ML20140C277
| ML20140C277 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry, Sequoyah, 05000000 |
| Issue date: | 03/10/1986 |
| From: | Breeding C, Jesse Rollins, Stevens W TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML082340275 | List: |
| References | |
| 00085, 85, I-85-651-SQN, NUDOCS 8603250308 | |
| Download: ML20140C277 (12) | |
Text
. _ _
~..._. =- _ -. _ -.. -.
l I
TENNESSEE VALLEY AUTHORITY l
NUCLEAR SAFETY REVIEW STAFF NSRS INVESTIGATION REPORT NO. I-85-651-SQN EMPLOYEE CONCERN: XX-85-122-001
SUBJECT:
ELECTRICAL REGULATIONS IGNORED AND VIOLATED i
l DATES OF j
INVESTIGATION:
FEBRUARY 3-25, 1986 d' # [,,
INVESTIGATOR:
m C. L. BREE0fNG GATE
- J /4/f<
REVIEWED BY:
/7.
=
g.B.ROLLINS DME '
APPROVED BY:
Mad 3//0/
H. D. STEVENS DATE /
1
$hh DOC PDR P
1 0008s l
I.
BACKGROUND A Nuclear Safety Review Staff (NSRS) investigation was conducted to determine the validity of an expressed employee concern received by Quality Technology Company (QTC)/ Employee Response Team (ERT). The concern of record, as summarized on the Employee Concern Assignment Request Form from QTC and identified as KX-85-122-001, stated:
Sequoyah: Electrical and I&C Regulations (Reg. Guidos, NUREcs Bulletins and Noticos) have been ignored and violated to a very largo degree at all plants. This has been caused by a lack of knowledge, a poor attitude
- toward safety and regulations, and a lack of knowledge of industry positions on regulations on the part of TVA personnel. CI has no further information, anony-mous concern via letter.
II.
SCOPE The scope of this investigation was determined from the stated concern of record to be that of two specific issues requiring investigation.
A.
Regulations concerning electrical and instrument and controls (I&C) areas have been ignored and violated at Sequoyah.
B.
The cause of ignored and violated regulations is lack of knowledge and poor attitudo.
III.
SUMMARY
OF FINDINGS A.
Requirements and Commitments 1.
10CFR, " Domestic Licensing of Production and Utilization Facilitics," contains regulations that govern the licensing of nucicar plants.
Among other requirements, this codo sets environmental qualification schedules for electrical equipment, specifies construction codes, gives general design critoria, requires quality assurance programs, and speciflos a fire-protection program.
2.
A letter from William J. Dircks, NRC, to Charles Dean dated September 17, 1985, contains, as an attachment, the most recent NRC Systematic Assessment of Licensee Performance (SALP)
Report. This report is a periodic assessment of how TVA is complying with NRC regulations in its oporation of nuc1 car units. This letter from Mr. Dircks required that TVA furnish information about concerns that the SALP report raised.
3.
TVA responded to the September 17, 1985 Dircks lotter with two volumes entitled " Nuclear Performance Plan - Corporato" and "Nucicar Performanco Plan - Sequoyah." These volumes addressed the actions TVA planned to take to address the concerns raised in the SALP report.
1
B. _ Findings The SALP review of Sequoyah (report numbers 50-327/85-22 and 50-328/85-22) contained a detailed NRC assessment of Sequoyah's efforts to comply with NRC regulations during the period March 1, 1984 through May 31, 1985. Sequoyah's efforts to meet electrical and instrument and control regulations were a part of this assessment.
The introduction of this report stated:
The SALP program is an integrated NRC staff effort to collect available observations and data on a periodic basis and to evaluate licensee performance
~
based upon this information. SALP is supplemental to normal regulatory processes used to ensure com-pliance to NRC rules and regulations. SALP is intended to be sufficiently diagnostic to provide a rational basis for allocating NRC resources and to provide meaningful guidance to the licen-see's management to promote quality and safety of plant construction and operation.
The SALP report was used as a basis for the investigation of this concern as it is a non-TVA view of how well TVA meets regulations.
The SALP report was very critical of TVA's nuclear management.
The transmittal letter of Mr. Dircks required that the shutdown TVA plants remain shut down until NRC agrees that "various plant-specific deficiencies and management problems" are corrected.
Among those deficiencies were problems in the electrical and instrument and control area. The letter required that Sequoyah meet the requirements of the environmental qualification program (much of this program contains requirements for electrical components),
analyze cable tray support seismic design, and " provide a detailed description of the design control survey which you (TVA) are conducting, including a discussion of any generic implications on plant design" (this would include evaluations of electrical design).
The SALP report contained many items related to problems in the electrical and I&C area such as:
1.
Page 8. "In April 1984 surveillance activities revealed wiring i
and switch deficiencies involving power operated relief valves (PORVs) on both units. These deficiencies had existed since the construction of the plant. Inadequacies in construction procedures and engineering postmodification testing requirements resulted in a miswired Unit 2 PORV."
2
r l
i
~
.2.
Page 9, "The resolution of technical issues with regards to prompt and accurate nonconformance identification and evaluation was weak. This was demonstrated by the ineffective handling of a radiation monitor nonconformance (violation n.), the inability to rapidly identify and characterize the safety significance of containment pressure transmitter environmental qualification concerns, and the failure to formulate adequate corrective actions to prevent inadvertent switch-generated safety injection signals (violation f.)."
1 3.
Page 26, " Strong management participation was also evident on the issue related to revising the schedule for environmental qualified. electrical equipment that needed replacement by November 1985. This implementation date was previously extended by the NRC in which licensee management participation on this issue has become evident only after the matter developed into a l
significant problem for the licensee and the NRC."
TVA responded to the Dircks letter and the SALP report with a two-volume " Nuclear Performance Plan."
In the conclusion to the l
introduction section of the Sequoyah volume, TVA stated:
"We j
believe that the documentation contained in this report demonstrates conclusively that the necessary actions are well underway for SQN to resume safe operation by the end of the year." This document is currently being totally revised with an expected completion date of March 11, 1986.
IV.
CONCLUSIONS AND RECOMMENDATIONS A.
Conclusions The current shutdown status of Sequoyah was partially due to problems in the electrical and I&C area. This was pointed out in the latest NRC SALP report. The concerns raised are substantiated, but TVA management is fully aware of the conditions and has planned corrective action in accordance with the Nuclear Performance Plan.
B.
Recommendations None at this time.
3
a i
i DOCUMENTS REVIEWED IN INVESTICATION 1-85-651-SQN AND REFERENCES 1.
Letter from William J. Dircks, Executive Director For Operations, NRC, to Charles Dean, Chairman, Board of Directors. TVA, dated September 17, 1985 (A07 850919 005) 2.
Title 10. Chapter 1. Code of Federal Regulations - Energy Part 50,
- Domestic Licensing of Production and Utilization Facilities" 3.
Letter from C. H. Dean, Jr., to William J. Dircks dated November 1, 1985 1
I J
l r
0563U 4
"YV A.4 405 9-65) (OP+WP-5 85)
UNITED STATES GOVE'tN31ENT 2V1C7H 0Tdn dMM TENNESSEE VALLEY AUTHORITY TO: H. L. Abercrombie, Site Director, Sequoyah Nuclear Plant FROM: K. W. Whitt, Director of Nuclear Safety Review Staff E3A8 C-K MAR 111986 DATE:
SUBJECT:
NUCLEAR SAFETY REVIEW STAFF INVESTICATION REPORT TRANSMITTAL
~
Transmitted herein is NSRS Report No.
I-85-651-SON
)
Subject ELECTRICAL REGULATION IGNORED AND' VIOLATED Concern No.
XX-85-122-001 No response or corrective action is required for this report.
It is being transmitted to you for information purposes only. Should you have any questions, please contact W. D. Stevens at telephone 6231 Reco::: mend Reportability Determination: Yes No X
l
/)DifliicTor, NSRS/ Designee i
WDS:GDM Attachment ec (Attachment):
W. C. Bibb, BFN W. T. Cottle, WBN James P. Darling, BLtl R. P. Denise LP6N40A-C C. B. Kirk, SQti D. R. Nichols. E10A14 C-K QTC/ERT, Watts Bar !!uclear Plant Eric Sliger, LP6tl48A-C
/3!b J. H. Sullivan SQti
/
0591U i
L kv !! V Vnt inne Rnnde Rnnlar/v nn the Payroll Savinn Plan
n l
TENNESSEE VALLEY AUTHORITY NUCLEAR SAFETY REVIEW STAFF NSRS INVESTIGATION REPORT NO. I-85-6SI-SQN EMPLOYEE CONCERN:
XX-85-122-001
SUBJECT:
ELECTRICAL REGULATIONS IGNORED AND VIOLATED DATES OF INVESTIGATION:
FEBRUARY 3-25, 1986 f g6 INVESTIGATOR:
C. L. BREEOfNG SATE
- 3[4/g REVIEHED BY:
/7.
=
$.B.ROLLINS DME '
APPROVED BY:
AM j//c/N H. D. STEVENS DATE /
i 1
0008s
I.
BACKGROUND A Nuclear Safety Review Staff (NSRS) investigation was conducted to determine the validity of an expressed employee concern received by Quality Technology Company (QTC)/ Employee Response Team (ERT). The concern of record, as summarized on the Employee Concern Assignment j
Request Form from QTC and identified as XX-85-122-001, stated:
1 i
Sequoyah:
Electrical and I&C Regulations (Reg. Guides, l
NUREGs, Bulletins and Notices) have been ignored and violated to a very large degree at all plants.
This has been caused by a lack of knowledge, a poor attitude
' toward safety and regulations, and a lack of knowledge of industry positions on regulations on the part of TVA personnel.
CI has no further information, anony-mous concern via letter.
II.
SCOPE The scope of this investigation was determined from the sta'.ed concern of record to be that of two specifi'c issues requiring investigation.
]
A.
Regulations concerning electrical and instrument and controls (I&C) areas have been ignored and violated at Sequoyah.
B.
The cause of ignored and violated regulations is lack of knowledge and poor attitude.
III.
SUMMARY
OF FINDINGS T
)
A.
Requirements and Commitments I
1.
10CFR, " Domestic Licensing of Production and Utilization Facilities," contains regulations that govern the licensing of nuclear plants.
Among other requirements, this code sets environmental qualification schedules for electrical equipment, specifies construction codos, gives general design criteria, requires quality assurance programs, and specifies a fire-protection program.
2.
A letter from William J. Dircks, URC, to Charles Dean dated j
September 17, 1985, contains, as an attachment, the most recent NRC Systematic Assessment of Licensco Performance (SALP)
Report. This report is a periodic assessment of how TVA is complying with NRC regulations in its operation of nuclear i
units. This letter from Mr. Dircks required that TVA furnish I
information about concerns that the SALP report raised.
3.
TVA responded to the September 17, 1985 Dircks lotter with two volumes entitled " Nuclear Performance Plan - Corporate" and
" Nucle,ar Performance Plan - Sequoyah." These volumes addressed i
the actions TVA planned to take to address the concerns raised in the SALP report.
1
.-----.--..--.-4
.--.,n-
---n- - - -..
,-n, m,,------,-.a
,,.n.--
,-r,-.
-,g,
+-w,v--
B.
Findings The SALP review of Sequoyah (report numbers 50-327/85-22 and 50-328/85-22) contained a detailed NRC assessment of Sequoyah's efforts to comply with URC regulations during the period March 1, l
1984 through May 31, 1985. Sequoyah's efforts to meet electrical and instrument and control regulations were a part of this assessment. The introduction of this report stated:
The SALP program is an integrated NRC staff effort to collect available observations and data on a periodic basis and to evaluate licensee performance based upon this information.
SALP is supplcmental to normal regulatory processes used to ensure com-pliance to NRC rules and regulations.
SALP is intended to be sufficiently diagnostic to provide a rational basis for allocating NRC resources and to provide meaningful guidance to the licen-see's management to promote quality and safety of plant construction and operation.
The SALP report was used as a basis for the investigation of this concern as it is a non-TVA view of how well TVA meets regulations.
The SALP report was very critical of TVA's nuclear management. The transmittal letter of Mr. Dircks required that the shutdown TVA Plants remain shut down until URC agrees that "various plant-specific deficiencies and management problems" are corrected.
Among those deficiencies were problems in the electrical and instrument and control area. The letter required that Sequoyah meet the requirements of the environmental qualification program (much of this program contains requirements for electrical components),
analyze cable tray support coismic design, and " provide a detailed description of the design control survey which you (TVA) are conducting, including a discussion of any generic implications on plant design" (this would include evaluations of electrical design),
i The SALP report contained many items related to problems in the electrical and I&C area cuch as:
1.
Page 8. "In April 1984 surveillance activities revealed wiring and switch deficiencies involving power operated relief valves (PORVs) on both units.
These deficiencies had existed since the construction of the plant.
Inadequacies in construction procedures and engineering postmodification testing requirements resulted in a miswired Unit 2 PORV."
2
.2.
Page 9 "The resolution of technical issues with regards to prompt and accurate nonconformance identification and evaluation was weak.
This was demonstrated by the ineffective handling of a radiation monitor nonconformance (violation n.), the inability to rapidly identify and characterize the safety significance of containment pressure transmitter environmental qualification concerns, and the failure.to formulate adequate corrective actions to prevent inadvertent switch-generated safety injection signals (violation f.)."
3.
Page 26 " Strong management participation was also evident on the issue related to revising the schedule for environmental qualified electrical equipment that needed replacement by November 1985. This implementation date was previously extended by the NRC in which licensee management participation on this issue has become evident only after the matter developed into a significant problem for the licensee and the NRC."
TVA responded to the Dircks letter and the SALP report with a two-volume " Nuclear Performance Plan."
In the conclusion to the introduction section of the Sequoyah volume, TVA stated:
"We believe that the documentation contained in this report demonstrates conclusively that the necessary actions are well underway for SQN to resume safe operation by the end of the year." This document is currently being totally revised with an expected completion date of March 11, 1986.
IV.
CONCLUSIONS AND RECOMMENDATIONS
'A.
Conclusions The current shutdown status of Sequoyah was partially due to problems in the electrical and I&C area.
This was pointed out in the latest NRC SALP report. The concerns raised are substantiated, but TVA management is fully aware of the conditions and has planned corrective action in accordance with the Nuclear Performance Plan.
B.
Recommendations None at this time.
3
DOCUMENTS REVIEWED IN INVESTIGATION I-85-651-SQN AND REFERENCES 1.
Letter from William J. Dircks Executive Director For Operations, NRC, to Charles Dean, Chairman, Board of Directors, TVA, dated September 17, 1985 (A07 850919 005) 2.
Title 10, Chapter 1 Code of Federal Regulations - Energy Part 50,
Domestic Licensing of Production and Utilization Facilities" 3.
Letter from C. H. Dean, Jr., to William J. Dircks dated November 1, 1985 0563U 4
tva e4ds-94s top-wp s esi g
UNITED STATES GOVERNMENT l%(
Memorandum 18xwesses vanter Aurnoniry H.
E,~. Abercrombie, Site Director, Sequoyah Nuclear Plant TO:
FROM: K. W. Whitt, Director of Nuclear Safety Review Staff, E3A8 C-K MAR 111986 DATE:
SUBJECT:
NUCLEAR SAFETY 5tEVIEW STAFF INVESTIGATION REPORT TRANSMITTAL Transmitted herein is NSRS Report No.
I-85-651-SON Subject ELECTRICAL REGULATION IGNORED AND VIOLATED Concern No.
XX-85-122-001 No response or corrective action is required for this report. It is being transmitted to you for information purposes only.
Should you have any questions, please contact W.
D. Stevens at telephone 6231 CPD /
Reco::: mend Reportability Determination: Yes No
,,,,73 3, wettu et STE DiMC'CP! 'NF80f hFd i[db
/N s
N
/D redfor, NSRS/ Designee
'5' n, s
WDS:GDM 2 4 Attachment ie cc (Attachment -
W.;
W. C. Bibb, BF (
'l^,_
W. T. Cottle, WBNN r-James P. Darling, BLN iN~
R. P. Denise, LP6N40A-C
}
G. B. Kirk, SQN e'*
D. R. Nichols, E10A14 C-K
~
~ ~ ~
QTC/ERT, Watts Bar Nuclear Plant Eric Sliger, LP6N48A-C
^~ 'N J. H. Sullivan, SQN N
!/
bb t
/
0591U s
k 7
A
~
Rm. I'.7 b'rhr*nns Rr,nds Rroularlv nn Ihr Patroll Sarinas Plan