ML20207K795

Rev 1 to, Surveillance Program & Instructions

ML20207K795
Person / Time
Site:	Sequoyah
Issue date:	12/18/1986
From:	Michal N TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20207K578	List: ML20207K577 ML20207K596 ML20207K617 ML20207K626 ML20207K646 ML20207K680 ML20207K697 ML20207K727 ML20207K748 ML20207K776 ML20207K795 ML20207K838 ML20207K854 ML20207K887
References
307.05-SQN, 307.05-SQN-R01, 307.05-SQN-R1, NUDOCS 8701090523
Download: ML20207K795 (9)

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TVA EMPLOYEE CONCERNS REPORT NUMBER: 307.05 SQN SPECIAL PROGRAM REPORT TYPE: Sequoyah Nuclear Plant Element REVISION NUMBER: 1 TITLE: Surveillance Program and Instructions REASON FOR REVISION:

To incorporate Sequoyah Corrective Action Plan (CATD 30705-SQN-01) Revision 1 and SRP and TAS Conunents.

PREPARATION PREPARED BY:

Norman R. Michal, Jr. 12-3-86 SIGNATURE DATE REVIEWS PEER:

M. W. Murphy , 12-3-86 SIGNATURE DATE E5 / /2 9 /C SIGNATURE DATE CONCURRENCES 8701090523 861222 PDR ADOCK 05000327 DR CEG-H:\ W M SRP: d b 2 /d /Z-/ / -N SIGNATURE DATE f' SIGNATURg7 (/ DATE APPROVED BY-

$/4k) $$$~$(p N/A ECSP MANAsER DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)

• SRP Secretary's signature denotes SRP concurrences are in files.

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TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT EMPLOYEE CONCERNS TASK GROUP OPERATIONS -

CEG Subcategory: Nuclear Power / Site Program / Procedure Element: Surveillance Program and Instructions Report Number: 307.05 SQN Revision 1 Concerns: IN-86-014-001 IN-86-208-001 Evaluator: Norman R. Michal, Jr. ///.5/fd

! Norman R. Michal, Jr. 'Date Reviewed by: // X# /MM/4 OPS G/e r 'Dite Approved by: 2 M

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I. SURVEILLANCE PROGRAM AND INSTRUCTIONS f This report evaluates two Watts Bar employee concerns having generic j applicability to Sequoyah. The two concerns regard " excessive L surveillance instructions (sis) run on essential equipment" and " sis i require too much of licensed operator time on paperwork versus a monitoring plant." Diesel generator reliability will be more

[id extensively addressed in Element Report 301.02 SQN.

V II. SPECIFIC EVALUATION METHODOLOGY ff k

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The employee concerns identified to Quality Technology Company (QTC) are stated as follows:

IN-86-014-001

, The amount of sis run on essential equipment is too much. Running

! numerous sis on certain systems require the pumps, chillers, compressors, etc., to be cycled on and off. The starting duty on the equipment wears it down and causes more frequent failures such as

bearing failures. An example is that only three of eight ERCW pumps are j presently operational.

l IN-86-208-001 .

Numerous SI packages are required to be performed, which is detrimental f to equipment operation due to an excessive number of start / stops. sis

, also require too much time of licensed operator positions (more time L spent.in paperwork than in monitoring plant performance). Equipment f affected is the ERCW pumps, diesel generators and fire pumps.

I Perceived issues involved with these concerns are:

j A. There is not an integrated approach to surveillance testing with the objective of minimizing starts.

B.' Surveillance requirements require excessive testing.

t i C. Excessive surveillance testing frequencies cause equipment I failures.

D. Excessive paperwork prevents licensed operators from attending c properly to the units.

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t To evaluate these concerns for which no previous investigations were I conducted at Sequoyah Nuclear Plant (SQN), interviews with cognizant b- operations personnel at SQN and Chattanooga were conducted, regulatory lR1

[' requirements were reviewed, relevant NSRS Watts Bsc Nuclear (WBN) 4 reports were reviewed, and applicable TVA procedures were reviewed.

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. i Ravision 1 III. FINDINGS There is an effort by the plant to minimize starts of equipment. This is accomplished by Appendix F of SI-1,Section II Item 22, of administrative adequacy which provides a checklist item asking "Are all tests to be run concurrent with sis listed in the instructions?"

However, the plant did not commit to performing the administrative ddequacy items prior to start up. Five of the completed 259

• surveillance-required instructions did not receive the administrative adequacy review. The 259 instructions represent 36 percent of a total of 920 instructions to be reviewed. The plant has not committed as to when the administrative adequacy will be completed. The plant committed to performing all technical adequacy checklist items identified in Appendix F of SI-1 Section I, before startup. '

Currently, there is an effort underway by the Regulatory Licensing Section to get technical specifications relief for testing the diesels j after they are idle started warmed up, and step loaded versus cold i starts to full load. This is documer.ted on Change Request (CR) 107 from j Domer to Youngblood, dated August 8, 1986. (L44 860808 808) The  !

Electric Power Research Institute (EPRI) Report " Failures Related to l Surveillance Testing of Standby Equipment," Volume 2, (Diesel  ;

Generators) supports this view. The report found that surveillance  ;

testing contributed to 12 percent of the failures in standby diesel generators *t nuclear power stations.

The EPRI report referenced above (Volume 1: Emergency Pumps) stated that none of the pump failures reviewed was caused directly by any aspect of the surveillance testing, even though most of those failures occurred during testing (the major portion of emergency pump operating i time). Sequoyah Nuclear Plant began their Maintrnance Trending Program in December 1985. One trending report has been partially evaluated and no diesel problems have been identified. The program is just getting started. The goal of the program is to evaluate failures for repetitive and generic problems. The supporting procedure is SQM-58, Maintenance i History and Trending R3, December 24, 1985. Volume 2 of the above referenced report indicated fast starts, fast loading, and other harsh features of periodic surveillance testing contributed to 12 percent of the emergency diesel failures. An analysis of utility and manufacturer's experience produced recommendations for testing, IR1 maintenance, design, and operations to help prevent such failures listed .

In the report.

The Nuclear Regulatory Commission has granted relief from technical specification testing requirements for the testing of the diesels after lR1 an idle start. Pumps and instrumentation loop functional testing l l frequency was changed from monthly to quarterly. The safety evaluation report from Novak to Parris, dated April 5, 1985, (L44 850416 402) granted the relief on testing pumps and the CR 36 Enclosure 3, '

from Kammer to Denton, dated September 17, 1982, (LOO 820922 267)

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Revision 1-i-

) requested the change on the instrumentation loop functionals which was granted March 16, 1983, Amendment 27 (Revision 31) to unit 1, technical i specifications and Amendment 16 (Revision 16) to unit 2 technical IR1 j specifications. TVA continues efforts as stated above to analyze l testing requirements in order to minimize m.inpower requirements and q

damage caused by excessive testing.

Section 1.16 of AI-2 states that during normal operations "The licensed operator positions (UO, ASE, or SE) have the authority to terminate activities and/or expel persons from the control room if he determines

?- that the condition is adversely affecting his capability to operate the q unit in a safe manner." lR1 f From interviews with six (6) cognizant operations personnel, paperwork lR1 does not interfere with the reactor operations job - the unit always I takes priority and the paperwork would be set aside until it could be done.

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Sometimes the paperwork would need to be completed before they could g continue power ascension. The operators all stated that when things became hectic they would put up the rope limiting access into the horseshoe, and then do one task at a time, the Unit permitting. Those interviews stated that during startup, or when needed, an operator would be required to work overtime or another operator would be shifted from the other unit to

, help the unit needing the extra operstor support. The SI paperwork is used I to verify the operability of the units.

Conclusions:

lR1 Issue A:

4' The findings indicate that there is a management awareness and an IR1 ongoing effort to provide an integrated surveillance testing program l l with the objective of minimizing of equipment start /stop evolutions. l The issue of the lack of an integrated surveillance testing program is l

[ not valid. l

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Issues B and C: lR1 The findings indicate, at least with respect to the diesel generators, that the surveillance requirements necessitating excessive testing are lR1 Y valid according to the referenced EPRI report. Furthermore, overall l diesel generator reliability is addressed in Element Report 301.02 (SQN). l c

The findings indicate that SQN has in the past, and continues to analyze testing requirements and take action to minimize damage caused by testing.

, Because of the findings above and the findings of the EPRI Report, the general issue of excess testing is not valid, except for the diesel generators as noted above.

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Revision 1 Issue D:

The findings indicate that controls are in place, and followed, such lR1 that operators can take appropriate action to perform their duties independent of scheduled paperwork requirements. Based on the findings, the concern of operators not performing operational duties, because of excessive paperwork is not valid.

The finding and conclusions drawn do not provide evidence of any safety-related issues IV. ROOT CAUSE Based on the findings and conclusions of the evaluation it is determined -

that test frequency is under consideration at the plant. However, the perceived root cause was a lack of a Maintenance History Trending Program in the past.

V. GENERIC APPLICABILITY Concerns IN-86-014-001 and IN-86-208-001 are applicable to WBN, Browns Ferry Nuclear (BFN), and Bellefonte Nuclear Plants (BLN). The concerns were addressed and answered with NSRS report I-85-367-WBN at WBN. The concerns have not been addressed at BFN or BLN.

VI. REFERENCES

1. I-85-367-WBN-01 (IN-86-014-01, IN-86-208-001) dated December 20, 1985

2. NRC Generic Letter 84-15 (Proposed Staff Actions To Improve and Maintain Diesel Generator Reliability) dated July 2, 1984 (A02 840716 019)

3. SI-l Surveillance Program, Revision 15, dated March 31, 1986

4. NSRS Report I-85-211-WBN (Excessive Paperwork Affects Operations) dated September 3, 1985

5. EPRI Report NP-4264 V1, V2 Failures Related to Standby Equipment Pump Testing V1, Diesel Generator V2, dated October 1985

6. 10CFR 50.36. Technical Specifications, dated January 1985

7. 10CFR 50 Appendix B, Quality Assurance Criteria, dated January 1985

8. ANSI N18.7-1976 5.28 and 5.2.19 Surveillance Testing and Inspection Schedule ,

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9. TVA Topical TVA-TR75-1A, 17.2.11 Test Control Revision 8. Test Control, dated October 1984

10. NQAM Part II, Section 4.5, Plant Surveillance Test Program, dated October 12, 1984

11. AI-4 Plant Instructions-Document Control, Revision 54, dated May 2, 1986

12. AI-2 Section 1.1, Revision-24, dated November 7, 1985

13. Draft W.B. Employee Concern Element Report 301.02, dated June 3, 1986

14. Memorandum from Technical Specification Review Committee to P. R.

Wallace, " Review of Technical Specifications SR/ sis," dated July 10, 1986, (553 860710 869)

15. Memorandum from J. M. McGriff to P. R. Wallace, "SI Review <

Completion Date," dated July 29, 1986 (555 860729 801)

16. Memorandum from P. R. Wallace to Plant Supervisor, Technical Review of sis, dated August 22, 1985

17. WB AI 2.4, Shift Manning and Reta11 of Personnel to Plant, Section 2.3, Revision 6, usted September 9, 1985

18. Memorandum from W. S. Wilburn to P. R. Wallace " Review of Technical Specifications REQ. VS. sis," dated February 14, 1986 (501 860214 804)

19. Memorandum from P. R. Wallace to Plant Supervisor, " Verification of T.S. Req.," dated March 17, 1986 (553 860317 804)

20. NRC 85 SALP Report, Pages IP-15. Attachment 2 dated September 17, 1985 (A07 850919 005)

21. Safety Evaluation Report on Sequoyah Inservice Test Program for Pumps and Valves, Novat to Parris, dated April 5, 1985 (L44 850416 402)

22. Domer to Youngblood, Change #107 to Technical Specifications, "To Reduce Diesel Testing Requirements" (as suggested in generic letter 84-15), dated August 8, 1986 (L44 860808 808)

23. Kammer to Denton Change #36, enclosure 3. " Instrumentation Surveillance Requirement Test Frequency of Tables 4.3-1 and 4.3-2,"

dated September 17, 1982 (LOO 820922 267)

24. SQM 58 Maintenance History and Trending, Revision 3, dated December 24, 1985 l

25. Sequoyah Employee Concerns Element Report 301.02-SQN, " Diesel lR1 l Generator Reliability Problema" Page 5 of 6 1

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Ravision 1 VII. IHMEDIATE OR LONG-TERM CORRECTIVE ACTION The Sequoyah Corrective Action Plan (CATD 30705-SQN-01) is stated as follows: l The maintenance component failure trending program described in SQM i 58 is structured to identify potential repetitive and generic l failure trends for plant components utilizing failure reports l submitted to the NPRDS data base and the EQIS data base. Since the l program is structured to look at any type of component failure, l component failures associated with excessive testing should be l identified if the component failure rate exceeds the threshold limits l established in SQM 58. l SQM 58 was implemented in December 1985 with the first NPRDS failure I report issued for evaluation in February 1986. The second NPRDS l report was issued in June 1986 and the third NPRDS report will be l issued in December 1986. l Maintenance groups are presently reviewing equipment history to lR1 evaluate the potential problems identified in the failure reports for l generic and repetitive failure trends. Failure reporting to the EQIS l data base was initiated in December 1985. The first EQIS failure i report was issued in November 1986 for maintenance group evaluation. 1 Summary reports have been issued for the first two NPRDS failure l reports indicating the findings of the mechanical maintenance group 1 and the electrical maintenance group evaluations. The results of the l instrument maintenance group ongoing evaluation of the first two l NPRDS reports are expected by March 1987. I Although SQM 58 is not structured to specifically look for failures l resulting from excessive testing, the component failure trending l program should discover repetitive or generic failure trends caused l from excessive testing. l Page 6 of 6

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- ECPS120J-ECPS12IC TENNESSEE VALLEY' AUTHORITY ', PAIE -

REFERENCE *'7 RUN TIME - 11:

FREQUENCY - REQUEST OFFICE OF NUCLEAR PONER '

OHP - ISSS - RNM EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS)

RUN DATE - 10/

O LIST OF EMPLBYEE CONCERN INFORMATION CATEGORY: OP PLANT OPER. SUPPORT ,

SUBCATEGORY: 30705 SURVEILLANCE PROGRAM AND INSTRUCTIONS S GENERIC KEYNORD A I H APPL QTC/NSRS P -

KEYNORD B CONCERN SUB R PLT BBSN INVESTIGATION S CONCERN KEYNORD C CAT CAT D LOC FLQB REP 9RT R DESCRIPTION KEYNORD D NUMBER

1. 30705 N HBN YYYN I-85-367-NDN NS THE AMOUNT OF SURVEILLANCE INSTRUCTI TESTING IN 014-001 OP ON (SI'S) RUN ON ESSENTIAL EQUIPMENT PROCEDURES T50108 K-FORM IS.T00 MUCH. RUNNING NUMEROUS SI'S SYSTEMS ON CERTAIN SYSTEMS REQUIRE THE PUMP GENERAL I S, CHILLERS, COMPRESSORS AND ETC. T 0 DE CYCLED ON AND OFF. THE STARTIN O DUTY ON THE EQUIPMENT NEARS IT DON

.N AND CAUSES MORE FREQUENT FAILURES I SUCH AS BEARING FAILURES. EXAMPLE B EING ONLY 3 0F 8 ERCH PUMPS ARE PRES ENTLY OPERATIONAL. CI HAS NO FURTHE R INFORMATION NO FOLLON UP REQUIRED B ~

IN 208-001 OP 30705 21 HBN YYYN I-85-367-MSN NS NUMEROUS SURVEIL' LANCE INSTRUCTION (S TESTING T50150 K-FORM I) PACKAGES ARE REGUIRED TO BE PERF0 PROCEDURES RMED,'HHICH IS DETRIMENTAL TO EOUIPM SYSTEMS I ENT OPERATION DUE TO AN EXCESSIVE NU EQUIPMENT MBER OF START / STOPS. SI'S ALSO REGU IRE TOO MUCH TIME OF THE LICENSED OP ERATOR POSITIONS (MORE TIME SPENT IN I PAPERNORK THAN IN MONITORING PLANT PERFORMANCE). EQUIPMENT AFFECTED AR E THE ERCH PUMPS, DIESEL GENERATORS AND FIRE PUMPS. NUCLEAR P0HER CONCE I RN. UNIT 1. CI HAS NO FURTHER INFO RMATION. NO FOLLON UP REQUIRED.

p 2 CONCERNS FOR CATEGORY OP SUBCATEGORY 30705 1

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