ML20210E310

Insp Repts 50-327/86-43 & 50-328/86-43 on 860728-0801. Violations Noted:Failure to Properly Implement Requirements of Administrative Instruction & Change Plant Approved Procedures

ML20210E310
Person / Time
Site:	Sequoyah
Issue date:	08/26/1986
From:	Branch M, Carroll R, Debs B, Mathis J, Paulk G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20210E303	List: IR 05000327/1986043 ML20210E297 ML20210E305 ML20210E310
References
50-327-86-43, 50-328-86-43, NUDOCS 8609220243
Download: ML20210E310 (11)

See also: IR 05000327/1986043

Text

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UNITED STATES

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NUCLEAR REGULATORY COMMISSION

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101 MARIETTA STREET, N.W.

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ATLANT A. GEORGI A 30323

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Report Nos.:

50-327/86-43 and 50-328/86-43

Licensee: Tennessee Valley Authority

6N38 A Lookout Place

1101 Market Street

Chattanooga, TN 37401

Docket Nos.: 50-327 and 50-328

License Nos.: DPR-77 and DPR-79

Facility Name:

Sequoyah Units 1 and 2

Inspection Conducted: July 28, 1986 - August 1, 1986

Inspectors:

~ Date' Signed

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M. W. Braren, InspectpliE TKm Leader

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R. E. Carroll, Jr. , Projecf/ffgfiieer

'Date Signed

G. Paul k, L. , ;#iM'/ $_

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Date Signed

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I g ec V (Browns Ferry)

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J. Mathi W KeacL~r inspg#Cor 7

Tate Signed

Approved by:

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B. Debs, Section Chief

D4te Signed

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Division of Reactor Projects

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SUMMARY

Scope:

This special, announced inspection was conducted in the area of

Modification Testing (MT) with a concentration on testing associated with

Environmentally Qualified (EQ) equipment modifications. This inspection involved

a review of major or complicated Post Modification Tests (PMT), as well as a

!

review of Post Modification Functional Tests (PMFT). Additionally, a followup of

associated Inspector Identified Items, discussed in paragraph 9 of Inspection

Report 327, 328/86-20, was performed.

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Results:

In the areas inspected, two violations were identified.

The first

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violation, discussed in paragraph 6, involved multiple examples of

failure to

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properly implement the requirements of Administrative Instruction (AI)-19,

Part IV, " Plant Modifications After Licensing" and Surveillance Instruction

(51)-166.6, " Post Maintenance Testing of Category A and B Valves." The second

violation, also discussed in paragraph 6, involved a failure to properly change

plant approved procedures.

8609220243 860912

PDR

ADOCK 05000327

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PDR

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REPORT DETAILS

1.

Licensee Employee Contacted

• P. R. Wallace, Plant Manager

L. M. Nobles, Operations and Engineering Superintendent

• B. M. Patterson, Maintenance Superintendeot

• N. E. Andrews, Site Quality Manager

• D. C. Craven, Quality Assurance Manager

• G. B. Kirk, Compliance Licensing Supervisor

• R. W. Olson, Modifications Branch Manager

• M. R. .Sedlacik, Electrical Section Manager, Modifications Branch

• R. M. Mooney, Systems Engineering Supervisor

• J. A. McPherson, Mechanical Test Supervisor

• R. W. Fortenberry, Technical Support Supervisor

• R. V. Pierce, Mechanical Maintenance Supervisor

• H. D. Elkins Jr., Instrument Maintenance Supervisor

• M. A. Skarzinski, Electrical Maintenance Supervisor

• R. H. Smith, Project Management

• J. H. Sullivan, Regulatory Engineering Supervisor

• P. H. Buckholz, Sequoyah Site Representative

S. D. Gilley, Modification Engineer

E. L. Legg, Modification Engineer

J. Edwards, Instrument Maintenance

T. L. Rutledge, Modification Engineer

D._R. Branham, Modification Engineer

Other licensee employees contacted included technicians, operators, shift

engineers and maintenance personnel.

• Attended exit interview

2.

Exit Interview

The inspection scope and findings were summarized on August 1,1986, with

those persons indicated by an asterisk in paragraph one above.

The

following new items were discussed:

a.

Violation for failure to properly implement the requirements of AI-19,

Part IV and SI-166.6 in the area of functional testing.

b.

Violation for failure to properly change plant approved procedures.

This item was initially categorized as an unresolved item then upgraded

after additional discussion with NRC personnel.

The licensee acknowledged the inspection findings.

The licensee did not

identify as proprietary any material provided to the inspectors during the

inspection. At no time during the inspection period did the inspectors

provide written material to the licensee.

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3.

Followup On Inspector Identified Items

a.

(Closed) IFI 327, 328/86-20-03; Review of modifications to Limitorque

Valves to determine effect, if any, of improper wiring. The issue was

. originally addressed in paragraph nine of inspection report 327,

328/86-20 and dealt with the rewiring of approximately 214 Limitorque

Operators to establish EQ qualifications as well as simplifying and

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correcting limit and/or torque switch discrepancies. The inspector was

concerned with the possibility-that the improper wiring of limit / torque

switches could have had an effect on valve operation.

During the review of Work Plan (WP) 11866 (unit 1) and WP 11853

(unit 2), which rewired the limitorque valves, the inspector's concern

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was re-addressed.

It was determined that some of the previous

torque / limit switch combinations did, under certain circumstances, have

the potential of preventing the fulfillment of valve function.

However, the inspector determined that these valves are part of the

ASME Section XI Article IWV valve test program and are tested for

operability on a routine basis per that program.

b.

(Closed) IFI 327, 328/86-20-11; Use of terminology of " perform the

applicable portions of a Plant Operations Review Committee (PORC)

approved procedure". This item is being combined with a related item

associated with changes to approved procedures.

Both items will be

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resolved as part of that issue which is identified as Violation 327,

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328/86-43-02 and discussed in detail in Paragraph 6 of this report.

4.

Unresolved Items

No Unresolved Items were identified during this inspection.

5.

Design, Design Changes, and Modifications (37700)

Although the major objective of this inspection was to determine the

adequacy of Modification Testing, the inspectors did review several of the

modification Work Plans (WPs) for technical adequacy, proper review and

approval, adequacy of safety evaluation as well as drawing and procedure

updates. Work Plans reviewed as well as inspection findings are as follow:

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a.

Containment Pressure Transmitter Modifications

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Engineering Change Notice (ECN) 6554 and WP 11912 replaces the existing

containment pressure transmitters 1 & 2-PDT-30-42 and 1 & 2-PDT-30-43

with qualified Foxboro transmitters per NUREG 0588. These transmitters

provide input to containment isolation and containment spray logic.

The replacement transmitters are functionally and electrically

equivalent. All functional and operability tests were performed with

revised

Surveillance

Instructions

and

Instrument

Maintenance

Instructions (IMI).

An error in documentation was noted on IMI-135

(Foxboro Instrument N-E130M Assembly Instruction) Appendix C data sheet

page 1 of

4,

Rev. 5 for 2-PDT-30-42 instrument.

The work plan

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documentation indicated that lubricant (P/N N0114AA) was used whereas

the correct lubricant should have been P/N X0114AA. A review of power

store procurement records indicated that P/N X0114AA was used for the

assembly installation. The cognizant engineer was made aware of this

documentation error.

The inspector further reviewed all greases,

sealants, and lubricants used in Work Plan 11912 for traceability and

proper usage. No deficiencies were noted other than this documentation

error.

The inspector reviewed Work Plan 11912 closecut package for adequacy

with regulatory requirements and commitments.

The work ' plan

subsections reviewed included a sampling of the work plan control

section, the work plan specification section,

the modification

authorization section, the data inspection sheet section, the material

traceability section, and the vendor information section.

No

deficiencies were noted.

b.

Reactor Coolant System Transmitters Removal to Outside the Crane Wall

ECN L6439

and WP 11750 moves existing reactor coolant system

transmitters 1 & 2 LT-68-320,1 & 2 PT-68-522 and 1 & 2 PT-68-523 to

outside the polar crane wall. The work plan was reviewed to determine

if regulatory requirements were being met.

The work plan status

currently was under the implementation and closecut phases.

Some

portions of the work plan documentation was not yet complete.

Work

instructions and in process signoffs were adequate as completed. The

Accountability of Modification Material forms, required for level I and

II materials (AI-19, Part IV, Attachment 16), were missing from the work

package. - This traceability form is required when material ordered for

one ECN is used instead for another ECN.

Material ordered for ECN

6533, 6550 was used on this work package, ECN 6439. The cognizant

engineer noted that the required forms will be included when the work

plan is closed out. No other deficiencies were noted during the sample

review.

c.

Instrument Setpoint Changes . Due to Environmental Consideration in

Various Systems

ECN L6551 and WP 11916 revises setpoints for various - safety-related

instruments to allow for instrument inaccuracies due to harsh

environments resulting from a high energy line break. The work plan

documentation was reviewed for regulatory adherence and completeness

All instruments in the work plan are 10 CFR Part 50.49 devices. .The

setpoints were

changed

using

existing plant procedures.

No

deficiencies were noted.

d.

Upper Head Injection Water Tank Level Switch Replacement

ECN L6359 and WP 11751 replaces the four Barton Model 288A level

switches on the upper head injection water tank with more reliable

switches. The switches function to close the UHI isolation valves on

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low level in the tank.

The closure of these valves preven.ts

introduction of nitrogen gas into the RCS following the injection of

borated water into the RCS. Under the ECN, the Barton level switches

were replaced with functionally equivalent switches.

After the. initial completion of work on this work plan it was noted

that a design error existed in the connection wiring drawings. A field

change request (FCR4335) was initiated to rework the design errors and

this rework has not been completed to date; therefore, this work plan

is still in the implementation work phase. The work plan, procedural

step 15, related to plant housekeeping after maintenance was not signed

off as complete although the

initial work was completed ~in

September 1985.

The signoff for the foreman to verify cleanliness

should occur after each work phase to assure adequate work controls and

plant housekeeping. No other comments can be currently made about this

work plan since it is still in process. The cognizant engineer was

informed of all inspector concerns.

6.

Modification Testing (72701)

The inspectors selected for review several WPs in the areas of Mechanical

Modification, Electrical Modification and Instrument Modification. The WPs

selected were those initiated between August 1985 and present, with an

attempt to concentrate on modifications in the area of EQ upgrade. The WPs

selected, including those discussed in paragraph five, included the

following:

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11750 (Relocate level transmitter 1 & 2-LT-68-320 & 1 & 2-PT-68-522 &

523), Units 1 & 2

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11751 (Replace Barton level switch on UHI tank), Unit 1

11762 (PMT 52), Unit 1

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11773 (Replace bolted bonnet valves), Unit 1

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11834 (Install flange on various component cooling lines), Unit 2

11853 (Replace wiring on limitorque operators), Unit 2

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11866 (Replace wiring on limitorque operators), Unit 1

11890 (PMT 74 Auto Shut Trip), Unit 2

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11893 (Relocate PT-68-322 & 323 & LT-68-320), Unit 2

11897 (Replace solenoid vivs), Units 1 & 2

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11906 (Replace motors on FCV-2-074-001 & 002), Unit 2

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11912 (Replace 1, 2-PDT-30-42 & 43), Units 1 & 2

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11916 (Change setpoints on various safety-related WST), Unit 2

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11928 (Replace NAMCO limit switches sys 30, 63, 77, 81 & 68), Units

1&2

12040 (Replace Rework & Reroute PP-7118 power feed for DG 2BB),

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Unit 2

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12074 (Replace Nozzles on Steam generators), Unit 2

The review of the above work plans concentrated on the MT aspects of the

Modification Packages. A brief description of the Sequoyah MT program, as

previously discussed in Inspection Report 327, 328/86-20, is provided to

clarify the licensee's terminology and program description. AI-19, Part IV,

Revision 18, is the controling document and specifies the MT process.

This

instruction requires a PiiT if the modification was major and the Division

of Nuclear Engineering (DNE) required it through issuance of a test scoping

document. However, the majority of testing associated with modifications

falls into the category of post modification functional test (PMFT). When a

PMFT is required, AI-19, Part IV requires this test be specified in the WP.

The WP that requires a PMFT must list all checks or tests necessary to be

performed before returning the equipment to service.

This functional test

is required to be comprehensive enough to ensure that the new components

perform their intended function and that the work did not inadvertently

degrade an operating system or component.

Specifics of the Work Plans reviewed and the inspectors' findings are

provided as follows:

a.

Main Steam and Feedwater Root Valves Replacement

ECN 6183 and WP 11773 replaced Hancock 5500 valves with Voght 300 in

portions of Main Steam and Main Auxiliary Feedwater System where design

temperature and pressure caused leakage.

This work (replacement) was

exempt from ASME Section XI, hydrostatic testing since all piping,

valves and fittings were one-inch or smaller. As a matter of prudence,

the cognizant engineer indicated that the affected valves and piping

would be inspected for leaks. Inspection will be either at hydrostatic

or operating conditions.

No deficiencies were identified.

b.

Installation of Flanges

ECN 6499 and WP 11834 install flanges in the component cooling water

inlet, outlet and relief valve lines to' the vent . condenser heat

exchanger associated with the Boric Acid Evaporator, Package

"B".

Functional testing consisted of a hydrostatic test per SI-265,

" Hydrostatic Testing Following Repairs and Modifications".

The

purpose of the Hydro was to test the newly installed flanges and

welds.

Test pressure was 165 psig.

In addition to a visible

examination of the welds, a liquid penetrant examination was performed

by the licensee.

No deficiencies were identified.

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c.

Pressurizer Level Transmitter Relocation

ECN 6439 and WP 11893 relocates level transmitters from inside the

crane wall to outside the crane wall in the incore instrument room.

The location was changed to the outside crane wall so maintenance can

be performed in mode 1, 2 and 3.

This will also. reduce radiation

exposure when working on the transmitters in modes 4-6.

Functional

testing consisted of calibration of. level transmitters and Non

Destructive Examination (NDE) of the welds.

No problems were

identified with this modification.

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d.

Steam Generator J-Nozzles Replacement

NCR 2215 and WP 12074 removes and replace original carbon steel

J-nozzles with new Inconel J-Nozzles. The subject work activities were

performed under the cognizance of the onsite Combustion Engineering -

(CE) Task Manager. QC visually examined "J" Nozzle Welds repairs per

OP-9.1, Rev. 5.

A final inspection of cleanliness was performed by QC.

No post modification testing nor functional testing were required for

this modification. No deficiencies were identified.

e.

Limit Switch Replacements

ECN 6556 and WP 11928 replaced existing limit switches on various air

operated valves in systems 30, 63, 77, 81, and 68 with environmentally

qualified NAMCO brand limit switches to meet 10 CFR Part 50.49

requirements.

Specified functional tests consisted of cycling the

valves to ensure proper limit switch adjustment / valve position

indication and stroke timing per SI-166.6. No problems were identified

with this modification.

f.

Limitorque Valve Modifications

ECN L6544 and WPs 11866 (Unit 1) and 11853 (Unit 2) replaced all wiring

within the limit switch compartment of approximately 214 limitorque

valve

operators with

environmentally qualified wiring.

This

Modification involved valves contained in systems 1, 3, 26, 62, 63, 67,

68, 70 and 74. Appropriate drawings were changed as part of this wire

replacement effort, such that previously jumpered out limit / torque

switches were eliminated 'from control circuits altogether in order to

simplify the circuits and their rewiring. Additionally, in the case of

16 valves, wiring changes were made to eliminate a limit switch that

was effectively making an existing torque swite:h in their respective

control circuit non-functional.

The functional tests specified in the work plans consisted of a hand

cycling of the valve actuators with a check on limit switches, closing

and opening contractors.

The valves were ther cycled open and closed

electrically. Excluding the 16 valves that were modified to include an

existing torque switch as a functional part of their control circuit,

the majority of these limitorque valves are containment isolation

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valves and are therefore subject to the surveillance requirements of TS 3.6.3.

Accordingly, TS Surveillance 4.6.3.1 requires that containment

isolation valves be cycled and timed to demonstrate them operable prior

to returning them to service after maintenance, repair or replacement

work is performed on the valve or its associated actuator, control or

power circuit.

The stroke timing test associated with these

containment isolation valves i s SI-166.6.

As for the 16 excluded

valves, section 6.8 of Technical Instruction (TI) -69, " Summary of

Pre-and Post-Maintenance Valve Tests For ASME Section XI and 10 CFR 50

Appendix

J,"

requires that a stroke timing test be performed per

SI-166.6 whenever maintenance of this nature is performed on a valve

control system. Consequently, the stroke timing test of each valve per

SI-166.6 would be required to be performed in order to prove valve

operability; however, SI-166.6 was not specified in either work plan as

a test to be performed.

Section 4.1.1.13.d (2) of Administrative

Instruction (AI)-19, Part IV, requires that any checks or tests

necessary -to return equipment back to service be specified in the WP.

The omission of SI-166.6 from the WPs is considered a violation of

AI-19, Part-IV (327, 328/86-43-01).

It should be noted that ongoing

MOVATS Testing of these valves, although not specified in the subject

work plans, will include a stroke test per SI-166.6.

g.

Residual Heat Removal (RHR) Loop Isolation Valves

ECN 6540 and WP 11906 replaced the existing motors on valves 2-FCV-74-1

and 2-FCV-74-2 with environmentally qualified motors.

These valves are the RHR suction isolation valves off of reactor

coolant loop 4 and are considered necessary to mitigate an RHR line

break.

Specified functional tests included megger, grease, and

rotational checks of the motors, and the performance of a stroke timing

test of the valves per SI-166.6. TS Surveilla"ce 4.4.6.2.2.c requires

that these valves be demonstrated operable by verifying leakage to be

within its limits prior to returning the valve (s) to service following

maintenance, repair or replacement work on the valve (s). Additionally,

TI-69 requires a Post-Maintenance Leak Test be performed on a motor

operated valve when motors are not replaced with identical motors. A

Leak Rate Test would be indicated in this case since the existing

motors were rated at 2.6 HP, whereas the replacement motors were rated

at 4~0 HP.

The Leak Test associated with these valves is SI-166.18,

.

"RHR Return Valve Leak Rate Test". The omission of SI-166.18 from the

WP as a specified test to be performed prior to returning the valves to

service is not in accordance with AI-19, Part IV. This is considered

another example of Violation 327,328/86-43-01 identified in paragraph f

above.

It is recognized that due to the duration of this outage,

SI-166.18 would have also been required to be performed by TS 4.4.6.2.2.c prior to entering mode 2.

This would be verified in

General Operating Instruction (GOI)-1, " Unit Heat Up From Cold

Shutdown to Hot Standby."

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h.

Replace Solenoid Valves With New EQ Valves

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ECN 6552 and WP 11897 replaced existing solenoid control valves with

new EQ valves required to meet the requirements of NUREG 0552. The WP

reviewed replaced 12 valves; three in system 43, six in system 62, one

in system 63, and two in system 87. The new valves were Automatic

Switch Co (ASCO) model #206-381 and model'#8316-54E.

Per the vendor

installation and maintenance instruction manual, the model #206-381

valves were required to be mounted with the solenoid vertical and

upright.

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The inspectors review of the above WP verified that inspection records

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were included.

These records indicated that the solenoid on valves

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2-FSV-43-(202, 207 and 208), model #206-381, were oriented vertical .

However, when the inspector reviewed the installation and inspection

step of the WP, Step 8.2a of Vertical was defined as, " Vertical i 45 .

The inspector requested TVA provide justification for the 45

allowance.

The modification engineer eventually produced a letter

dated April 29, 1985, where an ASCO sales manager indicated that the

model 206 series valves could function with a solenoid orientation up

to 45

from vertical .

However, the letter went on to state that

seismic qualification for the 206 series was performed in the vertical

position only and the effects of mounting in the other orientation

would have to be evaluated. The inspector requested the seismic test

data for other vertical orientation and received (from TVA) Seismic

Simulation Test Report #17746-1.

This report documented the Wyle

Laboratories test performed June 9 and 10, 1986, for TVA under Purchase

Order TV-56071A. The test concluded that for the seismic event the

valves continued to function and maintain their structural integrity.

The inspector was satisfied with the information provided by TVA.

However, since TVA had installed the valves in April 1986, several

months before qualification testing, the modifications supervisor was

cautioned about the use of equipment in a manner not recommended or

qualified by the manufacturer without prior testing or qualification by

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TVA.

Additionally, if the installation was conditioned to seismic

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qualification af ter installation it sFould have been specified in the

WP. The functional testing review for this WP indicated that testing

was performed, however, cross referencing of the testing performed back

to the WP was not always documented.

Specifically, WP 11897 was not

referenced on a SI-166.6 test package or master list reference for

eight of the twelve valves. The inspector did, however, locate a valve

functional tet t performed on the same date indicated in the WP but no

reference back to the WP could be produced by the licensee.

SI-166.6

specifically required a test data package or master list notation to

tie the specific test to the work plan.

This failure to follow the

requirements of SI-166.6 is considered another example of Violation

327, 328/86-43-01 identified in paragraph f. above.

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1.

Replacement of Cable PP711B in Cable. Tray AS-B1, Emergency Supply

Breaker Feeder From 6.9KV Shutdown Board 2B-B

ECN 6627 and WP 12040 replaced a section of cable identified as PP711B.

This work plan specified functional testing per SI-7 which was

accompitshed on June 17, 1986. No problems were identified with this

modification.

J.

PMT-74 Automatic Shunt Trip Modification Test (Unit 2)

ECN 6233 and WP 11890 specified the testing associated with the

Automatic Shunt Trip Modification on Unit

2.

This procedure had

several changes written prior to the completion of testing.

Change

1. 86-488 modified the expected voltage values at a specific test point.

This' change was processed using a change form (Appendix G of AI-4) and

handled as an expeditious change.

To understand the temporary change

process as'used by TVA, the following is provided:

TS 6.8.3 allows temporary changes to plant committee approved

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procedures under certain restrictions.

ANSI 18.7-1976, to which TVA is committed, also makes allowance

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(paragraph 5.2.2) for the licensee to make temporary changes to a

procedure providing certain conditions are met.

This ANSI also

requires this procedure change program to be described in writing

by the licensee.

Document Control", is the plant

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AI-4, " Plant Instructions

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procedure TVA used to describe this Procedure Change Program.

Section 13 of this procedure discusses the actual change process.

The method of changing a Plant Operation Review Committee (PORC)

approved procedure in an expeditious manner is described in

paragraph 13.1.

AI-4 only allows expeditious changes under the

following two conditions:

(1) To make changes which will remain in effect for only a limited

number of instruction performances (e.g., an SI needs to be

performed differently this one time because the plant is in an

abnormal configuration).

(2) To make urgently needed revisions when there is not time to go

through the original type of review / approval cycle (e.g., an NRC

inspection identifies a serious deficiency in an instruction'which

must be corrected immediately).

In this case, the plant

instruction change form (Appendix G of AI-4) authorizes an

expeditious change practice until a permanent instruction change

can be issued.

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As part of the Post Modification and Post Maintenance Testing

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program, plant engineers routinely specify in the WP or on the

maintenance form to " accomplish the applicable portions" of

approved procedure.

This method appears to circumvent the

procedure change process as described in TS 6.8.3 and AI-4.

Additionally, if the user omits certain steps or picks and chooses

steps of the approved procedure he has in fact changed the intent

of the original procedure. In this case, TS 6.8.3 requires that a

change with the same level of review and approval be executed

prior to use.

The specific example of changing a committee approved procedure (ie.,

changes to WP 11890) in an-expeditious manner as well as the improper

changing of committee approved procedures

(i.e.,

" accomplish the

applicable portions") is considered a violation of TS 6.8.3

(327,

328/86-43-02).