ML20147C793
| ML20147C793 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 01/06/1988 |
| From: | Myers H NRC |
| To: | Harold Denton NRC |
| References | |
| NUDOCS 8801190342 | |
| Download: ML20147C793 (18) | |
Text
hl January 6, 1988 To Harold Denton From Henry Myers pg Re: Attached Questions Concerning Sequoyah In the course of our inquiry into the Commission's regulation of TVA's nuclear program, we have reviewed many NRC and TVA documents pertaining to Sequoyah.
These documes.ts indicate the existence of conditions at Sequoyah which do (or did) not comply with NRC requirements.
Attached hereto is a list of questions derived from our review.
Many of these questions ara referenced to specific documents and are of the following general type:
1.
What reviews of the document and/or assessment of conditions described therein have been performed by the.4RC7 If such reviews were not conducted, what was the reason for their not having been done?
2.
Where and how are the results of any such reviews d>cumented?
3.
With respect to specific conditions enumerated in the referenced document, what corrective actions have been required by the NRC and how are these documented?
4.
With respect to specific conditions enumerated in the referenced document, what corrective actions have been completed by TVA7 5.
Are problems and/or deficiencies identified in the referenced document to be subject to corrective action prior to restart of Sequoyah?
If not, what is the i
basis for not requiring corrective action prior to restart?
We believe answers to the attached questions (many of which presumably exist) do or would provide information that is necessary, but not sufficient, for a determination of whether Segacyah complies with NRC regulations.
Accordingly, we believe that the NRC official responsible for authorization of Sequoyah restart should have (A) the answers to these questions within reach or (B) an explanation as to why particular questions are not relevant to the Sequoyah restart authorization.
8801190342 B90106 ADOCK05000gg7 DR
~
e January 5, 1988 QUESTIONS CONCERNING SEQUOYAH ISSUES I.
NRC Assessments of TVA Reviews Major TVA sponsored reviews of various aspects of TVA's nuclear program have been conducted by TVA's Nuclear Safety Review Staff, Black & Veatch, Gilbert Commonwealth, TVA's Design Baseline &
Verification Program (DB&VP), TVA's Engineering Assurance Audit 87-09, and TVA's Engineering Assurance Oversight Review (EA-OR-00:. ).
These TVA reviews identified numerous issues bearing directly on the safoty of TVA's nuclear facilities.
In addition, TVA employees have enumerated a largo number of actual and possible deficient conditions at Sequoyah and Watts Bar.
A.
Which of these reviews have been provided by TVA to the NRC7 Which have been reviewed by the NRC7 B.
Has NRC analyzed the design and construction problems identified by these TVA reviews and employee concerns to determine their generic applicability to Sequoyah and/or Watts Bar?
Where are any such analyses documented?
C.
Has the NRC compiled a comprehensive, categorized listing of Sequoyah design and constructiot' deficiencies enumerated in the foregoing TVA reviews?
D.
Has the NRC determined which of the Sequoyah design and construction deficiencies enumerated in the Joregoing TVA reviews predated issuance of the Sequoyal Operating License?
E.
Has NRC determined which of the problems identified by the TVA reviews and employees have been adequately resolved and/or subjected to corrective action?
F.
What action has NRC taken to identify and track resolution of design and construction problems identified in the foregoing TVA reviews?
G.
What actions has NRC taken to determine which Nuclear Safety Review Staff report findings, Black & Veatch (B&V) findings, and employee concerns pertain to Sequoyah?
What is the status of resolution of such findings and concerns?
H.
Which TVA employee concerns have been reviewed by the TVA Inspector General's Office?
Which of such concerns
have been substantiated?
Which have not been substantiated?
I.
On November 7, 1985, TVA sent the NRC a Gilbert-Commonwealth review of
"...the current design control program for the sequoyah Nuclear Plant.
This review was intended to provide an overall assessment of the i
completeness of the program, and its understanding and implementation by engineering personnel."
1.
What were the major findings of the Gilbert-Commonwealth review?
2.
What action has NRC taken with respect to the Gilbert Commonwealth findings concerning design control at Sequoyah?
3.
With respect to such findings, what corrective actions by TVA will be required prior to Sequoyah restart?
l J.
The following questions refer primarily to (A) the Design Baseline & Verification Program (DB&VP) and (B) the Engineering Assurance Review of the Sequoyah Unit 2 DB&VP, EA-OR-001, dated April 29, 1987.
The latter listed 357 action items, each such item apparently referring to a deficiency in the DB&VP and/or a Sequoyah design deficiency which the DB&VP had failed to identify.
1.
What reviews have been conducted by the NRC of TVA's DB&VP?
2.
What are the results of any such NRC reviews?
3.
What does the NRC believe to be the DB&VP's major findings?
4.
Which DB&VP findings indicated the existence of non-complying conditions that existed prior to the issuance of the Sequoyah Operating License?
5.
What does NRC believe to be the major findings of the Engineering Assessment (EA-OR-001) review of the DB&VP7 6.
What does NRC believe to be the major findings of the EA-OR-001 with respect to deficiencies in the
+
DB&VP7 7.
What hardware and design changes have resulted frma tne DB&VP and/or the Engineering Assessment,
l
of the DB&VP7 8.
Has NRC evaluated the scope and implications of TVA's not meeting requirements of the Topical Report Section 17.1 and 10CFR50.71 as they pertain to design criteria, calculations, and FSAR requirements on safety-related systams?
9.
EA-OR-001 states that the Engineering Assessment (EA) findings resulted in the issuance of "38 CAQs over and above those" identified by the DB&VP.
a.
How many CAQs were identified by the DB&VP7 6.
What are the 38 CAQs (i.e. identification number and substance) issued as a result of the EA-OR-001 review?
c.
What does generation of additional CAQ's by the EA effort imply with respect to the thoroughness of the DB&VP7 10.
Does EA-OR-001 and/or the DB&VP take adequate account of missing and/or incomplete calculations described in EA-87-097 11.
EA-OR-001 refers to the restart design basis document (RDBD).
(See EA-OR-001,
- p. 4-8.)
Has the RDBD been reviewed by the NRC7 12.
Has NRC reviewed the adequacy of the EA-OR-001 procedure for designating the extent (i.e. the generic applicability) and significance of the EA-OR-001 findings?
Has NRC reviewed the adequacy of implementation of the EA-OR-001 procedure for designating the extent and significance of EA-OR-001 findings?
(See EA-OR-001, p. 8-11 and Table 8.4-7.]
Where are any such NRC reviews documented?
13.
Does EA-OR-001 contain a separate listing of Action Items indicative of generic deficiencies in the DB&VP7 Where does any such listing appear?
Has the NRC reviewed the EA-CR-001 Action Items in order to determine the adequacy of the categorization of such items with respect to generic applicability and significance?
14.
At the April 10 meeting between TVA and NRC staff, Mr. John Cox, who was assigned overall direction of the DB&VP, stated that: l
4
.... none of these deficiencies (found by kne DB&VP), if left uncorrected, would or could have jeopardized the health and safety of the public from the operation of the facility." (Tr., p.18.]
a.
Is it TVA's position that none of the deficiencies found by the DB&VP, if left uncorrected, would or could have jeopardized the health and safety of the public from the operation of the facility?
b.
If so, does NRC staff agree with this position?
Is such a position consistent with the findings of the Engineering Assurance Oversight Review Report (EA-OR-001)7 c.
Is such a position consistent with the findings of Engineering Assurance Audit EA-87-097 15.
What has NRC done to date and what will it do in the future to determine the adequacy of corrective action plans and implementation with respect to the 357 action items enumerated in EA-OR-0017 i
Where are any such NRC actions documented?
16.
With reference to EA-OR-001, Appendix D, page 12 of 13, trend code for Action Item 012, this item (012) affects design criteria preparation, it is not a pre-or post restart issue, it pertains to inadequate design criteria documentation.
l a.
What review has NRC conducted of Q127 b.
Should Q12 have been identified as a restart issue for Sequoyah?
c.
What action will NRC require be taken by TVA with respect to 0127 d.
Does NRC concur with TVA's response to 0127 K.
On June 18, 1987, the TVA Nuclear Manager informed the TVA Congressional Caucus that:
The 37 major safety systems needed to shutdown the (Sequoyah) plant in the event of an emergency were evaluated and verified as capable of performing their designed functions.
Deficiencies were 4
I l
identified during the review and they are being tracked to ensure they are corrected.
These 37 system reviews were very comprehensive.
The completed review for one system, the Essential Raw Cooling Water System, required 19 volumes, each j
volume occupying a three-inch thick binder.
These reviews went back to the original system design requirements and forward to the latest design j
modifications to ensure the system would perform
)
its intended function.
(Underline added.)
)
The TVA Nuclear Manager further informed the Caucus that he disagreed with the NRC as to the necessity for additional design / construction verifications (the Integrated Design Inspection (IDI)).
1 a.
What reviews have been conducted by the NRC of the TVA review of 37 systems?
b.
What comparison has been made by the NRC of the IDI findings with TVA findings resulting from its various reviews of the Essential Raw Cooling Water (ERCW) system including reviews j
conducted in the course of the DB&VP7 c.
Is a finding that systems are capable of performing their designed (or intended) fu.nctions equivalent to finding that the systems comply with applicable NRC regulations and TVA licensing commitments?
If so, why does TVA not state that the systems in question comply with applicable NRC regulations and TVA licensing commitments?
If not, what is necessary to show that the systems in question comply with applicable NRC regulations and TVA licensing commitments?
II.
NRC Requests for Responses to NRC Inspection Reports and Other Matters A.
On January 15, 1986, NRC requested information on five design control questions pertaining to Sequoyah.
1.
What reviews of TVA's response to the January 15 letter have been conducted by the NRC7 2.
What are the results of any such review?
l B.
On October 20 and ilovember 14, 1986, the NRC sent TVA letters concerning NRC findings from an inspection of procurement and quality assurance records pertaining to Sequoyah.
1.
What review of TVA's response to the October 20 and November 14 letters has been conducted by the NRC7 2.
What are the results of any such~ review?
C.
On March 5, 1987, the NRC Director of Inspection and Enforcement sent a letter to TVA which raised questions as to deficiencies in the initial design of Sequoyah and the design modification process as applied to Sequoyah.
1.
What reviews of TVA's response with respect to specific issues raised in the March 5 letter have b9en conducted by the NRC7 2.
What are the results of any such review?
D.
On March 18, 1987 Commissioner Asselstine sent the NRC staff a list of questions concerning compliance of the Sequoyah Nuclear Plant with the Commission's regulations and the nature of reviews that would be necessary to establish compliance.
On March 31, 1987, NRC requested TVA to provide its views concerning questions posed by Commissioner Asselstine in his March 18 letter.
TVA responded on June 10, 1987.
1.
What reviews of TVA's June 10, 1987, response to Commissioner Asselstine's memorandum have been conducted by NRC7 What were the results of any such reviews?
i 2.
In the conduct of any such reviews, did NRC staff make use of comments by Mr. Dallas Hicks, transmitted to House Interior Committee staff on July 10, 1987, and forwarded to the NRC on July 13, 19877 What review of Mr. Hicks' comments hus been performed by the NRC7 l
E.
On April 24, 1987, NRC transmitted the results of Inspection 50-327/86-68 to TVA.
1.
What reviews of TVA's response with respect to specific issues raised in 50-327/86-68 have been conducted by the NRC7 2.
Where are any such reviews documented?
i 3.
What corrective actions have been undertaken to
remedy deficiencies noted in 50-327/86-687 F.
On August, 24, 1987, NRC transmitted to TVA the results of Inspection 50-327/87-27.
This report stated, among other things, that:
The TVA/CEB reviews highlighted above (i.e. SQN CEB 87-02, SQN CEB 87-03, SQN CEB 87-04, and SQN 87-06] indicate that a significant number of problems exist with newly regenerated calculations, many of which have been prepared by contract personnel.
With respect to the main feedester water hammer analysis, the 50-327/87-27 cover letter stated:
The TVA evaluation did not assess the main feedwater piping integrity and the increased loads transmitted to pipe snubbers. A TVA analysis performed on the Watts Bar main feedwater piping yielded snubber water hammer loads that were approximately 10 times greater than the snubber seismic loads.
The inspection 50-327/87-27 cover letter also stated:
The team also noted ineffective implementation of a procedure to track unverified assumptions made in calculations 1.
What reviews of TVA's response with respect to specific issues raised in 50-327/87-27 have been conducted by the NRC7 2.
Where are any such reviews documented?
3.
What corrective actions have been undertaken to remedy deficiencies noted in 50-327/87-277 G.
On September 25, 1987, NRC transmitted the results of Inspection 50-327/87-52 to TVA.
This report, which appears to have resulted from the walkdown portion of the IDI, stated, among other things, that:
We are particularly concerned that your design control process allowed components with undesignated valves, whose positions could affect the design of the ERCW system, to be installed in the plant without proper translation into specification, drawings, procedures and ____ _ _ -________.
instructions.
Other findings included:
- A-1. The drawings and instructions for the ERCW system did not reflect skid mounted valves in the ERCW lines that could isolate ERCW flow to the safety injection pump oil and bearing coolers and to the centrifugal charging pump oil coolers and there were no instructions for the initial or periodic alignment of the valves.
Further, the drawing did not show the specified high point vent valves.
- A-2. Cable installation procedures that allowed routing of safety-related cables through undesignated cable trays, without apparent regard to thermal loading, electrical separation, volumetrfc tray loading.
A-3. Procurement process did not specify that the ERCW screen wash pump be ASME Code Class III es specified in FSAR.
- A-4.
Procurement error that resulted in purchase of a flexible hose designed for 100 psi for application requiring 150 psi.
- A-5. Disconnection of sensors without review by TVA design organizations.
- A-6.
Installation of a prohibited cross connection between supposedly independent ERCW loops.
- B-1.
Three instrumentation drawings for the ERCW pump house instrument sense line floor sleeve packing showed conflicting requirements for its height and it was not installed according to any of them.
- B-2. Although the existing drawings reflected differently, heat tracing was not installed on the RA ERCW pump discharge pressure instrument line.
- B-3.
Failure to include safety-related instruments on CSSC list.
- B-4.
Failure to provide instructions for the positioning of valves downstream of the primary root valves.
B-5.
Failure to assure prevention of touching of cables between divisions.
- B-6.
Failure to route cables pursuant to cable pull cards and/or schedules.
- C.
Failure to control documents to show deletion of relief valves.
[ Note: (*) indicates items that did not carry over to the IDI.)
Inspection Report 327/87-52 concluded:
Although deficiencies associated with the ERCW system were observed by the inspection team, the team concluded that, in general and subject to resolution of those deficiencies, the ERCW system is satisfactorily installed and constructed in accordance with design specifications.
TVA was asked to respond to 327/87-52 within 30 days.
1.
Why were only two of the thirteen foregoing 87-52 findings listed in the IDI?
2.
On what date did TVA respond to 327/87-527 3.
What reviews of TVA's response to 50-327/87-52 have been conducted by the NRC7 4.
What analyses of the 50-327/87-52 findings have been conducted to determine the generic applicability of such findings?
H.
On December 3, 1987, NRC transmitted the results of Inspection 50-327/87-31 to TVA.
This report, concerning an inspection of the DB&VP stated, among other things, that:
implementation of corrective actions for DB&VP findings was still in progress at the time of the inspection, as was Engineering Assurance (EA) sampling and verification of implementation.
1.
What reviews of DB&VP and EA corrective action plans and implementation of such plans have been conducted by the NRC7 2.
Where are such reviews documented?
III. 10CFR50-Appendix B, CAO Program Ineffectiveness, Material Traceability / Procurement /Q-List /CSSC List, Engineering 9
I j
l Change Notice (ECN)
A.
What reviews have been performed by TVA since 1985 to j
i determine the adequacy of TVA's efforts to identify
)
l possible Appendix D violations at Sequoyah similar to J
those found at Watts Bar?
Where are any such reviews i
s documented?
What are the major findings resulting from any such reviews?
B.
With respect to TVA reviews conducted since 1984, what are the major design and construction deficiencies at-Sequoyah that have been identified as resulting from i
failures to comply with Appendix B7 Does NRC have a j
i compilation of actions taken by TVA to correct such j
design and construction deficiencies?
C.
Various TVA reviews have indicated that.the TVA program 4
for handling Conditions Adverse to Quality (CAQ) is i
deficient.
(E.g., Division of Nuclear Quality Assurance j
Audit, Deviation No. QSS-A-87-0012-D02 -and the June 16, 1987, memorandum from N.C. Kazanas, Director of Nuclear Quality Assurance to Abercrombie et al.: REVIEW OF THE NEW CONDITION ADVERSE TO QUALITY (CAQ) PROGRAM EFFECTIVENESS AT SEQUOYAH NUCLEAR PLANT'(SQN).]
1 1
1.
With respect to the CAQ program deficiencies existing as of-this date, what corrective actions
(
will have been completed vis-a-vis the CAQ program
)
prior to Sequoyah restart?
i 3
2.
With respect to corrective action program deficiencies since issuance of the Sequoyah l
Operating License, what actions have been taken to identify and correct non-complying conditions that may not have been corrected as a result of i
shortcomings in the corrective action program?
D.
Various TVA and NRC reports describe deficiencies I.
associated with material traceability / procurement, Q-List, and the CSSC List.
(E.g.,
NSRS R-84-17-NPS, 50-327/86-11, 50-327/86-61, 50-327/86-68, 50-327/87-40,
]
etc.)
1 1.
What is the status of resolution of such deficiencies?
Which of these deficiencies will be the subject of corrective action (s) prior to Sequoyah restart?
)
2.
What is the basis for NRC's not requiring as of j
]
January 1, 1987, a detailed Q-List or its equivalent for Sequoyah?
What is the basis for any claim that TVA's CSSC list is adequate and 1 3 i
j
that a Q-List or equivalent is not required?
3.
TVA documents dated October 6, 1986, January 4 and 29, 1987, April 21, 1987, and May 4, 1987, refer to traceability of materials used in pressure retaining piping components.
a.
What reviews of these documents have been conducted by the NRC7 b.
What is the NRC's position with respect to TVA's resolution of the employee concerns that resulted in the surfacing of this issue?
E.
There have been varying degrees of problems in handling ECNs by TVA per TVA's procedures.
1.
Do the ECN problems call DB&VP results into doubt?
2.
How will NRC oversee resolution of this problem prior to Sequoyah restart?
3.
What actions have been taken (or will be taken) by 1
the NRC to assure ccrrection of ECN deficiencies?
Which of such actions will be taken prior to Sequoyah restart?
F.
Since 1984, has TVA understated or misrepresented the scope and/or significance of the various safety and licensing problems associated with its nuclear program i
with respect to design and construction of Sequoyah?
IV.
Civil / Structural Calculation Issues i
A.
General Civil / Structural Calculation Questions 1.
Does NRC now know the extent of missing t
civil / structural calculations?
2.
Will NRC have reviewed TVA's original and j
regenerated Sequoyah calculations for adequacy prior to restart?
3.
What is the reason for the belated discovery of the calculation deficiencies which became a critical item in the Sequoyah restart schedule?
4.
Did TVA misrepresent to the NRC or unduly delay reporting to the NRC the status of the Sequoyah calculation problems?
B.
Specific Civil / Structural Calculation Questions related,
I to NRC findings of deficiencies in the civil / structural discipline in areas such as structural calculations, seismic calculations, and seismic response spectra.
1.
Why were these problems not identified by the NRC prior to the IDI or by TVA-via the DB&VP7 2.
What verification of TVA's corrective actions in these areas will NRC perform to insure that the actions taken are adequate for the safe operation of Sequoyah?
C.
Civil / Structural Questions Derived from the IDI:
1.
Which of the civil / structural problems, identified during the IDI, were not identified in the course of TVA's DB&VP and Engineering Assessment reviews?
2.
What is the reason for TVA's failure to find any such civil / structural problems prior to the IDI?
3.
With respect to problems identified by the DB&VP, why had corr"ctive actions not been taken prior to the initia' ion of the IDI?
4.
What reviews are being undertaken by TVA and/or NRC to determine whether the IDI findings are generic to the 37 Sequoyah safety systems other than the ERCW7 If such reviews are not being undertaken, what is the rationale for not doing so?
5.
If TVA performs such reviews for generic implications and takes corrective actions, will NRC verify that potentially generic problems have been identified and/or corrective actions have been taken?
6.
What corrective actions will be required for by the IDI in the civil /structuralresolution of the specific defici area?
Which of t
such corrective actions will be required prior to Sequoyah restart?
Electrical / Instrumentation & Control
\\
V.
(IGC)
A.
Calculations 1
l 1.
Has NRC reviewed TVA's regenerated electrical calculations for adequacy?
2.
Will NRC require independent review of the 4 i l
electrical calculations to assure their adequacy and that appropriate plant modifications are made where the regenerated calculations indicate such a need?
B.
Electrical and Instrumentation and Control (I&C)
[
i Questions Derived from the IDI 1.
Which of the electrical /I&C problems, identified during the IDI, were not identified in the course of TVA's DB&VP and Engineering Assessment reviews?
2.
What is the reason for TVA's failure to find any such electrical /IEC problems prior to the IDI?
3.
With respect to electrical /I&C problems which were found by the DB&VP, why had corrective actions not been taken prior to initiation of the IDI?
4.
What reviews are being undertaken by TVA and/or NRC to determine whether the IDI electrical /I&C findings are generic to the 37 Sequoyah safety systems other than the ERCW7 If such revious are not being undertaken, what is the rationale for not doing so?
5.
If TVA performs such reviews for generic implications of electrical /I&C findings and takes corrective actions, will NRC verify that j
potentially generic problems have been identified l
and/or corrective actions have been taken?
6.
What corrective actions will be required for resolution of the specific deficiencies identified by the IDI with respect to electrical and I&C7 l
Which of such corrective actions will be required prior to Sequoyah restart?
C.
Cables NSRS REPORT I-85-06-WBN (July 8, 1985), the Franklin a
Research Canter's Technical Evaluation Report (dated February 19, 1987), TVA employee concerns, and other sources have provided substantial evidence of cable problems at TVA nuclear plants.
Actual and potential j
cabling problems include:
poor engineering, inadequate calculations and methods for sizing cabling, improper
]
implementation of the National Electrical Code as committed in the FSAR (problems such as cable tray overfills, lack of properly derating cables, etc.),
inadequate specifications, inadequate procurement practices, inadequate installation procedures and 1
! 1 i
1 I
practices,~1nadequate testing, inadequate QA, improper cable bending radii, and jamming and vertical cable supported by 90 degree condulets, cable splicing and repair problems, pull tension and tension monitoring problems, cable inadequate lubricants, cable sidewall pressure problems, and cable ampacity problems.
- Moreover, had such limited scope that questions exist as toTVA's whether significant cabling problems have been addressed adequately.
1.
NRC staff have indicated that cable problems are limited mainly to silicone rubber insulated cables and, for this type cable, only those in containment.
What is the basis for any conclusions that cable problems identified by the above noted sources are limited to silicone rubber cables?
2.
What cable issues remain unresolved?
What prior to Sequoyah restart? corrective actions involving cables For example, no requirement for tests on all insulation typeswha and in all full range of cabling problems identified bytypes of various sources?
3.
Does NRC have or plan to have a detailed and comprehensive accounting of cable problems and resolutions or proposed resolutions?
- none, NRC review, prior to Sequoyah restart,when will the Will adequacy of such resolutions and any plant the configuration changes?
4.
How has NRC verified at Sequoyah the as-constructed cable routing versus the as-engineered routings?
verification documented?Where is any such has been made, If no such verification cable installation conforms to variouswhat is the basis for assu requirements with respect to separation, and cable tray loading?
ampacity 5.
What is the status of the Sequoyah cable ampacity program?
What reviews of this program have been conducted by NRC to determine the adequacy of this program and any corrective actions resulting from.
it?
6.
On November 2, 1987, a fire occurred in the Browns Ferry Unit 2 Reactor Building, a.
What actions have been taken and/h are planned by NRC to investigate the nature and cause of this November 2 fire?
b.
Was the fire caused by any of the cabling problems that have been identified by the above noted sources?
c.
Was PVC insulation involved?
What was the nature of damage caused by products of PVC combustion?
D.
Diesel Generators Various TVA documents raise questions as to the compliance of the Sequoyah diesel generator system with NRC requirements.
(E.g. See D51-A-84-0006-D01 dated July 2, 1984; PNO 05098, Jane 17, 1986, describing a TVA determination that thu Sequoyah diesel generators "may overload if a loss ca' off-site power occurs in coincidence with a phase B isolation"; and May 18, 1987 minutes of March 26, 1987, NRC/TVA meeting to discuss Sequoyah Diesel Generator Sequencing Calculations.]
What actions have been taken by NRC to assure adequate i
and reliable diesel generator capacity and shutdown capability?
VI.
Mechanical / Nuclear A.
Mechanical / Nuclear Calculations Questions Significant deficiencies have been identified in calculations in the mechanical and nuclear areas.
1.
Does NRC have a detailed accounting of the status of missing and deficient calculations in these disciplines?
2.
What reviews have been or will be conducted by the NRC to assure that TVA's regenerated calculations and those not regenerated are adequate?
3.
Since 1984, has TVA understated or misrepresented the scope and/or significance of the status of calculations?
B.
Mechanical / Nuclear Questions Derived from the IDI 1.
Which of the mechanical / nuclear problems, identified during the IDI, were not identified in the course of TVA's DB&VP and Engineering Assessment reviews?
2.
What ir, the reason for TVA's failure to find any such mechanical / nuclear problems prior to the IDI?
3.
With respect to mechanical / nuclear problems identified by the DB&VP, why had corrective actions not been taken prior to initiation of the IDI?
4.
What reviews are being undertaken by TVA and/or NRC to determine whether the IDI mechanical / nuclear findings are generic to the 37 Sequoyah safety systems other than the ERCW?
If such reviews are not being undertaken, what is the rationale for not doing so?
5.
If TVA performs such reviews for generic implications of the mechanical / nuclear findings and takes corrective actions, will NRC verify that potentially generic problems have been identified and/or adequate corrective actions have been taken?
6.
What corrective actions will be required for resolution of the specific deficiencies identified by the IDI in the mechanical and nuclear areas?
Which of such corrective actions will be required prior to Sequoyah restart?
VII.
Welding Issues A.
What reviews have been conducted to determine the existence at Sequoyah of welding problems identified at Watts Bar?
)
B.
What problems were identified through any such reviews?
C.
What corrective actions have been taken with respect to weld problems identified at Sequoyah through TV3 reviews, NRC reviews, employee concerns programs, and through other means?
VIII.
As-Built Configuration Versus Drawings A.
What is the nature and extent of discrepancies, discovered to date, between and among as-engineered drawings, as-constructed drawings, and the as-built plant configuration?
1 B.
Inspection 327/87-52 found discrepan:les between the i
j Sequoyah design documents and as-built conditions.
What actions will NRC take to deteraine the generic implications of such discrepancies" I
i C.
What discrepancies exist between the control room drawings (i.e. drawings used by control room operators) i versus the as-engineered and as-constructed drawings?
j What corrective actions in this area will be required prior to Sequoyah restart?
Will NRC verify that the required actions are taken?
IX.
Procedures / Training A.
Has NRC reviewed TVA's procedures, policies, personnel l
l training, operational readiness, emergency
)
preparedness, etc., required for safe management and operation of Sequoyah?
What problems have been found in these areas?
B.
With respect to procedures and training, what
[
corrective actions will have been taken prior to l
Sequoyah restart to resolve such problems?
With respect to such problems, what corrective actions have been deferred until after Sequoyah restart?
]
f X.
Restart criteria A.
Does NRC have a detailed listing of Sequoyah items required to be resolved prior to restart?
If not, when will such a listing be available?
B.
Inspection Report 327/87-31 stated:
A review of the SQEP-45, Attachment 2-forms showed that these items (i.e. punch 11st items 518, 955, 6066, and 9304) were actually determined to be pre-restart items.
The team believes that there are many discrepancies between the punch 11st and SQEP-45, Attachment 2 forms regarding the categorization of the punchlist items, and that the accuracy of the punchlist should be verified before restart. (p. 31.]
How many such discrepancies exist?
What are the i
specifics of the punch 11st items that had been determined to be pre-restart items but were shifted to i
the post-restart list?
C.
Will NRC require TVA to provide justification for each l i
item that has been removed (since initiation of development of the list) from the list of items requiring resolution prior to restart?
D.
Will NRC review and approve resolution of each restart item that TVA claims to have resolved?
Will NRC approve each of those items for which corrective actions will have been taken prior to restart and those for which corrective actions will be taken after restart?
E.
What are the titles and dates of exemptions from compliance with the original Sequoyah Unit 2 Operating License (OL) (including original licensing conditions) granted since the Sequoyah Unit 2 OL was issued?
XI.
Licensing A.
What percentage of TVA's total licensing commitments (including operating license basis commitments and subsequent changes to those commitments) has NRC reviewed for adequacy and regulatory compliance for Sequoyah since it was shut down in 19857 B.
Has NRC compiled a current listing of items of non-compliance with NRC regulations and TVA licensing commitments at Sequoyah?
C.
Which of such deficiencies will be subject to corrective actions prior to Sequoyah restart?
D.
Will NRC require TVA to certify that Sequoyah meets licensing requirements prior to restart?
If not, by what authority can NRC allow Sequoyah to restart in the absence of such a certification? r
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