IR 05000327/1993038

Insp Repts 50-327/93-38 & 50-328/93-38 on 930816-20.No Violations or Deviations Noted.Major Areas Inspected:Status of Corrective Actions for CAL Relative to Unit 2 Extraction Steam Pipe Break

ML20057E469
Person / Time
Site:	Sequoyah
Issue date:	09/01/1993
From:	Blake J, Crowley B, Economos N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20057E462	List: IR 05000327/1993038 ML20057E461
References
50-327-93-38, 50-328-93-38, NUDOCS 9310120183
Download: ML20057E469 (15)

Text

UNITED STATES

/p ergo,g NUCLEAR REGULATORY COMMISSION

'i

. [*-

-

-t REGloN il y

@

101 MARIETTA STREET, N.W., SUITE 2900

%

s E ATLANTA, GEORGIA 30R3-0199 i

o

%,,

f

....+

-

Report Nos.:

50-327/93-38 and 50-328/93-38 Licensee: Tennessee Valley Authority 6N 38A Lookout Place 1101 Market Street Chattanooga, TN, 37402-2801 Docket Nos.:

50-327 and 50-328 License Nos.: DPR-77 and DPR-79

,

Facility Name:

Sequoyah I and 2 Inspection Conducted: August 16 - 20, 1993 Inspectors:

8. k b cl+

T/.27 h]

B. R. Crowley f

Date Signed

~

)

7b ')

(

n

~ Y Econom d Dd'te Figned N

Approved by:

v'

i/

i

'

. Blake, Chief Date Signed

.

erials and Processes Section

'

E gineering Branch

,

Division of Reactor Safety

'

SUMMARY Scope:

This routine, announced inspection was conducted on site in the areas of:

(1) status of corrective actions for the Confirmation of Action Le.ter (CAL)

dated March 4,1993, relative to the Unit 2 Extraction Steam pipe break and the resulting overvoltage condition, (2) interfaces between corporate and site, and (3) review of corrective actions for previous inspection findings.

Results:

In the areas inspected, no violations or deviations were identified. The licensee had completed essentially all of the corrective actions identified in

the CAL. Repair of Unit 2 piping damaged by Flow Accelerated Corrosion (FAC)

was complete (except for one small diameter line identified late based on some additional inspections performed as a result of the EPRI 3rd party review) and i

repair of Unit 1 piping was in process. The overall FAC program had been

.

m.

9310120183 930913 PDR ADOCK 05000327 G

PDR a

i

2 i

improved substantially. At the conclusion of the inspection, TVA had resolved EPRI comments on their FAC Program and Erosion / Corrosion (E/C) Restart Program Manual. The final EPRI letter was issued on August 19, 1993. The E/C Restart j

Program Manual, issued subsequent to completion of the inspection, was a

detailed treatment of the E/C effort for restart, including the complete

!

inspection, analysis, and disposition process. The Manual also provides for i

transition from the outage restart effort to the improved long term FAC Program.

,

A detailed upper level interface agreement between the Site Vice President and the Corporate Technical Support Vice President was signed by both parties and issued. Where deemed necessary, lower level Interface Agreements and

Transition Plans were signed by affected parties and issued. All corporate and site personnel interviewed understood the interfaces and their responsibilities and expressed a sense of ownership for their particular areas.

Identification of Site procedures and Corporate standards to be changed as a result of moving responsibilities from Corporate to Site has not been completed.

i Note:

The terms Flow Accelerated Corrosion (FAC) and i

Erosion / Corrosion (E/C) are used interchangeable throughout this report.

l

.

I i

.

-

-

l REPORT DETAILS

,

1.

Persons Contacted i

Licensee Employees L. Alexander, ASME Section XI and Special Programs Engineer R. Alsup, Quality Audit Supervisor B. Anderson, Erosion / Corrosion Project Manager l

• L. Bryant, Maintenance Manager E. Camp, Site Steam Generator Engineer i

G. Clark, Assistant Section Supervisor, Instrument Maintenance

• M. Cooper, Maintenance Progran Manager E. Crane, ISI/NDE Programs Specialist N. Dietrich, Corrosion Prograns Supervisor

• R. Driscoll, Site Quality Manager S. Egli, Sequoyah Site Fire Protection Manager J. Gates, Site Outage Manager D. Goetcheus, Corporate Manager Operations & Maintenance J. Goulart, Site ISI/NDE Programs Specialist D. Hughes, Corporate Steam Generator Programs Manger

• R. Fenech, Vice President, Sequoyah J. Hamilton, Inspection and Material Supervisor, I. Heatherly, Nuclear Engineering, Principle Mechanical Engineer

!

D. Keuter, Vice President Nuclear Readiness

• D. Lundy, Technical Support Manager

• J. Macijewski, Manager Operations and Maintenance - Corporate J. McClanahan, Corporate ISI Specialist E. McCoy, Senior Maintenance Specialist M. Medford, Ph.D, Corporate Vice President Technical Support J. Naik, Site Snubber Program Engineer

• K. Powers, Plant Manager

• J. Proffitt, Licensing Engineer B. Rogers, Senior Maintenance Specialist

• R. Shell, Site Licensing Manager

• H. Skarzinski, Technical Programs and Performance Manager

• R. Thompson, Compliance Licensing Manager G. Wade, ISI/NDE Supervisor

'

• J. Ward, Manager - Engineering and Modifications C. Williams, Corporate ISI Specialist K. Wilson, Repair and Replacement Engineer K. Zimmermann, Manager Fire Protection Services

'

Hartford Steam Boiler

!

E. Farrow, Authorized Nuclear Inservice Inspector (ANII)

• N. Jackson, Authorized Nuclear Inservice Inspector (ANII)

Other licensee employees contacted during this inspection included engineers, QA/QC personnel, craft personnel, security force members, technicians, and administrative personnel.

,

-

r

f

~

.

i l

,

NRC Employees l

• C. Casto, Section Chief, Test Programs Section

-

• W. Holland, Senior Resident Inspector i

• P. Kellogg, Section Chief, Projects Section 4A

• S. Shaeffer, Resident Inspector

,

• A. Long, Resic'ent Inspector (

• Attended exit interview Acronyms and initialisms used throughout this report are listed in the

'

last paragraph.

2.

Corrective Actions for Confirmation of Action Letter (CAL) Relative to

'

Unit 2 Extraction Steam Pipe Break (92703)

See NRC Inspection Reports 50-327,328/93-12, 50-327,328/93-24, and 50-327,328/93-30 for documentation of previous inspections in this area.

On March 1,1993, a 10-inch extraction steam line feeding the No. 82 feedwater heater ruptured resulting in steam being introduced into the main generator instrumentation cabinet causing a voltage excursion in the generator output and a manual operator trip of the reactor.

The NRC performed a special Augmented Inspection Team (AIT) inspection of the event. The inspection activities and findings are documented in NRC Inspection Report 50-327, 328/93-10. A CAL was issued on March 4, 1993.

Most of the corrective actions specified in the CAL were in process and were inspected during the AIT inspection. Additional inspections of corrective actions are documented in NRC Inspection Reports identified above.

During the current inspection, the inspectors further evaluated actions identified in the CAL including the status of inspections and replacement of piping subject to FAC and the Technical Programs organization and procedures. The following s m arizes the inspector's review of the status of the actions identified in the CAL and TVA referenced letter-

-

Review your E/C program to identify any weaknesses, including a third party evaluation of the E/C program.

As noted in NRC Inspection Report 50-327,328/93-30, the third party i

review is being performed by the Electric Power Research Institute

(EPRI). TVA Engineering has provided EPRI their tirosion/ Corrosion Restart Program Manual.

EPRI has provided TVA a r4 umber of comments

,

relative to the Restart Program and the FAC program. Ai. the tirne or the 93-30 inspection, TVA was in the process of resolving the EPRI comments. During the current inspection, the inspector reviewed the status of the EPRI review, Many of the EPRI comments were editorial in nature.

The Technical Comments were mostlf related to treatment l

of piping (small bore and large bore) that did not receive CHECMATE analysis. As a result of EPRI comments, 61 additional inspections /re-inspections were performed in Auxiliary Boiler, Gland i

I l

]

.

.

,

Steam and Miscellaneous Bypass Vent and Drain Systems. As a result of these inspections,1 additional rejectable condition (small Auxiliary Boiler System pipe) was identified. Discussions with the Corrosion Programs Supervisor indicate that the EPRI Technical concerns have been adequately addressed.

EPRI issued a final letter on August 19, 1993, indicating "a high degree of confidence that no large bore pipe will rupture before the next refueling outage", and

"the restart program, in our opinion, does significantly reduce the

'

probability of a rupture in small bore piping before the next

refueling outage."

'

At the conclusion of the inspection, the Erosion / Corrosion Restart Program Manual was in the final review and approval process. After completion of the inspection, the final version of the Manual was approved and subsequently forwarded to the RII Offices. The inspectors reviewed the Manual and found that it is a very detailed treatment of the E/C effort for restart, including the complete inspection, analysis, and disposition process. The Manual also provides for transition from the outage restart effort to the improved long term FAC Program. Most aspects of E/C restart effort were reviewed during the inspections documented in the NRC Inspection Reports noted above.

-

Conduct field measurements of piping to assess the state of piping i

subject to E/C effects.

l Field measurements are complete for Unit 2, but are still in progress on Unit 1.

As noted in NRC AIT inspection Report 50-

-

327,328/93-10, in order to determine the extent of wall thinning due to FAC, TVA developed a screening, ultrasonic (UT) thickness measurement program. Details and implementation of the program were inspected and are documented in the AIT report. The inspectors i

reviewed the status of these inspections since the completion of the AIT inspection. The following is a summary of the inspections and

!

the results through August 19, 1993:

INSPECTION POINTS INSPECTIONS INSPECTION POINTS

)

PROJECTED COMPLETED REJECTED Small Bore Unit 1 692 679

Unit 2 871 871 123 Larae Bore Unit 1 410 375

Unit 2 442 442

i

.

.

l

For Unit 2, four evaluations in small bore and one evaluation in large bore is not complete, although the thickness measurements are complete and do not appear to indicate any rejectable conditions.

The " INSPECTION POINTS REJECTED" column is the number of inspection areas tht require repair or replacement because of being below minimum or close to minimum wall. The large majority of significantly thinned piping is in the steam extraction systems.

For piping replacements, Stainless Steel materials are being used for large bore piping and Chromium - Molybdenum (CrMo) steel for small bore piping.

For Unit 2, the screening thickness measurements are complete.

,

In addition to the screening inspections, grid locations were being inspected for input into the CHECMATE program. The following is a summary of these inspections current to August 19, 1993:

Unit 2 - 421 inspection grid locations identified, 421

-

inspections complete, 12 areas rejected

,

Unit 1 - 338 inspection grid locations identified, 325

-

inspections complete, 14 areas rejected

-

Repair or replacement of all such piping and other hardware l

adversely impacted by the rupture or that were identified as needing repair during the technical evaluations will be completed.

Except for one additional Unit 2 repair (Inspection point 192A -

3/4" diameter Auxiliary Boiler Piping) resulting from the additional inspections performed based on the EPRI comments, pipe replacements i

are complete for Unit 2.

Piping repair / replacements are still in l

progress for Unit 1.

l l

Although piping replacements and repairs are not-ccaplete, it appears that a program is in place to ensure that replacements and l

repairs are completed. No further inspections are needed in this area,

-

The TVA letter referenced in the CAL indicated that insight gained

.

'

from evaluation of the weaknesses in the FAC program would be used i

i to evaluate the effectiveness of other programs that may directly

'

affect the :afe operation of the units.

!

Partially in response to this item, TVA initiated an effort to evaluate the effectiveness of and revise as appropriate the organizational structure, and to clearly define roles, responsibilities, and interfaces.

Inspection of corporate and site interfaces is documented in paragraph 3. below.

No further inspections are needed in this are.

5 In the areas inspected, no violations were identified. The licensee had completed essentially all of the corrective actions identified in the CAL. Repair of Unit 2 piping damaged by Flow Accelerated Corrosion (FAC)

was complete (except for one small diameter line identified late based on some additional inspections performed as a result of the EPRI 3rd party review) and repair of Unit 1 piping was in process. The overall FAC program has been improved substantially. At the conclusion of the inspection, TVA had resolved EPRI comments on their FAC program and the E/C Restart Program Manual. The final EPRI letter was issued on August 19, 1993. The final version of the E/C Restart Program was a detailed treatment of the E/C outage effort, including the complete inspection, analysis, and disposition processa l

3.

Corporate and Site Interfaces (92701)

Prior to the current outages, TVA management had been evaluating division of responsibilities between Corporate and SQN site. After shutdown and in parallel with the restart effort the TVA Corporate organization in Nuclear Power was restructured. All Corporate technical functions were realigned under one Vice President of Technical Support to consolidate technical and programmatic oversite and site support functions into a single organization. One purpose of the restructuring was to ensure that all site technical functions are owned by and conducted from site organizations. As a result, a number of technical functions were l

transferred from Corporate to Site. Based on changes in technical i

functions, a number of roles, responsibilities, and interfaces changed.

To implement these changes, interface agreements, transition plans, and division of responsibilities documents were issued. At the same time, Corporate and Site organization charts and responsibilities were issued.

During the current inspection, the inspectors evaluated interfaces between Corporate and Site for technical programs. The following summarizes the inspection effort and the results:

a.

The inspectors reviewed the following documents:

M. O. Medford to R. A. Fenech memo dated May 14, 1993, with tabbed binder outlining division of responsibilities between Technical Support Corporate Staff and Sequoyah M. O. Medford to R. Fenech memo dated July 1,1993, Division of Responsibilities - Technical Support and Nuclear Plants Joint M. O. Medford and R. A. Fenech memo dated August 3, 1993,

,

l Transfer of Responsibilities - Technical Support and Sequoyah j

Nuclear Plant M. O. Medford to R. A. Fenech memo dated August 4, 1993. Division of

.

Responsibilities - Technical Support (TS) and Sequoyah Nuclear Plant (SQN) with updated tabbed binder

,

.

!

'

,

!

Nuclear Power Technical Support Mission Statement and Organization Charts dated August 12, 1993 Site Organization Charts and Roles and Responsibilities dated i

August 6, 1993 Site Interface Document dated August 11, 1993

,

W. C. McAuthur to K. Powers memo dated August 12, 1993, Corporate

!

Technical Programs (TP) (Technical Support) interface With Sequoyah j

(SQN)

J. Allen to M. O. Medford memo dated August 11, 1993, Site and Corporate Engineering and Modifications Responsibilities and Reporting Relationships Document Transition Plans as follows:

-

Corporate ASME Section XI Programs Transition Plan dated August 4, 1993 i

-

Corporate Operations & Maintenance Transition Plans dated August 12, 1993

-

Transition of Staff Augmentation Functions From Corporate Nuclear Training to Sequoyah Training Department dated i

August 13, 1993

-

Transition Plan for Exposure Information Functions dated May 17, 1993

-

Transfer of Responsibilities - Corporate Licensing And Site Licensing

The August 3, 1993, memo is a signed agreement between M. O. Medford i

and R. A. Fenech to transfer certain functions from corporate to site. The functions to be transferred are detailed in the May 14, i

1993, memo, as revised by the August 4, 1993 memo. The August 4, 1993, memo divides the functions covered by the agreement into 4 categories (tabs) as follows: (1) Corporate performance cf SQN line functions during formal routines, (2) Corporate performance of SQN i

line function during the current Unit I and 2 outagr (3) Transfer

'

of responsibilities from corporate to SQN line funch ons, and (4)

Transfer of the performance of loaned SQN line functions from i

Corporate to SQN. Based on the agreement, Corporate and Site

'

'

interface agreements and transition plans were signed and issued to implement the changes in functions / responsibilities.

b.

In addition to review of the above documents, the inspectors interviewed Corporate and Site personnel relative to selected functions to determine if responsibilities and interfaces were understood.

Personnel interviewed included management, supervision,

.

,

.

and working level personnel. The functions / responsibilities listed

'

below were chosen from the August 4, 1993, Division of

,

Responsibilities memo for this evaluation.

Functions chosen were from all 4 of the categories described in paragraph a. above.

'

-

Develop steam generator (SG) long-term strategic, operational, modification, chemistry, and maintenance program for optimum

,

economic SG life - Corporate

,

i

-

Maintain a data base of industry SG damage mechanism history to provide a basis for development of TVA's strategic program -

Corporate

-

Establish programmatic requirements for SG testing, maintenance, and repair - Corporate

-

Provide SG corrosion expertise and characterization of SG tubing damage mechanisms during outage eddy current testing -

Corporate

-

Generate SG Inspection Scan Plan based on industry experience, projected degradation, previous tube degradation, industry guidelines, and Technical Specifications requirements -

,

Corporate

'

-

Based on results of SG tube inspections, initiate Scan Plan changes and track indications for Technical Specification conformance - Corporate

-

Inservice System Pressure Test Program - Test director and assistance in performance of tests - Site

)

-

Expertise on SG repair maintenance and testing - Site l

-

ASME Section XI Inservice Inspection (ISI), Pump and Valve Test (IST) Program, Inservice Pressure Test Program, and Repair and Replacement (R&R) Program - Most functions for program preparation and program upkeep transferred to site resulting in site responsibility for essentially all of the program and program implementation

-

Own and implement SG 5 year plan - Site

-

Oversee and insure SG secondary and primary chemistry meets SG integrity requirements - Site

-

Budget, Plan, and Coordinate craft and contractor services for SG activities - Site

-

Expertise on SG repair, maintenance and testing - Site

-

Ice Condenser support - Site i

w

-

..

!

.

.

-

Full time outage support for activities such as snubber

,

testing, RID cross calibration, acoustic valve monitoring i

system, and loose parts monitorina operability testing - Site

-

Ice Condenser floor position monitoring system technical support - Site

-

ENTEK motor current monitoring - Site Specialized diagnostic testing including main steam check valve

-

non-intrusive monitoring and structural dynamic testing - Site

-

Perform repair and maintenance on all SCBA units used by fire brigade; provide / conduct initial and re-qualification training for station fire brigade - Corporate

-

Provide site Fire Protection Engineer currently being

,

provided by Corporate - Site i

c.

The inspectors questioned licensee personnel relative to revisions

,

to Corporate Standards and Site Procedures necessary for the above

changes in responsibilities. Since the newly organized TP&P Department has most of the site responsibilities for the ASME Programs, recently issued Site Procedures for these programs reflect the new responsibilities.

However, Site Procedures for other i

responsibilities h4ve not been changed. Also, a number of Corporate Standards have not been changed. At the conclusion of the inspection, the licensee was in the process of identifying which Corporate standards and which Site procedures need to be changed.

.

The Corporate Standards are scheduled to be revised by September 30, 1993.

The revision of Site Procedures is identified as Restart Item 450.083.

d.

The inspectors discussed with QA their audit activities and findings relative to corporate and site interfaces.

SUMMARY AND CONCLUSIONS An upper level interface agreement between the Site Vice President and the Corporate Technical Support Vice President was signed by both parties i

and issued. The supporting information for the agreement contained

detailed lists of specific functions of each party. Where deemed necessary, lower level Interface Agreements and Transition Plans were signed by affected parties and issued.

In general, all of the interface documents were detailed and provided specific lists of functions / responsibilities.

All corporate and site personnel interviewed were knowledgeable of functions being transferred from Corporate to Site and of their responsibilities and expressed a sense of ownership for their particular areas.

-

-

.

QA appeared to be actively involved and providing an independent

-

evaluation of the transition of responsibilities from Corporate to Site.

The total 1 st of Site Procedures and Corporate Standards to be changed as a result of transferring responsibilities from Corporate to Site has not been identified.

Some new standards and procedures will be required, e.g., a new Corporate Standard and a new Site Procedure will be issued for SGs.

No violations or deviations were identified.

4.

Technical Programs Evaluation See NRC Inspection Report 50-327,328/93-30 for documentation of a pervious inspection in this area.

NRC Inspection Report 93-30 identified three areas that needed additional inspection. These were the FAC Program, Fire Protection Program and Drawing Control. Additional inspections were performed as follows:

a.

FAC Program In addition to the inspections documented in paragraph 2. above the inspector reviewed the following additional FAC procedures:

-

Technical Instruction 0-TI-DXX-000-005.0, Revision 0, Additional Requirements for Flow -Accelerated Corrosion UT Examinations

-

Evaluation and Disposition of Non-Modeled E/C-Susceptible Piping The purpose of this document was to detail the methodology used

,

for disposition of all piping not modeled by CHECMATE. The document will be an attachment to the final Engineering closure package.

b.

Fire Protection Program As noted in NRC Inspection Report 50-327,328/93-18, a weakness was identified in the lack of communications between onsite and corporate fire protection organizations concerning microbiological fouling and corrosion caused leaks in fire protection piping. This weakness was identified based on discussions with corporate and site personnel and the fact that site personnel did not appear to be i

fully aware of problems with butterfly valves at Browns Ferry not performing their isolation function because of the disks being

'

completely destroyed by corrosion. Sequoyah utilizes some of the same type butterfly valves as Browns Ferry.

The inspector also

.

noted that Raw Water Corrosion personnel were not communicating with Operations personnel in selecting inspection sites (see NRC Inspection Report 327,328/93-20).

.

.

l

10 The following inspections were performed during the current inspection:

-

During the interviews documented in paragraph 3. above, the i

'

Corporate and Site Fire Protection Managers were interviewed and the above weakness discussed.

In addition, Corporate Standard 12.15, Revision 1, Fire Protection and Site SSP-12.15, Revision 1, Fire Protection Plan were reviewed in the area of responsibilities and interfaces.

j

.

Based on the above discussion, it appears one reason the Site Fire Protection Manager may not have been fully aware of the Browns Ferry Valve Problem was the severe degradation of the valves happened several years back and the. Site Fire Protection Manager has only been in the job for approximately 8 months.

Also, based on these discussions, it appears that, compared to Browns Ferry, Sequoyah only has a few of the butterfly valves.

In addition, the only problems identified with the butterfly valves at Sequoyah has been crud buildup to prevent proper i

operation.

Review of the Corporate Standard and the site SSP revealed very detailed responsibilities and interfaces with corporate responsible to review generic issues and ensure implementation of uniform requirements at all sites. Relative to the Raw Water Corrosion Program personnel not consulting Operations personnel about inspection site selections, this problem was corrected during the 93-20 inspection.

Based on the above, it appeared that interfaces are defined and communications are not currently a problem.

-

The inspectors reviewed the status of raw wate'. corrosion inspections and pipe replacements for the High Pressure Fire Protection piping. The inspection program for the current outage included 47 grid and 11 visual inspection locations.

Based on these inspections, a total of 18 areas required piping replacement. All Unit 2 locations have been inspected and repaired. Three Work Requests (WRs) are still outstanding for Unit 1.

TVA is considering connecting the High Pressure Fire Protection System to a municipal water supply in lieu of the current river water supply to decrease the corrosion degradation of the piping.

c.

Drawing Control See NRC Inspection Report 50-327,328/93-41 for additional evaluation of drawing control.

Based on this inspection, updating Category I drawings to incorporate outstanding Drawing Deviations still remains a restart issue.

No violations or deviations were identified.

.

. _ _ _ _ _ _ _ _

___

_ _ _ - -

.

.

'

5.

ASME Section XI Pressure Test Program (73753)

TVA's Ownership and Health evaluation of the ASME Section XI Pressure Test Program disclosed that four audits had been performed. The audits were performed by TVA ASME Regulatory Programs, TVA QA, and contractors (Reedy Associates and United Energy Services Corporation). A review of the subject program, including the Ownership and Health document, was performed and the results documented in NRC Inspection Report 50-327,328/93-30.

Following the close of the 93-30 inspection, further review of the audits revealed that both contractor auditors had characterized the relationship between TVA's corporate personnel and the i

ANII as "adversarial". This observation was the result of difficulties experienced between the two parties in resolving differences in l

interpreting certain code requirements and, to a lesser extent, the

'

ANII's role in ASME Code activities.

'

Through discussions with both ANIIs presently assigned to Sequoyah, corporate personnel, site supervision and technical support staff (Planning and Modification personnel), the inspectors ascertained the following:

-

The Senior ANII is a knowledgeable, well trained, conscientious individual with a strong sense of what his role is at Sequoyah.

Because of his ten years plus length of service at Sequoyah, he has gained valuable knowledge of the plant. This, along with his thorough knowledge of the code, has established him as a valuable

,

source of information and advise to site personnel involved in code related activities.

-

Based on the interviews, the inspectors confirmed that the ANII's i

relationship with site personnel was generally cooperative and functioning well. However, the inspectors determined that, on occasion, the ANII's code interpretation differs from that of the corporate personnel responsible for code activities.

Because of both parties taking very strong positions on the correctness of

their code interpretations, there have been instances involving spirited discussions which have resulted in unresolved issues, e.g.,

refusal of the ANII to sign ASME Code Reports on pressure testing.

The inspectors found that, although these confrontations have occurred on occasions, they are not an on-going, daily occurrence and neither party (the ANII or TVA) characterizes the relationship as adversarial.

l

-

Recently, a new site Technical Program and Performance (TP&P)

Department was formed and ASME Code programs are now the responsibility of this organization. To help alleviate problems similar to the one above, the TP&P supervisor in charge of individual ASME program is responsible for interfacing with the ANII.

In addition, to further improve interfaces with the ANII, TVA is developing a document to detail procedures and practices for interfacing with the ANII, both at site and corporate levels. This

i

.

.

.

'

document will provide details for resolving impasses between both parties through correspondence, which should facilitate interfacing between TVA and the ANII.

No violations or deviations were identified.

6.

Licensee Action on Previous Inspection Findings (92701, 92702)

(0 pen) VIO 327,328/93-24-01, Failure to Perform and Document Adequate Suitability Evaluation of Replacement Parts In Accordance with ASME Section XI

,

This violation concerned an inadequate suitability evaluation for

.

replacement steam generator feedwater cracked piping components in 1992.

The evaluation did not provide evaluation of suitability for operations

,

'

with the 'like for like' replacement materials.

The licensee letter of response was issued on August 6,1993 and found to be acceptable.

,

Corrective actions included:

-

Performance of the required suitability evaluation.

-

Establishment of Auxiliary Feedwater (AFW) System usage monitoring to trigger points for nondestructive examination (NDE)_for cracks.

-

Establishment of the TP&P organization with ownership and responsibility for the Repair and Replacement (R&R) program.

-

Revision of SSP-6.9 to enhance requirements for suitability evaluations.

Problem Evaluation Report (PER) SQPER930125 was issued to track corrective actions for this problem.

The following is a summary of inspections verifying corrective actions:

-

NRC Inspection Report 50-327,328/93-30 documents inspection of the completed suitability evaluation and establishment of usage monitoring to trigger additional NDE inspections. The suitability

.

I analysis determined that the piping components are suitable for at least one more fuel cycle.

-

NRC Inspection Reports 50-327,328/93-12, 93-24, and 93-30 document

!

'

inspections of the new TP&P organization, the R&R program, and review of SSP-6.9.

During the current inspection, the inspectors further reviewed the status of the corrective actions as follows:

-

Review of SSP-6.9 revealed that the procedure still does not adequately define various levels of review of suitability evaluations, i.e., when is it satisfactory for the Cognizant

,

Engineer to perform the evaluation, when is it satisfactory for the

, _

__

.

.

13

'

R&R Coordinator to perform the eva W tion, and when does Design Nuclear Engineering need to be inve b.d? The licensee plans to better define this area.

-

The inspectors discussed with responsible licensee personnel (R&R Coordinator and Licensing Engineer) the generic aspects of this

,

problem, i.e., other suitability evaluations. This is a corrective action item still open on the PER that is not scheduled for

'

completion until September 28, 1993.

This violation will be reviewed further after the above corrective actions are completed by the licensee.

7.

Exit Interview The inspection scope and results were summarized on August 20, 1993, with those persons indicated in paragraph 1.

The inspector described the areas inspected and discussed in detail the inspection findings.

Proprietary information is not contained in this report. Dissenting comments were not received from the licensee.

8.

Acronyms AIT Augmented Inspection Team AFW Auxiliary Feedwater ANII Authorized Nuclear Inservice Inspector ASME American Society of Mechanical Engineers CAL Confirmation of Action Letter CrMo Chromium Molybdenum E/C Erosion / Corrosion EPRI Electric Power Research Institute FAC Flow Accelerated Corrosion ISI Inservice Inspection IST Inservice Testing NDE Nondestructive Examination NRC Nuclear Regulatory Commission PER Problem Evaluation Report QA Quality Assurance QC Quality Control RII NRC Region II

,

R&R Repair and Replacement SG Steam Generator SI Surveillance Instruction SQN Sequoyah Nuclear Plant SSP Site Standard Practice TI Technical Instruction TP&P Technical Programs and Performance TU Technical Support TVA Tennessee Valley Authority VIO Violation WR Work Request

>