosure 2 contains the response to the identified weaknesses; and enclosure 3 contains the list of commitments contained in enclosures 1 and 2.
TVA admits all six examples of violations 87-52-01 and 87-52-02.
- However, violation 87-52-03 is being denied because the drawing deviation on the 738-and 747-series relief valves found by the inspection team had been previously identified by TVA, and corrective actions were initiated before the inspection.
If you have any questions, please contact M. R. Harding at (615) 870-6422.
Very truly yours, TENNESSEE V LLEY AUTHORITY R. G idley, Di ector Nuclear Licen ing and Regulatory Affairs
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Enclosures cc:
see page 2 l
7 9711170102 871110 l
PDR ADOCK 00000327 fn o
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'l An Equal Opportunity Employer
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~* U.S..NucleahRegulatoryCommission Otf 101987 i
.ccL(Enclosures):
Mr.'G. G. Zech Assistant Director-for. Inspection Programs.
1 Office of Special Projects
.U.S. Nuclear Regulatory Commission 101 Marietta Street, NW, Suite-2900 Atlanta, Georgia 30323 Mr.;J. A. Zwolinski, Assistant Director for Projects Division of TVA Projects Office of Special Projects U.S.' Nuclear Regulatory. Commission 4350 East-West. Highway EWW 322 Bethesda, Maryland 20814 Sequoyah Resident Inspector-Sequoyah Nuclear Plant 2600 Igou Ferry Road
. Soddy Daisy, Tennessee 37379 I
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v iL ENCLOSURE 1 RESPONSE - NRC INSPECTION REPORT NOS.'50-327/87-52 AND 50-328/87-52 STEWARD D. EBNETER'S LETTER TO S. A. WHITE i
DATED SEPTEMBER 25, 1987 Violation 50-327. -328/87 No. 1 "10 CFR Part 50, Appendix B, Criterion III sta'tes that measures shall be established to assure that applicable regulatory requirements and the design basis for those structures,. systems, and components to which this appendix applies are. correctly translated into specifications, drawings, procedures, and instructions.
In addition, it states that design changes, including field changes, shall be subject to design control measures commensurate with those applied to the original design and be approved by the organization that performed the original design unless the applicant designates another responsible organization.
Contrary to the above, before the August 1987 NRC ERCW system as-built walkdown inspection, the licensee's design control measures failed to assure that applicable regulatory requirements and the design basis for the ERCW system were correctly translated into specifications, drawings, procedures, and instructions as follows:
A.
The design basis for the ERCW system was not correctly translated into drawings and instructions in that ERCW system drawing 47W845 did not reflect skid mounted valves in the ERCW lines that could isolate ERCW flow to the safety injection pump oil and bearing coolers and to the centrifugal charging pump oil coolers. Because of this, the licensee failed to provide any instructions for the initial or periodic alignment of the valves and failed to include the valves in the 31 day alignment verification required by Technical Specification Surveillance Requirement 4.7.4.a.
Additionally, ERCW system drawing series 47W845 was inadequate in that it did not reflect specified high point vent valves located between the instrument isolation valves and instrument root valves.
B.
The licensee failed to correctly translate applicable regulatory requirements and the design basis into specifications, drawings, procedures, and instructions in that the licensee allowed routing of safety-related cables through undesignated cable trays, without apparent regard to thermal loading, electrical separation, and volumetric tray loading. An example of this is the routing of cable IPP/18B through cable tray NK-B.
C.
The licensee failed to properly transfer the design basis and regulatory requirements into specifications in that the design specification for purchase of the ERCW screen wash pump did not specify that the pump be an ASME code Class III pump as required by the FSAR nor was action taken to change the design basis when it was determined to purchase non-code pumps.
D.
The licensee failed to properly transfer the design basis and regulatory requirements into specifications in that the metal flexible hose on the ERCW inlet and outlet to the diesel generator lube oil coolers was purchased to a design pressure of 100 psi instead of the 150 psi ERCW j
system design pressure.
Contrary to the above, in-plant changes which affect plant design were implemented without design control measures commensurate with the original design and without formal engineering approval.
E.
The licensee failed to take adequate design control measures commensurate i
with the original design in that the ERCW 2A traveling screen level differential transmitter was disconnected from its level detectors and the inlet level detector was removed from its well without review by any of the licensee's design organizations.
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F.
The licensee failed to take design control measures commensurate with the original design in that an ERCW loop cross connect was installed between j
two drain plugs downstream valves 2-67-674A and 2-67-674B without any a
formal engineering review or approval. Because of this, the licensee was I'
unable to establish two independent loops of ERCW as required by Technical Specification 3.7.4.
This is a Severity Level IV violation (Supplement II)."
1.
Admission or Denial of Alleged Violation (Example A) 1 (For clarity, the inspection report sections referenced in the alleged j
violation are reproduced herein before TVA's admission or denial.)
Inspection Report Section l'.a (Example A)
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"a. Conformance of ERCW System With The As-Constructed Drawings i
I The relative order of all branches and components was inspected to verify installation in accordance with the flow diagrams.
Several sets of in line valves located on the skids for the safety injection pumps and centrifugal charging pumps were not shown on the flow diagrams and were not labeled. These valves are in the lines to the oil and bearing coolers and appear to have been supplied by the vendor with the skid mounted motor and pump. These valves, if closed, would not allow cooling water flow to these pieces of safety equipment. This is considered a violation of 10 CFR 50 Appendix B Criterion III for failure to assure applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures, and instructions, and is designated as Violation 327, 328/87-52-01."
Inspection Report Section 3.d (Example A)
"With respect to the fact that valves critical to instrument functionability are not specified on plant drawings, the licensee was able to demonstrate that the specified instrument isolation valves were shown without labeling on instrument series drawings which are working level drawings for instrument technicians. The inspectors were unable, however,
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Admienion or Denial of Alleged Violation (Example A) (Continued) to identify the specified high point vents on any drawings. This is considered to be an additional example of Violation 327, 328/87-52-01, for failure to assure applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures and instructions."
Inspection Report Section 6.a (Example A)
"The inspectors noted that the sets of oil cooler and bearing cooling in line valves located on the skids for the safety injection pumps and centrifugal charging pump, which were not labeled nor identified on drawings, were also not properly controlled. Specifically these valves were not required to be aligned in the system operating instructions for ERCW, safety injection or centrifugal charging systems nor were they included in the Technical Specification surveillance instrucio'ns associated with monthly valve lineup verifications for those systems.
Additionally the valves were not locked, sealed, or otherwise secured in position. The inspectors are concerned that these valves, if mispositioned could prevent cooling water flow to the safety injection and centrifugal charging pumps thus disabling those pumps if they had been called upon in an accident. Although there was no apparent control over the positioning of these valves, the inspectors could find no direct evidence that the valves were ever positioned in a manner such that the affected pumps were not adequately cooled. This condition is considered to be a result of violation 327, 328/87-52-01 since these valves were not formally identified on drawings. Additionally this is concidered to have resulted in a condition of non compliance with Technical Specification surveillance requirement 4.7.4.a, from initial plant start up to shutdown in August 1985, in that these valves were not verified to be in the correct position every 31 days to demonstrate both ERCW loops operable.
The inspectors are concerned that had this deficiency not been identified I
during this inspection, this condition would have remained uncorrected at unit startup."
TVA's Admission or Denial 4
TVA admits this example (Example A) of the above violation occurred as stated.
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2.
Reason for the Violation Skid-mounted and instrument tigh point vent valves do not appear on the 47W800 drawing series because the skid valves were considered to be part of the skid equipment itself, and the high point vent valves were installed on field-routed sense lines that the engineering organization did not include on the drawings.
Since these drawings were used as part of the basis for the development of SQN's surveillance, operating, and maintenance procedures, those procedures did not list the valves.
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3.
Corrective Steps Taken and Results Achieved For the skid-mounted in-line process valves, the following actions are being taken:
(1) the Division of Nuclear Engineering (DNE) has identified the skid equipment within the Design Baseline and Verification Program (DBVP), Phase I, system boundaries; (2) Operations personnel are, in turn, taking this list of skid equipment and walking down unit 2 and common skid equipment needed for unit 2 operation to identify those valves in process lines to and from the skid equipment; and (3) the above process line valves associated with the skid equipment list will then be listed in the appropriate system operating instructions (SOIs) or surveillance instructions (sis - in the case of ERCW and component cooling water) by nomenclature description or valve number if it exists to ensure proper valve configuration control. This effort will be completed before unit 2 initial entry into mode 4.
For the high point vent valves, the DNE Instrument Project located, identified (with temporary stainless steel tags), and documented on instrument drawings or sketches valves associated with the unit 2 restart instrumentation from the root valve to and including the panel or instrument isolation valve. The unit 2 restart instruments include TVA-mounted instrumentation within the DBVP, Phase I, system boundaries meeting one of the following attributes:
reactor protection set (RPS) inputs, engineered safety feature (ESF) actuation, Final Safety Analysis Report (FSAR) postaccident monitoring (PAM), or technical specification (TS) devices.
SI-604 was revised to include the above instrumentation valves. This SI will verify proper position of the in-line instrument valves on a frequency of once every refueling outage.
Further, as a result of the procedure' enhancement effort at SQN, instrument maintenance instructions and sis that call for manipulation of the subject valves control their configuration by either nomenclature description or configuration control sheets.
4.
Corrective Steps Which Will Be Taken To Avoid Further Violations Walkdowns will also be conducted for unit 1 to ensure skid-mounted valves in process lines to and from the skid equipment within the DBVP, Phase I, system boundaries are controlled by the way of SI's and S0I's before unit 1 initially enters mode 4. In addition, the DBVP phase 2 effort will include the identification of other safety-related system's skid mounted in-line process valves. This effort, as outlined in TVA's May 12, 1987 DBVP Post Restart Scope and Schedule submittal, will be complete in January 1990 for unit 2, when SOIs are revised to contain valve numbers.
For instrumentation valves between the root valve and instrument isolation or panel valves, walkdowns will be conducted to identify unit i restart I
instrumentation valves before unit 1 initially enters mode 4.
In addition, skids within the Phase I DBVP system boundaries are being reviewed to ensure RPS input, ESF actuation, FSAR PAM, and TS instrumentation valves on the skids are appropriately identified.
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effort will also be completed before unit 2 initial entry into mode 4 (before unit 1 entry into mode 4 for unit i valves).
Further, a units 1 and 2, phase 2, effort will be initiated to cover the safety-related L
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Corrective Steps Which Will Be Taken To Avoid Further Violations (Continued) instruments not in the units 1 and 2 restart instrumentation effort. The phase 2 effort will include the production of drawings needed for control of the high point vent valves within the scope.
Further, an instrument engineering requirements specification will be issued requiring valves be tagged and identified on engineering output drawings.
Implementation of this specification is expected by Ebrch 15, 1988.
In addition, by June 1, 1988, unit 2 (January 1, 1989, for unit 1) in-line valves for process lines to and from skids within the DBVP, Phase I, system boundaries will-be included on the associated flow diagrams (47W800 series). The valve numbers will in turn be added to sis or SOIs.
It is important to note that, before this inspection, walkdowns had been initiated to identify skid-mounted valves in process lines to and from skid equipment.
SOIs were being revised coincident with and following the inspection as a result of these reinspection walkdowns.
5.
The Date When Full Compliance Will Be Achieved For skid-mounted valves in process lines to and from skid equipment within the DBVP, Phase I, system boundaries, full compliance will be achieved following issuance of the flow diagrams (47W800 series) with these valves identified and subsequent incorporation of those valve numbers within the I
appropriate sis and SOIs. We expect to complete this work by l
September 1,1988, for unit 2 and by April 1,1989, for unit 1.
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For skid-mounted valves in process lines to and from skid equipment within l
the DBVP, Phase 2, system boundaries, full compliance will be achieved f
following issuance of the flow diagrams (47W800 Series) with the valves l
identified (by October 1,1989, for unit 2; a schedule will be developed l
for unit 1) and subsequent incorporation of these valves within the appropriate SOIs. We expect to complete this work by January 1990 for unit 2 (a schedule for unit 1 will be developed).
For instrument high point vent valves, full compliance will be achieved upon completion of the Instrument Project's units 1 and 2, phase 2 (all other safety-related instruments), instrumentation effort. The effort should be complete by September 1989 for unit 2 (a schedule for unit I will be developed) as outlined in TVA's September 22, 1987 response to Inspection Report 50-327, -328/87-23 (violation 87-23-02).
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Admission or Denial of Alleged Violation (Example B) l l
(For clarity, the inspection report sections referenced in the alleged l
violation are reproduced herein before TVA's admission or denial.)
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Inspection Report Section 2.b (Example B)
"b. Cable Tracing The examination of selected Class 1E circu'its associated with the ERCW system was accomplished by physical inspection of the actual field
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f routing. Cables ware traced by applying a modulated RF signal.of 100Hz to
. selected conductors of each cable. The signal was then monitored from
-l it's initiation source through the length of the cable routing in. order to verify.that the installed configuration of the cable accurately reflected the approved. design routing. The cables selected for examination. initiate vital control and power functions within the ERCW system, and represent both electrical divisions. The following cables and associated system
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devices were examined:
Cable # Device Services Service 2PP686A ERCW Pump RA Power 2PP687A ERCW Pump RA Power 2PP693A SI Control - Pump RA Control 2PP 694 Aux Control - Pump RA Control 1PP712B ERCW -Pump NB Power 1PP718B SI Control - Pump NB Control 1PP719B Aux Control - Pump NB Control 2V3020A 2-FCV-67-130 Power 2V2021A 2-FCV-67-130 Control 2V3051B 2-FCV-67-138 Power 2V3052B 2-FCV-67-138 Control The inspectors noted the following conditions.
j Signal tracing was initiated on cable #1PP712B, which is the motor power feed for ERCW pump NB.
This circuit initiates from the Unit 1 6.9KV shutdown board IB-B and is routed through the plant raceway system and duct banks to the ERCW pumphouse where the motors are located. An RF signal was applied to the phase "A" and "B" bus stabs at the shutdown l
board and monitored from that point to determine whether the cable had been routed as shown on the computer generated cable pull card.
During
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the examination the inspectors observed that cable 1PP712B had been routed i
into tray segment AW-B, which was located between junction box JB-3933 and four inch conduit IPP712B. This tray segment is not shown on the cable pull card or in the licensee's computerized cable routing system (CCRS) which provides directions for installation of cable throughout the plant.
Consequently, the routing of this cable is not in accordance with applicable design documents.
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Admission or Denial of Alleged Violation (Example B) (Continued) i The examination of cable iPP718B also disclosed deviations from the routing specified on the pull card and in the CCRS. This cable provides ERCW system SI control for pump NB, and is routed from the 6.9KV shutdown board 1B-B to panel 1-R-51 in the control room. Design information specifies that the cable should route from tray NF-B to conduit 1PP1340B as it enters the 6.9KV panel. However, physical inspection indicates that l
the cable also routes through tray NK-B, and terminates in the panel via conduit 1PP1335B instead of the conduit specified by design.
l The identified routing deficiencies were discussed with licensee i
engineering personnel in order to determine their root cause. The discussions indicate,that similar problems had been previously identified by Employee Concern 238.01 and one of these problems, the routing of cable iPP718B through tray NK-B, may have been the result of a 1975: project memorandum on the subject of cable routing which states... 'For computer cable routing the node point in the cable tray network nearest the cable
-entry is chosen as,the starting point for the run. On occasion, a cable will enter the network near an intersection. Since some tray designations change at intersections, the computer routing may be such that the short segment of entry tray will not appear on the routing card. When this situation occurs, route the cable in this tray to the conduit even though the tray designation does not appear on the routing card, providing the l
voltage level of the cable and the tray correspond and the length of the cable from entry point to the intersection is not more than 10 feet.'
This memorandum was later incorporated into the requirements of licensee maintenance and alteration instruction (M&AI)-4 via revision 7 to that document and implemented during plant modifications.
This allowance was-later removed from M&AI-4 by revision and is not in the current version of that document.
Consequently, numerous cable installations may be routed through raceway segments which are not shown on approved design documents.
Although the routing of cable iPP718B into tray segment NK-B may have been the result of implementing the requirements of this memorandum, the deficiencies identified in the routing of cable 1PP712B, however, can not i
I be attributed to this document in that, the length of cable 1PP712B routed in unscheduled tray segment AW-B is longer than 10 feet, and is not at a point of entry or exit from the raceway network. Additionally, the routing of cable 1PP718B into conduit 1PP1335B instead of 1PP1340B is
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clearly outside the scope of M&AI-4.
l In response to these observations the licensee has initiated a technical l
evaluation of the identified deficiencies to determine whether important quality attributes such as thermal loading, voltage segregation, and electrical separation have been compromised.
While formal response has not been received, the preliminary evaluation indicates the existing installation is technically acceptable. However, of more generic concern are the implications associated with wide spread use of the previously i
mentioned project memorandum and the quantity of routing deficiencies.
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Admission or Denial of Alleged Violation (Example B) (Continued) identified in the team's relatively small inspection sample. The licensee has indicated in a response to employee concern 238.01 that an evaluation of the practices and procedures utilized in routing and installing cables at Sequoyah will be initiated and will include a review of relevant i
installation and inspection records stored on site.
This review will be utilized in establishing the accuracy of the CCRS and determining the adequacy of cable installations at Sequoya,h. This review is currently programmed to be implemented as a post restart long range program.
The inspectors have concern that the licensee's programs which were implemented to resolve electrical concerns, such as the ampacity review program, depend on the unverified assumption that cables are routed pursuant to cable pull cards and computerized cable routing syctem. As evidenced by this inspection finding, this assumption may not be valid.
The inspectors consider that additional action will be required to be taken by the licensee to properly bound the scope of this concern as
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either isolated or generic and to appropriately resolve the concern.
In pursing this resolution the licensee should also pro,1de technical justification for allowing 10 foot cable sections to enter cable trays not identified on the routing cards. This justification should include the elements of separation, segregation, volumetric tray loading, and thermal loading.
General Construction Specification G-38, ' Installing Insulated Cables Rated Up to 15,000 Volts,' requires in paragraph 3.1:
'Among other things, cable pull cards or cable schedules specify the route a cable is required to take between points of termination.
Measures shall be taken to ensure that this route is followed in installing the cable.
If instances occur where cables cannot be installed exactly as indicated on the cable pull card or cable schedule (see section 3.2.1.8.2.b for one example), the engineering project shall be notified for disposition. Alternate routes shall not be selected by OC/NUC PR without the approval of OE.'
As stated above cables 1PP718B and IPP712B were not routed in accordance with cable pull cards or cable schedules. With the exception of the routing of cable 1PP718B into tray segment NK-B there is no documentation or indication that alternate routing was appropriately allowed and approved by engineering. This failure to comply with cable installation l
instructions is considered to be an additional example of violation 327,
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328/87-52-02.
In the case of routing of cable 1PP718B into tray segment NK-B, the inspectors have been unable to ascertain that adequate technical j
justification existed for the previous M&AI-4 allowance for routing cable sections less than ten feet through unspecified tray segments if the cable j
enters the network at an intersection point. This is considered to be an j
additional example of violation 327,328/87-52-01 for failure to correctly
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translate applicable regulatory requirements and the design basis into specifications, drawings, procedures, and instructions."
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TVA's Admisalon or Denial l
TVA admits this example (Example B) of the above violation occurred as 4
stated.
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2.
Reason for the Violation A memorandum was written in August 1975 on.the subject of SQN cable routing and cable pull cards. The memorandum allowed limited flexibility consistent with the industry practice at the time for the routing of cable
.near the end component without this portion of the route being documented on cable pull cards.
3.
Corrective Steps Taken nnd Results Achieved The stioject memorandum is technically justifiable considering the following. The memorandum was for limited application, i.e.,
it was for use only where the exit from a cable tray could be facilitated by a different exit node. During construction of SQN, a typical situation would be for equipment located near an intersection of trays, field routing cf the cable would be optimized by routing the cable through an undesigna?.ed tray for a limited distance (no more than 10 feet).
In addition, this memorandum did not authorize routing deviations in the middle of a tray route and specifically required keeping the cable in the same voltage level tray.
Based on the above, the design of SQN cable tray system (i.e., physical distance between different divisional tray and lack of trays connecting different divisional trays), and the limited distance allowed, the likelihood of violating the ampacity, 10 CFR 50 Appendix R, voltage / train separations, equipment qualification, and cable tray loading design criteria is remote.
See the response to Violation 87-52-02 (Example F) for additional discusssion concerning cable routing issues at SQN.
4.
Corrective Steps Which Will Be Taken To Avoid Further Violations No further corrective actions are required.
5.
The Date When Full Compliance Will Be Achieved SQN is in full compliance.
1.
Admission or Denial of Alleged Violation (Example C)
(For clarity, the inspection report sections referenced in the alleged violation are reproduced herein before TVA's admission or denial.)
Inspection Report Section 1.d (Example C)
"The inspectors verified name plate data for all ERCW pumps, screen wash pumps, traveling screens, and strainers against vendor data packages and design documents. The only exception was the four ERCW screen wash pumps which were not ASME code stamped as required by the design documents.
The licensee's contract and bid specifications had been amended during the bid
' Inspection Report Section 1.d (Example C) (continued) process to eliminate ASME code requirements due to a lack of bidders.
These pumps were bid three different times before the existing pumps were purchased. The licensee stated that they intended to eliminate the code requirement in the design documents because of the problem in finding bidders to bid on ASME code stamped pumps of this type for the nuclear industry. This observation is being further reviewed by the integrated design inspection team for technical adequacy.
This is considered to be an additional example of Violation 327,328/87-52-01 for failure to assure applicable regulatory requirements and the design basis are correctly translated into specifications, drawings,. procedures, and instructions."
TVA's Admission or Denial TVA admits this example (Example C) of the above violation occurred as stated.
2.
Reason for the Violation TVA initially tried to purchase N-stamped ERCW screen wash pumps, as evident from Certified Design Specification SWP-DS-1925-2653-00, which required they be " designed, built, and stamped in accordance with ASME Boiler and Pressure Vessel Code,Section III, Class 3..." However, no bids were received on this invitation.
TVA then entered into negotiations with suppliers, culminating in Contract No. 76K35-B20227. Addendum 1 to this contract amends the TS to delete the N-stamp requirements.
It is likely that the FSAR preparer failed to recognize the specification changes incorporated in Addendum 1, but rather stated the original requirements from the body of the specification.
3.
Corrective Steps Taken and Results Achieved The screen wash pumps, as delivered, were designed to ANSI B58.1, were seismically qualified, and required the manufacturer to have a quality assurance program in accordance with ANSI N45.2, Sections 4, 8, and 9.
It further required that the motor satisfy electrical Class 1E requirements.
TVA interprets that the above specifications meet the requirements of TVA Class C and that the screen wash pumps are suitable for the service.
Therefore, this is a documentation problem cnly, and TVA commits to correcting the affected FSAR section in the next annual update.
4.
Corrective Steps Which Will Be Taken To Avoid Further Violations The incorrect FSAR specification that the screen wash pumps be American Society of Mechanical Engineers (ASME)Section III, Class 3, may be attributed largely to the unusual circumstances associated with their procurement, but also indicates inadequate review of the accuracy of the design code specifications in FSAR Section 9.2.2.
The former cause is an isolated occurrence requiring no further action.
The latter cause will be addressed by deleting all design code references from Section 9.2.2 and including an accurate correlation of TVA Class to design codes in FSAR Section 3.2.
This will be submitted in the next annual FSAR update.
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Corrective Steps Which Will Be Taken To Avoid Further Violations (Continued)
Future FSAR. revisions now require a " Review for Approval" in accordance with Nuclear. Engineering Procedure (NEP)-5.2 before submittal; therefore, j
no additional corrective steps are required.
In addition, an unreviewed safety question determination j
(USQD-10 CFR 50.59 safety evaluation) of the screen wash pumps will be 1
performed before unit 2 initially enters m' ode 4 to validate there is no impact on safe operation of the plant with the present pumps.
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The Date When Full Compliance Will Be Achieved j
Full compliance will be achieved upon issuance of the next FSAR update, which is scheduled for April 1988.
1.
Admission or Denial of Alleged Violation (Example D)
(For clarity, the inspection report sections referenced in the alleged violation are reproduced herein before TVA's admission or denial.)
Inspection Report Section 1.d (Example D)
"The inspectors identified that the metal flexible isolation hoses located on the inlet and outlet of the emergency diesel generator heat exchangers were ordered for a design pressure of 100 psi rather than the 150 psi-pressure rating of the ERCW system. The licensee stated that a typographical error had occurred in the 1973 bid and order process which identified the working pressure and temperature as 100 psi and 150 degrees instead of the intended 150 psi and 100 degrees.
Fortunately, the vendor had in fact supplied a part capable of operating at a higher pressure l
rating. During this inspection the licensee went back to the vendor for -
resolution of this concern and the vendor has now rerated the metal hose i
for operation at ERCW system design pressure.
This is considered to be an I
additional example of Violation 327,328/87-52-01 for failure to assure applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures and instructions."
l TVA's Admission or Denial TVA admits this example (Example D) of the above violation occurred as stated.
2.
Reason for the Violation These flex hoses were purchased with other components (i.e., piping.
l valves, etc.) for the diesel generator (dg) system.
The error on the design conditions for these hoses appears to have occurred because of the I
l wide range of conditions that was specified on this bill of material for
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the different dg support systems.
Specifically, the fuel oil system
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l pressure used in these procurement was 100 psig. This, along with the j
fact that the valves specified for use on ERCW have the correct design conditions, indicates a typographical error was made and propagated j
through the procurement process.
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3.
Corrective Steps Taken and Results Achieved Flexonics.(the metal hose manufacturer) was contacted concerning.the suspected typographical error referenced above and on August 10, 1987, provided documentation that the hoses they supplied were suitable for the installed service.
In addition, the bill of material for the hoses will be revised to reflect the actual design conditions for these hoses by l
April 1, 1988.
4.
Corrective Steps Which Will Be Taken To Avoid Further Violations TVA has design verification and. procurement-procedures that address preparation and checking of documents that transfer the design basis requirements to the procurement specifications. This error is' considered i
an isolated typographical error that was not caught in the review process. The existing programmatic controls for transfer of design basis requirements to' procurement specifications are considered adequate, and no further actions are deemed necessary.
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The Date When Full Compliance Will Be Achieved SQN is in full compliance.
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1.
Admission or Denial of Alleged Violation (Example E)
(For clarity, the inspection report sections referenced in the alleged violation are reproduced herein before TVA's admission or denial.)
Inspection Report Section 3.a (Example E)
"The 2A traveling screen level differential transmitter, 0-LDT-67-487 was observed to be disconnected from both the inlet and outlet screen level W
detectors and the inlet detector had been removed from its well. There were no provisions for preventing debris from entering the impulse line ports on the transmitter and there was no indication that the work was J
being controlled through either the licensee's modification program or maintenance / work request program.
This level transmitter is safety related and is designed to activate the traveling screens upon attaining j
normal pump operating pressure. This automatic function prevents clogging of the screen and assures proper suction pressure for the ERCW pump.
Again, the inspectors consider that modification of safety related systems without proper control and review is a significant deficiency with generic i
implications.
This item is considered to be an additional example of violation 328/87-52-01 for failure to subject adequate design control measures and approval to the work which disconnected this level q
transmitter."
TVA's Admission or Denial TVA admits this example (Example E) of the above violation occurred as i
stated.
J
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, 2.
Reason for the Violation This violation occurred because of the following reasons:
(a) The instrumentation involved was not on the Critical Structures, Syotems and Components (CSSC) List. Consequently, retention of maintenance records was not required.
i (b) The instrumentation involved has been, defective since the preoperational testing in 1980 making.it difficult, considering (a) above, to find documentation on the work leading to the disconnection.
of the level instrumentation.
i l
These reasons appear to have lead to undocumented work activities.on the instrumentation.
3.
Corrective Steps Taken and Results Achieved
'A temporary alteration control form (TACF) is being written to document the present condition of this instrumentation. The TACF will, in. turn, require DNE to evaluate the condition by the way of a USQD.
4.
Corrective Steps Which Will Be Taken To Avoid Further Violations The lack of documented work controls on this instrumentation is believed to be an isolated occurrence because of unique circumstances surrounding the ERCW screens and strainers.
The fact that the circumstances are unique is validated by the corrective steps outlined in the response to Violation 87-52-02 (Example C) (i.e.,
only a small (4-percent] error (including this instrumentation] was found
-I between the CSSC list and the instrumentation listed in SMI-0-317-61) and f
the results of the Plant Operations Review Staff (PORS) review outlined in
]
the response to observed weakness No. 1 (i.e., no operability issues were found for equipment within the DBVP, Phase I, system boundaries other than the ERCW screens and strainers).
-5.
The Date When Full Compliance Will Be Achieved j
Full compliance will be achieved upon the completion of the TACF and the associated USQD. This should be completed before unit 2 enters mode 2.
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1.
Admission or Denial of Alleged Violation (Example F).
l (For clarity, the inspection report sections referenced in the alleged violation are reproduced herein before TVA's admission or denial.)
Inspection Report Section 1.a (Example F) l "The inspectors verified.that two separate independent trains of I
mechanical components existed within the plant.
One-exception was found 1
which was located on the boric acid transfer pump and AFW pump space cooler return lines. An unidentified piping and valve assembly had been installed such that it connected the two drain plugs located downstream of the 674A and 674B valves. This piping would allow cross connecting of the train A and train B return headers. This short section of 3/4 inch pipe did not appear on the drawings. The licensee was unable to produce any l
documents showing when this' header cross connect had been installed.
The l
I licensee has since initiated action to remove this section of pipe. The licensee had_ identified this section of pipe as a drawing discrepancy on a previous design baseline program walkdown, however, the wnikdown did not identify this section of pipe as a train cross connect nor as an l
uncontrolled safety operability cencern.
The inspectors consider that
{
modification of safety related systems without proper control and review is a significant deficiency with generic implication and in this case one-that involves cross connecting independent trains of equipment.
This item is considered to be another example of violation 327, 328/87-52-01 for failure to subject adequate design control measures and approvals for this cross connect installation."
TVA's Admission or Denial TVA admits this example (Example F) of the above violation occurred as stated.
2.
Reason for the Violation i
l The installation of the piping and valve assembly cross-connecting train A l
and B ERCW return headers appears to have been installed during the l
original construction time period for hydrostatically testing of the A and 1
B train headers simultaneously. The temporary piping was inadvertently a
left installed and painted giving it the appearance of permanent piping.
]
The piping was identified during the DBVP walkdowns, but it was dispositioned improperly in that an operability issue was not declared and J
the issue carried only as a drawing deviation.
]
3.
Corrective Steps Taken and Results Achieved The DBVP drawing deviations were reviewed to determine if a similar condition existed elsewhere within the walkdown program, and this item was found to be an isolated case.
In addition, to ensure proper programmatic controls of temporary features and hydrostatic testing of piping during 1
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' ' l 3.
Corrective Steps Taken and Results Achieved (Continued) the construction time period, procedures for control of teruporary features and hydrostatic test of piping were reviewed (i.e., Construction Procedure No. P-17, " Documentation of Permanent Plant Temporary Features," required temporary features to be logged and tagged at the time of installation to document the existence and removal of the temporary procedures; and Construction Inspection Procedure No. 41, " Hydrostatic Test of Piping Systems," while it did not reference Procedure No. P-17, was revised in November 1980 to include system configuration on a marked up flow diagram to show test boundaries and temporary vent, fill, flanged joint, relief valve, and blank connections).
The results of the DBVP drawing deviation review (no other conditions similar to this violation) and the existence of programmatic controls of temporary features and hydrostatic piping during the construction time period provide strong evidence that this violation documents an isolated problem; and no further action is required.
4.
Corrective Steps Which Will Be Taken To Avoid Further Violations As described above, no further actions are required to preclude further j
violations of this type.
5.
The Date When Full Compliance Will Be Achieved SQN is in full compliance.
Violation 50-327, -328/87 No. 2 "10 CFR Part 50, Appendix B, Criteria V states that activities affecting J
quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished l
in accordance with these instructions, procedures, or drawings.
Contrary to the above, prior to the August 1987 NRC ERCW system as-built walkdown inspection, the licensee's drawings, procedures, and instructions were not properly prescribed or accomplished as follows:
A.
The licensee failed to properly prescribe or accomplish the installation of the ERCW pump house instrument sense line floor sleeve packing in that ERCW instrumentation drawings 17W600-2 and 17W600-3 and drawing 37W206-3
)
included conflicting requirements for the prescription of the sleeve packing height.
In addition, the licensee failed to properly install the I
floor sleeve packing in accordance with either drawings 17W600-2 and l
B.
The licensee failed to install heat tracing on the RA ERCW pump discharge pressure instrument line as required by drawings 17W600-2 and 17600-3.
C.
The licensee failed to adequately accomplish Standard Practice SQA-134 in that the safety-related ERCW screen level differential transmitters'and level detectors, and the safety-related ERCW high flow alarm transmitter were not listed on the critical structures systems and components (CSSC) list.
SQA-134 Appendix A Part I requires safety-related items to be on the CSSC list.
D.
The licensee failed to provide any instructions for positioning of valves located in instrument lines downstream of, primary root valves.
E.
The licensee failed to accomplish electrical equipment and design criteria instruction SQN-DC-V-12.2 in that Beldon Braid sheathed handswitch wiring
'within portions of the main control panel were not properly installed to prevent touching of cables between divisions.
F.
The licensee failed to adequately accomplish General Construction Specification G-38 in that safety-related cables IPP718B and 1PP712B were not routed pursuant to cable pull cards or cable schedules.
This is a Severity Level IV violation (Supplement II)."
1.
Admission or Denial of Alleged Violation (Example A)
(For clarity, the inspection report sections referenced in the alleged violation are reproduced herein before TVA's admission or denial.)
Inspection Report Section 2.c (Example A)
"The inspectors noted problems with the sleeves used to route instrument sense lines from the ERCW pumps in the upper level of the ERCW pump house to the next lower level where the affected transmitters and instruments were located.
Specifically ERCW instrumentation drawings 17W600-2 and 17W600-3 require vertical sleeves for the ERCtl instruments to be sealed and filled in accordance with the following note:
' Field to seal sleeves by filling them to a thickness of 12" 1"
with DOW Corning's 3-654B Silicone RTV foam and using Johns Manville Cerabianket or Cerafiber as the damming material.
Drawing 37W206-3, however, requires vertical sleeves for the ERCW instruments to be sealed and filled in accordance with the following note:
' Pack all sleeves with DOW Corning 3-654B Silicone RTV foam or equal to the thickness of the wall or floor using Johns Manville Cerablanket or Cerafiber as the damming material.'
The above two notes provide conflicting instructions on the actual installation of damming material within the vertical sleeves. These conflicting instructions are further complicated by a note on detail sketch A-6 and D-6 of drawing 37W206-6 which directs the water-tight caulking of both ends of the sleeves.
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'The licensee stated.that this damming' material was'to prevent flooding' from'the upper _' level to the'next lower level'wher'e; safety related
~
ele'ctrical transformers, motor control centers, and instruments were i
located.
t J
The51nspectors visually examined several vert'ical sleeves-(listed'below).
and noted-the following:
E O'
-All sleeves examined were seale'd on t.he top;only.
A11: sleeves extended approximately 6 -inches:up from the floor-instead 0
of 2 inches as shown on drawing '37W206-6.
A11 sleeves' appeared to~be dammed with black, sheet foam insulation, 0
not the materia 1'specified in either drawing note.
ll 0
The amount'of damming material in the. vertical sleeves appeared to be insufficient. 'The distance'from the bottom of the sleeve to the
. bottom of the damming material on several of th'e sleeves was as.
listed below:
INSTRUMENT DISTANCE FROM OTHER BOTTOM-REMARK
> PT-67-433
'26 inches PT-67-437.
30 inches 0-PT-67-441 31 inenes 0-PT-67-445 31 inches 0-PT-67-457 31 inches
]
0-PT-67-465 seal was broken and air was leaking 4
through 0-PT-67-468 28 inches
?
0-PT-67-480 28 inches These measurements reflected substantially less damming material was installed than required by either of the licensee's drawings.
=An inspector observed the licensee's removal of sealant and insulation from the vertical sleeve for the 0-PI-67-468 instrument line.
During the removal the inspectors were able to confirm some of the above listed items. The material used as the damming material was black foam pipe wrap insulation instead of the specified material and the sleeve was only packed to a depth of approximately 2.5 inches. After the completion of the inspection of the vertical
' sleeve the licensee filled the sleeve with the correct material and to the correct depth. Because of this finding it appears that all L'
vertical sleeves in the ERCW pumping station first level will need to be repacked and sealed to the specification of the design documents.
The licensee had initiated a work request to perform the repacking and resealing of these sleeves to the design specifications.
- - - _. _ _. = _. - - - - - _
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' These' deficiencies are considered to be addit.ional examples of Violation 327 328/87-52-02 for. failure to prescribe and accomplish activities affecting quality.in acecrdance with the specified drawings."
.3 TVA's' Admission or Denial i
TVA admits this example (Example A) of the above violation occurred as 3
]
stated.
2.
Reason for the~ Violation
'l This violation occurred as'a result of the following:
(a)- conflicting notes between drawings 17W600-2 and -3 and drawing
.]
37W206-3;'
(b)- misinterpretation of the drawing notes during installation of the sleeve filler material; (c). lack of details on drawings ~concerning sleeve height for the ERCW i'
pumping station sleeves; and-(d) different engineering disciplines were responsible for~the different drawings for the sleeves; i.e., 17W600s are instrument drawings, 1
while 37W206s are mechanical drawings.
. 3.
Corrective' Steps Taken and Results Achieved.
A design change notice (DCN) has been written to resolve the drawing discrepancies for the sleeve sealMg. Note 3 on drawing 17W600-2 was changed (the same note on the 17W600-3 drawing will be revised to be consistent with 37W206-3 by. November 15, 1987) to reference drawing 37W206-3 as the drawing for sleeve sealing at the ERCW pumping station. A workplan (WP) was, in turn, written to implement the above DCN and to document the removal of the original sealing material and resealing the vertical sleeves with DOW Corning-#3-6548 or equivalent RTV foam and to l
replace the 1 inch of the RTV foam with a silicone sealant GE-102 or equivalent. This work has been completed for the ERCW pumping station sleeves. The sleeve height discrepancy was resolved by revising the note on drawing 37W206-3 from 2 inches to 2-inch minimum.
4.
Corrective Steps Which Will Be Taken To Avoid Further Violations A review of the conditions surrounding this violation indicates this problem is probably isolated to the ERCW pumping station since other vertical sleeves in the plant have additional drawing details with respect i
~to sleeve height and fill material; but, as an added precaution, a L:
schedule is being prepared for determining the existence of vertical l '.
sleeves with fill material with the same design basis and for performing a subsequent walkdown to ensure proper sealing.
I.
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The Date When' Full' Compliance Will Be Achieved l
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-SQN is believed.to be in full compliance' based on the information
]
'available at this time.-
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Admission'or Denial of Alleged Violation (Example B) y..
P (For clarity. the inspection report sections referenced;,in the alked$,
j h
violation are reproduced herein before TVA's adinission or denial.')
- h y
f Inspection Report Se' tion 2.c-(Example B).
M c
.W "The inspectors' examined. instrument line slope and heat' tracing within the
[
ERCW pumping station. ERCW-instrument llities tihat are exposed' to t
3
. atmosphere are required-to be sloped to allow!'self-draining to prevent the Q;Q accumulation andLpossible freezing of stagnan't water;in.apcordance with SQN-DC-V-7.4.
Thetinspectors traced all EROW instrument;lirds in the,ERCW Q
pumping station that could possibly be expoed'.to f reezir6(conditions.
i The licensee. stated;that this-condition wasippplicable~6hly to the upper U
level of'the ERCWQump house. The'inspectprs:consideredLthislicenseed
. assessment was correct.- ' The ' inspectors dethrmined thst all of these lines 1
appeared to be-correctly sloped to allov'thdiself-draining of any water.
Theseinstrumentlinesarealsorequired,pecto%'at to be, traced in accordance
.with system" design and drawings.
The' irs rsidefdifiedthattheRA-ERCW pump di charge pressure instrument line did not have heat tracing as required by drawings 17W600-2 and 17W600-3.
Some of the other ERCW pumps J
' [Y ^f did have thi required heat tracing, however, it was not clearly evident
['
that all instrument lines shown to have heat tracing in fact do because of the laggingfon the lines.
The failure to install heat tracing on the RA J,"
ERCW pump discharge pressure instrument line pursuant to drawings, 17W600-2 and 63 is considered to be an1 additional example /of violation 327, 328/87-52-02 'for f ailure to adequa'tely accomplish activities hL affecting quality in accordance with specified draniuss."
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TVA's Admission or Denial
)
t c
TVA admits this example (Example E) of the above violation occurred as'
!, +.
stated.
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)
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z 2.
Reason for the Violation l.
During the performance of int erance of ERCU pump NA,3 the heat trac'e on 4
the sensing line to the pu discharge-prpnsure instrument line was
'(
identified as a restraint to removing the pump discharge spool piece.
A
~
work request (WR) was' written and'the heat trace removed using two electricians. The original two electricians did notbadequately document g
'the removal of the subject heat trace.
Further, the instructions and
, 9L drawings available for removal and reinstallation of the heat trece were F
]
marginal and as a result the heat. trace.was not reinstalled.
~
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- 3.. Corrective Steps Taken and Results Jehieved A WR has been written to reinstall the hea't trace on the ESCW pump RA l
discharge pressure transmitter sense line. This WR was determined not to be a pre-mode 4 entry requirement for unit 2 (but will be complet'ed.by 1
i
)
.)
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1
. 3.
Corrective Steps Taken and Results Achieved (Continued)
December 1, 1987)' based on the fact that this heat trace is for freeze protection.and current ambient temperatures are not such that freeze protection is needed.
In addition, since the WR on removal of the subject heat trace was written, the maintenance procedure governing planning of a maintenance activity (SQM-2) has been revised and maintenance planning has been improved.
~
To ensure the problem found was an isolated occurrence of failure to reinstall required heat trace, a WR was written to walk down five:
additional heat trace circuits (i.e., the heat trace circuits were associated with the fire pumps, main feedwater flow elements, refueling i
water storage tank high and low levels, and postaccident air sampling).
The walkdown has been completed and no problems were fcund.
4.
Cerrective Steps Which Will Be Taken To Avoid Further Violations As a result of the present maintenance planning procedure (SQM-2) programmatic planning requirements and enhancement since-the writing of the initial WR on ERCW pump RA and the associated heat trace, coupled with the fact that no problems were found during the walkdown of the five additional heat trace circuits, we believe this violation documents an isolated occurrence of the failure to properly reinstall heat trace.
The' vendor for the ERCW pumping stat-ion heat trace is different from that for CSSC heat trace; and the vendor drawings available, which indicate where the pumping station heat trace should be located, are marginal.
Further, adequate procedures and drawings exist for CSSC heat trace used elsewhere in the plant. To ensure proper removal and reinstallation of heat trace at the ERCW pumping station, SQM-2 will be revised by December 15, 1987, to proceduralize the requirements for working ERCW pumping station heat trace, i.e., a field sketch of and a basic reinstallation techniques for the heat trace. While SQM-2 is being revised, maintenance planners will administrative 1y implement those same requirements for any WRs' planned for the ERCW pumping station heat trace.
By June 1988, a new maintenance instruction will be written to control heat trace removal and reinstallion. Further, by December 15, 1987, an evaluation will be made to determine the need for revision of the present ERCW pumping station heat trace drawings.
5.
The Date When Full Compliance Will Be Achieved SQN will be in full compliance December 15, 1987, when administrative l
controls for WR planning are initiated, requiring ERCW pumping station I
heat trace field sketches and outlining basic installation techniques.
i
. 1.
Admission or Denial of Alleged Violation (Example C)
(For clarity, the inspection report sections referenced in the alleged violation are reproduced herein before TVA's admission or denial.)
Inspection Report Section 3.a (Example C)
"The inspectors noted while the screen level differential transmitters were safety related, the level detectors, which are designed to input level signals to the transmitters, were not.
This appeared to be inconsistent. Additionally, the inspectors noted that neither the safety related level transmitters nor the level detectors are listed on the licensee's Critical Structures, Systems, and Components (CSSC) list, SQA-134. These concerns are identified as an additional example of violation L27, 328/87-52-02 for failure to accomplish activities affecting quality in accordance with documented instructions.
During the inspection of ERCW instrumentation in the auxiliary building, flow transmitter 0-FT-67-206, which monitors ERCW flow to the station air compressors, was found to have its electrical transmitter removed from the fluid portion of the instrument. Two work requests (WR-B220452 and WR-B226246) were found on the transmitter, however, after reviewing the WR tags the inspectors were unable to determine if either tag covered the current condition of the transmitter. The licensee provided copies of the two active WRs to the inspector and WR-B226246 stated that the transmitter was broken and needed to be replaced. The licensee further provided a design change request requesting a replacement transmitter be acquired because the current type of transmitter is no longer available. This item has been identified by the licensee as an item to be corapleted prior to Unit 2' restart. The inspectors observed that this instrument is safety related and is designed to provide alarm capability to the control room operators so that the non-safety related piping to the station air compressors can be isolated by operator action on a high flow condition indicative of a pipe break. This instrument as well as its other train counterpart are not listed in the licensee's CSSC list, SQA-134. Again, this is considered to be an additional example of violation 327, 328/87-52-02 for failure to accomplish activities affecting quality in accordance with documented instructions."
TVA's Admission or Denial TVA admits this example (Example C) of the above violation occurred as stated.
2.
Reason for the Violation i
The instrumentation for monitoring ERCW flow to the station air j
I compressors (FT-67-206, FS-67-206, FT-67-209, and FS-67-209) was installed by Engineering Change Notice (ECN) 5414, which was issued March 1, 1981.
The instruments were not identified as CSSC during the implementation of the modification. Consequently, they were not added to the CSSC list.
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L_____._.__.__.__
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2.
Reason for the Violation JC21tinued).
During the performance of preoperational testing on the automatic ERCW screen wash system, the screen level instrumentation (LDT-67-470, -477, j
-482, and -487) did not function properly. As a result, the instrumentation (LDTs and associated LTs) was disabled, the screen wash system put,in manual mode, and the subject instrumentation not originally evaluated for inclusion on the CSSC list.
i 3.
Corrective Steps Taken and Results Achieved For the ERCW flow instrumentation to the station air compressors, it is important to note that, although the instruments were not listed on the j
CSSC list,~a search of maintenance history performed on the subject instruments indicates they have been treated as CSSC. The instruments are included in IMI-67 (requiring calibration every 18 months) and in TI-41-67 (the setpoints and sealing document). Further, NRC, during their performance of the Safety Systems Outage Modification (SSOMI)
Follow-Up/ Procurement Inspection, stated at the' exit meeting that while our system for application of the CSSC list to the performance of maintenance was cumbersome, it was adequate. As an extra check on the accuracy of the CSSC list, a comparison of the instrumentation listed in SMI-0-317-61 (approximately 220 instruments) snd the CSSC list was made.
The subject SMI was written to find and correct problems on instruments and their associated sense lines, e.g., bent tubing / piping, instrument l
I valve condition, instrument line support schemes, sense line slope, instrument line separation, and instrument mounting. The scope of instruments listed in the SMI was those referred to as phase 1 instruments, i.e., those instruments mounted by TVA, within the D3VP, Phase I, systems' boundaries, and meeting any of the following I
attributes: RPS inputs ESF actuation, or FSAR PAM.
As a result of the above comparison, three types of discrepancies were found:
(1) items not previously on the CSSC list (this included the ERCW flow instrumentation to the station air compressors and ERCW screen-level instrumentation that are specifically mentioned in this violation), (2) typographical errors, and (3) items previously identified or because of recent modifications. The CSSC error rate is most accurately defined by I
those discrepancies (17 total) categorized in (1) above, because any potential operability issues would be limited to this category.
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3.
Corrective Steps Taken and Results Achieved (Continued)
An analysis of discrepancies above indicates one discrepancy involves an instrument with no safety function and four discrepancies involve the ERCW screen level transmitters. The ERCW screen level instruments are no longer required on the CSSC since they do not perform a' safety function (i.e., DNE is able to write a USQD defending manual operations of the ERCW screens without the use of the subject instruments). The remaining 12 discrepancies involve ECN 5414 (described.above) and one ECN on the fifth vital battery.
From the discussion above, it is expected that no more than 12 instruments _will be added to the CSSC list. This is approximately a 5-percent error between the SMI instrumentation list and the current CSSC list.
The procedures in place (i.e., AI-19, Part IV, and AI-39)'should' result in the evaluation of future modifications and the discrepancies in category 3 (items previously identified or because of recent modifications) for inclusion in the CSSC list. AI-19 and AI-39 require the cognizant engineers.for modifications to present the modifications for review by the CSSC committee for determination of the need to revise the CSSC list. A Condition Adverse to Quality Report (CAQR SQP871476IDI) has been written because of "fifth vital battery" discrepancies and two ECNs (6810 and 6707) for which the equipment was declared operable before the CSSC Committee was presented the modifications for evaluation of the need to revise the CSSC list, which is inconsistent with AI-39.
4.
Corrective Steps Which Will Be Taken To Avoid Further Violations The CSSC list will be revised to include FT, FS-67-206 and -209 before unit 2 entry to mode 2.
Further, the resolution of the 17 discrepancies found during the comparison of the SMI and CSSC list will be complete
_before unit 2 entry in mode 2.
Also, as outlined in TVA's August 28, 1987 letter to NRC on the Q-List Program Development Status, TVA will provide an implementation plan for the Q-List by March 1, 1988. Further, as an additional accuracy check, the Instrument Project phase 2 instrument list will be compared against the CSSC list.
In addition, preliminary thoughts for corrective actions for CAQR SQP871476IDI include an evaluation of:
(1) the need for enhancing AI-19 (Part IV) with respect to the cognizant engineer's submission of changes to the CSSC list, and (2) the need for additional review of recently completed workplans to verify that needed changes to the CSSC list had been submitted to the CSSC Committee.
5.
The Date When Full Compliance Will Be Achieved SQN will be in full compliance after the phase 2 instrument list is compared with the CSSC list and any discrepancies resolved. We expect
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this to be completed July 1988.
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1.
Admission or Denial of Alleged Violation (Example D)
I' '
(For clarity, the'. inspection report sections referenced in the alleged 4
. violation are reproduced herein before TVA's admission or denial.)
/
Inspection Report Section 6 (Example D)
"The inspectors questioned the licensee w'ith respect to how in line
~
instrument and-vent valves between primary root valves and the' instruments-were' controlled. The. licensee informed the ins'ectors that control was p
maintained through skill of the craft. The inspectorsiconside'r that skill of the craft in itself is not an adequate control for assuring.that instrument' valves.are properly aligned and periodically. verified to be aligned. This is considered to be an additional' example of_ violation 327,.
-328/87-52-02 for failure to establish and implement written procedures for R
activities.affecting quality."
TVA's Admission or Denial, r
TVA admits this example (Example D)'of the above violation occurred; however sk111:of the craf t was not Othe only rcethod of control.
Control-
~
L was enhanced by the'use of configuration control sheets'for valve manipulation during maintenance and surveillance. testing by. plant procedures.,
- 2. _ Reason'for the Violation 7
The instrument valves between-the primary root valves and-the instruments are located on field-run sense lines,that are not shown on plant' l
drawings. As inscrument maintenance and surveillance instructions were written, the on1v valves-listed (until-the recent procedures enhancement
.j effort)'were those on plant drawings, consequently omitting the subject valves.
3.
Corrective Steps Taken and Results Achieved As outlined in the response to violation 87-52-01 (Example A), the Instrument Project has located, identified with temporary tags, and documented on instrument drawings or sketches those valves (from the root valve to and including panel or instrument isolation valve) in the unit 2 restart instrumentation scope. The restart instrumentation scope is outlined in the response to violation 87-52-01 (Example A).
Briefly, the
-unit 2 restart instruments are those TVA-mounted instruments within the LBVP, Phase I, system boundaries that meet one of the following attributes:
(a) RPS input, (b) ESF actuation, (c) FSAR PA%, or (d) TS device.
Subsequent to this walkdown, SI-604 (Essential Instrument Operability Verification) was revised and an appendix added for verification of proper l
< alignment of the in-line. instrument valves, identified by the Instrument Project above, on a once per refueling outage frequency.
In addition, as a result of the procedures enhancement effort, maintenance and surveillance instructions that call for the manipulation of the subject valves have instituted valve control by the way of either a nomenclature description of the valve or a configuration control sheet.
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. I 4.
' Corrective Steps Which Will Be Taken To Avoid Further Violations I
1 Before unit 1 initially enters mode.4, the same scope of work as outlined i
in the corrective' steps above will be completed for unit i equipment.
)
Skid equipment within the DBVP,' Phase I, system boundaries is being reviewed to determine if instrumentation valves (i.e;, for instrumentation meeting any of the four attributes listed above) on skids require controls similar to those outlined above.
If similar controls are required, they will be implemented by a revision of SI-604 before unit 2 initially enters mode 4 (before unit 1 initially enters mode 4 for unit 1 instrumentation valves).
In addition, a phase 2 (all other safety-related instruments) instrumentation effort will be conducted to determine if any_other safety-related instrumentation exists requiring commensurate procedural controls for the valves. The schedule for completing any needed procedural controls will be included in the March 1988 schedule to which TVA committed in the August 14, 1987 submittal on Maintenance Instruction
-Enhancement Effort.
Further, an instrument engineering requirements specification will be issued requiring valves be tagged and identified on engineering output drawings.
Implementation of this specification is expected by March 15, 1988.
5.
Th__e Date When Full Compliance Will Be Achieved Full compliance will be achieved upon the completion of procedural controls for the units 1 and 2, phase 2, instrumentation valves. The
-schedule for completing any needed procedural controls will be included in the March 1988 schedule te which TVA committed in the August 14, 1987 submittal on Maintenance Instruction Enhancement Effort.
1.
Admission or Denial of Alleged Violation (Example E)
(For clarity, the inspection report sections referenced in the alleged violation are reproduced herein before TVA's admission or denial.)
Inspection Report Section 2.a.3 (Example E) k "The examination of components in Main Control Board 0-M-027, disclosed several installation deficiencies. This panel houses the ERCW systee transfer and hand switches required for manually operating system components. Due to proximity of these devices, redundant divisional cables have been routed into the same panel and installed in barriers such as 'Belden Braid' in order to diminish the effects of a locally generated fire. The installation of circuits in enclosures containing more than one division of redundant Class 1E wiring is controlled by section 4.4.6.1 of L
Sequoyah Design Input Memorandum on Separation of Electrical Equipment and l
Wiring Design Criteria SQN-DC-V-12.2, which states:
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Inspection Report Section 2.a.3 (Example E) (continued) x;
>'The minimum separation distance between redundant Class 1E circuits internal to Control' Boards, Panels, Relay. Racks, etc., shall be six inches of free air' space...Wherever this separation distance is not m&intained, barriers shall be provided be' tween redundant Class 1E wiring. Within the Westinghouse supplied main and auxiliary control room panels, braided sheath material, such as Belden Braid, is an acceptable barrier for reducing the redundant Class 1E separation to
~
less than six inches. The braid shall be used only over wire with
' teflon or.other approved insulation.. Braid covered wiring for redundant Class 1E circuits shall be restrained such that their braids do not touch nor shall they be able to migrate with time to touch.'
o The requirement reflects'the TVA response to NRC question 7.31 of the FSAR which prohibits the use of Belden Braid as a barrier me.terial in lieu of-l the' required six inch separation.
In response to this question the licensee's FSAR provides the follow commitment...' Wiring for each train is.
routed from the field to separate vertical risers, separated horizontally in enclosed horizontal wireways and then routed from the wiring to the enclosed switch module using metallic cover cables. Maximum air space between cables of different trains has been maintained and in no case does L
cable from a different train touch or can migrate with. time-to touch.'
Contrary to this' requirement the inspectors identified numerous examples l
of redundant wiring whose braids were in physical contact within panel l
0-M-27.
Most of the deficiencies noted occurred between risers located in the panel, and were the result of inadequate training of cabling to their
. respective hand and transfer switches. This condition was also identified in some sections of the auxiliary control panel, and'was in evidence in other portions of the main control boards.
In response to this issue the
_ licensee presented CAQR SQP-87-1325IDI, written July 30, 1987. This j
document identifies the existing deficiencies in panel 0-M-27 and proposes l.
corrective actions which would require the retraining of cables to assure conformance with the separation requirements. However, the CAQR does not
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address the existence of similar deficiencies in other portions of the l
main and auxiliary control boards. Consequently, additional work will be i
l required to' assure that redundant panel wiring is in accordance with
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separation requirements. The inspectors consider that this deficiency may i=
be generic to all portions of the main and auxiliary control panel. This l.
item is considered to be a violation of 10 CFR 50 Appendix B Criterion V L
for failure to accomplish activities affecting quality in accordance with j
l documented instructions and is designated as Violation 327, 328/87-52-02."
l TVA's Admission or Denial TVA admits this example (Example E) of the above violation occurred as etated.
- 4 2.
Reason for the Violation This violation occurred because of the lack of design detail in providing a method or hardware necessary to establish and maintain separation of the j
Belden Braid.
3.
Corrective Eteps Taken'and Results A;hieved DNE determined the use of Beiden Braid was limited to main control room and backup control room boards where multiple trains are within the same space and initiated WRs to perform a quality-controlled walkdown of the affected boards. The walkdown will identify the occurrence of and correct i
Belden Braid separation in accordance with drawing 45W1640, revision 5, (Control Boards Critical Wiring Braid Installation) note 2 (" Maintain maximum air space between Train A and Train B wiring assemblies and bundles.
In no case shall wiring assemblies from different trains touch or be able to migrate to touch.").
This drawing was recently revised (September 22, 1987) to add Detail D concerning the separation of Belden Braid cables. The affected boards are 1, 2-M-1 through 1, 2-M-6; 1, 2-M-9; 0-M-12; 0-M-27A; 0-M-27B; 1 _2-M-30; 1, 2-M-31; and 1, 2-L-10.
A note of clarification is in order. The inspection report accurately states that the associated CAQR (SQP871325IDI) documents Belden Braid deficiencies in panel 0-M-27 (in the description of the condition), but.it appears NRC believed that 0-M-27 was the only panel TVA intended to check for deficiencies. Part B of the subject CAQR documents this issue required a generic review; and, as outlined above, TVA identified additional panels with deficiencies as a result of the review of this issue.
4.
Corrective Steps Which Will Be Taken To Avoid Further Violations No further actions are needed to avoid further violations since all use of Belden Braid in main control room and backup control room panels is within I
the scope of corrective steps outlined above.
5.
The Date When Full Compliance Will Be Achieved Full compliance will be achieved before unit 2 initially enters mode 4.
1 1
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Admission'or Denial of Alleged Violation (Example F)
(For clarity, the inspection report sections referenced in the alleged violation were reproduced herein for Violation 87-52-01 [ Example B]).
l TVA's Admission or Denial TVA admits this example (Example F) of the above violation occurred as stated.
I 2.
Reason for the Violation For the cable routing discrepancy where cable iPP712B was found routed into cable tray segment AW-B, the tray segment was added to the route by Field Change Request (FCR) 420 and not reflected back into the cable routing program or reflected on the actual pull card.
This tray segment 2
was used to translate six power cables from a horizontal to vertical
)
configuration instead of utilizing conduit. Two errors occurred.
First the cable routing program data base was not updated to reflect the FCR, and second, the actual pull card was not noted with the additional tray segment.
For-the cable routing discrepancy where cable 1PP718B was found routed through cable tray NK-B, instead of NF-B and terminated at.the 6.9 kV panel by way of conduit IPP1335B, instead of 1PP1340B, the routing used was for convenience since cable trays NK-B and NF-B intersect and the i
conduits'are paralleled (see the attached sketch).
3.
Corrective Steps Taken and Results Achieved The routing discrepancies above were evaluated for acceptability in the following technical areas (later referred to as the five basic criteria):
ampacity, 10 CFR 50 Appendix R, voltage / train separation, environmental qualification (EQ), and conduit / tray overfill.
]
For cable 1PP712B, cable tray segment AW-B took the same route as the conduit designated in the cable routing data base.
Therefore, voltage / train separation, Appendix R, and EQ design criteria are met.
The 1
tray segment was an engineered segment and filled to only 20 percent with six power cables. This low loading ensures ampacity and tray loading are f
bounded. Therefore, the as-routed cable is technically acceptable as is.
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For cable 1PP718B, cable tray NK-B and conduit IPP1335B are the same voltage and separation group es the tray and conduit specified in the cable routing data base. Since the sctual cable route used was parallel and in close proximity to the cable routing data base route (on an intersecting tray) separation, EQ and Appendix R analyses remain intact.
There is no impact on tray and conduit loading since there was a one for one swap of cables involved; and, since these cables are used for control, ampacity is not a problem because of the low currents involved. Thus, the as-routed cable is technically acceptable as is.
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4 The issue regarding the accuracytof the overall SQN cable routing program and the installed cable configuration has been addressed in several restart activities,~e.g., EQ, employee concerns, and condition adverse to i
quality reports. The overall program will be divided into two efforts:
short term and long term. The short-term effort will support SQN unit 1 and 2 heatup/startup and is based on the review /results of the following restart efforts: EQ, cable testing, Appendix R, ampacity, and cable routing findings from this inspection and Inspection 50-327-328/87-18.
Long-Term Program The long-term program will focus on the as-construction of the cable routing data base. This approach implements the same philosophy as our
- DBVP, i.e., verification of functionality is a restart requirement while l
configuration is a postrestart requirement.
i Short-Term Program The confidence necessary to support heatup and restart of SQN has been gained subsequent to our review of the cable routing issue and the associated restart effort mentioned above.
The subject review ensured FSAR Chapter 15 accident detection, investigation, and monitoring were not adversely impacted by the cable routing issue.
Factors considered during l
the review included programmatic controls in place for the routing of cable, the design of the cable tray system, verification of the cable routing program, all to ensure train separation.
Further, the review included ampacity, voltage regulation, cable tray loading, Appendix R, voltage segregation, and equipment qualification, all to ensure functionality. To date, this review has resulted in only four instances where an as-routed cable failed to meet the design criteria for one of the five basic technical areas addressed in the evaluation. These four i
failures to meet'the design criteria came from a total of 822 cables
{
evaluated.
Programmatic Controls:
Cable installation procedures have been in place since the start of construction to control this process.
During the construction phase, two procedures governed this work.
From January 10, 1973, to October 4, 1977, Procedure E-6, " Electrical Cable Storage and Installation," was in force. From 1977 until the end of construction, Inspection Instruction No. 28, " Cable Pulling Inspection," was in place.
Modifications and additions since the plant was turned over to Operations have been controlled by M&AI-4, issued October 3, 1979.
Typical of those procedures is the following information from Inspection l
Instruction No. 28, the controlling document during the most active period of I
cable pulling for unit 2.
This procedure required witness of class 1E cable installation. Specifically, paragraph B3 requires the inspector to check one physical routing for compatibility with the specified routing, to check with the engineer if problems were found, and to STOP pulling until resolved.
i Further, paragraph 6D required inspection of non-1E cables in IE trays.
i No redundant train interactions have been found to date.
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. j Design of the Cable Tray System: The tray system is designed with physical separation between different divisional trays.
Further, the design precludes one tray from connecting two different divisional trays. Therefore, the i
design makes interaction of different trained cables difficult.
Verification of Cable Routing Programs This program has been verified that for a given input the proper output is obtained.
Ampacity: As part of restart, TVA has regenerated all class 1E calculations.
As part of this effort, all class 1E power cables in trays were resized.
Based on the results of this analysis, 116 cables were replaced.
In replacing these cables, the point of tray exit and entry was in conformance with the design documents; and no evidence of tray or conduit misrouting was discovered.
4 Voltage Regulation: The calculations used the cable lengths on the cable pull cards. Construction practice required the craft to write the lengths pulled f
off the reel to account for their productivity. This is conservative as the length pulled off the reel is typically more than the length actually used, considering that the ends are cut to accommodate the configuration.
Appendix R: This was a restart activity that identified the Appendix R required shutdown cables and field verified points of exit and entry for those cables where a potential interaction of the redundant shutdown paths could occur in the raceway system. This verification confirmed that the cable was I
installed as designed at the points of exit and entry into the tray system.
i The verification involved use of the cable data base to walk down the route
)
where required from source to load at points of exit and entry.
This was j
documented on a dimensional sketch.
This ef fort looked at approximately 276 cables. Thirty-eight occasions were found where the entry and exit points
)
differed from the cable route data base.
Voltage Segregation: The design reflects a very conservative approach in maintaining five voltage classifications in the raceway system.
The 6.9 kV and instrument cables are susceptible for causing /being impacted by incorrect voltage segregation. However, both of these types of cables are shielded and have the proper spacings or twisting to mitigate the consequence of any electromagnetic or electrostatic effects.
Therefore, any discrepancy with regard to voltage segregation would not impact the cable's ability to perform its function.
Equipment Qualificaiton: The cable data base was used to determine the type of cable and whether it was in containment or out of containment. A given cable type was qualified for a worse case environment.
If it was necessary to take credit for less harsh environment, walkdowns were conducted to verify location where routing (specific location) was critical to the EQ determination.
Tray Loading: CEB has analyzed the tray fills based on field verified profiles and received a draft SER on this issue on December 5, 1986.
Five specific restart efforts lead to the evaluation of the routing of 822 cables. The five efforts were:
Inspection Report 50-327, -328/87-18; cable testing; Inspection Report 50-327, -328/87-52; Appendix R; and ampacity.
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The scope of each effort with regard to total cables, partial / complete routes, l
cable routes inconsistent with cable route data base, failure to meet design criteria, and conclusions (based on an evaluation using the above five basic criteria) is presented in the following matrixt EFFORT POPULATION PARTIAL COMPLETE ROUTE DIFF.
FAILURE CONC.(1)
ROUTES ROUTES FROM CRDB(1) TO MEET DESIGN CRITERIA IR-87-18 78 0
75 3
1 Technically ade-quate, however, 1E cable will be replaced in IE tray CABLE 319 304 15 5
0 Technically ade-quate TESTING 0
Technically ade-IR 87-52 11 0
11 2
TVA FURTHER quate INVEST.
6 6
0 5
0 APP. R 276 276 38 3(2)
Technically ade-Quate AMPACITY 135 99 36 0
0 TOTAL 822 685 137 53 4
(1) CRDB - Cable Routing Data Base, DIFF.-Different, CONC.-Conclusions (2) To date 12 of the 38 routes not like the CRDB have been evaluated, and this table reflects those findings. The remainder of the routes will be evaluated by 11-15-87.
IR 87-18 The three routing inconsistencies in this program were two non-1E cables routed in a 1E tray and one 1E cable in a non-1E tray. These are documented in CAQRs SQP870702 and SQN871585 respectively.
Before the initial unit 2 entry into mode 4, the non-1E cables will be traced either by a hand-over-hand walkdown or signal tracing to determine if the cables are associated with redundant equipment.
If no redundant equipment interaction is found, the installation will be technically acceptable and will be used as is.
Before the initial unit 2 entry into mode 4, the 1E cable in the non-1E tray will be placed into the proper tray.
Cable Testing The routing inconsistencies found in the cable testing program consisted of five control cables taking alternate conduit routes to the scheduled destinations.
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Each of these cables utilized a conduit which paralleled the scheduled conduit. In each case none of the five basic criteria above were violated because the actual path was of the correct voltage and separation group,
.ampacity is not a concern in control cables, the paths were addressed for Appendix R, the cables are all environmentally qualified for the paths, and the conduit fills are appropriate.
Based on this evalution, these cables are l
technically acceptable as is.
IR 87-52 The routing inconsistencies for this effort are specifically addressed above.
However, as a result of the review of these specific issues, six other cables were evaluated. Five of these cables were identified in tray AW-B, with the other cable identified in conduit IPP1335B.
For the five cables routed in tray AW-B, the technical evaluation is the same as noted for the specific cable routing inconsistency discovered during this inspection with the same results, i.e.,
technically acceptable as is.
Appendix R (see discussion above)
Each cable was evaluated for Appendix R considerations from actual tray entry and exit points, and protection added based on those findings. The remaining four basic criteria were used to complete the evaluation of each routing I
inconsistency. To date, three occurrences of failure to meet the design criteria for cable tray loading have been discovered. These three occurrences will be evaluated as part of SCRCEB8622 and the interim acceptance criteria l
which were approved in the December 10, 1986 draft SER on cable tray loading.
NRC also asked that we address the following questions with respect to cable 1
routing:
1.
"How does TVA assure that non-1E cables which are routed with lE cables do not cross the redundant division?"
Programmatic controls for installation of cables were maintained as outlined in the Short-Term Program Programmatic Controls discussion.
In addition, General Construction Specification G-38 (" Installing Insulated Cables Rated Up To 15,000 Volts") required in paragraph 3.1:
"Among other things, cable pull cards or cable schedules specify the route a cable is required to take between points of termination.
Measures shall be taken to ensure that this route is followed in installing the cable.
If instances occur where cables cannot be installed exactly as indicated on the cable pull card or cable schedule (see section 3.2.1.8.2.b for one example), the engineering project shall be notified for disposition. Alternate routes shall not be selected by OC/NUC PR without the approval of OE."
r Further, from a design controls perspective once a non-1E cabic is routed with a 1E separation group, it is controlled by TVA's computerized cable routing system that enforces separation throughout the tray system.
- _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - - _ _ _ - _ = _ _ _ - _ _ _ _ _ _ - _ _ _ _
.. For SQN, cables are assigned a node voltage (NV) designation that delineates voltage separation and divisional separation (e.g., NV10 is voltage level 3, train A). - To accomplish these separations, separate tray networks (continuous tray segment paths) have been designed and given the individual NV
' designations. At no place do-any of the networks intersect; this was verified during the computerized cable routing system verification and validation process. Therefore, once a cable has been assigned to a particular NV, it cannot cross to another NV network. Manually routed and computer-routed cables must be assigned to a network in order to be accepted for routing.
This assignment is required by the cable routing system as a minimum input.
No instances have been discovered where divisional cables have crossed into the redundant group. Thus the proven capability of the routing system will prevent non-1E cables that enter the tray path from migrating to the redundant tray.
In addition, the physical distances implicit in separation between redundant i
divisions make it very difficult for one divisional cable to be routed in the other divisional cable tray because no trays interconnect the separation groups.
The TVA field investigation for Appendix R and ampacity produced a total of 411 cables with tray to conduit interfcces. Of the 411 cables, 394 are class 1E and 17 are non-class IE.
There were 38 inconsistencies between the cable routing program and the actual routing for the subject cables. Thirty-seven are routing inconsistencies of IE cables, and one is a routing inconsistency for a non-1E cable. All non-1E cables were found routed to nondivisional trays, both in the' field walkdown and cable routing data base. This sample did not identify any non-1E cables in IE trays needed for detection, mitigation, and monitoring chapter 15 events.
2.
"In the instance where a 1E cable entered a non-1E tray, has TVA assured that there is no interaction with redundant 1E cables?"
As mentioned above, the subject 1E cable will be placed in the correct divisional tray before the initial entry of unit 2 into mode 4.
The specific 1E cable (IV2943B), control voltage level 3 (NV11), entered the non-1E tray in error (documented on CAQR SQN 871585). Using the cable routing data base, no other interaction with a A-train or B-train 1E cables or nondivisional cables associated with A-train IE cables has been found in the subject non-1E tray. This problem is believed to be an isolated error, as a result of our review and the fact that the cable was not installed per design cable pull card, upon exit from the non-1E tray, the subject cable enters the correct 1E conduit. As stated in response to question 1, once a cable enters a given group of trays, it is highly unlikely to cross over to a redundant tray group because of programmatic requirements and physical separation of redundant divisions.
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3.-
"Does TVA take credit 'for non-1E isolation devises -between IE 'and non-1E circuits, and.if'so, where?"-
,SQN'is not committed to R.G.1.75; however, consistent with similar:
vintage plants, credit'has been.taken for non-1E iso 1ation devices
.between 1E.and non-1E circuits-inttwo areas, Appendix R and containment penetration protection.
Appendix R. analysis.took credit for non-1E circuit' protection'to prevent-fault propagati t between required circuits, and specific analysis'has.
shown the installed protection is adequate.
For containment ' penetration protection. TVA. does ensure redundant -
overcurrent protection for all electrical. containment. penetrations, including-those penetrations. connected to non-1E power. systems.by combinations of fuses'and/or breakers. TVA further ensures separations-by installing independent 1E. penetrations and non-1E penetrations.
~
Cables use the appropriate divisional penetration.
4.
. Corrective Steps Which Will Be Taken To Avoid-Further Violations A long-term cable' routing pregram will-be conducted to:
-(1)
Verify.the existing computer program for cable routing.
'(2).
Directly compare cable tray drawings.to the a(cual installation to verify cable tray installation.
(This is the cable tray network, not the. cable routing within the network.)
(3)
Ferform a walkdown to determine the entry and exit points of the cablas. The walkdown results will, in turn, be evaluated against the cable program, and discrepancies resolved.
(4)
Using the walkdown data, add new intermediate' cable tray node points to the computer program to more accurately define cable routing.
(5)
Compare the cable routing program with the quality controlled j
cable pull cards, and generate routing exception reports where discrepancies are found.
Each exception report will be evaluated for acceptability using the following five attributes:
(a) tray and/or conduit overfill, (b) cable ampacity, (c) separations (train and voltage), (d) 10 CFR 50 Appendix R, l
and (e) environmental qualification.
1 (6)
Verify the balance of the data base by signal tracing, using l
acceptable sampling ~ procedures.
Exceptions found will be i
evaluated using the five attributes above, and the sample expanded where a cable fails to meet'any of the attributes, j
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(7).
' Update the cable routing data base with the new data discovered or developed.
(8)
Evaluate discrepancies to determine the root cause, e.g., procedural or_ technical issue.
(9)
Develop new computer program user's manual that incorporates the improvements developed during this program and its use required for future modificat. ions.
5.
The Date When Full Compliance Will Be Achieved i
In conclusion, the short-term program performed to support heatup and restart of the SQN units has resulted in the evaluation of 822 cables with only 4 occurrences of failure to' meet the design criteria for Appendix R, EQ, voltage / train separation, ampacity, and cable tray / conduit fill.
j Full compliance will be achieved upon completion of the above program.
The program should be completed by January 1990 for units 1 and 2.
Violation 50-327, -328/87 No. 3 i
"10~CFR 50 Appendix B Criterion VI states that measures shall be established to control the issuance of docun.ents, such as instructions, procedures, and drawings, including changes thereto, which prescribe all activities affecting qttality. These measures shall assure that documents, including changes, are reviewed for adequacy.
Contrary to the above, before the August 1967 NRC ERCW system as-built walkdown inspection, the licensee's document control measures failed to assure proper review for adequacy of ERCW flow drawing 47W845 in that the drawing did not properly reflect the deletion of the 738 and 747 series relief valves located downstream of the ERCW strainers, by ECN 2860.
ECN 2860 was completed in 1980.
This is a Severity Level V violation (Supplement II)."
1.
Admission or Denial of Alleged Violation (For clarity, the inspection report sections referenced in the alleged violation are reproduced herein before TVA's admission or denial.)
Inspection Report Section 1 (Violation 87-52-03)
"Other lesser significant drawing discrepancies were also identified i
during the mechanical inspection.
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.0-The'738 and 747 series' relief valves shown on the flow-i L
diagram.down stream of the ERCW strainer. discharge were not-l Lfound during'the walkdown.
The licensee subsequently-
' produced ECN 2860 dated 1980 which had deleted these valves Ifrom the system prior to. plant licensing. 'These valves (1 each series per strainer) were still'shown on flow diagram 47W845-5 for three of the four strainers (not shown for-
. strainer A1A-A). Although the drawing was updated for.the' AIA-A strainer, this drawing change was: inadequate in that it -
did not update the drawing for the other three strainers..
This is considered to be a violation of 10 CFR 50 Appendix B
[
Criterion VI for failure of document control' measures to j
assure that drawing changes were properly reviewed for.
1 adequacy and is identified as Violation 327,328/87-52-03.
The licensee' deleted these valves from'the flow diagrams after the discrepancy was pointed out.
The strainer and isolation valve assemblies in the supply lines'to the ERCW pump motor cooling coils were not located during the walkdown.. TVA produced ECN 6014 which removed the strainer and valve in addition to resizing the.line.. The work for
[
this ECN had been recently completed. The licensee located
.the flow dingram after.the discrepancy'was pointed out."'
TVA's Admission or Denial TVA denies this alleged violation occurred.
2.
Reason for the Denial The described drawing deviation was discovered by TVA during a walkdown of ERCW conducted on July 13, 1987 (before this inspection), and a drawing deviation.(87-DD-2971) was written the same day to correct the identified condition. The control room drawings.were, in turn, updated on August 13, 1987, (coincident with this inspection) as a result of the July 13, 1987 drawing deviation, but giving the appearance that the drawing update was made as a result of the inspector's comments.
NRC found additional drawing deviations (DDs) during the mechanical portion of this inspection, but TVA has procedural requirements for handling these and similar deviations.
Specifically, SQN Engineering Procedure (SQEP)-43 (Control of Drawing Deviations) and SQN Administrative Instruction (AI)-25, Part II (Drawing Deviations), govern the handling of potential DDs similar to those found by NRC. The specific DDs found by NRC are being dispositioned in accordance with these procedures. AI-25 outlines the steps to be taken by the individual finding a potential DD, the process for the shift technical advisor's review and categorization of the DD, and the process for 4
correcting the DD, including DNE's review and subsequent corrective actions. The procedure also outlines steps to be t.aken for DDs found during DBVP.
SQEP-43 outlines DNE's responsibili'.ies in handling potential DDs and their interfacing with the Division of Nuclear Construction (DNC).
In addition to the above, TVA has instituted programmatic requirement changes as outlined below for the drawing control process.
p
- In June 1985, TVA transferred responsibility for the update and maintenance of as-constructed (AC) drawings from the Site Services l
Organization to DNE.
In addition to this transfer in responsibility,
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many program improvements have been initiated.
Some of the major improvements are listed below.
a.
DNE now updates and issues the AC drawings.
b.
A new interim change control. process is being implemented that, over time, will replace the AC and as-designed (AD) drawings with one configuration control drawing (CCD).
c.
New procedures have been developed governing change control and drawing control.
SQEP Interim Change Control SQEP Creation of Configuration Control Drawings SQEP Update of AC Drawings SQEP Update of Configuration Control Drawings SQEP Emergency and Minor Modifications (design change notices (DCNs])
i d.
The practice of using "to be changed /to be added/to be l
deleted" markings on drawings has been eliminated.
e.
All drafters have been trained in the use of proper drafting standards and equipment.
f.
Emphasis on drawing quality and legibility by drawing unit checkers has been increased.
l
o-ENCLOSURE 2 l
Observed Weakness No. 1 "A weakness was identified in your conduct of operations which we have currently identified as an unresolved item pending completion of enforcement action review. Specifically, safety-related functions of the ERCW system were j
disabled with temporary measures put in place to compensate for those J
functions. As noted in the enclosed report, this was done in some cases i
without appropriate review and analysis. Addi~tionally compensatory actions j
were not' appropriately specified and controlled in all cases.
To this end, we have concern that your actions did not address system operation in an accident mode. Also we are concerned that permanent resolution had not-been implemented to resolve problems associated with these safety functions even though some of these problems were identified prior to licensing. Thirdly, we are concerned that, without NRC intervention, these conditions would have gone uncorrected at startup. You should evaluate these concerns and in your response address the root'causes and generic span of these concerns and identify necessary corrective actions to resolve the technical concerns as well as prevent recurrence. Your evaluation should consider possible weaknesses in your engineering-operations interfaces which may have contributed to a lack of appropriate engineering input to the applied temporary compensatory measures and the prevention of timely permanent resolution of problems."
Root Causes of Identified Weakness l
The root cause of this identified weakness can be attributed to the following:
1.
Failure.to inform DNE of the manual operation of the ERCW strainers and i
screens required as a result of the use of continuous hypochlorination for microbiological 1y induced corrosion (MIC) control.
2.-
Failure of DNE to adequately assess the operations once they were l
informed.
3.
Failure of operations to adequately control manual operations of the strainers.
1 4.
Failure to prioritize the resolution of the inoperable ERCW screen instrumentation.
l The above is indicative of a root cause in which operations and engineering lacked good and timely exchange of technical information and responsiveness as a team.
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Corrective Steps Taken and to be Taken l
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l Before unit 2 initially enters mode 4, DNE will write a USQD (10 CFR 50.59 l
evaluation) to address the safety aspects of manually operating the ERCW j
screens and strainers in both normal and accident conditions; and consistency with the USQD will then be achieved in the ERCW System Operating Instruction (S0I)-67.1 and annunciator response instruction (S0I-55-0-M-27A).
Accident operations will be controlled using Radiological Emergency Plan Implementing Procedure (IP-6) and Abnormal Operating Instructions (AOIs)-7 (Flood), -8 (Earthquake), and -9 (Tornado Watch / Warning). DNE has produced a
-flow-differential pressure curve to guide the backwash of the ERCW strainers.
Certain accident conditions will require that both screens and strainers be put in continuous operation.
A concern was expressed in the inspection report that the manual operations of ERCW screens'and strainers would not be addressed before SQN restart, if.it I
had not been for this inspection. A review of Condition Adverse to Quality Report (CAQR) SQP871263IDI, which was written on July 21, 1987, and directly i
relates to this subjecc, indicates that CAQR was identified as " required for' I
restart." The resolution of this CAQR would require manual operation of the ECRW screens and strainers be addressed before restart. Additional corrective actions being taken to address this situation include extension of the present range on the strainer differential pressure gages, addition of on/off backwash switches for screens and strainers, throttling of ERCW strainer backwash flow, and a long-term joint study of the ERCW strainers, traveling screens, and hypochlorite injection system. The joint team that will evaluate the present l
system will include DNE, Operations, and Maintenance personnel to ensure a good' problem definition is achieved and a technically acceptable resolution for all concerned is accomplished.
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In order to address the potential generic applicability of the problem with the disabling of safety-related functions without approved operating procedures, the following actions were taken.
P0RS conducted a review of Operations' night orders, hold orders, and open temporary alteration control forms on systems required to mitigate FSAR Chapter 15 accidents to determine j
if any similar conditions exist.
In addition, interviews of Operations'
.l personnel (16 Senior Reactor Operators, 10 Reactor Operators, and 30 Assistant Unit Operators) were conducted to identify facility changes and/or operating practices that could inhibit automatic operation of safety-related equipment.
As a result of the review, 8 of 71 TACFs reviewed were found with weak USQDs (all 8 were on systems or portions of systems outside the DBVP, Phase I, system boundaries); 5 of 127 hold orders reviewed were found issued for other than maintenance and/or modifications, or were not being controlled by plant approved documents, e.g.,
General Operating Instructions (all 5 were on systems or portions of systems outside the DBVP, Phase I, system boundaries);
and 1 night order of 79 reviewed removed an automatic safety function (this was the night order on ERCW screens and strainers, which has since been l
deleted).
Further, none of the 56 operators interviewed identified any additional (other than those outlined above) automatic safety functions as being bypassed.
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.In conclus on, no operability problems were found, and no new procedures are I
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- needed as a result of the PORS review that impact systems within the DBVP, Phase I. system boundaries other than the ERCW screens and strainers.
(The
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- night order no longer exists.
SOI-67.1 and the radiological emergency plan s
implementing-procedures now control manual operation of ERCW screens and q
strainers).
Some weak USQDs and some misuse of hold orders were found.
As a a
result of the review findings, specific CAQRs have been written.
Further,.a i
revision has been made to the night order procedure preventing its use in controlling safety-related. equipment; and, before unit 2 enters mode 2, the hold order procedure will-be revised to require those hold orders 'for other than maintenance and/or modifications related work not be hung until a USQD.is l
written.
Positive actions have been taken to address the weaknesses in the Operations / Engineering interface that contributed to this observed j
weakness.These actions are directed at improving the exchange of technical information, timeliness, and responsiveness between Operations and Engineering
- and enhancing the team concept.
These actions include:
1 (a) the. establishment of a DNE/ Operations System Engineering Trouble Shooting Team in which a multidiscipline team of systems-oriented engineers has been i
integrated into the plant operations
- organizations to identify.and resolve system.and component issues related to design, modification or maintenance, (b) establishing DNE in an advisory role with the plant Operations Review j
Committee (PORC), (c) multidiscipline engineering support and interaction in daily " War Room" meetings with plant management supporting restart, (d) multidiscipline engineering coverage for plant evening shift activities for efficient technical interface and timely support of modifications and
- maintenance activities, and (e) enhanced operations and engineering management attention on team actions and improved communications between Operations and Engineering personnel.
l In order to ensure compensatory measures required during emergency and abnormal conditions have received appropriate engineering input and can be-implemented during emergency / abnormal conditions, the following actions are j
being taken before unit 2 initially enters mode 4:
1.
DNE will review documentation for their nonconformance/significant condition reports, condition adverse to quality reports (CAQR), employee l
concerns DBVP punchlist, integrated design inspection findings, USQDs, (including an assessment of engineering calculations and safety evaluations) all issued since August 30, 1985, which prompted i
incorporation of compensatory actions into existing or new procedures.
2.
PORS will review JCOs for the lowest mode determinations, CAQRs which were j
determined to have a potential affect on operability, open restart items i
from the Operability Review Project, and corrective actions for LERs and l
Potential Reportable Occurrences all since August 30, 1985, to identify compensatory actions.
3.
Site Licensing will review the Corporate Commitment Tracking System data i
base for procedure changes implementing compensatory actions.
4.
Safety evaluations (SE) or USQDs will be written, as needed, to evaluate l
individual compensatory actions.
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AlUSQD wil'1 'e: written to evaluate the aggregate of the above compensatory b
actions.
6.
A single point'of' contact will be established to'contro'1 the implementation'of future emergency / abnormal condition compensatory actions.-
7.
Ar. interim system for tracking' present and future emergency / abnormal condition compensatory actions from time.of implementation until removal
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will.be initiated.--(A formal procedure.will be in place'before unit 2 ente'rs mode 2.)
Observed' Weakness No. 2
" Numerous findings indicate a weakness with your past practices associated with equipment identification. As noted in the enclosed report, examples of this include the inspection team's observation of many missing, damaged, and incorrect valve, instrument and conduit labels.
It is recognized that TVA has a program in place to identify and correct these. types of human factors deficiencies.' In your response you should address when implementation of this program will bel completed and what actions have been, or will be instituted to preclude. recurrence."
Corrective Steps:Taken and To Be Taken
'Several initiatives have been or are being undertaken to address SQN's equipment identification weaknesses as outlined below:
The systems walkdown effort conducted as part of the DBVP identified numerous component identification and tagging deficiencies. Work requests were
' initiated as corrective action, and the items were placed.under.the control of the DBVP punch 11st. All'ofEthese tagging deficiencies have been evaluated under the Sequoyah Restart Criteria to determine'which ones must be corrected i
before restart. Correction of these' tagging-related deficiencies will significantly improve the level of component identification existing.in the plant.
Particular improvement has been made on the D/Gs (system 82)'and air j
heating and cooling systems (system 31). ' Essentially all DBVP punchlist tagging items required for restart have been completed.
Coordination has been obtained from Operations personnel performing system valve lineups to identify tag-related deficiencies by the way of work requests. Correction of the deficiencies identified on systems or portions of systems that are outside the scope of the DBVP, although not required before restart, will be expeditiously pursued by the DBVP Systems Walkdown Group.
These efforts will ensure a high confidence that valves required for system alignments are properly identified.
As a result of this inspection effort, the identification of restart instrumentation sense line valves is being addressed.
Under SQN Special Maintenance Instruction 0-317-61, temporary tags with unique identifiers
-(UNIDs) are being attached to the instrument sense line valves between the process line root valve and the isolation valve at the top of local panels.
These valves and their UNID will be shown on DNE instrumentation drawings or sketches.
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Also, as noted in this inspection, many skid-mounted valves-are not. uniquely l
identified with a UNID. To ensure that the position of these in-line l
skid-mounted valves can be verified during system alignments, appropriate procedures are being revised to reference the in-line process valves controlling process flow to or from the skids by their description and/or j
' function.
_I In addition, to ensure the proper level of identification in the plant is maintained, Maintenance Planning has been directed to develop the controls necessary to ensure that the component remains' properly tagged following maintenance activities that could remove the tag.
These controls are expected I
E to be in place by December 15, 1987.
Observed Weakness No. 3 "The inspection team identified several conditions that are symptomatic of a weak preventive maintenance program. As noted in the enclosed report, these conditions included observed corrosion on pipe sections and components, rusted instrument stands and strainer supports, and water leakage from ERCW strainers. Additionally, these conditions included the fact that a preventive maintenance program for snubber lubrication has not yet been implemented.
In your response, you should address how and when your newly developed programs will assure that plant components, systems, and structures are not unnecessarily allowed to degrade with age."
Corrective Steps Taken and To Be Taken TVA recognizes.that it has had a weak preventive maintenance (PM) program at SQN and has committed to improve the program.
(Reference the NPP, Volume II, section 4.3, and Volume I, section VI E.2.)
TVA has committed its management focus and program objective for plant maintenance to become more proactive and aggressive in system and component performance and evaluation by an integrated use of:
- Predictive Analyces
- Component and System Trending
- Root Cause Failure Analysis
- In-house and Industry Experience
- Routine Maintenance Activities TVA's PM program is being based on actions that are long term (reference NPP, Volume II, section 4.3.1).
= - - - - - - - - - - - - - - - - -
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'TVA w'ould:like to emphasize'that_certain PM improvement plans were not yet l
h initiated during the inspection time period (August 3-14 and August 19, 1987) l for. Inspection: ??eport Nosl.. 50-327, -328/87-52; but, with the_ exception of the leakage on;the;.;ERCW strainers, the examples of a weak PM found during the inspection hsd been recognized by Maintenance and included within the scope of an, engineering or maintenance program. The. corroded carbon steel ERCW pipe noted'in the RHR pump' room was'being replaced with stainless steel under ECN
- 5009 Workplan 12572.
Under Corrective Action Report (CAR)87-014, critical i
4 instrument issues such-as missing clamps, loose clamps, rusted features,
- missing or degraded coatings, and instrument riounting or damage are being addressed. 'The project has been divided into restart and nonrestart instrumentation'and will-remain an-ongoing project to ensure that all instrument systems are restored to engineering approved configurations.
1 A PM program for snubber l1ubrication was cited as a weakness in SQN's PM l
. program in your. inspection report.
SQN currently has an SI for inspecting snubbers that does.not presently require the lubrication of spherical bearings. The lubrication of snubber spherical bearings had been previously j
identified within-the Maintenance organization as a result of an employee
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concern,.and an evaluation of its impact on snubber operability was j
I
. performed. The scope of the improvements in the snubber program, including the' lubrication issue, will be determined by March 15, 1988.
TVA believes that it has'made significant progress toward the goal of establishing an effective and comprehensive PM program and has established program improvements as a goal for SQN in both the corporate and SQN NPPs.
Observed Weakness No. 4
" Weaknesses were identified which were indicative of poor maintenance practices in the restoration of equipment to operational status after j
maintenance activities and the apparent inability of the station's staff to relate to_the need to repair and correct the damaged equipment. As noted in l
the enclosed report, examples of this include the team's observation of a bent i
valve stem, shortened flange studs, broken flex connections on cable conduit, i
minor wiring and~ housekeeping deficiencies within motor operated valve housing, a broken instrument bracket, inadequate cleanliness provisions for I
open' instrument ports, damaged armored cables and conduits, and a loosened pipe support locknut. Many of these deficiencies may demonstrate a short coming in your ' skill of the craft' concept as implemented at Sequoyah.
In i
your response you should address what actions have been or will be instituted to assure proper maintenance of plant components, systems, and structures and when these actions will be implemented."
Corrective Steps Taken and To Be Taken Present efforts to improve maintenance are intended to eliminate poor maintenance practices. This is being addressed in our NPPs (reference
' Corporate NPP, Volume I, section VI E.2, and SQN NPP, Volume II, section II 4.0) and includes initiatives to improve management involvement, personnel training, adequate staffing, planning upgrade, work control initiatives, maintenance goals, and trending of equipment performance as well as conditions adverse to quality (CAQs).
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Strong commitments to enhance and strengthen management involvement, accountability, and control of maintenance activities are positive steps to eliminate recurring poor maintenance practices.
Corporate maintenance managers, both temporary and permanent, are currently in place and are working with the various site maintenance superintendents and staffs to strengthen the maintenance programs, establish goals, and ensure qualified staff with clear roles are in place. Regular mar.agement and craft meetings are conducted to ensure positive as well as poor and unacceptable performance is recognized by i
management. Daily plant inspections by management and consolidation of the morning plant manager and restart meetings have made TVA management aware of and accountable for the work of their people.
TVA management has recognized that inadequate training of maintenance craft and foremen is a problem that can result in excessive rework, noncompliance with requirements, lack of procedure adherence, and poor maintenance. A sign!ficant expenditure and commitment of resources have been dedicated to craft awareness, training, and commitment to quality work.
Institute of Nuclear Power Operations (INPO) accreditation of the mechanical, electrical, and instrument training programs; expansion of site training courses; and incentive programs to recognize achievement of proficiency and skill of a craftsman have been implemented. The Employee Recognition Program promotes and recognizes individual achievement in performance of duty. These programs are intended to promote excellence and recognize employee accomplishments.
Other maintenance initiatives and progress have been documented in NRC Inspection Report Nos. 50-327, -328/87-37.
Specific items identified in Inspection Report Nos. 50-327, -328/87-52 have been resolved or are addressed in the maintenance backlog that is being worked. The Maintenance department approach to working off the backlog work has been to give first priority to items deemed critical to startup, second priority to industrial safety, and third priority to the support of restart efforts while trying to maintain the goal of reducing the backlog of work requests. Maintenance is making steady progress in reducing the work backlog I
despite new work identified as restart system test plateaus are approached.
-Improved housekeeping, plant appearance, and minor maintenance items are being systematically addressed by dedication of resources. A number of the poor maintenance practices were deemed housekeeping and could more efficiently be handled by a composite crew. A portion of a composite crew is already formed and is in place; additional craft are being considered. This will allow cleanliness, rust, and minor maintenance deficiencies to be addressed throughout the plant.
Individual nuclear plant employee responsibilities with respect to identification and reporting of equipment problems have been recognized as an area needing attention. A memorandum has been issued to address identifying, tagging, and removing work request tags, and individual's responsibilities for identifying problems.
Individual responsibilities relative to the identification of equipment problems were again amplified in revision to Sequoyah Maintenance Procedure (SQM-2) in March 1986.
To increase craft awareness of the importance of equipment degradation identification and reporting, briefing material is being prepared including slides to illustrate the types of housekeeping and material conditions considered unacceptable.
This material should be ready by January 1988.
.- The specific items identified during the inspection and those given as examples.have either already been corrected or are in the work control system for completion.
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ENCLOSURE 3 LIST OF COMMITMENTS CONTAINED IN ENCLOSURES 1 AND 2 Violation 87-52-01 (Example A)
- 1. '(a).The Division of Nuclear Engineering (DNE) has identified the skid equipment within the Design Baseline and Verification Program (DBVP).
Phase I, system boundaries; (b) Operations personnel are, in turn, taking this list of skid equipment and walking down unit 2 and-common skid equipment needed for unit 2 operation to identify those valves in process lines to and from the skid equipment; and (c) the above process line valves associated with the skid equipment list will then be listed in the appropriate system operating instructions (SOIs) or surveillance instructions (sis - in the case of ERCW and component cooling water) by nomenclature description or valve number if it exists to ensure proper valve configuration control.
This effort will be completed before unit 2 entry into mode 4.
2a. Walkdowns will also be conducted for unit 1 to ensure skid-mounted' valves in process lines to and from the skid equipment within the DBVP, Phase I, system boundaries are controlled before unit 1 enters mode 4.
2b. Walkdowns will be conducted to identify unit i restart instrumentation valves before unit 1 enters mode 4.
3.
Skids within the DBVP, Phase I, system boundaries are being reviewed to ensure RPS input, ESF actuation, FSAR PAM, and TS instrumentation valves on the skids are appropriately identified.
This effort will also be completed before unit 2 entry into mode 4 (before unit 1 entry into mode 4 for unit 1 valves).
t 4.
A units 1 and 2, phase 2, effort will be initiated to cover the safety-related instruments not in the units 1 and 2 restart instrumentation effort. The phase 2 effort will include the production of drawings needed for control of the high point vent valves within the scope.
This effort should be completed by September 1389 for unit 2 (a schedule for unit I will be developed).
5.
An instrument engineering requirements specification will be issued requiring valves be tagged and identified on engineering output drawings.
Implementation of this specification is expected by March 15, 1988.
6a. By June 1, 1988, unit 2 (January 1, 1989, for unit 1) in-line valves for process lines to and from skide within the DBVP, Phase I, system boundaries will be included on the associated flow diagrams (47W800 series).
6b. By October 1, 1989, unit 2 (a schedule for unit 1 will be developed) in-line valves for process lines to and from skids within the DBVP, Phase 2, system boundaries will be included on the associated flow diagrams (47W800 Series).
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7a.
For skid-mounted valves in process lines to and from skid equipment l
within the DBVP, Phase I, system boundaries, full compliance will be j
achieved following issuance of the flow diagrams (47W800 series) with
)
these valves identified and subsequent incorporation of those valve I
numbers within the appropriate sis and S0Is.
We' expect to complete this work by September 1, 1988, for unit 2 and.by April 1, 1989, for unit 1.
l 7b.
Skid-mounted valves in process lines to and from skid equipment within the DBVP, Phase 2, system boundaries will be incorporated within the SOIs by valve numbers by January 1990 (a schedule for unit 1 will be developed).
Violation 87-52-01 (Example B) i 8/9 No commitments are made in this response.
Violation 87-52-01 (Example C) l 10.
The portion of the FSAR indicating the ERCW screen wash pumps are to be I
ASME Code stamped will be revised by the next annual update, presently scheduled for April 1988.
11.
FSAR Section 9.2.2 will be revised to delete all design code references and include an accurate correlation of TVA class to design codes will be added to FSAR Section 3.2.
This will be part of the next FSAR update, presently scheduled for April 1988.
12.
An unreviewed safety question determination (USQD-10 CFR 50.59 safety evaluation) of the screen wash pumps will be performed before unit 2 enters mode 4 to validate there is no impact on safe operation of the plant with the present pumps.
Violation 87-52-01 (Example D) 13.
The bill of material for the diesel generator flexible hoses will be revised to reflect the actual design conditions for these hoses by April 1, 1988.
Violation 87-52-01 (Example E) 14.
A TACF and the associated USQD will be completed for the ERCW screen-level instrumentation before unit 2 enters mode 2, documenting the condition of the subject instrumentation.
Violation 87-52-02 (Example A) 15a. The sleeve sealing note on 17W600-3 will be made consistent with 37W206-3 by November 15, 1987.
15b. A schedule is being prepared for determining the existence of other vertical sleeves with fill material with the same design basis as the ERCW pumping station vertical instrumentation sleeves and subsequent walkdown to ensure proper sealing.
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L Violation 87-52-02 (Example B) 16a. The WR for replacing the heat trace on ERCW pump RA will be worked by December 1, 1987.
I 16b. To control removal and reinstallation of heat trace, a new maintenance instruction will be written-by June 1988.
I 16c. An evaluation will be made to determine the need for revision of the present ERCW pumping station heat trace drawings by December 15, 1987.
16d.
By December 15, 1987, SQM-2 will be revised to proceduralize the requirements for working ERCW pumping station heat trace, i.e. a field l
sketch of basic reinstallation techniques for the heat trace. While j
SQM-2 is being revised, maintenance planners will administrative 1y implement those same requirements for any WRs planned for the ERCW pumping station heat trace.
Violation 87-52-02-(Example C) 17a. The CSSC list will be revised to include FT, FS-67-206 and -209 before unit 2 entry to mode 2.
Further, the resolution of all the discrepancies found during the comparison of the SMI and CSSC list will be complete before unit 2 entry in mode 2.
17b. The Instrument Project Phase 2 instrument list will be compared against the CSSC list and any discrepancies resolved by July 1988.
18.
As outlined in our August 28, 1987 letter to NRC on the Q-List Program development status, TVA will provide an implementation plan for the Q-List by March 1, 1988.
l Violation 87-52-02 (Example D) 19a. As outlined in the response to violation 87-52-01 (Example A), the Instrument Project will locate, identify with temporary tags, and document on instrument drawings or sketches those valves (from the root valve to and including panel or instrument isolation valve) in the unit I restart instrumentation scope.
The restart instrumentation scope is outlined in the response to violation 87-52-01 (Example A).
- Briefly,
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the unit i restart instruments are those TVA-mounted instruments within I
the DBVP, Phase I, system boundaries that meet one of the following attributes:
(a) RPS input, (b) ESF actuation, (c) FSAR PAMs or (d) TS device. This work, which is directly related to commitment No. 2, will l
be completed before unit 1 enters mode 4.
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19b. Subsequent to this walkdown, SI-604 (Essential Instrument Operability Verification) will be revised and an appendix added for verification of proper alignment of the in-line instrument valves, identified by the Instrument Project above, on a once per refueling outage frequency.
In addition, as a result of the procedures enhancement effort, maintenance and surveillance instructions that require the manipulation of the subject valves have instituted valve control by the way of either a nomenclature description of the valve or a configuration control sheet.
l This work, which is directly related to commitment No. 2, will be completed before unit 1 enters mode 4.
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20.
Skid equipment within.the DBVP, Phase I, system boundaries is being reviewed to determine if instrumentation valves (i.e., for instrumentation meeting any of the four attributes listed above) on skids require controls similar to those outlined above.
If similar controls are required, they will be implemented by a revision of SI-604 before unit 2 enters mode 4 (before unit 1 enters mode 4 for unit 1 instrumentation valves).
21.
A phase 2 (all other safety-related instruments) instrumentation effort will be conducted to determine if any other safety-related instrumentation exists requiring commensurate procedural controls for the valves.
The schedule for completing any needed procedural controls will be included in the March 1988 schedule to which TVA committed in the August 14, 1987 submittal on Maintenance Instruction Enhancement Effort.
Violation 87-52-02 (Example E) 22.
DNE determined the use of Belden Braid was limited to main control room and backup control room boards where multiple trains are within the same space and initiated WRs to perform a quality-controlled walkdown of the affected boards. The walkdown will identify the occurrence of and correct Belden Braid separation in accordance with drawing 45W1640, revision S (Control Boards Critical Wiring Braid Installation), note 2
(" Maintain maximum air space between Train A and Train B wiring assemblies and bundles.") before unit 2 enters mode 4.
Violation 87-52-02 (Example F) 23.
Before unit 2 enters mode 4, the non-1E cables will be traced by a hand over hand walkdown ov' signal tracing to determine if the cables are associated with redundant equipment.
24a.
Before unit 2 enters mode 4, the 1E cabla in the non-1E tray will be placed into the proper tray.
24b.
A long-term cable routing program will be conducted to:
(a) Verify the existing computer program for cable routing.
(b) Directly compare cable tray drawings to the actual installation to verify cable tray installation.
(This is the cable tray network, not the cable routing within the network.)
(c) Perform a walkdown to determine the entry and exit points of the cables. The walkdown results will, in turn, be evaluated against the cables program, and discrepancies resolved.
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(d) Using the walkdown data, new intermediate cable tray node points l
will be added to the computer program to more accurately define I
cable routing.
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-28.
Before unit 2 enters mode 2, the hold order proc edure will be revised to I
require those hold orders for other than maintenance and/or s
modifications related work not be hung until a USQD is written.
j 29a.
To address the Operations / Engineering interface problem, the following actions have been or are being undertaken:
(a) DNE coverage, including recently added second shift, to ensure timely response for technical specification situations; (b) establishment of DNE/ Operations Trouble Shooting Team for implementation of modifications and identification of operability issues; (c) establishment of DNE in an advisory role to Plant Operations Review Committee; (d) DNE participation in daily restart meetings with plant management;'and (e) focusing of management attention on better DNE/ Operations communication.
29b.
Before unit 2 enters mode 4, DNE will review documentation for their nonconformance/significant condition reports, condition adv,ise to l
quality reports (CAQR), employee concerns, DBVP punch litt, integrated design inspection findings, and USQDs (including an assessment of engineering calculations and safety evaluations), all issued since August 30, 1985, which prompted incorporation of compensatory actions into existing or new procedures.
29c.
Before unit 2 enters mode 4, PORS will review JCOs for the lowest mode determinations, CAQRs which were determined to have a potential affect on operability, open restart items from the Operability Review Project, and LERs and corrective actions for LERc and Potential Reportable Occurrences, all since August 30, 1985, to identify compensatory actions.
29d.
Before unit 2 enters mode 4, Site Licensing will review the Corporate Commitment Tracking System data base for procedure changes implementing compensatory actions.
29e.
Before unit 2 enters mode 4, safety evaluations (SE) or USQDs will be written, as needed, to evaluate individual compensatory actions.
29f. Before unit 2 enters mode 4, a USQD will be written to evaluate the aggregata of the above compensatory actions.
295 Before unit 2 enters mode 4, a single point of contact will be established to control the implementation of future emergency / abnormal condition compensatory actions.
29h. Before unit 2 enters mode 4, an interim system for tracking present and future emergency / abnormal condition compensatory actions from time of implementation until removal will be initiated.
Weakness Number 2 1
30.
Correction of the deficiencies identified on systems or portions of systems that are outside the scope of the DBVP, although not required I
before restart, will be expeditiously pursued by the DBVP Systems Walkdown Group.
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Y -28.
'Before unit '2 enters mode 2, theLhold' order procedure will be revised to
. require its use for'other than maintenance =and/or modifications related work ~until a USQD is written.
29a.
To' address the Operations / Engineering' interface problem, the following.
. actions have been'or are being undertaken::.(a) DNE. coverage, including recently.added second shift,'to ensure timely. response.for technical specification situations; (b) establishment of DNE/ Operations Trouble-Shooting Team for implementation of modifications and identification of operability l issues; (c) establishment of DNE_in an advisory role to-Plant Operations Review Committee; (d) DNE participation in daily restart meetings with plant management; and (e) focusing of management attention on better DNE/ Operations communication.
29b. Before unit 2 enters mode 4, DNE will review documentation for their nonconformance/significant' condition reports, condition adverse to quality reports (CAQR), employee concerns, DBVP punch list, integrated design inspection findings, and USQDs (including an assessment of engineering calculations and safety evaluations), all issued since August 30,.1985, which prompted incorporation of compensatory actions into existing or new procedures.
29c. Before unit 2 enters mode 4, P0RS will review JCOs for the lowest mode determinations, CAQRs which were determined to have a potential affect on operability, open' restart items =from the Operability Review Project, and LERs and corrective actions for LERs and Potential Reportable Occurrences, all since August 30, 1985, to identify compensatory actions.
29d. Before unit 2 enters mode 4.' Site Licensing will review the Corporate Commitment Tracking System data base for procedure changes implementing compensatory actions.
29e. Before unit 2 enters mode 4, safety evaluations (SE) or USQDs will be written, as needed, to evaluate individual compensatory actions.
29f. Before unit 2 enters mode 4, a USQD will be written to evaluate the aggregate of the above compensatory actions.
j 29g. Eefore unit 2 enters mode 4, a single point of contact will be established to control the implementation of future emergency / abnormal condition compensatory actions.
1 29h.
Before unit 2 enters mode 4, an interim system for tracking present and future emergency / abnormal condition compensatory actions from time of implementation until removal will be initiated.
Weakness Number 2 1
30.
Correction of the deficiencies identified on systems or portions of systems that are outside the scope of the DBVP, although not required before restart, will be expeditiously pursued by the DBVP Systems Walkdown Group.
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To ensure the proper level of identification in the plant is maintained, Maintenance Planning has been tasked to develop the controls necessary to ensure that the component remains properly tagged following maintenance activities that could remove the tag.
These controls are expected to be in place by December 15, 1987.
Weakness Number 3 32.
The scope of the improvements in the snubber program, including the lubrication issue, will be determined by March 15, 1988.
Weakness Number 4 No new commitments. Programmatic commitments are outlined in NPPs, Volumes 1 and 2.
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