IR 05000327/1987031
| ML20236X564 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 10/18/1987 |
| From: | Architzel R, Imbro E Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20236X530 | List: |
| References | |
| 50-327-87-31, 50-328-87-31, NUDOCS 8712090287 | |
| Download: ML20236X564 (53) | |
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g U.S. NUCLEAR REGULATORY COMfilSSION OFFICE OF NUCLEAR REACTOR REGULATION Division of Reactor Inspection and Safeguards Report Nos.: 50-327/87-31, 50-328/87-31 Docket Nos.: 50-327; 50-328 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: Cedar Bluffs and Soddy Daisy, TN Inspection Conducted: June 29-July.2 and July 20-24, 1987 Inspection Team Members:
Team Leader: R. E. Architzel, Senior Operations Engineer, NRR Mechanical Systems: F. J. Mollerus, Consultant, Mollerus Engineering In Nuclear Engineering J. A. Nevshemal, Consultant *
Mechanical Components: A. V. du Bouchet, Consultant Civil / Structural: A. I. Unsal, Consultant, Harstead Engineering Electrical Power: S. V. Athavale, Electrical Engineer, NRR*
Instrumentation &
Control: L. E. Stanley, Consultant, Zytor In Operations: P. E. Harmon, Resident Inspector, Sequoyah H. E. Bibb, Resident Inspector, St. Lucie NPP*
du/ M Ralph E. Architzel
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-Nn Date Team Leader
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i Eugene V. Imbro Date Section Chief Team Inspection Appraisal and Development Section #2 Special Inspection Branch
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LIST OF ABBREVIATIONS ABGTS auxiliary building gas treatment system AFW auxiliary feedwater CAQ condition adverse to quality CAQR condition adverse to quality report CCP centrifugal charging pump CCRIS Calculation Cross Reference Information System CCS component cooling water system 5 CEB Civil Engineering Branch CFR Code of Federal Regulations DBVP Design Baseline and Verification Program DCR design change request DES Discipline Evaluation Supervisor DIM design input memorandum DNE Division of Nuclear Engineering EA Engineering Assurance ECCS emergency core cooling system ECN engineering change notice EEB Electrical Engineering Branch ERCW essential raw cooling water system FCN field change notice (Westinghouse)
FCR field change request FSAR Final Safety Analysis Report HPFP high pressure fire protection HVAC heating, ventilation, and air conditioning I&C instrumentation and control IEEE Institute of Electrical and Electronics Engineers LDCR local design change request LOCA loss of coolant accident MEB Mechanical Engineering Branch MI maintenance instruction NCR nonconformance report NEB Nuclear Engineering Branch NPSH net positive suction head NRC Nuclear Regulatory Commission NSSS nuclear steam supply system OR oversight review PGCE potential generic condition evaluation PIR problem identification report PL punchlist
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QIR quality information report RCS reactor coolant system RHR residual heat removal RIMS records information management system SCR significant condition report SE System Engineer SI surveillance instruction SQR Static-0-Ring SQEP Sequoyah Engineering Procedure SQN Sequoyah Nuclear Plant SSE safe shutdown earthquake SWBID system walkdown boundary identification drawing SYSTER System Evaluation Report i
TACF temporary alteration control form l
TVA Tennessee Valley Authority l
USQD unreviewed safety question determination WDP walkdown package WP work package WR work request i ZPA zero period acceleration
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.SEQUOYAH NUCLEAR POWER PLANT Design Baseline and Verification Program Inspection Report 50-327/87-31 & 50-328/87-31 June 29-July 24, 1987 l INTRODUCTION AND BACKGROUND The Design Baseline and Verification Program (DBVP) was developed by TVA's Division of Nuclear Engineering (DNE) to resolve design control issues described in several TVA-sponsored evaluations and audits and NRC inspection The Sequoyah Nuclear Plant (SQN) Design Baceline and Verification Program has.
, been used by.TVA to provide an additional level of confidence that the i modification to selected plant systems, implemented since receipt of the operating license, have not resulted in any violation of the plant's licensing basi This report summarizes the results of the fifth NRC inspection conducted to assess the adequacy of TVA's Design Baseline and Verification. Program to support restart of Sequoyah Nuclear Plan NRC inspection report 50-327/86-38 and 50-328/86-38 summarized (1) the NRC's ,
review of TVA's overall DBVP plan and scope, (2) TVA's procedures for DBVP '
project review and Engineering Assurance (EA) oversight, (3) TVA's preparation of system walkdown packages within the DBVP scope, and (4) the NRC's preliminary !
review cf 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 sunurized (1) the NRC's review of.TVA's compilation and implementation of the commitment / requirement data base, (2) the design criteria which TVA prepared to support SQN restart, and (3) the adequacy of EA's independent oversight review of commitment / require-ments and design criteri NRC' inspection report 50-327/86-55 and 50-328/86-55 summarized the NRC's review of the DBVP engineering change notice (ECN) revie NRC inspection report 50-327/87-14 and 50-328/87-14 summarized the NRC's evaluation of the System Evaluation Reports (SYSTERs), summary reports that reflect the DBVP's integrated assessment, on a system basis, of the reviews, )
evaluations, and findings of the progra Licensee actions for previous inspection findings (including design control inspection 50-327/86-27 and 50-328/86-27), pre-restart corrective action decisions, and the effectiveness of the Engineering Assurance oversight effort were also examined during these inspection . PURPOSE The purpose of this inspection was to assess the implementation and completion r' of the DBVP. This included evaluating whether or not the findings identified j by the DBVP were being adequately resolved and properly scheduled for corrective l action before plant restar The inspection was also held to evaluate the-1-
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effectiveness of the EA Oversight Team and the adequacy of the licensee's actions taken in response to previous NRC inspection finding . INSPECTION ACTIVITIES The following activities were generally performed by all team members:
(1) Reviewed TVA's corrective actions associated with its in-house Engineering Assurance (EA) oversight of the DBV Team members concen-trated on the " observations" identified in the EA report (Reference 12).*
(2) Reviewed TVA's resolution of DBVP punchlist item The team assessed the restart categorization (using docketed restart criteria) of selected items and planned corrective action (3) Verified implementation of corrective actions for selected, more signifi-cant findings of the DBV (4) Assessed if the generic implications of inspection activities 1, 2, and 3 had been adequately addresse (5) Reviewed the Phase I (pre-restart) reports summarizing both the DBVP (Reference 13) and the associated EA oversight (Reference 12).
(6) Reviewed the action taken by TVA in response to the deficiencies, un-resolved items, and observations previously identified in NRC inspection report Nos. 50-327/86-27 and 50-328/86-27, 50-327/86-38 and 50-328/86-38, 50-327/86-45 and 50-328/86-45, 50-327/86-55 and 50-328/86-55, and 50-327/87-14 and 50-328/87-1 . SUMMARY OF FINDINGS The following paragraphs summarize the more significant team findings and conclusions. Sections 4.1 through 4.7 contain detailed descriptions of the inspection findings in each discipline. Observations are provided in Appendix A to this repor In the operations area, the team concluded that the DBVP was adequately planned and implemente All questions raised by the team pertaining to both scope and depth of the walkdowns and resolution of deficiencies and findings were addressed and resolved. In particular, the team felt that the EA oversight was effective and responsive in the operations area. The corrective actions reviewed by the team appeared to be relevant and comprehensive. Review of the restart /non-restart categorization process indicated some weaknesses. In particular, the inspectors questioned the tendency to classify as non-restart the actions that were deter-mined to be outside the DBVP boundary (Observation 7.5). Several items were reclassified after the inspectors challenged the original classificatio Although several examples of questionable categorizations were identified and ultimately resolved, the overall process for assigning restart classification appeared acceptable in the operations are * References are listed in Section C.2 of Appendix _ _ _ - _ _ _ _ - _ _ - _ _ _ :
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_During the inspection, the team observed that the concurrence of the DBVP System Engineer and Discipline Evaluation Supervisor were not required for changes to the restart categorization and proposed corrective actions for punchli-t items following initial concurrence by the DBVP. TVA adequately resolved this concern by changing project directives to require such concurrence reviews for future technical changes, and has examined those changes which had previously occurred to assess their adequacy. These actions were delineated in an August 20, 1987 letter to the NRC (Reference 17).
In the mechanical systems area, the team reviewed several of TVA's corrective actions for open NRC observations from previous inspections, reviewed TVA's corrective actions'for observations made by the EA group, and reviewed how TVA had resolved DBVP'punchlist items. The team also reviewed field implemen-tation of corrective actions. The team found the findings, evaluations, and determinations of EA-Mechanical Engineering to be competent, and the resolution and implementation of DBVP punchlist items to be satisfactor In the nuclear engineering area, the team reviewed several of TVA's corrective actions for open NRC observations from previous inspections, reviewed TVA's corrective actions for observations made by the EA group, and reviewed TVA's l resolution of DBVP punchlist items. The team found the findings, evaluations, l and determinations of EA-Nuclear to be competent, and resolution and implemen-tation of DBVP punchlist items to be generally satisfactory. However, the inspection team disagreed with TVA's decision to reclassify from restart to post restart punchlist item 4426. This item concerns the need to provide a safety-related air supply for the isolation valves in the system that monitors the radiation in containment air (Observation 4.8). Also, the team identified several cases in which there was inconsistency between the DBVP punchlist and the associated Attachment 2 form to Sequoyah Engineering Procedure 45 (SQEP-45)
(Observation 7.5).
In the mechanical components discipline, the team reviewed the DBVP and EA reports to assess the adequacy of the DBVP's review of the SQN Unit 2 change documents and nonconformances, and EA's oversight of DBVP project's revie The team reviewed the Civil Engineering Branch's (CEB's) implementation of a sample of civil / structural punchlist items, DBVP's post-restart categorization of a sample of punchlist items, and DBVP's decision to request generic reviews for a sample of the nonconformances that DBVP personnel prepared to categorize the punchlist item The team also reviewed several open action items in EA's report to assess the adequacy of DBVP responses to EA's concerns and, in addition, reviewed EA's verification of DBVP implementation of corrective actions for two of the three mechanical components action items that EA had completed verifying at the time of the inspection.
l- The team identified two observations during this inspection concerning the l lack of a generic evaluation for a nonconformance, and the lack of a calculation to qualify a design variance (Observations 3.'16 and 3.17).
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The team concluded that the DBVP's review of the SQN Unit 2 change documents .
and ncnconformances issued since the operating license had been issued ade- l quately defined the corrective actions required to validate the design change control process at SQN Unit In the instrumentation and control.(I&C) area, the team reviewed the EA group's oversight of commitments and requirements, design criteria, calculations, DBVP assessments of-post-modification tests, SYSTERs and DBVP restart decision The team is satisfied that the EA oversight program provided an effective j review of the DBVP process and its output l The team also directly reviewed DBVP evaluations of ECNs, post-modification I tests, calculations, design criteria, commitments and requirements, SYSTERs, generic implication evaluations, and restart decisions in the I&C are Other than two specific exceptions, DBVP evaluations and restart decisions were. deemed to be correct and appropriate. Four out of the five condition adverse ,to quality reports (CAQRs) for the TVA setpoint accuracy calculation program reviewed by the team had appropriate corrective actions, but corrective action for the fifth sample was found to be incomplete. TVA took into account the potential for generic implications of the SQN findings at other similar facilitie The team generally agreed with TVA's resolution of DBVP punchlist items. DBVP restart decisions were found to be acceptable in each instance reviewed by the team; however, the team did identify one instance ik which DNE was in the process of changing a pre-restart decision to post-restart without having adequately evaluated and justified that change.
- Throughout the various inspections, the team has been satisfied with the extent l and depth of inquiry evidenced by the DBVP. Individual team observation.s, albeit numerous, did not indicate a programmatic problem with the DBVP l approach. TVA has been preparing corrective action design change notices for l implementation before restart, a positive indication that latent design l problems are now being evaluated and correcte In the civil / structural area, the team reviewed the corrective actions taken by the project to resolve the punchlist items that were generated by the DBVP and the EA observations as reported in EA oversight report EA-0R-001 (Reference 12). The team also reviewed the restart categorization of punchlist items to determine whether such categorizations were appropriat The review by the team showed that the punchlist items and the EA observations
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are being closed properly by the DBVP project. The team concurs with the l categorization of the punchlist items as noted on the governing SQEP-45, Attachment 2 forms. The team was, however, concerned with the adequacy of l the tracking system used to control the status of punchlist items. Discre-pancies were noted between the restart status and the implementation status of many punchlist items. The team also noted that when a biased sample of five restart punchlist items associated with field changes was selected for review, none were implemented at the time of the inspection (Observation 7.5).
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The team also reviewed the appropriate. sections of report EA-0R-001 and the DBVP Unit 2 Phase.I report (Reference 13). This review did not identify any deficiencies relating to these two reports in the civil / structural are In the electric power area, the team reviewed TVA's corrective actions associated with past NRC inspections of the DBVP, TVA's corrective actions for some significant condition reports (SCRs) and CAQRs, and TVA's process for addressing the generic impact of Sequoyah DBVP findings at other TVA plant The team also reviewed the restart categorization of several DBVP punchlist items and the report of EA's oversight of the DBVP (EA-0R-001). EA's oversight resulted in a total of 357 action items, of which 91 related to the electric power discipline. These electric power action items were further analyzed and classified into various categories. Approximately 63% of the action items were related to design deficiencies, and approximately 14% of the action items were related to design criteria deficiencie The NRC team also noted that the electric power discipline was a leading contributor of deficiencies related to unreviewed safety question determinations, testing and interface contro The-types of documents affected by the electric power action items were ECNs (approximately 26.9%), design criteria (approximately 25.8%), SYSTERs (approxi-mately 13.2%), walkdown packages (approximately 9.2%), calculations (approxi-mately 5.9%), and technical procedures (approximately 5.3%).
The NRC team found EA's analysis of findings in the electric power area, as presented in the final report, acceptable.
l 4.1 Operations l 4. Corrective Actions Associated With EA Oversight of the DBVP In the operations area, the team examined Engineering Assurance Observations Q1-Q5,
T-1, EA-1, and Condition Adverse to Quality Report (CAQR) SQE-870-R01-002 documen-
- ted in "EA Oversight Review Report", EA-0R-001. This included an assessment of l the observations, responses from the SQN Engineering Project and/or DBVP, adequacy of proposed corrective actions and restart categorizations.
- Observation Q-1, corresponding to Action Item Q-07, pertained to the implementa- tion of several EA recommendations for the SQEP-13 process, for example, System i
Engineer review of changes to ECN pre-restart status. The corrective actions j were implemented and EA concurred with this dispositio Observation Q-2 was issued to transfer responsibility for corrective action verification for CAQR 86-03-012 to the EA group. Design criteria and design calculations were not being properly maintained as required by DNE procedures and TVA Topical Report TR751A, Section 17.1.3. Part A of the CAQR concerned design criteria. Design criteria required for restart were captured in the Restart Design P,asic Document). All specific f examples found in Part A of the CAQR were resolved by issuing of appropriate design criteri Part B of the CAQR concerned design calculations. TVA's calculation review program is scheduled for completion by September 30, 1987. The program will review and/or regenerate all essential calculation In addition, the program-5-
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will provide a uniform change process and t'acking system (Calculation Cross-Reference Information System, CCRIS) and will allow for cross referencing of-change documents, drawings and calculation j EA concurred with the proposed corrective action EA was to sample implementation of these actions at a later dat Observation Q-3 concerned SQEP-13, " Transitional Design Change Control." EA recommended several changes to the SQEP-13 process to be included in the next revision. DBVP personnel agreed to revise SQEP-13 to incorporate all the principal items identifie Revision 5 documented this set of changes (see Observation Q-4).
Observation Q-4, corresponding to Action Item Q-11, identified the systematic use of a waiver process to bypass the new SQEP-13 requirements issued to control the ECN process during transition. A revision to SQEP-13 (Rev. 5) eliminated the waiver as a means of ECN implementatio All ECNs processed under the waiver format were reviewed to verify compliance with the requirements of SQEP-1 Observation Q-5 concerned changes that EA recommended to the draft DBVP repor EA still needed to verify that its recommendations were implemente The following items were included:
Item 1 Trending of punchlist items was revised to include tracking and res61ution via the CAQR process (Ref. CAQR SQE 870R01-002).
Item 2 Resolution to address documentation of closed and implemented SCRs/NCRs which were evaluated in the DBV Item 3 Transitional Design Change Control Procedure was revised to note the use of waivers in the SQEP-13 proces Observation T-1 noted that the red-line process used to mark up control room drawings did not include an independent review for accuracy by a second part Inspection report Nos. 50-327/87-24 and 50-328/87-24, and 50-327/87-54 and 50-328/87-54 independently opened this item. A violation for failure to per-form independent review of change was identified in these Office of Special Projects inspection report Observation EA-1 concerned items to be corrected in Phase II of the DBVP. All items with corrective actions will be tracked via the CAQR process. Five selected items were reviewed to assess whether the post-restart designation of these items was correct. The inspector concurred in the disposition of the selected items as appropriate to Phase II implementatio CAQR SQE-870-R01-002 identified by a random sample by EA that approximately 50%
of the punchlist items that represented conditions adverse to quality (CAQs)
had not resulted in written reports (CAQRs). Disposition of this CAQR included review of all open punchlist items that had not had corrective action reports written against them to ensure that a problem identification report (PIR), a significant condition report (SCR), or a CAQR, as appropriate, is assigne EA had concurred with this resolutio )
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Overall, the team concluded that the EA oversight was effective and responsive in the operations area. The corrective actions reviewed by the team seemed to the relevant and comprehensiv . Resolution of DBVP Punchlist Items and Implementation of Corrective Actions A limited number of punchlist items were reviewed regarding the assignment of restart / post-restart category. The inspector agreed with the assignments in general, but did not agree that punchlist itea 5644 was appropriately assigned as a post-restart-issue. This item involves the improper (non-
-seismic) mounting of handswitches on the main control board. The decision had been made to classify this as a post-restart issue because the switches were out of function on the system walkdown boundary identification drawing j (SWBID) (addrened in NPC Observation 7.5). The team concludes that the i potential effect on system operability should be assessed before restar The team raised a question about the adequacy of residual heat removal pump flow indication in the control room. Specifically, when heat exchanger bypass valve 74-32 is open, total pump flow indication is not available. The additional (unmonitored) flow through the bypass valve is enough to force the pump into runout as evidenced by a 1980 test [W2.2 (SCR NEB 8708)]. This item will be tracked by the' resident inspectors as part of the normal closecut of SCR During the course of the inspection, the inspector reviewed TVA correspondence relating to emergency diesel generator operations while in the test mode. TVA has determined through the DBVP (punchlist item 8514) that the diesel generator will not transfer from the test mode when a valid emergency start signal is received; this is contrary to the FSAR. This apparent deviation will be followed by the resident inspector The team examined the programmatic controls which were established for tracking, resolving, establishing restart items, closing, and statusing implementation of punchlist items. These were primarily established by SQN SQEP-45 (Rev. 5) and various DBVP directives which amplified and clarified the procedural controls. The controls required System Engineer (SE) and Discipline Evaluation Supervisor (DES) concurrence (documented on SQEP-45, Attachment 2 I forms) for both the restart categorization and the proposed corrective action In addition, SYSTER closure statements were required to be generated to identify any changes between the corrective action and restart category finally 1 agreed to by the DES and the SE and the categorization at the time of issuance J of the SYSTE DBVP Directive 87-007 (June 18, 1987) clarified that punchlist items were to be closed when the SE and DES concurred with the restart categorization and the implemented or planned corrective action. The punchlist item was separa-tely tracked for implementation status, as opposed to DBVP closure. The directive stated that the purpose of the DBVP was no longer to verify the adequacy of the work performed by the SQN project; new policies and procedures are in place to correct past design control deficiencie As such, the SQN project was being allowed to change restart categorization and proposed ;
corrective actions without concurrence of DBVP personnel. The team was '
concerned that this practice substantially degraded an important feature of-7-
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the DBVP, that is, the overall perspective, from a system level, of the impact of the particular punchlist item and its relative importance to system function as evaiuated by the DBV The team acknowledged that for some changes in punchlist status, DBVP concur-rence reviews were not essential. For example, some punchlist items had corrective actions defined for both pre- and post-restart. Following comple-tion of the pre-restart corrective action, the SQN project was supposed to initiate an Attachment 2 form (SQEP-45) to change the status of the item to post-restar In addition, the SQN project was supposed to initiate an Attachment 2 form (SQEP-45) to change the status of items to " implemented" to reflect that proposed corrective action had been completed. The team noted that numerous non-administrative changes were also being made to punchlist items, and expressed concern with the apparent relaxation of controls by the DBV The team was informed that CAQR SQT-871268 had been initiated by the Engineering Assurance oversight group addressing this same concer Following the inspection, the licensee changed the control and processing of changes to the punchlist to address these concerns (TVA letter from Gridley to NRC, dated August 20, 1987). DBVP Directive 87-008 (August 8, 1987) classifies punchlist changes into three categories: administrative changes, implementa-tion status changes, and technical changes. Technical changes now require DBVP concurrence (System Engineer and Discipline Evaluation Supervisor). Punchlist changes occurring before implementation of Directive 87-008 are being reviewed, categorized, and dispositioned'in accordance with the directive. These actions adequately resolved the team's concern The team selected a sample of five punchlist items to astess the status of implementation and the consistency between the P verning SQEP-45, Attachment 2 form and the actual punchlist database information. The team biased the sample by only selecting punchlist items for which field modifications were require Of these five punchlist items:
One was listed as outside the scope of the DBVP, tabulated as implemented with actual status unknow Two were not implemente One was listed as implemented; however the associated SQEP-45, Attachment 2 form documenting implementation was not available - the associated SQEP-45, Attachment 2 form documenting DBVP closure indicated that pre- and post-restart corrective actions were required, implying improper implementation statu Another implemented item did not have the required SQEP-45, Attachment 2 form on file and apparently was improperly listed as implemented, based on DBVP closure.
l-The fact that none of the selected punchlist items within the scope of the DBVP were implemented was of concern to the team, notwithstanding the biased selection rf punchlist items requiring field modifications. The team further noted that the licensee's procedures for control and statusing of punchlist items did not specifically address handling of these aspects of the punchlist items (NRC Observation 7.5).
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4. 2 Mechanical Systems 4. Corrective Action Associated With EA Oversight of the DBVP
. During this inspection, the team reviewed the EA observations contained in EA Oversight Review Report'EA-0R-001 and the DBVP and/or SQN project response to-these observations. The mechanical engineering discipline of EA reported four observation <
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EA Observation M1 identifies a concern related to the adequacy of the informa- l tion for valve stroke times included in the auxiliary feedwater system design criteri The project responded by issuing Quality Information Requests and a commitment to issue Design Input Memoranda or design criteria revisions. EA i
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found the response generally acceptable. However, EA questioned the use of plant technical specifications as the source of the valve stroke data, and was L holding the observation open pending SQN project response to this concern and l EA review of the memoranda and revised design criteria.
I EA Observation M2 concerns the need for the System Evaluation Report (SYSTER)
to state whether identified corrective actions need to be completed before or after restar The observation also noted that the draft SYSTER for the con-tainment spray system addressed the incorrect use of cable lengths in certain I electrical calculation EA report EA-0R-001 notes that this observation was i
. resolved by a DBVP commitment to issue instructions to ensure a thorough j
! " buy-in" of corrective action categorization by the System Engineer (SE) and-i Discipline Evt.luation Supervisor (DES) and a commitment to issue an Electrical l Engineering Branch (EEB) policy memorandum regarding how cable lengths are to be used'in electrical calculations.
l EA Observation M3 addresses three EA action items: M-30, M-43, and M-46. The j'
observation, action items, and SQN project response were reviewed and found to be acceptable. The SQN response to M-43 was to conduct a pre-restart leakage test of the component cooling water surge tank baffle. The test was performe However, the test produced inconclusive results because there are valves in the system that may allow leakage in the test configuration. EA is holding this item open pending a visual inspection or a test that measures.only baffle leakag EA Observation M4 identified a concern that, ir some cases, punchlist items have been implemented and closed before the corrective action was assigned on the initiating condition adverse to quality (CAQ). At the time the EA report was issued, the observation remained unresolved. The observation has subsequently l been closed by DBVP reviews and policy promulgated in SEQP-45, Revision 3, l " Control of DBVP Action Items," and DBVP Directive 87-06, Revision 1, "Statusing ( Punchlist Items."
In addition to the above observations, the mechanical engineering discipline of i EA initiated and reported on two CAQRs in its oversight report:
CAQR SQE-870-R01-001 reported an unverified assumption in a calculatio CAQR SQE-870-R01-003 reported an inconsistency in the design temperature for the containment spray piping inside of containmen l l
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Subsequent to the oversight report, the first CAQ has'been resolved by EA based on corrective action proposed by the SQN project and the determination that the CAQ is not significant and is a post-restart ite EA and the SQN project found that the second CAQR did not present a condition adverse to quality as the inconsistent temperature identified in the CAQR is not a design conditio Rather, it is a beyond-design-basis condition used only for piping design and support stress analysi j In general, the inspection team found the findings, evaluations, and determi-nations of EA-Mechanical Engineering to be competent. The team expects that this competency and satisfactory EA results can be continued, provided the EA resources and manpower are maintained at a level commensurate with the effort required for a 5% sampling of the DBVP result . Resolution of DBVP Punchlist Items During this inspection period, the team also inspected 25 DBVP punchlist restart decisiens. Many of the punchlist items were selected from those identified in the D8VP Phase I report as not required for Unit 2 restart. Most of the decisions to place the punchlist item in a post-restart category were found'to be justifie However, several post-restart decisions involving the following punchlist (PL) items required close review during this inspectio (1) PL 2672 - Replace Missing AFW Steam Line Insulation The decision-to categorize this item as post-restart was questioned by the inspection team because of two potential adverse effects of uninsulated steam piping: (a) the formation of additional condensate which challenges both the auxiliary feedwater (AFW) steam piping drain system and the fast start capa-bility of the AFW steam turbine drive and (b) additional heat loads on safety-related heatinge ventilation, and air conditioning (HVAC) system During the inspection, DBVP personnel informed the team that PL 2672 was ,
mistakenly categorized as post restart and that the work required by the item j is, in fact, being done before restar During the second inspection period, the team was provided with information showing that the insulation had been replaced under work package (WP) 1230 (2) PL 1946 - Containment Bypass, System 26 The DBVP Phase I Report observed that System 26, the high pressure, fire-protection system, may become a bypass of the auxiliary building gas treatment system (ABGTS) if parts of System 26, such as the head tank and associated piping that are not designed as safety-related, should fail. The item was categorized as post-restart by DBVP on the basis that the bypass is a bypass of the ABGTS, not a bypass of primary containment. However, upon questioning by the inspection team, TVA determined that the FSAR offsite dose calculations take credit for the effectiveness of the ABGT TVA was informed at the end of the first inspection period that the team considered that this should be a restart item. During the second inspection period, the team was provided with information showing that PL 1946 had been recategorized to a pre-restart statu t _ -_
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(3) PL 8894 - RHR RETEST Attachment 1 of SQEP-45 was issued for punchlist item 8894 as a result of significant condition report (SCR) SQN-NEB-8708, which identified cavitation problems during preoperational testing of residual heat removal (RHR) pumps on Unit 1. ~ The SCR observed that severe cavitation problems occurred when one RHR pump was aligned to four cold-leg injection lines. As a consequence, the RHR preoperational test instructions for Unit 2 were revised to avoid testing in the cooldown modes which created severe cavitation in Unit 1. The description of condition of the SCR further addressed the need to test in the emergency core cooling system (ECCS) modes on Unit 2 to ensure that the adverse effects of cavitation observed at Unit I would not occur. However, in the root cause and corrective action sections of the SCR, it was concluded that testing was not require A subsequent SQEP-45, Al ;achment 2 form and Revision 1 to SCR SQN-NEB 8708 changed the item's category to post-restar However, the revised SCR contains no clear explanation for this actio Discussion with TVA personnel revealed the following information that was not in the SCR:
(a) The condition of cavitation observed at Unit 1 occurred with one RHR pump in operation, return flow to the reactor through four cold-leg injection lines, and flow through the RHR bypass line with the bypass valve in a throttling mode. The reactor vessel head was off and tho reactor coolant system was cold and depressurized. Cavitation occurred in the bypass line and valve, not at the RHR pumps or in the injection line (b) The configuration noted above will not be used for cooldown. Furthermore, 4 the heat exchanger bypass line is closed off by manual block valves in all '
modes of ECCS standby and operatio ;
I (c) Surveillance test procedures 6.1.e and 6.1.a.1 have been performed at Unit 2 to demonstrate satisfactory performance of the RHR aligned in the ECCS mode ]
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During the second period of the inspection, the team reviewed the results of Pre-operational Test W-6.1A1, " Safety Injection System Integrated Flow Test."
This test confirms the adequacy of net positive suction head in the ECCS modes and the validity of the post-restart recategorization. However, SCR SQN-MEB-8708 should be revised to clarify the decision and the remaining post-restart action . Implementation of Corrective Actions for DBVP Findings In the mechanical systems area, the team reviewed implementation of corrective action by a field inspection of two recently completed punchlist item !
PL 2672 required the installation of missing insulation on the auxiliary )
feedwater turbine steam line. The work was done under WP-12301. Field i inspection showed that the steam line was fully insulate )
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PL 3264 required that-a ventilation grill in System 31 be cleaned and cleared
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of penetration sealing splatter that was obstructing air flow. The team found that the work, done under work request (WR) 121450, was satisfactorily complete .4.3 Mechanical Components 4.3.1 Corrective Actions Associated With Engineering Assurance Oversight of the DBVP TVA's Engineering Assurance (EA) oversight review of the Sequoyah Nuclear Plant (SQN) Unit 2 Phase I Design Baseline and Verification Program (DBVP) is summarized in EA Oversight Review Report EA-0R-001, entitled "Sequoyah Nuclear Plant - Unit 2 Design Baseline and Verification Program," which EA issued on April 29, 1987. Section 5.0 of the report summarizes EA Observation Nos. C1 through C6, which EA documented to track 16 action items in the civil /
structural discipline. EA had accepted the corrective action plans for these action items, but the DBVP and/or SQN project had not completed implementing all the associated corrective action, nor had EA yet verified its entire sample of the completed corrective action In the mechanical components area, the team reviewed Action Item C-10 (EA Observation No. C2), Action Items C-15 and C-27 (EA Observation No. C3), and Action Items C-28, C-53, C-54, C-55, and C-57 (EA Observation No. C6). The team reviewed EA's documented concerns for each of the action items, and evaluated the adequacy of the responso to EA's concerns. The team noted that the DBVP had not completely defined or fully implemented corrective action for several action items. However, the team concluded that the DBVP was responding age-quately to EA's documented concern Action Item C-10 documented EA's concern that the SQN project had not captured the following provisions of NRC Regulatory Guide 1.29 in the SQN design criteria:
(1) protection of Category I piping and equipment from the potential failure of non-Category I piping (2) extension of seismic Category I design to the first seismic restraint beyond the Category I isolation valv EA also noted that the SQN design criteria did not adequately define the distinctions between Category I, safety-related pressure-retention, and safety-related position retention pipin The DBVP prepared Problem Identifi-cation Report (PIR) SQN-CEB-8670 (RIMS No. 825 861008 015) to address EA's concerns. On June 5, 1987, EA characterized Action Item C-10 as resolved but ,
open, pending the DBVP's response to EA's request for additional corrective actio Action Item C-15 noted that design criteria SQN-DC-V-13.3, " Detailed Analysis ,
of Category I Piping Systems," did not address the following requirements: j (1) overlap design considerations, such as rigorcus analysis interface with alternate analysis or dead weight hung pipirib <
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(2) interface procedures to control and identify the system / piping' design ;
input required by the pipe stress analyses to implement the design criteria (3) interface criteria to define the TVA stress analysis scope and the Westinghouse Class I nuclear steam supply system (NSSS) analysis l (4) applicability of the design criteria to tubing (5) protection of Category I piping and equipment from the potential failure of non-Category I pipin I The DBVP did not prepare any conditions' adverse to quality (CAQs) in response i to EA's concerns, noting that the DBVP was tracking item (5) by PIR SQN-CEB-8670 (see Action Item C-10). On June 25, 1987, the DBVP provided EA with a summary of completed corrective actions to address Action Item C-15. Action Item C-15 remains open, pending the DBVP's response to EA's request for additional informatio EA reviewed Westinghouse design criteria SQN-DC-V-27.4, "Reacter Coolant System (RCS)," and prepared Action Item C-27 to document the following EA concerns:
(1) The RCS design criteria references design criteria SQN-DC-V-13.3, " Detailed Analysis of Category I Piping Systems," which specifically excludes consid-eration of RCS pipin (2) A lack of definition in the RCS design criteria for the TVA/ Westinghouse RCS pressure boundary interfac (3) The need to review other Westinghouse piping systems to ensure the exis- )
tence of proper stress qualification criteri I The DBVP prepared PIR SQN-CEB-8669, Revision 1 (RIMS No. B25-861219-063), to j address the concerns that EA identified in Action Item C-27. EA has reviewed f
the corrective actions documented in the PIR and is keeping Action Item C-27 open, pending response to EA's request for additional informatio EA reviewed design criteria SQN-DC-V-27.5, Containment Spray System (CSS), and prepared Action Item C-28 to document the following concerns:
(1) failure to reference four design criteria: SQN-DC-V-24.1, " Location and Design of Piping Supports and Supplemental Steel in Category I Structures"; )
SQN-DC-V-2.14, " Piping and System Anchors Installed in Category I Struc-tures"; SQN-DC-V-1.1.2, " Auxiliary Building Structural Steel"; and SQN-DC-V-1.3.4, " Category I Cable Tray Support System" (2) reference to Civil Engineering Branch interim restart criteria (3) improper reference to design criteria SQN-DC-V-13.8, Seismically Qualify-ing Round and Rectangular Duct
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(4) reference to civil design guides instead of to applicable design criteria I
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The DBVP prepared PIR SQN-CEB-8672 (RIMS No. 825-861008-008), to address the concerns EA identified in Action Item C-27. EA concurs with the corrective action to address EA's concerns, and is keeping Action Item C-28 open, pending EA verification of SQN project's corrective action EA reviewed engineering change notice (ECN) L6710 and issued Action Item C-53 to document the following EA concerns:
(1) discrepancies between the pipe support design loads used in the calcula-tions and the pipe support design loads tabulated on the load summary sheets for three pipe supports (2) inconsistent definition and use of normalized /unnormalized design loads for two pipe supports The DBVP prepared PIR SQN-CEB-8709, Revision 1 (RIMS No. B25-870220-088) to address EA's concerns. EA has accepted the proposed corrective actions to address Action Item C-5 EA is keeping Action Item C-53 open, pending EA verification of project's corrective action EA issued Action Item C-54 to document an EA concern that a temporary altera-tion control form (TACF) which specified the tack welding of the valve bonnet to the valve yolk for two high pressure fire protection (HPFP) valves had not been adequately evaluated for seismic considerations. EA has accepted and verified the DBVP corrective actions to address Action Item C-54 and has closed this action ite EA prepared Action Item C-55 to note that the cumulative effects matrix which the DBVP prepared for the high pressure fire protection SYSTER did not include field change notices (FCNs), TACFs, or local design change requests (LDCRs),
and did not include a detailed evaluation of potential synergistic effect EA has accepted and verified the DBVP's corrective actions to address Ad. ion Item C-55 and has closed this action ite EA reviewed the SYSTER for the residual heat removal (RHR) system and prepared Action Item C-57 to document the following EA concerns:
(1) An engineering change notice (ECN) evaluation did not reference a punchlist ite (2) Three ECNs were inconsistently documente (3) The inability to confirm that bolts associated with a partially imple-mented ECN within the system walkdown boundary identification drawing (SWBID) had been torqued to the requirements specified on the typical pipe support detail drawin (4) The SCR/NCR evaluations did not identify punchlist item (5) Discrepancies existed between the System Engineer's SQEP-12, Attachment 2 form and the civil / structural DBVP checklis (6) Restart categorization e' Lwo ECNs that involved component analysis was questione _ _ _ - _ _ _ _ _ _ _ _ -
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(7) An ECN had two SQEP-45 attachments which disagreed on corrective action and justification for a restart decisio (8) A SQEP-45, Attachment 2 form did not document the corrective action .
and justification for restart decision- for an ECN punchlist ite l (9) No restart categorization designations were on the SQEP-45,. Attachment 2 forms for several punchlist item (10) A punchlist item involved components that lack qualification document These components are subject to potential water spray from Category I(L)
piping. EA questioned the documented restart determination for this punchlist ite (11) Discrepancies exist in the restart determination for an ECN punchlist ite (12) Two punchlist items lack a civil / structural evaluatio EA is currently evaluating the DBVP's responses to each of EA's documented concerns, and is keeping Action Item C-57 open, pending completion of this revie .3.2 Review of TVA's Re;91ution of DBVP Punchlist Items The team reviewed the restart categorization of the following component cooling water system (CCS) punchlist iteus:
(1) punchlist item no. 068L1 -(NCR SQN-CEB-8203)
(2) punchlist item nos. 00756, 00763, 00776, 00777, 00793, 00798, 00802, 00805, 00808, 01229, 04917, 06192, 06208, 06967, 07610, and 08974 (PIR SQN-CEB-8638)
(3) punchlist item no. 06241 (PIR SQN-CEB-8657)
(4) punchlist item nos. 00801, 03696, 04544, 04806, 04807, 04810, 04835, 04859, 04871, 06184, 07484, and 07563 (PIR SQN-CEB-8665)
(5) punchlist item no. 08398 (Cat. D FCR 4391)
The team reviewed the SQEP-45, Attachment 2 form for each punchlist item, and the DBVP report, "Sequoyah Nuclear Plant (SQN) - Submittel of Design Baseline and Verification Program (DBVP) Unit 2 Phase I Report," to assess civil /struc-tural DBVP's restart disposition of the PIRs and associated punchlist item The team concurs with the DBVP's post-restart dispositio The team reviewed 16 (of 185) punchlist items associated with PIR SQN-CEB-8638, which identify ECNs that were not documented in piping analysis calculation packages or on piping isometric drawings. The project has verified that the identified ECN changes were incorporated into the calculations and design output documents, and will update the calculations and drawings to reference the identified ECNs after restar _ _ _ _ _ - - _ _
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.Punchlist item 6241 is being closed under punchlist item 4835, which is being tracked by PIR SQN-CEB-8665. The punchlist items tracked by PIR SQN-CEB-8665 identify the lack of alternate analysis (field-routed piping)
-documentation. The DBVP has closed all (210) punchlist items associated with PIR SQNCEB8665. Corrective action to address lack of alternate analysis documentation is being performed under the SQN alternate analysis program, which has completed all Phase I activities required. for restart of SQN Unit Punchlist item 8398 documented a minor drawing discrepancy which is scheduled for correction after restart, and punchlist item 6881 identified a nonconfor-mance report (NCR) that lacks a signatur The NCR will be corrected after restar The team reviewed the following NCRs to confirm the adequacy of CEB's internal and external generic reviews:
(1) PIR SQN-CEB-8637, dated July 21, 1986 (RIMS No. 625-860819-019)
(2) PIR SQN-CEB-8638, dated July 24, 1986 (RIMS No. 825-860730-006)
(3) PIR SQN-CEB-8639, dated July 21, 1986 (RIMS No. B25-860819-016)
(4) PIR SQN-CEB-8657, dated February 20, 1987 (RIMS No. B25-87033-004)
(5) PIR SQN-CEB-8665, dated September 16, 1986 (RIMS No. B25-861126-013)
(6) PIR SQN-CEB-8669, dated November 14, 1986 (RIMS No. 825-861219-063)
(7) PIR SQN-CEB-8670, dated September 25, 1986 (RIMS No. B25-861008-015)
(8) PIR SQN-MEB-86117, dated January 7, 1987 (RIMS No. B44-870108-007)
(9) PIR SQN-MEB-86118, dated January 7, 1987 (RIMS No. B44-870108-006)
(10) PIR SQN-MEB-86127, dated January 13, 1987 (RIMS No. B44-870120-003)
The team concurred with DNE's decisions to conduct internal and external generic reviews for these PIRs as required, except for MEB's failure to conduct an external generic review for PIR SQN-MEB-8612 MEB prepared PIR SQN-MEB-86127 to identify motor cperators that were not installed as shown on the piping physical drawings. MEB did not require a potential generic condition evaluation (PGCE) for this PIR, noting that the deficiency was an " isolate 1 case unique to Sequoyah." The team did not concur with MEB's disposition for PIR SQN-MEB-86127 (NRC Observation 3.16).
The team also reviewed the following additional sample of punchlist items associated with PIR SQN-CEB-8637 for the essential raw cooling water (ERCW) and component cooling water systems (CCSs):
(1) punchlist items 0829, 0831, 0832, and 0876 for the component cooling water syste (2) punchlist items 0828, 0851, 0875, 1186, and 6112 for the ERCW system Punchlist items 0828, 0829, 0875, and 0876 documented missing seismic qualifi-cation documents for valves installed at SQN that had been transferred from Watts Bar Nuclear Plant. Punchlist item 0831 documented missing seismic qualification documents for a replacement switch, and Punchlist item 0832 documented the lack of seismic qualification documents for several valve j Punchlist items 0851 and 1186 documented the lack of seisndc Category I(L) <
position-retention documentation to qualify several switches, and punchlist item 6112 documented a lack of seismic qualification documents for several replacen nt valve motor operator i
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The team reviewed the SQEP-12, Attachment 2A civil / structural checklist forms, the SQEP-45, Attachment 2 forms and the referenced ECNs for each punchlist item to confirm that these punchlist items had been properly dispositioned for post-restart corrective actio The team concurs with the DBVP's post restart disposition of these punchlist item ~4. Implementation of Corrective Actions for Punchlist Items The team reviewed punchlist item 0442 for the ERCW system and punchlist items j 7349 and 9005 for the component cooling water system to assess the adequacy of '
the calculations that CEB regenerated to resolve these punchlist item The DBVP prepared PIR SQN-CEB-8639 (subsequently upgraded to SCR SQN-CEB-8714),
to track the corrective action required for these punchlist items. The i civil / structural DBVP wrote a total of 1070 punchlist items to track missing calculations, out of a total of 1688 valid civil / structural punchlist item The team reviewed the following sample of regenerated calculations which the CEB project prepared for each of these punchlist items:
(1)- pipe support calculations 47A450-21-450 and 47A450-21-451 for punchlist item 0442 (2) pipe support calculations 2-H10-119 and 1-H10-1128 for punchlist item 7349 (3) pipe support calculations 2-J10-910 and 2-H10-911 for punchlist item 900 The team concluded that the calculations prepared by CEB properly imple- 1 mented the corrective action required to resolve these punchlist item The ten also reviewed CEB's implemented corrective actions for two of the three punchlist items that civil / structural EA had completed overviewing at the time of the inspection. Punchlist item 0928, associated with PIR SQN-C2B-6637, documented missing seismic qualification documents for a number of rep?scement solenoid valves installed in the auxiliary feedwater system to meet the requirements of NUREG-058 Punchlist item 7939, associated with PIR 1 SQN-CEB-8669, documented the absence of design criteria for the reactor coolant I system piping in design criteria SQN-DC-V-13.3, which specifically excludes the reactor coolant loops. The team concurs with EA's acceptance of CEB's corrective actions to address these punchlist items. However, the team's review of the work plan which installed the replacement solenoid valves in the auxiliary feedwater system indicated that two support configurations for solenoid valves mounted in the radiation monitoring system lacked CEB seismic qualification calculations (NRC Observation 3.17).
4. Review of EA and DBVP Reports The team reviewed the DBVP report entitled "Sequoyah Nuclear Plant (SQN)
- Submittal of Design Baseline and Verification Program (DBVP) Unit 2 Phase I Report," dated May 29, 1987 (RIMS No. B25-87059-010), and EA's Oversight Review Report EA-0R-001 entitled "Sequoyah Nuclear Plant - Unit 2 Design Baseline and
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Verification Program," dated April 29, 1987. No problems were identified during this review beyond the issues identified previously in Section 4.3 of this repor .4 Nuclear Engineering-4.4.1 Corrective Action Associated With Engineering Assurance Oversight of the.DBVP The TVA Engineering Assurance Oversight Review Report (EA-0R-001) listed seven
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observations (N1 through N7) for the Nuclear Engineering Branch (NEB). These-seven observations embodied numerous action items identified earlier. The team reviewed each of the EA nuclear observations from the standpoint of the adequacy of the agreed-upon corrective action (if the item was considered resolved) and the plan by which EA intended to verify proper implementation of the corrective actio The team found that each of the seven EA nuclear observations were considered resolved relative to having a corrective action that has been agreed to by both EA and the project NE In one instance (N6), EA's review of the implemented corrective action resulted in the status being changed from " resolved" to l " unresolved". The project responded with a five step approach to the correc-i tive action. This revised approach was agreed to by EA and the observation was l again given a resolved status. The team found the steps taken regarding '
Observation N6 to be adequat The team reviewed the proposed corrective action for each of the EA observations and found them to be representative of the concern and adequate. The team met with the EA nuclear staff to discuss their approach for verifying of the imple-mentation of the corrective actio The team questioned the representativeness of the EA verification approach with respect to EA Observation N4. The thrust of this observation was to reconcile the restart category and status between the SYSTER (including addendum) and the punchlist. The reconciliation is to be reported in SYSTER " Closure statements."
The purpose of the closure statement is to ensure involvement and concurrence of the System Engineer with the corrective action and restart categorization for punchlist items developed by the DBVP. EA proposes to verify proper implementa-tion by selecting punchlist items and determining if there is consistency between the SYSTER plus addendum and the punchlist. The team feels that since the ;
reconciliation is being done on a system basis, an enhanced approach would !
involve a sample of systems for which each associated punchlist item is checked for restart category and status consistenc The team inspected the remaining EA observations and found that both the agreed to corrective action and the proposed approach by EA to verify proper implementation were adequate.
l The team reviewed the SQEP-45, Attachment 2 forms and the associated punchlist items for consistency. This was part of the team's effort to independently assess the planned corrective action and restart category. The team found several instances in which the SQEP-45, Attachment 2 form indicated "no change" for the restart category; however, the punchlist notation was changed from
" required for restart" to "not required for restart."
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The team was concerned and believed that the problem could have arisen because of the procedure that controlled the entry of data into the punchlis The team feels that TVA should resolve the problems so that the information con-tained on the punchlist is accurate and usable (NRC Observation 7.5).
4.4.2 Review TVA's Resolution of DBVP Punchlist Item The team reviewed the resolution of several punchlist items. It was noted during this review that punchlist item 4426 had been reclassified from pre restart to post-restar Punchlist item 4426 and SCR SQN-NEB-8615 identify tne corrective action to provide safety grade auxiliary control air to System 90 radiation monitor supply valves in order to meet the requirements of Regulatory Guide 1.45 and design criteria SQN-DC-V-9.0 R2. The punchlist item has been reclassified as post-restart and closed based on this reclassifi-cation. Continued use of non-safety grade air can cause loss of capability to maintain airborne. monitoring capability following a safe shutdown earthquake (SSE) as required by Regulatory Guide 1.45. Furthermore, a loss of non-safety-grade air will not cause containment ventilation isolation, as claimed in quality i information request (QIR) NEB-8624 The inspection team was advised that TVA is currently evaluating QIR NEB-8624 The reclassification of punchlist item 4426 and the present status of QIR NEB-86241 are the bases for NRC Observation .5 Electric Power 4.5.1 Corrective Actions Associated With EA Oversight of the DBVP In the electric power discipline, the NRC team reviewed EA's process for resolving those action items for wnich the DBVP and/or SQN project's response was found to be satisfactory. The team also examined closure of those action items for which the corrective action either has been completed, or has been defined by the project and accepted by the EA grou In the electrical discipline, the EA review of the DBVP resulted in 91 action items. Twenty-three action items remained open when report EA-0R-001 was issued. These were grouped where desirable and converted into 14 EA observa-tions. The team noted that all 14 of these observations were resolved. The team reviewed the resolution of selected action items. Satisfactory resolution -
of each action item was based upon review of the response addressing proper resolution of the concern, assessment of the cause, extent, action to correct the concern, schedule of implementation of the corrective action, action to prevent recurrence, and significance of the concern for the design function of the safety system. The following paragraphs summarize the EA observations that the team reviewe Observation E1: This observation involves Action Items E87 and E8 Action Item E87 related to a discrepancy involving drawing 45N727 and walkdown l package (WDP) 82-52. The drawing discrepancy was scheduled to be corrected before restar Action Item E88 related to errors involving the recording of incorrect walkdown data for 480 V breakers in the auxiliary power system. A supplemental walkdown
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for 31 samples was performed for this action item and an additional error was noticed by E Therefore, a 100% comparison of as-constructed and walkdown drawings of the 480V breaker trip settings was initiated. This review revealed several more discrepancie The NRC team questioned why these discrepancies between actual settings on the breakers and setting data on the as-constructed drawings had not been spotted during surveillance testing. The team was told that during surveillance testing the test technicians failed to readjust the settings to their pre-testing position. To prevent this error in the future, TVA revised surveil--
lance instructions SI-275.1, Revision 8; SI-275.2, Revision 12; SI-258, Revision 11; and SI-258.2, Revision 13.
, Observation E2: This observation involves Action Item E57, which was related l to acceptance of failed test results without justificatio A test was i performed for engineering change notice (ECN) 2945, in accordance with l procedure TVA-22, which requires. verification that a 10 F temperature differen-tial between outside air and the dc ventilation fan exhaust is not exceeded to prevent overheating of the controller. The testing verified a successful pump run for 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, but failed to meet the 10 F temperature differential requiremen The consequences of excessive heating were corrected before the test by moving the controller to a cool area and insulating the heat source As a result of these measures, the 10 F temperature differential cordition was no longer required, but the test procedure was not % vised. Corrective action for this action item includes revision of test procedure TVA-22 to remove the 10 F differential temperature conditio Observation E3: This observation involves Action Itera E51, E53, E55 E64, E65, E69, E72, and E7 Actions Items E51 and E53 identified that reviews per the SQEP-12 checklist for ECN 6712 and ECN 6676 failed to address cable sizing requirement In response
, to these action items, the DBVP referenced the cable ampacity program in lieu of verification of sizing and thermal ratings for the ECN-specific cables. The NRC
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team noted that the DBVP took similar credit for cable sizing evaluation for all ECNs that involved power cables. The ampacity program is based on statistical samplin In light of this fact, the team was concerned about the validity of 100 percent review for each affected ECN. The cable program is being reviewed separately by the NRC Office of Special Projects. Acceptability of this program will be separately addressed by the Office of Special Project Action Item E55 involved a motor replacement with a larger horsepower motor per ECN 2945, without evaluation for sizing of the motor overloads. In response to this action item, the SQN project evaluated and replaced the overloads per work request B222144. Action Item 69 involved minor drawing discrepancies between ECN 6573 drawings, which were corrected by the projec EA closed this action item after verificatio Action Item E64 identified that the voltage range of Brown Boveri relays may not be compatible with the vital dc power voltage range. The project contacted the vendor who confirmed by letter that the range of these relays (70 V-142 V)
was compatible with the voltage range of the dc vital power syste .
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' Action Items E65 and E72 were generated to track concerns identified during ECN 5363 review. Action Item E65 identified design discrepancies relating to response time evaluations and discrepancies relating to the improper referencing of 10 CFR 50 Appendix R calculations. The project resolved these discrepancies and the action item was considered resolved by EA. Action Item E72 identified that the design of an ECN did not meet the design objective This action item was initiated to address NRC Observation 5.7 of inspection report'Nos. 50-327/87-14 and 50-328/87-14. The NRC team reviewed the project's response to this action item and noted that the response did not consider a detailed evaluation of all postulated conditions of plant operation. TVA
. subsequently submitted.a revised response detailing its resolution of this l
item. Action Item E75 identified that the SQEP-12 checklist did not adequately address the problem of imposed voltage for the failure mode analysis. This corresponds-to NRC Observation 6.14, which is addressed in Appendix B to this repor Observation E4: This observation (Action Item E10), was generated by the electrical EA group to identify that the review scope of SQEP-11 did not address technical evaluations of potential generic conditions evaluations in the DBVP. The DEVP resolved this concern by directing engineers (via memo 86-17-04, dated h ne 13, 1986) to perform a 100 percent review of the elec-trical potential generic conditions evaluations (PGCEs) for problems identified at other TVA plants which emy have an impact on the Sequoyah design. Procedure
! NEP-9.1 addresses evaluations of the effects of the PGCEs for Sequoyah on other j t
TVA plants. On the basis of the above DBVP response, EA has resolved this '
observatio Observation E5: This observation was initiated to track 35 action items
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covering all disciplines. These action items are related to items concerning i
the commitment / requirement database and appropriate capture of commitment /
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requirements in the applicable design criteria. EA has resolved this observa-tio I
l Observation E6: This observation involves Action Item E25, which was initiated to identify that a number of electrical design requirements were not captured in mechanical design criteria SQN-DC-V-11.8 R0, " Diesel Generator and Auxiliary Systems." The project included all the required missing electrical criteria in )
i the current revision of design criteria SQN-DC-V-11.8. The effect of the missing criteria on the diesel system was evaluated. This response from the project was found acceptable by the EA group and this observation is now considered resolve Observation E7: This observation involves Action Item E26, which identified that testing requirements were omitted from design criteria SQN-DC-V-11.6 R3,
"120V Vital Instrument Power System." The project intends to include the missing test requirements in the latest revision of the criteri Pending verification of the project's response, EA considers this observation resolve Observation E8: This observation involves Action Item E31, which identified missing references in design criteria SQN-DC-V-27.5 (preliminary), "Contain-ment Spray System." The project plans to incorporate the missing references in the next revision of these design criteri Pending verification of the project's response, EA considers this observation resolve _ _ _ _ _ - _ _ _ _ _ _
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Observation E9: This observation involves Action Item E74, which identified l.
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inappropriate labeling of Class 1E cables for the reactor protection syste The project issued work orders 8214300, B218263, and 8218266 to install the l proper tag EA reviewed the tagging and found it acceptable. This observa- '
tion is now considered closed by the EA grou Observation E10: This observation involves Action Item E77, regarding directive DBVP-D-86-019 which eliminated all open CAQs from the DBVP review scope. EA was concerned that non-DBVP personnel performing reviews of open CAQs would not have i sufficient information to conduct the review adequately. The DBVP responded that open CAQs will be reviewed in accordance with the guidelines of procedure NEP- This response was acceptable to EA and EA considers this item resolve Observation Ell: This observation involves Action Item E80, which was initiated to identify a concern that three change documents were not included in the SYSTER evaluation package for System 82. The project responded that the missing documents will be included in an addendum to the SYSTER. EA verified inclusion of'these missing documents in the SYSTER for System 82 and considers this observation close Observation E12: This observation involves Action Items E83 and E8 Action Item E83 identified a mismatch of the restart category for punchlist items E3586 and E6301 between the vital power system SYSTER evaluation and the SQEP-45 punchlist. It was further noted that many punchlist items having PIRs as originatin'g documents were improperly downgraded to post-restart items based solely upon their categorization as PIRs. To correct this problem, the DBVP issued a directive (DBVP-D-87-002), instructing all the responsible System Engineers to re-review the restart category of applicable punchlist items on the basis of system function. EA considers Action Item E83 resolve Action Item E85 noted that several SQEP-45 punchlist items were omitted from the vital power system SYSTER and several conflicted with the restart categorization in the SYSTER. The DBVP responded that the missing punchlist items will be included in the SYSTER package addendum and the punchlist items will be re-reviewed for restart category based on functionality of the system in accordance with directive DBVP-D-87-00 This response was acceptable to E Observation E13: This observation involves Action Item E90, which identified a concern that unimplemented ECNs 5668 and 2656 were incorrectly evaluated as not required for restar This incorrect restart decision also raised a general concern that appropriate restart criteria were not used in making the restart decisions for unimplemented and partially implemented ECNs. The DBVP responded that ECN 5668 and ECN 2656 would be addressed correctly in the auxiliary power system SYSTER addendum. The DBVP indicated that all of the unimplemented and partially implemented ECNs have now been re-reviewed by the System Engineers per Sequoyah Standard Practice SQA-183 and directive DBVP 87-005. EA verified this by sampling five ECNs (out of total of 34 re-reviewed ECNs in the electrical discipline) and found the evaluation acceptable. EA considers this observation resolve Observation E14: This observation involves Action Item E91, which identified a concern that corrective action defined for punchlist item 6399 did not address the full scope of the problem. In addition, the restart category was not defined. The project response included the correct restart category for
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the punchlist item and the revised scope of'the corrective action addressed the problem completel The project's response was acceptable to the EA grou .5.2 Conditions Adverse-to Quality Reports (CAQRs)
The NRC team also reviewed the handling of conditions adverse to quality (CAQs) to assess TVA's corrective actions for both SCRs and significant CAQRs identified by the DBVP within the scope of the electrical disciplin The team's review included CAQR SQE-870-R01-004 generated by EA and two randomly selected DBVP generated reports (SCRs SQNEEB-8771 and SQNEEB-8790).
CAQR SQE-870-R01-004: This CAQR was written in response to Action Item E5 This action item identified that no indication of the operation of the diesel generator and electrical panel ventilation fans was provided in the main control roo These fans are required to start (in accordance with the technical specifications) in order to keep the diesel inlet air temperature at 120 F or less. Since there is no remote indication for operation of these fans, the plant could be operating outside the technical specification condi-tion without the knowledge of the plant operator. The nominal setpoint for starting these' fans is 80 The project responded that:
The 120 F ambient temperature limit can only be exceeded with one diesel generator running. Any time a diesel generator is running, operation of these fans is verified per operating instruction Diesel generator room temperatures are monitored once per shift; if abnormal temperatures (above 80 F) are noticed, temperature readings are taken every hou Failure of one fan to operate constitutes a single failure: redundant fans remain operabl EA accepted this response and closed this CAQ The NRC team considered this response acceptabl SCR SQN-EEB-8771: This SCR identified a situation in which Class 1E documents were revised by a local design change request (LDCR SQ-DCR-L-1745). In error, this modification was classified as non-safety-relate Corrective action included reversion of all TVA drawing changes since the TVA drawings could be used for field settings of ampacity trip sensors. Because the (subsequent)
revision of drawings per ECN L6434 (generated to address LDCR SQ-DCR-L-1745)
was no longer required, this ECN was cancelled. The project informed the team that the error was caused by lack of proper procedures when this LDCR was
. issued. Present criteria restrict the use of LDCRs to ensure that they are not used for safety-related modifications. The NRC team found the corrective action and the action required to prevent recurrence acceptabl SCR SQN-EEB-8790: This SCR identified a concern that drawings 45N749-1 through 4, which are part of the "SQN-Restart Design Basis Document," did not show or reference the breaker trip setting data for the 480V shutdown boards. Correc-tive action requires the project to revise these drawings to either include adequate references or show the setting data on the drawings. Procedure NEP requires the lead engineers to have all drawings prepared in accordance
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with Division of Nuclear Engineering-Standard 7.01. This procedure requires all related drawir.gs that are not listed as companion drawings to be included as a reference. According to NEP-5.1, revisions to drawings are handled in the same manner as original drawings. Corrective action and action required to prevent recurrence of conditions reported in this SCR were considered acceptable by the NRC tea The NRC team found EA's approach for identification, resolution, and/or closure of the action items and observations acceptable. The approach was considered to meet the technical objectives of the EA oversight program for the DBV .6 Instrumentation and Control
l 4.6.1 TVA Corrective Actions for EA Oversight of the DBVP
- The following Engineering Assurance observations were reviewe Action taken or planned was found to be acceptable
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EA Observations E3 (corresponding to EA Action Item E-75; NRC Observa-tion 6.14), E9 involving RPS cable tagging in the turbine building, 11 l involving upper head injection system design inconsistencies, and 12 L involving steam generator level transmitter accurac A number of EA action items were reviewed and found to be satisfactory, such as I-22, I-23, 1-24, and I-1 Thirty punchlist items being tracked by EA were also reviewed, and the EA approach was considered satisfactor EA has maintained Observation I3 in an unresolved status. This involves a power supply modification for transmitter change-outs and the addition of a diode to a control switch. The team found EA's closure of the transmitter power supply to be satisfactory, and agrees with EA that TVA needs to provide an analysis to confirm that a commercially procured diode is acceptably dedicated as a Class 1E component in the control switch modificatio EA reviewed the DBVP supplemental walkdown results of sensing lines and con-cluded that there was no pervasive as-constructed inadequacy (TVA report EA OR 001, page 7.2.3-3). On the basis of two walkdown results involving HVAC instruments, the team recommended that TVA consider a 100 percent walkdown of the HVAC systems. TVA has subsequently performed a walkdown of protection and control interlocks for the HVAC systems, and has issued a CAQR for the inadequacy of HVAC instrumentation design drawing EA reviewed Action Item I-22 'for the upper-head injection tank level switch substitution, and confirmed that the accuracy calculation indicated that the present switches were not satisfactory. The team agrees with EA's review and conclusions regarding this ite EA Action Items I-23 and I-24 dealt with the addition of the Westinghouse setpoint document as a reference in a number of TVA design criteria documents.
, The team reviewed TVA's corrective actions for this item and found them to be
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EA Action Item I-17 addressed the erroneous categorization of a source document as
"not applicable" for the licensing commitment program. The team confirmed that
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the TVA Nuclear Engineering Branch performed an adequate re-review of these
"NA" designations given to a number of source documents (EA Action Item N-25).
4.6.2 TVA Resolution of DBVP Punchlist Items The team reviewed approximately 12 PIR/SCR/CAQR sets of records in the DBVP electrical and instrumentation areas involving inadequate corrective action, separation criteria violations, failure to meet design criteria, inadequate equipment conditions, lack of electrical calculations, and the temperature range evaluation of the refueling water storage tank transmitter. In this area, the team generally agreed with TVA's resolution for DBVP punchlist item The planned analysis approach described in CAQR SQT-871198 for punchlist item 7843, involving the potential for unintended blowdown of more than one steam generator, was deemed to be satisfactor The. approach taken for punchlist item 8482 in SCR SQN NEB 8722, involving postaccident monitoring channel 1 separation from non-safety-related wiring, was found to be unsatisfactory (NRC Observation 6.21).
l The corrective action analysis for the added isolation power supply in response to punchlist item 6971 was satisfactory.
l TVA's corrective action for punchlist item 7658, involving both a slope change to the sensing lines between the AFW pump suction piping and the associated pressure switches and new process pipe tap locations, was assessed as appro-priat . Implementation of Corrective Actions for Punchlist Items Because of the early stage of corrective action implementation, only several examples were available for inspection. As mentioned in the previous section, corrective action implementation in the analysis area appeared responsive and appropriate. However, the team identified one situation in which the correc-tive action concurred with by the DBVP was technically questionable, in that i the revised corrective action allowed auxiliary control air pressures considerable below design criteria requirements following a postulated LOCA
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l with an adverse auxiliary control air interaction (NRC Observation 6.22).
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4. EA and DBVP Phase I Reports The team reviewed the applicable sections of TVA Report EA-0R-001 addressing the EA oversight effort, and the DBVP Unit 2 Phase I Report. These reports were considered to generally reflect the results of the EA oversight effort and the DBVP, respectivel NRC Observation 6.20 (Appendix B) addresses several concerns with characterization of selected conclusions in the DBVP repor The team also noted that the DBVP report was silent on the content of SCR SQN-EEB-8743, which required relocation of AFW instrument sense lines for pump suction pressure switches 2-PS-139A, B, D and 2-PS-3-144A, B, D. This plant modification was needed to ensure proper operation of the ERCW system supply valves to AFW. This provides the safety-related path of water to the
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-AFW syste This SCR resulted in a significant hardware change to the plant, but was identified only as a calculational deficiency by the DBVP repor .7 Civil / Structural 4.7.1 Corrective Actions Associated With EA Oversight of the DBVP EA Observation.C1 contains EA Action Item C-21, which identified an ECN that was thought to affect Unit.1 only; however, a more in-depth review indicated that Unit 2 was also modified by this Unit 1 ECN. The Sequoyah project issued PIR SQN-MEB-8659 (B44 860910 006) to resolve this action item. As corrective action to this PIR,.the project reviewed all ECNs that purported to apply solely to Unit 1 and found two additional cases-in which the ECNs actually affected both units. EA is waiting for revision of the SYSTERs to include these identified ECNs before closing this observation. The NRC team concurs with the resolution of this action ite EA Observation C4 contains EA Action Items C-41 and C-56. Action Item C-41 stated that adequacy of partially implemented ECN L5779 was not evaluated by the. civil engineering group of the DBVP. The unverified support variances could have affected the supports for a bypass line. The project has stated that partially implemented ECNs are reviewed per SQA-183 and that the SYSTER which includes ECN L5779 would be reviewed by the civil DBVP. EA.is keeping this action item open pending the review of the regenerated support variance calculations and the verification of the SYSTER which includes this EC i Action Item C-56 raised questions regarding the adequacy of the resolution for various punchlist items that were reviewed by EA. The response to this action item shows that a DBVP directive, DBVP-D-002, issued on March 13, 1987, requires that all punchlist items be signed by the System Engineer and the Discipline Evaluation Supervisor before a particular punchlist item can be closed. The DBVP also committed to reevaluate all punchlist. items which were closed before this directive was issued. This action item is being kept open by EA until the DBVP completes this revie The NRC team reviewed.the available documentation regarding Action Items C-41 and C-5 The team concurs with the resolution of both of these action item EA Observation C5 contains EA Action Items C-3 and C-44. Action Item C-3 questioned the technical adequacy of several change documents. The technical adequacy question related to calculations which support the change documents, as well as drawing discrepancies which were discovered during the reviews performed by EA. EA also raised questions regarding field change requests (FCRs) which were not adequately reviewed for. technical adequacy. The SQN project response stated that review of calculations supporting the change documents was part of the calculation review program which would separately verify technical adequacy. The project's corrective action for this EA action item does not address the concerns raised by EA regarding drawing discrepancies and FCR evaluations. This action item was still being followed by EA because of the lack of defined corrective action. The NRC questioned the " resolved" status of this observation since there was no planned corrective action stated by the projec _ _ _ _ _ _ - _ _ _ - - - _ _ _ _
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In response to the NRC concern, EA changed the status of observation C5 to
" unresolved." The project, in turn, revised its response to EA to address resolution of the discrepancies between the calculations and drawings. EA plans to verify that such considerations are properly addressed by the projec l l
Action Item C-44 is related to Action Item C-3 since EA review of ECN L6213 i showed discrepancies between the calculation and drawing related to this EC /
A field walkdown'showed that the calculation was correct and the drawing was wrong. The project response for this action item was acceptable to EA since the particular drawing discrepancy was resolved by the walkdown and because the generic implications of drawing discrepancies would be covered under action Item C-3. The resolution of this action item was acceptable to the NRC tea Observation C6 contains Action Items C-28, C-37, C-40, C-47, C-53, C-54, and C-57, which all relate to various deficiencies in the civil engineering group of the DBVP. In the civil / structural area, the team reviewed Action Items C-37, C-40 and C-4 Action Item C-37 stated that the SQEP-12 review checklist for ECN 2944 R1 did not reference calculations relating to a pipe support drawing change. Later evaluation of this problem showed that the calculations for this particular i support were missin The project has regenerated the missing calculations l' under PIR SQN-CEB-863 The project also reviewed the SQEP-12 Attachment 2 form of the related SYSTER to ensure that this ECN was appropriately captured in the SYSTER. These corrective actions were acceptable to EA and the action item was closed. The NRC team concurs with the resolution of this action ite Action Item C-40 raised questions about improper incorporation of ECN reviews into the system evaluation checklists by the System Engineers. This was a documentation problem and the DBVP has revised the checklists to include the correct information. The DBVP also stated that discipline reviews of draft and final SYSTERs, as required by directive DBVP-D-86-010, would ensure the accuracy of the final version of the SYSTERs. EA has accepted this response and closed this action item. The NRC team concurs with the resolution of this action ite Action Item C-47 was written to address NRC Observation 7.4 - Project Review of Support Variance (NRC inspection report Nos. 50-327/86-55 and 50-328/86-55).
The NRC observation raised questions about the DBVP's review of ECN-5298. In response to this action item, the SQN project has regenerated the missing support variance calculation EA is keeping this action item open pending the review of these regenerated calculations. The NRC team concurs with the resolution of this action item.
i l 4.7.2 Resolution of DBVP Punchlist Items and Implementation of Corrective Actions The team reviewed the corrective actions taken by the project for various punchlist items that were generated as a result of the DBVP. Samples were selected in the following areas (as described in the Sequoyah Unit 2 DBVP Phase I report, Section H-1):
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missing calculations open FCRs no evaluation for pipe rupture inadequate design Samples in each category were picked by the team. The corrective action was reviewed systematically. The sheet identifying the punchlist item, SQEP-12, Attachment 2B (the civil attachment sheet), was reviewed in conjunction with the calculation which resolved the deficiency to determine whether the corrective action was comprehensive. The calculations were also reviewed cursorily to determine whether they were technically adequate. The following are the team's comments on the corrective actions reviewe (1) Missing Calculations The DBVP review showed that calculations for some changes could not be foun Punchlist item 449 relates to a missing calculation that could not be locate The civil design review checklist (SQEP-12, Attachment 28) for ECN L5569 shows that supporting calculations for drawing 48N1314-1 Revision 2 could not be found. In order to resolve this punchlist item, the project has performed calculations (B25-870324-304) to show that the protective structure (MK-6)
for the ERCW piping is acceptable. The team found that this corrective action by the project addressed the punchlist ite Punchlist item 472 identified that FCR 3490, which is related to ECN L6235, was written for a variance to support 47A056-51. The civil design review check-list (attachment 28) identified that the calculation for the variance could not be found. The project has performed additional calculations (B25-851202-300) to show that the variances to 47A056-51 are acceptable. The team agrees with the resolution of this punchlist ite Punchlist item 506 was written to address missing calculations for drawing 41N353-14 Revision 1, which added a battery rack foundation under ECN L559 Attachment 2B of the civil design review checklist shows that these calcula-tions could not be found. The project has performed additional calculations (B25 870407 327) to show that the pads and the anchor bolts for the battery rack are acceptable. The team found the resolution of this punchlist item to be appropriat Punchlist item 3772 identified that no calculations could be found for variance 47A055-78-Al to typical support 47A055-78. The civil design review checklist (attachment 28) for ECN L5207 showed that FCR 342 was written for this variance, but the DBVP reviewer could not locate any calculations relating to this variance. The project has generated calculation B25-870513-302 to shw that this variance to the typical support is acceptable. A cursory review.of this calculation showed that it addressed the correct variance to the support. The team agrees with the resolution of this punchlist ite Punchlist item 6136 relates to missing calculations for typical conduit support 47A056-151. The civil design review checklist (Attachment 28) for ECN L5298 shows that calculations relating to 47A051-151 for FCR 451 could not be locate In order to resolve this punchlist item, the project has performed a
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computer analysis, B25-870507-303, to show that the support is acceptable. The team reviewed this calculation and concluded that it addresses the punchlist item' appropriatel Punchlist item 9291 identified that no calculations could be found for the reinforcing bar cuts that were approved in FCR 1682. The civil aesign review (checklist Attachment 28) for ECN L5429 shows that drawing 41N736-1 was revised for reinforcing bar cuts, but no calculations could be located. The project has performed an evaluation, B25-870401-319, to resolve this punchlist item. It has concluded that the structural integrity of the operating deck floor slab has not been compromised by the reinforcing bar cut shown on drawing 41N736- The team concludes that this resolution addressed the concern raised by the punchlist ite (2) Field Change Requests (FCRs)
The DBVP identified various ECNs with open FCRs. At the time of the DBVP review, documentation for these open FCRs was not available and an engineering evalua-tion could not be made. The team reviewed the following punchlist items relating to this DBVP finding:
Punchlist item 939 was written to identify that the review of ECN L5220 showed FCR 3833 Revision 2 to be open. This FCR was initiated to approve variances to conduit support 47A056-1053 The documentation package provided by the project, including calculations B25-870223-308, showed that Revision 3 of the FCR cancelled these variances to the conduit support. The changes were not implemented and the FCR was closed as documented in B25-86118-61 The team found the closure of this punchlist item appropriat Punchlist item 954 was written to show that FCR 4023 (related to ECN L6533)
was not closed out by DNE. The FCR was issued to request a variance to typical conduit support 47056-1002. The documentation provided by the project showed that calculations (B25-860806-306) were performed to qualify the variances to the typical support. The FCR was closed as shown in document B25-860820-60 The team agrees with the closure of this punchlist ite I Punchlist item 964 stated that FCR 4010, relating to ECN L6553, was open at the time of the DBVP review. The FCR was written for variances to conduit typical .l support 47A056-106 The documentation reviewed by the team showed that l calculations (B25-860814-304) were performed to evaluate the support variance Also, the FCR was closed, as shown in document B25 861022 685. The team found <
the closure of this punchlist item appropriat J Punchlist item 1189 was written because FCR 4076 was open at the time of the DBVP review of corresponding ECN L653 This FCR was written to cover variances to typical conduit support 47A056-10004. Calculations provided by the project (B25-860717-307) show that the variances were acceptable. This FCR was then closed as shown in document B25-860807-616. The team agrees with the
' closure of this punchlist ite ;
l Punchlist item 6252 was written because FCR 4581 was open at the time of review for ECN L6649. The FCR was written to obtain approval for several variances to typical conduit support 47A05-114A. The calculations provided by the project, ,
B25-861029-389 and B25-861029-392, showed that the variances were acceptabl !
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The FCR subsequently was closed as shown in document B25-861118-62 The closure of this punchlist item is acceptable to the tea '(3) No Evaluation for Pipe Rupture The DBVP review found that for various cases, incomplete or no pipe rupture evaluations were made for plant modifications. Each such case was identified by a punchlist item. The team selected four samples to determine whether the closure of the punchlist items was appropriate. The selected punchlist items.and the project evaluation document numbers are as follows:
Punchlist item ECN N Project evaluation RIMS N '
2711 L2775 B41 870611 006 2729 L5194 B41 870228 016 4490 L6533 B41 870617 004 5187 L5594 B41 870228 030 The review of the above documentation showed that the SQN project performed evaluations to determine the effects of pipe ruptures on the changes performe The team did not perform a detailed review of these evaluations. However, the civil design review checklist (attachment 2B) for each ECN was reviewed to determine whether the concern identified was covered within the SQN project evaluation. The team found the closure of these punchlist items to be appropriat (4) Inadequate Design The review performed by the DBVP identified various ECNs that had technically inadequate calculations or analysis. In the civil / structural area, there were ,
only two ECNs with'such a classification. The team reviewed the resolution of both punchlist item Punchlist item 4775 identified deficiencies in the resolution of SCR SQNCEB8627 which was related to ECN L675 The SCR was written to qualify the 1/4-inch surface-mounted plate attached to the crane wall. The project has performed a computer analysis (B25-870107-801) to show that the 1/4-inch plate is structur- i ally adequate. A cursory review of this calculation showed that the concerns raised by the punchlist item were considered properly. The team found the ;
closure of this punchlist item appropriat Punchlist item 7720 was written to document that an incomplete analysis was !
performed for pipe support 17A586-2. The civil design review checklist (attach- I ment 2B) for ECN L6322 shows that the monorail load was not included in the analysis performed for pipe support ]7A586-2. In order to resolve this item, the SQN project has performed additional calculations (B25-870119-803) to show that the monorail supports are adequate for supporting the pipe support load The team agrees with the resolution of this punchlist item.
l The team also reviewed punchlist item 6189, which had already been reviewed by J
EA, to assess appropriate closure. The civil design review checklist (attach-ment 2B) for ECN L6263 identified a discrepancy in the length of a structural brace as shown in the calculations and the as-constructed drawings. The SQN project's response showed that this was a drawing discrepancy and that the
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SQN project has revised the drawings to show the correct length of the brac The team, as well as EA, found the closure of this punchlist item adequat Overall in the civil / structural area, the limited samples reviewed by the team showed that the punchlist items are being resolved properl The NRC team also reviewed 15 punchlist items to determine the adequacy of the restart categorization (punchlist items nos.: 518, 527, 728, 817, 821, 862, 955, 4749, 4907, 4993, 6066, 6216, 7462, 7619, and 9304). The team noted that 4 of the 15 punchlist items (nos. 518, 955, 6066, and 9304) were shown as post-restart items in the computer listing. A review of the SQEP-45, Attachment 2 forms showed that these items were actually determined to be pre-restart items. The team believes that there are many discrepancies between the punchlist and SQEP-45, Attachment 2 forms regarding the categorization of the punchlist items, and that the accuracy of the punchlist should be verified before restart (Observation 7.5).
Overall, the team concurs with the categorization of the punchlist items for restart and post-restart in the civil / structural are The team. reviewed the appropriate sections of TVA report EA-0R-001 covering the EA effort for the DBVP and the DBVP Unit 2 Phase I report. As shown above, the team selected samples to determine whether the items identified by EA and the DBVP were addressed and closed properly. The review of these reports and the limited samples did not identify any major deficiencie . OBSERVATIONS Specific findings of individual NRC discipline inspectors are categorized as
" observations." These observations elaborate on the general comments stated in this report and in some cases provide additional comments not considered to be of a general natur The observations identified by each discipline of the NRC team are provided in Appendix A of this report. TVA actions relating to individual observations will be reviewed by the NRC. Individual observations may be closed on the basis of TVA's response to this inspection report as appropriate. Selected items, noted as confirmatory items, remain open, pending TVA confirmation that the indicated action has been complete . REVIEW Of PREVIOUS INSPECTION FINDINGS The team reviewed TVA's responses to the deficiencies, unresolved items, and observations documented in the following previous NRC inspection reports:
50-327/86-27 and 50-328/86-27 50-327/86-38 and 50-328/86-38 50-327/86-45 and 50-328/86-45 50-327/86-55 and 50-328/86-55 50-327/87-14 and 50-328/87-14 Details about that review can be found in Appendix B to this inspection repor _ _ _ _ _ _ _ _ _ _ _ _
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- MEETING SUMMARIES - REFERENCES A summary of the meetings held relating to the DBVP inspection and a lidt of references related to the series of design control inspections are provided in Appendix C.
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APPENDIX A OBSERVATIONS The observations identified by the team during inspection 50-327/87-31 and 50-328/87-31 are described in the following sections. The observation numbers used continue the numbering system used for previous NRC inspections of the DBV Observation 3.16 - Valve Motor Operator Orientation On. January 13, 1987, the Mechanical Engineering Branch (MEB) prepared problem identification report (PIR) SQN-MEB-86127 to document differences between the installed orientations and the physical piping orientations of ten component cooling water system (CCS) valve motor operator MEB did not request a potential generic condition evaluation (PGCE) to determine if a similar condition existed.for other piping systems at (SQN), or at Browns Ferry, Bellefonte, or Watts Ba The team questioned the lack of a potential generic condition evaluation for this item, and later learned that on May 27, 1986, MEB had drafted an informal i memorandum to request that PIR SQN-MEB-86127 be revised and reissued to require j a PGC The team concurs with MEB's request to reissue the PIR, but notes that i MEB had not yet reissued the PIR. The team also notes that the Civil Engineering Branch (CEB), assigned a portion of the corrective action detailed in the PIR, did not apparently review the PIR for generic applicability, or require initia-tion of such a revie Observation 3.17 - Solenoid Valve Mounting Support Variances !
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TVA drawing 47A054-33 depicts a oypical mounting support detail for the installation of solenoid valves and regulators which consists of a steel !
angle welded to a surface mounted plate restrained by two anchor bolts. Team review of workplan No. 9503, which installed replacement solenoid valves in several different piping systems in accordance with ECN 5457, indicated variances Nos. 54-33-A43 and 54-33-A45 to the typical mounting support detai These consisted of an unbraced 89-inch span of tube steel supporting six solenoid valves. The team asked CEB to provide the seismic qualification i calculation for these variances, but CEB was unable to retrieve the calcula- !
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Observation 4.8 - Containment Airborne Radiation Monitoring System Air Supply Punchlist ite; 4426 had been generated in response to SCR SQN-NEB-8615 which
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identified that isolation valves in the containment airborne activity radiation monitoring (System 90) sample lines are not supplied with essential control i
air, making the radiation monitors not seismically qualified. The SCR notes that the condition was identified in a 1980 licensee event report and that TVA is committed to applicable portions of Regulatory Guide 1.45, which require the airborne particulate radioactivity monitoring system to remain functional when subjected to the safe shutdown earthquake. On the other hand, Quality )
Information Request (QIR) NEB-86241 concludes that it is not necessary for a A-1 )
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seismically qualified air supply to be available to the radiation monitor isolation valves. Reasons stated in the QIR for this conclusion include:
.The sole safety-related function of the monitor is to generate a containment ventilation isolation signal. A loss of air to the sample valves will cause the monitor to produce that inpu The valves will fail closed upon loss.of air. Thus, the contain-ment isolation function is assured without a seismic air suppl The inspection team reviewed punchlist item 4426 and questioned the decision to reclassify it from restart to post-restart. The intent of Regulatory Guide 1.45 is to maintain the airborne particulate radioactivity mcnitoring system functioning after a safe shutdown earthquak This cannot be achieved if the valves close because of failure of the non-safety grade air suppl Also, the team was advised that QIR NEB-86241 is not correc A lost of air to the valves will not cause the monitor to produce the input signal to cause containment ventilation isolatio Observation 6.21 - Change in Corrective Action for PAM Isolation In SCR SQN-8722, TVA identified that separation of one postaccident monitoring channel (i.e. , PAM-1) from non-safety-related wiring had not been implemented as specified in TVA design criteria documents and FSAR Section 7.5.2, which states: "One of the PAM channels may be associated with non qualified circuits, while the other is fully separated from non qualified circuits." The DBVP punchlist (SQEP-45, Attachment 2) was closed out late May 1987 on the basis that either qualified isolation devices would be added to provide electrical isolation or the non qualified instruments would be disconnected from the PAM-1 channel before restart of Unit In late June 1987, the SQN project was in the process of changing the agreed-upon corrective action. The project stated that the isolation requirement would be deleted from the PAM design criteria and the FSAR, and stated that this item was no longer a constraint for restart of Unit 2. The team did not find documentation that the corrective action change had been coordinated with l DBVP, and noted that the proposed change was in direct conflict with a PAM separation requirement stated in TVA electrical separation design criteria l document SQN-DC-V-12.2, Section 4.3.5. The team believes that improved ;
controls are necessary when the line organization deviates from DBVP specified f corrective action Observation 6.22 - Auxiliary Control Air System Design Criteria ]
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Approximately one year ago, TVA stated that the design of the auxiliary control air (ACA) headers within containment had sufficient separation to preclude adverse interaction with high-and moderate-energy lines. However, this conclusion appears to have been without basis as TVA has been extensively evaluating the acceptability of the current ACA design. Both hardware changes and improved analyses are being considered. The team noted that each alterna-tive currently being reviewed by TVA required that the minimum ACA header pressure of 70 psig, as stated in the design criteria documeat, be violate One scenario depicts a minimum ACA pressure of 26 psig, and a period of 5 minutes following a loss-of-coolant accident (LOCA) within containment before ]
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the 70 psig minimum value is restored. Since ACA controls the heating, ventila-tion, and air conditioning (HVAC) systems used to cool safety-related equipment, the team was concerned with the operability of the HVAC equipment and the impact of degraded ACA header pressure for 5 minute Observation 7.5 - Punchlist Accuracy The team's review of the computerized output of punchlist data in the civil /
structural area revealed that punchlist items 518, 955, 6066, and 9304, were
, all categorized as non-restart. However, a review of the governing SQEP-45, L Attachment 2 forms indicated that all these items should be categorized as pre-restar Numerous discrepancies were evident between the data base and the Attachment 2 determination The mechanical systems team reviewed for consistency the SQEP-45 Attachment 2 forms and the associated punchlist items. The team found several instances (punchlist items) in which the SQEP-45, Attachment 2, form indicated "no change" for the restart category, however the punchlist was changed from
" required for restart" to "not required for restart." This was noted for punchlist items 6688, 6691, 6692, 7572, and 757 In the operations area, the team disagreed with the post-restart categorization i of punchlist item 5644. This item concerned non qualified mounting of main '
steam system handswitches on the control panels. This item was closed out because SCR SQE-8618-R0 was initiated to address this issue. In addition, the change was considered outside the DBVP boundary. The team considers that this item should be examined before restart to assess its potential impact on opera-bility of systems during a seismic even The team additionally selected a sample of five punchlist items (Nos. 386, 7742, 8514, 9670, and 9689) to assess the status of implementation and the consistency between the governing Attachment 2 form (SQEP-45) and the actual l punchlist database information. The team biased the sample by only selecting I punchlist items for which field modifications were required. A printout (dated May 26, 1987) of punchlist items with field modifications required was used as the source for the sample selection. The dated printout was used to assess the licensee's progress toward completing required restart actions. (All selected i punchlist items were tabulated as pre-restart on the printout.) The following summarizes the status of this sample:
Punchlist item 385 concerr.ed the fact that approval of valve support and component nozzle loads in excess of the vendor specifications was not documented (SCR SQNCEB8511). This was given the status of
"DBVP closed" based on a decision to exclude from the scope of the ;
DBVP those CAQs that were identified before the DBVP was initiated i l but not yet implemented. (CAQs identified before the DBVP and already implemented were reviewed by the DBVP). These were to be resolved l and tracked by the TVA CAQ process. The punchlist implementation status was tabulated as " completed." The team considered this
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misleading becaase the actual status was unknown, and was immaterial to the DBV Punchlist item 7442 identified that non-safety-related pressure indica-i tors were used to replace existing indicators in the auxiliary feedwater A-3
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system. A SQEP-45, Attachment 2 form closed this item on April 23, 1987, based on proposed corrective action to replace or qualify the pressure
. indicators (SCR SQN-EEB- 8726, Part B). This item was erroneously classified as " implemented," as well as " closed," and also as upon receipt of the Attachment 2 form. This was of concern to the team-because DBVP closure does not imply implementation of corrective action, and the DBVP indicated that the punchlist database (as updated for implementation status by the SQN project) would be used to verify that all pre-restart requirements were satisfie Two. items were not implemented, according to the latest punchlist status. Punchlist item 8514 identified an unimplemented design requirement to abort diesel generator testing automatically fol-lowing receipt of an accident signal and trip the diesel generator supply breaker to the 6.9-kV shutdown board. Punchlist item 9689 concerned the need to restore the hotwell pump trip on a feedwater isolation signal. The FSAR takes credit for hotwell pump trip on feedwater isolation,-and alternative trips of the condensate booster and demineralized pumps (ECN L6215) are not yet implemented, and not scheduled before restar Punchlist item 9670 concerned the addition of a fast bus transfer circuit in parallel to a 30-second time delay circuit in the RPS, potentially degrading the existing circuit. The punchlist item was listed as implemented; however the associated Attachment 2 form (SQEP-45) which should have been used to document implementation was not available. The associated Attachment 2 form documenting DBVP closure (7/6/87) indicated that operability of the subject relays should be verified before restar Post-restart corrective actions, consisting of control circuit revisions to provide indivi-dual testing of the subject relays, were also required. No change-in restart categorization was authorized. Per verbal discussions with DBVP personnel, punchlist items with both pre- and post-restart portions were to change restart status to "no" upon completion of pre-restart corrective actio The implementation status would remain open pending completion of the post-restart corrective
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action. This punchlist item appeared as a complete, implemented,
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pre-restart item in the database without documentation supporting completion of pre-restart corrective action nor a means to track post restart wor The team noted that the licensee's procedures for control and statusing punchlist l items did not specifically address handling of these aspects of the punchlist i item A-4 l
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APPENDIX B LICENSEE ACTION FOR PREVIOUS INSPECTION FINDINGS The team reviewed the corrective actions taken by TVA to resolve the open deficiencies and observations identified in ~NRC inspection report Nos. 50-327-and 50-328/86-27, 86-38, 86-45, 86-55, and 87-14. Correspondence associated with these findings, including TVA responses, are tabulated in Attachment .The following are the team's comments on these item Report No. 86-27 (Closed) Deficiency 6.1-1 - AFW Pump Discharge Pressure Switch Rating TVA provided a description of the process used to change the pressure switches and referred to retrievable instrument range and setpoint calculations that l supported the individual substitutions of these switche Based on this additional information from TVA, the team has closed this ite (Closed) Deficiency 6.1-2 - FW Bypass Control Valve Solenoid Replacement TVA provided. documentation to confirm that the replacement control valve solenoid would be a Class 1E seismically mounted device; hence, this item has been close (Closed) Deficiency 6.1-3 - AFW Pump Suction Pressure Switch Setpoint l As a result of replacement of the AFW pump suction pressure switch, a TVA setpoint calculation was. prepared and issued in March 1986. This calculation did not identify or supersede a previous setpoint calculation made in 197 TVA has subsequently superseded the earlier calculation; on this basis, this item has been close (Closed) Deficiency 6.3-1 - Pressure Switch Hydrostatic Test After Seismic Qualification Testing The team noted that TVA did not routinely specify that instrument vendors provide confirmation of pressure boundary integrity for pressure switches subject to seismic qualification. TVA had the vendor conduct confirmatory pressure boundary tests for the specific Static-0-Ring (50R) example identified by the team. These particular SOR pressure switches were shown to be satisfac-tor TVA submitted a revised response addressing this issue on January 30, 1987 (Reference 11)*, noting that a review of environmental qualification binders revealed that the instruments had been pressure tested. The need to require some form of a pressure test to confirm the integrity of the instrument pressure boundary following seismic qualification has been referred to the Office of Special Projects for review. Therefore, this item is closed for the purpose of this inspectio ,
- References are listed in Section C.2 of Appendix B-1
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Report No. 86-38
.(Closed) Observation 1.1 - Impact of Walkdown Findings on Operating Procedures In inspection report No. 50-328/86-55, the team noted that although the observation was answered and resolved, no sampling had been done to track the corrective action process and confirm satisfactory implementation. The licensee's response indicated that Corrective Action Report SQ-CAR-85-10-016 documents the corrective action taken to address the observation. The team reviewed this report and confirmed that it did address the team's previous concer (Closed) Observation 1.2 - Walkdown Scope Difference From Calculation Boundaries This observation concerned the fact that the extent of the system marked up on the drawing used for the walkdown was not the full extent shown in the boundary calculation. No justification for the difference was filed for revie Procedure SQEP-16 has been changed to require the System Engineer to provide justification for the walkdown boundaries in the System Evaluation Report (SYSTER).
The team reviewed sections of the EA Review Plan which, in turn, had audited the SYSTERs for inclusion of the required just-ifications. The Review Plan stated:
"Has adequate technical justification been provided for any portions of the system on the SWBID [ system walkdown boundary identification drawing] but not walked down?" The audit determined that adequate justificatici had been provided, or in cases where this was lacking, an action item was generated. These deter-minations resolved the team's concerns with this ite (Closed) Observation 1.3 - System Interfaces on Drawings This observation concerned the information related to "out-of-function" portions depicted on system flow (mechanical and controls) diagrams. During system _ walkdowns performed by TVA, the team noted that -some "out-of-function" information was not marked properly or treated in a consistent fashion. The team had left this item open in inspection report No. 50-328/86-55 until a project policy was promulgated regarding out-of-functon information on drawing This policy was formally implemented in a memorandum from the SQN Project Engineer dated January 30, 1987, and widely distributed. This policy was supplemented by a memorandum from the Project Engineer to the Plant Manager and the Modifications Manager further describing the policy and requesting that personnel using drawings at Sequoyah be trained in the appropriate inter-pretation of out-of-function informatio (Closed) Observation 4.2 - Reactor Protection System (RPS) and Neutron Monitor- ,
ing System (NMS) DBVP Scope Boundary The team reviewed Revision 5 of TVA calculation SQN-CSG7-048 (B25-870319-801),
entitled " Identification of Systems Required for Sequoyah Restart." Also reviewed were the marked-up drawings for the RPS and NMS. The team found that the calculations adequately incorporated the necessary portions of RPS and NMS in the description of the systems or portions thereof required to be functional B-2
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l for safe shutdown and accident mitigation. The team found that the markup of the drawings adequately represented the description given in the calculatio l l
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Therefore, the team found the corrective action to be adequately implemented '
and the observation can be considered close (Closed) Observation 6.2 - Neutron Monitoring System (NMS) Flux Detector Qualification Basis
, This observation concerned the lack of qualification of NMS flux detectors and
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their need to function in a postaccident environment.
' In an unreviewed safety question determination (USQD), Westinghouse stated
, that a new accident scenario was not created for postulated failure of the ;
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NMS detectors after a loss-of-coolant accident (LOCA) event within containment that could lead to uncontrolled withdrawal of control rods for approximately 15 seconds. ' Westinghouse subsequently provided additional text to support its USQD determinations, A cycle specific analysis has been performed for both Units 1 and 2 by Westinghouse to address the consequences of a continuous rod withdrawal caused by the postulated environmental conditions following a small-break LOCA (Westinghouse letter TVA-86-733). Acceptable margins to
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critical heat flux (departure from nucleate boiling ratio) were demons-l trated'for the current cycle This adequately addresses this concern for
! pre-restart consideration The associated CAQ (SCR SQN-NEB-8609-R2) remains open, pending long-term corrective action. Three options are being considered by the licensee: continued cycle-specific analyses, qualification of the detectors, or demonstration that the steam line break accident will not cause the postulated rod withdrawa These alternatives are considered to be techni- cally adequat (0 pen) Observation 6.3 - Instrument Sensing Line Walkdown Because of several differences between the design drawings and the actual installation of a sample of heating, ventilation, and air conditioning (HVAC)
sensors, the team had recommended that each sensor in HVAC systems (30, 30A,
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31, 31A, and 65) be walked down. TVA documented in CAQR SQP-871147 that the design drawings were inadequate for HVAC instrument lines based on a walkdown performed pursuant to procedure SMI-0-317-61. TVA noted that sketches were being made of the installation of HVAC sensors that performed a protective or control interlock function, and that these sketches would be converted into design drawings at some point in the future. The team considers that TVA needs t to confirm that the as-built installation as depicted on these sketches is I technically adequate and meets the design requirements for these sensor In addition, TVA should provide a schedule for issuing the applicable design drawing This is a confirmatory ite Report No. 86-45
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(Closed) Observation ? 3 - Status of NSSS Vendor Proprietary Information I I
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requirements made in a nuclear steam supply system (NSSS) vendor's proprietary j document, have been replaced with non proprietary documents. Information '
provided by TVA in its revised response (enclosing Westinghouse letter TVA-86-609), states that all'information considered to be a commitment or a B-3 l
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design requirement is incorporated in the formal proprietary documents that have been sent by the NSSS vendor and incorporated in the commitments /
requirements lis This satisfactorily resolves and closes this observatio (Closed) Observation 3.4 - Pipe Support Design Criteria Observation 3.4 documented provisions for stiff piping clamps and piping sleeves in Watts Bar design criteria WB-DC-40.31.9 that CEB did not reiterate in Sequoyah design criteria SQN-0C-V-24.1, which supersedes the Watts Bar design criteri On March 19, 1987, CEB issued design input memorandum DIM-SQN-DC-V-24.1 to incorporate these provisions into design criteria SQN-DC-V-24.1. Observation 3.4.is close (Closed) Observation 4.4 - Spray Shields for Certain Hydrogen Igniters The team reviewed both the system description for the combustible gas gontrol system (System 83) and the System 83 design criteria (SQN-DC-V-26.1, Rev. 1).
The team found that both documents have been revised to adequately incorporate references to the need for spray shields. The team also reviewed the backup information upon which the design of the shields is based and found that information was adequately referenced in the system design documents. The team found the corrective action to be adequate. Therefore, NRC Observation 4.4 is close Report No. 86-55 (Closed) Observation 2.6 - Flow Rate Assumption Used in Calculation Observation 2.6 noted that calculation SQN-60-0053 used the recommended vendor pump head curve and runout condition to calculate design pressure of the refueling water return line to the refueling water storage tank and observed that a system resistance curve or other justification should be the basis for the runout flow used in the calculation of design pressure. The team reviewed the revised calculation which determined ~the system resistance curve for the refueling water transfer mode of operation for the RHR pump. The calculation was found to be technically adequate. One of the dominant pressure drop factors in the system resistance curve was the partial opening of a valve. The opening of this valve is administratively controlled for purposes of preventing a too rapid drawdown of water inside containment. The team considers NRC Observation 2.6 to be closed, but notes that changes in the administrative procedure controlling the extent of valve opening will affect the results of the calculation. Therefore, the subject procedure and calculation should be linked (cross-referenced) in. light of this interdependenc (Closed) Observation 2.7 - Drawing Control The team reviewed the TVA proposed corrective actions (planned for post-restart) for this observation and found them to be adequate. TVA plans to l t issue revised drawings for the SQN waste disposal system by April 1, 198 i j The TVA commitment (enclosure 3 to Reference 8), which has been entered into l the Corporate Commitment Tracking System, was modified by a TVA letter dated 1 October 2, 1987, to reflect a later completion dat '
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(Closed) 0bservation 5.7 - Diesel Breaker Trip This observation identified a race between load shedding and diesel breaker closure in the diesel generator starting logic which was introduced by a modification. TVA issued a significant condition report (SCR SQN-EEB-86206-R0)
to address this concern. .The team was informed that TVA later determined that although a. failure a breaker to operate during certain plant conditions (such as a blackout during a routine test of a diesel generator before it is
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synchronized with the bus) may cause damage to an emergency diesel generator, this kind of failure is covered by the single-failure criteri In addition, no two diesel generators are tested simultaneously;.therefore, the possibility of a common mode failure for two redundant diesels does not exist. TVA provided a revised response to this observation in a letter dated September 1, 1987'(Referance 16). TVA further noted that to ensure that the breakers are maintained in an operable state, an operational test of the load shedding features is performed every 18 months and a complete disassembly and inspection are performed every five year TVA.further added that the sequence of a safety injection with a delayed loss of offsite power (blackout following a LOCA) is not among the diesel generator loading cases being analyzed (March 12, 1987 letter to the NRC) because it does not significantly contribute to the probability of core mel The FSAR will be updated in 1988 to eliminate this sequence as a design-basis even The NRC team accepts the TVA position that the failure of a breaker to operate can be classified as a single failure and considers this observation closed, (0 pen) Observation 6.12 - Periodic Test of Component Cooling Water System Surge Tank Baffle An internal tank baffle plate within the component cooling water system (CCS)
surge tank provides independent water volumes for the redundant CCS pump The team noted that the integrity of the baffle plate had not been confirmed by CCS preoperational or periodic tests. TVA subsequently performed a leakage test on the surge tanks in both units,'and found no leakage from one tank and minor leakage, possibly from external piping sources, from the other tan This item remains open, pending assessment of the need for a periodic surge tank leakage tes (0 pen) Observation 6.14 - Project Evaluation of SQEP-12, Question 3C This observation concerned the narrow perspective from which DBVP engineers appeared to be addressing failure modes and effects analysis of facility change Note 17 of SQEP-12, Appendix A design review checklist was modified to confirm that electrical open circuit and short circuit failure modes within a panel would not disable the electrical distribution system to the point that required safety functions could not be performed. TVA evaluated the effect of imposed voltage sources within a panel on safety-related circuits (PIR SQN-EEB-86171).
Several changes were nade to the TVA separation design criteria document-(SQN-DC-V-12.2) for qualification of isolation devices and separation of lighting and power outlet circuits as a resul However, during the SQEP-12 review process, TVA did not consider the application of the maximum credible B-5
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ac and dc potential to safety-rela % circuits within equipment cabinets, panels,'and racks. Such analyst e s specified in Institute of Electrical
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and Electronics Engineers (IEEE) 5 al Use Standard 379-1972, Section 5.1 and IEEE Standard 379-1977 section 6. A The team believes that the process for future plant modifications should 1o .ude an imposed voltage analysis as a requirement. In addition, TVA should confirm the acceptability of relay contact-to-contact electrical isolation of Class 1E to non-Class 1E circuit (0 pen) Observation 6.15 - Periodic Functional Test and Reset Timers During a previous' inspection, the team identified that 0.5 second time delay relays in four safety-related pump circuits had not been subjected to periodic calibration or system functional tests. TVA subsequently prepared maintenance instruction (MI) 13.1.3 for an out-of-circuit calibration of these time-delay relays. The team reviewed the maintenance instruction and recent calibration data for 11 such relays in each unit, noting the following:
(1) The required time delay accuracy was stated to be 15 percent. In the I procedure, this was converted to 14 percent which was equivalent to a range of 489 to 520 milliseconds. However, the test equipment used for the calibration had an accuracy of 40 milliseconds, which corresponds to 18 percent of the relay range. This test equipment was not appropriate for the specified accuracy of these calibration (2) Of the 22 relays calibrated, 1 was found to be inoperable and 12 others were found to be out of tolerance. The rang 9 of "as-found" time delay values was 380 to 590 millisecond (3) The calibration method required disconnecting and subsequently reconnecting conductors to these relays. TVA does not plan to perform an "in-circuit" system functional tes The team remains concerned with item 3 in that portions of an initiating circuit, which need to function for certain accident sequences, are not tested in either an integrated or, alternatively, overlapping fashio Report No. 87-14 (Closed) Observation 2.8 - Valve Seat Material Qualification This observation concerned the environmental qualification of certain soft seals used in containment isolation valves. TVA has issued an addendum to the System Evaluation Report (SYSTER) for System 31 which states that the material l is satisfactory based on similar material test data from the Watts Bar Equipment Qualification Progra Furthermore, the seat material will be specifically addressed and qualified for the environmental conditions under the Sequoyah Mechanical Equipment Qualification Program, scheduled for completion by the end of the Unit 2 second refueling outag This satisfactorily resolves and closes this observatio (Closed) Observation 3.10 - Control of Field Sketches i Observation 3.10 documented CEB's use of uncontrolled field sketches in a calculation which CEB prepared to qualify sampling tubing and supports. On B-6 l
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March 5, 1987, CEB issued CAQR SQP-870125 to develop verified field sketches and update the calculation as required before restart. Observation 3.10 is close (Closed) Observation 3.11 - Electrical Board Room Cooler Seismic Qualification Document Observation 3.11 indicated that CEB could not access the seismic qualification documents for the electrical board room cooler. On April 17, 1987, CEB issued PIR SQN-MEB-8797 to retrieve a copy of the missing vendor report post-restar Observation 3.11 is close (Closed) Observation 3.12 - Retrieval of Seismic Qualification Data Observation 3.12 indicated that CEB could not retrieve the flooding and seismic calculations that qualified the restraint designs for two removable block walls. TVA has noted that the block walls have been removed and are not planned to be reinstalle TVA has issued CAQR SGP870170 to regenerate the calculations if the walls are replaced, and has prepared a quality information request to ensure regeneration of the calculation prior to reinstallation of the block walls, should TVA decide to reinstall the wall Observation 3.12 is close (0 pen) Observation 3.13 - West Steam Valve Room Main Steam Line Break Evaluation Observation 3.13 indicated that CEB did not prepare the pipe rupture calcula-tions for the valve room walls in accordance with the FSAR and design criteri On June 4,1987, CEB issued Revision 1 to CAQR SGP870183 to specify the required corrective action post-restart. Observation 3.13 remains open pending further NRC revie (Closed) Observation 3.15 - Zero Period Acceleration Loads The team reviewed the following calculations which CEB prepared to address the additional effect of zero period acceleration (ZPA) loads on the hanger bank that contains pipe support 1CCH-548:
(1) calculation " Pipe Support H10-621," Revision 0, dated June 18, 1987 (RIMS No. B25-870619-801)
(2) calculation " Reactions at Attachment to Embedded Plate From Cable Tray Support MK 2B," Revision 0, dated June 15, 1987 (RIMS No. B25-870616-802)
(3) calculation " Attachment to Aux. Bldg. Embedded PL MK11, 48N1221, El 689'-0", 59'-0"A4, 29'-0"T," Revision 0, dated June 1, 1987 (RIMS No. B25-870601-800)
(4) calculation " Attachment to Aux. Bldg. Embedded PL MK13, 48N1221, El 689'-0", N5'-6"A5, W13'-2"T," Revision 0, dated June 1, 1987 (RIMS No. B25-870602-800)
(5) calculation " Reactions at Attach. to Embedded Plate From Cable Tray Support MK128," Revision 0, dated June 15, 1987 (RIMS No. B25-870616-801)
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(6) calculation "N2-CEB-NRC-MISC., Evaluation of ZPA Effect on Support-1CCH-548," Revision 0, dated July 20, 1987 (RIMS No. 825-870720-804)
(7) calculation " Attach. to Embed. Plate MK13C, Aux. Bldg. El 690, 51'-2"A5, W13'-2"T," Revision 0, dated September 12, 1986 (RIMS No. B25-870602-801)
The team reviewed CEB's calculations to confirm that CEB used default, instead of interim, general design criteria, and that computed forces, stresses, and deflections were within the allowable limits specified in the long-term i criteri The team concurs with CEB's conclusion that the referenced calculations adequately qualify the hanger bank which contains pipe support ICCH-548 for ;
the additional ZPA force '
The team notes that CEB's latest version of TPIPE incorporates ZPA load CEB is using this version for all new piping analysis and reanalysi The NRC Office of Special Projects is currently reviewing TVA's handling of ZPA loads under the employee concerns progra (Closed) Observation 4.7 - Classification of Pre-Restart Items The team had noted that two System 30A punchlist items, involving thermal calculations for cables replaced for NUREG-0588 and main control room indica-tion of vent fan operation, were listed as post-restart item TVA responded that the adequacy of cable ampacity would be resolved before restart and that punchlist item 5943 had been recategorized as pre-restart. The vent fan operation concern was identified for System 30A as punchlist item 6521 and for System 30 as punchlist item 6520. TVA responded that punchlist item 6521 was outside the DBVP boundary for System 30A, and that punchlist item 6520 had been closed and implemented. However, the team determined that TVA did not intend to provide a main control room indication of vent fan operation, and had not implemented any hardware design chang This TVA statement was considered misleading; however, the team had no technical disagreement with the licensee's resolutio (Closed) Observation 5.9 - Punchlist Item Classification The team reviewed the disposition of punchlist items involving the auxiliary power system, the ventilation system, and the component cooling water syste Review of the punchlist items which had dispositions that were questioned by the inspectors was performed during this inspection period. Several changes were made by TVA for items listed in Observation 5.9. For those items that did not change category, adequate documentation of the rationale for the classification was presented to allow closure of this ite (Closed) Observation 5.10 - Design Verification of Drawing Changes The team noted a number of instances in which equipment ratings or settings determined from plant walkdowns differed from values shown on the design drawings. As a result, the team raised a concern about the apparent lack of design verification of technical characteristics by TVA before the design drawings were change The TVA response indicated that DNE reviews each B-8
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drawing deviation for adverse impact on plant safety, and prepares a CAQR or ECN where.necessary to change the plant configuration or to revise other ]
l plant document In addition, DNE is involved in the resolution of any {
additional deviations identified by Modifications Engineering. The TVA response also discussed and dispositioned each specific punchlist item identified in the team's observation. On this basis, this item has been close (Closed) Observation 5.11 SYSTER Consistency l The team identified several errors and inconsistencies in the auxiliary power and component cooling water system SYSTER The TVA response stated that ECN L-5298 had been readdressed in the responses to SQEP-12, Attachment 2 form, Questions 5.a and 5.3 for voltage drop and cable thermal capacity, respectively. The removal of the . electrical interlock for component cooling water pump C-S breakers (ECN L-6310) has been augmented with precaution statements added as Caution Order 1461 and by a change to procedure 50I-70.1, l which provide administrative c'ontrol over the operation of the tranrfer switc '
The post-restart categorization of punchlist items 7797, 8220, f221, and 8518 have been changed to be pre-restar Based on these TVA actions, this item has been close '
(0 pen) Observation 6.16 - HVAC Flow Switch Calibration Data Records and System 30 Surveillance Instruction Procedures The team had noted that the calibration records for HVAC flow switches 2-FS-30-200 and -207 had inconsistencies, and that these switches had not been calibrated over the 1982-1985 period. In addition, no system level surveil-lance instruction existed to the test the various control logic interlocks developed by these sensor During this inspection, the team reviewed TVA's response to the calibration data inconsistencies and found the additional information to be satisfactor Thus, the calibration data record portion of this observation is close i In Section 9.4.5.4 of the Sequoyah FSAR, TVA stated that the electrical components, switchovers, and starting controls of the diesel generator building heating and ventilating systems are tested initially and periodically. Such tests have not been conducted in the past, and a TVA CAQR SQT-871016 Operability / Deportability Assessment Sheet (AI-12) stated that operations personnel verify that, in accordance with SQI-82, the appropriate fans are running when the diesels are started. This assessment concluded that this surveillance provides assurance that the HVAC system is operating properl The team does not agree that this conclusion is correct; rather, such surveil-lance demonstrates only that a particular fan is running, and does not provide any information regarding starting controls or train-to-train switchover interlocks. The team believes that a surveillance instruction procedure is needed for the HVAC system to provide assurance of its operational capability and also to comply with the existing FSAR commitmen B-9
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(0 pen) Observation 6.17 - Diesel' Generator Building Ventilating Fans Control Logic and Surveillance Instruction Procedure
'1 The team identified inconsistencies in the drawings for the diesel generator I building ventilation fan The team was informed that TVA conducted a series I of tests that confirmed the correct operation of the system in accordance with l the electrical. wiring diagrams. These tests also confirmed the existence of i drawing errors in the mechanical control drawing and control logic diagram TVA indicated that the control room drawings would be corrected before restar TVA furt her stated that CAQR SQT-871016 had been initiated to resolve the discrepancy of periodic test of the HVAC system controls and electrical components; however, upon further investigation, the team learned that TVA did not intend to prepare a surveillance instruction (SI), but rather intended to eliminate the FSAR commitment for periodic tes TVA also changed the CAQR corrective action to be post-restar (0 pen) Observation 6.18 - Centrifugal Charging Pump Auxiliary Oil Pump Low Flow Bypass Switch The team was concerned about the administrative control of a manual bypass switch added to the 6.9-kV shutdown board to permit starting of a centrifugal charging pump (CCP) without requiring the operability of the auxiliary oil pum In the unreviewed safety question determination (USQD) for this design
! change (ECN L-60308), Westinghouse personnel were said to have stated that the CCP could be started several times without having the auxiliary oil pump operable. During the inspection, TVA personnel indicated that neither Pacific Pump nor Westinghouse had provided any additional documentation that would support the basis stated in the USQ TVA responded to this concern by stating ~that the addition of the manual bypass did'not create a new operating condition. However, this statement appears to overlook the increased probability that the CCP will be inadvertently started one or more times without initial oil lubrication because CCPs are started so often during normal operation. Hence, this item remains open, pending receipt by TVA of documentation from Westinghouse or the pump vendor to support the USQD statement for this design change. This is a confirmatory ite '
(Closed) Observation 6.19 - 480-Volt Board Room Air Handling Unit Control Logic The team had identified a number of air handling unit fans that could be disabled by a high-temperature cutout switch set at either 85 F or 100 Should the temperature switches disable the ventilation fans at the time of need, this action could cause the loss of other safety related equipmen TVA has subsequently stated that the high-temperature cutout switches would be disabled before plant restart (Reference 15). The team agrees with this commitment; hence, this item is close (0 pen) Obse vation 6.20 - Preliminary DBVP Report The team noted that a number of DBVP draft report evaluations were made from a j very narrow perspective by stating the particular instances were " random j events" or " isolated situations." For example, the number of similar items B-10
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i labeled as random varied from 3 to 41 individual situations. . The team 1 questioned whether these random or isolated situation characterizations were valid, based on the number of situations evaluated by the DBV The response provided in TVA's July 16, 1987 letter (Reference 15) did not seem to be totally responsive to the team's concern because it dealt mostly with the HVAC system. In the area of inadequate testing, TVA changed the j designation to " extensive," which appeared to be more appropriate. The team )
had remaining questions regarding both the electrical and mechanical disci- '
pline's extensive use of the random or isolated characterization for individual item .,
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APPENDIX C MEETINGS AND REFERENCES-C.1 MEETINGS Table C.1 provides a matrix of meeting attendance and lists principal persons contacted for.the meetings conducted at Cedar Bluffs, Tennessee and at Sequoyah Nuclear Plant site in Soddy Daisy, Tennessee. Other licensee personnel wre also contacted. The following paragraphs summarize'the general purpose of these meeting Meeting 1: On June 29, 1987, the NRC held an entrance meeting at the TVA offices in Cedar Bluffs, Tennessee. The DBVP System Engineers and EA Oversight Review Teams are located at Cedar Bluffs. The NRC reviewed the inspection team's plans'to inspect TVA DBVP findings and corrective actions, to evaluate TVA's Engineering Assurance oversight of the DBVP, and to assess the adequacy of TVA's corrective actions for previous inspection finding Meeting 2: On July 2, 1987, a meeting was held at Cedar Bluffs to discuss the interim status and the results of the inspection as of this dat Meeting 3: On July 20, 1987, a meeting was held at the Seouoyah site to review plans for the onsite inspection. The EA Oversight Review Team also provided the NRC a summary of its findings during EA's review of corrective actions for the DBV Meeting 4: On July 24, 1987, the NRC held an exit meeting at the plant site to summarize the results of the inspection team's effort l C-1
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. Table C.1 - MEETINGS Name Organization Title Meeting Attended 1 2 3 REArchitzel USNRC-I Team Leader X X X X SVAthavale USNRC-IE NRC-Electric Power X X l' PEHarmon USNRC-RII Resident Insp., SQN X X X X AduBouchet NRC-Consultant NRC-Mech. Components X X X X FJMollerus NRC-Consultant NRC-Mech. Systems X X X X AIUnsal NRC-Consultant NRC-Civil /Strrctural X X X X LStanley NRC-Consultant NRC-Instr./ Controls X X X X HEBibb NRC-RII SRI St. Lucie X X JNevshemal NRC-Consultant Nuclear Engineer X X APCappozzi TVA-DNE Manager - EA X X X MPBerardi TVA-EA EA Oversight Ad X X X X RPSvarney TVA-EA Civil /Struct. Eng X JFCox TVA-DNE Asst. Proj. En X X BHall TVA-0NP Licensing-Sequoyah X X X X JvonWeisenstein TVA-DNE Team Leader EA ORT X X X EWSteinhauser TVA-DNE Mech. Disc. Eval. X X GBKirk TVA-0NP- Comp. Lisc. Mg X X MTTormey TVA-DNE-S&W Advisor X DSVassallo TVA-EA Senior Civil /Struct. Eng. X JWSemore TVA-DNE Elec. Eng X X HLJones TVA-DNE DBVP Prog. Mg X X X X PRBevil TVA-EA QA Specialist X JBHosmer TVA-0NP Plant Engineer X RCParker TVA-DNQA Plant Engineer X HRRogers TVA-0NP P0RS X WRBrock TVA-DNE Nuclear DES X X X RJames TVA-DNE Civil DES X X X '
PBNesbitt TVA-DNE Electrical DES X X X JCStandifer TVA-DNE Staff X APBianco TVA-DNE SQEP28 DES X X X DLKitchel TVA-DNE DBVP Eng. Mg X X X X RT Holliday ONSL-KLS Nuclear En X X TCPrice TVA-DNE Design Basis Mg X PKGuha TVA-DNE Asst. Br. Ch. - EEB X JAGraziano TVA-EA Lead Civil DBVP X X RTucker TVA-EA Lead Mech. DBVP X X CHGabbard TVA-EA Lead Nuclear DBVP X X
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CCarey TVA-DNE NEB - Nuclear En X l RCSaver TVA-EA Ops. En X WCrosslin TVA-DNE Mech. DES X JH0' Dell TVA-DNE DBVP Plant Mg X PHBucholz TVA-0NP Site Representative X JTLaPoint TVA-0NP Deputy Site Di X HAAbercrombie TVA-0NP Site Director X AMQual k TVA-0NP Asst. to Plant Mg X JRobinson TVA-ONP Asst. Mod. Mg X JRFair NRC-0SP Sr. Mech. En X RAHerman NRC-0SP Chief - Eng. B X LEMartin TVA-DNQA Site QA Mg X-TJArney TVA-DNQA QA Mgr.. SQN X NCKazanas TVA-DNQA Director - Nuc. QA X C-2
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,. C. 2 REFERENCES (1) Inspection Report 50-327/86-27 and 50-328/86-27, forwarded by J. Taylor letter dated April 22, 198 (2) Inspection Report 50-327/86-38 and 50-328/86-38, forwarded by J. Taylor ;
i letter dated September 15, 1986.
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(3) Inspection Report 50-327/86-45 and 50-328/86-45, forwarded by J. Taylor letter dated October 31, 198 (4) 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 (5) TVA Response to Inspection Report 86-27 (Gridley to Grace), dated July 28, 198 (6) TVA revised response to Inspection Report 86-27 (Domer to Grace), dated December 31, 198 (7) TVA response to Inspection Reports 86-38 and 86-45 (Domer to Taylor),
dated February 3, 198 (8) TVA response to Inspection Report 86-55 and other Inspection Items remaining open (Gridley to Ebneter), dated April 22, 198 (9) Inspection Report 50-327, 328/86-55, forwarded by J. Taylor letter dated February 3,198 (10) Inspection Report 50-327, 328/87-06, forwarded by S. Ebneter letter dated April 8, 198 (11) TVA Additional Information in Response to Inspection Report 86-27, (Domer to Taylor), dated January 30, 198 (12) Engineering Assurance Oversight Review Report, "Sequoyah Nuclear Plant-Unit 2 Design Baseline and Verification Program," EA-0R-001, issued April 29, 198 (13) Sequoyah Nuclear Plant - Design Baseline and Verification Program Unit 2 Phase 1 Report, dated May 29, 198 (14) Inspection Report 50-327, 328/87-14, forwarded by S. Ebneter letter dated June 4, 198 (15) TVA response to Inspection Report 50-327, 328/87-14 (Gridley to NRC),
dated July 16, 198 (16) TVA revised response (Observation 5.7) to Inspection Report 50-327, 328/87-14 (Gridley to NRC), dated September 1,.1987.
l (17) TVA letter relating to control and processing of changes to the punch list (Gridley to NRC), dated August 20, 198 C-3
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