IR 05000327/1986055
| ML20209J485 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 01/29/1987 |
| From: | Architzel R, Imbro E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20209J455 | List: |
| References | |
| 50-327-86-55, 50-328-86-55, NUDOCS 8702060326 | |
| Download: ML20209J485 (71) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Division of Quality Assurance, Vendor, and Technical Training Center Programs Report Nos.: 50-327/86-55, 50-328/86-55 Docket Nos.: 50-327; 50-328
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Licensee: Tennessee Valley Authority 6N, 38A Lookout Place 1101 Market S Chattanooga, TN 37402-2801 Facility Name: Sequoyah Nuclear Plant, Units 1 & 2 Inspection At: Soddy Daisy, TN Inspection Conducted: November 3-7 and 17-21, and December 1-4, 1986 Inspection Team Members:
Team Leader: R. E. Architzel, Senior Inspection Specialist, IE Mechanical Systems: F. Mollerus, Consultant, Hollerus Engineering In J. Nevshemal, Consultant *
Mechanical Components: A. V. du Bouchet, Consultant Civil / Structural: A. Unsal, Consultant, Harstead Engineering Electrical Power: S. V. Athavale, Inspection Specialist, IE Instrumentation &
Control: L. Stanley, Consultant, Zytor In Operations: P. E. Harmon, Resident Inspector, SQN*
P. Holmes-Ray, Sr. Resident Inspector, Plant Hatch *
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Ralph E. Architzgl 'Dats l Team Leader 2 7. W 4 o- //20//7 Eugene V. Imbro Date Section Chief
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Quality Assurance Branch j * Part time G702060326 870129 PDR ADOCK 05000327 O PDR
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LIST OF ABBREVIATIONS AFW Auxiliary Feedwater AI Action Item ASME American Society of Mechanical Engineers CAQ Condition Adverse to Quality CCS Component Cooling Water System CEB Civil Engineering Branch C/R Commitment / Requirement DBVP Design Baseline and Verification Program DIM Design Input Memorandum DNE Division of Nuclear Engineering EA Engineering Assurance ECN Engineering Change Notice EEB Electrical Engineering Branch ERCW Essential Raw Cooling Water System ESF Engineered Safety Features EQ Environmental Qualification FCN Field Change Notice (Westinghouse)
FCR Field Change Request FSAR Final Safety Analysis Report HVAC Heating, Ventilation and Air Conditioning IEEE Institute of Electrical and Electronics Engineers LOCA Loss of Coolant Accident MEB Mechanical Engineering Branch MOV Motor Operated Valve NEB Nuclear Engineering Branch NRC Nuclear Regulatory Commission NRR Office of Nuclear Reactor Regulation NSSS Nuclear Steam Supply System PIR Problem Identification Report RIMS Records Information Management System SCR Significant Condition Report SQEP Sequoyah Engineering Procedure SQN Sequoyah Nuclear Plant SWBID System Walkdown Boundary Identification Drawing t SYSTER System Evaluation Report i
TACF Temporary Alteration Control Form TVA Tennessee Valley Authority USQD Unreviewed Safety Question Determination
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WBN Watts Bar Nuclear Plant l
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SEQUOYAH NUCLEAR POWER PLANT Design Baseline and Verification Program Inspection Report 50-327/86-55 & 50-328/86-55 November 3-7, 17-21, and December 1-4, 1986 INTRODUCTION AND BACKGROUND The Design Baseline and Verification Program (DBVP) was developed by the Division of Nuclear Engineering (DNE) to resolve design control issues de-scribed in several TVA sponsored evaluations and audits and NRC inspection The Sequoyah Nuclear Plant (SQN) Design Baseline and Verification Program will be used by TVA to provide the required level of confidence that the modifica-tions to selected plant systems, implemented since receipt of the operating license, have not resulted in any violation of the plant's licensing basis. The program is described in the " Program Plan for the Engineering Assurance Inde-pendent Oversight Review for the Sequoyah Nuclear Plant Design Baseline and Verification Program," dated May 9, 1986 and forwarded to the NRC as an enclo-sure to Mr. R. L. Gridley's letter dated June 27, 198 . PURPOSE This report summarizes the results of the third NRC inspection conducted to assess the adequacy of TVA's Design Baseline and Verification Program (DBVP) to support restart of Sequoyah Nuclear Plan NRC inspection report 50-327/86-38 and 50-328/86-38 summarized the NRC's review of TVA's overall DBVP plan and scope, TVA's procedures for DBVP project review and engineering assurance (EA) oversight, TVA's preparation of system walkdown packages within the DBVP scope, and the NRC's preliminary review of TVA's design criteria for FSAR Chapter 15 safety-related systems within the scope of the DBV NRC inspection report 50-327/86-45 and 50-328/86-45 summarized the NRC's review of TVA's compilation and implementation of the commitment / requirement (C/R)
data base, the design criteria which TVA prepared to support SQN restart, and the adequacy of EA's independent oversight review of C/Rs and design criteri The purpose of this inspection was to:
(1) Assess the adequacy of the DBVP project's ECN revie (2) Assess the adequacy of EA's oversight of the DBVP projec (3) Perform an independent technical evaluation of an ECN sample that DBVP project reviewed, and a sample of ECNs that EA also reviewed in order to assess the adequacy of program implementation and oversight by E (4) Review the adequacy of TVA's actions regarding (1), the deficiencies and unresolved items detailed in NRC inspection reports Nos. 50-327/86-27 and 50-328/86-27; and (2), the observations identified in NRC inspection reports Nos. 50-327/86-38 and 50-328/86-38, and 50-327/86-45 and l 50-328/86-4 __ - _ - _ _ . -
. - _ . __ - . _ INSPECTION ACTIVITIES The following activities were generally performed by all team members:
An independent technical review of a sample of ECNs within the scope of (1) the OBVP and scheduled for partial or complete implementation prior to restart of the Sequoyah Nuclear Plant. The team selected a number of ECNs for review that TVA prepared in the latter part of 1985,The justteam prioralso to and following TVA's shutdown of the Sequoyah Nuclear Plan reviewed a sample of ECNs which modified the component cooling water system. Other ECNs within the scope of the DBVP were also reviewe An overall assessment of the DBVP project's ECN review, including electri-(2) The team compared its ECN findings with the cal test results revie project's findings, and reviewed the project's resolution of EA action items which documented deficiencies which the project's ECN review did not identif The team also (3) An overall assessment of EA's oversight of the ECN revie compared its ECN findings with EA's findings, and reviewed resolution of the project's responses to EA action item (4)
A review of the action taken by TVA in response to the deficiencies, un-resolved items, and observations previously identified in NRC inspection reports Nos. 50-327/86-27 and 50-328/86-27, 50-327/86-38 and 50-328/86-38, and 50-327/86-45 and 50-328/86-4 As Additionally, TVA provided a summary of the calculation review progra required by SQEP-12, the DBVP project confirmed that the calculations support-ing each ECN were retrievable and addressed the scope of the ECN design I modification. However, the DBVP project was not required to perform an A separate calculation in-depth technical evaluation of these calculations.One of the features of this program review program is being conducted by DN Therefore, includes an assessment of the technical adequacy of calculation the DBVP is not examining this aspect of ECN . SUMMARY OF FINDINGS The following paragraphs summarize the team's findings A more and conclusions detailed description as they of the relate to the purposes of the inspectio findings in each discipline is provided in Attachment A to this repor .1 Review of Design Baseline Verification Program TVA calculation SQN-0SG7-048 identifies 31 systems or portions of systems required to mitigate FSAR Chapter 15 Design Basis Accidents at the Sequoyah Nuclear Plan The DBVP project evaluates design modifications to these systems in accordance with Sequoyah Engineering Proc Evaluating Engineering Change Notice and Field Change Notice Document The DBVP project uses SQEP-11 to identify ECNs and other change documents The w modify the safety-class systems tabulated in TVA's reference calculatio DBVP project uses SQEP-12 to review ECNs scheduled to be unimplemented or
. partially implemented prior to restart to determine how much of the design and field work needs to be completed prior to restart. SQEP-12 is also used to evaluate ECNs scheduled for partial or full implementation priorIdentified to restart for technical adequacy and compliance with procedural requirement deficiencies are documented as " punch list" items. These items are also evaluated to determine if they constitute a condition adverse to quality (CAQ).
If a CAQ exists, then the DBVP initiates a problem identification report (PIR).
The DBVP project has written a number of generic PIRs that identify the same For example, civil / structural DBVP project has deficiencies in different ECN written PIR SQNCEB8639 to identify 98 different ECNs with missing calculation PIRs have also been identified relating to distinct technical issues which correspond to unique DBVP Punch List item TVA's engineering assurance group overviewed DBVP project's ECN review effort, and wrote action items to identify deficiencies that DBVP project had not identified. In a number of instances, DBVP project wrote a PIR to address an EA action item. Sequoyah project and staff personnel (as opposed to DBVP project staff) are resolving the PIRs and punch list items which the DBVP project identified. The team was informed that the cognizant DBVP sytem engineer is actively involved in the resolution of identified " punch list" items and associated PIR The Sequoyah Engineering Project is making deter-minations on a punch list basis of those items which are considered The restart extent of EA items that must be assessed and addressed prior to restar NRC considers involvement in the corrective action process was not obviou that EA should audit the corrective action process, and that this action should be completed prior to restart of either unit for those items determined to be restart items by the Sequoyah projec The team overviewed the DBVP project's review effort by independently evaluat-ing a number of the ECNs that the DBVP project had In aevaluated, number ofand by comparing instances, the the team's findings with the project's finding team identified findings that neither the DBVP project or EA (for the limited sample of ECNs that EA reviewed) had documente Some of these observations were determined to be not "in scope", identifying deficiencies in design modifications for inspection attributes that were not part of the DBVP progra As an example, the team documented several observations which identified errors in supporting calculations. However, SQEP-12 did not require the DBVP project The team to perform detailed in-depth technical review of calculation concluded that, for the most part, the DBVP project effectively implemented the SQEP-11 and 12 criteria in identifying and reviewing design modifications to the safety-class systems within the scope of the DBVP.
l The team also noted that training was provided within DNE regarding the 08V The team attended a lecture being given to DNE engineers on SQEP-13, Transi-The lecture was compre-tional Design Change Control, on November 20, 198 hensive and well prepare Discipline-specific summaries of the 08VP project's findings are discussed below:
In the mechanical systems discipline, the team conducted inspections of the This included change evaluations being performed by DBVP project personne discussions with the mechanical and nuclear discipline leads and the system l engineers and review of DBVP evaluations conducted in accordance with SQEP-12.
( Summaries prepared for many ECNs by the system engineers were also reviewed.
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It was noted that the DBVP project evaluation Most had not findings were of afound any changes programmatic nature with substantial technical deficienc involving the need to address missing information such as test results and seismic calculation In the mechanical components discipline, the DBVP project reviewed approximate-ly 700 ECNs within the DBVP that were scheduled for partial or full implementa-tion prior to restart of Sequoyah Nuclear Plant, and identified 342 d The DBVP review of ECNs resulted in the creation of a punch reports (PIRs). list with approximately 2800 items in the Civil Engineering Branch are In the electrical power discipline, the DBVP project reviewed approximately PIRs 395 ECNs and generated approximately 50 problem identification report resulting from review of ECNs are related to missing and poor documentation of calculations, deficiencies in design criteria, design errors and discrepancies in the associated documentatio The team was informed that none of these PIRs resulted in hardware change In the instrumentation and control discipline, the DBVP project stated that their current review and evaluation of approximately 513 ECNs indicated that numerous documentation improvements were required, but that none of their The evaluations had identified any need to change existing plant hardwar types of documentation problems identified by the project included missing instrument setpoint calculations, the absence of instrument accuracy and range specifications in source documents, inadequate scoping of po of a requirement for seismic qualification of replacement component To assess the depth of review accomplished by the project, ten component cooling water system ECNs that had not previously been reviewed by EA or w selected for review by the NRC tea evaluations improvements were considered necessary for the checklists' An evaluation of postulated failure effects of each design modificatio incomplete response had been provided for these ECNs since the evaluation was limited to postulated short circuit effects and the potential loss of the affected electrical board (Observation No.6.14).
In the civil / structural discipline, the project reviewed approximately 700 ECN This review did not include an evaluation of the technical adequacy of Therefore, the project generic findings were mostly related the calculation The major project findings include missing calcula-to documentation problem The project has issued generic tions, undocumented changes and unclosed FCR PIRs against these findings and have included them in the punch list for restar Excluding the calculation technical adequacy reviews, which were not performed, the project review of the ECNs was comprehensive and identified generic documentation problem .2 Review of Engineering Assurance Audit of the DBVP TVA's engineering assurance (EA) group audited the DBVP project's ECN review effort in the civil / structural, electrical, instrumentation andEachcontrol, EA disci-mechanical, nuclear, operations and quality assurance area For pline performed this oversight in accordance with its own review pla example, the civil / structural EA group used review plan No. 5100, Engineering Assurance Oversight Review Plan, to assess the DBVP project's ECN review effort in the civil / structural are The EA team audited the DBVP project's SQEP-11 review of change documents by checking the DBVP project's compilation and classification of change documents which should be reviewed by the DBVP. These include those modifications to systems required for safe shutdown or FSAR Chapter 15 accident mitigation, as EA also evaluated the specified in TVA's reference calculation SQN-0SG7-04 adequacy of the SQEP-12 checklists which the DBVP project used to review ECNs for technical adequacy and compliance with procedural requirements. EA also performed an independent review of change documents that the DBVP project had reviewed to confirm the adequacy of the DBVP project's ECN review. EA review of ECNs was performed on a sampling basis. For example, civil / structural EA reviewed 20 of the 700 ECNs that the DBVP project reviewed in the civil / structural disciplin EA wrote action items for deficiencies identified The DBVP during EA's review of ECNs which the DBVP project had not identifie project reviewed EA's action items and wrote PIR's as required to address EA's finding Discipline-specific summaries of EA's findings are discussed below:
In the mechanical systems dis:ipline, the EA team is conducting reviews of the DBVP evaluations in accordance with plans such as Review Plan No. 4100. The team reviewed the results of the EA oversight by discussions with the EA team and by reviewing the action items developed by EA. It was noted that the EA Most of the EA team had not found any substantial technical deficiencie findings in the mechanical and nuclear disciplines were related to the need for clarification of scope, the need for thoroughness and completeness of DBVP review, guidance in carrying out the project evaluations and identification of
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) administrative deficiencies. The EA oversight review does appear to be contributing to the overall quality of the DBVP produc TVA's Civil Engineering discipline comprises the areas inspected by the team's civil / structural and mechanical components disciplines. EA reviewed 20 of the 700 ECNs which the CEB project reviewed and prepared 20 action items to document deficiencies not previously identified by the project. Their review included the evaluation of calculations for technical adequacy. The action items written by EA show that their findings were also mostly related to poor documentation. The review of calculations identified certain discrepancies between calculations and drawings. The EA action items were not considered indicative of a major deficiency in implementation of the DBVP. The limited review by EA did not identify any major technical issue In the electrical power discipline, EA had reviewed approximately 25 ECNs and six test packages and generated 77 action items. One action item, relating to the need to monitor performance of a new diesel generator room ventilation system, may result in hardware changes. The team considers that the EA action items have enhanced the implementation of the DBVP in the electric power are In the instrumentation and control discipline, the results obtained from ECN oversight reviews performed by the engineering assurance instrumentation and control team were similar to the results obtained by the DBVP project. None of the ECNs reviewed by EA led to a requirement that plant hardware be changed or replaced. A majority of the ECNs reviewed by EA dealt with the adequacy of
instrument setpoints and related setpoint tolerance calculations. An improved depth of technical review, as compared to that noted by the NRC during Theirprevious review inspections, was demonstrated by the more recent EA action items.
identified missing instrument setpoint calculations, missing accuracy and range specifications, missing seismic qualification data, inadequate justifications for some conclusions stated in the project evaluations, and missing or incomplete source document and corrective action reference .3 Inspection of Engineering Change Notices The team inspected the DBVP project's and EA's ECN review efforts by selecting These ECNs had been a sample of ECNs for independent technical review.Some of these ECNs had also be reviewed by the DBVP projec In addition to reviewing this sample of ECNs to assess the DBVP's implementa-tion of SQEP-11 and -12 procedural requirements, the team also performed an independent technical review of selected calculations which supported the ECN The team identified the following observations regarding design modification program:
(1) Instances of inadequate drawing control, including a piping. physical drawing with incorrect and conflicting plans and sections (Observation N .7), use of a piping isometric drawing with an incorrectly oriented plan coordinate for rigorous piping analysis (Observation No. 3.5), and use of a Unit 1 piping isometric for Unit 2 alternate piping analysis (Observation No. 3.8).
(2) Instances of unconservative, missing or erroneous calculations, including a computer coding error in a rigorous piping analysis (Observation No. 3.5),
an unconservative calculation to seismically qualify a containment penetration test line (Observation No. 3.6), incorrect analytical seismic qualification of solenoid valve tubing changes (Observation No. 3.8),
failure to analyze the effects of non-Class IE fan motor loads on the Class 1E system (Observation No. 6.10), and unchecked and unverified calculations for an FCR (Observation No. 7.4).
(3) The team found instances in which engineering did not clearly document the scope of some post-modification tests and instances in which operations did not implement some surveillance test criteria (Observation Nos. 6.15, 6.13, and 6.12).
(4) The team also identified an instance of a race in the diesel generator This was starting logic between load shedding and output breaker closur introduced by a modification, and may require a hardware change to resolve (Observation No. 5.7).
(5) The team found that the DBVP project was taking credit for the work of other TVA programs for resolution of selected technical attributes without confirming that such attributes were properly addressed in the other programs (Observation No. 5.8).
Discipline-specific summaries of the team's findings are discussed belo _ _ _ _ - _ _ _ - ._ _ . _ . _ - _ _ _
In the mechanical systems discipline, the inspection team independently exam-ined ECNs and work packages for many of the plant systems. The team noted that there were changes to CCS heat loads and ERCW minimum flow rates that are significant reductions from values stated in the FSAR but that there were no plans to appropriately revise the FSAR during the next scheduled annual updat Other findings involve improper evaluations of a design (Observation No. 2.4).
criteria which did not incorporate licensing restrictions prohibiting plant operation with less than four reactor coolant loops; an improper basis for a calculation consolidating design conditions; and drawing errors (Observation Nos. 2.5, 2.6 and 2.7).
In the mechanical components area, the team reviewed seven ECNs which had been Two of these ECNs had also been reviewed by reviewed by the project.The team identified five observations (Observation No engineering assuranc .5 - 3.9) in addition to the observations which the project and engineering assurance groups identified for the ECN sampl The team noted that in two instances, TVA used mirror image piping One of isometric the drawings drawings to seismically analyze safety-related pipin appeared to be a Unit 1 drawing whichEach wasofused without these appropriate drawings resides in control a TVAfor the qualification of Unit 2 pipin In alternate analysis calculation package (Observation Nos. 3.5 and 3.8).
another instance, TVA did not properly perform the seismic qualification of the tubing and clamps which support a solenoid valve replaced for environmental qualification concerns. TVA based the calculation which qualified the clamps on an uncontrolled and incomplete field sketch of the installed valve configuration. TVA was also unable to verify that the tubing supporting the solenoid valve had been seismically analyzed (Observation No. 3.8).
The team also reviewed TVA's corrective actions to resolve potential deficien-cies in the Category 1(L) position retention pipe support and piping seismic No observations were qualification programs for Sequoyah Nuclear Plan identified during this revie In the electrical power discipline, the team reviewed several ECNs and several The team noted that TVA's design test packages and associated document process for ECN 5363, implementing load shedding prior to diesel generator breaker closure, did not consider a breaker failure which could result in not meeting the design objectives of this ECN under certain conditions (Observation No. 5.7). The team also noted that TVA's design verification process lacks cross references to the other TVA programs where related attributes have been reviewed (Observation No. 5.8).
In the instrumentation and control discipline, the team reviewed approximately 15 ECNs reviewed and evaluated by EA and 23 recent action items prepared by E Ten ECNs involving component cooling water system changes that had been Six reviewed and evaluated by the the DBVP project team were also examine other environmental qualification ECNs, 5 work plan packages involvingApproxi-post-modification testing and 6 design criteria documents were examine mately half of the team's observations were determined to be within the scope of the DBVP (i.e."in-bounds"), but had not been identified during the project's review. Other team observations related to technical adequacy of calculations and other aspects not within the scope of the 08V Based on comments developed by the the DBVP project for particular ECNs and other observations made by the team, the technical communication of test requirements and test acceptance criteria between engineering and has Engineering plantnot opera-tions personnel has not been sufficiently effective.
documented its understanding of the required scope of post-modification tests, and Operations has not demonstrated its awareness of certain periodic test and surveillance requirements. ECN-L-6648, which added a 20 second time delay for starting of certain pumps and ECN-L-6374 which replaced a pump discharge In pressure switch were representative examples that illustrate this poin the first case, the ECN review failed to identify that a reset timer in the circuit being modified was not being tested; and in the second case the modifi-cation did not require testing or establish criteria for the reset feature which was the purpose of the modification (Observation Nos. 6.15 and 6.13).
During a review of ECN-L6202, which added level switches to the component cooling water surge tank, the team noted that the integrity of the surge tank internal baffle plate that provides independence between redundant CCS water volumes had not been periodically confirmed by either test or inspection (Observation No. 6.12).
TVA analysis SQN-0SG7-038 was issued to justify the connection of unqualified loads to Class 1E buses in response to environmental qualification requirements Two ECNs issued in 1983 and early 1985 stated in 10CFR50.49 section b(2).
deleted Class 1E qualification requirements for the control rod drive mechanism and lower compartment cooling fan motors. When the TVA analysis was subse-quently prepared in late 1985 and revised in mid-1986, it did not include these unqualified loads (Observation No. 6.11). The team also noted that the TVA design criteria document for power, signal, and control cables in Category I structures (SQN-DC-V-11.3) contained incorrect temperature values for environ-mental qualification (Observation No. 6.9).
In the civil / structural discipline, the team reviewed 17 ECNs which were Five of these ECNs were also reviewed by E already reviewed by the projec The team reviewed calculations, drawings and in some cases, work plans related to these ECNs. In various cases the team found that original and revised calculations were missing (Observation No. 7.4). The team believes that this is a generic problem at Sequoyah since both the project and EA also have identified numerous cases of missing calculations and evaluations of change The team did not identify any substantial technical deficiencies in the Civil /
Structural disciplin .4 Review of Previous Inspection Findings Team review of TVA's responses to the deficiencies, unresolved items and obser-vations documented in NRC inspection reports 86-27, 86-38 and 86-45 is detailed in Appendix A. Discipline - specific summaries of the team's review are presented belo One of the four previously identified items in the operations area was close Observation No. 1.1 remains open pending further inspection of TVA's implemen-tation of corrective action for DBVP findings; Observation No. 1.2 remains open pending review of system evaluation reports (SYSTERs) to verify implementation, and Observation No. 1.3 remains open pending TVA action regarding the depiction of "out-of-function" systems on drawing . . . -_- .- . , l l.
l In the mechanical systems discipline, the team closed one of the two deficien-l
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cies documented in NRC report 86-27, and all of the six observations detailed I
in NRC reports e6-38 and 86-45. One deficiency has been transferred to NRC
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Region II for review and resolution (Deficiency D2.3-1).
In the mechanical components discipline, the. team closed seven of the nine deficiencies documented in NRC report 86-27 Oneand two of remains deficiency the four open observations pending detailed in NRC reports 86-38 and 86-45.
i NRC review of TVA's post-restart program to address this issue (Deficiency 03.3-1), one observation remains open pending receipt of a revised TVA response l
(Observation No. 3.4).
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In the electrical power discipline, the team reviewed TVA's response to inspec-l tion findings described in NRC inspection reports 86/27,
- Six 86/38, 86/45 of the 11 and findings
' Gilbert / Commonwealth's report dated March 3, 198 Two of the
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listed in the above NRC inspection reports have been resolve three findings listed in Gilbert / Commonwealth's report have also been resolved.
TVA has been working to resolve the findings which remain open and expects to complete this work in the near future.
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i In the instrumentation and control discipline, the team reviewed the status of three nuclear and 14 instrumentation and control observations made by the team
[ The TVA response to each of the nuclear
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in previous inspection report Similarly, i
discipline observations (i.e. 4.2, 4.5, and 4.6) was satisfactor six of the instrumentation and control observations were closed Two during the of the eight inspection (i.e. D6.2-1, U6.3-2, 6.1, 6.4, 6.6, and 6.8).
observations that remain open involve the development of a specific walkdown inspection plan for instrument lines and the justification of Unreviewed Safety
Question Determination answers for the unqualified excore neutron detectors l
i provided by both Westinghouse and TVA Nuclear Power group In the civil / structural discipline, the team closed all the deficiencies in Deficiency D4.3-1 l
' report number 86-27 except Deficiencies D4.3-1 and D4.3- is open pending evaluations that have to be performed by TVA for reinforcing l
bar cuts. Deficiency D4.3-3 is still open pending evaluations that are being
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performed by Westinghouse for the steam generator lower support .1, 7.2, 7.3 remain For inspection reports 86-38 and 86-45, Observation No open pending further work that has to be performed by TVA, as detailed in 4 Attachment A of of this repor .
! SPECIFIC COMMENTS
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Specific observation comments of individual NRC discipline inspectors are cat j
by each discipline of the NRC team are provided in Attachment A of this report.
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' TVA actions relating to individual observations willIndividual be reviewed by the NRC observations may be
' during future inspections on a selective basi These closed based on TVA's response to this inspection report as appropriat observations elaborate on the general comments stated in this report and in j
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some cases provide additional comments not considered to be of a general j
nature.
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- MEETING SUMMARIES - REFERENCES
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A summary of the meetings held relating to the DBVP inspection and a list of references are provided in Attachment B.
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Att:chment A - InspIcticn Activitics and Obs:rvations NOTE: The observation numbers used in this report are a continuation of the numbers used for the previous DBVP inspections (Report Nos. 50-327/86-38 &
50-328/86-38 and 50-327/86-45 & 50-328/86-45). Observations identified during this inspection are listed at the end of each discipline section belo The references are listed in Attachment Team review of TVA's responses to the deficiencies and unresolved items docu-mented in NRC inspection report 86-27 and to the observations documented in inspection reports 86-38 and 86-45 is detailed in Section .0 OPERATIONS In the operations area, the team examined several ECNs, the work packages associated with some of the ECNs, and EA action items initiated in response to previous inspections. The team ,also coordinated with other team members in such areas as FSAR incorporation of ECN changes and Surveillance Instruction revisions as result of ECN The following ECNs were reviewed:
(1) ECN L5846 - Remove relay 62, energize relay 62X directl (2) ECN L5861 - UHI setpoint changes for level switc (3) ECN L5954 - Add test connection to diesel generator start ai (4) ECN L5957 - Replace SI reset timing relay with an on-delay /off-delay rela (5) ECN L6047 - Install a reactor vessel sight glas (6) ECN L6055 - Add a fourth wide range pressure transmitter (RCS).
No observations were identified relating to these ECNs from an operations standpoin .0 MECHANICAL SYSTEMS The NRC team conducted inspections in the area of mechanical systems with emphasis on the impact of actual and proposed plant changes on system function-al performance. The inspection included review of the results of the DBVP project reviews, review of the EA results and action items and independent review of other ECNs, associated work plans and implementation results. In addition, the team reviewed the licensee's actions taken on previous inspection finding A-1
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lJ Attachment A - Insp ction Activitics and Obs2rvations l
l 2.1 DBVP Project and EA Reviews of Changes I
The DBVP Project was in the process of reviewing the changes within the bounda-ries of TVA Calculation SQN-0867-048. The NRC team reviewed the DBVP project evaluation of ECNs and FCNs for the essential raw cooling water, component cooling water, diesel fuel oil, diesel starting air, and HVAC system This was done primarily by reviewing project evaluations conducted in accor- In many dance with SQEP-12 and by discussions with the TVA system engineer cases the system engineers had completed preparation of one page summaries for each ECN, covering a description of their review effort and their finding These summaries were very useful to the NRC tea The NRC team noted that the DBVP project review had not found any changes Mostwith DBVPa substantial technical findings involved missing deficiency in the mechanical systems are The DBVP project information, such as test results or seismic calculation issues Problem Identification Requests (PIRs) for such items, which in turn may result in Significant Condition Reports (SCRs).
Typical findings included:
(1) DBVP Finding Requiring Test Valve Replacement During issue of Drawing 47W5150-17, a test connection valve that is part of containment isolation piping was specified as ASME Section III, Class 3, instead of the required specification of ASME Section III, Class The cause was a drafting error. Corrective action included replacement of the valve before entering Mode 4. This DBVP finding is reported in SCR SQNMEB866 '
(2) DBVP Finding Concerning TVA Quality Class Requirements Filter pressure regulators for supply air to the combustible gas control hydrogen analyzers per ECN 5444 do not meet the requirements of TVA Class C, are not designated Seismic Category I and do not meet QA requirements (SCR SQNMEB8667).
(3) DBVP Findings Requiring Additional Testing During an evaluation of a diesel generator lube oil modification, ECN L5451, it was found that although testing was performed to verify equip-ment added per the ECN functioned correctly, sufficient testing was not done to verify that the modification would perform its desired functions at all condition PIR SQNMEB8665 was issued and remarked that formal testing at all conditions needs to be performed and documented in order to supplement and verify the vendor provided package design. A similar finding identifying the need for further testing due to the addition of a sample cooling loop to the post accident sampling system was identified in PIR SQNMEB867 Another finding concerning lack of post-modification testing of dampers per ECN L5422 and Work Plan 9341 was identified by the DBVP (SCR SQNMEB8645).
In another case, DBVP identified the lack of vibrational testing of new
fans replaced for environmental qualification reasons while the pre-operational test scoping documents for the HVAC systems require
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Attachment A - Inspecticn Activitics and Observations observation of the fans to assure that they operate without excessive vibration (PIR SQNMEB8687).
(4) DBVP Finding Related to Drawing Errors Balancing dampers and filters were not shown on Drawing 47 W866-9. This was discovered in the SQEP-19 walkdown package. Valve 2-59-522 in the demineralized water system, shown as a gate valve on drawings and bills of material, is a globe valve in the plan Valve 2-59-529, shown as a ball valve, is a globe valve in the plan In another case ECN5573 was can-celled, but the "As-designed" drawings were not revised back to the original conditio .2 Engineering Assurance Review of ECNs The TVA Engineering Assurance oversight team is conducting an independent review by sampling DBVP activities. This has resulted in action items being issued by the mechanical and nuclear engineering. discipline of EA. The NRC team noted that neither EA mechanical nor nuclear had found a substantial technical deficiency in their review The mechanical discipline of EA has issued approximately 44 action items (AIs).
The AI is structured to state a Potential Concern / Question and requires a corrective action response from DBVP. The inspection team reviewed the Als and found them to be mostly administrative in nature, without any AI reporting a significant concern for the technical adequacy of a change. The Als dealt primarily with the need for clarification of scope of the DBVP effort, the need for thoroughness and completeness of review, guidance in carrying out the project evaluations and identification of administrative deficiencies. The EA oversight review is contributing to the overall quality of the DBVP produc This is illustrated in the action taken in response to AI M Action Item M6 expressed concern that, although the project will include checking the design review attributes of Attachment 2 to SQEP-12, the project will not review drawing and calculations to assure they have been addressed adequately, e.g., they will check that a calculation is complete and addresses the change, but not that it is correc The corrective action by project is to require that documents, including calculations, be reviewed for adequacy by assuring that the change has been addressed. This included assuring that the appropriate design considerations, inputs and interfaces are evident; including resulting effects on other systems, components, et This response falls short
of a full check of the document for adequacy, however it shows that EA favors a more thorough evaluation of ECN .3 Team Review of ECNs During the inspection period, the NRC team examined ECNs and work packages for several systems, including; essential cooling water, component cooling water, diesel fuel oil, diesel starting air, control air, ventilation, air condition-ing, residual heat removal, and chemical and volume contro The team reviewed seven ECNs and other documentation for the component cooling water system (CCS). CCS heat loads and flow requirements are specified in the A-3
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Attrchm:nt A - Insp:ction Activities and Observations These requirements are supported by a CCS Design Criteria, SQN-DC-V-13.9.9.This load list references other correspondence CCS load list, 844 860402 00 The inspection team did and calculations as the basis for the listed loads.
not review the referenced calculations and correspondence during this inspection.
The NRC team was informed that component cooling water heat exchangers B and C are approximately 13% plugged. ECNs L6429 and L6474 have been issued However, to is TVA replace these components with plate-type heat exchangers.The team reviewed the planning to postpone replacement until after restart. basis for postp 860211 00 The NRC did not identify any concerns relating to the basis of this decision. This calculation provides required essential raw cooling water (ERCW) flow rates for the various plant operatingThe modes overteam inspection a range was of 5 to 20% plugged tubes in the existing heat844 exchanger .
told that surveilla and assure compliance with the flows required by Two ECNs were issued to revise The team reviewed six ECNs for System 67 (ERCW).The latter ECN is considered to be the system flow rates, ECNs L5415 and L652 the basis for restar The Unreviewed Safety Question Determination (USQD) for ECN L6520 states that calculations contained in 844 850822 015 have been made to justify the minimum flows and form the basis for SI 566, which is used for ERCW flow verificatio is a summary of ERCW flows that reference other memo-Document 844 850822 015 The inspection team did not review these additional randa and calculation references during this period of inspectio The two largest, safety-related ERCW flows are to the componentThe teamcooling water noted that (CCS) and containment spray (CSS) system heat exchanger the ERCW flow rates authorized by ECN L6520 are significantly l rates stated in the FSA heat loads do form the basis for ECNs authorizing CCS heat exchanger replace-ment ment and changes to essential This rawreplacement water cooling system is not planned until after the heat exchangers are replaced.Since the plant will be operating before restar prior to heat exchanger replacement, the FSAR should be appropriately rev during the next scheduled annual update (Observation 2.4).
The inspection team noted that ECNs L5497 and L5937 add unions to the relief These ECNs valve lines on the CCS side of the spent fuel pit heat exchangers.The purpos The relief specify the use of threaded fittings. tate removal of the relief valve valves are in a TVA Class C piping syste SQN-DC-V-3.0, a TVA Class C system must meet the requirements of the Section III, Class The team reviewed the Code and found that Section NC3671.3 permits threaded fitting ECN L5064 replaced existing containment isolation valves in the componentThe chan cooling water system with check valves having soft seats.to red seat The change involves replacement of metallic seats with non-metallic The EA seats that will be subject to post-LOCA radiation dose of 108 Rad A-4
Attachment A - Insp;cticn Activitics and Observations review of the ECN identified the need for documentation qualifying the soft seats for this level of radiation (Action Item M32).
The team noted that there have been several ECNs to replace portions of ERCW carbon steel piping with stainless steel piping. This is being done due to corrosion and deposit buildup in the piping that can reduce flow below minimum requirements. Piping is being replaced on an as-needed basis. Control of the flow effects of piping replacement is accomplished by annual surveillance test SI 566. This test measures and evaluates ERCW flow through all components cooled by ERCW and results are used to evaluate where and when corrosion is limiting flo No observations were identified relating to these ECNs.
The inspection team reviewed several ECNs modifying the diesel generators. ECN 5417 adds dryers to the starting air system. This is an improvement recom-mended by most vendors. ECN 5451 modified the diesel engine lube oil system to provide continuous lubrication of the turbocharger. The modification was made at the recommendation of the diesel generator vendor to correct a deficiency that could result in a high failure rate of the turbocharger bearing. The retrofit was essentially a design and equipment provided by the vendor. The work plans implementing the plan were reviewed. Exceptions were noted and reported by the DBVP project. PIRs were issued to:
(1) Check lube oil performance per vendor's maintenance instruction MI 964 (2) Calculate the effect of increased heat loads on the diesel generator roo (3) Correct documentation discrepancie The inspection team also reviewed the following ECNs which modified containment isolation motor operated valves for reasons primarily associated with electri-cal qualificatio ECN6667 and ECN6697. These ECNs required removal of clutch tripper finger This results in no change in the automatic function of the valves. The modi-fied valve requires two persons to manually open or close the valve as the second person is required to maintain the valve declutched from the moto ECN6665. This ECN removed existing motor brakes and regeared the operator for slower speed. Speeds are to ue maintained at the present maximum stroke times allowed by Technical Specifications. The brakes, which were installed to prevent high speed closure damage, were unable to be environmentally qualifie The inspection team noted that the work plans for these ECNs correctly identi-fied the need to functionally test the modification using the appropriate SQN surveillance instructio The inspection team also reviewed several ECNs for the Chemical and Volume Control System (CVCS). This review identified one ECN of significance with respect to functionalit ECN 6024 authorized the change out of charging pump impellers with impellers that produce a higher hea The replacement impellers are identical to those supplied for Watts Ba The basis for this change is anticipated wear and interchangeability between plants. The ECN is unimple-mented, but remains an open authorization to replace impellers when and if it is determined to be necessar TVA did consider the impact of increased horsepower when ordering the new impellers from the vendor. The increase is within the 1.15 service factor of the motor. Diesel loading calculations were based on the motor being operated at the 1.15 service facto A-5
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Attrchment A - Insprction Activities and Obs:rvations Reactor Coolant System Design Criteria, SQN-DC-V-27.4, states that the plant has a design and operating capability with less than all four reactor coolant EA correctly observed that the reactor coolant system design system loops. criteria should be revised to be consistent with Technical specification limiting condition for operation 3.4.1.1, which requires that all four loops be available for startup*and power operation. The DBVP project responded that the inconsistency will be allowed to remain because the plant was designed for two-loop operation. The teamIn believes that plant modification may be required addition, questions remain regarding the to allow two-loop operatio ability of the plant to meet coastdown flow requirements when tripped from three-loop operation. Therefore, the design criteria should be revised to reflect present day capability and license constraints (Observation No. 2.5).
was performed to determine a single Calculation SQN-63-0053 (EMP-SMJ-022886)
set of design conditions for piping from the refueling water storage tank that is shared by the residual heat removal, containment spray system, chemical The calculation and incorrectly volume control system and safety injection syste used the vendor's recommended runout limit rather than the flow based on the intersection of the system resistance curve and the pump head curve which could produce flow rate greater than 4500 gpm (Observation No. 2.6.).
During the course of its reviews, the team noted several inconsistencies in system flow diagrams:
The team noted that (1) Drawing 47W810-1, residual heat removal flow diagra the change in design condition for valve FCV 74-2 is improperly flagge It should have the higher rating of the reactor coolant system to which it is attached and forms the high pressure boundary isolation valv (2) Drawing 47W560-1, Waste Disposal System. The team noted that section J5-J5 does not agree with the plan view, the piping depicted by the plan view and section MS-M5 apparently does not exist and there are conflicting references to section MS-M These findings are the basis for Observation The team reviewed many ECNs, the results of TheDBVP evaluations, resulting and the EA observations are given oversight in the mechanical systems are below. The team also noted that the DBVP effort will culminate No changesin resulting the near in a future in final System Evaluation Reports (SYSTERs).
substantial technical deficiency were identified in the mechanical systems are .4 Observations Observation No. 2.4 - Design Criteria vs FSAR Component Cooling System Heat Loads The CCS design criteria cor.tains tabulations of heat loads that are being used to (a) revise the essential raw cooling water flow diagram per ECN L6520, (b)
establish revised test evaluation criteria for SI 566 (essential raw cooling water), and (c) determine acceptability of restart with partially plugged CCS heat exchangers, allowing deferral of heat exchanger replacement planned per ECNs L6429 and L647 The heat loads in the design criteria are considerably A-6
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Atttchment A - Insp2ction Activitics and Obs2rvations less than those listed in FSAR Chapter 9.2 for modes such as loss of coolant accident recirculation and hot shutdown. The inspection team was informed that TVA plans to revise the FSAR when new CCS heat exchangers are installed per ECN L6429 and L6474 after restart. The team considers that the FSAR should be revised prior to heat exchanger replacement in order to reflect restart with lower minimum essential raw cooling water flow rates, revision to SI 566 and partially plugged CCS heat exchangers. ECN L6520 revises and reduces essential raw cooling water flow to the containment spray heat exchangers to less than the flows shown in the FSAR. This section of the FSAR should also be revise Observation No. 2.5 - Reactor Coolant System Design Criteria vs. Technical Specification (Four Loop Operation)
During a review of EA action items, the NRC team noted that item N-29 identi-fied an inconsistency between the plant Design Criteria SQN-DC-V-27.4 and the Technical Specifications. The design criteria indicates that the plant can be operated with a minimum of two loops. The Technical Specification states that all four loops are required for startup and operation. The project responded that the inconsistency should be allowed to remain because the Technical Specifications will govern plant operation and that the plant was designed for inactive loop operation. Thus, the plant would not need any modification to be operated with less than four loops. EA accepted the reasoning of the project and closed the Action Item without any change to the Design Criteri The team reviewed the EA Action Item and concluded that the Technical Specifi-cation limitation was based on the inability of plant to meet the coastdown flow requirements for proper core cooling (maintain the departure from nucleate boiling ratio greater than 1.3) when tripped from three loop operatio Therefore, the plant is not designed for less than four loop operation. The i Design Criteria gives the false impression that the plant can be operated with less than four loop EA has agreed to reopen the Action Item N-29 and requested that the project modify the Design Criteri Observation No. 2.6 - Flow Rate Assumption used in Calculation During the team's review of ECNs related to the residual heat removal system it was noted that ECN-L6673 requires that a variety of design conditions shown on i flow diagrams for the same section of piping be corrected to a single set of conditions. The particular piping is the suction manifold for the residual heat removal, containment spray, chemical and volume control, and safety injection system pumps from the refueling water storage tank and therefore appears on several flow diagrams. SCR SQN-MEB 8604 states that the design conditions (temperature and pressure) varied between the various system flow diagrams. For example, the chemical and volume control system flow diagram lists the design conditions to be 100* F and 30 psi, where as the residual heat removal flow diagram states the design conditions to 100 F and 100 psi.
I Calculation SQN-63-0053 (EMP-SMJ-022866) was performed to determine a single set of design condition The calculation used a flowrate of 4500 gpm, which is the residual heat removal pump recommended runout flow limit shown on the vendor pump head curv This flow may occur when this piping is used to return refueling water to the refueling water storage tank. When operated in this mode, the piping is valved A-7
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Attachment A - Insptcticn Activities and Observations The flow in a system is to the discharge of the residual heat removal pum the value at which the system resistance curve intersects the pump head curv The calculation did not contain a system resistance curve or other justifica- The tion of why the flow of 4500 gpm should be the basis for the calculatio team noted that in the event that the actual runout based on the system resist-i ance curve exceeds 4500 gpm, the calculated design condition may be non-con-
' servative, in that a higher flow would involve a greater pressure drop in the piping, resulting in an increase in design condition pressur Observation No. 2.7 - Drawing Control i
Two drawings were observed to have errors during the course of the team's
! inspection:
(1) As part of an effort to inspect ECN-L6570 which is intended to correct an inconsistency in design conditions, the flow diagram for the residual heat removal system (47W810-1) was reviewed. Valve PCV 74-2 is a point of change for the design conditions between the reactor coolant system and residual heat removal system. Since the valve provides isolation between the two systems during normal high pressure operation of the reactor coolant system, the valve needs to be included as part of the reactor coolant system. The drawing shows the location for a change in design conditions such that the valve is part of the low pressure residual heat removal system. This valve is an isolation valve and is required to have
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- the design conditions of the reactor coolant system in order to withstand the higher pressures and temperature of the reactor coolant syste i (2) As part of an effort to inspect ECN-L6784, which is intended to correct identified inconsistencies in class break designations, one of the waste The team found disposal system piping drawings (47W560-5) was reviewe Further, the team that Section J5-J5 did not agree with the plan vie was told that the piping arrangement depicted in both the plan view and j Section MS-MS did not exist. Apparently, when the piping wasThe rerouted team also
! during construction all affected sections were not revised.
i noted that the drawing has conflicting references to two sections MS-M5.
3.0 MECHANICAL COMPONENTS i
In the mechanical components discipline (part of TVA's Civil Engineering l Branch) the team reviewed portions of ECNs 5724, 5746, 5750, 6454, 6487, 6499
,
and 6556 to assess the quality of the ECN review which TVA's Design Baseline l and Verification Project (DBVP) staff and Engineering Assurance oversight i
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groups were conducting in the Civil / Structural area at the time of the j inspection.
i The ECNs which the team selected for review were within the scope of the DBVP
' as defined by TVA calculation SQN-0SG7-048, Identification of Systems Required for Sequoyah Restart, and SQEP-11, Procedure for Identifying and Assembling Change Documentation. These ECNs also required partial or full implementation prior to restart and had been reviewed by the DBVP Civil / Structural group in i
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Attachment A - Inspiction Activities and Obs:rvations accordance with the review criteria detailed in SQEP-12, Procedure for Evaluat-ing Engineering Change Notice and Field Change Notice Document .1 Overview of DBVP Project Review The DBVP project evaluated ECNs within the boundary of systems or portions of systems required to mitigate FSAR Chapter 15 Design Basis Accidents (D8A) in accordance with SQEP-12, Procedure for Evaluating Engineering Change Notice and Field Change Notice Document ECNs scheduled for partial or full implementation prior to restart of Sequoyah Nuclear Plant were evaluated for design changes which affected equipment,
- rigorously analyzed and field routed (alternately analyzed) piping, pipe In supports, civil / structural items, pipe rupture, and vibratory respons the civil / structural discipline the DBVP Project reviewed approximately 700 ECNs, and grouped 342 deficiencies into seven generic Problem Identification Reports (PIRs). These are summarized below, including two examples of ECNs for each PI (1) PIR CEB 8637, identified equipment in 41 ECNs that was not seismically qualified as require * ECN L2181 (System 30A, Ventilation System)
This ECN added field fabricated exhaust grilles with adjustable dampers at each outlet of the purge air exhaust system - upper and lowerThis compartments change is of the reactor building to exhaust proper air quantitie within the boundaries of the System Walkdown Boundary Identification Drawings (SWBIDs) that have been marked to identify portions of the systems required to mitigate Design Basis Accidents as described in FSAR Chapter 15. Item 6.1 of SQEP-12, Attachment 2A checklist indicates seismic qualification documentation for this change has not been ad-dresse * ECN L6249 (System 01, Main Steam)
The seal leak off lines (1/2-inch schedule 80 carbon steel pipe)Theon ECN steam supply valves FCV-1-17 and FCV-1-18 were leaking excessivel threaded the leakoff line and installed a pipe cap or a valve with a pipe plug to prevent a leakage path out of the leakoff line,Thethuschecklist causing the remaining packing rings to carry steam sealing loa indicates the " Modification to the valves was not addressed by CEB" (Component Qualification) and a PIR was written to identify this deficienc (2) PIR No. 8638, identified design changes that were not documented in calculations and/or drawings in 31 ECN * ECN L2777 (System 68, Reactor Coolant)
This system
'
This ECN adds the Reactor Vessel Head Vent System For unit 2.
f is designed to remove gases from the reactor vessel head and is remotely A-9
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Att chment A - Insp;cticn Activities and Obsarvations operated from the control roo Item 6.2c of SQEP-12, Attachment 2A checklist indicates this change was incorporated into the piping analysis and isometric drawing (47K465-52 isometric, 478465-72 thru 74 load tables), however calculation package N2-13-7R does not reference this EC Items 6.4c and 6.4d of the checklist indicate that conduit support vari-ances for a typical support shown on drawing 47A056-3A were documented for attachment to cable tray supports, however, the calculations were not changed to document the increased loading for the cable tray support * ECN L5204 (System 67, ERCW)
This ECN was written to correct inconsistencies for overlapped regions of the auxiliary feedwater and ERCW piping systems in regard to piping analysis documentation. The analysis in overlapping regions is performed using a portion of each adjoining piping system. Upon completion of the analyses, the results were screened and the lesser of the two expunged for the overlapped regions. Item 6.2c of SQEP-12 Attachment 2A checklist indicates this change was evaluated for the existing analyses and drawing changes were made, however, it was not addressed in the calculation package. Therefore, SQEP-12 Attachment 2 iteni 6. A specifies "A PIR must be written to identify this deficiency."
(3) PIR No. 8639, identified missing calculations in 98 ECN * ECN L5274 (System 31A, Control Bldg. HVAC)
Due to excessive leakage from isolation dampers FCO-31A-105A, B, and D and ,
FC0-31A - 106A, B, and D, this ECN was written to remove all of the dampers and replace them with pneumatic motor operated butterfly valve * Ductwork and supports were modified to accommodate the change Items 6.3A and 6.3B of the SQEP-12 Attachment 2A checklist indicate that no calculations were found addressing qualification of support variances 47A052-18-A1, A2, A3 and A4 per FCR 384 for this EC Therefore, SQEP-12 Attachment 2 items 6A, B specify "A PIR will be written" to identify this deficiency.
i
- ECN L5000 (System 26, Fire Protection)
i l
This ECN installs a 1.5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> fire barrier from elevation 701 to elevation 713 that will enclose exposed conduit exiting from the top of the ERCW l
! junction box in the auxiliary building. The barrier will be a steel enclosure coated with pyroc. ate. The USQD states the barrier will be
i seismically qualified. Items 6.4C, D, and E of the SQEP-12 attachment 2A checklist indicate that drawing 48N1342 incorporated this change but that l
no calculations were found to document the seismic qualification. There-fore, SQEP-12 Attachment 2 items 6.A 8, and E specify "A PIR will be
i written" to identify this deficienc (4) PIR No. 8657, identified Field Change Requests (FCRs) with Civil / Structural involvement that were not closed by DNE in 13 ECN t i
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Attachment A - Insp::cticn Activitics and Obs:;rvattens
This ECN was written to install a 1-hr. fire barrier wall in the auxiliary building on elevation 714.0' from the floor to the ceiling. The wall location is along the A-8 line from the Q-Line to a point 20 feet east of the Q-line. However, interference problems associated with the installation must also be resolved. The comments on SQEP-12 Attachment 283725, of the checklist notes "The following FCRs have not been closed by DNE:
3769, 3917, 4182, 4488 and 4036." .Therefore, SQEP-12 attachment 2 item 6. A specifies "A PIR will be issued" to address this deficienc ECN L6561 (System 3A, Feedwater)
This ECN was written to modify the East and West valve vault's exterior doors and louvers to provide a flow area consistent with the calculated flow rate provided in the calculation titled " Flooding Levels in the East and West Valve Vaults" (RIMS B45 851116 235).
The comments on SQEP-12 Attachment 28 of the checklist notes "The follow-ing FCRs have not been closed by DNE: 4257, 4257R1, 4257R2, 4272 and 4162." As noted above, a PIR will be issue (5) PIR No. 8659, identified inadequate technical evaluations in 6 ECN * ECN L6263 (System 3A, Main and Auxiliary Feedwater System)
This ECN redesigns and replaces (2) pipe support hangers located on the feedwater line going into the steam generator. Item 6.3a of SQEP-12, Attachment 2A checklist indicates seismic qualification documentation for i this change was not addressed due to discrepancies between as-designed and as-constructed drawings. Therefore SQEP-12 Attachment 2 item 6.a speci-fies "A PIR will be written" to identify this deficienc * ECN 2129 (System 31, Air-Conditioning)
This ECN adds block valves, test vents or drains as required to provide air test capability for certain containment isolation valves. The effect on piping analyses for many of the valves added under ECN 2129, (written for Unit 2), were addressed under ECN 5030 and ECN 2971 (IE Bulletin 79-14 discrepancies) which are for unit 1. These valves were incorrectly added to the flow diagrams under ECN 503 Therefore SQEP-12 Attachment 2 item 6.C was addressed by "A PIR will be written" to identify this deficienc (6) PIR No. 8665, identified missing field-routed (alternately analyzed)
documentation in 86 ECN * ECN 5526 (System 67, essential raw cooling water System).
This ECN rerouted ERCW control valve leak off drain line RME from floor drain to equipment drains. Item 6.5.1 (d) of SQEP-12, Attachment 2C checklist indicates seismic qualification of alternately analysed piping was not addressed for the affected alternate problems N2-67-A-034A, -332 A-11
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Attachment A - Insp:ction Activitics and Observations Therefore, SQEP-12 Attachment 2 item 6.a specifies " A PIR will be writ- i ten" to identify this deficienc ,l
- ECN 5371 (System 32, Control Air System)
This ECN replaces emergency gas treatment system isolation dampers with butterfly valves to conform to ANSI N-509 for Class 1 leakage requFements (memo J. A. Raulston to R. W. Cantrell 12/17/80 (NEB 801217274)). ; Item 6.3 (a) of SQEP-12, Attachment 2A checklist indicates seismic qualification documentation for this change has not been addressed due to calculdtion not being found for FCR 501, variance to drawing 47A054-3. Therefore, SQEP-12 Attachment 2 item 6.1 specifies "A PIR will be written" to identify this deficiency.
(7) PIR No. 8666, identified missing pipe rupture evaluations in 67 ECNs.
- ECN L5333 (System 3B, Auxiliary Feedwater)
This ECN was written to realign the A.C. and D.C. power supply on levsl instrumentation loops for the turbine driven auxiliary feedwater pump to be independent of the A.C. and D.C. power on level instrumentation loops for the motor driven auxiliary feedwater pumps A and B. The ECN includes FCRs which revise cable and conduit routing. Item 1.5G of the SQEP-12 Attachment 2D checklist indicates the relocation / addition of safety ,
related instrument sensing lines, electrical conduit, electrical ,
components or equipment was not addressed by a pipe rupture evaluation to .
document if the conduit changes resulted in additional targets (ccuments on checklist Attachment 2B-PR). Therefore, SQEP-12 Attachment 2 item specifies "A PIR will be written" to identify this deficienc * ECN L6300 (System 26, Fire Protection)
This ECN was written to add / modify sprinklers, temperature alarms, drains, supports, piping, concrete and other associated components to the system in order to comply with various interaction items identified by Appendix R (10 CFR 50) review Item 1.5C of SQEP-12 Attachment 20 checklist indicates the reroute or addition of any fluid piping greater than 1-inch nominal diameter was not addressed by a pipe rupture evaluation to documerit effects for any surrounding essential electrical equipment that may become target Therefore, item 6.j of SQEP-12 Attachment 2 specifies "A PIR will be written" to identify this deficienc ,
In the Civil / Structural discipline the DBVP review of ECNs resulted in the creation of a punch list with approximately 2800 items to be resolved by Sequoyah engineering project and staff personne The DBVP project accessed approximately 10,000 civil / structural calculaticus to confirm the existence of each calculation and to confirm that the calculation addressed the design changes which the ECN implemented. Although a detailed technical review of calculations was beyond the scope of Civil /Structurer Project's review, the Project did identify six technically inadequate calculations (PIR No. 8659).
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Attrchment A - Insp;ction Activities and Obssrvstions
"' 3.2' Overview of Engineering Assurance Oversight TVA Civil / Structural Engineering Assurance (EA) reviewed twenty of the 700 ECNs ,
which DBVP project reviewed and prepared 20 action items to identify deficiencies Civil / Structural not previously identified by the Civil / Structural disciplin EA identified four generic concerns regarding the DBVP project review:
,x (1) Failure to identify and/or evaluate some Field Change Requests (FCRs).
(2) Failure to identify some discrepancies between design drawings and calculation P (3) Some incomplete and/or incorrect reviews were performed by DBVP We'ojec .s s (4) Improper identification of some ECNs as in or out of the DBVP scop As of December 1, 1986, DBVP project had resolved 34 of 52 EA action items identified during the course of EA's DBVP overview in the civil / structural are Ci,vil/ Structural EA also reviewed the technical adequacy of the calculations for the sample of 20 ECNs, as required by Review Plan No. 5100, and wrote action items to document three identified deficiencie The team concluded that the TVA DBVP Project and Engineering Assurance groups properly implemented the programmatic criteria detailed in S TVA's review of the ECNs scheduled for partial or complete implementation prior to restart of Sequoyah Nuclear Plant in the Civil / Structural disciplin Although the TVA Civil / Structural Engineering Assurance group performed a technical review of the calculations which supported a sample of ECNs, the team believes that the small sample size limits the additional assurance which can
- De obtained by the evaluation of this aspect.
I
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,-<
3. 3 NRC Review of ECNs P
The team identified five observations in addition to the items which the TVA
- Civil / Structural Project and Engineering Assurance groups identified for the ECNs reviewed (Observations Nos. 3.5, 3.6, 3.7, 3.8, 3.9).
The team noted that in two instances (Observation No. 3.5, Item 1 and Observa-tion No. 3.8, Item 1), TVA used mirror image piping isometric drawings to analyze safety-related piping. One of the drawings appears to be a Unit 1 drawing which was used without apparent control for the analyses of Unit 2 l
' piping. Each of these drawings resides in a TVA alternate analysis calculation package. The team is concerned that some piping isometrics prepared to analyze field-routed piping and supports may not be adequately controlle In another instance (Observation No. 3.8, Items 3 and 4) TVA did not properly perform the seismic qualification TVAofbased the tubing and clamps the calculation which which support qualified a the replacement solenoid valve.
f clamps on an uncontrolled and incomplete field sketch of the installed valve l
' configuration. TVA was also unable to verify that the tubing supporting the i
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Attichment A - Insp:ction Activitics and Observations solenoid valve had been seismically qualified. The team is concerned that the seismic qualification documents for some installed components may be incorrect and incomplet The team also reviewed TVA's corrective No observations were actions to reso qualification programs for Sequoyah Nuclear Plan identified during this revie .4 Review of TVA's Corrective Actions In the mechanical components area the team reviewed TVA's responses to the nine deficiencies detailed in NRC inspection report 86-27Seven and the four observations deficiencies and two detailed in NRC inspection reports 86-38 and 86-4 observations were closed (Deficiencies D3.1-1, D3.2-2, D3.2-3, D3.2-4, D3.3-2, D3.3-3, and D3.3-5 and Observations No. 3.1 and No. 3.3), one deficiency remains pending NRC review of TVA's post-restart program to address this issue open (Deficiency D3.3-1), and one observation For inspection remains purposes, open pending the team receipt o revised TVA response (Observation No. 3.4).
closed a deficiency and an observation which have been transferred to the NRC Office of Nuclear Reactor Regulation (NRR) for review (Deficiency 03.3-4 and Observation No. 3.2).
Team review of TVA's responses to the deficiencies and observations documented in NRC inspection reports 86-27, 86-38 and 86-45 is detailed in Section The team also reviewed TVA's corrective action program to address deficiencies in the lateral support capacity of some Category 1(L) pipe support designs at On November 12, 1985, TVA prepared Watts Bar Nuclear Sequoyah Nuclear Plan Plant Significant Condition Report (SCR) WBNCEB8537 to indicate that the pipe support details shown on the typical series 47.A058 a A TVA calculation entitled deadweight and vertical seismic loads onl SCRWBNCEB8537 Evaluation Report, dated August 29, 1986, TVA summarizes evaluated TVA's program to address this deficiency at Watts Bar Nuclear Plant. series pipe supp all 47A054, -55, -57, -58, and -59 analysis or test, and concluded that all installed position retention 47A057 and -55 (excluding the diesel generator bui bi 7)1 pipe stalled support position typicals were retention adequate as originally designed, and that. N 1 4I pipe supports were designed 47A054, -58 and -59 series Category 1(L) U p) satisfactorily and in a and Design of Piping Supports and Supplemental Steel in Category I17, Structure to TVA piovided a final 10 CFR 50.55(e) report to the NRC on SeptemberTVA prepa close out this deficiency. On December 24, 1985, initiate a stuct of the Category 1(L) position retention pipe supportsTVA will issu installed at the Sequoyah Nuclear Plan summarizes the results of this study on December 15, 198 The team finally reviewed TVA's corrective action program to address a TVA poten-tial deficiency in TVA's seismic analysis of safety-related piping.March 17,
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prepared SCRs WBNCE88553 and 8631 for Watts Bar Nuclear Plant on
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1986, to indicate that piping seismic analyses did no hertz zero period acceleration (ZPA) loads.
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Attachment A - Insp:cticn Activities and Obssrvations Watts Bar Nuclear Plant on November 12-14, 1986, that about five percent of the pipe supports at Watts Bar Nuclear Plant would require some rework as a result of TVA's program to address this deficiency. TVA also provided the NRC team with an informal memorandum dated November 14, 1966 which summarized the results of similar studies conducted for seismically analyzed piping at Sequoyah Nuclear Plant, and which concluded that while some support loads increased, the supports were adequate as designe On December 3, 1986, TVA provided the inspection team with a preliminary copy of a TVA report entitled Final Review of ZPA Effects on Sequoyah Nuclear Plant Piping, which summarizes the studies conducted by TVA CEB, Impell and Bechtel to verify the design adequacy of the seismically analyzed piping at Sequoyah Nuclear Plant. The report concludes that no hardware modifications are re-quired for seismically qualified piping or pipe supports at Sequoyah Nuclear Plant. Moreover, TVA will revise the Rigorous Analysis Handbook to instruct piping analysts to incorporate ZPA loads in all future piping analysi .5 Observations Observation No. 3.5 - Vent Condenser Heat Exchanger Flange Installations ECN No. L-6499, Rev.1, dated January 14, 1986, installed flanges in the component cooling water 2 inch inlet and outlet lines and 3/4 inch relief line of the vent condenser heat exchanger for Sequoyah Unit 2 boric acid evaporator package "B". TVA performed a rigorous TPIPE analysis of the affected TVA Class C piping, and incorporated this rigorous analysis into TVA alternate piping analysis calculation No. N2-70-A-301A, Rev. O, dated October 1, 198 The team noted that:
(1) The piping stress isometric shown on page 24C of the piping analysis is the mirror image of the referenced piping isometric shown in Detail F13 of TVA drawing 47W464-13, Rev. 2 (2) Because of a TPIPE coding error, the pipe stresses and pipe support loads tabulated on pages 24D and 24E of the piping analysis do not include the effects of the 200 degree F thermal mod i Observation N .6 - Primary Containment Leak Rate Test Lines
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! ECN No. L-5750, dated October 7, 1982, as revised by FCR-1210, dated December L 9,1982, welded two 3/4 inch test lines with manually locked closed containment isolation valves to the outboard plate head of containment penetration No. X-87 to enable integrated leak rate testing of primary containment. The test lines penetrate the inboard plate head with approximately 0.04 inches clearanc The team noted that TVA calculation No. N2-52-1R, dated October 28, 1982, which qualifies the test lines is unconservative, because the calculation does not
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consider the frequency response of the inboard valve with respect to the test line support at the outer plate. Rather, TVA considered this subsystem an-chored at the inner plate. A calculation performed to address this vibratory A-15
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Attachment A - InspIction Activities and Obssrvations mode will yield a decrease in the fundamental frequency of the test line and an increase in the maximum pipe stres Observation N .7 - TVA - Supplied Limit Switch Brackets ECN No. L-6556, Rev.1, dated January 17, 1986, replaced existing limit switch-es on valves installed in the ventilation, safety injection, waste disposal, primary water and reactor coolant systems with limit switches qualified to the environmental requirements of 10 CFR 50.4 TVA drawings 47A348-260, Rev. 2, and 47A348-287, Rev. O, detail TVA-supplied limit switch mounting brackets to be used when a limit switch cannot be mounted to a vendor-supplied valve mounting plate because of interference. The team noted that:
(1) TVA drawing 47A348-260 does not specify the bolts which connect the TVA-supplied bracket to the valve mounting plat (2) TVA has not seismically qualified the brackets shown on the drawings for use as intermediate limit switch support Observation N .8 - Solenoid Valve Mounting Seismic Qualification
- ECN No. L-6487, Rev.1, dated January 14, 1986, replaced solenoid valves in the chemical and volume control, safety injection, reactor coolant and waste disposal systems with solenoid valves qualified to the environmental require-ments of NUREG-058 The team noted that
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(1) Piping Isometric 0-WD-215, Rev. 1, which shows TVA Class B containment isolation valve 2-FCV-77-20, and which is a part of TVA alternate analysis calculation No. N2-77A-314A, dated September 16, 1986, details the mirror image of the installea Unit 2 piping configuratio (2) The approximate 6' 9" span between field routed supports for the 1" diameter pipe which supports 70 lb. valve 2-FCV-77-20 exceeds the maximum 2' span specified on TVA drawing 47A053-158. TVA indicated to the team that review of field routed support designs for large concentrated in-line weights is a post-restart activity, as documented in Sequoyah Alternate Analysis Review Program Description SQN-AA-001, dated July 7, 198 The team noted during review of the Sequoyah Nuclear Performance Plan Section 5.2.2 (DBVP Phase II (Post-Restart), that TVA stated that "The need to provide support for large concentrated weights is apparent and it is unlikely that many deficiencies will be foun The largest of the concentrated weights will be evaluated with the MOVs and pneumatic operat-ed valves (POVs) prior to restart."
The team noted that contrary to this statement, TVA did not plan to analyze the concentrated weight effect of 2-FCV-77-20, a POV, prior to restar A-16
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Attachment A - Inspection Activities End Observations s
(3) TVA tubing support calculation No. 47A054-33A-A174, dated August 28, 1986, addressed a variance in the spans of the 3/8" copper tubing which support solenoid valve 1-FCV-77-20. The calculation was prepared to qualify the clamps which restrained the tubing, but does not consider the additional weight of the condulet and 1" conduit attached to the solenoid valve, apparently due to the use of an incomplete and uncontrolled field sketc (4) TVA could not retrieve the documentation to confirm that the 3/8" copper tubing detailed in item (3) was seismically qualifie (5) Sequoyah FSAR Section 3.9.2.6, Field Run Piping, limits the application of the field run piping to stainless steel, carbon steel and aluminum for TVA Class B, C, D, G, K and M process piping and instrument lines, and does not address the use of copper tubin Observation N .9 - High Energy Line Break Designation ECN No. L-5724, Rev. 2, dated July 9,1984, revised identical support designs in the Sequoyah Units 1 and 2 chemical and volume control system to reduce vibration problems associated with an undiagnosed vibratory mod The team noted that TVA drawing 47K432-51, Rev. 4 designates the 2" diameter line from Steel Containment Vessel penetration X-15 to the letdown heat ex-changer in Sequoyah Unit 1 as a high energy line, while TVA drawing 47K432-56, Rev. 3 designates the corresponding Unit 2 piping segment as a low energy lin TVA has indicated that the Unit 1 piping is also a low energy line and there-fore the drawing is incorrec .
- 4.0 NUCLEAR. SYSTEMS The inspection activities conducted in the nuclear systems. discipline are summarized in the mechanical systems and instrumentation and control sections of this repor .0 ELECTRICAL POWER In the electrical power discipline, the team reviewed TVA's ECN process and implementation, evaluated the findings which resulted from the DBVP project's review of ECNs, and evaluated the action items which resulted from EA's over-view of DBVP project activities. The team also evaluated TVA's responses to the findings documented in NRC inspection reports 86-27, 86-38, and 86-45, and Gilbert / Commonwealth's review report dated March 3, 198 The team specifically reviewed:
(1) TVA's design process for 16 ECN (2) The test evaluation results for three test packages reviewed pursuant to DBVP procedure SQEP-1 A-17
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Attrchment A - Insp';ction Activities and Observaticns (3) Problem Idenfication Reports and other findings identified by the DBVP projec (4) Action Items drafted by E The team identified two observations relating to a design error and an inade-quate ECN review pursuant to DBVP SQEP-12 (Observations No. 5.7 and 5.8).
5.1 Design Baseline Verification Program Review The DBVP group reviewed approximately 215 ECNs in the auxiliary power area and 180 ECNs in the vital power area for boundary status. The DBVP review resulted in the generation of a number of Problem Identification Reports (PIRs) for about one-third of these ECNs, which fall into the following four categories; calculations not found, information missing from design criteria, design errors, and drawing inconsistencie The following list summarizes the PIRs which DBVP project identified in the electrical power area:
PIR N Description 86155 Checker's signa ee missing from RIMS #B25860611-80 Unit numbers are not shown for fuses under column fuse UNID on drawing 45N643-4-R As* constructed dwg. 45N677-2 R9 shows discrepancies regarding wire no., color of lights hand switch panel n .
86166 Design criteria SQN-DC-V-7.4 does not address removal of power and control air from certain valve ECN-L6124 and ECN-L5842, discrepancy in settings of time delay relay DC-SQN-V-2.15 design criteria does,not specify closure' time of containment isolation valve Design criteria SQN-DC-V-4.1.1 and 3.1.1 do not include stroke times for main steam and steam generator blowdown system valves. Design criteria SQN-DC-V2.15 R0 does not provide reference to main steam isolation valve or steam generator power operated relief valve closure tim Design criteria SQN-DC-V-9.0 for " Radiation Moritoring System" does not address separation criteri Discrepancy between control room as constructed drawing and as designed drawing for cable number and its locatio Design criteria SQN-DC-V-11.8 does not clarify control condition of diesel generator on safety injection signa A-18
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Attachment A - Insp;ction Activities tnd Obs rvations 8687 ECN-L5651, a clarification regarding addition of a 525 contact required to be adde ECN-L6310 note 6 has wrong wire numbe ECN-L6313, Inconsistency between ECN and control room as-constructed drawing 45N703-2 Rev. EE regarding cable 184 ECN-6783, Lack of voltage drop calculatio For auxiliary power 480 V/120 V protection - There was neither a procedure nor a calculatio ECN-L5451 - No voltage drop calculation ECN-L6245 - Inconsistency between single line diagram and ECN for horsepower value Design criteria SQN-DC-V-7.4 does not address removal of power from motor operated valves, and removal of control air from valve ECN-L5196 adds a cable, but drawing 45N706-2 Rev. KK does not reflect this additio ECN-L5200 adds a cable, but drawing 45N706-2 Rev. KK does not reflect this additio Inconsistency between as-constructed drawing 45N703-4 Rev. HH and 45N703-4 Rev. 19, regarding breaker trip (15 versus 30 amps).
8696 No documentation could be located to support acceptance criteria limits for. qualification requirements per NUREG-058 Drawing 45N771-1, inconsistency between state of valve contacts as-shown and as describe Design criteria SQN-DC-V-9-0 lacks response timing for containment isolation valve The team noted that the DBVP group evaluation of 215 ECNs in the auxiliary power area and 180 ECNs in the vital power area constituted 90% and 80% of the respective evaluations required for the vital power and auxiliary power System Evaluation Review (SYSTER) process.
i j 5.2 Engineering Assurance Oversight Reviews In the electrical power area, EA's overview of DBVP project resulted in 77 action items. Fifty of these action items were considered to be technical in content, and the remaining 26 were considered programmatic. The team performed the following two part audit of EA's overview activities:
(1) Independent Audit: The team reviewed the completed DBVF checklists for
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the following sample of ECNs and test packages which were not reviewed by EA: ECNs L-6219, L-6608 and L-6204, and the test packages for ECNs L-5913, L-6533 and L-6667. The team found examples of lack of proper A-19 l
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.- _ - . . .-. Attachment A - Insp:ction Activitics and Obssrvations documentation, improperly validated design input and output and unverified calculations. However, the team found that EA had identified similar findings during EA's overview of DBVP projec (2) Parallel Audit: The team reviewed the same ECN (ECN The L-5451)
team foundwhich the team was reviewing, and compared its findings with EA' that their findings such as, failure to check a battery rating and failure by DBVP to verify voltage drops for ac and de lube oil pumps, had also been identified by E The following is a partial list of EA findings in the electrical power area that required the DBVP project to take action:
(1) Project review of an ECN did not identify inadequate EA actioninstrumentation item E-50 for newly installed diesel generator ventilation fans.resulted in pr lack of instrumentatio (2) As-designed drawings were used to evaluate the adequacy of electrical test results via red lining on the drawings; EA action item E-56 resulted in the project re-reviewing test results using as-constructed drawings for red lining to demonstrate the adequacy of modification (3) Project personnel were not adequately addressing which field changeSome FCN notices (FCNs) were to be included in the DBVP progra are design changes requested by the NSSS vendor) were incorrectly left out of the DBVP program. EA action item N-16 required the project to take action to clearly define which FCNs were to be included in the DBVP progra Th'e project issued an SCR to resolve this issu ~
EA noted that the DBVP project was not adequately considering the guidance (4)
of NRC Regulatory Guide 1.29. Action items C-10 and C-15 resulted in the
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DBVP project's preparation of a PIR to address this issu EA noted a lack of consistency in DBVP project's review of ECNs EA wrote several which (5) resulted in unclear evaluation of technical adequac action items which resulted in the project issuing specific guidelines to clarify what information is required and what review is needed to complete an ECN evaluatio (6) Project cia review of calculations to support an ECN e cover shee EA wrote several action items which The DBVP resulted in the project nowpro- reviews ject's modification of the review procedur the input assumptions, margins of safety and calc j
(7)
EA noted that the project was not handling system EAreviews at points action item M-10 of
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I interfaces to other systems in an adequate manne resulted in the project issuing a project directive to require system interfaces to be adequately evaluate Based upon the results of the team's two part audit and the types of EA ac items discussed above, the team concluded that EA performed an effective overview of DBVP project in the electrical power discipline.
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Attachment A - Insp:ction Activitics and Observations 5.3 Team Inspection of Engineering Change Notices For this activity, the team reviewed 16 ECNs, three test packages and several The team evaluated functional drawings, FCNs, SCRs, workplans and cable card logics, functions of the modified system, test results, validation of design inputs and outputs, failure modes and effects, and compatibility of mod tions to the existing desig not constitute breaches of commitments, but weaknesses which could be resolved with improved engineerin ECN L-5363 was issued to revise the diesel generator breaker closing circuit such that the breaker will never close on a partially loaded bus in the auto-matic mod The design did not consider delayed tripping and/or failure of the load breaker to trip, which could result in closing of the diesel generator breaker on partially loaded bus under certain plant conditions (Observation N .7).
ECN L-6533 was issued to re-route 68 cables This re-routing above changed cablethe flood level lengths, in ment for four safety-related system These added conduit seal assemblies and routed some cables through fire stop changes can affect various circuit parameters such as voltage drop, thermalHowe rating of conductors and accuracy of instrument loop process failed to verify the technical attributes related to the affected parameters (Observation No. 5.8).
ECN L-6204 was issued to install two series fuses in a non-Class 1E ungrounded circuit passing through a containment penetrat' ion to provide Theprimary team found and backup protection for the penetration in accordance with IEEE-317.that but a review of the implementation indicated that the two series fuses are part of a single fuse block. In such an installation, a single jumper or ground This would estab-fault can be postulated connecting the fuse block to its box; The team lish a parallel path and negate the design objective of this EC ' believes that the installation of these two fuses in separate boxes would eliminate this failure mode and represents an enhanced desig During the team's review of these and other ECNs, the team noted that TVA wasT not initiating FSAR changes for some modification ,
TVA's licensing division will be drafting and incorporating these changes into l
the FSAR at a future date in accordance with 10 CFR 50.71 (e).
The team concluded that the review and evaluation Theof ECNs team foundwhich that the DB project and EA performed met their technical objectives.DBVP In
addressed by other TVA programs, but failed to verify these assumption addition, the SQEP-12 checklist did not enable a cross-reference to an applica-ble in-house program.
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' Licensee Actions on Previous Inspection Findings Team review of TVA's responses to the deficiencies and observations documented EA in NRC inspection reports 86-27, 86-38 and 86-45 is detailed in Section 9.
i has initiated an action item for each of the observations identified in reports l 86-38 and 86-45 and is tracking these action items. In addition, the team i
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Attichment A - InspIction Activities and Obstrvations
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reviewed the corrective actions which TVA initiated to resolve the findings documented in Gilbert / Commonwealth's March 3,1986 design control surve Gilbert / Commonwealth identified three findings in the electrical power area. The This survey was previously inspected by the NRC (Inspection Report 86-27).
following paragraphs summarize each Gilbert / Commonwealth finding and TVA's corrective actions to address the finding:
The team noted that TVA has (1) Tracking abandoned cables in cable tray issued procedure SQEP-06, Rev. O to track cables to be abandoned at a future date. The Electrical Engineering Branch (EEB) and Civil Engineer-ing Branch (CEB) currently have separate programs to track and evaluate previously abandoned cabl EEB is identifying overloaded trays in the auxiliary building and control building by walking down cable trays in accordance with calculations SQN-E2-016 for vertical trays and SQN-E2-017 CEB for horizontal trays to determine the tray weight per running foo is evaluating this information to verify the adequacy of the existing supports, and to re-design supports if require CEB is evaluating the adequacy of the cable tray supports for overloaded trays identified in the containment building and the diesel buildin I The team noted that neither EEB or CEB was evaluating the essential raw cooling water pump house trays. The team also noted that EEB and CEB use EEB analyzes any cable different methods to identify, overloaded tray + tray for which the computer data base shows a loading equal to or greater than 14 lb/ft, for vertical trays and 16 lb/ft. for horizontal tray Th'ese figures were establisjied by a random survey of failure rates (more than 45 lbs/ running ft.) with different loadings. CEB identifies over-
... ~ loaded supports by reviewing the drawings and other related documentatio TVA informed the team that three supports have been re-designed to date as a result of the EEB and CEB studies. The NRC will follow TVA's completion
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of these evaluation The (2) Replacement of polyethylene jacketed cable in the steam valve roo team verified that cable numbers have been properly identified for harsh environment and that such identification is included in the documents related to the 10 CFR 50.49 study and for associated junction boxe (3) Diesel loadings in FSAR figures. TVA has not revised the FSAR to show the loading figures because new loading figures have resulted due to changes in the calculations. NRR is currently reviewing these calculation TVA intends to revise the FSAR figures in accordance with 10 CFR 50.71 (e).
5.5 Observations Observation No. 5.7 - Diesel Breaker Trip The team's review of ECN L-5363 indicated that the design process failed to evaluate failure of the load breaker to trip or the effects of delayed trip-pin TVA issued the ECN to revise the closing circuit of the diesel breakers A
to prohibit closing of this breaker unless load shedding has occurre tripping delay could t'e due to the single or combined effects of drift, aging or continued operation on an overloaded condition. During certain plant A-22
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Atttchment A - Insp2ction Activitics End Observaticns conditions such as the appearance of a blackout signal during a routine test of the diesel generator before it is synchronized with the bus or the appearance of a blackout signal following a LOCA, a race between tripping loads and closing diesel breaker will occur, and a failure of the load breakers to trip or a delay in tripping will result in closing of the diesel breaker on a partially loaded bus, contrary to the ECN's design objective Observation No. DBVP Review Per Procedure SQEP-12 Checklist The team's review of the completed SQEP-12 checklist for ECN L-6533 indicated that the DBVP project had entered N/A (not applicable) into the checklist for electrical attributes such as voltage drop, thermal rating of cables and accuracy of instrument loop TVA issued this ECN to re-route 68 cables above flood level in containment for four safety systems. The team noted that this re-routing resulted in changes to cable lengths, the addition of electric The team conduit seal assemblies and the passage of cables through fire stop believes that these changes affect voltage drop and The the additionally team thermal rating of the found that cables, and change instrument loop accurac the reviewer assumed the existence of calculations / analyses which addressed these referenc attributes, but failed to verify this and failed to provide a cros the resolution of a technical attribute which is addressed by another TVA program unless DBVP project reviews the governing program to confirm that the technical attribute in question is properly addressed, and documents this review in the SQEP-12 checklis .0 INSTRUMENTATION AND CONTROL '
A major objective of this inspection was to review a sample of engineering In this review, change notices for overall design and implementation adequac ~
the adequacy of ECN evaluations prepared for the Design Baseline Verification Program and the adequacy of the Engineering Assurance oversight of the project Finally, TVA's responses to individual observa-results were to be assesse tions made by the team during earlier inspections were to be examined for possible closur The team selected and examined a sample of engineering change notices that had been reviewed and evaluated by the Design Baseline Verification Program A second project sample of team in accordance with TVA procedures SQEP-12 and SQEP-1 ,
' ECNs was examined for the technical evaluations developed by the Engineering Assurance oversight team. A number of ECNs reviewed by the team concerned component cooling water (CCS) system design changes and the impact on plant design of environmental qualification requirements implemented for various systems. The team also selected a third sample of engineering change notices Each instrumentation on specific technical topics for its independent revie and control and several nuclear discipline observations from the previous 86-27, 86-38, and 86-45) were reviewed with design control inspections (Reports TVA personnel for their current statu Approximately 15 ECNs reviewed and evaluated by Engineering Assurance Ten and 23 action items developed from this evaluation were examined by the team.
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_ _ _ . - _ ~ . _ _ Attachment A - Inspxction Activities and Observaticns component cooling water ECNs that had been reviewed and evaluated by the D8VP project team were also examined. Six other ECNs involving environmental qualification changes 5 work plan packages involving post-modification testing, and 6 design criteria documents were examined. The team's independent review of other ECNs and work plan packages involved their technical adequacy, e.g. ,
review of analyses, identification of test requirements, specification of acceptance test criteria, and resolution of test data anomalies. Portions of several work plans were examined for recorded data values taken during system level preoperational tests. The team inspected the installed component cool-ing water system surge tank level instruments added by ECN-L-620 Approximately half of the team's instrumentation and control observations identified during this inspection were determined to have been within the scope of the DBVP (i.e. "in bounds").
6.1 Design Baseline Verification Program Project Review The NRC team was informed that none of the instrumentation and control ECNs reviewed and evaluated by the DBVP project team had identified any impact on existing plant hardware. The team's review of a small sample of ECNs confirmed this statemen The types of documentation problems identified from the project's reviews included: (1) instrument setpoint calculations did not exist; (2) instrument accuracy and range specifications were missing in source documents; (3) the scoping of post-modification testing in some work plans was deemed inadequate; and (4) documentation errors such as the absence of a requirement for seismic qualification of replacement component .
While the project evaluations were considered generally satisfactory, the team questioned the DBVP evaluations for checklist question 3.c which evaluated the postulated failure effects of each design modification. For this question, an incomplete response was provided since the evaluation was limited to postulated short circuit effects and the potential loss of the affected electrical boar The evaluations did not consider the effects of open circuits or the applica-tion of the maximum credible voltage level, and did not explicitly confirm that all required safety functions remained intact after the design modification was implemented (Observation No. 6.14).
The following is a summary of the results of DBVP project's ECN review:
(1) Missing Instrument Setpoint Calculations Were Identified:
ECN-L-6202 CCS surge tank level switch setpoint was identified as missing by the project, and was then specified as 65 inches of water by QIR SQP 86002.
I ECN-L-2614 did not have a setpoint calculation for ventilation pressure switches PS-31-483B and 508 ECN-L-2661 did not have a setpoint calculation for a ventilation circuit time delay relay change from 5 to 10 second A-24
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Attichment A - Insp cticn Activitics and Obs:rvaticns l J
ECN-L-5156 was missing a setpoint calculation for a change in ventilation system pressure switches PS-31A-172 through -175 from 190 to 160 psi to meet system operating requirement ECN-L-5995 was missing a setpoint accuracy calculationThese for steam generator instruments wide range level instruments LT-3-55, -93, and -11 provide safety-related information to the operato ECN-L-5883 was missing a setpoint calculation for AFW pump suction header i pressure switches PS-3-121A, -1218, and -121D that initiate AFW transfer to the ERCW suppl Several other ECNs reviewed by the DBVP also identified missing setpoints fo annunciator alarms; however, these were designated as being out-of-bounds for the DBVP scop (2) Missing Accuracy and Range Specifications for Instruments Were Identifie For the ECNs that the NRC team reviewed, no particular examples of this category were found. The project said they had found such cases, which would be consistent with NRC Gilbert / Commonwealth review inspection findings (Report 86-27).
ECN-L-5620 was missing a loop accuracy calculation for AFW turbine pump discharge pressure transmitter PT-3-13 ECN-L-5125 had an incorrect range of 0 to 9000 standard cubic feet per minute for a flow rate measurement in the ventilation system (System 30).
No allowance had been made for the +/- 10 percent flow rate tolerance when the instrument was ranged; hence, the instrument could be over-ranged in operatio .
(3) Inadequate Scoping of Post-Modification Testing Was Identified.
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t ECN-L-6374 work plan did not have a functional +est, so the project stated The NRC tea.a noted that the alarm that the alarm should be verified.
i reset value was not listed and was not confirmed by post-modification testin A satisfactory reset characteristic was confirmed by instrument calibration.
i ECN-L-6648, which added a 20 second time delay for component cooling w l pump start had post-modification test changes implemented into the w l' plan based on project review comment ECN-L-2890 work plan post-modification testing was deemed inadequate by the project since a functional test of the circuit wiring changes had not been provided when the valve stroke timing surveillance instruction was performe ECN-L-5991 required retesting of modified Westi correct pin connections and correct circuit functioning after switch
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A-25 l ,- -. . _ . - . . - - - - _ _ _ _ _ _ . _ . . _ _ . - - - Attachment A - Insp;cticn Activities and Obssrvations ECN-L-5114 added circuit breaker position monitoring to the reactor coolant system. Test prerequisites were not properly set up, and the circuit changes were not fully teste ECN-L-6055 relocated reactor coolant system wide range pressure switches to a higher elevation. However, the calibration of the instruments did not take into account the head correction effect of the elevation chang ECN-L-6584 modified the torque switch configuration for the AFW turbineThe The retest was performed at cold condition supply valve FCV-1-5 project has stated that the functional test must be performed at operating pressure and temperature condition ECN-L-5490 modified the AFW steam turbine speed controller, but the modification was completed before the test procedure had been documente Hence, the post-modification retest had not been thoroughly documente ECN-L-2873 did not adequately test the safety injection signal logic to assure proper circuit functioning after modificatio ECN-L-5856 contained incomplete testing after a sample line was relocate The sample line was shared with a level transmitter, and the retest did not verify that a change in level would be detected when a sample was take ECN-L-6308 modified the control logic of the centrifugal charging pump circuit. The test did not verify all of the logic, such as the low lubrication oil pressure interloc (4) Various Types of Documentation Errors Were Identifie ECN-L-6374 had PIR SQNCEB8637 written by the project to list missing documentation for the seismic qualification of the replacement switche ECN-L-5107 for radiation monitor flow switch replacement also had PIR The SQNCEB8637 applied for inadequate seismic qualification informatio project comment stated that the replacement switches had been procured as non-seismi ECN-L-6667 work plan for removal of valve torque and limitThe switches projectdid noted not have a complete post-modification test descriptio and tracked this omissio .2 Engineering Assurance Oversight Review The oversight review by EA of ECNs reviewed and evaluated by the DBVP project team yielded similar documentation omission results as found by the project. A majority of the ECNs reviewed by EA dealt with the adequacy of instrument setpoints and related setpoint tolerance calcula-tions. The more recent EA action items showed an improved depth of technical review in that their review identified missing instrument setpoint calculations, missing accuracy and range specifications, missing l
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Attrchment A - Insp;ctien Activitics and Obssrvaticns seismic qualification data, inadequate justifications for some ccnclu-sions stated in the project evaluations, and missing or incomplete source document and corrective action reference Following is a summary of the results of EA's oversight of the DBVP project:
(1) Missing Instrument Setpoint Calculations Were Identifie ECN-L-6124 did not have a setpoint calculation (AI-I-34).
ECN-L-6254 did not have a setpoint calculation (AI-I-28).
(2) Missing Accuracy and Range Specifications for Instruments Were Identifie ECN-L-6124 did not have documented setpoint tolerance ECN-L-6254 did not have documented setpoint tolerances (AI-I-29).ECN-L-63 ECN-L-5884 had no calculation basis (AI-I-26).
tion basis (AI-I-22).
(3) Missing Seismic Qualification Data or Reference ECN-L-5600 had a conflict over Civil Engineering review of the change (AI-I-31).
ECN-L-6404 did not reference a Condition Adverse to Quality (AI-I-27).
ECN-L-6359 did not list a PIR number (AI-I-21).
ECN-L-5884 did not have CEB input (AI-I-25).
(4) Inadequa'te Justification Provided in the DBVP, Evaluatio ECN-L-5275 evaluation checklist did not justify a number of conclusions drawn by the projec .
(5) Missing References to Source Documents in the ECN Packag ECN-L-6175 did not have a reference to SI-620 (AI-I-32).
ECN-L-5275 did not identify the needed administrative procedures (AI-I-36).
CAQ's not referenced for several "not addressed" items in th (AI-I-38).
CAQ was not provided for the setpoint calculation (AI-I-30).
CAQ was not issued for the time delay change basis (AI ECN-L-5791 had a design criteria reference, but this did not provide a sufficient basis (AI-I-23).
- Team Inspection of Engineering Change Notices Because of the relative complexity of electrical circuit changes required by ECN-L-6202, which added level switches to the component cooling water surge tank, the team reviewed the logic, electrical one-line, and schematic diagrams in detail for conformance with electrical separation and single failure crite-
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ria requirements. This detailed review did not identify any deficiencies with l the design of this modificatio One common weakness noted by the team during the review of ECNs involved the technical communication of test requirements and test acceptance criteria A-27
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Attcchment A - Insp';ction Activitics and Observatiens In a number of instances, between engineering and plant operations personne Engineering had not documented its understanding of the required scope of post-modification tests, and Operations had not demonstrated its awareness of certain periodic test and surveillance requirement For example, ECN-L-6648 added a 20 second time delay for starting of the component cooling water pumps to improve the sequence Operation of theofcircuitry adding direct-electrical loads onto the emergency diesel generator ly affected by this change was confirmed in accordance with the work pla post-modification test procedure.the same circuit had not been periodically te in 1978. The 0.5 second timer is used to reset (i.e. restart) the 20 second timer when a safety injection signal occurs after a loss of offsite power condition. Similar time delay circuits exist for the essential raw cooling This timer water, motor driven auxiliary feedwater, and charging system pump (in each of these pump control circuits) did not have a surveillance instruc-tion for periodic calibration of its time delay, nor did the system level periodic test procedures test the functional performance of the 0.5 second tim delay or its initiation circuitry (Observation No. 6.15).
Another example relating to post modification test criteria involved ECN-L-6374, where the original component cooling water pump discharge high pressure switch would not reset with This normal system aoperating switch provided pressure of high pressure approximately 113 psig restored. annunciator alarm at 120 psig, but would its large deadband characteristic. This ECN specified a replacement switch from a different manufacturer; however, neither the ECN nor the post-modification test procedure in the work plan identified either the desired or expected reset value. While instrument calibration records did confirm proper reset action of the replacement switches, the actual work plan post-modification test did not require that this test data be taken (Observation No. 6.13).
During review of the level switches added to the component cooling water surge I
tank by ECN-L-6202, the team noted that the integrity of the surge tank inter-This nal baffle had not been periodically confirmed by either test or inspectio baffle plate safety function is to provide for independence of redundant CCS watar volume An undetected passive failure of the baffle plate in one surge tank, coupled with a postulated leak in the component cooling loop of system one unitpiping, and could drain the stored water volumes loopsin the of affected the CCS are"A" shared between Units the "B" loops of both units (the "B" 1 and 2) (Observation No. 6.12).
TVA analysis SQN-OSG7-038 was issued to justify the connection of unqualified
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loads to Class 1E buses in response to environmental qualification requirements stated in 10 CFR 50.49, section b(2). ECN-L-5944 was issued in 1983 to delete Class IE qualification requirements for the control rod drive mechanism cooler fan motors. ECN-L-6459 deleted Class IE qualification requirements for the The SQN-OSG7-038 analysis lower compartment cooling fan motors in mid-198 which was prepared in late 1985 and revised in mid-1986 did not include the unqualified loads identified by these two ECNs (Observation No. 6.11).
The team also noted that the TVA design criteria document for power, signal, and control cables in Category I structures (SQN-DC-V-11.3) contained incorrect temperature values for environmental qualification requirements (Observation No. 6.9).
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h Attachment A - Inspection Activitiss and Obssrvatiens The team also noted an inconsistency in the format and content of calibration data sheets included in work plan 11916 for temperature detectors replaced by ECN-L-6551 in that as found data was not consistently recorded (Observation N .10).
The team concluded that the review and evaluation of ECNs by the D8VP project team appeared to be satisfactory, not withstanding the lack of SQEP-12 checklist question 3.c consideration The of potential failure modes and effects introduced project also identified a number of post-by the design modificatio The Engi-modification test omissions from their SQEP-14 checklist review neering Assurance oversight review of a sample of ECNs also appeared to be satisfactor The team's periodic test observations went beyond the boundaries of the present
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DBVP scope; however, they are indicative of a potential weakness in the inter-face between engineering and operations group .4 Observations Observation No. 6.9 - Cable Design Criteria Temperature Limits Sections 4.3 and 4.4.2 of the design criteria document for " Power, Control, and Signal Cables in Category I Structures" (SQN-DC-V-11.3, Revision 5 dated 9/30/85) stated that the qualification temperature profile These wasvalues 300 degrees were F for 15 minutes and 250 degrees F for the next 10 day incorrect since they did not conform with the environmental data drawing (47E235-45, Revision 1 dated 1/28/85), wh'ich contained a peak tempera requirement of 327 degrees F. stated that it was the governing document in c document .
Observation No. 6.10 - Instrument Calibration Data Consistency Work plan 11916, which implemented the replacement of a number of safety-rel temperature switches with environmentally qualified un The work plan contained records for cal data for instrument calibration instruments TS-12-91B through TS-12998 that provided both "as found" and "as left" setpoint columns; however, the records for instruments TS-1-17A No justification wasthrough TS-1-18B contained only an "as left" setpoint column.
l l provided for this difference in these two data sheet Revised values of the nominal setpoints (e.g. 97* F for TS-12-918 However, and the 148 F for TS-1-17A) were properly referenced in the work pla was described in the permitted setpoint tolerance range of plus or minus 5 work pla was the case for instrument 0-TS-12-91 A-29
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Attachment A - Insp;cticn Activitiss and Obssrvations Observation No. 6.11 - Environmental Effect Calculation for In-Containment Non-Class 1E Loads Connected to Safety-Related 480 Volt Shutdown Boards In 1983, engineering change notice ECN-L-5944 changed the designation of the control rod drive mechanism cooler fan motors located inside containment from Class 1E to non-Class lE. Two years later, a similar change was made to four in containment lower compartment cooling fan motors (2-MTR30-74, -75, -77, and-78) by engineering change notice ECN-L-6459. Each of these motors had been designated as Class 1E because of its connection to a Class 1E bus; however, further analysis indicated that no safety-related function was performed by On this basis, these motors for any of the FSAR Chapter 15 accident analyses.
these motors did not need to be environmentally qualified, and the Class lE buses were protected by an existing Class lE fuse and circuit breaker tripped on a containment isolation phase B signa In late 1985, TVA performed an analysis (SQN-OSG7-038) of the effect of unqual-ified loads connected to Class lE buses in response to the environmental This analysis qualification requirements stated in 10 CFR 50.49, section b(2).
was revised in July 1986. In each instance, the unqualified motors identified by ECN's L-5944 and L-6459 were not included in the analysi Because the Unreviewed Safety Question Determination (USQD) stated that failure of these cooler fan motors "during normal or accident conditions will not degrade the safety of the plant," the team discussed some of the technical aspects that had been considered by several TVA individuals that had partici-pated in the decision making process. For example, had the cooler fan motors been qualified for a harsh environment, no fault current challenge to the Class IE 480 volt shutdown boards would need to be postulated. However, since the cooler fan motors were not qualified, their simultaneous failure could present a fault current challenge to each of the four redundant shutdown boards. The TVA evaluation stated that the Class IE series fuse and circuit breaker combi-nation provided for each motor would ' protect the individual shutdown board The team noted during this review that the pressurizer heater breaker circuit, which was similar in design to the lower compartment cooler fan motor breaker circuit, was tripped by a safety injection signa The team then determined that no consideration had been given to tripping the control rod drive mecha-nism or lower compartment cooler fan motor circuit breakers with a safety injection signal rather than the containment isolation phase B signal to assure that the unqualified motors would be disconnected from the 480 volt shutdown boards prior to connection of the diesel generators to the emergency buse The team considered that the ECN should have identified both the available technical options and the effects of simultaneous failure of unqualified motors inside containment in its justification of the chosen design configuratio Observation No. 6.12 - Periodic Test of Component Cooling System Surge Tank for Internal Baffle Integrity A single surge tank is shared by the redundant A and B loops of the component cooling water system as shown on TVA flow diagram 47W859-1. This tank has an internal baffle plate that extends from the bottom up to 68 percent of the maximum tank volume to provide the minimum water storage volumes needed for each cooling loop. Independence of these two water volumes is provided Level by separate suction taps on opposite sides of the internal baffle plat indication is provided in the control room for each section of the tan A-30
Att chment A - Insp;cticn Activitics cnd Obssrvations Independence of the minimum water volumes required for CCS pump net positive suction head for both loops A and B can be compromised should an undetected leak occur through the internal baffle plate. Because the water level in the tank is normally maintained automatically above the top of the baffle plate during plant operation, the level instrumentation will not detect the existence of a leak through the baffle plat In addition, deterioration of the internal ,
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baffle plate cannot be detected by external observations of the tank made during a plant walkdow Requirements for suitable redundancy in cooling system components and for compliance with the single failure criterion are stated in 10 CFR 50 Appendix A General Design Criterion 44. A requirement for periodic inspection to assure cooling system component integrity is stated in General Design Criterion 45. A requirement for periodic testing of the operability of the cooling system as a whole is stated in General Design Criterion 46. The SQN FSAR states that the CCS comprises 2 independent loops which are not susceptible to a single passive failure. This statement depends on the continued integrity of the tank baffle plate.
I Typirally, a. combination of periodic inspections and periodic tests would provide a means of early detection of the loss of baffle plate integrity, and would then permit the baffle plate to be designated as a passive element exempt from postulated failure prior to and during the short term period following an accident. However, when periodic inspections and tests fail to detect the loss of baffle plate integrity, the undetected baffle plate failure is considered to exist prior to and during both the short and long term periods associated with an acciden Since such postulated degradation of the baffle plate could jeopardize the independence of the redundant water volumes, TVA was requested to provide preoperational and periodic test data that would confirm the ongoing integrity of the internal baffle plate. No such test data could be located during the
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inspectio .
Observation No. 6.13 - Component Cooling System Pump Discharge Pressure Switch Reset Each of the component cooling water pumps has a discharge pressure switch to
provide a control room annunciation for a high pressure condition (2PS-70-57,
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2-PS-70-31, and 0-PS-70-49). The original pressure switch alarmed when pres-sure increased to 120 psig, but could not be reset during normal conditions since the normal system operating pressure of 113 psig exceeded the pressure switch reset value of 98 psig, decreasing. Engineering change notice ECN-I L-6374 replaced these pressure switches with those from another manufacturer to achieve a smaller pressure differential between trip and reset of the pressure
switch output contac Documentation provided in the project's evaluation of the engineering change notice, work plan, and post-modification test results did not state what the revised reset setpoint value should be and failed to confirm that the opera-tional problem had been satisfactorily resolve The engineering change notice and unreviewed safety question determination provided with the DBVP project's SQEP-11 evaluation did not describe the new A-31
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Attachment A - Insp;ction Activities tnd Observctions pressure switch reset value or reference a revised instrument data sheet used for procurement of the replacement pressure switche Project evaluation sheets prepared in accordance with the SQEP-12 procedure ,
identified the omission of seismic qualification documentation and noted that l the reset value was changed; however, an actual reset value was not identified j and the only designated post-modification test was for sense line leakag Project evaluation sheets for procedure SQEP-14 identified that the high pressure alarm needed to be verified, but did not require verification of the pressure switch reset. Work plan 10256 stated the high pressure setpoint as 120 psi without a tolerance band, and did not state a specific reset valu Consequently, the decreasing pressure reset value was not measured during the post-modification tes Observation No. 6.14 - Project Evaluation of Electrical Failure Analysis for Procedure SQEP-12, Design Review Checklist Design review checklists are prepared by the project for individual Engineering Change Notices in accordance with procedure SQEP-12. Checklist question asks whether the design change creates an electrical problem in any of its failure modes. In a number of instances, the completed design review checklist provided a reference to Note 17 of (checklist) Attachment A. This note states that the change will not cause a simultaneous short which would cause a loss of the board. By only referencing this note, the team is concerned that only a partial answer has been provided for the question of failure modes and their effect Failure mode and effects analysis, whose methodology is' described by IEEE St , requires the consideration of short circuits, open circuits, and the application of the maximum credible voltage within electrical circuits in cabinets, panels, racks, cable trays, and conduits. For any of these postu-lated conditions, the safety system must accomplish all protective functions required for each design basis event in the presence of any postulated single failur Moreover, the anticipated loss of one control board does not provide a direct correlation to the potential loss of one or more protective functions involving reactor trip, containment isolation, emergency core cooling, control of radio-active releases, or safe shutdown of the plant.
l In this instance, the team considers that the SQEP-12 procedure has asked the
! correct question; however. the project's implementation was considered insuf-l ficien Observation No. 6.15 - Periodic Functional Test of Agastat Timer Relays in Pump Motor Start Circuits Engineering Change Notice ECN-L-6648 introduced a 20 second time delay in starting of the component cooling water system pumps. This change was made to accommodate a revised sequence for applying various loads on the emergency diesel generator buses. Similar time delays exist in the motor starting A-32
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Attachment A - Insp;cticn Activitics tnd Obs;rvations circuits of the essential raw cooling water, auxiliary feedwater, and charging system pump Two separate time delay relays are used in each of these motor starting cir-cuit One Agastat model 7012-PD time delay relay provide second dela second time delay to reset the 20 second timer when a safety injection signal follows a loss of offsite power, such that proper sequencing of the motor loads The 0.5 second timers are designated as CCS-A, AFW-A, ERCW-A, and will occu CPAX-1A, in their respective circuit Automatic initiation of the pumps by an accident signal is Simulation of required the loss ofby Techn cal Specification 4.7.3.b at an 18 month interval.offsite power emergency loads is required by Technical Specification 4.8.1.1.2.d. Operability of the trip functions is required to be demonstrated during ch functional test During the component cooling water system preoperational test 20A con 1978, the functional performance of both time delay relays was confirme Subsequent periodic surveillance testing, in accordance with instruction SI.220.2, rela has provided a periodic calibration of The theteam20 sec time delay relay has not been required by a surveillance instructio was unable to locate plant data that would confirm that the 0.5 second time delay relay in the aforementioned circuits has been periodically tested or calibrate .0 CIVIL / STRUCTURAL s
In the Civil / Structural area the team reviewed the technical adequacy of selected ECNs, as well as the project oversight activitie activities related to DB ECN 2548, 5274, 5357, 5600, the DBVP project, EA oversight, and the NRC Theteam.5703, team also re- 6202, project and included in the NRC Civil / Structural sample. vie 86-27, 86-38 and 86-4 The Civil Engineering Branch project review of ECNs resulted in the followin generic findings:
(1) Calculations could not be foun (2) Component analysis / seismic qualification was not mad (3) Pipe rupture evaluations were not made.FCRs with Civil involve (4) Changes were not documented in calculations and/or drawing (5)
(6) Inadequate technical evaluation was mad The project has issued generic Problem Identification Reports (PIRs) re
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Attachment A - Insp;cticn Activitics and Observaticns these findings. They have documented each finding in a punch list. An assess-ment of the need to resolve each punch list finding must be made before restart.
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Specific examples of ECNs associated with DBVP project's generic findings in the Civil / Structural area are summarized in Section 3.0, Mechanical Component The review performed by the DBVP project did not involve checking technical adequacy of calculations. As stated by TVA, calculation reviews are being performed through another calculation review program. Excluding this aspect, the project review of the ECNs was comprehensive and did identify generic documentation problem EA performed a more comprehensive review of the sample of ECNs they selecte Their selection was limited to 19 ECNs in the Civil area. EA, during their review, evaluated the technical adequacy of the calculations related to these ECN Their review resulted in the following generic types of findings:
(1) The project did not identify / evaluate some field change request (2) The project performed an incomplete / incorrect revie (3) The project improperly identified ECNs to be out-of-scope for the DBV (4) There were discrepancies between calculations and drawing (5) The system engineer incorrectly incorporated the project civil inpu Team review of the EA findings determined that they were mostly documentation related and did not result in any hardware modification The NRC team reviewed a total of 17 ECNs, of which 5 were previously reviewed by EA and the rest by the project. The team independently reviewed calcula '
4 tions and drawings associated'with these ECNs to determine their technical adequacy. Cartain work plans were also reviewed. This review identifi.ed the following deficiencies:
(1) Missing original calculations and walkdown information (ECN 5357).
(2) Missing support variance calculations (ECNs 6700, 3354, 5274).
(3) Missing evaluations for reinforcing bar cuts (ECNs 5600, 5277, 5726).
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The team noted that all of these deficiencies were also identified by the project prior to the NRC inspection. During the NRC review of ECN 5298, the team found that the DBVP project review incorrectly stated that calculations were not required for the resolution of a Field Change Request (FCR). Also related to the same ECN, the project reviewer failed to verify whether calculations were performed for another FCR (Observation No. 7.4).
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Due to the lack of calculction review performed by the project and the limited reviews performed by the EA and NRC teams, a conclusion on the technical adequacy of the ECNs could not be reached at this time. These limited calcula-tion reviews performed by the EA and the NRC team did not identify the need for any corrective hardware modifications in the Civil / Structural are A-34 l
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Attechment A - Inspecticn Activities and Obs rvatiens Observation No. 7.4 - Project Review of Support Variance
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A review of ECN 5298 and its supporting documents showed the following deficiencies:
The Civil / Structural design review checklist (Attachment 28) shows that no (1) calculations are required or needed for the resolution of FCR #455. A review of this FCR in the work plan showed that there were variances to a typical support where calculations should have been performe (2) The same Achecklist shows review of this thatbyFCR document #565 the team is evaluated found that it was notin TVA 810528 03 The project review failed to related to the evaluation of this FC verify whether calculations were performed for the resolution of this FC The review of work plan 8737 by the NRC team revealed unchecked and unverified calculations for this FC .0 QUALITY ASSURANCE
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In the Quality Assurance (QA) area, the team reviewed a sample of were MRs 47 Mainten ance Requests (MRs) from the period of June MRs were 1985 select- to D thus should be handled as an Engineering Change Notice (ECN).
ed from a TVA list for the safety injection system, containment spray system,
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component cooling water system, residual heat removal system,Although chemical an volume control system, main steam system, and main feedwater syste the team did not find that MRs were being utilized in an improper manner to
' accomplish maintenance activities, other recent NRC inspections have noted instances of such occurrences.
l A review of the TVA Engineering Assurance Oversight Review Plan was conduc In the plan's checklist for the QA discipline, to determine QA involvemen the team noted that there were no provisions to verify that design calculations were rechecked for accuracy. This item is further addressed in the Civil /
Structural and Electrical Power Sections of this attachment.
l LICENSEE ACTION ON PREVIOUS INSPECTION FINDINGS The TVA response, dated July 28, 1986, to the NRC Design Control Inspection Report 86-27, dated April 22, 1986, has been evaluated by the Office of Inspec-An NRC letter requesting additional informationDuring relating tion and Enforcemen , 1986 (Reference 12).
to this response was sent to TVA on Octoberthis inspection, the t items and deficiencies identified in Inspection Report 86-27 and for the Observations identified in the previous DBVP inspection reports (86-38 and 86-45, References 10 and 11, respectively).
For items designated as closed in this report, theOther NRCitems considers that the TVA are considered actions delineated in the responses are adequat open based on a need for additional information, completion of licensee
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Att:chment A - Insp:ction Activitics and Obs;rvaticns Several items are designated as closed or a response considered to be inadequate.for the purpose of IE foll review and resolutio (0 pen) Observation No. 1.1 - Impact of Walkdown Findings on Operating Procedures The concern that the discrepancies found during system walkdowns were not formally being reviewed for application to operations This group proce been addresse to be sent to the Surveillance Instruction (SI) review grou When compares the revised drawing number to the data b the change for possible procedure revisio This program for operations review reported in writing to the SI review grou of walkdown findings satisfies the concern identified in Observation No. The that a team procedure noted was that Observation in place to ensure that was valves answered found missing from and re syste prints line-up sheet were placed in the appropriate Surveillance Instructi through the process to verify that the identified item was inde in the appropriate document oversight team should sample corrective action processes to ensure that pro dures working as intende intended to close items brought to individual bounda the corrective action procedures and processes accomplish their objectives d would demonstrate proper implementation, and not just the existence of a Observation' 1.1 remains open pending additional inspec-for their resolutio tion of implementation of DBVP corrective action !
(0 pen) Observation No. 1.2 - Walkdown Scope Difference From Calcula Boundaries This observation concerned the fact thatProcedure the extent tio No justification for the difference was filed for revie SQEP-16 has been changed to require the system engineer to provid tion for the walkdown boundaries in the System Evaluation Report (SYSTE This item will remain open pending review of a sample of boundary justific tions in the SYSTER (0 pen) Observation No. 1.3 - System Interfaces on Drawings The team review determined that TVA had not fully understood the origina The concern that the "out of function" systems shown on a observatio drawing be accurate will remain open until a project policy is promulg reviewed by the NR A-36
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Attachment A - Insp;ction Activitics and Obs3rvations (Closed) Observation No 1.4 - Diesel Fuel Oil Line Pipe Size The team's concern was that the non-use of the discretionary attributes was not The D8VP program did not require justifi-justified when these were exclude cation of the exclusion of the discretionary attributes and the team review during this inspection did not find a case of disagreement with the specified (or not specified) attributes. This item is close (Closed) Deficiency D2.1-1 - Furmanite Leaking Valve Bonnet The inspection team found that TVA applied the "Furmaniting" process to check valve 1-VLV-3-891 of the auxiliary feedwater system by drilling into the valve bonnet flange without addressing stress analysis. TVA has committed to:
(1) Remove the valve modified under ECN L622 (2) Perform a stress analysis of the valve modified under ECN L631 (3) Identify, evaluate and qualify other valves modified by the Furmanite process and replace components that cannot be qualifie (4) Require that an Unreviewed Safety Question Determination (USQD) be issued by the Nuclear Engineering Branch (NEB) for all components repaired by the Furmanite process. NEB personnel will be instructed regarding the need for stress analysis evaluation when preparing a USQ .
(Closed) Deficiency D2.3-1 - Long Term Unincorporated ECNs The inspection team found that Temporary Alteration This Control is cont ~rary Formto(TACF)
the TVA 80-734-67 was in effect for more than 60 day policy to return the alteration to normal or to issue TVA and hasprocess committed a design to:
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change request within the prescribed time perio (1) A safety evaluation of all open TACF (2) Plant Operation Review Committee review of open TACFs and associated ECNs every six month (3) Division of Nuclear Engineering safety evaluation of all future safety-related TACFs before implementation.
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(4) Reassessment of each open TACF before plant restart to ensure that l safety is not degraded due to the existence of alteration Region II will review TVA's followup actions and review of implementation of these commitments.
i (Closed) Observation No. 2.1 - Walkdown Scope Differences in scope were identified between various system walkdown packages.
This observation is considered closed on the basis that:
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Attachment A - Inspecticn Activitics and Observatiens (1) The DBVP project team has written a letter to the system engineers advis-ing them of inconsistency in identifying valve stem leakoffs and advising them to use supplemental walkdowns if there is a need to identify leakoff (2) The location of local instrumentation is not functionally safety-related; however, the gauge may have pressure integrity requirements if it connects into a safety grade system. EA has sample inspected several local gauges and has found that they all meet the requirements of the TVA piping into which they connec (Closed) Observation No. 2.2 - Nameplate and Dimensional Data The team noted that the system walkdowns were not required to identify compo-nent nameplate data nor obtain dimensional data. This observation is consid-ered closed on the basis of a letter issued for the project (Reference 5)
concerning guidelines for using supplemental walkdowns for collecting required dimensional and nameplate data on modified or replaced components if the data '
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cannot be otherwise obtained from a Quality Assurance verified program and by Revision 3 to SQEP-0 .
(0 pen) Observation No. . Status of NSSS Vendor Proprietary Information TVA has received a letter (Reference 6) from the NSSS vendor stating that all proprietary document C/Rs are also contained in formal non proprietary docu-ment This was confirmed by an EA audit of the NSSS vendor document EA action item M-22 states that TVA will replace references to proprietary infor-mation with non proprietary references during the phase of the program follow-l ing restart of Unit 2. This approach is considered satisfactory. However, this item remains open pending a confirmatory letter that the action has been complete (0 pen) Deficiency D3.1-1 - Exhauster Installation Deficiency D3.1-1 indicated that TVA could not obtain the seismic qualification documents for eight quick exhauster installations. To address this deficiency, TVA has documented the seismic adequacy of the eight quick exhauster installa-tions, and has evaluated a sample of 60 out of approximately 300 ECNs involving component seismic qualification that TVA has issued since fuel load. TVA has found no seismically inadequate installations. TVA is evaluating additional critical safety system ECNs as part of the DBVP, to be completed before restar TVA has revised interface control document CEB-DI-121.03 to clarify situations requiring seismic qualification review / approval. TVA has revised the Local ECN (LECN) Unreviewed Safety Question Determination (USQD) process to ensure that any special requirements and/or design considerations referenced in the USQD have been implemented by the responsible discipline, as described in Nuclear Engineering Procedure 6.1. This item is open as a confirmatory ite (0 pen) Deficiency D3.2-2 - USQD Requirement Deficiency D3.2-2 detailed TVA's inability to retrieve seismic qualification documents for two existing valves with added extension operators and cover A-38
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Attachment A - Insp;cticn Activitics and Observctions
,
t To address this deficiency, TVA will evaluate existing valve extension operator l'
modifications and provide seismic qualification documentation for the remote valve stem operators, attached valves, and rigorously analyzed piping and supports prior to restart of SQN Units 1 and 2. TVA will evaluate field-routed
'
l (alternately analyzed) piping for additional concentrated weight effects after i restar TVA has revised seismic interface document CEB-DI-121.03 to clarify I situations requiring seismic analysis and approval. TVA has revised the Sequoyah Rigorous Piping Analysis Handbook to include remote valve actuator modeling requirements, and TVA has revised NEP-6.1, Change Control, to require
.
j
re-review of the USQD at the time of the ECN closure to ensure that any special requirements and/or design considerations referenced in the USQD have been implemented by the responsible discipline organizations. This item is open
i as a confirmatory ite ;
l (0 pen) Deficiency D3.2-3 - Piping Flow Diagram
' Deficiency D3.2-3 identified a TVA piping flow diagram with a missing class j boundary break. To address this deficiency, TVA will review and revise flow
' diagrams ani piping drawings for systems defined by design criteria to be
! safety-related or to contain safety-related portions prior to Unit 2 restar ;
>
'
Systems which do not have any safety-related portions will be completed after Unit 2 restart. This item is open as a confirmatory ite (Closed) Deficiency 3.2-4 - Sample Connection Support t
!
- Deficiency 03.2-4 identified an apparent variance in a standard clamp support i f
detail. TVA indicated that the support detail which specifies Basic Engineers i i
- type BE-122 heavy-duty pipe clamp or equal, with 3/4" bolts torqued to 100 i
ft-1bs, is adequate for the 3" main run pipe support. This item is closed.
i i
j (0 pen) Deficiency D3.3-1 - Pipe Support Friction Design
'
Deficiency D3.3-1 indicated that TVA had not considered friction forces for
'
pipe support design at Sequoyah Nuclear Plant. To address this deficiency, TVA will evaluate a sample of SQN support designs in critical piping systems after restart to determine the ef fects of friction loads. TVA's evaluation will
' start on January 2, 1987 and will be completed on June 1, 1987. TVA has issued I
a design criterion for pipe supports that will require the consideration of l
friction loads due to temperature for the design of new pipe supports and for i
the modification of existing pipe supports. This item remains open pending NRC I review of TVA's evaluatio ,
i l (Closed) Deficiency D3.3-2 - Valve Accelerations I
I Deficiency D3.3-2 documented TVA's qualification of some valves to acceleration i l
1evels greater than 2g vertical and 3g horizontal. To address this deficiency,
! TVA plans to amend the FSAR to state that accelerations higher than specified in the design specification are approved by TVA on a case-by-case basis, as
,
limited by the seismic capacity of the valves. TVA has indicated that docu-
[
mented analyses exist which justify approval of the increased valve accelera-l tions. TVA has also issued a Significant Condition Report to document a l
i A-39 i
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Attachment A - Insp;cticn Activities and Observsticns generic question regarding the control of FSAR informa plant design basis described in the FSAR is consistent with TVA design inp document This item is close (Closed) Deficiency 03.3-3 - Valve Fundamental Frequency Deficiency D3.3-3 identified TVA's procurement of some valves toTo a minimum address frequency criterion less than the criterion specified in the FSA this deficiency, TVA has amended the FSAR to lower the minimum fundamental frequency for valves from 33 to 25 Hz andTVA to approve exceptions has indicated to this min that non-rigid frequency criterion on a case-by-case basi TVA valves are modeled as flexible cantilevers in rigorously analyzed pipin has indicated that the difference in seismic response spectra This item isatclose Hz and 33 Hz is not significant for Sequoyah Nuclear Plan (Closed) Deficiency D3.3-4 - Alternate Pipe Support Criteria Deficiency 3.3-4 documented TVA's failure to promptly address two nonconfor-mance reports that TVA prepared in 1982 to detail problems with theNRR fieldis routed (alternately analyzed) piping program at Sequoyah Nuclear Plan NRR reviewing TVA's corrective action program to address this deficienc evaluation of the adequacy of the alternate pipe support criteri separately documente inspectio .
(Closed) Deficiency D3.3-5 - Pump Fundamental Frequency
The team noted that TVA failed to procure and install floor-mounted in the FSAR. pumps TVA's to
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.the 33 Hz minimum frequency criterion specified for pumps The pump procurement specifications had not incorporated e fied in Deficiency 03.3-5 indicated that the pump baseplate was flexibl. and exhibited a natural frequency below 33 Hz. The team was concernedIn that the addition piping downstream of the pump might not be seismical identified in Deficiency 03.3-5, the team asked TVA to address t implications of Deficiency 03.3-5. inspected the floor-mounted pu rigid, since TVA had grouted the pump baseplate and the TVA vendor's also pum model had not incorporated this additional baseplate rigidit indicated that the pump baseplate had been grouted in accordance with st installation procedures. TVA will be amending the FSAR to drop the minimum This item frequency criterion as a requirement for pump seismic qualificatio is close (Closed) Observation No. 3.1 - Documentation of Containment Penetrations i The team found inconsistent documentation of containment penetrations in Unit 2 walkdown package In response to this observation, TVA revised Sequoyah Instruction Letter OBV SIL 1. Design Baseline and Verificati A-40
.
Atiachment A - Insp;cticn Activitics and Observaticns
- , .
-
,
Walkdowns, to provide more detailed guidelines for the documentation Addit'ional penetrationofdata containment penetrations in walkdown package for completed walkdown packages can be obtained by supplemental walkdowns as required by the DNE system engineer. This observation is close .
(Closed) Observation No. 3.2 - Margins of Safety for Restart The NRC noted TVA's issuance of interim revisions to several general design criteria to be used for Sequoyah restart which specified reduced margins of safety. NRR is reviewing the TVA program whichThis addresses this observatio item is therefore closed NRR resolution will be separately documente for the purposes of this inspectio (Closed) Observation No. 3.3 - Control of Dual Qualification Criteria Observation No. 3.3 indicated that TVA did not have a procedure to ensure that hardware qualified to interim criteria which specified reduced margins of safety criteri would be requalified to the default requirements of th July 24, 1986 to establish temporary control over the use of interim restart TVA issued SQEP-33, SQN Post-Restart Activity criteria. On August 21, 1986, Tracking, which controls work items that require work to be done after restar This observation is close (0 pen) Observation No. 3.4 - Pipe Support Design Criteria Observation No. 3.4 noted that two design requirements'specified in a Watts Bar procedure used to design and modify pipe supports at Sequoyah Nuclear Pla
were not included in the Sequoyah design criteria which TVA issued on June 23, 198 The team Observation considersN TVA's initialopen 3.4 remains action to resolve pending TVA's confirmationObservation N to be inadequat that floor and wall sleeves subjected to piping axial loads are qualified for these load Observation No. 4.1 - Rationale for Selection of Design Basis Events (Closed)
The team noted that TVA'sThis rationale forisselection observation considered of events closed as a within scope was not precisely define result of several actions taken by TVA:
(1) Revision 3 to calculation SQN-0SG7-048 was issued with clarific the rationale used to establish the systems required for restar (2)
The EA operations discipline reviewed the Emergency Operating Instruction and determined that no instrumentation and valves required to mitigate Chapter 15 events had been excluded from the system boundaries of the calculatio A-41
, _ _ - _- _ _ _ _ _ _ . _ - - . _ -. - _ - _ . __ _ _ _ . _ . . _ . - . . _ - __
Attachment A - Inspecticn Activities and Ohservatsr'ns
!
(0 pen) Observation No. 4.2 - Definition of ' Reactor ! Protection System amd Neutron Monitoring Sy' stem Scope The team identified that an explicit definition of system boundaries fur these two systems had not been provided in TVA cc7culation SQN-OSG7-048 or its associated marked up drawings. These documt.nts have been used to identify the TVA issued DBVP systems needed and their scope boundaries for; plant restar Directive 86-020 on November 21, 1986 stating that written descriptions of flow paths linking components for these two systems would be added to the TVA calculation, and that reactor protection system sketches would be prepared to augment the text material. TVA also indicated This item thatremains existingopen drawings pendingforTVA the neutron monitoring system would be use confirmation of corrective action.
.
(Closed) Observation No. 4.3 - Criteria for Sampling Project Work Products for EA Oversight This item is considered closed based on the team's review of the project
'
response to EA Action Item 010. This response sets forth adequate criteria for sampling. These criteria were added to a revision of the EA oversight review pla (0 pen) Observation No. 4.4 - Spray Shield Commitment / Requirement for Certain Hydrogen Igniters in Upper Compartment In their response to EA action item N-22, the DBVP project has committed to revise section 3.7.2 of SQN-DC-V26.1 (Reference 7) to include the requirement for enlarged spray shield for the igniters of the combustible gas control
! system. This will remain open as a confirmatory ite (Closed) Observation No. 4.5 - Clear and Consistent EQ Requirements In Design Criter The statement of environmental qualification requirements was found to vary in an inconsistent manner among several TVA design criteria documents reviewed by the team. The team identified the combustible gas control system design criteria document as one example where possible misinterpretation by users could occur. TVA developed improved wording for the environmental quaUifica-
'
i tion requirements, and has revised section 3.3 of Design Criteria SQN-DE-V-26.1 l
t- for his system. This action resolves this observatio )
(Closed) Observation No. 4.6 - Missing Criteric for Neutron Monitoring System The team reviewed the Westinghouse neutron monitoring system criteria wnile it was still in draft form and noted the omission of two requirements. Ir this document, the indication of source range flux outside the control room f.or safe l
! shutdown and the specification of special high impedance requirements for containment electrical penetrations had not been addressed. TVA has committed during phase 2 to modify the neutron monitoring design criteria to reflect or reference the source range flux indication requirements currently statetl in the remote shutdown design criteria document (i.e., SQN-DC-V-2.17). TVA has also '
stated that the neutron monitoring system design crHteria document referrences A-42
, - - . - - - --, . . . - - - - _ , . - . - . - - - - . . - - - - . . - - . - - - . - ,. . - ----
Attachment A - Insp cticn Activities cnd Observations IEEE Std. 317 for containment electrical penetrations and that this standard contains appropriate technical requirements regarding impedance, frequency, and pulse transmission characteristics of coaxial and triaxial penetration assemblies. Hence, this observation is close (Closed) Observation No. 5.2 - Technical Attributes of Design Verification Procedures This observation was related to missing technical attributes in the SQEP-12 procedure checklist. The team verified that these attributes have been added to the current revision of SQEP-12. This action is considered acceptable to the team and this observation is close (Closed) Observation No. 5.3 - Test Acceptance Criteria This observation was related to the use of old test acceptance criteria for the modified system for test adequacy evaluation pursuant to the SQEP-14 procedur The team noted that the current revision of this procedure addresses theistest This acceptance criteria using post modification and functional test acceptable to the team and this matter is considered close ' (Closed) Observation No. 5.6 - Cable Sizing for Overload Currents This observation related to the cable sizing design criteria which instructed the use of 125% full load current instead of performing a case-by-case analy- The si The team noted that project has issued standard DS-E12-6-3 Re team reviewed this document and found that it addresses allisofacceptable This action the upratingandand derating factors related to power cable sizin this matter is considered close (Closed) Unresolved Item US.3-2 - Sizing Calculations The team identified missing calculations for the evaluation of electrical The issue of the adequacy and completeness of TVA's elec-equipment ratings.trical calculations has been transferred to NRR for review and res therefore, this item is closed for inspection purposes.
i' (Closed) Unresolved Item U5.3-5 - Lo-s of Control Power Annunciatio This item documented TVA's failure to implement a bypassed and inoperable status monitoring system in accordance with TVA's commitment to Regulatory Guide 1.4 TVA informed the NRC of their intention to remove the Station Monitoring System (SMS) and to combine this system with the Safety Parameter Display System (SPDS) at the technical support center in a letter dated Septem-ber 13, 1982. TVA removed the SMS but experienced difficulty in combining the SMS and SPDS. The team was concerned with this problem because TVA did not promptly inform the NRC that it had not combined the SMS and SPDS, and co ued to operate the plant without fulfilling this commitment for approximately three year This item has been transferred to NRR for review and resolution, and is closed for the purpose of this inspectio A-43
.. .-. -_- .
Attichment A - InspIcticn Activitics and Obscrvations (Closed) Unresolved Item U5.3-4 - Diesel Generator Loading Calculations This item was related to errors in the diesel generator rating and load se-The adequacy and completeness of electrical calcula-quencing calculations.tions, including diesel generator calculations, has been This item is closed for the purpose of this inspectio review and resolutio (0 pen) Deficiency 05.3-1 - Temporary Alterations Using TACFs This deficiency related to the programmatic control of temporary modification The team was informed that TVA is in the process of revising the applicable This item procedures and expects to complete the revision by January 2, 198 remains ope (0 pen) Unresolved Item U5.3-3 - Motor Operated Valve Thermal Overload Trip Setting This item related to the verification of the trip settings of motor operated valve thermal overloads to assure that premature tripping will not occur during The team was informed that TVA intends to perform a case-accident condition This item remains ope by-case analysis in the near futur (0 pen) Observation No. 5.1 - Walkdown Scope This observation is related to a team concern regarding the incomplete walkdown scope in the electrical and I&C areas, and the lack of cross references The team was between the DBVP project effort and other TVA verification program informed that TVA's response to this observation will be forwarded to the NRC in the near future. This item remains ope (0 pen) Observation No. 5.4 - Design Criteria This observation is related to TVA's failure to perform an independent verification of the list of commitment / requirements (C/Rs) which Impell compile The team was informed that a TVA response to this observation This item remains ope will be forwarded to the NRC in the near futur (0 pen) Observation No. 5.5 - Commitment / Requirement Inclusion in Design C ria for the Auxiliary Power System This observation is related to the emission of some applicable C/Rs from design criteri TVA plans to complete corrective action relating to this observation This in the near future, and will inform the NRC of their action at that tim item remains ope (0 pen) Deficiency D6.1-1 - AFW Pump Discharge Pressure Switch Ratings i
The team identified that three instrument data sheets used to specify the original pump discharge pressure switch and two subsequent replacements A-44 l
l
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- _ _ _ _ _
Att chment A - Insp:cticn Activitics and Observ tions t it contained rating inconsistent technical values for pressure, voltage differences among these three data sheets; however, This item remains this material was not available for review by the team during this inspectio data sheets open pending TVA's justification of the differences in these l t (0 pen) Deficiency D6.1-2 - Feedwater Bypass Control dValve to Solenoid Re Replacement solenoid valves did not meet the Class functio E In requirements n assure accomplishment of the required feedwater isolation safetyld be h Unresolved the TVA response, a procedure change was to be implemented for te Safety Question Determination to assure that required safety d to functions wou identified and tracked. In addition, preparationi of aen.new ECN was co correct this specific problem. review by the team during this inspection; hence l tion (0 pen) Deficiency D6.1-3 - AFW Pump Suction Pressure been Switch Setp h
The team identified that TVA calculation The TVA SQN-CA-D setpoint value changes were implemented by several dECNs in March i to in 198 response indicated that a revised setpoint calculation was i n update or supersede previous setpoint calculations.al was avail (Closed) Deficiency D6.2-1 - Reactor Coolant System Narrow Range Re Temperature Detector Qualification Category Change in Temperature detectors used for reactor protection system trips were c 1983 from environmental qualification category A (i.e. fully qualified i ) for harsh environment) to category C TVA ( not required fo immediately 279-1971 and NUREG-0800 Branch Technical Position ICSB 26. The team revie issued a change to restore these detectors to category Sequoyah's environmental qualification binder Hence, this ITE-002 item is which confirme appropriate corrective action had been implemente close (0 pen) Deficiency D6.3-1 - Specification of Hydrostatic Test to Demon Instrument Pressure Boundary Integrity After Seismic Qualification Testin i re During site procurement of instruments Two examples needed were to s test after the seismic qualification testsperformed One vendor had were complete this test, but another vendor j reviewed by the tea ,
had no The TVA response stated that onsite pressure switches d to would be te j
to 2982 psig and the ones used for seismic qualification would be t
3000 psig by the supplie However, the TVA response was less d and i
pressure integrity had been demonstrated. clear about whether futu A-45
,
.. _ -_ _ _ _ _ _ _ _ _ . . _
Attachment A - Insp:ction Activitics rond Obs:rvretiens seismic category I non-Class 1E instruments would The team reviewed TVArequire pressure int specification tests following seismic qualificatio SS-E18.742 for safety-related pressure and differ the design hydrostatic pressure value) was tio required Because for seismic category I non-safety-related (i.e. I (L)) instrument the TVA position regarding I (L) instruments was not currently Pendingdocumen team requested that TVA provide a specific response on this issu receipt of that response, this item remains ope t (Closed) Unresolved Item U6.3-2 - ECN Quality Assurance and Se Designations The team had noted inconsistency in the designation of quality assurance The team applicability and seismic analysis requirements The wording of a TVA for a his characteristics during their review of individual ECN issu Hence, this item is close (Closed) Observation No. 6.1 - Manually Initiated Safety-Related Act The team had noted that manually initiated safety-related actions had specified in the development of NRC Regulatory Guide 1.97 Type A monitoring instrumentation variable implementation of Regulatory Since Guide 1.97 a separate was isfor program the fall inof anticipated 1987 outside the bounds of the DBVP.1987 for implementation of Regulat
.
(0 pen) Observation No 6.2 - Neutron Monitoring Detector Qualific Westinghouse indicated that failure of unqualified ex-core neutron dete tic could result in automatic withdrawal of control For the upcoming Sequoyah fuel ro reactor trip in approximately 15 second ii cycle, Westinghouse has determined that During thedepart it not need to be environmentally qualified fori harsh co l was noted that "no" responses were provided for the following quest ons:
(4.3) May the possibility of an accident which is different than any already evaluated in the FSAR be created?
(4.4) Will the probability of a malfunction of equipment important-safety previously evaluated in the FSAR be increased?
(4.5) Will the consequences of a malfunction of l
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A-46 l
Attachment A - Inspecticn Activities and Obs:rvaticns (4.6) May the possibility of a malftinction of equipment important to safety different than any already evaluated in the FSAR be created?
(4.7) Will the margin of safety as defined in the bases to any technical specification be reduced?
The team did not find that these "no" conclusions were adequately supported by the data provided with the Westinghouse analysis; consequently, the team requested that explicit justifications be provided to support the response to each of these question In addition, the team reviewed responses prepared by TVA's Nuclear Power Plant Operations Review Staff for SCR SCNNEB8609 Revision 0 dated July 2,1986. The justification for continued operation stated that the issue was only an envi-ronmental qualification documentation problem, that no FSAR revision was required, and that the deficiency did not adversely affect safe operation of the plan Since the Westinghouse analysis was not available until November, the team questioned how Nuclear Power could reach such conclusions four months earlie The team was informed that Nuclear Power viewed the entire concern as only an environmental qualification documentation issue. The team does not agree with this narrow perspective; hence, an improved justification of their evaluation was also requeste This item remains ope (0 pen) Observation No. 6.3 - Consistency in AFW Turbine Controls Walkdown Scope The team had noted inconsistencies in the inspection of components for the
-
turbine AFW controls between the unit 1 and unit 2 walkdowns. TVA indicated that different teams had performed each walkdown. The team considers this to be an acceptable response except for the issue of instrument line walkdown Hence, this issue is being held open in concert with Observation No. 5.1. At l this time, TVA has presented several concepts for consideration by the EA oversight team; however, a definitive scope of the instrument line walkdowns has not been established. TVA should provide a definitive plan that explicitly describes those instrument lines that will be walked down. This item remains open.
!
(Closed) Observation No. 6.4 - Conduit Box Covers and Installed Cable Pull Rope During a plant walkdown, the team noted a missing cover on a conduit box that also had a cable pull rope hanging from the box. The rope has been pushed up The team reviewed existing
,
l into the conduit and the cover has been replaced.
l maintenance instructions that control the replacement of conduit covers. On this basis, this item is closed.
l (0 pen) Observation No. 6.5 - Replacement Part and Equipment Qualification During the team's review of several design criteria documents, inconsistent wording was noted for environmental qualification requirements applicable to components and replacement parts. The team specifically requested that TVA develop criteria where the use of IEEE Std. 323-1971 might be permitted. TVA has developed the new text, but has not prepared a design input memorandum to A-47
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Attachment A - Insp2ction Activities and Observations This item remains open pending TVA's commence the implementation proces actions needed to implement the chang (Closed) Observation No. 6.6 - Auxiliary Control Air System Design Criteria Three design basis commitments and requirements had not One been issue implemented design criteria document for the auxiliary control air system.
- concerned the specification of a 3 second time delay relay in the compressor TVA extensively reviewed this requirement and determined control circui that this particular time delay was not required to be specified in the design The team agrees with the TVA position on this item as the criteria documen A second issue con-exact time delay is determined by the equipment vendo cerned upgrading of the air supply for containment radiation monitoring isola-In this instance, the commitment was deemed to be unclear as to tion valve the determine meaning of " upgrading" to the point where definitive a In this instance, TVA confirmed containment to prevent adverse interactio that the implemented design was satisfactory; hence, this item is close (0 pen) Observation No. 6.7 - Oil Free Compressed Air Requirement
' The team identified a commitment for oil free compressed air from Westinghouse that did not appear in the design criteria document for the auxiliary control
air syste The team reviewed the proposed resolution of this item with TVA Hence,
i and determined that the change would be satisfactory once implemente this item remains open pending the preparation of a design input memorandum t 1 implement the revised text in the design criteria document.
,
a (Closed) Observation No. 6.8 - Single Failure Design Criteria Several concerns were raised by the team regarding definitions and criteria In a statements provided in the TVA single failure design criteria document.
,
meeting among TVA, EA, and team participants, a satisfactory resolution was reached for consideration of the loss of offsite powe The EA representatives will continue to monitor this issue until the design Because of the active role taken by EA to assure criteria document is revised.
l
!
an eventual closure of this observation, and the fact that no violation of the single failure criterion has been found during the extensive review of ECNs all parties, the team has closed this item.
l (0 pen) Deficiency 04.3-1 - Evaluation of Structures for Reinforcing Bar Cu l The initial NRC design control inspection (86-27) had iden
- ' Since then, the DBVP and EA have identified other examples of this situation, TVA still needs to perform a technical evaluation making it a generic issu of these reinforcing bar cuts. This item remains open.
t A-48
. _. . . _ _ _ ._ . _ _ _ ._ _ _ _ _ _... _._ _ _ _ _ __ ______-______
Attachment A - Insp;cticn Activities tnd Obssrvatiens (0 pen) Deficiency D4.3-3 - Steam Generator Access Platform Design The initial inspection identified that the steam generator lower supports were not evaluated for permanently attached platform loads. During walkdown of these supports, TVA identified additional piping and supports that are attached to these lower supports. They have contracted an evaluation of the lower supports to Westinghouse, which is still performing this work. Therefore, this item remains ope (Closed) Deficiency D4.3-4 - Cable Tray Support Response Spectra The team found that an improper response spectra curve was referenced in a calculation. TVA, in their response, stated that the correct response spectra curve was used in the design, but the NRC inspector was given the wrong revi-sion of the response spectra report (CEB Report 8-20). The team reviewed the correct response spectra curves and agrees with the TVA statement. This item is close (Closed) Deficiency D4.3-5 - Loads on Cable Tray Supports During the initial NRC inspection, the team found that cable tray support design did not consider the 75 pounds per linear foot load on the top tray as stated by TVA design criteria. TVA, in their response to this deficiency, stated that this load was intended to be applied as a construction load case only. TVA has investigated this load case in Significant Condition Report SCRSQNCEB862 Team review of the calculations related to this SCR shows that structural adequacy of the supports are not affected by this loading conditio This item is closed.
!
(Closed) Deficiency D4.3-6 - Torsional Shear Stress Effects on Weld Design In the design of certain cable tray supports, TVA did not consider the effects of torsional shear stresses during an earthquake due to the asymmetrical geometry of the supports. TVA has issued Significant Condition Report SCRSQNCEB8622 to resolve this issue. The calculations performed for this SCR show that TVA selected 25 worst case cable tray supports and evaluated these for torsional effects. All welded joints were structurally adequate to carry the extra shear stresses. This item is close (Closed) Unresolved Item U4.3-7 - Cable Tray Support Base Plate Analysis NRC inspection 86-27 identified that certain surface mounted base plates for cable tray supports were designed without consideration of baseplate flexibi-lit TVA has evaluated this condition in the calculations performed for Significant Condition Report SCRSQNCEB862 These calculations show that 40 baseplates were evaluated for flexibility and found to be structurally adequat This item is close A-49
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Attachment A - Insp;ction Activities and Observations (Closed) Observation 7.1 - Inconsistency in Walkdowns During the system walkdowns, TVA did not show penetration X-46 on drawin 47W-809-7 R7 since it was "out of function". TVA has not should have marked this penetration to make the drawing accurat determined a policy regarding verifying the depiction of "out of function" The identical issue is identified and left open in systems on drawing Observation No. 1.3. This observation'is close (0 pen) Observation 7.2 - Commitments / Requirements Related to Drilled in Anchors During their review of Commitments / Requirements database, TVA did not eval those C/Rs that were related to drilled in anchors for inclusion restart criteri Criteria SQB-DC-V-1.0, which includes a listing of the C/Rs which are gene and therefore applicable to all safety system This list a list showing where these C/Rs are captured in design documents.This observation is ke also shows whether a C/R is a restart item or no open pending the issuance of this design criteri (0 pen) Observation 7.3 - Revision of Design Criteria for Restart TVA commitment SQNCEB-CG1170 stated that attachments to the reinforce walls be made only using through wall bolt that a revision to the design criteria SQN-DC-V-1.1.1 was necessary to capture this commitmen Appendix B to the draft general civil design criteria SQN-DC-V-1.0 This prepared by TVA shows that the criteria will be revised to observation will be open pending the issuance of this t this commitmen general design criteria and the inclusion of the commitment in design c SQN-DC-V-1. Observation Nos. 8.1- Several concerns were identified during Inspection 86-45 by team members fro These observations related to l
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the NRC Office of Nuclear Reactor Regulation. reviews of interim supports containment isolation design criteria, and cable tray design IE considers these observations to be open licensing issuesthese Consequently, that will are be independently resolved by NRR and the license considered closed for inspection purpose A-50
Attachment B - Mestings and References B.1 Meetings Table B.1 provides a matrix of meeting attendance and principal persons contacted for the eight meetings conducted at Sequoyah Nuclear Plant site in Soddy Daisy, Tennessee. Other licensee personnel were also contacted. The following paragraphs summarize the general purpose of these meeting Meeting 1: On September 30, 1986, the NRC held a meeting to determine the status of TVA's DBVP and oversight work at SQN, and to plan an inspection of modifications within the DBVP scop Meeting 2: On November 3, 1986, the NRC held an entrance meeting. The NRC reviewed the inspection team's plans to inspect ECNs within the scope of the DBVP, to evaluate TVA DSVP project's ECN review and to evaluate TVA's engineer-ing assurance oversight of the DBV Meeting 3: On November 5, 1986, TVA presented the team an overview of the DBV Meeting 4: On November 7,1986, the NRC inspection team held an interim status meeting to brief TVA on the inspection team's findings for the on-site inspec-tion the team conducted on November 3- Meeting 5: On November 7, 1986, TVA presented an overview of the technical calculation reviews which the various engineering branches (EEB, CEB, MEB, and NEB) were conducting in TVA's Knoxville office ' Meeting 6: On November 21, 1986, the NRC inspection team held a second interim status meeting to brief TVA on tM inspection team's findings for the on-site inspections conducted on November 3-7 and 17-2 Meeting 7: On December 1, 1986, the NRC held a meeting to summarize the inspec-tion team's plans to review TVA's responses to NRC inspection reports 86-27, j
86-38 and 86-45.
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Meeting 8: On December 4, 1986, The NRC held an exit meeting to summarize the results of the inspection team's on-site inspection for the periods November 3-7, 17-21, and December 1-4.
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B-1
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Attcchment B -
Mettings and References Table B.1 MEETINGS Name Organization Title Meeting Attended 1 2 3 4 5 6 7 8 REArchitzel USNRC-IE Team Leader x x x x x x x x SVAthavale USNRC-IE NRC-Electric Power x x x x x x PEHarmon USNRC-RII Resident Insp., SQN x x x ADuBouchet NRC-Consultant NRC-Mech. Components x x x x x x x FJMollerus NRC-Consultant NRC-Mech. Systems x x x x x x AIUnsal NRC-Consultant NRC-Civil / Structural x x x x x x EVImbro NRC-IE Section Chief x x x x x WBelke NRC-IE NRC-QA x x x x x LStanley NRC-Consultant NRC-Instr./ Controls x x x x x JFWeinhold TVA-DNE EA Manager x x x APCappozzi TVA/S&W Consultant - EA x x x x x MPBerardi TVA-EA EA Oversight Ad x x x x x x x AWLatti TVA-DNE Advisor DNE Mg x x x RPSvarney TVA-EA Civil /Struct. Eng x x x x x JPLittle TVA-MEB Supervisor x JPDurham Impell Consultant x JFCox TVA-DNE Ast. PE SQEP-K x x x x x FAKoontz TVA-DNE Gr. Head T/H & x BHall TVA Licensing-Sequoyah x x x x x x x x DGRenfro TVA-DNE Nuc. Eng x x x x x JvonWeisenstein TVA-DNE Ch. Tech. Audits x x x x AHRitter TVA-DNE Engrg. Assur. Eng x JWKelly TVA-DNE Engrg. Assur. Eng x x TGCarson TVA-DNE EA Reviewer x x x DRBarnaby TVA-DNE Mech. Eng x x RTucker TVA-DNE Mech. Eng x SAShuman TVA-DNE Mech. Eng x x x x x l SLong TVA-DNE Walkdown Mg x x EWSteinhauser TVA-DNE Mech. Disc. Eval. x x JRRupert TVA-DNE Civil Disc. Eval. x x x BKWilliams TVA-DNE Nuc. Disc. Eval. x WMMatejek TVA-DNE Elec. Disc. Eval. x x x TESpirn TVA-DNQA Proj Engr x GBKirk TVA Comp. Lisc. Sup x x LMNobles TVA Supt. Ops. & Engr x WEAndrews TVA Site Qual. Mg x PHolmes-Ray NRC-RII Sr. Res. Ins x x MTTormey TVA-DNE Advisor x x x BMGore TVA-DNE Princ. Engr.Elec. Lead x x x x x RWhitt TVA-DNE Elec. Eng x PPFiliak W-Nuc. Safety Sr. Engr. Des. Base x JHutson TVA-DNE Asst. Br. Ch., EEB x RKCothren TVA Asst. Mgr x x RJFaubert TVA-DNE Reviewer x x x CEGrass TVA-DNE I&C Engr x x B-2
Attachment B - Meatings and References Meeting Attended Name Organization Title 1 2 3 4 5 6 7 8 Prin. Nuc. Eng x KKeith TVA-DNE x WJKagay TVA-DNE Asst. Civil. Lead Eng Elec. Engr x x x KFliao TVA-DNE x x Tech. Engr DBVP x REDaniels TVA-DNE x x Civil Eng ABSavery TVA-DNE x x x x TVA-DNE DBVP Supv JEStaub NRC-Nuclear System x JANevshemal NRC-Consultant x x TVA-DNE Elec. Eng JWSemore x TVA-DNE Mech. Engr. Asso DWFolks x DBVP Oper. Coor J mcGriff TVA-0PER Systems Engr x AKGeer TVA-0PER x x TVA Licensing-SQN MCooper x NRC-RII Sr.Res.Insp-WBN MWBranch x TVA Nuc. Engr.-Compliance FMashburn x x TVA-DNE Nuc. Engr ARRice Modification Mg x RW01 son TVA-DNE x TGChapman TVA Act. Proj. Engr. -BFN x
HAbercrombie TVA Site Director-SQN x TVA Plant Manager-SQN PRWallace Maintenance Supr.-SQN x BPatterson TVA x TVA Plant Supt.-SQN LMNobles x TVA Design Base. Pgm. Mgr.- WBN GWCurtis DBVP Lead Engr. - BFN x HECrisler TVA-DNE Conf. Mgmt. Pro MBHolland TVA x Mgr. - BFN x
RJFloyd TVA-DNE EA Auditor x TVA-DNE DBVP Lead Engr. - BFN JFMurdock x CHFox, J TVA-0NP Asst. Mgr. Nuc. Power x
NRC-IE Deputy Dir. - DQAVT 9 HJMiller x JHSmith TVA SQN Restart Task Force TVA Asst. Proj. Mgr. -
SDLove x WBN ECAP x
TVA-DNE Lead Mech. Eng JCKey x RWCantrell TVA-DNE Division Di x JBlankenship TVA Mgr. Info. Svc x DWWilson TVA Proj. Eng x (
TLHoward TVA Qual. Surv. Supv x l
TVA Site Lic. Mg MRHarding x J0wnby x TSpink Lead Nuclear Eng xx xx x x x l TVA-DNE l HLJones l
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Attachment B -
Meetings and R:;ferences B.2 REFERENCES (1) TVA Design Criteria, SQN-DC-V-13.9.9, Component Cooling Water System.
(2) EN DES Calculations, B44 860402 005, CCS Load List.
(3) EN DES Calculations, B44 850822 015, Essential Raw Water Cooling (ERCW) -
Summary of Equipment Flow (4) Letter and enclosure, R. Gridley, TVA, to Dr. N. Grace, USNRC Region II, regarding Sequoyah Nuclear Plant Units 1 and 2 NRC-0IE Region II Inspection Report 50-327/86-27 and 50-328/86-27, " Response to Deficiencies and Unresolved Items."
(5) Memo from C.Y. Wang, "Sequoyah Nuclear Plant - Supplemental Walkdown Instructions for the Design Baseline and Verification Program," May 7, 198 (6) Letter TVA-86-609, Westinghouse Electric Corporation to TVA, Tennessee Valley Authority Sequoyah Unit 2, Commitment Requirement Review, July 16, 198 (7) TVA Design Criteria, SQN-DC-V-26.1, Combustible Gas Control Syste (8) Inspection Report 50-327/86-27 and 50-328/86-27, forwarded by J. Taylor letter dated April 22, 198 (9) Letter Acknowledging Receipt of Response to Inspection Report 50-327/
86-27 and 50-328/86-27, G. Zech, NRC RII, to S. A. White dated August 12, 198 ,
(10) Inspection Report 50-327/86-38 and 50-328/86-38, forwarded by J. Taylor letter dated September 15, 198 (11) Inspection Report 50-327/86-45 and 50-328/86-45, forwarded by J. Taylor letter dated October 31, 198 (12) Letter Requesting Additional Information Relating to Inspection Report 50-327/86-27 and 50-328/86-27, J. Taylor, NRC IE to C. C. Mason dated October 30, 198 l l
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