ML20063Q246

Forwards Cable Test Program Resolution Plan to Resolve Issues Re Pullbys,Jamming & Vertical Supported Cable & TVA- Identified Cable Damage.Tva Commits to Take Actions Prior to Startup to Verify Integrity of safety-related Cables

ML20063Q246
Person / Time
Site:	Sequoyah
Issue date:	08/17/1990
From:	Wallace E TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
TAC-77129, TAC-77130, NUDOCS 9008240094
Download: ML20063Q246 (19)

Text

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• i TENNESSEE VALLEY AUTHORITY CH ATTANOOG A. TENNESSEE 374o1 l SN 157B Lookout Place August 17, 1990  ;

i U.S. Nuclear Regulatory Commission  !

ATTN! Document Control Desk Washington, D.C. 20555 Gentlemen:

In the Matter of ) Docket Fos. 50-327 Tennessee Valley Authority ) 50-328 SEQUOYAll NUCLEAR PLANT (SC..) - UNITS 1 AND 2 - CABLE TEST PROGRAM (CTP)

RESOLUTION PLAN (TAC NO. 77129/77130)

References:

1. TVA letter to NRC dated July 31, 1987, "Sequoyah Nuclear Plant (SQN) Units 1 and 2 - Revised Cable Test Program"

2. TVA letter to NRC dated July 27, 1990, "Sequoyah Nuclear ,

Plant (SQN) - Condition Adverse to Quality Report (CAQR)  ;

SQP900305 - Operability Determination"  ;

3. NRC letter to TVA dated August 8, 1990, " Justification for Continued Operation Regarding the Cable Testing Program (TAC Nos. 77129/77130) - Sequoyah Nuclear. Plant, Units 1 and 2" The purpose of this letter is to provide a CTP resolution plan to resolve the issues relative to pullbys, jamming, vertical supported cable, and TVA-identified cable damage. This resolution plan supersedes portions of the original CTP as submitted in Reference 1.

TVA and NRC met on Ju'y 23, 1990, in Rockville, Maryland, to discuss the problems recently identified by TVA with the ranking calculation used to select conduits to be tested for pullby damage and plans to resolve these problems. TVA submitted a revised operability determination, ao agreed to in the meeting, by Reference 2. Additionally, TVA agreed to provide a complete

' plan and schedule to resolve the CTP problems. The resolution plan includes a two-phase (Phase I and Phase I') evaluation of SQN safety-related conduits, a quality assurance (QA) 'lookback" plan to investigate for programmatic '

problems with the original CTP, and a QA " forward look" plan to munitor the activities.

Following the July 23, 1990, meeting, TVA continued evaluations of the data collected by United Engineers and Contractors (UELC) for the original test conduit selection for pullby damage. These evaluations indicated additional errors in compiling the raw data itself from computerized cable records and pull cards. Errors ssre found involving incorrect pull dates, cables not identi L onduits, and improperly identifying tue number of cables in 9008240094-900817 PDR d pO/

P ADOCK 05000427 H PDC An Equal Opportunity Employer //[

l U.S. Nuclear Regulatory Commission August 17, 1990  ;

pullbys. These discrepancies were found by looking at a random selection of 59 conduits in the population of 770 conduits with 7 or more cables. A review  :

of~the approximctely 7,000 safety-related cables indicated additional errors in identifying all conduits with 7 or more cables. These errors necessitated either reverification or justification of much of this data prior to applying ,

the screening equation. Preliminary information on these problems and the '

potential _ impact to the schedule described in the July 23, 1990, meeting were provided to NRC by phone on August 6, 1990.

The Phase I and Phase II evaluation plan is included as Enclosure 1 to this letter. Phase I involves.the activities to evaluate condults that are not in ALARA (an low as reasonably achievable) or harsh environment areas, which -

includes walkdowns to prepare sketches and detailed isometries. Evaluations for conduits in Units 1 and 2 reactor buildings and other locations that pose >

personnel safety considerations will be performed as Phase Il at the first outage of sufficient duration. For Unit 2, this will be the September 1990 Cycle 4 refueling outage and will overlap the Phase I efforts; both efforts are scheduled to be complete October 5, 1990. For Unit 1, the unit 1 Cycle 5 refueling outage or the first available outage of sufficient duration will be utilized for that corresponding portion of Phase II.  :

i The QA lookback plan and current schedule are incloded as Enclosure 2 to this letter. This plan describes the objectives and activities to determine the contributing factors leading to the unissued Calculation SQN-CSS-009. This will include evaluations of past and present program controls for calculations, determinations of the extent of unissued calculations, and verification of data adequacy to be used in the new program from Calculation oQN-CSS-009. :These objectives are scheduled to be, completed by late i August 1990, followed by a report scheduled to be issued September 7, 1990, to '

the Site Director. '

The QA forward look plan and current schedule are included as Enclosure 3 to f" this letter. This part of the resolution plan will monitor ac M vities to ensure proper application and performance of the conduit ranking criteria.

These activities include but are not limited to reviewing adequacy of the 1987 ranking calculation data. verifying that aufficient data is obtained to implement new ranking criteria, verifying proper performance of sidewall .

bearing pressure (SWBP) calculations, and verifying acceptability of vertically supported cables and jawning evaluations. These activities are scheduled to be completed by October 9, 1990.

During~the July 23, 1990, meeting. TVA proposed a 6- to 8-week program a duration to complete the new ranking and SWBP calculations by mid-September to late September 1990. This estimate was primarily based on the data collected by UE&C being suitable as a starting point for further calculations. As TVA has discovered, this data, which includes field sketches, was not dependable and will require a more extensive effort to achieve a ranking by SWBP. TVA has allotted additional resources to provide the best possible effort to meet

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l U.S. Nuclear Regulatory Commission August 17, 1990  !

the original schedule and now projects that Thase I and Unit 2 Phase II should be completed by 0ctober 5, 1990. TVA is also sensitive to the need for j accuracy and completeness in this effort and realizes the importance of  ;

- working in a centro 11ed fashion. For this reason as well as supporting the  !

-Unit 2 Cycle 4 refueling outage, the schedule could be impacted to some Lextent. In any case. TVA is working to meet with NRC the end of September 1990 to discuss the program results! we believe sufficient results  ;

will be available to allow a substantive meeting with the staff. TVA will l continue to communicate closely with NRC during completion of the program to  !

establish the appropriate date for the meeting. l After completion of Phase I and Unit 2 Phase Il ranking by SWBP, the results }

will be compared with and evaluated against the Browns Ferry Nuclear Plant (BFN) CTP data and results. TVA acknowledges the concerns that NRC expressed .

In Reference 3 regarding bounding of SQN results by the BEN test resultsi such -}

application of the.BFN results will be made only as technically appilcable..

• TVA believes the similarities between SQN and BFN conduit configurations and pulling practices as discussed in the July 23, 1990, meeting clearly afford  ;

the technical basis for this application and will yleid important information .;

regarding the SQN cables. In further recognition of this overall similarity, j SQN's evaluation of associated BFN cable problems provides confidence that tho  :

application of BFN CTP results remains valid. "

Based on the current schedule to-complete the' Phase I and Unit 2 Phase II i conduits early.in the Unit 2 Cycle 4 refueling outage. TVA commits to take the I appropricte actions prior to start-up from that outage to verify the integrity I of safety-related cables atLSQN. These actions could include demonstration of l 3 cable acceptability, replacement of cables, or' testing as necessary to obtain the required confidence. .TVA fully expects the current schedule to support  ;

completion of- this program and resolution prior to start-up. If it becomes 1 apparent that SQN will not be able to' complete these activities prior to start-up from the Cycle 4 outage, you will-be promptly notified.

The commitamnts made in this letter are included as Enclosure 4.

Please direct questions' concerning this' lasue to Marcia A. Cooper at

'(615) 843-6422.

Very truly yours.

TENNESSEE V LLEY AUTHORITY

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4 E. . 'a ace, Manager Nuclear Licensing and Regulatory Affairs l-

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,. U.S. Nuclear Regulatory Commission August 17, 1990

- Enclosures cc (Enclosures):

Ms. S. C.: Black Deputy Director Project Directorate II-4 U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockv111e-Pike Rockville.. Maryland 20852 A

Mr. J. N. Donohew-Prr ' ct Manager V Nuclear Regulatory' Commission

( . White Flint, North 11555 Rockville Pike Rockville, Maryland 20852.

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NRC Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road

' Soddy Daisy, Tennessee;'37379 ,.

- Mr. B. A.-Wilson, Project Chief U.S. Nuclear' Regulatory Commission

, Region II'

-101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323

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l ENCLOSURE 1 l l

Phase I and Phase II Evaluation Plan  :

I. BACKCROUND i

During a June 19, 1990, audit of the documentation to support Sequoyah j Nuclear Plant's (SQN's) 1987 Cable Testing Program (CTP), TVA advised NRC that.the calculations to support that effort had been prepared and checked but never issued. At that time, TVA was in the process of performing an administrative review to determine what actions would be  ;

required to issue these documents in accordance with current I procedures. During the course of this review, TVA became aware of allegations that Calculation SQN-CSS-009 contained errors in the way the screening criteria had been applied. .As a result of this, TVA initiated an in-depth technical review of that process. Although TVA has not identified any evidence of the systematic misapplication of the selection criteria, several data errors were noted that affected the '

original ranking of conduits. l r

Subsequent to the July 23, 1990, meeting at NRC offices in Rockville, Maryland TVA performed a sample review of the raw data to which the criteria were applied. Data errors (incorrect mark letters, cable count, and pull dates) were identified. The following plan has been developed in response to these findings. Though errors have thus

, far only been identified in the pullby portion of the document. TVA's plan will include consideration for the other issues addressed by the subject calculation (jansning and lack of cable support in vertical conduits). Implementation of this plan will resolve the concerns regarding the subject calculation and provide additional assurance-regarding the integrity of.the.SQN cable system.

II. RESOLUTION OF PULLBY ISSUES In response to the aforementioned errors. TVA has decided to regenecate its pullby analysis using methodology similar to that recently employed

,f _at Browns Ferry Nuclear Plant (BFN). This analysis will consist of a ranking' process based on the forces generated within a condult during a pullby. Phase I of the analysis will include conduits that are accessible during normal plant operation, while Phase II will include the balance of conduits that are only accessible during unit outages.

The population of conduits at SQN containing safety-related circuits in which the potential exists for cable pullbys to have occurred will be subjected to this process. This will be based on the original 1987 SQN Computerized Cable Routing System data base, because the SQN cable installation program has been upgraded to acceptable standards since that time. The worst-case conduits will be considered as those i satisfying the following selection criteria.

1. The conduit will contain a minimum of seven cables.

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2. The cenduit segment length between pull points will be greater than 'I 20 feet. This will be based on the original 1987 field sketches

("C" condulets will not be considered as pull .oints).

1 If no field  !

sketch exists, design drawings will be used to ensure the total conduit length will be greater than 20 feet. '

3. The remaining conduits will initfally be evaluated using an enhanced ,

version of the BFN screening process. The data used for this .';

screening process will be reverified by' field walkdowns. The BFN i review employed the following ranking factort (L*F)/R = ranking factor i wheret f

L = conduit length  !

F = conduit fill s R =. conduit. bend radius per TVA standards i 4

Based on lessons learned during the BFN evaluations and utilizing data available for the SQN conduits, the formula has been modified as follows to more closely reflect the forces generated during a j pullby "

. (1.*K*We*F*p/R)*EXP(K*A*We*n) = ranking f actor wheret L.= conduit segment length (feet)

K.= coefficient of friction We= weight correction factor F = conduit fill percentage

.p = pullby fraction RE= conduit bend radius (feet)

A'= total bends in a segment (radians) n = configuration conversion factor

" This equation reflects the formulas for determining sidewall bearing-pressure (SWBP) during pulling, and includes several of the key parameters of consideration during a pullby.

Pull tension'and SWBP increase directly with length. While the BFN-program utilized the total-conduit length, the SQN effort will derive a greater degree of accuracy by identifying the length of conduit in each segment (i.e., pull point to pull point) f rom field sketches.

Since SWBP is. inversely proportional to the radius of bend of its conduit, the-screening will assume that each segment contains bends formed to the minimum allowed by TVA and industry standards.

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6 The fill percentage (F) of a given conduit and the pullby l fraction (p) have been incorporated to account for the influence of  !

the size of a pullby in a given conduit. It can be expected that a pullby in a small (0.75 inch) conduit may easily have involved half l of the final fill percentage (i.e., the pulling of one cable over the top of one other). In a five-inch conduit, 60 to 80 small  :

diameter cables may be required to achieve the same degree of fill i and a much smaller f raction would likely be involved in any one pullby. Therefore, the unitiess multiplier (p) is applied. The #

multiplier is on a sliding scale according to the size of_the  ;

conduit and reflects the fact that pullbys in small conduits are f likely to have involved a larger portion of the cables than pullbys  !

in large conduits.

d in a similar fashion, the weight correction factor (We) has been i applied to. enhance the model. Given that We generally varies from '

1.0 for single cable pulls.to 1.4 for pulls of four or more cables, ,

a sliding scale has been developed that attributes a low value of We to small conduits and higher values. for the larger raceways.  ;

r The BFN model has been enhanced through the inclusion of l configuration data taken from field sketches of the conduit. These  !

sketches show the total degrees of bend between adjacent pull =

points. Consideration for these bends has been incorporated ,

exponentially to best reflect the various formulas for determination ,

of SWBP.

I Finally, the unitiess factor (n) has been included to account for f the fact that bends are being treated as if they were all located at .,

the ends of the run, whereas.-in reality, they are distributed along _l the length of the_ individual segment.

i y The combination of these factors will permit quick and efficient *

' determination of a family of conduits that contain the potential for significant pullbys.to have occurred. This family will then be further screened as outlined below.

4 '. A review of this grouping will be performed to identify the top l

30 conduits in which a pullby has occurred. This review will be perforned using existing pull cards or installation inspection records.

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5.'.As required._walkdowns will be performed of the top 30 conduits identified to obtain isometrics for use in subsequent SWBP calculations. ,

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6. Detailed calculations will be performed to conservatively estimate the maximum SWBP that would have been encountered during the worst ,

pullby in each conduit. This analysis is based on the configuration  ;

and cable data discussed above and will utilize standard industry ^

methodologies and formulas for the determination of expected pull tension and SWBP derived from the fundamental laws of physics. .

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'7. .The top 30 conduits discussed above will then be reranked according c to SWBP. Since cables of differing construction and SWBP-  !

limitations may be involved, the ranking will .be based on the i percentage of allowable SWBP rather than its magnitude. j NOTE: The screening process described in Item 3 does not include i exact data for conduit configuration and cable pull groupings.  ?

Therefore,'following completion of the detailed calculation and reranking' process, the methodologies will be reviewed to confirm '*

that the screening process has produced viable results. If acceptable correlation does not exist between the screening process and the detailed calculations. TVA will expand the selection o' conduits to be walked.down and !acluded in the rigorous evalua sn.

8.' SWBP. results obtained as a result of this process will be compared with those of the BFW tested conduits. This comparison will datermine whether or not any further testing or additional actions should be taken.

III. REVERIFICATION OF CABLE JAMMING ISSUES

-In February of 1987, TVA began development of a calculation- :I (EEB-CSTF-0008) to impicment the selection criteria and identify a

• family of conduits in which the jam ratio criteria were fulfilled. This [

calculation was prepared and checked, but never issued.- TVA will rework this calculation to meet current requirements and issue it.- This family ,

of conduits was reviewed in accordance with Calculation SQN-CSS-009, and this review identified the worst-case conduits. As a result of the otner errors discovered in Calculation SQN-CSS-009, this portion will be ,

! reviewed for accuracy. This will be done concurrently with Phase I of '

the-pullby analysis. ,

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IV. REVERIFICATION OF VERTICAL CABLE SUPPORTED ISSUFS As presented in the July 23, 1990, meeting. TVA has reviewed 10 of the 400-conduits contained in Appendix 6 of the vertical cable support criteria portion of SQN-CSS-009. There were no problems identified at that tine with this small sample. However TVA intends to complete the review of this data to ensure the data contained in Appendix 6 is accurate. This will be done concurrently with Phase I of the pullby analysis.

V. OTHER ISSUES Two other issues involving cable damage discovered at BFN were also discussed at the July 23, 1990, meeting. The first issue involved missing conduit bushings in junction boxes, which resulted in insulation damage to type "PN" cable. It should be noted that this type of cable has a thin nylon jacket (4 mils), which wonid be more susceptible to damage by rough conduit edges. There are no PN-type cables used at SQN in 10 CFR 50.49 applications, although they are utilized in some safety-related circuits. SQN original construction' procedures, including quality control (QC) inspection, required conduit bushings to-be installed. A field inspection for possible moisture damage was performed in 1979-1980 on approximately 1100 junction boxes. This inspection, includinF QC inspections prior to declaring each box acceptable, reverified proper junction box conf!guration (all mounting hardware installed, all conduits properly attached, general cleaaliness, box covers, and gaskets installed, etc.). Therefore, there is a high degree of confidence that conduit bushings are installed properly at.SQN.

1 ~The second issue involved cable insulation damage within a penetration.

This damage was apparently the result of using sharp objects to dig out the room temperature vulcanizing (RTV) when adding new cables to the l penetration. This issue has been previously addressed at SQN as part of the Employee Concern Program (Item 10900-NPS-02). It was determined that the practices utilized at SQN were acceptable and would not result in undetected cable damage. Both of these issues will be furtner addressed by SQN as necessary as part of the condition adverse to quality (CAQ) process.

i VI. CONCLUSION The program previously described is a major effort to ensure that the worst-case conduits for the issues of pullbys, jamming, and lack of vertic 1 cable support have been identified and properly evaluated, and that the cables therein are capable of performing their intended safety .

function. For pullbys, the analysis will verify whether the results of 1 p SQN's SWBP calculations are bounded by the BFN tested conduits and  !

dictate whether any. additional testing or other actions must be taken.  !

t Upon completion of this program, the cable installation concerns will be f l resolved for SQN.  ;

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1 ii y- ~. SEQUOYAH NUCLEAR' PLANT.($QN)-

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t ENCLOSURE 2 i

Purpose of Assessnent: Determine contributing factors that 1ed to-the root  :

cause of the condition. ,

. Key objectives

1. Determine the adequacy of program controls for calculations at the time of l restart and present.  !

f 2 '. Determine extent of the condition. Was this a limited occurrence or a ~i generic problent  !

3. Determine if additional program controls are necessary ~ to preclude recurrence of the condition. '

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4. Determine input f rom old calculation to be used in new calculation and j evaluate it for adequacy.

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Plan '

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A. Program Controls at the Time Calculation August 13, 1990  ;

was Prepared  :

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1. Engineering Procedures I

• TVA

• Contractor. (

2. Licensing Procedures t

• . Validation of.submittals  !

• - Identification and tracking of [

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B. Program Controls Today A agus t 13, 1990- l

. 1. Engineering l Procedures, *

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.* Validation of.submittals

• - Identification and tracking of  ;

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C. Complete Interviews (see attachment) August 20, 1990 D. Extent (Generic or Limited) of Condition August 27, 1990 (The condition is the review and approval of a calculatior. to support an engineering decision)

1. Review audits / oversights /surveillances for similar conditions

• Essential calculation audit

• Design Baseline Verification Program (DBVP) oversight

• Essential calculation assessment

• Design change control audit

• Procured services audits of United Engineers and Contractors (UE&C)

• Surveillance by Engineering Assurance (EA) Technical Audit Group

• Surveillance / monitoring by SQN Site EA

2. Review similar calculations to determine if condition exists

• Determine population

3. Determine inputs from old calculation to be used in new calculation and evaluate adequacy E. Issue Report September 7, 1990

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Interview Sheet  !

ll Person Interviewedt __

Current Positiont I

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Position at time of Calculation SQN-CSS-009: 2 i ;1. What were quality assurance (QA) and administrative controls for issuance of calculations at the time of SQN-CSS-0097 (If they do not know, ask who was responsible for knowing.)

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[, 2A. Did those QA and administrative controls apply to SQN-CSS-009? Why?

Yes No 2 8.~ If.2A answered yes, were QA and admlnistrative controls followed?

Yes No-20.- If 2B answered no, should a condition adverse to quality report (CAQR) have been initiated?

Yes No Why?.

2D. - If answer to 20 is no because no problems were known to exist with' the calculation. what was' individual's understanding of who in TVA had.

reviewed the calculation for technical adequacy, and what were the results of this review?

3. Who for TVA' owned the technical aspects of Calculation SQN-CSS-0097 4 Was calculation to'be issued' under UE&C's QA program or TVA's QA program?. UE&C TVA

35. ,Did UE&C QA or TVA QA/EA overview UELC's work on this calculation?

Yes. No About when  ?

What'was your personal knowledge'concerning the circumstances surrounding

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the nonissuance of the calculation?

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p l -ENCLOSURE:3 p

SUBJECT - Sequoyah Nuclear Plant - Site Quality Organization (SQO) Action Plan for. Cable Test Program Reverification PURPOSE: To provide an additional level of assurance that SQN's (1) Sidewall

, Bearing Pressure Calculation (SWBP) for accessible conduit is R bounded by Browns Ferry Nuclear Plant's (BFN's) tested conduitst (2) cables in vertical raceways comply with National Electric Code p

(NEC) requirements; and (3) jamming calculations are appropriately evaluated and documented.

OBJLcTIVES: A. To determine if regulatory commitments and applicable program controls are implemented for the preparation of calculations.

B. To determine if reverification of the sample data associated with the 1987 ranking calculation is adequate.

C. To determine if conduits are ranked in accordance with-established criteria.

D. To determine if needed information is collected for top

- ranked conduits.

E. To determine if the SWBP calculations are acceptable.

F. To determine if vertical cables supported by a 90-degree condulet or "T" meet the' requirenents of . the National Electrical Code, Article 300-19.

t .G. To determine if jamming calculations are acceptabic.

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OBJECTIVE At To determine if regulatory commitments and applicable program controls are implemented for the preparation of calculations.

Completion Action Due Date

1. Identify regulatory commitments for cable testing calculations

2. Review NE programs and procedures 08/01/90 for preparation of calculations OBJECTIVE Bt To determine if reverification of the sample data associated with the 1987 ranking calculation is adequate.

Completion

. Action Due Date

1. Review qualification of personnel performing verification of cable pull data.

2. Ensure controlled cable pull data is utilized for verification activity of 59 randomly selected conduits.

3. Ensure the resolution of differences in United Engineers and Contractors's (UE&C's) data f rom cont rolled cabic pull data.

4. Verify that discrepancies with the applicable sketches are identified i during walkdown and those missing are second-party verified. (Phase I)

5. Verify that discrepancies with the a*plicable sketches are identified during walkdown and those missing are second-party verified. (Phase II)

6. Issue Summary Report for Objective B 10/07/90

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• OBJECTIVE' C To determine if-conduits are ranked in accordance with

-established criteria.

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l/ ', Completion Action Due Date

1. Review screening criteria used for conduit ranking.

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2.- Review actual ranking of conduits

.against established criteria, iG ,

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3. ' Issus monitoring ' report documenting 09/10/90 results.

'0BJECTIVE Dt' -To. determine if needed information is collected for top ranked!

Jconduits.

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Completion lt Action Dite._Da t e; .

1. Overview walkdowns for collection of data. .

2. Review isometrica..

Lr .- 3.:-: Verify proper collection of data pull dates for L  : pull groups, t

4. Issue monitoring report-documenting-results. 09/14/90=

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n 1 .0BJECTIVE Et ,.To determine if the SWBP calculations are acceptable.

p. s e Completion p Action- _Due Date T

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1. Sample SWBP' calculations for adequacy.

p [2.-0verviewthecomparisonofSQNresultstoBFN's p . tested' conduits to determine if~they are L bounded.

L lJ 3. Verify.that calculations are properly.

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checked., reviewed, approved, and issued.

E 4. Issue final' monitoring report. 10/09/90 L

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OBJECTIVE F: To determine if vertical cables supported by a 90-degree condulet or "T" meet the requirements of the NEC, Article 300-19.

Completion Action Due Date

1. Verify selection criteria are properly utilized for screening conduits.

2. Verify QA documentation is complete including source documents referenced, assumptions are documented, and missing data is collected or evaluated.

3. Issue monitoring report. 09/17/90 OBJECTIVE G To determine if jamming calculations are acceptable.

Completion Action _Due Date

1. Verify general requirements with jamming data are acceptable.

2. Ensure cable data for conduits is field verified as appropriate.

3. Verify issuance as a jamming calculation or other appropriate QA documentation per NRC commitment.

4. Issue monitoring report. 10/07/90

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ENCLOSURE 4 List of Commitments

1. TVA will perform a new preliminary ranking process similar to the Browns Ferry Nuclear Plant (BFN) program and execute a new sidewall bearing pressure (SWBP) conduit ranking. TVA expects to complete Phase I and Unit 2 Phase 11 by October 5, 1990.

2. In implementing the quality assurance (QA) lookback plan, TVA's QA organization will determine the contributing factors that led to Calculation SQN-CSS-009 not being issued. A report to the Site Director is expected by September 7, 1990.

3. In implementing the QA forward look plan, TVA's QA organization will monitor the activities associated with the new SWBP ranking process. A report to the Site Director is expected by October 9, 1990.

4. Based on the current schedule to complete the Phase I and Unit 2 Phase 11 conduits early in the Unit 2 Cycle 4 refueling outage. TVA commits to take the appropriate actions prior to start-up from that outage to verify the integrity of safety-related cables at SQN. These actions could include demonstration of cable acceptability, replacement of cables, or testing as necessary to obtain the required confidence. TVA fully expects the current schedule to support completion of this program and resolution prior to start-up. If it becomes apparent that SQN will not be able to complete these activities prior to start-up from the Cycle 4 outage, you will be promptly notified.

5. TVA will perform the Unit 1 Phase II portion of this plan at the first outage of sufficient duration but no later than the Unit 1 Cycle 5 refueling outage.