ML20140C358
| ML20140C358 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry, Sequoyah, 05000000 |
| Issue date: | 03/11/1986 |
| From: | Owens G, Jesse Rollins, Stevens W TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML082340275 | List: |
| References | |
| I-85-225-SQN, NUDOCS 8603250330 | |
| Download: ML20140C358 (7) | |
Text
.
TENNESSEE VALLEY AUTHORITY NUCLEAR SAFETY REVIEW STAFF NSRS INVESTICATION REPORT NO. I-85-225-SQN EMPLOYEE CONCERN:
XX-85-122-014
SUBJECT:
ENVIRONMENTAL QUALIFICATIONS OF ELECTRICAL AND I&C EQUIPMENT AND COMPONENTS DATES OF INVESTICATION:
FEBRUARY 6-14, 1986 INVESTICATOR:
/1 3 9
(
- h. B. ROLLINS p(TP/
Jil//D[fyt$,
l REVIEWED BY:
G
. OWENS DATE 3!//Tb APPROVED BY:
W. D. STEVENS DATE' 8603250330 860321 PDR ADOCK 05000259 p
's 4
J I.
BACKGROUND A Nuclear Safety Review Staff (NSRS) investigation was conducted to determine the validity of an expressed employee concern received by the 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 XX-85-122-014, stated:
Sequoyah: Environmental qualifications of electrical and I&C equipment and components is inadequate.
Qualification was often not done, or if done, records do not exist in many cases, which results in modification or replacement.
Current upgrade program for environmental qualifications needs scrutiny.
CI has no further information.
Anonymous concern via letter.
II.
SCOPE The scope of the investigation was defined by the concern of record and entailed investigating two issues in order to validate or refute the concern.
A.
Documentation supporting the environmental qualification (EQ) of electrical and I&C equipment and components is not adequate.
B.
The current upgrade program for EQ needs scrutiny.
The concern was investigated by contacting applicable personnel and reviewing documentation relating to the environmantal qualification of electrical and I&C equipment and components. NSRS reviewed requirements and commitments, procedures / instructions, and audit / reports.
III.
SUMMARY
OF FINDINCS A.
Requirements and Commitments 1.
Title 10 Code of Federal Regulations Part 50, Section 49 (10CFR50.49), " Environmental Qualification of Electric Equipment Important to Safety for Nuclear Power Plants" (Ref. 1) l 2.
U.S. NRC NUREG 0588, Revision 1, " Interim Staff Position on Environmental Qualification of Safety-Related Electrical Equipment" (Ref. 3) 1 c
B.
Findings 1.
10CFR50.49 (Ref. 1) requires that each holder of or each applicant for a license to operate a nucicar power plant shall establish a program for qualifying electric equipment important to safety. These categories of electric equipment important to safety were identified to be qualified for their application and specified performance. These three categories are:
(1) safety-related electric equipment (Class lE), (2) nonsafety-related electric equipment (non-Class 1E) whose failure under postulated environmental conditions could prevent satisfactory accomplish-ment of safety functions by safety-related equipment, and (3) certain postaccident monitoring equipment.
10CFR50.49 also establishes environmental qualification methods and qualifica-tion parameters.
2.
U.S. NRC NUREG 0588 (Ref. 3), which applies to Sequoyah Nuclear Plant (SQN) and later plants, provides the basis for evaluating Clasc IE electrical equipment.
NUREG 0588 is divided into Categories I and II.
Category I applies to plants committed to IEEE-323-1974, and Category II applies to plants committed to IEEE-323-1971 [SQN and Watts Bar Nuclear Plant (WBN)].
Since IEEE-323-1971 contains no specific requirements concerning i
margin, aging, or maintaining document files and does not specify accident conditions, it must be used concurrently with the 1974 version of the standard.
3.
A review of the WesTec/TVA " Management Review of Environmental Qualification (EQ) Activities and Documentation for Compliance with 10CFR50.49" (Ref. 6) identified the following information.
A team of WesTec Services Incorporated, and TVA personnel a.
performed a programmatic and technical review of TVA environmental qualification (EQ) activities and documenta-tion to determine the degree of compliance to 10CFR50.49.
The scope of the review included T7A's entire EQ program for Browns Ferry Nuclear Plant (BFN), SQN, and WBN.
b.
Based on its review of the TVA EQ program at Knoxville and BFN, the team concluded that qualification had not been established for many equipment items.
In general, the EQ files were found to be incomplete and not readily auditable; where technical information could be found the majority of it was scattered and not easily retrievable. The team j
believed that this situation was due to the fragmented nature of the program and the lack of overall cohesive direction of the effort. This fragmentation was evidenced by the team's observations of inconsistent approaches to qualification by various organizations, lack of detailed review, and poor documentation. The team believed that the identified deficiencies were significant, systematic, and pervasive, in that the same type of deficiency could be expected to be found in other EQ files. The team recommended that TVA place the highest priority on the expeditious resolution of these issues.
2
~
\\
i As a result of this review, TVA management made the decision to shut down SQN.
4.
Environmental Qualification Project managers stated after evidence was presented that a significant programmatic problem
)
with the EQ program existed, management implemented corrective action through the establishment of the Environmental Qualification Project (EQP). The EQP was charged with the responsibility for developing an environmental qualification i
(EQ) documentation program to verify the acceptable EQ status of all plant equipment covered under 10CFR50.49. This effort consisted of developing EQ package binders and a 10CFR50.49 list representing the as-configured status of the plant.
EQP also supported plant and engineering organizations in developing and implementing programs and interfaces that will ensure compliance with 10CFR50.49 for the life of the plant.
As part of this effort, EQP has generated significant condition reports when specific qualification deficiencies were j
identified. Appropriate corrective action to these deficiencies will be implemented prior to startup.
]
5.
A joint DQA and OE/QMS audit report was issued in January 1986 l
(Ref. 7).
This report concluded that the acceptability of the SQN EQ program in the near future is a matter of continued progress. At the conclusion of this audit, it was clear that a significant number of issues remain viaresolved and that an extensive amount of work needs to be completed, suggesting that full implementation may still be some distance away. However, the controlling documents of this program are of very respectable quality, appear to be well controlled, and should prove to be effective in establishing that installed plant equipment is environmentally qualified and will be maintained as such.
6.
DQA managers stated that the EQ program for SQN will be audited annually. Audits within this timeframe will be performed upon request.
7.
NRC is presently involved in reviewing the programmatic and technical aspects of the EQ program for SQN. Because of the magnitude of their work, NRC has identified, through inspection status meetings (Ref. 8), items or areas that need improvement so that correct 4"e action can be initiated. Upon completion of this revie', the EQ program will be discussed in one inspection report.
8.
NRC inspectors involved in the inspection of SQN's EQ program stated that NRC will complete its inspection of the EQ program prior to startup. NRC will monitor the functioning of the EQ program at SQN in the future; however, no dates have been established.
3
s i
_9.
SQN is in the process of establishing a permanent staff for site i
EQ program coordination.
The EQ coordinator, under the I
direction of the Plant Maintenance Superintendent, will be responsible for coordinating the implementation of the site EQ program and ensuring that program effectiveness and compliance are maintained.
IV.
CONCLUSIONS AND RECOMMENDATIONS A.
Conclusions The concern of record was substantiated, based on the evidence that a significant programmatic problem with the environmental qualifica-tion program existed. However, with the establishment of the Environmental Qualification Project, work has progressed toward obtaining compliance with 10CFR50.49. This task will be completed prior to startup of Sequoyah Nuclear Plant. The EQ program for SQN has received and will continue to receive scrutiny from internal TVA quality assurance organizations and NRC.
B.
Recommendations None at this time.
4
~
r
DOCUMENTS REVIEWED IN INVESTIGATION I-85-225-SQN AND REFERENCES I
1.
10CFR50.49, " Environmental Qualification of Electric Equipment Important to Safety for Nuclear Power Plants" 2.
U.S. NRC Regulatory Guide 1.89, " Environmental Qualification of Certain Electric Equipment Important to Safety for Nuclear Power Plants," R1, dated June 1984 3.
U.S. NRC NUREG 0588, " Interim Staff Position on Environmental Qualification of Safety-Related Electrical Equipment," R1 4
U.S. NRC IE Bulletin No.79-01B, " Environmental Qualification of Class IE Equipment," and Supplement Information Nos.
1,.2, and 3 5.
Area Plan Program Procedure TS 01.00.08.14.03, " Environmental Qualifica-tion of all Safety-Related Electrical Equipment," revised November 20, 1985 6.
WesTec Services /TVA, " Management Review of Environmental Qualification Activities and Documentation for Compliance with 10CFR50.49," dated September 25, 1985 7.
TVA Division of Quality Assurance and Office of Engineering Quality Management Staff, Joint Audit Report QSS-A-86-0004, " Environmental Qualification of Safety-Related Equipment" 8.
Minutes for Environ = ental Qualification (EQ) NRC exit at Sequoyah Nuclear Plant (SQN) dated January 21, 1986 9.
Sequoyah Nuclear Plant Standard Procedure SQA 173, "Sequoyah Nuclear Plant 10CFR50.49 Environmental Qualification Program," R1, dated November 18, 1985 10.
Sequoyah Nuclear Plant Standard Practice SQA 174, "Sequoyah Nuclear Plant 10CFR50.49 List and Environmental Qualification Binder Control,"
issued November 18, 1985 11.
Sequoyah Nuclear Plant Standard Practice SQA 161 " Procurement of 10CFR50.49 Equipment," R1, dated November 20, 1985 l
5 m
TV A,60 (05-9-65) (OP-WP-5-8 5)
UNITED STATES COVERN3!ENT Memorandum rtxxtsste vattsy aurnoniry H.U.Abercrombie,SiteDirector,SequoyahNuclearPlant TO:
FROM: K. W. Whitt, Director of Nuclear Safety Review Staff, E3A8 C-K MAR 121986 DATE:
SUBJECT:
NUCLEAR SAFETY REVIEW STAFF INVESTIGATION REPORT TRANSMITTAL Transmitted herein is NSRS Report No.
I-85-225-SON Subject ENVIPOMENTAL QUALIFICATION / ELECTRICAL /I&C EOUIPMENT/ COMPONENTS Concern No.
XX-85-122-014 No response or corrective action is required for this report.
It is being transmitted to you for infomation purposes only.
Should you have any questions, please contact W. D.
Stevens at telephone 6231 Reco:::mond Reportability Determination:
Yes No' X
/
/ -
/ rector, NSRS/ Designee WDS:GDM l
Attachment cc (Attachment):
W. C. Bibb, BFN W. T. Cottle, WBN James P. Darling, BLN R. P. Denise, LP6N40A-C G. B. Kirk, SQN D. R. Nichols, E10A14 C-K QTC/ERT, Watts Bar Nuclear Plant Eric Sliger. LP6N48A-C j
J. H. Sullivan, SQN
-l
~2, h s
9,0593U a,... r r e c..;... n,. as, p,.. 1,,,1.. n o I,,,
p,,,.,nli en,,; nr Pin,,
. _ -.