ML20138G187
| ML20138G187 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 09/25/1985 |
| From: | Crane C TENNESSEE VALLEY AUTHORITY, WESTEC SERVICES, INC. |
| To: | |
| Shared Package | |
| ML19306B153 | List: |
| References | |
| NUDOCS 8512160259 | |
| Download: ML20138G187 (18) | |
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MANAGEMENT REVIEW OF ENVIRWENTAL QUALIFICATION ACTIVITIES AND DOCUENTATION FOR COMPLIANCE WITE 10CFR50.49 September 25, 1985 PREPARED FOR s
TENNESSEE VALLEY AUTHORITY PREPARED BT WESTEC SERVICES, INCORPORATED -
I AND l TENNESSEE VALLEY AUTHORITY 4
WESpCS Sawa(ERVICESCEe_eh>. .
G TVA ()
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NES ffY _ _
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. TABLE OF CONTENTS
'I. Overview I
< II. Introduction j l
III. Results of the Review l IV. Discussion of Significant Deficiencies V. Conclusion Table 1 Management Review Team Members Table 2 Equipment Qualification Files Reviewed Table 3 Executive Stammary of EQ File Review Results ;
Appendix A observations Table A-1 Attendance List at OE - Knoxville Exit Meeting Table A-2 Attendance List - Browns Ferry Exit Meeting Table A-3 Fersonnel Contacted by Review Team .
Appendix B Inspection Plan Appendix C Checklist for Environmental Qualification Report Review (EQR)
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- 1. Ovtrview A team of WESTEC Services, Incorporated, and TVA personnel (see Table
') ~ 1) performed a programmatic and technical review of TVA environmental q qualification (EQ) activities and documentation to determine the degree of compliance to 10CFR50.49, the Federal Law that requires
" environmental qualification of electric equipment important to safety
. for nuclear power plants." Envirosmental qualification is required because it helps assure that safety-related equipment will perform as '
required during accident conditions. The scope,of the review included TVA's entire EQ program for Browns Ferry (BFN), Sequoyah (SQN), and Watts Bar (WBN) Nuclear Plants. The review was conducted at the Office of Engineering (CE) in Knoxville and at the BFN site. (Review of SQN i
and WBN site activities was postponed in order to focus on the TVA EQ problem resolution phase. As part of the Knoxville review, the team inspected programmatic (horizontal) aspects (e.g., procedures, list of equipment requiring qualification, design basis accidents, environ-ments, and systems required to mitigate those accidents) and conducted '
a 100 percent technical (vertical) review of 30 equipment qualification .
files (see Table 2). As part of the BFN site review,- the team :
inspected programmatic aspects (e.g., maintenance and surveillance, procurement, and procedures and documentation) and conducted field verificstion inspections.
,. ,Although the review teamj udge_a_that_certain aspects _o lthe ,EQ yrogram ,_
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i _are satisfactorydh_er.e_are_s.uf_f_icient r other unsatisfactory aspects, *.o lead the _ team _ to conc,1ude,that; document'ed qualitication.haa.not be,an.
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.establishef for. the large majority..of equipment-reviewed. The team
} believes; that many of the~ deficiencies' identified ~ in~the review are
/ significant and are both systematic and pervasive in that the same type of deficiencies could be expected to be found in other EQ files. In
, addition, the team judges that the present EQ files are incomplete and
- not readily auditable due to scattered or missing information. In the team's opinion, the lack of established qualification is most likely the result of an unstructured program, a lack of adequate guidance, and a lack of detailed engineering evaluation during file development. The team observed that the approach to establishing qualification was inconsistent between organizations and that the EQ program was fragmented. The team observed that, in general, the cognizant EQ engineers had the experience, ability, and knowledge to do an adequate job even though the EQ files did not reflect this.
i A report-~oD this type. tends to dwell on deficiencies since the primary .
purpose of the review effort was to discover and constructively point l out any weaknesses in the TVA EQ program. In the team's opinion, many ;
of the observations discussed in Appendix A of this report would be 1 identified should the NRC review the program to the same degree even j though particular observations depend on the individual review team. ;
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The: team 'did find areas of strength, most notably:
.. o The team believes that the "10CFK50.49 List" of equipment requiring qualification is reasonably complete based on a verification that s} essential components in a sampling of safety-related systems were on the list.
o The environmental data drawings provide a controlled way to distribute'a large amount of environmental data in an organized and coherent manner. The large majority of the data presented on the drawings reviewed is supported by verified design analyses.
(Observation GN2-BFNSQWBN).
A o The justifications for the exemption of qualification for nonsafety-related items whose failure under postulated enviromental
. conditions must .not prevent satisfactory accomplishment of safety functions -(10CFR50.49(b)(2)) were valid. (observation GN4-WBN.) ,
All necessary components in systems supporting the ability of the l o
SQN contaiimment spray system to perform its safety-related function ,
were included on the "10CFR50.49 List" and had appropriately defined category and operating times. (Observation GN5-SQN.)
1 o An effective system is in place to ensure that NRC IE Information l Notices are properly handled and evaluated including assignment of responsibility and verification of appropriate action. -(Observation GN6-BFNSQWBN.)
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]~ j., o The ' sampled BFN Technical Evaluation Report. commitments made to NRC had either been , fulfilled or activities were in progress to fulfill them. (Observation GN7-BFN.)
o At BFN, the team found that, in general, the maintenance .
instructions developed by plant personnel ars comprehensive and 2.
are consistent with information provided in the QMDSs by CE.
(Observations 33-BFN and 35-3FN).
II. Introduction Follwing an NRC Commissioners' meeting on April 2,1985, in which the status of EQ was discussed at length, James P. Darling, then Manager of Nuclear Power, requested that TVA conduct a " pre-NRC sudit" on EQ.
Subsequently, TVA contracted with WESTIC Services, Incorporated, and f
assembled a review team composed of the WESTEC and TVA personnel shown in Table 1.
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, N team performed an NRC-type review of the TVA EQ program and
. activities for BFN, SQN, and WBN to determine the degree of compliance -
-- to the NRC Final Rule on EQ in 10CFR50.49. N purpose of the review was to identify elements of the TVA program that fully comply and also
} to identify deficiencies or weaknesses in the program. This report presents the details and s m ry conclusions of the review.
N objective of, the review was to obtais the maximian exposure to the TVA EQ program elements within the review period. N review process was both horizontal and vertical. N horizontal review was performed to include sampling of the programmatic elements of the program such as:
o identification of design basis events, o identification of abnormal and accident environmental conditions, o confirmation of the existence and completeness of supporting analyses for environmental parmaeters, o methodology and basis for the safety-related systems list, o methodology and basis for the master list of equipment requiring EQ, o accuracy and completeness of the master list, o procedures for develonent and control of the master list,
.r-procedures and methodology for development of the EQ files,
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o o equipment maintenance and surveillance procedures, o procurement practices, o resolution of NRC concerns in the Technical Evaluation Reports on EQ, o administrative procedures for implementing the EQ progran, ;
o disposition of NRC I&E bulletins on EQ, I o field verification inspections, o training, and o work requests and modification packages, m.
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Th2 vertical review consicted of a tschnical rcview cf ths 34 EQ filcs (30 of which were 100 percent reviewed) identified in Table 2. These N EQ files generally consist of an EQ evaluation worksheet and a contract file containing documentation. The team reviewed 19 BFN, 11 SQN, and 4
%). WBN EQ files.. The types of equipment. associated with these files were representative of equipment typically requiring EQ such as motors, -
transmitters, cables, connector seal assemblies, peneterations, terminal blocks, limit switches, solenoids, motor-operated valve actuators, and various instrtusents. l The scope of the review included the TVA EQ program for BFN, SQN, and WBN. The original plan was to review the OE Knoxville elements of the 3 program for two weeks followed by a week at each of the' BFN, SQN,' and WBN sites. The OE-Knoxville entrance meeting was held July 29, 1985, and the exit meeting was held August 14,1985 (see Table A-1 for list of attendees). The BFN site entrance meeting was held August 15, 1985,-
and the review was prematurely suspended at the direction of TVA on' .
August 21, 1985, in order to focus on the TVA EQ problem resolution phase. As a result, a number of technical areas at BFN were not reviewed in depth. A BFN site exit meeting was held on August 21, 1985 (see Table A-2 for list of attendees). As a result of the change in focus, the team did not visit the SQN and WBN sites. An average of eight engineers conducted the review with a total of -approximately 1440 i man-hours expended.
The inspection plan, shown in Appendix B, outlined five areas for review: identification of equipment on the EQ master list, EQ
- documentation, maintenance and surveillance, control and tracking, and procurement. -The review effort was based on a definite, comprehensive
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. plan and made extensive use of checklists. The team reviewed EQ-documentation and made field verification inspections. The cognizant EQ engineers were interviewed in an informal interaction process with the emphasis on obtaining all relevant material available, whether or not it was actually in a formal EQ file. During the N xville portion of the review, the individual team members wrote complete descriptions of each observation noted. These observations were typed and' distributed daily during the review to the cognizant EQ engineers to inform them immediately of the team observations and to allow any feedback and subsequent revisions as necessary. Observations are included in Appendix A of this report. l l
The review team received excellent cooperation and support from each of l i
the EQ individur.ls in Knoxville and at BFN. A list of personnel j contacted by the review team is included in Table A-3. ;
V I III. Results of the Review I The review team made a total of 61 observations - 38 on BFN, 15 on SQN, and 8 on WBN. These observations pertained both to the vertical (EQ file) and horizontal (programmatic) aspects of the review.
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, A total of 34 EQ filcs which cro identifi d in Table 2 were review:d using the Checklist for Environmental Qualification Report Review
- included in Appendix C. Of these, 100 percent technical reviews to
) determine the establistment of qualification were performed on 30 of
\' the files. A matrix tabulating the review results of the 100 percent reviewed EQ files is shown in Table 3.' Also, programmatic aspects of the TVA EQ program were reviewed on a selected basis in accordance with ~
the inspection plan in Appendix B. The ful1 text of the observations is included in Appendix A. ,
Table 3 presents the following salient information with respect to each EQ file: ,
o An equipment EQ file cross-referenced to the list of files-identified in Table 2.
o The observation number (Appendix A), where applicable, o The overall conclusion with respect to goalification of -equipment (identified by an "0") .
o A summary of the specific qualification deficiency arens (identified by an "x") based on the team's technical review of the EQ file and s its supporting documentation such as analyses and test reports.
o . An identification of the predominant type of. deficiency (e.g.,
documentation, technical, or procedure).
A corrective action priority listing for each observation subites.
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o The priority level assigned (e.g., high, medium, or low) to these subitems is the team's recommendation to TVA for initiating the resolution effort.
The team's 100 percent review of 30 EQ files indicated the following:
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o Qualification was established for equipment associated with 5 of 30 EQ files (17 percent).
o ~ Qualification was established except for an adequate assessment of qualified life for equipment associated with 2 of 30 EQ files (7 percent).
o _ Qualification was not established for equipment associated with 23 of 30 EQ files (76 percent).
Predominant deficiencies observed in EQ files included:
o Documented evidence of qualification was inadequate in 8 of 30 files (27 percent).
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o ~ Similarity between installed equipment and test specimen was not
-established in 11 of 30 files (37 percent).
n .J o Aging evaluation and qualified life assessment was inadequate in 16 K v: of 30 EQ files (53 percent).
. o . Criteria regarding functional testing representative of plant applications was not satisfied in 9 of 30 EQ files (30 percent).
o Qualification maintenance data sheets (QMDS) were not adequate in 15 of 30 EQ files (50 percent).
Other deficiencies observed in EQ files included:
o' 'Long-term post-accident operability was not addressed in 4 of 30 EQ files (13 percent).
o Test anomalies were not adequately addressed in 5 of 30 EQ files (17
-percent). .
o Interfaces were not adequately addressed in 4 of 30 EQ files (13 percent).
The team's review of programmatic (horizontal) issues (which are not summarized in Table 3) indicated deficiencies with a high ' priority level existed in the following areas:
o Although the list' of equipment requiring 1Q appeared to be reasonably complete based on our system review, there was inadequate documentation of the historical development of the equipment list.
(Observations 2-BFN, 6-SQN, and 3-WBN).
o - Some instrumentation referenced in the BFN emergency operating procedures are not on the "10CFR50.49 List." Certain motor-operated
- valves taking suction from the suppression pool were not on the 10CFR50.49 list. Several inconsistencies were found between the BFN '
Master Component Equipment List (MCEL), Component Master List (CML),
and the "10CFR50.49 List" (Observations 3-BFN sad 1-SQN).
o The "10CFR50.49 Lists" do not include such essential information for l each piece of equipment as location, manufacturer, and model number l (Observation 27-BFN) .
o cable traceability, i.e. , knowing the manufacturer, type, and location of a particular installed cable, is not documented adequately. This is a significant problem at 3FN, SQN, and WBN.
o . Lack of qualification documentation for a number of cables (Observations 11-BFN, 5-SQN and 8-WBN). !
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o Inadequate demonstration of satisfactory functional capability of cable during submergence (observation 15-SQN). -
o Approved BFN procedures do not reflect the actual activities, 1 documentation, and qualification evaluation methods used (Observation 6-BFN).
o Equipment category and operating times for some valves and -
associated local band switches do not reflect the containment isolation function served (Observation 4-SQN).
.o Many items on the BFN "10CF150.49 List" have not been field-verified; therefore, it cannot be ensured that all of the equipment qualification evaluations are based on as-constructed configurations (observation 27-BFN).
o BFN site has no current EQ training program (Observation 29-BFN). ,
IV. Discussion of Sienificant Deficiencies .
A. Deficiencies Related to E0 Files (1) Inadequate Documented Evidence.of Qualification 10CFR50.49(j) requires that "a record of the qualification
. . . must be maintained in an auditable form . . . to permit verification that each item of electric equipment important
,,_ to safety . . . is qualified for its application." The team j found several instances where there was inadequate
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documentation to establish qualification. For example, the most definitive test report available for GE canister s
penetrations was not reviewed or included in the EQ file (Observation 18-BFN). Documentation was not available to show the manufacturer, model number, and application for terminal blocks used in BFN safety-related circuits (Observation 21-BFN). No evaluation of qualification was ,
performed for the GE shutdown and emergency shutdown board transformers (Observation 24-BFN). The MEB qualification evaluation for NAMCO limit switches consisted of one sentence stating that the devices were qualified (Observation 12-SQN).
The teen recommends that this issue of Jocumentation adequacy be investigated and resolved for each EQ file.
(2) Failure to Establiah SLailarity Betwees Test Specimen and Installed Equipment Installed equipment models are of ten dif ferent thau thode reported in the ventar's qualification documentation. The similarity of one device to another mus't be closely evaluated i
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in order to ensure qualification since even minor differences s could cause significant differences in the ability of a
) device to withstand the severe conditions. In order for the V tested equipment to be show"1 to be representative of. the installed , equipment, it must be determined' that the equipment has similar materials,.similar components, similar functional performance characteristics, similar construction, and.
similar service ratings,' and is fabricated by the 'same manufacturer with similar procedures. Justification must be provided for any deviations.
It should be recognized that establishing similarity is a fundamental qualification issue; however, the team found that similarity was a qualification deficiency in 11 of 30 EQ files. For example, the RHR motors installed at BFN have' Class.B Fibremat V insulation whereas a qualification test
- report for motors with Class F YPI epoxy insulation was ,
referenced without justification (Observation 1-BFN).- No l documentation was available which establishes similarity of an AIW cable to the test specimens (Observation 17-BFN). GE canister penetrations were not evaluated for similarity of materials and construction (Observation 18-BFN). The installed Westinghouse RER, CC, and SI motors are 6600V whereas a qualification test report for 4000Y motors was referenced without justification (Observation 7-SQN). The i- installed Westinghouse CS motors are 6600Y and 700 hp whereas qualification test reports for a 480V, 20 hp motor and a, e
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) 4000Y stator were referenced without justificatiori' (Observation 8-SQN).
- With similarity not established, the validity of the entire evaluation is in question. The team recommends that-the issue of similarity be investigated and resolved for each EQ file.
(3) Aging and Qualified Life Assessment Inadequacies The team found deficiencies in aging degradation and qualified life assessments in 16 of 30 E files. Although aging is subordinate to other qualification issues, it is nonetheless a regulatory requirement and a principal consideration in establishing maintenance and surveillance plans. A wide range of deficiencies was identified. For example, the team found that a plant-specific aging assessment for SOR conduit seals would have shown a qualified
- life in excess of 40 years based on a reported 20 year life at more severe conditions. However, since no assessment was performed, the OtDS required replacement after only 20 years (Observation 8-BFN). Qualified life.for cables outside containment at BFN was assessed incorrectly based on testing conducted in a nitrogen environment used to simulate drywell s
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. inerting (Observation 12-BFN). No aging evaluation was performed to support the conclusion that the GE canister s penetrations have a 40-year qualified life and that the
-)* . penetration connectors have a 20 year qualified lif e (Observation 18-BFN). The aging evaluation performed for
%- V ASCO solenoid valves did not address the coil's; temperature rise due to a normal energized state (Observation 22-BFN).
The' team recommends that the issue of aging and the .
assessment of qualified life be investigated -and resolved for each EQ file. , -
(4) Plant Specific Functional Requirements Not Adequately Addressed Sections 2.2.(2)'and 2.2.(7) of NUREG-0588 require that test results demonstrate that equipment can perform its safety function and that performance characteristics should be verified. Section 5.2.(5) of the D01 Guidelines also requires that operational modes tested should bes representative of the actual plant applications. The team found deficiencies in functional requirements in 9 of 30 EQ files. For example, the undervoltage starting capability of
' Limitorque actuators was not addressed (Observations 7-BFN and 2-WBN). The GE modular penetration qualification evaluation did not evaluate the penetration's functional
^ capability with respect to maintaining electrical and mechanical integrity under short-circuit and overcurrent conditions during an accident (Observation 20-BFN). The Reliance motor qualification evaluation was. based on Imotorette test data and does not address the operability of a complete motor assembly (Observation 23-BFN). The tesa recommends that the issue of functional requirements be investigated and resolved for ea'h c EQ file.
(5) Inadequate Qualification Maintenance Data Sheets (QMDS)
Equipment requires adequate surveillance and maintenance to l
preserve the qu'alific; tion status that has been established for-it through the evaluation in the EQ file. The responsible OE engineer uses a QMDS to identify and transmit to the plant site those surveillance and maintenance activities required for qualification. The team found deficiencies in QMDSs in 15 of 30 EQ files. For -exampler the QHDS for Rosemount transmitters does not specify all absolute requirements such as cover 0-ring replacement and torquing to ensure continued qualification (Observation 5-BFN). The QMDS for Limitorque actuators does not specify all absolute requirements such as lubricants, cycling, T-drains and gresse reliefs inside containment, and' orientation i
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(Obs:;rvation 7-BFN). The QMDS for Conas canduit sants do2s not specify a thread sealant or torquins (observation 15-
- . gyy) ,. The QMDS for Rancon actuators does not specify the 10-
- t= l year Buna-N seal replacement interval (Observation 25-BFN).
^' ' N QMDS for Westinghouse CS, EER, CC, and SI motors does not specify lubrication requirements (Observation' 7-SQN). .N'- .
QMDS for GA radiation detectors does not specify Raychem beat -
shrink sleeving around the connector (Observation 10-SQN). .
N QMDSs developed separately by EEB and -MEB for MAMCO limit switches are not consistent and do not specify thread sealant -
and torquing (Observation 12-SQN). . N QMDS for Mince RTDs attached to RCS process -lines does not address the potential temperature rise and its effect on qualified life of the
' connector (Observation 7-WBN); The team recommends that this issue of QMDS adequacy be investigated and resolved for each-EQ file.
B. Deficiencies Related to Programmatic Issues (1) Deficient Identification and Documentation of Safety-Related Systems and Equipment Requiring Equipment Qualification 4
10CFR50.49 requires that equipment important to safety be identified and environmentally qualified, and that this process be documented and auditable. The team discovered several areas of concern related to the development,
. verification, and documentation of the. list. of. equipment
- requiring environmental qualification. N broadest deficiency was the inadequate doctamentation of the -
development of the~ equipment list'for all three TVA plants (Observations 2-BFN, 6-SQN, and 3-WBN). . Nre were no .well-documented basis, verification, or procedural requirements for the development of the original lists. N refore.'it cannot be ensured tht the approach used to identify
- equipment requiring qualification is correct er that the list itself is complete and correct. This situation has been recognized and documented in an NCR for EFN, but the required re-enalysis has received low priority. Another major deficiency was the lack of a single, well-documented equipment list that contained the ministan information about the equipment to be useful as well as auditable (Observation 27-BFN). For instance, the BFN "10CFR50.49 List" does not include such essential information for each piers-of equipment as location, manufacturer, and model number. Nre were a confusing number of lists with different purposes, requirements, and a number of inconsistencies (Observation 3-BFN). Several components referred to in the emergency
- operating procedures were not on the equipment list requiring EQ (Observation 3-BFN) . 10CFR50.49(b)(2) requires that non-safety-related electrical equipment be qualified "whose 4
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failure under postulated environmental conditions could prevent satisfactory accomplisimment of safety functions . . .
. by the safety-related equipment." The evaluation of this -
7 class of . equipment is not well-documented (Observations 9-BFN g/ and 2-SQN). . The team recommends-that these, equipment list deficiencies-be investigated and resolved for.all TVA' plants.
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The team found that the only approved procedure, IN DES SEP 82-10 " Electrical Equipment Environmental Qualification Report for BFN Units 1, 2, and 3 - Preparation and Bandling,"
, does not accurately reflect the actual, ongoirg EQ activities .
(Observation 6-BMI). Although the team understands that a revised procedure is in preparation, there is substantial basis for concern about previous and current work. EN DES SEP 82-10 was written to control an engineering effort. ,
' intended to produce a. licensing submittal and not to provide overall direction of a long-term design, qualification, and maintenance EQ effort.. Because the procedure has been informally superseded, inconsistencies are occurring in the EQ effort. For example, NEB and MEB have taied one evaluation form and EEB has used another set of evaluat ion forms for similar equipment. .Perhaps most indicative of the procedural inadequacies is the complete omission of the "10CFR50.49 List" from EN DES SEP 82-10 although it is currently considered the ultinste equipment list. In addition,'the team found that a ntamber of QHDSs were inconsistent. andf.
'T lacked essential requirements-(observation 16-BFN). ; The team
,/ attributes this inadequacy ,to be the result of a lack of ,
- specific and proper guidance in procedure'EN DES SEP 84-03
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" Qualification Maintenance Data - rreparation and Randling."
The team recommends that these Fmedural deficiencies be investigated and resolved for all TVA plants.
(3) Some Containiment Isolation Tunctions Not Reflected in the NUREG-0588 Category and operating Times Document In reviewing the equipment category and operating times calculation for the SQN containment spray system, the team found that the containment isolation function aspect of several dual function valves and associated local hand o switches had not been incorporated (0boems. tion 4-SQN). As a result, the analysis does not conclude that certain system
- valves must close after 30 days and remain in that position for the duration of the accident. This omission can be attributed to the failure to recognize that some components i serve dual functions. The omission can also be attributed ;
i to the f ailure to completely meet analysis guidelines that j
-- require that a description of the system safety functions be
@rovided at.the beginning of the evaluation. The team i
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recommends that the generic implications of this observation
~ should be investigated and resolved for all TVA plants by reviewing systems to confirm that all safety functions are '
.. . identified-in the equipment category and operating times _ ~
. analyses and by reviewing all containment isolation valves .'l .
for correctategory..and c .
operating times., , '.., y J ...,,
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(4) ' Lack of Field' Ve'rification .and Inadequate Incorporation'of Field-Verified Data Into EQ Files . . .
In reviewing the BFN."10CFR50.49 List," the toan observed that many of.the components have.not been field verified (Observation 27-BFN). The team believes that an' effective '
field verification effort is lacking and that, as a result,' l many of the EQ evaluations are based on as-designed, rather l than as-constructed, information.- An essential element in j establishing qualification is the assurance that evaluations i are representr.tive of as-constructed equipment. .For example, .- 1
-certain trac 9 ability problems at Limitorque have necessitated field inspeation of components to confirm the similarity of
-as-constructed components to Limitorque-tested components. l Although a great deal of this particular Limitorque field verificecion effort has been completed, the information has not bee.1 documented in the EQ file (Observations 7-BFN and 2 'tBN). The team conducted a field verification .
inspection of two Limitorque valve actuators and found
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...- several inaccuracies'in the previously-verified data and Yound that unidentified internal control wiring and' '
unqualified terminal blocks were being used (Observation 28-BFN). The team recommends that field verification data be accurately obtained and incorporated into the EQ files.
(5) Lack of BFN Site EQ Training The team found no evidence of a current EQ training program at the BFN site (Observation 29-BFN). The team discovered that the maintenance training section at the BFN site training center was not' aware of EQ requirements and was not familiar with the @!DS system. Adequate training of the maintenance staff must be conducted to provide assurance that i the need for EQ requirements is recognized and considered in
!. normal, scheduled maintenance, in
- trouble shooting," and in l procurement. The team recommends that all affected site I
personnel be given adequate EQ training.
(6) Cable Qualifiestion Deficiencies Based on the team's experience, cable qualification is of
- great interest to NRC. Since cable qualification files are generically applied (e.g., applicable to numerous, EQP249.02 -_ _ . _ . _ _ _ _____ _ _ _ _ _ - . _ . . _ . _ , ____ _ ___
i diverse, and redundant safety-related circuits), failure to demonstrate cable qualification greatly enhances the potential for common mode failure. Other equiment such as l transmitters and solenoids can be easily replaced to resolve 1
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qualification deficiencies. However, cable replacement is generally not a viable option.. It is for these reasons, that
. cable qualification is regarded' as 'a " big ticket" item. The
- team found significant: deficiencies' covering several . i ,
documentation and technical issues. A major observation is that cable traceability, i.e., knowing 'the manufacturer, type, and location of a particular installed cable, is not doe mented adequately for BFN (Observations 14-BFN and 36-BFN). This detailed information is important because the NRC has rejected a TVA approach to generically qualify cable. A review of the BFN component master list revealed that site procured cable had not been addressed,'that no program is in place to ensure that the information on the list is current, and that several of a random sample of cable .
contract numbers were erroneous. As a result, without field verification, the cable manufacturer an - Joe ne w -_
. datgained for a given circuit number. The team reviewed an d uncontrolled" BFN cable list and found that TVA currently
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possesses EQ documentation for less than half of the cables potentially used in Class 1E circuits at BFN (Observation 11-BFN).. The team believes that cable traceability and cable list completeness problems also exist at SQN and WBN ,
(Observations 5-SQN,13-SQN, 6-WBN, and 8-WBN). In addition, j the team found inadequacies in a JC0 for several cables (Observation 13-BFN). and in a demonstration of cable functional capability during submergence (Observation 15-C{' ~
- SQN). Based on the " big ticket". nature of cable j, qualification and on the magnitude and breadth of the cable [
qualification problems at BFN, SQN, and WBN, the team lf considers this to be the most significant issue resulting f from our review of the TVA EQ program. In the team's l ,
opinion, expeditious resolution of cable qualification ( l
-irequir'as. the highest priority. i V. Concleaion Based on its review _of_the TVA EQ program at Knoxville and BF_N, the TeCconcludes that qualification has not been establisheiffor many equipment items'.' ~ In general,~theYfiles were found to .be incomplete',
~
and not readily auditable; where ' technical ~information could be found 1 the majority of it was scattered and not'ea's'il'y7e'trievable. The team believes that this situation is due to the fragmented nature of the program and the -lack of overall cohesive direction of the effort. This fragmentation is evidenced by the team's observations of inconsistent approaches to qualification by various organizations, lack of detailed review, and poor documentation. The team believes that the identified l
deficiencies are significant, systematic, and pervasive, in that the same type of deficiency can be expected to be found in other EQ files.
The team recommends that TVA place the highest priority on the
, expeditious resolution of these issues.
EQP249.02 13 -
i
,J TABLE 1
)qutAGDENT REVIH TEAM MEMBERS ,
..^
Cy Crane - WESTEC - Team Leader ,
Jim Teague ,- TVA/CRP/NUCSEE - Assistant Te Leader .
Carl Schwartz - WESTEC
- ~~.. ,
- Ken Weise '- WESTEC Dick Bevil - TVA/W P/QA' Tom Spink - TVA/W P/QA-David Renfro - TVA/OE/DETS Gary Overbeck - WESTEC (part-time) .
Stu Klein - WESTEC (part-time)
Bob Brown - TVA/ GIP /EUCSER .(part- time) ~
Pat Brooks - TVA/W P/QA~(part-time) -
Stan Thorne - TVA/ W P/QA (part-time)
Lon Brock - TVA/WP/QA (part-time) . ,
l'
--l.- .
f 9
4 s
- EQP249.02 yN -
gic. TABLE 2 up;
- .J.
2 EQ Files Reviewed '
. .* n - '
M .
SON BFN '
-f - . . ._ . . , . , . ,. g. . ,, ,
f, -
1.- CE RER Motors' - -
1'- Wes'tinghouse SI MotorsE .'" -
g -"
- 2. Tarway Indicator . ~ 2'.' Westinghouse CS Motors .
9'-
[:*
- 3. .Rosesount Transmitters
- 4. Limitorques- -
3.. GA Radiation Detectors'.
- 4. Barton 764 Transmitters- .
- 5. SOR Conduit Seals 5. Neco Limit Switches (EEB)
- 6. Cable - Plastic Wire 6. Namco Limit Switcht s (MEB)
- 7. Cable - AIW 2 7. Cable - Anaconda
- 8. Cable - Essex 2 .- 8. . Cable - AIW 3
- 9. Cable - Brand Rex
- 9. Cable-Carolinay
- 10. Conax Conduit Seals 10. Cable - Brand Rex 4
- 11. GE Penetrations - Canister 11 . Fenwal Temperature Switches *
- 14. ASCO Solenoids - NP Series WBN
- 17. Terminal Blocks 2. TEC Charger Converters i 18. Reliance Fan Cooler Motors 3. Minco RTD
- 19. Emscon Damper Actuators 4. Cable - Moore i
- Individual: entries in Table 3 do not appear. for the footnoted components here in Table 2 for the following reasons: .
IEQ file mot 100 percent reviewed because equipme'nt is being replaced, f
20bservation 12-BFN for Plastic Wire cable (item No. 6 above) applies.
3EQ file not 100 percent reviewed because generic deficiencies were l discovered.
4 EQ file not 100 percent reviewed.
~.
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