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Insp Repts 50-327/88-09 & 50-328/88-09 on 880125-0317. Violations Noted.Major Areas Inspected:Snubber Surveillance Program,Piping Thermal Expansion,Ie Notice 85-045,testing of Main Steam Safety Relief Valves & IE Bulletin 80-11
	ML20154P999
Person / Time
Site:	Sequoyah
Issue date:	05/06/1988
From:	Jape F, Lenahan J; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	;
Shared Package
ML20154P990	List: ML20154P987; ML20154P992; ML20154P999;
References
	50-327-88-09, 50-327-88-9, 50-328-88-09, 50-328-88-9, IEB-80-11, IEIN-85-045, IEIN-85-45, NUDOCS 8806060153
	Download: ML20154P999 (9)
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Cro ug UNITED STATES

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NUCLEAR REGULATORY COMMISSION

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g j 101 MARIETTA STREET,N.W.

'* ATLANTA, GEORGI A 30323

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Report Nos.: 50-327/88-09 and 50-328/88-09

Licensee: Tennessee Valley Authority

6N38 A Lookout Place

1101 Market Street

Chattanooga, TN 37402-2801

Docket Nos.: 50-327 and 50-328 License Nos.: OPR-77 and DPR-79

Facility Name: Sequoyah 1 and 2

Inspection Conducted: January 25-29, February 16-18, March 2,10 and 14-17,

Inspector: 5 I

Date Signed

J. J. Lenahang//

Approved by: fa-sh ~'

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MI

F. Jape, SectiWChf'ef

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Test Programs Section

Division of Reactor Safety

SUMMARY

Scope: This routine, unannounced intpection was in the areas of the snubber -

surveillance program, piping thermal expansion. IEN 85-45, tasting of the

main steam safaty relief valves, IEB 80-11, and licensee action on a previous

inspection finding.

Results: Two violations were identified. Installation of Improper Bolts

During Modification of the Movable In Core Flux Mapping System, Paragraph 8,

and Improper Storage of Quality Assurance Records, Paragraph 9.

8806060153 880517

PDR ADOCK 05000327

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REPORT DETAILS

1. Persons Contacted

Licensee Employees

L. D. Alexander, Modification Group B Supervisor

R. N. Butler, QA Evaluator, Site QA Group

L. Bryant, Mechanical Maintenance Engineering Supervisor

J. Casey, Mechanical Maintenance Engineer

C. R. Farreau, Snubber Engineer, TVA Nuclear Maintenance Division

B. T. Hensley, Restart Test Unit Supervisor

M. K. Jones, Restart Test Manager-

G. B. Kirk, Compliance Licensing Manger

R. Landis, Modification Engineer

W. H. Lee, Civil Engineer

K. Mogg, Supervisor, Civil Eningeering Unit, Office of Engineering

P. C. Murray, Engineering Aid, Mechanical Maintenance

R. W. Olsen, Modification Manager

T. Sanders, Mechnical Engineer, Maintenance

W. Snathers, Unit Supervisor, Civil Engineering Unit

P. B. Turner, Modifications Engineer

C. H. Whittemore, Licensing Engineer

Other licensee employees contacted included civil, mechancial and startup

engineert.

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Other Organizations

D. Hale, Restart Test Engineer, Stone & Webster

' R. Rhiner, Stress Anc.lyst, Gilbert Associates

NRC Resident Inspoctors

K. Jension, Senior Resident Inspector

P. Harman, Resident Inspector

M. Branch. Senior Resident insepctor

Attended exit interview

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2. Exit Interview

l- The inspection scope and findings were summarized on March 17, 1988, with

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those persons indicated in paragraph 1 above. The inspector described the

l areas inspected and discussed in detail the inspection findings. The

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following new items were identified.

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a. Violation 327, 328/88-09-01, Installation of- Improper Type of Bolts

During Modifications of the Movable Incore Flux Mapping System,

Paragraph 8.

b. Violation 327, 328/88-09-02, Failure to Take Prompt Correction

Action in Regard to Improper Storage of Quality Assurance Records,

Paragraph 9.

The licensee did not identify as proprietary any of the material provided

to or reviewed by the inspector during this inspection. Dissenting

comments were received from the licensee regarding violation item 327,

328/88-09-02. These comments are further discussed in Paragraph 9.

3. Licensee Action on Previous Enforcement Matters

(0 pen) Unresolved Item 327/86-24-02, Load Ratings of Mechanical Snubbers.

The inspector examined procedure SMI-0-317-28, Collection of Name Plate

Data for Mechanical Snubbers. This is the procedure used to determine

locations (pipe supports) where Pre-NF snubbers are installed in Unit 1.

The inspector examined the data collected as of the inspection date.

Approximately 400 Pre-NF snubbers have been identified. Due to lost or

misplaced design calculations for some Unit 1 pipe supports, the licensee

is re-constructing the missing calculations. The Pre-NF snubbers will be

evaluated during this redesign effort to determine if any Pre-NF supports

need to be replaced-with a NF snubber. The inspector examined Sequoyah

Design Criteria No. SQN-DC-V-24.2, Supports for Rigorously Analyzed

Category I Piping. Review of the design criteria and discussions with

responsible design engineers disclosed that the design capacity of the

Pre-NF snubbers used for faulted load is twice the load rating on the name

plates (i.e. twice the normal rated load). The ir,spector questioned

licensee engineers regarding the basis of these values. These discussions

disclosed that the snubber manufacturer, Pacific Scientific, proviJed the

design data in a September *,1987 letter to TVA in which they stated

that the Pre-NF snubbers had a one-time load ca;acity of twice the rated

load and that this value could be used for faulted loads. The inspector

questioned the meaning of a one-time load and whether this in acceptable

for use in design. The inspector will examine the basis for these design

loaos in a future inspection. UNR 327/86-24-02 will remain open pending

completion of the Unit 1 pipe support redesign effort.

4. Unresolved Items

Unresolved Items were not identified during this inspection.

5. Snubber Surveillance Program - Unit 1 and 2 (70370)

The inspector examined procedures and quality records related to the

snubber surveillance program and inspected snubbers on safety-related

piping systems. Acceptance criteria utilized by the inspector appear in

l Technical Specification (TS) 3/4.7.9.

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a. Review of Snubb:r Surveillance Procedure (Units 1 and 2)

The inspector examined the following procedure which control Unit 1

and 2 snubber surveillance activities:

(1) Surveillance Instruction SI-162.1, Visual Examination of

Snubbers

(2) Surveillance Instruction SI-162.2 Snubber Functional Testing

(Hydraulic and Mechanical)

b. Inspection of Snubbers: (Unit 2)

The inspector performed a visual inspection of selected snubbers

installed on safety-related piping systems inside the Unit 2

containment building. This inspection was conducted while the

reactor coolant system was at ambient temperature and during the

heatup process to normal operating temperature. During the inspec-

tion, the inspector verified that the snubbers were not damaged, and

that attachment of the snubbers to the supporting structure and

piping was secure.

c. Review of Quality Records: (Unit 2)

The inspector performed a detailed review of the -results of

functional testing conducted on Unit 2 safety-related mechanical

snubbers. Three of 71 snubbers tested in the initial lot failed to

meet the snubber functional test acceptance criteria. Therefore,

in accordance with TS 4.7.9.f, an additional lot (first subsequent

lot) equal to one-half of the initial sample size was selected for

functional testing. One of these snubbers failed to meet the

functional test acceptance criteria. However, no additional samples

were selected for testing since the TS permits one test failure in

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ecch subsequent test lot. The inspector examined the functional test

performed on snubbers placed in locations (pipe supports) where the

previous functional test was not acceptable and verified that all

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snubbers placed in these locations had been tested. The inspector

also examined calculation titled SI-162.2 Evaluation, Problem No.

N2-SI-162.2-MISC. This calculation was performed to determine if

inoperable snubbers adversely affected the components restrained by

the snubbers per the requirements of TS 4.7.9.g. Results of the

calculation indicated that the load imposed on the components by the

inoperable snubbers were well below design allowable limits.

Within the areas inspected, no violations or deviations were

i denti fied.

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6. Testing of Main Steam Safety Valves Unit 2 (Module 61701)

The inspector examined the test procedure and results of testing and

setting of the Unit 2 main steam s=.fety relief valves. A portion of

the actual valve testing was ' witnessed by the NRC resident inspectors.

Acceptance criteria utilized by the inspector appear in Technical

Specification 3/4.7.1 and a NRC letter dated October 23, 1987, to TVA

clarifying commitments pertaining to _ relief. valve testing. The licensee

coniitted to test all 20 main steam safety relief valves. The inspector

examined Surveillance Instruction SI-111, Testing and Setting of Main

Steam Safety Valves, Revision 8, and Instruction Change Forms ICF 88-360,88-445, 88-580, and 88-603. The ICFs were written to change Revision 8 of

SI-111 and will be incorporated into the next general procedure revision.

The precedures cover relief valve testing requirements including prereq-

uisites, test holdpoints, precautions, special test equipment, detailed

test instructions, test acccptance criteria, data sheets, and test

equipment calibration requirements. The inspector examined the test

results. The lift setting of 15 of the valves was within the test

acceptance criteria and Technical Specification limits when initially

tested. The remaining five were slightly outside the plus or minus one

percent tolerance when initially tested and required minor adjustments to

be within the specified lift setting limits. Initial test results versus

specified test range of the five valves which did not meet the specified

range on the initial test are summarized below

Summary of Main Steam Relief Valve Tests Which Fell Outside of Acceptance

Range

Valve Nu.nber Specified Test Range (psig) Initial Test Results (psig)

2-1-513 1066.23 - 1087.77 1064.5

2-1-515 1091.97 - 1114.03 1087.7

2-1-517 1053.36 -

1074.64 1081

2-1-527 1053.36 - 1074.64 1053.2

2-1-526 1105.83 - 1128.17 Erratic Data, but

Slighty Low

The above deficiencies were documented on test deficiency numbers, ON-1

through 0N-5.

Within the areas inspected, no violations or deviations were identified.

7. Thermal Expansion Test Unit 2 (70370)

During a previous inspection, the inspector reviewed the thermal expansion

test procedures and the results of inspections conducted by the licensee

to identify potential interferences which could restrict movement of

piping systems during heatup to normal operating temperature. The results

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of this inspection are sunmarized on Page 20 of NRC Inspection Report Numbers

50-327/87-73 and 50-328f 87-73. During the current inspection the

inspector walked down variots piping systems in the reactor building,

examined the potential interferences, and reviewed the licensee's actions

to correct these interference while the reactor coolant system was at ambient

temperature. The inspector also examined the crossover leg whip

restraints while the temperature of the reactor coolant system was at

450 F. The clearance requirements for the whip restraints are specified

on Drawing Number 48N430RZO, Structural Steel Equipment Supports, Cross-

over Leg Restraints. The gap for one of two of the Loop 2 restraints

was less than the specified clearances. This problem was corrected by

removing a shim in the support and reinstalling a new shim fabricated to

meet the specified clearances. The new shim was fabricated based on

dimensions obtained during several gap measurements made at various

intervals during heatup to 535 F. The inspector accompanied licensee

engineers and walked down selected piping systems when the reactor coolant

system was at normal operating temperature. Examination of the eight

crossover leg whip restraints showed that gaps between the piping and

the restraint met the specified criteria. Two minor interferences were

detected by licensee personnel. The inspector examined the interferences.

One of these occurred on relief line piping on top of the Loop 2 steam

generator, and another occurred in small diameter RC piping adjacent to

the Loop 3 reactor coolant pump. The licensee was in process of repairing

these deficences at the conclusion of the inspection.

Within the areas inspected, no deviations or violations were identified.

8. IE Information Notice 85-45, Fotential Seismic Interaction Involving the

Movable In-core Flux Mapping System Weld in Westinghouse Design Plants

ItN 85-45 provided information to licensees regarding possible interaction

during a seismic event between the nonsafety-related portions of the flux

mapping system and the seal table in Westinghouse designed plants event.

The potential interactions existed because portions of the flux mapping

system that had been seismically designed were located directly above the

incore instrumentation tubing and seal table. In a letter to TVA dated

June 7, 1988, Westinghouse recommended that TVA investigate this problem.

The licensee performed a design evaluation of the movable incore transfer

device and determined that it should be restrained from moving during a

scismic event. ECN L6447 was issued to add seismic restraints to the

movable incore transfer device. This modification consisted of replacing

5/16 inch diameter bolts of unknown properties with 3/4 inch diameter

A-325 high strength bolts, replacing 3/8 inch diameter bolts of unknown

properties with 3/8 inch diameter A-193, bolts, and adding two seismic

res traints . The modification was implemented under Work Plan Number

11672. Two additional seismic restraints were added under ECN L6548.

This modification was implemented under Work Plan 11929. The inspector

examined the completed modifications on the Units 1 and 2 Seal Tables and

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the quality records documenting completion and inspection of the modifica-

tions. Examination of the completed modifications disclosed 12 A-307 bolts

had been installated in the Unit 2 seal table and eight A-307 bolts were

installed-in the Unit i seal table in locations where WP 11672 called for

A-325 bolts. Also, the quality records documenting installation and QC

inspection of the bolts indicated that the type of bolts specified on the

drawings had been installed. The . failure to install the correct bolts

when completing the seal table modification and the failure of the QC

inspectors to identify the discrepancy was identified to the licensee as

Violation Item 327, 328/88-09-01, Installation of Improper Type of Bolts

During Modification of Movable Incore Flux Mapping System. This violation

involved failure to control safety related materials (bolts), installation

of the wrong type of bolts by the craf t personnel, and an inadequate

inspection of the completed modification by QC inspector personnel. The

licensee implemented immediate corrective action by replacing the 12 A-307

bolts in the Unit 2 seal table with A-325 bolts. These bolts were

installed under Work Request B 273600. The inspector examined the

modification and verified that the A-307 bolts had been replaced with

A-325 bolts. The A-307 bolts in the Unit 1 seal table will be replaced

prior to restart of Unit 1.

9. (0 pen) IE Bulletin 80-11, Masonry Wall Design - Units 1 and 2

IEB 80-11 was previously inspected during inspections documented in

NRC Inspection Report Nos. 50-327/81-05, 50-328/81-04, 50-327/86-24 and

50-328/86-24. The inspector examined supports which were added to two

walls in the Unit 1 and 2 Elevation 690 Sample Rooms. This work was

specified by ECN L5703, and implemented under WP 11952. Two additior.al

sample room walls were removed par ECN 6741 under WP 12178. .The inspector

examined quality records attached to WP 11952 which document inspection of

the modifications and traceability of materials used for the modifica-

tions. Inspections included reviewing the installation of expansion

anchors, weld fit up and the completed welds.

During exaraination of WP 11952, the inspector noted that this document,

and approximately 200 others were stored on open shelves in Trailer 9.

The storage facility provided by the trailer does not meet the licensee's

QA Procedure NQAi III, Section 4.1 and referenced ANSI N45.2.9-1974 which

requires quality assurance records to be stored in facilities which will

protect the records from possible destruction by causes such as fire,

flooding, tornadoes, insects, rodents, and extreme variation in tempera-

.ture and humidity. The Trailer 9 storage facility did not provide the

required protection for records. Further discussions with licensee

personnel disclosed that a similar problem was initially identified by the

licensee's QA staff in an audit conducted in the Spring of 1986.

CAR 86-024 was issued on May 12, 1986, to document and disposition this

problem. In an attempt to correct the CAR, licensee personnel had

identified improper storage of the records in Trailer 9 as an item needing

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resolution. However, questions as to what constitutes a "QA record" have

delayed implementation of corrective actions. The inspector identified

the failure to promptly correct CAR 86-024 and the improper storage of QA

records (work plan packages) stored in Trailer 9 as Violation item 327,

328/88-09-02, Failure to Take Prompt Corrective Action in Regard to Improper

Storage of Quality Records. During the inspection and exit interview,

members of the licensee's staff disagreed with the inspector concerning

the violation. This disagreement was based on fact that TVA does not

consider a document to be quality record until the final signature is made

on the cover-sheet of the llP. The signature lacking was that designating

that updated ("As-Built") drawings had been completed to show

implementation of the modification. In response to CAR 86-024, the

licensee revised NQAM III, Section 4.1, to cover temporary storage of

"In Process" records. The revised procedure (Revision 2 to NQAM III,

Section 4.1) was issued and became effective on December 31, 1987.

Appendix 8 of' the revised procedure gives guidelines for control of

in-process QA Document. The guidelines state that in-process records can

be stored in facilities which do not meet the requirements ANSI N45.2.9

for up to 30 days. The 30 day limit from the effective procedure date had

been exceeded by 13 days on February 12, 1988, when the inspector

initially identified the problem. Licensee personnel stated to the

inspector that the Appendix B of NQAM III Section 4.1 is only a suggested

guideline and thus is optional. In response to the inspector's concern,

the licensee relocated the records to a concrete structure on or about

February 16, 1988, which was to serve as a fire resistant storage facility

meeting the requirements of ANSI N45.2.9. This structure had been under

construction in response to CAR 86-024 and was to serve as a long term

storage facility. The inspector examined the new storage facility on

March 15, 1988. This examination disclosed that this facility did not

meet the "suggestions" of Appendix B to NQAM III, Section 4.1, or the

requirements of ANSI N45.2.9. The new facility lacked a fire suppression

system, the doors to the "vault" had a 2 to 3 inch gap under them when

they were closed and thus humidity was not controlled, and records were

not protected from rodents or fire since the records were still stored on

open shelves in the new facility. These actions document further the

inadequate and delayed corrective action to CAR 86-024. The inspector's

basis for citing this item as a violation was the fact that documents

attached to the WP document physically completed modifications to various

safety-related structures, systems, and components. These documents

contain quality assurance records which furnish evidence of activities

affecting quality, e.g. completed inspections, material traceability and

control of special process. The inspector agrees with the licensee that

"in-process" documents are difficult to store in approved facilities while

work is in progress, and that some relaxation of the storage requirements

is necessary during completion of plant modifications under the work

plans. However, the majority of the quality assurance records stored in

the trailer had been there in excess of six months, and there is evidence

that some had been stored there for up to one year pending completion of

"as built" drawings to update plant drawings. The fact that the final

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authorized signature had not been affixed to the work plan cover sheet to

indicate completion of the total work plan, does not negate the importance

of preservation of the individual documents (quality assurance records)

within the work plan packages.

Prior to this inspection, NRC personnel identified an IDI deficiency

pertaining to missing masonry block wall calculations. During resolution

of this problem, the licensee identified a construction deficiency where

angles supporting the top of the block wall had been omitted during

construction. CAQR SQT88-0177 was written to document and correct this

problem. Discussions with licensee personnel disclosed that the angles

had been installed on the walls considered critical to restart of Unit 2.

Installation of the remaining angles is proceeding under WP0000-04. The

licensee is reanalyzing the block walls to recontruct the missing

calculations. Review of the new calculations is being performed by

personnel from the NRC Office of Nuclear Reactor Regulation and Office of

Special Projects.

IE Bulletins 80-11 will remain open pending review of the design

calculations and closeout of WP0000-04.

10. Temporary Instruction (TI) Closeout (Units 1 and 2)

(Closed) Temporary Instruction (TI) 2500/16 - Inspection to Determined if a

Potential Seismic Interaction Exists Between Movable Incore Flux Mapping

System and Seal Table at Westinghouse Designed Facilities of Similar

Design. This TI defined the NRC inspection requirements for IE

Information Notice 85-45. The inspector completed the inspection

requirements detailed in the TI during this inspection (see Paragraph 9).

A Violation Item 327,328/88-09-01 was identified pertaining to the movable

incore flux mapping system modification.

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ML20154P999

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