IR 05000327/1986056
| ML20148D102 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 03/17/1988 |
| From: | Richardson S NRC OFFICE OF SPECIAL PROJECTS |
| To: | White S TENNESSEE VALLEY AUTHORITY |
| References | |
| NUDOCS 8803230310 | |
| Download: ML20148D102 (10) | |
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'l4 MAR 171988 Docket'Nos. 50-327/328
Tennessee Valley Authority ATTN: Mr. S. A. White Manager of Nuclear Power 6N 38A Lookout-Place 1101 Market Street Chattanooga, Tennessee 37402-2801 Gentlemen:-
SUBJECT:
CLOSURE OF NOTICE OF VIOLATIONS AND INSPECTION REPORT 50-327, 50-328/86-56, DATED JANUARY 28, 1987 The purpose of this letter is to address the TVA responses submitted.as a Lresult of the Notice of Violation and inspectiun report findings which are applicable to the Sequoyah Nuclear Plant.
Enclosure 1 provides a summary of the issues (violations and findings) iden-tified as a result of the _NRC inspection and the resolution of each of the issues based on TVA actions and NRC review.
Enclosure 2 provides a listing of the key documents relevant to these issues.
Based on our review of the TVA responses and actions, the issues raised as a result of the original special inspection are considered by the NRC staff to be resolved. This letter serves as the closure for the Sequoyah Nuclear Plant on these issues.
If there are any questions, please contact this office.
Sincerely,
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Ongleu signeo o,
Steven D. Richardson, Acting Director TVA Projects Division Office of Special Projects Enclosures:
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Resolutions 2.
Relevant Documents cc w/ enclosures:
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Mr. S. A. White
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Tennessee Valley Authority Sequoyah Nuclear Plant cc:
General Counsel Regional Administrator, Region II Tennessee Valley Authority U.S. Nuclear Regulatory Comission 400 West Summit Hill Drive 101 Marietta Street, N.W.
E11'B33 Atlanta, Georgia 30323 Knoxville, Tennessee 37902 Resident Inspector /Sequoyah NP Mr. R. L. Gridley c/o U.S. Nuclear Regulatory Comission Tennessee Valley Authority 2600 Igou Ferry Road SN 157B Lookout Place Soddy Daisy, Tennessee 37379 Chattanooga, Tennessee 37402-2801 Mr. Richard King
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Mr. H. L. Abercrombie c/o U.S. GAO Tennessee Valley Authority 1111 North Shore Drive Sequoyah Nuclear Plant Suite 225, Box 194 P.O. Box 2000 Knoxville, Tennessee 37919 Soddy Daisy, Tennessee 37379 Tennessee Department of
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Mr. M. R. Harding Public Health Tennessee Valley Authority ATTN:
Director, Bureau of Sequoyah Nuclear Plant Environmental Health Services P.O. Box 2000 Cordell Full Building Soddy Daisy, Tennessee 37379 Nashville, Tennessee 37219 Mr. D. L. Williams Mr. Michael H. Mobley, Director-Tennessee Valley Authority Division of Radiological Health 400 West Sumit Hill Drive T.E.R.R.A. Building W10 B85 150 9th Avenue North Knoxville, Tennessee 37902 Nashville, Tennessee 37203 County Judge
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Dr. Henry ny:es, Science Advisor Hamilton County Courtnouse Comittee on In;. rior Chattanooga, Tennessee 37402 and Insular Affairs U.S. House of Representatives Washington, D.C.
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ENCLOSURE 1 RESOLUTIONS
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1.
Violation A, Sample #1 Issue: TVA was cited for failing to report a condition considered to be reportable under the requirements of 10 CFR 50.73 within 30 days after discovery. TVA had determined by March of 1984 that there were conditions at the Sequoyah plant where spray from the failure of non. seismically qualified piping could affect Class 1E electrical safety ecuipment in the auxiliary, control, and diesel generator buildings. TVA had identified this issue in Nonconformance Report SQNCEB8409 which had not been closed at the time of the special inspect:en.
Action: On March 23, 1987 TVA responded to the Notice of Violation, admitting the violation had occurred. The cause was attributed to inadequate CAQ dispo-sitioning. This cause is reidted to the root causes of the shutdown of the Sequoyah nuclear plant which were weaknesses in such areas as organizational structure, management accountability and the corrective action process. TVA has taken actions to prevent recurrence of these causes as described in Volumes 1 and 2 of the NPP.
The NRC staff has agreed to the acceptability of the changes made in the TVA management structure and corrective action program specifically for Sequoyah in the Safety Evaluation Report (SER), dated January 21, 1988, in Sections 4.2 and 4.3.1.
TVA submitted an LER (SQR0-50-327/87-020) on April 17, 1987 which addressed the technical aspects of the issue. Walkdown inspections were performed by TVA to identify ar i document the postulated hazards of water spray from piping that was not tiesigned and installed for pressure boundary integrity under all loading cases.
Class 1E electrical equipment in the hazard areas has been identified and those Class IE components which could possibly have their function impaired have been protected either by ensuring pressure boundary integrity of the piping or by sealing or shielding the Class 1E equipment against water spray. An engineering change notice (ECN L6770) was issued to accomplish the necessary modifications. The electrical engineering branch issued Work Package (WP) 12243 to seal conduit threaded connections within 10 feet of the Class IE electrical equipment end devices as identified on the piping hazards identification data sheets (PHIDS). The civil / mechanical work associated with the ECN was addressed by WP12231. Work under these two WP's has been completed.
The NRC performed an inspection during the period of March 23-27, 1987 of work completed under WP12243 with only minor comments. This was reported in NRC Inspection Report Nos. 50-327, 328/8/-20, dated April 24, 1987. TVA finished work for Unit 2 on July 20, 1987. NRC inspection followup on the LER has also
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-2-been performed during the period of November 6 - December 5, 1987. As a result, the corrective action taken to resolve the issue is complete. This has been reported in Inspection Report 50-327, 328/87-71, dated January 22, 1988.
Based on the information supplied by TVA and the independent inspection infor-nation obtained by the NRC staff, the issues arising from Violation A as derived from Sample #1 are considered closed.
2.
Violation B, Sample #1 Issue: TVA was cited for not following one of their internal procedures related to a notification of a Standards Board as a result of deviating from a
design standard, Action: TVA responded to the Notice of Violation on March 23, 1987 by denying the violation.
Several reasons were provided for the TVA position, NCR SQNCEB 8409 had been issued at the time the violation was noted and it a.
identified action required for the plant to meet the Design Standard.
TVA had the intention to follow through with corrective action but the work had not been completed at the time of the inspection,
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The corrective action taken consisted of identifying the piping hazards on piping hazard identification data sheets, and protecting piping by modification to ensure pressure boundary integrity or by sealing or
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shielding against water spray. Unit 2 design and modification work has been completed and remaining Unit 1 work is scheduled for completion prior to restart.
I Not reporting the incident to the TVA Standard Board chairman is not a c.
violation of "EN DES Design Manual-Statement of Policy" dated May 2,1977
since such reporting requirement applies only when the approved design standard cbanot be used for either technical or other valid reasons and l
l TVA intended to use the design standard.
The NRC staff concurs with the TVA additional information and assessment and, therefore, the denial of Violation 8 of the inspection report is accepted.
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Violation C.I., Sample #7 l
Issue: TVA was cited for not pronptly correcting a known design deficiency
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(NCR SQNCEB 8301) related to the support of the diesel generator exhaust lines under the faulted loading combination which includes the safe shutdown earth-quake. There were also no supportable engineering facts or analyses which l
would justify the position of no corrective action on the part of TVA.
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Action: TVA responded to the Notice of Violation on March 23, 1987 by admitting that the violation did occur. The cause was attributed to inadequate CAQ dispositioning. TVA has taken actions to prevent the recurrence of the
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-3-weaknesses in the corrective action process as described in Volumes 1 and 2 of the NPP.
The NRC staff has agreed to the acceptability of the changes made in the TVA management structure as well as the corrective action program specifically for Sequoyah in the Safety Evaluation Report (SER), dated January 21, 1988 in Sections 4.2 and 4.3.1.
TVA revised the original NCR in April of 1986 to address the pressure integrity requirements of the piping and analysis problem N2-8203A was completed on August 21, 1986. The evaluation completed indicated that no hardware modifications were required.
-Based on the information supplied by TVA to the NRC staff, the issue arising from Violation C.1. as derived from Sample #7 is considered closed.
4.
Violation C.2., Samples #8 and #9 Issue: TVA was cited for not promptly correcting a condition I'entified nearly d
3-1/2 years before the special inspection which questioned the capability of the alternately analyzed piping to meet the seismic requirements. This issue arose as a result of questions on the analysis techniques and their application.
Action: T'/A responded to the Notice of Violation on March 23, 1987 by admitting that the violation did occur.
The cause was attributed to inadequate CAQ dispositioning. TVA has taken actions to prevent the recurrence of the weaknesses in the corrective action process as described in Volumes 1 and 2 of the NPP.
The NRC staff has accepted the changes made in the TVA management structure as well as the corrective action program specifically for Sequoyah in the Safety Evaluation Report (SER), dated January 21, 1988 in Sections 4.2 and 4.3.1.
As a result of this finding and other recognized problems, TVA initiated a program to review and address the adequacy of piping and pipe supports which had been installed and qualified by the alternate analysis criteria. The specific issues have therefore been encompassed by this larger program for alternately analyzed piping and supports. The NRC staff review summary and acceptance of TVA actions are contained in Section 2.4 of the Sequoyah Safety Evaluation Report (SER), dated January 21, 1988.
The issues for Violation C.2 are considered closed.
5.
Finding from Sample #3 Issue: Two redundant control circuits (one ac and one de) for the turbine
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driven auxiliary feedwater pump were found by TVA to have been routed in the
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same conduit due to a misinterpretation of the design criteria. This had been
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4-identified as an NCR in 1981 and the corrective action had also been determined to be locating the two circuits in separate conduits. As of the spring of 1986 the field work still had not been completed.
Action: TVA indicated in the response on March 23e 1987 that this issue was on
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the list of items to be completed prior to restart. The NRC staff has examined the documents related to the closure of this iten and found that the field work was completed as verified on September 2,1987.
As a result of the TVA action to complete the physical changes this issue is considered to be resolved.
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6.
Finding from Sample #16 Issue: TVA had identified an issue via an NCR relative to drawings being issued prior to the applicable design criteria being developed.
In this instance a situation was found where cable tray supports were attached to the steel containment without the design loading conditions addressing all of the design basis accident (DBA) conditions.
The item was at the time considered by TVA to not be significart.
The NRC requested that the item be re-evaluated and completed prior to restart.
Action:
TVA has revised the NCR to show the failure to consider the accident loading case as not having been addressed during the original design of the cable tray supports attached to the steel containment vessel. An engineering report was completed by TVA and the item was considered for reportability and found not to be reportable.
The NRC staff approved interim acceptance criteria for cable tray supports which were to be met prior to plant startup. These were contained in a letter with the draft safety evaluation report from Youngblood to White, dated December 5, 1986. TVA has reanalyzed the supports considering the OBA loads and has evaluated the effect on the steel containment vessel. As a result of the reanalysis there was a need to modify three existing supports and add twelve new supports. These modifications and additions were made so as to meet the original necessary conditions including the DBA.
As stated in Section 2.5.1.2(1) of the Sequoyah Safety Evaluation Report (SER),
dated January 21, 1988, "the staff and censultcits reviewed sample qualifica-tion calculations and performed a walkdown o# the affected supports. The staff audit team also reviewed selected calculations covering the DBA response spectra generation, thermal and pressure-induced displacements, stiffness of the steel containment vessel (SCV), stiffness at support attachment points, and effects of support loads on the SCV wall and stiffeners.
Based on the audit results, the staff concluded the methods used in re-evaluating the SCV cable tray supports were adequate and that the interim acceptance criteria were appropriately implemented to qualify the supports for the pl6nt restart."
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-5-Based on this effort and the TVA commitment to restore the original FSAR criteria for the affected cable tray supports after restart the NRC staff considers this issue to be closed.
7.
Finding from Sample A2g Issue: TVA identified the inability to retrieve calculation packages related to the design of piping supports on the Watts Bar plant.
Initially this was thought to be a result of errors in coding the document access numbers, but finally led to determining that record calculations were in many cases, missing. Conc (rn over the availability of design calculations extended to other TVA plants and an NCR was written in July of 1984 on Sequoyah. At the time of the special inspection, the issue of missing calculations had no't been adequately addressed and resolved.
Action: As a result of this issue and others raised by NRC inspections as well as circumstances found by TVA to exist, a design calculations program was developed. This was to address the missing, incomplete or outdated calcula-tions.
This also involved defining the essential calculations for the plant.
A new significant condition was defined with its resolution being required prior to restart.
The NRC staff has conducted inspections which addressed calculations. Conclu-sions relative to the design calculations program for Sequoyah are contained in the Safety Evaluation Report (SER), dated January 21, 1988 in Section 2.3.
Based on these actions by TVA and the staf review completed to date, this issue is considered to be closed.
8.
Finding from Sample #54 Issue:
Copes Vulcan solenoids used in solenoid valves for post accident conditions were not specified as Class IE at Bellefonte as discovered by TVA in 1983.
Progression of the in-house review and evaluation by TVA led to the distribution of the NCR in 1985 to other TVA nuclear plants. A more complete review for the Sequoyah plant was deemed to be necessary to assure that the purchasing of equipment was dictated by the qualification of the equipment.
Action: TVA reviewed the specific condition documented in the NCR for applicability to Sequoyah and found that the condition did not impact the facility.
A related generic review conducted by TVA in the fall of 1986 identified Class 1E equipment for use in a mild environment for which adequate seismic qualification documentation did not exist. This becane part of the piece parts issue. The subject area of equipment qualification and piece parts are addressed in the Sequoyah Safety Evaluation Report (SER) dated January 21, 1988 in Sections 3.2 and 3.3.
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-6-The NRC staff has concluded that the issue arising from this finding has been adequately resolved for Sequoyah.
9.
Finding from Sample #61 1ssue: TVA in 1984 identified instances at Bellefonte where the design change report procedures as applied to component supports were not properly _used.
These instances raised the question of the impact of these failures on the design control cf supports for the Bellefonte facility. This question was also considered to possibly be applicable to the other TVA facilities.
Action: TVA has indicated that while the NCR written on Bellefonte did raise the issues for the other TVA facilities nothing had been done to resolve'the
- question at the time of the special inspection. -Subsequently, TVA issued a memorandum to address the issue at Sequoyah.
As a result of that memorandum, dated February 13, 1987, TVA has found that for the Sequoyah plant the design change report was not a document used but was uniquely defined for the Bellefonte project in BLP-EP-44.76.
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Based on this information this issue is closed for Sequoyah.
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ENCLOSURE 2 s
RELEVANT DOCUMENTS
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1.
December 5, 1986, Draft Safety Evaluation Report.
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January 28, 1987 NRC' letter and Report Taylor to White.
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' February 27, 1987 TVA request for time extension to reply =to 3/23/87
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Report, Gridley to Taylor.
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-March.11, 1987 NRC response to 2/27/87 letter granting time extension.
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March 23, 1987 TVA response, Gridley to Ebneter,
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April 17,1987, LER - SQRO-50-327/87-020.
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' April 24, 1987, Inspection Report 50-327, 328/87-20.
8. - - September 16, 1987,-Update to 3/23/87 TVA response for Violation B.
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September 21, 1987, Update to 3/23/87 TVA response for Sample No. 54 as applied to Sequoyah.
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January 21, 1988, Safety Evaluation Report, Sequoyah Nuclear Performance Plan.
11.- January' 22, 1988, Inspection Report 50-327, 328/87-71, e
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Mr. S. A. White.
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_Sequoyah Nuclear Plant SUBJECT: CLOSURE OF NOTICE OF VIOLATIONS AND INSPECTION REPORT 50-327, 328/86-56, DATED JANUARY 28, 1987
'DISTRI6UTION w/ enclosure:
$,DocketFile-[50-327/328)j MRC & L.oc,a.l SPORT ~ ~^
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