IR 05000327/1987022

Insp Rept 50-327/87-22 & 50-328/87-22 on 870406-10.No Deficiencies Noted.Major Areas Inspected:Implementation of Program Per Requirements of 10CFR50.49 for Establishing & Maintaining Qualification of Electric Equipment

ML20215H491
Person / Time
Site:	Sequoyah
Issue date:	05/19/1987
From:	Hubbard G, Pierson R NRC OFFICE OF SPECIAL PROJECTS
To:
Shared Package
ML20215H476	List: IR 05000327/1987022 ML20215H474 ML20215H481
References
50-327-87-22, 50-328-87-22, NUDOCS 8706240125
Download: ML20215H491 (16)

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l U.S. NUCLEAR REGULATORY COMMISSION i l

0FFICE OF SPECIAL' PROJECTS l Report Nos.: 50-327/87-22; 50-328/87-22 Docket Nos.: 50-327, 50-328 License Nos.: DPR-77, DPR-79 Licensee: Tennersee Valley Authority 6N 38A Lookout Place *

1101 Market Street Chattanooga, Tennessee 37402-2801

Facility Name: Sequoyah Nuclear Plant, Units 1 and 2 Inspection At: Chattanooga, Tennessee Inspection Conducted: April 6-10, 1987 Inspector: - f/7 G. T. Hubbard, Equipment Qualification & Test /Date .

Engineer (EQ&TE)

Also participating in the inspection and contributing to the report were:

0. P. Gormley, EQ&TE, NRR J. B. Jacobson, Reactor Engineer, NRR A. B. Ruff, Reactor Inspector, RII J. W. Grossman, Member of Technical Staff, Sandia National Laboratories V. P. Bacanskas, Senior Engineer, Franklin Research Center Approved by: -(- A R. C. Pierson, Acting Chief, Plant Systems

$ll*l Date Q

Branch, OSP l

8706240125 870617 gDR ADOCK 05000327 PDR

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INSPECTION SUMMARY ,

Inspection on April 6-10, 1987 (Inspection Report Nos. 50-327/87-22; 50-328/87-22)

Areas Inspected: Announced inspection to continue the review of the licensee's implementation of a program per the requirements of 10 CFR 50.49 for establish-ing and maintaining the qualification of electric equipment within the scope of 10 CFR 50.4 Results: The inspection identified no deficiencies in the SQN implementation of a program to meet the requirements of 10 CFR 50.49. Based on the inspection teams' reviews and evaluations, Potential Enforcement / Unresolved Items (PE/Uls)

50-327/86-01-15 and 50-328/86-01-16 are resolved; however, these PE/Uls along with seven previously resolved PE/Uls from Inspection Report 50-327,328/86-01 are subject to enforcement action (see below). Open Items 50-327,328/86-01-01 thru -04 were close While no deficiencies were identified in EQ program implementation, there are certain activities, which SQN has identified as needing completion before SQN is in compliance with 10 CFR 50.49. Two of the items needing completion are completion of Replacement Items Project (RIP) and resolution or staff approval of the main-steam-line break with superheat release and its effects on the environmental qualification of equipment in the east and west valve vault rooms (A1, A2, A10, and All). Since these items will be the subject of specific safety evaluations, they are not identified for follow-up in this inspection repor Two other items identified by SQN as needing completion are identified as inspection follow-up item Report Name Paragraph Item Number Violation Failure to Adequately 4.A.(2)(b) 50-327,328/87-22-01 )

Establish Qualification i for Certain Equipment ]

Inspection Follow-up Items: Qualification Requirements 4.C.(1) 50-327,328/87-22-02 for Certain Events Completion of EQ Fieldwork 4.C.(2) 50-327,328/87-22-03 i

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l DETAILS PERSONS CONTACTED:

1.1 Tennessee Valley Authority (TVA)

L. M. Nobles, Plant Manager

• M. A. Purcell, Licensing Engineering

• M. R. Sedlacik, Modifications Section A Supervisor

• M. J. Peters, Modifications Section A Electrical Engineer 1

• P. R. Wallace, Site Directors Office

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• R. H. Buchholz, Site Representative

• W. H. Mackay, Mechanical Test Supervisor

• T. L. Howard, QA Manager - Sequoyah (SQN)

• L. P. Woodley, Jr., EQ Project Section Supervisor

• W. H. Deen, EQ Project Section Supervisor

• B. W. Hooper, Electrical Maintenance

• C E. Lanstrom, Licensing Engineer

• G. B. Kirk, Compliance Licensing Manager

• S. M. Ar.thony, Licensing Engineer

• W. S. Wilburn, Assistant to Maintenance Superintendent

• R. F. Hansen, Licensing Engineer

• H. R. Rogers, Plant Operations Review Staff, Section Supervisor

• S. W. Littrell, EQ Coordinator

• A. E. Ives, Program Administrator

• S. D. Scott, Instrument Engineer

• B. M. Patterson, Maintenance Superintendent

• H. B. Rankin, Manager of Projects

• J. M. Blankship, Manager, Information Services A. H. Ritter, Engineering Assurance Engineer T. A. Flippo Quality Surveillance Supervisor

• M. A. Cooper, Licensing Engineer W. L. Elliott, EQ Project Manager H. D. Elkins, Instrument Maintenance Supervisor W. V. Horn, Deputy Manager, Modifications R. W. Olsen, Modification Supervisor F. Walker, Production Planner B. Bensing, QC Representative i

1.2 NRC S. D. Ebneter, Director, TVA Projects Division, OSP F. R. McCoy, Section Chief, Inspection Programs, OSP

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, PURPOSE:

The purpose of this inspection was to continue the review of the licensee's -

l implementation of a program to meet the requirements of 10 CFR 50.49 for Sequoyah Nuclear Plant (SQN), Units 1 and . BACKGROUND:

On August 21-22, 1985, TVA shutdown both units at SQN due to concerns that ,

documentation at TVA nuclear sites might be inadequate for environmental j qualification of electric equipment within the scope of 10 CFR 50.4 (

Since that time, TVA has initiated an indepth program to ensure that environmental qualification of electric equipment within the scope of 10 CFR 50.49 is established at SQN prior to restart (Note: Certain Regulatory Guide 1.97 equipment has been exempted for restart due to a later implementation date accepted by the NRC).

In order to evaluate the new program at SQN, the NRC has conducted four inspections of the SQN program and has documented the results in NRC Inspection Reports 50-327,328/86-01, dated August 15, 1986, and 50-327, 328/86-70, dated March 9, 1987. This inspection is a continuation of the NRC evaluation of the SQN equipment qualification (EQ) program and its implementation. This inspection focused on the activities completed since the last EQ inspection and included review of your corrective actions on deficiencies identified in the previous inspection . FINDINGS: Follow-up of Previous Inspection Findings The NRC inspectors reviewed SQN's corrective actions relative to some of the unresolved findings identified during the previous EQ inspections. Status of the unresolved items is discussed in the following paragraph (1) Open Items:

(a) (Closed) Completion of EQ Training (50-327,328/86-01-01)

After shutdown of Sequoyah plants because of EQ concerns, a new EQ program was developed by the licensee. This program is now in its final stages of implementatio To ensure that personnel involved in the new EQ program were aware of the importance of this 1ssue and to help ensure success of the new EQ program a training program was initiated. This program consisted of two separate parts (1) a general aware-ness for EQ for a large group of employees and (2) a training session on specific procedures for a smaller group of employees that needed more details. The NRC inspectors determined that the initial training has been accomplishe Over 650 employees received the general awareness training and over 150 employees received the specific procedural aspects of the training. The inspectors reviewed the attend-

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ance sheets for these training sessions. The licensee stated that additional awareness training sessions have been planned and should commence the latter part of Apri These new training sessions, to start in April, are to inform new SQN employees of the importonce of EQ. The i licensee stated that a long term and/or periodic trair.ing on EQ is to be developed for future use. This item is close (b) (Closed) Correction of Audit Corrective Actions (50-327,328/ l 86-01-02)

At completion of inspection 86-01, in June 1986, the licensee had performed three audits in the EQ area. The first was a TVA Management Review of the SQN plant Environmental Qualification Program performed by Westec Services and TV This was performed October 28-31, 1985. The second was a joint audit performed by TVA Division of Quality Assurance and Office of Engineering Quality Management Staff (Audit ReportQSS-A-86-004). This was issued in January 1986. The third audit (EA-Audit 86-22) was performed by Engineering Assurance (EA) during the Spring of 1986. The audits identified findings requiring corrective actions as well as some program enhancement items. Many of the findings per-tained to the TVA management organization. Based on the new TVA organization, these findings are no longer applicabl There are no outstanding action items with regard to the first and second audit. The nine deficiencies identified in the third audit have had corrective actions initiated and are considered closed; however, Engineering Assurance has not completed their review of five of the items and these remain open on the TVA Audit tracking system pending their concurrence to the resolutions. This item is close A recent Audit by the Nuclear Quality Audit and Evaluation Bronch (No. QSQ-A-87-0008) was performed February 23 to March 4, 1987. The items identified in this report are being resolved by the issuance and tracking of a Condition Adverse to Quality Report (CAQR). One of the CAQR items concerns general and/or specific EQ training for personne ,

TVA stated that over 650 employees have received a general awareness training. The lack of training cited in this

audit involved employees loaned from other TVA organizations {'

and/or sites. TVA stated that work plans involving EQ work which are prepared by these loaned employees are reviewed by engineers and supervisors who have had the EQ trainin Plant supervisors that implement activities affecting the EQ program are responsible to ensure that their workers are j informed about the EQ requirements and if necessary, to schedule EQ training for their new workers. The EQ coordi- !

nator indicated that the personnel in the mainstream of EQ r

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4 work have had the EQ training, but added that a new aware-ness training program'has been planned and will start the latter part cf April for these loaned employee (c) (Closed) Revision of Maintenance Procedure SQM-62 (50-327, 328/86-01-03)

The inspectors determined that Revision 3 of procedure l SQM-62, "10 CFR 50.49 Program Qualification Maintenance Data Sheets Implementation," added Appendix F entitled, "10 CFR 50.49 QMDS Recommendation Change Evaluation." Revision 6 to SQM 57, " Preventive Maintenance Program," deleted Attachment 3. " Evaluation for QMDS Recommenoations." Storage require-ments for EQ equipment are addressed in SQM-62 procedure under the "QMDS Review" Section. Environmentally qualified equipment that is placed in storage and that have QMDS storage requirements are scheduled and listed in Admin-istrative Instruction 36, " Storage, Handling, and Shipping of QA Material." The inspectors determined that NRC recom-mendeo changes were made; therefore, this item is close (d) (Closed) Com letion of Maintenance Program (50-327, 328/86-01-04 The licensee's program for the essential, recommended, and storage requirements for environmentally qualified equipment is identified in the QMDS section in the EQ binders. The licensee is in the final stages of completing and ensuring that the baseline essential requirements are complete for plant restart and ensuring that the periodic requirements will not impact operation after restart. The licensee's

"EQIS" computer program is used to identify QMDS requirements and it also provides a record of the documentation used for completion of these items. The licensee plans to imple- ;

ment a Quality Maintenance (QM) computer program for all QMDS items that will supplement the EQIS program. This program will provide a printout of QM procedures that are {

required to be performed periodically. It will indicate due dates to aid scheduling and performance of periodic QMDS items. This action is presently done manually by the planners and maintenance engineer The inspector reviewed the QMDS Requirements and Recommen-dations Implementation Log [ Required by Appendix C of SQM-62] to verify that items were signed off as complet In addition several work plans (WPs) and work requests (WRs)

[WP-11916,WR-11931,B200687andB200686] were reviewed to verify completion of some QMDS item Except for potential changes in the QMDS requirements, as a result of final stages of ongoing work in the Equipment Qualification Project (EQP), the QMDS essential requirements l

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are approximately 98% complete (including electrical and instrumentationitems). The incomplete items are being i followed by the licensee's P/2 computer tracking system and i when new or revised QMDS items are identified, these are l added to the P/2 tracking system. These items are identi- '

fied as restart items and require sign off by several super-visors, including the EQ coordinator, before they are removed front the tracking system. Based on the inspectors reviews, j this item is close (2) Potential Enforcement / Unresolved Items:

(a) (Closed) Raychem Splices / Breakouts (50-327/86-01-15; 50-328/86-01-16)

During the June 1986 EQ walkdown inspection, the NRC inspec-tors identified instances of improperly installed Raychem splices on 10 CFR 50.49 qualified cables. These problems included numerous minimum bend radius deficiencies as well as improperly installed oversleeves. Due to these identified deficiencies SQN conducted a splice qualification test program to qualify configurations of Raychem splices installed at SQN. In addition, SQN initiated a splice inspection program to inspect all 10 CFR 50.49 splices and Class 1E penetration splices prior to restar During this inspection, the inspectors followed the guide-lines of NRC Temporary Instruction (TI) 2500/17, " Inspection Guidance for Heat Shrinkable Tubing." The inspectors reviewed documentation associated with the SQN EQ splice activities as well as performing a walkdown inspection of a sample of the splice The inspectors reviewed the SQN methodology for identifying splices and determined that a preliminary splice list was prepared by the SQN electrical design group. This list was developed by reviewing " splice cards" and end device connect-ing diagrams. Since a complete list did not exist, the inspectors raised concern that not all splices would be inspected during the current program. In fact, some unlisted and unqualified Amp butt splices were located during TVA SQN inspections. The inspectors reviewed a draft walkdown procedure which was written to look for similar splice Additionally, the inspectors reviewed spacial maintenance instructions (SMI-2-317-39) for end devices and (SMI-2-302-1)

for penetration enclosures. These instructions were written to inspect and evaluate the various Raychem installations in Unit The inspectors determined that SQN had reviewed 962 Class 1E EQ splices and over 900 have been determined to be deficient and are being replaced. The inspectors reviewed maintenance

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instruction (M-AI-7) which is the applicable instruction for 4 splice rcplacement. This instruction contains explicit f

instructions concerning splice design, installation, and inspection criteria. The inspectors also reviewed data sheets used to record splice measurements and configuration Information recorded on the sheets included part numbers for all parts required for the splice, a sketch of the splice, lot numbers for the Raychem material, micrometer ncmbers, dimensions, and sign-offs for craftsman and Quality Control ,

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(QC). The inspector noted that prior to February 15, 1987, measurements supplied to engineering for splice design were taken by craftsmen without benefit of QC verificatio After this date, a change was made to M-Al-7 which required i QC verification of these measurements. SQN is currently !

evaluating whether splices made without QC measurement verification will require additional inspectio The inspectors reviewed qualification binders SQN-EQ-MCK-001, '

Raychem NMCK Motor Connection Kit; SQN-EQ-MCK-002 Raychem NPKV Motor Connection Kit; and SQN-EQ-SPLC-001, Raychem WCSF-N Splice. The inspector raised one question concerning test anomaly number two of binder MCK-001. This anomaly involved the failure of all four aged splice samples to complete the entire LOCA test with 1000 volts AC applie The failure was attributed to the test cables and not the splices; however, no aged splice samples were ever retested in a LOCA chamber. TVA was able to resolve this concern by demonstrating that the time the splices must withstand (

1000 volts AC for the SQN's plant EQ profile was encompasset by an aged splice test specimen that withheld voltage for the required time perio The inspectors walkdown inspection included visual observation ,

of various installed splices in Unit 2 to determine adequate l implementation of SQN's Raychem program. The following 1 component splices were reviewed and found to be acceptable:

Temperature Switch 30-96 - two splices located inside a condulet Electrical Penetrations Nos. 8 and 45 - over two dozen j inline instrumentation and power caole splices Solenoid Valve FSV-65-9 - two splices In addition to these splices, the inspectors visually observed several other splices during their inspection of other equip-ment. The inspectors did observe questionable splices on i safety injection system pump cooler 2 MTR 030179B in that the splices were installed over braided motor lead insulatio The inspector determined that this deviation was addressed in qualification binder M0T-001 for Reliance motors and the splices were appropriate for the applicatio 'y g (_*

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Based on the inspectors review of documentation, observation of installed splice configurations, and review of the SQN

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program implementation, it was. determined that SQN is .imple-

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menting a program to identify all 10 CFR 50.49 splices and ;

ensure their qualification. Based on the inspectors' findings

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that, controls are inplace at SQN for completing this activity, only splice fieldwork remains and it is being tracked ~by SQN, and fieldwork completion will be verified by the NRC prior to restart, this item is considered close Since the guidance of TI 2500/17 was followed during this inspection, the requirement for the performance of the T1 is I

, considered satisfied for SQN. It is pointed out that even though the physical inspection only concentrated on Unit 2, the findings are equally applicable to Unit 1; therefore, credit.for completion of this TI on Unit 1 is also take (b) While the NRC has reviewed and accepted the corrective actions on closure of the Raychem splice PE/UI above and the other PE/Uls identified in Inspection Report 50-327,328/86-01.during previous inspections, enforcement action relative to some of the PE/UIs is considered {

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appropriate. Based on an evaluation of the eleven PE/UIs identified in the inspection report the NRC has determined that in eight of the PE/UIs, TVA failed to adequately establish qualification of certain electric equipment important to safety. This failure to adequately establish qualification of certain electric equipment important to safety is identified as a Violation (50-327,328/87-22-01)

of 10 CFR 50.49 requirements. The PE/Uls which provide a basis for this violation are listed below:

Essex Power and Control Cable 50-327/86-01-08; 50-328/86-01-08 ASCO Solenoid, Valve, Model 206-381 50-327/86-01-09; 50-328/86-01-09 Nutherm 32K Air Duct Feater 50-327/86-01-10; 50-328/86-01-10 GA Technologies RD-23 Radiation 50-327/86-01-11; Detector / Brand-Rex Coaxial Cable 50-328/86-01-11 Eaton Multiconductor Signal Cable 50-327/86-01-12; 50-328/86-01-12 Limitorque Motor Valve Operators 50-327/86-01-13; 50-328/86-01-13 Barton Transmitter, Lot 7-764 50-328/86-01-15

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Raychem Splices /8reakouts 50-327/86-01-15; 50-328/86-01-16 Since the NRC has accepted TVA's corrective action on the above PE/VIs, no response will be required to the violation and these PE/Uls are considered close TVA's corrective actions for the other three PE/UIs, 50-327,328/86-01-06, -07, -014, are considered acceptable; therefore, they are considered close B. Draft SER Confirmatory Items The draft safety evaluation for SQN, Units 1 and 2, transmitted to TVA on December 5, 1986 contained nine confirmatory items which required certification of completion. These items were addressed in Enclosure 2 to TVA's letter to Mr. S. Ebneter, NRC, from R. l.. Gridley, dated March 24, 1987, subject, "Sequoyah Nuclear Plant (SQN) -

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Compliance with 10 CFR 50.49, Environmental Qualification of Electrical Equipment Important to Safety for Nuclear Power Plants." The NRC inspectors reviewed TVA's certification for the nine confirmatory items and discussed the responses with TVA during the inspectio Based on the review and the discussions, the following comments are provide Confirmatory Items:

(1) (0 pen) Resolution or staff approval of the main-steam-line break with superheat release and its effect on the environmental quali-fication of equipment in the east and west valve vault rooms (A1, A2, A10, and All).

Comment: TVA's resolution is currently undergoing stoff review dnd will be the subject of a SER dealing with the issue. In dnticipation of approval of the TVA proposed resolution, TVA hos already implemented or is implementing EQ changes required by their resolution of this issu (2) (0 pen) Completion of All EQ Fieldwork Comment: During the inspection the NRC inspectors reviewed scheduled completion dates for outstanding fieldwork and deter-mined that TVA still has several items of fieldwork to complet The inspectors also determined that TVA has a tracking system to assure completion of the work prior to restart. Completion of fieldwork remains as an open confirmatory item (see discussion inparagraph4.C.(2)).

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(3) (Closed)MainsteamVaultSubmergenceReview Comment: During the inspection, the NRC inspectors reviewed significant condition reports (SCR) SQNEQP8635, Revision 2, and SQNEQP8661, Revision 1, and determined that only fieldwork remains regarding this item. In addition during the June 1986 EQ inspection, the inspectors reviewed eight EQ binders relative I to this item. Since only fieldwork remains for resolution of )

this item and it is being tracked by TVA as part of the field- l work of item 2 above, this item is closed as a separate i confirmatory item. Resolution of this item will be followed as part of the fieldwork confirmatory ite (4) (Closed) Management Review of EQ Binders Comment: During the four EQ inspections of 1986 and this inspection the NRC inspectors determined that SQN EQ binders have undergone management review. TVA's response is acceptabl (5) (Closed) Supplemental Vendor Information Comment: The inspectors reviewed SCR SQNEQP8542, Revision 1, and "10 CFR 50.49 Cable and Splice List," SQN-CASL-001, dated March 27, 1987, and determined that this confirmatory item was complete. TVA's response is acceptabl (6) (Closed) Cable Load Study Comment: The inspectors reviewed Quality Information Request /

Release (QIR) SQP-87-169 and a sample of the April 3,1987, computer printout for the " Cable Average Conductor Temperature Analysis Testing (CACTAT) Study for mild-harsh-mild and harsh 50.49 cables." Additionall (SQN-EQ-CABL-016 and of -032)

the sixyEQ thebinders inspectors which reviewed were two affected by changes in cable ampacity tables and determined that appropriate revisions were included in the binder Completion of this item is acceptabl (7) (Closed) Inside Containment Flood Analysis for 5-minute Operability Comment: The inspectors reviewed SCR SQNEQP8515, Revision 0, and its asscoiated SCR completion verification; as weil as, Office of Engineering calculation number EQP-27 pertaining to this confirmatory item. The inspectors determined that this item is complete. TVA's response is acceptabl F .- -

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(8). (Closed) Verification of Instrument Accuracy Calculation Comment: The NRC inspectors reviewed the three EQ binders (5QN-EQ-XMTR-001 and -004 and SQN-EQ-IPT-002) affected by this confirmatory item during the June 1986 and April 1987 inspec-tions and determined that this item was complete. TVA's confirmatory response is acceptable, j (9) (Closed) Finalization of the EQ Master List Consnent: The inspectors reviewed the TVA letter from J. Domer to V. Stello, Jr., dated August 13, 1986 which included the 10 CFR 50.49 list for SQN. In addition during the January 1986 inspection., the NRC inspectors reviewed the Master List f that existed at that time; as well as, the SQN methods of I controlling the list. Since the reviews have identified no problems with either the January list or the August list and i no deficiencies with the methods of controlling the list, TVA's J confirmatory response is acceptabl C.. Techaical and Field Open Items (1) Technical Open Items:

The NRC inspectors reviewed TVA's letter to Nr. S. Ebneter, NRC, from R. L. Gridley, dated March 24, 1987. Enclosure 1 Attach-ment B to the above letter identified two open EQ technical items I which are being addressed by SQN. One item deals with the review {

of piece parts purchased as "QA Level II" and is being addressed l

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by the TVA Replacement Items Project (RIP). Since RIP will be the subject of a separate NRC inspection, the inspectors did not review the RIP activitie The other technical item pertained to the qualification require-ments for containment cooling for certain events. The NRC l inspectors reviewed documentation and held discussions with SQN concerning this item. As a result of a TVA generic review of significant condition report (SCR), SCRWBNNEB8637 for Watts Bar Nuclear Plant, TVA documented the issue for SQN in SCRSQNNEB861 This SCR documented a postulated event which would result in environmental conditions not previously identified for safety-related equipment located in reactor containment. The licensee determined that a high energy line break (HELB) in the auxiliary building could create environmental effects in localized areas (pressurizer and lower compartment) of containment where safety-related equipment is located. While reviewing this problem, the licensee identified concerns with regard to the main-steam-line break (MSLB) profile for a MSLB inside containment. This concern was addressed in condition adverse to quality report, CAQR-870349. The initial analysis indicates that certain localized temperatures (pressurizer and lower compartment)

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l for the time period of i day and beyond after event initiation was not enveloped by existing qualification profiles. The maximum deviation from the existing profiles was approximately 17 degrees Fahrenhei The licensee is investigating several resolutions to -these issue One involves the use of containment coolers to mitigate the effects of.an event; however, the coolers (including air return fans) are not environmentally qualified and would have to be qualifie Another method involves using containment spray for coolin This item is identified as Inspection Follow-up Item 50-327,328/

~87-22-02, which will be reviewed during a future NRC inspectio prior to SQN restar (2) Fieldwork Open Item: The NRC inspectors reviewed the fieldwork open item identified in the letter from R. L. Gridley, dated March 24,1987, and determined that the items are being tracked by TV At the time of the inspection most of the items identified had not been completed. The latest scheduled item for completion was " replacing cables based on revised ampacity tables" wit a completion dated of May 24, 1987. Completion of identified -

fieldwork will be reviewed by the NRC prior to restart; there- .

fore, fieldwork completion is identified as Inspection Follow-up Item, 50-327,328/87-22-0 Environmental Qualification Files The NRC inspectors reviewed three new environmental qualification binders (SQN-EQ-CABL-030. -050, and -051) which had been generated since the previous NRC EQ inspections. In addition, the inspectors reviewed binders SQN-EQ-CABL 016, -032, and -043 to evaluate revisions to the binders which had been made since the other inspections. The binder revisions reviewed pertained to the issues of main steam valve vault " Hot Spots," superheat in the main steam valve vault, "ABGT5" filter modifications, and electric cable ampacity table change The new binders were reviewed to compare plant service conditions with qualification test data and to verify the basis for these condi tion Additionally, the inspectors reviewed areas such as required post-accident operating time compared to the duration of time the equipment had been demonstrated to be qualified; similarity of tested equipment to that installed in the plant (e.g., insulation class, materials of components of the equipment, test configuration compared to installed configuration, and documentation of both; evaluation of adequacy of test conditions; aging calculations for qualified life and replacement interval determination; effects of decreases in insulation resistance on equipment performance; adequacy of demonstrated accuracy; evaluation of test anomalies; and appli-cability of EQ problems reported in IE ins / Bulletins and their resolutio '

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The revised binders were reviewed to ensure that the revisions did not change the qualification st'atus of the equipment covered by the binders. The review also determined whether the revisions were properly implemente In addition to the binder reviews discussed above, binders for equipment selected for walkdown inspection were reviewed to identify information which could be verified during the walkdown. This information included such things as mounting configurations, orientations, interfaces, model numbers, and ambient environment During the binder reviews, the intpectors identified minor file concerns / inconsistencies and made recommendations to TVA for binder improvements to clarify informati6n in the binders. These concerns /

inconsistencies and recommendations were not considered significant by the inspectors and qualification of the equipment covered in the binders was considered established; however, the licensee agreed to make changes to the binders as discussed with the inspectors. Binders identified for changes included: (1)SQN-EQ-CABLE-030,Okonite"EPR" Cable;(2)SQN-EQ-CABLE-050, Brand-Rex"XLPE" Cable;(3)SQN-EQ-SOL-004, Gould/ Allied (MSIVActuatorManifoldAssembly);(4)SQN-EQ-PENE-004, WestinghouseCannisterPenetrations;and(5)SQN-EQ-PENE-005,Conax Modular Penetration. Since the changes were considered to be minor .

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and qualification was supported, the changes are not identified for inspection followu E. Plant Physical Inspection i The NRC inspectors selected 18 pieces of equipment for physical inspection during the plant walkdown. The 18 items inspected covered 10 different equipment types which included solenoid valves, {

resistance temperature detectors, transmitters, and penetration l The equipment types were selected on the basis taat they had not j been physically inspected during previous EQ inspection During the physical inspection, the inspectors examined characteristics such as mounting configuration, orientation, interfdces, model number, ambient environment, and physical condition. No deficiencies were identified during the plant walkdown inspection. In addition to the f above, Raychem splices were inspected as part of the closeout effort associated with the Potential Enforcement / Unresolved Item on Raychem splices / breakouts. Activities associated with the Raychem inspections are discussed in paragraph 4.A.

I ASCO Solenoid Valve, Model NP8316 I

I During the inspection, the inspectors received a copy of a TVA letter from R. Gridley, Director, Nuclear Safety and Licensing, subject:

"Sequoyah Nuclear Plant (SQN) Units 1 and 2 - NRC-0!E Region II Inspection Report Nos. 50-327/86-42 and 50-328/86-42 - Denial f

j of Violation," dated April 6, 1987. At the request of the Senior

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Resident Inspector (SRI), the inspectors reviewed the response and ]

held discussions with the licensee relative to violation 50-327,328/ 1 86-42-01 concerning ASCO Model NP8316 solenoid valve The violation cited SQN for failure to following Administrative Instruction 19, Revision 12, " Plant Modifications After Licensing,"

concerning Work Plan 11806. The Work Plan did not give adequate instructions for craft personnel to reconfigure 10 CFR 50.49 qualified ASCO solenoid valves for proper installation and did not specify the 4 j

impact of improper actions associated with modifying the valve Specifically, the violation was for failure to establish, in the work plan, valve bonnet bolt torque and sequence requirements in dCCorddnce with vendor documentatio During the discussions the licensee provided additio'nal information supporting the points made in the denial of the violation. The inspectors reviewed the information including information demon-strating that the solenoid valves in question are installed in the ,

I plant in fail-safe applications. The inspectors determined that even though SQN feels that their procedures were adequate and the violation is not valid, they have tightened the bolts in accordance with vendor documentation on the questioned valves. Since the bolts have been tightened in accordance with vendor documentation this issue will not delay restart. A decision regarding the validity of the violation will be made by the NRC following evaluation of information in the letter, information reviewed during the inspection, and other available information relative to the issu G. Employee Concerns The inspectors reviewed lists of employee concerns from the TVA Employee Concerns Program to identify those that appeared to have potential effects on the SQN EQ Program. The inspectors selected ten concerns, which were reviewed to determine if they affected the EQ Progra If it was determined that they affected the EQ program, they were evaluated to determine if they had adequately been resolved in the SQN EQ Program. The concerns which affected the EQ program are discussed below:

(1) MAS-86-002: This concern is discussed in Element Report 301.05 dnd deals with the improper mounting of limit switches in I

valve 2-FCV-30-15. The report determined that a work request was written to correct the deficiency. These limit switches are included on the 10 CFR 50.49 list. The NRC reviews of the SQN EQ program have determined the program includes provisions to ensure that specific environmental qualification mounting requirements for environmentally qualified equipment are identified and verified for compliance. The inspectors deter-mined that the generic aspects of this concern are being adequately addressed by the EQ progra I

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(2) TAK-85-001: This concern.is discussed in Element Report 302.01 and deals with problems of Raychem splice installations. This concern is EQ related and was verified as a problem at SQN in inspection report 50-327,328/86-01. Raychem installation problems were identified as Potential Enforcement / Unresolved

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Items in the report. Resolution of this issue is discussed in paragraph 4. A of this repor (3) TAK-85-004: This concern is addressed by Element Report 30 and states that Beacon 325 grease supplied in the geared limit switches of Limitorque motor valve operators hardens. The resolution given in the element report was that,the grease in all Unit 2 and most Unit 1 safety-related Limitorque limit switches was changed to Mobil 28. The inspectors determined that use of Beacon 325 or Mobil 28 grease.in the limit switches is discussed in the qualification binders for Limitorque operators. The hardening of the Beacon 325 is specifically addressed and the binders recommend the grease be changed to Mobil 28 when hardening of the Beacon 325 is observed. The inspectors determined that this concern was adequately addressed by the EQ progra