ML20024J255
| ML20024J255 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 09/21/1994 |
| From: | Boger N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Kingsley O TENNESSEE VALLEY AUTHORITY |
| References | |
| NUDOCS 9410130087 | |
| Download: ML20024J255 (14) | |
Text
September 21, 1994 l
Tenr.essee Valley Authority ATTN: Mr. Oliver D. Kingsley: Jr.
President, TVA Nuclear and Chief Nuclear Officer 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801
SUBJECT:
ENFORCEME'lT CONFERENCE
SUMMARY
Gentlemen:
On September 20, 1994, the NRC staff held an enforcement conference at the Region II office with representatives of the Sequoyah Nuclear Plant management staff. The purpose of the enforcement conference was to discuss the events surrounding the determination that unqualified protective coatings in the area of the Unit 2 containment sump exceeded a value previously calculated to be acceptable. is a list of the individuals who attended the meeting and is the handout material supplied by the licensee.
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10 Code of Federal Regulations, a copy of this letter and its enclosures will be placed in the NRC Public Document Room.
1 Should you have any questions concerning this letter, please contact us.
Sincerely, (Original signed by B. Boger)
Bruce A. Boger, Acting Director Division of Reactor Projects Docket Nos. 50-327, 50-328, License Nos. DPR-77, DPR-79
Enclosures:
1.
List of Attendees 2.
Presentation Notes cc w/encls:
(See page 2) fO.. n n c;,
vv.,
6 9410130087 940921 PDR ADOCK 05000327 k
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TVA 2
cc w/encls:
Nr. Craven Crowell, Chairman Mr. R. W. Huston, Manager Tennessee Valley Authority Nuclear Licensing and ET 12A Regulatory Affairs 400 West Summit Hill Drive Tennessee Valley Authority Knoxville, TN 37902 4G Blue Ridge 1101 Market Street Mr. W. H. "ennoy, Director Chattanooga, TN 37402-2801 Tenness" 'talley Authority ET 12A Mr. Ralph H. Shell 400 Wt Summit Hill Drive Site Licensing Manager Knoxv ele, TN 37902 Sequoyah Nuclear Plant P. O. Box 2000 Mr. Johnny H. Hayes, Director Soddy Daisy, TN 37329 Tennessee Valley Authority ET 12A TVA Representative 400 West Summit Hill Drive Tennessee Valley Authority Knoxville, TN 37902 Rockville Office 11921 Rockville Pike Mr. O. J. Zeringue, Senior Vice Pres.
Suite 402 Nuclear Operations Rockville. MD 20852 Tennessee Valley Authority 3B Lookout Place Mr. Bill Harris 1101 Market Street Route 1, Box 26 Chattanooga, TN 37420-2801 Ten Mile, TN 37880 Dr. Mark 0. Medford, Vice President Mr. Michael H. Mobley, Director Engineering and Technical Services Division of Radiological Health 3B Lookout Place 3rd Floor, L and C Annex 1101 Market Street 401 Church Street Chattanooga, TN 37402-2801 Nashville, TN 37243-1532 Mr. D. E. Nunn, Site Vice President County Judge New Plant Completion Hamilton County Courthouse Tennessee Valley Authority Chattanooga, TN 37202 3B Lookout Place 1101 Market Street Distribution:
(See page 3)
Chattanooga, TN 37402-2801 Site Vice President Sequoyah Nuclear Plant Tennessee Valley Authority P. O. Box 2000 Soddy Daisy, TN 37379 General Counsel Tennessee Valley Authority ET llH 400 West Summit Hill Drive Knoxville, TN 37902
TVA 3
Distribution w/encls:
H. S. Lesser, RII S. E. Sparks, RII D. E. LaBarge, NRR G. C. Lainas, NRR Dccument Control Desk NRC Resident Inspector U. S. Nuclear Regulatory Commission 2600 Igou Ferry Soddy-Daisy, TN 37379 NRC Resident Inspector U. S. Nuclear Regulatory Commission Route 2, Box 700 Spring City, TN 37381 SEND OFC DRP/R!l DRP/R!l TO NAME SSparks:vyg MLesser PDR?
DATE 09/ Z l 94 09/ 7 l /94
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/94
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Ves No COPY 7 No Yes No Yes No Yes No Yes No OFFICIAL RECORD COPY DOCUMENT hAME: [G:\\SEC4A\\ SEQ 920. SUM)
i ENCLOSURE 1 LIST OF ATTENDEES NRC L. A. Reyes, Deputy Regional Administrator, Region II (RII)
A. F. Gibson, Director, Division of Reactor Safety, RII B. A. Boger, Acting Director, Division of Reactor Projects (DRP), RII M. S. Lesser, Acting Branch Chief, Branch 4, DRP, RII S. E. Sparks, Project Engineer, DRP, RII W. E. Holland, Senior Resident Inspector, DRP, RII S. M. Shaeffer, Resident Inspector, DRP, RII J. W. York, Project Engineer, DRP, RII D. E. LaBarge, Project Manager, Project Directorate ?I-4, Division of Reactor Nuclear Regulation (NRR)
R. B. Elliot, Reactor Systems Engineer, NRR 1
L. J. Watson, Enforcement Specialist, RII C. F. Evans, Regional Counsel, RII TVA
- 0. J. Zeringue, Vice President, Operations M. O. Medford, Vice President, Engineering and Technical Services i
R. R. Baron, General Manager, Nuclear Assessment and Licensing J. S. Baumstark, Plant Manager R. F. Driscoll, Nuclear Assurance and Licensing Manager R. H. Shell, Site Licensing Manager K. E. Meade, Acting Licensing Compliance Manager M. J. Burzynski, Engineering and Materials Manager B. S. Snider, Protective Coatings Engineer E. B. Dietrich, Principle Materials and Chemistry Engineer i
ENCLOSURE 2 i
UNQUALIFIED COATINGS ENFORCEMENT CONFERENCE TENNESSEE VALLEY AUTIIORITY S
lUOYAII NUCLEAR PLANT I
i t
Y September 20,1994 NRC Region II Office
UNQUALIFIED COATINGS ENFORCEMENT CONFERENCE SEPTEMBER 20,1994 i
AGENDA INTRODUCTION J. S. B AUMSTARK SEQUENCE OF EVENTS M. J. BURZYNSKI SAFETY SIGNIFICANCE M. J. BURZYNSKI REGULATORY PERSPECTIVE R.H.SHELL CONCLUSIONS J. S. BAUMSTARK l
4 l
INTRODUCTION Issue involves TVA-identified concern regarding unqualified coatings.
Issue occurred in 1986 when Westinghouse report and TVA review of that report did not identify coatings on the inside of the RCP motor i
stand.
i Adequate corrective actions were taken in 1986 based on the infonnation provided by Westinghouse.
Questioning attitude in 1993 by coatings engineer during walkdowns led to discovery of additional unqualified coatings inside the RCP motor stand -- corrective actions promptly taken.
Safety issue qualitatively assessed promptly.
Adequate margin available.
Additional analyses performed to quantify previous conclusion and document engineering margin.
Communications with NRC may not have completely explained SQN's focus associated with the three-dimensional flow model.
l
4 SEQUENCE OF EVENTS 1/86 TVA started an assessment of contaimnent coatings as part of the design baseline verification program.
4/86 As part of the verification process, TVA requested an evaluation of containment coatings from Westinghouse.
5/86 Westinghouse notified TVA of unqualified coatings used on equipment. The coatings on the inside of the RCP motor stand were not identified as unqualified.
6/86 TVA initiated corrective actions and walkdowns to determine the amount of unqualified coatings inside contaimnent.
12/86 TVA performed modifications to prevent unqualified coatings from blocking the containment sump.
9/87 Westinghouse issued an evaluation (WCAP 11534),
demonstrating that the emergency core cooling system (ECCS) would operate safely without removing the identified unqualified coatings (56.5 square feet).
9/93 As the result of an organization change (creation of the Technical Programs and Performance group), the new coatings program engineer performed walkdowns to assess the adequacy of the program. The walkdowns resulted in the identification of the unqualified coatings on the inside of the RCP motor stand.
9
i 9/17/93 TVA detennined that the licensing basis limit for unqualified coatings inside containment had been exceeded.
9/17/93 TVA notified NRC of the identified condition.
9/29/93 TVA completed modifications to trap coatings inside the RCP mo'.or stand that may come loose during design basis events.
10/4/93 Walkdowns were completed on Unit 1, identifying the same condition, and a follow-up notification was made j
to NRC.
10/5/93 TVA completed an Incident Investigation (II) of the subject issue. The II determined the cause of the failure to identify the unqualified coatings on the inside of the.
RCP motor stand to be a combination of a lack of infoITnation from the vendor and the failure to have the proper questioning attitude in the identification of unqualified coatings during the 1986 walkdowns.
I 10/18/93 TVA issued LER 50-327/93026 reponing the coatings issue to NRC.
11/9/93 NRC issued Inspection Report 93-42 documenting the i
unqualified coatings issue with URI 93-42-02.
8/1-5/94 NRC performed an inspection of TVA's coatings program. A potential violation was identified.
8/23/94 NRC notified TVA of an enforcement conference on the coatings issue.
i l
SAFETY SIGNIFICANCE Upon discovery of the additional unqualified coatings in 1993, the operability of the containment sump, and subsequently the ECCS, was quickly assessed to be acceptable.
The assessment was based on numerous significant conservatisms contained within the Westinghouse WCAP.
Basis for conclusion containment sump was operable:
Unlikely that all unqualified coatings will fail.
Unlikely that all coatings that fail will fall out of the inside of the RCP motor stand.
Unlikely that the design basis event would occur at exactly the ideal time in order for all the coatings to be transported to the contaimnent sump.
Unlikely that all coatings that fail will be transported r
t from the RCP area to the contaimnent sump.
Unlikely that all subject coatings are of the proper size and strength to block containment sump screen.
Westinghouse analysis bounded the above considerations Adequate margin was available to reach qualitative conclusion that the contaimnent sump remained operable.
6 COATINGS PROGRAM ACTIONS TVA contracted with Westinghouse to develop a three-dimensional flow model of the containment sump to quantify the available design margin.
The three-dimensional flow model was determined to provide the most future benefit to TVA.
The three-dimensional flow model would also confirm the qualitative analysis performed for the containment sump and resolve the outstanding regulatory issue (resident l
inspector's URI).
Continued emphasis at SQN on repair of damaged coatings to ensure effective coatings system inside containment.
Consolidation of coatings program responsibilities and design responsibilities.
1
I REGULATORY PERSPECTIVES TVA acknowledges that actions in 1986 provided an opportunity tc.
identify the unqualified coatings on the inside of the RCP motor stand, i
Coatings were vendor-supplied as part of the original plant design.
TVA reasonably relied on Westinghouse conclusion in May 1986 regarding location of unqualified coatings.
Westinghouse analysis (WCAP 11534) concluded that known unqualified coatings did not present an operability problem.
Corrective actions were timely, comprehensive, and effective for identified unqualified coatings.
Watts Bar identification of unqualified coatings inside the RCP motor stand.
l Coatings concerns were generic to the TVA system, and were being addressed on a plant-by-plant basis.
Watts Bar finding was documented on a field coating examination record.
REGULATORY PERSPECTIVES Enforcement policy promotes questioning attitude by licensees.
Coatings program is effective and adequate.
Doubts about coatings program implementation relate back to 1980s.
Safety / operability questions as demonstrated were quickly resolved in 1993 when coatings within RCP motor stand were identified.
Additional analyses not necessary to reach safety / operability conclusions -- used to clarify / quantify future engineering margin.
TVA's review of NRC enforcement policy concludes no violation exists.
However, if NRC concludes a violation does exist, the issue meets the criteria for regulatory discretion.
6 CONCLUSIONS i
i TVA understands the regulatory concern of the issue.
Regulatory and safety issues addressed in 1993.
Recent NRC inspection confirms this conclusion.
Watts Bar findings not reasonably considered an opportunity to identify.
Upon discoven of unqualified coatings in 1993, safety / operability concems quickly assessed.
TVA was being aggressive and forward looking when three-dimensional analysis was initiated.
1 A detailed evaluation was not necessary to conclude the containment sump was operable.
TVA's review of NRC enforcement policy concludes no violation i
exists. However,ifNRC concludes a violation does exist, the issue meets the criteria for regulaton discretion.
I
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