IR 05000327/1987042
| ML20237H552 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 07/20/1987 |
| From: | Mccoy F, Patterson C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II), NRC OFFICE OF SPECIAL PROJECTS |
| To: | |
| Shared Package | |
| ML20237H513 | List: |
| References | |
| 50-327-87-42, 50-328-87-42, NUDOCS 8708170265 | |
| Download: ML20237H552 (16) | |
Text
I l u UNITED STATES
[@ Mo )D o MUCLEAR REGULATORY COMMSSION y" p REGION 11 g,
j 101 MARIETTA STREET, c ATLANTA, GEORGI A 3032J
%)***** ,o Report Nos.- 50-327/87-42 and 50-328/87-42 l Licensee: Tennessee Valley Authority 500A Chestnut Street Chattanooga., TN 37401 Docket Nos.: 50-327 and 50-328 License Nos. DPR-77 and DPR-79 Facility Name: Sequoyah Units 1 and 2 Inspection Conducted: June 15, 1987 thru June 26, 1987 Lead Inspector: _ l A)$u,[o Jt>1 ~1/ho/87 G. A. Patterfon / Date Signed Accompanying Personnel:
P. Holmes-Ray, Sr. Resident Inspector, Hatch W. Bearden, Resident Inspector, Bellefonte M. Runyan, QAS, Region II B. Wright, QAS, Region II Approved by: g [ W [ . n 4 J/g_Q/G7 F. R. McCoy, Section t.nief' 6 ate Yigned Division of TVA Projects Summary Scope: This special announced inspection was a quality assurance design control inspection conducted on sit Implementation of the transitional design change process was inspected. This inspection also followed up on previous enforcement items identified in Inspection Report 86-6 Results: In the areas inspected one violation was identified in paragraph 3 for failure to perform a 10 CFR 50.59 evaluation for Revision 3 to the FSAR concerning the hydrogen analyzer accuracy. One licensee identified violation is discussed in paragraph 5.d concerning timely implementation of upper tier procedure requirement h
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E REPORT DETAILS ,
.. Licensee Employees Contacted
H. L. Abercrombie, Site Director ,
- J. T. La Point, Deputy Site Director <--
- L. M. Nobles, Plant Manager B. M. Willis, Operations and Engineering Superintendent ,
B. M. Patterson, Maintenance Superintendent ,
R. J. Prince, Radiological Control Superintendent
- M. R. Harding Licensing Group Manager L. E. Martin, Site Quality Manager
"J. B. Hosmer, Project Engineer R. W. Olson, Modifications Branch Manager (_
J. M. Anthony, Operations Group Supervisor :
R. V. Pierce, Mechanical Maintenance Supervisor M. A. Scarzinski, Electrical Maintenance Supervisor H. D. Elkins, Instrument Maintenance Group Manager *
R. S. Kaplan, Site Security Manager J. T. Crittenden, Public Safety Service Chief R. W. Fortenberry, Technical Support Supervisor
- G. B. Kirk, Compliance Supervisor D. C. Craven, Quality Assurance Staff Supervisor
- J. H. Sullivan, Regulatory Engineering Supervisor J. L. Hamilton, Quality Engineering Manager D. L. Cowart, Quality Engineering Supervisor H. R. Rogers, Plant Operations Review Staff s R. H. Buchholz, Sequoyah Site Representative
- M. A. Cooper, Compliance Licensing Engineer Other licensee employees contacted included technicians, operators, shift engineers, security force members, engineers and maintenance personne * Attended exit interview Exit Interview The inspection scope and findings were summarized with the Plant Manager and members of his staff on June 26, 1987. The following new items were discussed: Violation (327/87-42-01 and 328/87-42-01), Failure to perform 10 CFR 50.59 safety evaluation for Revision 3 to the FSAR on hydrogen analyzer accurac As part of the corrective action for this violation review of past similar type changes is considered a restart ite Licensee Identified V'olation (327/87-42-02 and 328/87-42-02),
Failure to implement upper tier procedure requirements in the specified ninety day time perio _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ . _ _
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The licensee acknowledged the inspection finding The licensee did act identify as proprietary any of the material reviewed by the inspectors during this inspectio During the reporting period, discussions were held with the Site Director and other managers concerning inspection finding During the exit a commitment to provide time limits for the closure of workplans, engineering change notices (ECNs), and Design Change Notice (DCNs) af ter field completion for items under the transitional design change program by August 31, 1987, was discusse The commitment was confirmed on July 2,1987, by the plant licensing staff. This commitment was in regard to Insoector Followup Item 328/86-62-0 . Licensee Action on Previous Inspection Findings (92702)
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(CLOSED) Inspector Followup Item (328/86-62-03); This item was a followup of Revised Calculations for Effects of Radiation on Device Qualification Analysis SQNAP53-036, " Dose From Control Building Emergency Air Cleanup System" (TVA correspondence B45 861218 235, dated December 19,1986). The calculations performed the required reanalysis of the 100-day integrated dose from the Control Building Emergency Air Cleanup System filters following a maximum hypothetical loss of coolant accident. The analysis
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included the integrated dose from the charcoal filter and the HEPA filter i and estimated the 100-day dose on contact to be 36.5 rads and 11.6 rads, respectively, a level of radiation which would have insignificant effects on equipment qualificatio This item is close (OPEN) Inspector Followup Item (328/86-62-13); This item involved the correction of FSAR irregularities described in Corrective Action Report (CAR) SQ-CAR-86-021. The licensee has initiated a three phase program to
, address deficiencies in the present update program and deficiencies in the l Sequoyah FSAR. This is an on going program with a scheduled completion date for the FSAR Verification Program on October 15, 1988. This item will remain ope (CLOSED) Inspector Followup Item (328/86-62-15) and Licensee Identified Violation (328/86-62-14); These related items involved a failure to establish programs regarding commitments by Design Division Procedures and followup on the corrective action. A method was needed to ensure that long-term commitments implemented by procedures are not deleted by sub-sequent revisions. The inspector reviewed the latest issue of Sequoyah Engineering Procedure SQEP-21, Revision 3 (B25 870116 006), Procedure For Preparation, Review, and Approval of the SQ4 Project Manual. The inspec-tor verified that long-term commitments are identified in the procedure /
instructions log so they will not be inadvertently deleted as required by TVA Nuclear Quality Assurance Manual (NQAM) Section 5. These items are close (OPEN) Inspector Followup Item (328/86-62-04); The licensee committed to provide closure times for design change packages as discussed in paragraph 2. Upon review of the applicable procedure changes this item can be close This item will remain ope _ _ _ _ _ __ - _______________
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(OPEN) Violation (327/86-62-02 and 328/86-62-09); This item involved a failure to control design requirements for the hydrogen analyze Applicable vendor manual requirements were not followed during installa-tion of the hydrogen analyze The inspector reviewed SQEP-39, Review and Approval of Vendor Manual Revisions. This procedure describes the Division of Nuclear Engineering (DNE) responsibilities for the receipt, review, and approval of new vendor manuals, and vendor manual revision request This procedure also describes the DNE review of existing manual Procedural controls are in place to prevent similar problem Since the manual review program is not complete the inspector takes exception to the statement in TVA's response to this violation that this is believed to be an isolated case. The vendor manual control progra was reviewed, and out of 600 manuals in the library only 146 had been labeled as approved for conditional use. Conditional use means a request was made to use the manual and the manual has undergone a Nuclear Site Director approval process. Copies have been made of all the manuals and sent to DNE for technical review. Once this review is completed the manual will be a " controlled" vendor manual. This review is scheduled to be completed by January 1988. This item will remain ope (OPEN) Inspector Followup Item (328/86-62-02); This item concerned the closure of ECNs prior to restart. The licensee's supplemental response dated May 22, 1987, regarding ECN closure and FSAR updates was reviewe The closure of 1200 old ECNs is to be completed by October 15, 198 Of the 1200 ECNs, 670 are those on Critical Structures, Systems, and Com-ponents scheduled for closure in December 1987. This ECN closure effort was found acceptable for restar This item will remain open until completion of the ECN closecu (OPEN) Unresolved Item (327/86-62-01 and 328/86-62-08); This item concerns the adequacy of the hydrogen analyzer to meet operability requirements of the Technical Specifications (TSs). This is still under review due to inspection of the sample lines in containment and identification of potential water traps of 14 feet. The vendor has recommended a maximum of six fee This item will remain ope (CLOSED) Unresolved Item (327/86-62-03, 328/86-62-11); This item involved evaluation of an Unreviewed Safety Question Determination (USQD) for changes to the FSAR on Hydrogen Analyzer Accuracy. This unresolved item is administratively closed in this inspection report but has been upgraded to a Violation (327,328/87-42-01). 10 CFR 50.59 states that modifications or design changes that cause a change in the system or component description in the FSAR require a written safety evaluation to assess whether the change constitutes an unreviewed safety question or a change in the facility TS Revision 3 of the Sequoyah FSAR changed the speci-fied accuracy of the hydrogen analyzer from the previous value plus or minus 0.35% to plus or minus 1.5% without the support of a 10 CFR 50.E9 safety evaluation. A USQD was subsequently performed by the licensee for the subject FSAR change on March 26, 1987, and concluded that the indi-cated accuracy of the hydrogen analyzers would not exceed plus or minus
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1.5%. Licensee actions taken to resolve this specific violation and corrective steps taken to avoid similar future violations (B45 861114 257
- DNE Program Plan for Update FSAR Revisions; L44 870203 805- ECN Closecut and FSAR Updates) appear to be satisfactory. However, the inspector is concerned that other similar documentary type changes to the FSAR may have been implemented in.the past without supporting safety evaluations being conducte Review of past FSAR revisions is considered a restart ite The licensee is requested to address this concern when responding to the subject violatio (CLOSED) Inspector Followup Item (328/86-62-01); The licensee has revised Administrative Instruction AI-19 (Part IV), Attachment 14, DCN/ECN Closure Verification, to update the checklist to include any requirements that have been previously identified by the ECN Closure Task Group. A single checklist for ECN closecut is now in use. This item is close (CLOSED) Inspector Followup Item (328/86-62-05); Table 6.3.2-4 was revised in FSAR Amendment Four dated April 20, 198 Table 6.3.2-4 specified the sequence of changeover operation from injection to recir-culation for the RHR system and was modified in Amendment 4 to agree with the current plant configuration, i.e., that the SI actuation signal must be reset. This item is close (OPEN) Inspector Followup Item (328/86-62-12); The licensee has completed the evaluation of the problems associated with maintaining battery room temperature. Various work requests have been performed to calibrate air conditioning system flow switches and temperature switches and verify proper operation of unit heaters. The inspector determined from discus-sions with licensee employees that the battery room temperature problem was now under control but that the four battery room exhaust fans could not be repaire The existing exhaust fan motors were apparently originally supplied as 208 volt motors and locally rewound for 460 volt application during constructio ECN 7164 has been generated to procure and install the new Class 1E motors. ECN is in the review process and procurement is underway. This item will remain open pending review of further corrective actio (CLOSED) Inspector Followup Item (328/86-62-06); The licensee has deter-mined that no change to the TSs is required since the main feed pump trip is an additional safety feature and is not taken credit for in FSAR i accident analysis. As such, the associated instrumentation is not needed to be included in the TSs. AI-19 (Part IV) requires a determination of need for a change to be made by the Regulatory Licensing Supervisor and a Senior Reactor Operator with the determination documented in the work pla The basis for the licensee's determination is the Atomic Industry ,
Forum (AIF) criteria for what should be included in TSs and the proposed ]
Commission's Policy Statement concerning TS changes, as filed in the !
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Federal Register dated February 6, 1987. -The inspector agrees with the licensee's evaluation that a change to the TSs is not needed and that an adequate program exists for determining when a change to TSs is require This item is close (CLOSED) Unresolved Item (328/86-62-07); The licensee has completed an evaluation of the shield wall penetration associated with ECN L603 The results of this evaluation are documented in Quality Information Release-QIR N2B87151 (B45 870430 252). The inspector reviewed the licensee's evaluation which stated that the subject penetration was acceptable with respect to ALARA and Environmental Qualificatio Additionally the inspector reviewed the transitional program as described in SQEP-13 and determined that additional administrative controls are present which should ensure that this review will be performed as part of the design process. This item is close . Unresolved Items There were no new unresolved items in this repor . Program Overview (37700) Two phased approach Problems in the control of the design process led to the establishment of a design baseline and verification program to correct the past problems. To prevent problems in the future an improved design control program is being implemente The program will consist of first a transitional phase followed by a permanent phase. In Section II.3.3 of the Sequoyah Nuclear Performance Plan, TVA committed to implementing the transitional program prior to restar The permanent program is currently scheduled to be implemented the first quarter of 198 During the inspection, meetings were held with onsite and corporate representatives to obtain an understanding of the differences between the two phases since only the transitional program will be imple-mented prior to startup. Two major items included in the transi-tional program are the unitized design changes and usage of configu-ration control drawings (CCDs). The goal of the transitional program was to improve the cxisting design control process and to provide an effective transition to the permanent syste The change to the permanent program is expected to be mainly administrativ The permanent program is based on a plant modification package (PMP). The PMP program will be more formalized using Corporate Nuclear Engineering Procedures (NEPs) for all the sites. . The essential elements of the design change process consists of technical reviews and approvals and will not change. The PMP will replace the engineering change notice,
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6 Change Process The design change process consists of a change request initiated by one of. three methocs. A simplified block diagram is shown' in Attachment 1. The change request is followed by the engineering preparation of an ECN or a design change notice (DCN) for minor or emergency items. Next the work plans are prepared and warked by the modification and maintenance sections. Finally, the dr.iwings are updated and the change package close The main procedures covering the program are as follows:
Sequoyah Engineering Procedure, SQEP-13, Procedure For Transi-tional Design Change Control Sequoyah Engineering Procedure, SQEP-60, Handling Of Modifica-
-tions Using Design Change Notices
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Sequoyah Engineering Procedure, SQEP-43, Control 0F Configura-tion Control Drawings Administrative Instruction, AI-19, Plant Modifications:
Modifications Requests All of the above procedures were found to have been implemented and used during the preparation of design change During the inspection of the design change process the mechanism for assessment of operability and determination of deportability was reviewe As an example a recent issue concerning the potential for loss of a containment air fan due to a design and construction deficiency was checked against the assessment method. Licensee Event Report 327/87003 dated February 11, 1987, provides the details 'of this proble A new administrative instruction, AI-12, Corrective Action, was implemented February 20, 1987, to resolve conditions adverse to quality (CAQs). This procedure provides a single comprehensive method of resolving CAQ Items are identified by issuing a condition adverse to quality report (CAQR). The Plant Operations Review Staff is required to complete an assessment within three working days of receip Proper implementation of this procedure i should preclude delays in reporting item j c. Transitional Phase Program Implementation Status During the review of the implementation of the transitional program 160 ECNs were found in progress. Of this number 17 had :ompleted the preparation stage. Two items had completed the modification and were i
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in the process of updating the drawings. None of the ECNs had been close l The review during this inspection was based on this limited number of ECNs. The number of completed items is not expected to change for several months. Based on this limited review the program was found to be implemented in accordance with the Nuclear Performance Plan with one item of concer No time limit for closure of ECNs or DCNs was in the applicable procedures. Time limits for updating of plant drawings were found in SQEP-43. Fifteen (15) days for primary drawings and 90 for secondary drawings were specified. However, nothing seemed to drive the final l closure of the ECNs. This was the area of concern for Inspector Followup Item 328/86-62-04. For this program to be effective in correcting past problems _in the design control process with a backlog of open ECNs some type of closure controls are necessar TVA committed to provide closure times as discussed in paragraph 2 of this report. TVA is scheduled to . complete closure of a backlog of 1200 old ECNs by October 15, 1988, Of the 1200 ECNs 670 are Critical Structures, Systems, and Components which are to be completed in December 198 The inspector reviewed a new computer tracking system. Based on !
conversations with licensee personnel and a system demonstration, the new Design Control Document Tracking System (DCDTS) apparently will consolidate and effectively control design information interface The computer-based DCDTS will allow a designer to. call up a given drawing, for example, all ECNs, FCRs, sketches, and calculations which affect it. This QA-certified system will comprise a central logging system for ECNs, Field Change Requests (FCRs), and drawings and should eliminate the discrepancies inherent in a multiple logging ,
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sy stem . Used effectively, the DCDTS will give the designer sufficient information to avoid errors due to overlapping or conflicting ECN The licensee is loading information into the DCDTS, which should be fully functional before startup and fully implemented shortly thereafte d. Design Change Notice A design change notice (DCN) may be used in lieu of an ECN package for emergency or minor modifications. The primary purpose of the DCN
, is to approve design status changes to ECNs controlled per SQEP-13.
l The structure of the DCN is tailored to be the method of changing PMPs once the permanent program is in plac The DCN procedure SQEP-60 was implemented on April 14, 198 Only two minor modifications have been initiated using the procedure.
- Minor and emergency modifications are defined in SQEP-6 Minor l modifications shall not be any of the following
Affect TSs or involve an Unreviewed Safety Question
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Change System functional operability
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Require extensive or complex design work Involve a change to the FSAR Involve substantial changes to operating or maintenance procedures Emergency modifications are used to prevent or correct conditions which could lead to :
Imminent loss of operating capability Imminent loss of operability of safety equipment Equipment damage l
A potential hazard to the health and safety of employees or the
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public The two minor modification packages were reviewe The first DCN (X-00001 A) was a modification to the condenser water l boxes to prevent leaks in the bellows of expansion joint The modification consisted of removing an internal ring and then coating the inside of the joint bellows with belzon This modification involved a change to a vendor drawing and the inspector reviewed the control process for this change. A portion of a drawing from the vendor manual was redrawn on a TVA drawing and the change'made on the TVA drawing. The inspector questioned what prevented someone from getting the ol'd drawing from the vendor manual and using it if it was not somehow noted or updated. The vendor manuals are con- !
trolled by AI-23, Vendor Manual Control . Stated in AI-23 is th vendor manual drawings are for information only. All controlled or conditional use manuals have a sticker affixed to the front of the manual stating, " Drawings in manuals are for information onl Contact DCC for drawings". Drawing required to be used from vendor manuals shall be processed in accordance with AI-25, Request to Use Vendor Drawing. The inspector toured the storage location for vendor manuals and found the stickers to be in place. Thus, the controls in place on usage of vendor drawings should prevent problems using outdated vendor drawings. Sequoyah has committed to provide vali-dated vendor manuals for all CSSC and EQ equipment by January 31, 198 >
The second DCN (X-00005 B) was replacement, installation, or substitution of damaged missing or incorrect clamps on capillary tubing for various instrument system loop In this package the inspector noted that the USQD checklist consisted of several pages while the first DCN (X-00001 A) contained only a short USQD screening review form. The source of the screening review form was questioned
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and found to be from an upper tier document'(Program Manual Procedure
- PMP) which had not been implemented into the NEP procedures. 'The short form was contained in ' PMP 0604.04, Evaluation of Changes, Tests, and ' E'xperiments , dated January 20, 1987. This PMP- had not been implemented into Nuclear Engineering Procedure (NEP-2.1),
. Licensing Support. Program procedure 1701.01.01, Section 6. J requires implementation in 90 days. Since 90 days had elapsed this i was a' noncompliance ite The licensee provided a letter dated May 21, 1987, from Engir.eering Assurance (EA) where the problem was i recognized. Stated in the letter was that each PMP was being reviewed by EA and compared against the NEPs for any impacts. The -
licensee provided a change order to NEP-2.1 dated June 23, 1987, to ;
correct the specific inspector concern. Since both the specific and l programmatic corrective actions where being addressed this item was J considered a licensee identified violation and no notice will be i issued (LIV-327,328/87-42-02). Implementation Review (37700) Review of ECN 7102 / Workplan 12500 Capping of control air lines The modification accomplished by WP 12500 and ECN 7102 was initiated by Design Change Request (DCR) 2259, Significant Condition Report (SCR)86-121.and. Employee Concerns Task Group (ECTG) Report 229.0 Its purpose was to resolve an interaction between the pressurizer j spray .line and a section of the auxiliary control air system (ACAS) 1 in the event of a high energy line break (HELB). The section of the ACAS involved was the piping no longer in use which had been the supply to the PORVs. The PORVs are no longer air operated. The j modification was to install a blank in the one inch ACAS line to 4 isolate the piping near the pressurizer spray line and thereby i ensure that a HELB would not depressurize the ACA l The ECN was reviewed for compliance with the transitional ECN !
program. Since the ECN was not closed, the complete process imple- I mentation could not be reviewe Workplan WP 12500, which was !
developed from ECN 7102, was field complete and the drawing revision was in progress. All of the applicable elements of the transitional ECN program were included in the package. The USQD adequately addressed the safety issues associated with the modification. On the modification criteria sheet the component testing, system testing and inservice testing were addresse The review for need of a TS change was contained in the workplan and was signed by a Regulatory Licensing supervisor. Material requirements and welding requirements were included. The effects on system operability were discusse One area of concern surfaced during this ECN/WP review. An instruction change form was initiated after the job was field ;
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complete to change a valve number in the workplan. The reference to the wrong valve number was recognized at the time of issuing the I
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clearance for the work. In this case the listed valve number was
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-2-32-333 and was obtained from a poor copy of the applicable drawin The correct valve number was 2-32-338 as determined from a better copy of the drawing. No workplan change was initiated at that tim The practice of continuing work with a known procedure error is not to be condoned. This example is of minor technical significance and does not, by itself, appear to be a programmatic problem. Unless additional examples are seen no citation will be issued, Review of ECN L7083/ WP 12374 Add Baffle Plates to the Diesel Crankcase Pressure Detectors ECN L7083 as implemented by WP 12374 added baffle plates to the crankcase pressure detectors on each diesel engine to prevent false high pressure signals from causing unwarranted engine trips. Ttis modification was initiated on a temporary Alteration Control Form 1-87-003-82, followed by a Category D FCR No. 505 A recent modification to the diesels replaced the existing vibration dampers with gear-type dampers, resulting in increased oil spray hitting and activating the high crankcase pressure detector The baffles block the oil spray while permitting legitimate pressure surges to be felt by the pressure detector The ECN was reviewed to determine compliance with the transitional design control program as delineated by SQEP-13. The ECN appeared to contain all of the elements required by the transitional program which bare relevance to this particular modification and the sequential flow of events was consistent with SQEP-13 and other related procedure The inspector's review of the USQD and seismic analysis revealed no discrepancies. Both of these analysis were well thought-out and writte Workplan 12374 documented the field installation of ECN L7083, which is field complete and currently in the drawing update proces One item of concern was that six (over half) of the crankcase high pressure detector setpoints were found to be above the specified band ,
of 1.0 to 1.7 inches wate It was later determined that the acceptance band was in error in a conservative direction. A revision is in progress to IMI-82, Appendix A, to change the acceptance band to 1.0 to 3.0 inches water in accordance with vendor information, j Other than a few minor administrative errors which were corrected, '
the workplan appeared to conform to procedural controls and accurately implemented the EC Review of ECN L7089 / WP 12499 Replacement of Containment Isolation Check Valves The licensee initiated ECN L7089 (4-13-87) in response to Category D FCR 5161 dated 12-25-87. The ECN was written to replace four
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existing, worn out Essential Raw Cooling Water (ERCW) containment isolation check valves (2-67-562 A,B,C,0) with another style more capable of passing the containment leak tes This ECN will also revise the pertinent flow diagrams to show proper class boundaries, replace carbon steel test connections 561 A,B,C and D with stainless steel connections and relocate the one-half inch drains and vents to accommodate the installation of the new check valves. The inspector examined documentary evidence (not in the ECN package - S02 870414 806) verifying that the Change Control Board approved the subject modification in accordance with SQA - 183. The inspector had the responsible DNE Task Engineer discuss the preparation, contents and adequacy of the required documentation contained in the subject ECN packag Approval was granted to this ECN to use as-designed drawings in lieu of CCDs by the Project Engineer on April 13, 198 This exception was given in order to expedite the start of field work. A CCD will be originated prior to the completion of the field wor The existing design criteria documents listed for this modification (Section 1.6 for Modification Criteria N2-L7089-01) do not mention the use of TVA interim revisions to general design criteria which specify reduced margins of safety. Examination of the DNE calculation summaries and discussion with responsible Civil Engineers revealed that an interim safety factor (SF) of 2.8 for hanger and pipe support expansion anchors was determined acceptable by TVA for the restart of SQN. The hanger and support anchorages are to be requalified to the original general design criteria (SF=5)
after restart of the plant. The inspector examined the NRC Staff evaluation of the proposed interim acceptance criteria for small-bore piping (A02 861222 032). Page 6 of the subject document grants NRC acceptance of this interim reduction of licensee commitments for small bore piping. The NRC has not reviewed nor approved interim acceptance criteria for large bore piping nor such criteria for large bore hanger and support anchorages to date. This area is currently being discussed between NRC/OSP and TVA. The inspector reviewed the ECN package for proper documentation, authorizations, preparation, review, approval and distributio All areas were found acceptable except for one very minor documentation omission. The "N0" box for the third question in the USQD documentation was not checked; however, the written justification clearly specifies the margin of safety for any TS is not reduced. The inspector concluded that ECN package L7089 had been acceptably evaluated, documented and processed in accordance with SQEP-13, the governing procedur Workplan (WP) 12499 was written by the Mechanical Modification Section to implement the entire scope of ECN L708 Field work (protective coating of carbon steel) was nearing completion at the
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time of this evaluation. Consequently, the subject ECN had not gone through the complete cycle to closure. The WP package was examined and found to contain the required table of contents. WP control form, ECN package, WP specification with detailed instructions, inspection requirements and inspector hold . points, a revision section, the applicable FCR, inspection data sheets and other required reviews and approvals. The inspector concluded the completed package adequately defines the work requirements, and contains sufficient detail to ensure correct installation, inspection and documentatio This in process WP has been satisf actorily documented and processed in accordance with SQN AI-19 (Part IV), Rev. 21 to date, Review of ECN L7082 / WP 12429 Limitorque Actuator Gear Replacement ECN L7032 as implemented by Work Plan 12429 replaced gear sets on the MOV actuator for 2-FCV-1-17, main steam isolation valve to turbine driven auxiliary feedwater pump. This change was necessary to ensure operation within required closing stroke time of 10 seconds assumed by the High Energy Line Break (HELB) analysi Prior actual times had exceeded 10 seconds during ASME Section XI testing. This ECN was accomplished in conjunction with ECN L6823 as implemented by Work Plans 12298 and 12305 which replaced the existing MOV actuator motor with a larger (25 Ft-Lb) mntor 'to adequately handle the thrust and torque required by the valve closure during maximum differential pressure condition Under this ECN the motor pinion, shaft gear, torque switch and limiter plate were to be replaced to accomplish the faster stroke timin The licensee was in the process of installing the new parts at the time of the inspection and post maintenance testing had not yet been attempte Additionally, the inspector reviewed this ECN and WP to determine the !
extent of licensee efforts to utilize available vendor information during the accomplishment of the modification wor Limitorque l Manual (Bulletin SMBI-82C), Type SMB-00 Instruction & Maintenance, was utilized in development of the WP but the vendor manual did not ,
i address the subject of changing gear sets to reduce valve stroke
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times. Documentation contained within the ECN did confirm that the i licensee had corresponded with Limitorque Corporation to determine i new recommended gear ratio, needed motor capacity, and torque switch settings.
L Audits (37700) Engineering Assurance Review of Transitional Change Control TVA's Engineering Assurance (EA) Staff conducted a review of the transitional design change program as a portion of its review of the Design Baseline and Verification Program (DBVP). This report was
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issued April- 30,1987, and entitled " Engineering Assurance Oversight Review Report, EA-0R-001, For the Sequoyah Nuclear Plant Unit 2 -
Design' Baseline arid Verification Program".
The EA review of the transitional program was divided into three major areas -
operations ' engineering, quality assurance, .and
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constructio The. assignment given the . Operatior; Engineering discipline was to determine'whether adequate interfaces were in place between Plant 0perations and other involved organizations, and that
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the p scess could be effectively implemented. This review conc 'uded P that. the transitional program delineated in procedure SQEP-la is
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technically adequate and appears to be workable in its present for i e
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Several recommendations were made for prcgram enhancement including
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the addition of Operations signoff blocks on the ECN cc/er shee EA!sQRd5sgipline'reviewedthetransitionaldesignchangeprogramto verify 'that the program was procedurally controlled and adequately i
implemented. In addition, the team determined whether interfaces-had been adequt*ely est.nblished between DNE, Site QA, DNC,'and the Plant Staff, and'whether previout,1y identified design control weaknesses had been corrected. Ssen ECNs were reviewed in detail but due to the nature and status of these ECNs, the EA Team was unable to make a conclusive assessment cf tN transitional program implementatio Several of the ECNs reviewed had been grantec' waivers to use the old design control program in t!ne interest of expediting work. Several program concerns were identified by the EA Team including the need for additional signoffs ir the ECN review process and various proceduial clarification '
EA'ad Construction discipline " reviewed the transitional program to determine the adequacy of modification constructability for two recent ECN's and the associated workplans. This review concluded that the ECN packages and workplans accurately reflected the required change, were complete, and were processed in accordance with the'
'A requirements of the transitional design change control procedure.
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The EA Tean will perform a followup eview in the near future when a fE greater number of ECNs have been processed through the transitional
- T progra Quality Assurance Audit The inspector examined CAQR No. KXF 87 0004, Rev. O, (B05 870316 003)
resulting from DNQA Audit No. QSS-A-87-0012-D01. The subject audit was ' performed to determine the extent of DNE Nuclear Engineering Procedures (NEP) compliance (initial issue dated 7/1/86) with the quality assurance requir.ements of the NQAM, Part I, Section 2 documents, the ID-QAPs, and ASME Section III, Articles NCA-413 through 4134.18. This extensive review, as would be expected,
'
identified some spoeific areas of noncompliance, omissions, requests for clarification, and recommendations for enhancement of the NEP The inspector randomly sampid the procedural corrective actions that are underway and concluded tha+ dequate measures were being taken.
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l *
The -inspector performed a cursory review of Sequoyah Engineering Procedure SQEP-13, Procedure For Transitional Design Change Control, to . ascertain that it contains applicable essential basic design control elements identified in NQAM, Section 2.3, paragraph The inspector's review concluded that the subject procedure was satisfactory when enhanced by its referenced procedure . Conclusions and Summary.
L The transitional design change program was found acceptable for restart l with addition of closure times for design change packages. However, this review was limited due to the limited number of completed items. It is considered that NRC inspection will be required following transition to the PMP program in early 193 Attachment:
A Block Diagram of DCN Change Process
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