ML20149C382

Requests That Commission State Position Re Validity of Encl D Hicks 870328 Concerns on TVA Nuclear Project.Items Presented by Hicks Have Potentially Significant Implications W/Respect to Whether Facility Complies W/Nrc Regulations

ML20149C382
Person / Time
Site:	05000000, Sequoyah
Issue date:	04/09/1987
From:	Dingell J, Udall M HOUSE OF REP., ENERGY & COMMERCE, HOUSE OF REP., INTERIOR & INSULAR AFFAIRS
To:	Zech L NRC COMMISSION (OCM)
Shared Package
ML082310263	List: ML20147G782 ML20149C382
References
FOIA-87-726 NUDOCS 8706040254
Download: ML20149C382 (27)

Text

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easWastan, DC 20615 4'

Apr11'9e 1987 '

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The sonorab1e Lando - E ech, Jr.'

Chairman

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@C4 nuclear segulatory Commission 1717 E Street,.N.

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Washington, D.

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20555 f>gg Dear Chairman secho We have received the enclosed letter f rom.Mr. Dallas sicks, an engineer wbo once worked in the Tennessee valley Authority (TVA) nuclear power program.

As the materials sutsnitted by since. leaving his TVA position, Mt. 51 cts mate r clear, he has, maintained a deep interest in the saf ety of TVA's nuclear plants.

The 28 items presented bylMr. Ricks in the first attachment

' to.his letter have potentially.signit icant, implications with respect to whether the Sequoyah reactors comply with the in order for there to be Commission's requistions.

According public confidence in any Commission cision to arllow restart of the Sequoyah ro60 tors, it its important that the Commission state its positlon with respect.to the.validi of Mr. Nicks' 28 items.

In addition, please provide the commissi n's position with respect to which of these titems need be resolved prior to restart at sequoyah, which need be resolved atter restart, and the rationale f or placing the : items in the pre-o; post-restart category. ;

Thank you fOcur attention to this inatter.

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sincerely,

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JOhl DT D4WGELL

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MORA L

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Chairuan Lraan i Committee on Coamittee on-Energy and Commerce Interior and Insular Aff airs fnclosure IDO - 002768

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k Xeled esat wuores..t.ane Enoxville. TN 37912 Warch 28, 1937i Dingslit. Chaivaans Hon. John D.

subcommittee on Oversight and 1 Westigations Unit'ed States, House of Representatives Room 2323.

Rayburn H05 :

Washington. D. C. 20516 -

Hon. Warris,K. Uda11. Chairman.

committse on Interior andiInsuler Af f airs '

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United States House of Representatives 1327 Longworth Buildivig Washington. rD. C. 20S15 Genticaens TVA-StGUOTAH NUCLEAR PLANT PROBLCMS.

subj ect:

Letter. Front D. Nicks to Representatives #

• References Dingel? and W. Udall and the Nuclear J.Regulatory Cosedssion. :"Concerns Regarding The 1985.:

TVA Nuclear Program.I' dated November 27, This letter transmits my ) concerns and coussents on the TVA-Sequoyah Nucleer < Plant problemi resolutions andilack thereof and the attaapt by TVA to rest, art Sequoyah without having'done an adequata and. thorough. Job in evaluating and The vast majority of.these concerne were fixingsprobleasa initially hight tad in the Reference and sube ently discussed with personnel on February 21.19 At the request of the staff of The Subcosmittee on oversight and Investisetions. :and pursuant to 'a forthcoming JamesiKeppler. Director of The NRC Office -

meeting with Wrd of special Projects.. and Mr. Sen Hayess Director of The NRC Office of Investigations.1 prepared an agenda of some of

. the major itemsithat, are being inadequately addressed or I en ignored or misrepresented by TVA et sequoyah.

enclosing a aumanery of itene discussed in that meeting onThe Enc Warch 23. 1987.

documents provided to Wre Keppler and used to illustrate the problems with current and past TVA plans.

There is a strong need far TVA to' truly establish Seqpoyah's baseline configuration to an acceptable configuration that meets NRC Regulations (not. TVA's limited "Regulation. as addressed in the definition of the.ters.

Enclosure) in order to assure adequate health and safety for

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Nhelun TVA-SEQUOYAHiPROBLEMS)

Pese 2 the Tannessee Val' ley residents.:

As included in the Enclosure, the documents indicate that a case can be made that TYA 's original design, construction, testing, and inspection vers grossly.different from comunitsents in the i

F3AA and from acceptable national standards and practices.

and the current TVA' plana are inadequate to resolve these TVA sisely did not implement its coanni'taants to problems.

the WRCa thus voiding the very ibases for TVA's operating license for Sequoyah.

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..u There is a large. gap existirig between how TVA built A

sequeyah and how -TVA countitted in the FSAR to cuiis 1t.

partial fix.ing (largeLy based on unacceptable and narrowly scoped sampling techniques with no analytical and/or logical bases) of only changes made to the plant configuration.

since the original license, will :not bridge this serious gap -

in work lef t undone and in problems not :being assessed and

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fixed.

TVA is currently attempting:to convince the NRC that TVA is establishing,e baselir.e configuration for Sequoyah.'

However, the Design Baseline and verification Program (DBYP)'

that TVA has implemented only looks at a small percentede of.

the total baselines Evenithe changes that, have been.jocked >

at in the. DBVP were not. thoroughly Cor at all) reviewed for technical edequacy.-

TVA has only rasched the tip of the Aceberg as f at as def.ining the der,ign bases and showing that the design bases have been met.

TVA has had and continues to have an inadequate Quality Assurance Program, i TVA' should not be perinitted 1.o operate any plant, including Sequoyah. until this serious situation and regulatory violation is resolved with an adequate and ef fective quality Assurance < Program in place.

In sumamary the.WRC should require TVA to perforia a l

complete (100 percent) verification program and go.through l

the licensing review. process again, covering each system in l

depth, in order.to again obtain an operating license for Sequoyah.

Additionally, a complete preoperational. testing program should be required to shake down the plant syatens at Sequoyah because they will have been idle for a long

. period aince they were.last operated.:

i Sincerely, kat&2.%.

i Dallas R. Hicks' Enclosures TYA-$fQUDYAH PROBLEMS '

cc Mr. James Keppler, Director NRC Of fice :of Speelal Proj ects g

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StMdARY OP 1TEus DISCUSSED WITH WR; JAMES rEPPt.ER DtAtING A=WifWG M MARCH 23. t987 TVA-5EQUOTAH WUCLEAR PLANT PROBLEMI

1. IMITIALiLicENS1HC RAREE'YOfD.

sequoyah Nuc0 ear : Plant was liconeed on the basis that TVA had adequate ' design (and construction practices and that TVA followed NRC requirements.

However, it has been found that thase assumptions were incorreetc and there are documented findings adverse to these:

assumptions.

TVA misrepresented the @elity of its work' and has in general.not fol'10wed requirements for the bases of the initial license.

Therefore, the original bases for a 11eense at se4aoyah oan be considered void.

TVA should not> be permitted to continue on the basis of its ongoing "band-aid" approach at sampling and Mxing portions of.the plant.

TYA thould the required to go through. a thorough. licensing review for Sequoyah similar to a new planti in order.that the. Tennessee Valley residents can be assured that every safety function of the plant.will. operate and thai, TVA has not just sampled areas where TVA personnel : decided necessary.

2. FSAR PROBLEMS,*

In particular,: there is a massive dif ference between the PSAR and the actual construction configuration.

Wuch of the original design bases :had no analytical or logical bases.

This further justifies the need for re-licensing efforts.

3. PROBLE*M FIXEt AT SEQUQYAM. POST-RESTART VERSUB PRE-REETART There are too many thingst in all areas that TVA is planning and promising to do af ter: restart.

Many of these must be fixed before restart due to their serious impacts.

TVA.has had a long history of promising the NRC that TVA will do.something in the future and TVA has not kept its promises.

With these endless unfulfilled promisee by TVA. the NRC must not grant permission to restart prior.to the f1xas..

Refer to Enclosed Item 22. Memo f rom R. W. Cantral1 to Those listed. "SEQUOYAH NUCLEAR PLANT - RESTART REQUIREMENT CRITERIA." dated December 23. 1986.

Ps SEQuoYAH PROBLEWS.

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4. WATTS RAR PROBLEM GENERIC APPLICABILITY _70_SEQUOYAH There must be an understanding of each Watts Bar Nuclear Plant concern and an adequate assessment of its applicability to Sequoyah lfuclear Plant prior to restart.

TVA pegaannel iclaim that they are concentrating on fixing eSequoyah and will do Watts Bar later.

1 hey have bid requests issued to potential contractors for the Watts Bar Recovery Program, t'o supply personnet Cbetween 900 and tooo)'for two and a half years.. Until 'TVA adequately assesses, understands, and addresses the probl6es at Watts Bar they are incapable of totally understanding the generic taglications of the same kinds of problems at Sequoyah.

S. APPENDIX X c

TVA has, had and still has >m generic problem with its implementation of an acceptable Appendix B Program.

Untti this iscu= is resolved. TVA cannot be permitted to operate. argr p1 ants.i including Ieqpoyah. i

6. QUALITT_ASSURA)tg A recent TVA Audit Deviation QW8-A-87-0004-D02, reflects much of the sesaa.QA attitude as has existed in the past at,TVA. '

Refer to Enclosed Item 8, ;"UPGRADING AUDIT DEVIATION

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QW8-A-87-004-DO2 To TTPE I. " and. "COMnE'NTS" on subj ect docunent.

7. CALCULAT!dNS

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TYA has only scratched the surface in assuring that calculations are adequat.e in all disciplines.

An acceptable calculational basis for. items in all disciplinestmust be in piece prior:to restart.

Refer to Enclosed Item S. Wemo. front W.

S. Raughley to Those listed. "POLICY WCMORANDW PW96-02R1 (EEE)

- REVISIDW i - ELECTRICAL :CALCIA.ATIONS. " dated February 4,.1987a Refer to Enclosed Item 9. Wemo froen C. A. Chandley to MECHANICAL Those listed. "POLICY WEWORANDW (WEB)

CALCUL AT7OWS - WPWA6-04. " dated JUNE 25. 1986: Weao from C.

A. Chandley to Those listed. "SEQuoTAH NUCLEAR PLANT

- REVIEW CP ESSEMTIAL MECHANICA1. CALCULATIONS FOR TECHNICAL ADEQUACY," dated December 17 19661 Memo from J. C. Key to C. A. Chandley. "SEQUDTAH NUC1. EAR PLANT (SQN) - DESIGN CALCULATION REVIEW." dated October 7..

1986) and individual TVA responses to C. A. Chandley concerning the mechanical calculations.

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P7 SEQuoYAH PROBLEMS.

[)(elup Paan 3 g, grCTRICAL C ALCtLATIONS,:

Meny of the electrical: calculations tre cossaitted by TVA >

to be coupleted after restart, but this should not be Mary assumptions were made relative to the permitted.f act that 5 argent and Lundy were to1d byiTu t. hat certain calculations were not done becaume the information was contained in design : standards or guides.

.However. since TVA personnel have had such a blatant attitude about dewngrading-etendarde, abusins the intent and not following them, the design,

of such documents, standards and guides could not be relied on toFurther, the.

substitute for. calculations in many ? areas.

results.of coloulations have,not been of feci,1vely integrated into design ard construction documents and -. T

criteria, misuse of calculations has.not been evaluated for the -

degrees of problem areas that exist and the magnitude of Thts should be. comp 1eted and all uperading required.

fixes made prior to restart.

Refer to Eno30 sad Item 3. Wemo from If. S. Raughley to

"*0LICY' WDORAWDtM PM86-02Ri' CEES)

Those listad.

- REVISION l' - EL,ECTRICAL CALCLA.ATIONS, " dated i 4 February 4, 1987,'

9. WECHANICAL CALCULATION 11 TVA is not taking responsibility for vender calculations i

and is not independently reviewing and verifying them.

The reviews by mechanical ' personnel are.only paper reviews, not technical reviews and ere not independent reviews for adequacy in order to scope the problems and An independent review, similer to identify.the fia a.

to that,done by Sargent and Lundy for electrical-

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calculations, should be done for the mechanical Many of these calculations are missing calculations, All and many are committed to be done after restart.

i should be independent 3y. Yeviewed ior adequecy and fixed +

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or done initially (since it appears that many were never prior to restart.

done or done prcperly and recorded)

Since TVA personnel have had such a blat' ant attitude about downgrading standards, abusing their intent. and not following them the design standards and guides could not be re!!ed on to eubstitute for calculations Further, the results of where such is being done. -

calculations have not been ef fectively integrated into The design and construction documents and criteria.

inef fective integration of and misuse of nubj ect of calculations has not been evaluated for the' degrees of problem areas that, exist and the magnitude of upgrading Thie work should be completed arxi all fixes required.

made prior to restart.-

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Ps C/U Pnge 4 SEQUOYAH PROBLEWS There is no evidence of TTA 's assessing and including e

sechanical calculatierts : for non-safety-related systems that could impect sataty: syatems and/or important to safety items that could impect safety systems and/or in ;their plane for either before or plant reliability,calewissions for control room f titertna etter restart, (NEPA or other) were not found.to be included in TTA *s list of calculations. :

' Refer to EncNeed ItN 9'. Sieno boa C.,A. Chaibleh to

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I those listed, "POLICY:NDthi (MEB) - 1stCHANICAL CALCULATION $i-W'M86-04,?' dated JUNE 25.: 19965 Weso from A. Chandley ato These listeo, "SEQUOTAM NUCLEAR PLANT C.

- REVIEW CF ESSENTIAL nECHANICAL CALCULATIONS FOR 1986 Nemo from -

TECHNICAL ADEQUAC7," dated December.17, Key to C. A. Chandley, **SEQUOTAM NUCLEAR PLANT J. C.

- DESIGWiCALCULAT30N RETIEW. " dated Octaber.7, CSQN) and individual TVA resportses to C. A. Chandley 1986; concerning theimechanical calculatione.

10 ELECTRICAL ANDam'MAMICAL LOAD #CALCtLATIONE TVA 's current and past act:fons.have, not :sf factively addressed and solved these serious problems.

$c ktions and (1xes are required prior to restarta TVA has not adequately established the calculated and actual bases for each load and has. not established a systeatvith traceability of requirements.

Ref er to D. Nicks ' : letter.to NRC on Concerns Regarding

'the TVA Wuclear Program. dated November.27. 1905, and:

above calculations.-

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11 NARGINE - IN CAPACITT POR DIEEEL ~ GENERATOR 5 AND BATTERY MSTrue.

I TVA 's current and past actions have not effectively l

eddressed and solved these serious problems.- TVA must couplete Items 8, 9, and to obove and integrate actual i

data froen vendor information and from vendor and TVA testing to establish a controlled and traceable load Until list, clearly.identifyitig:aargins that exist.

this is done and TTA corrects deficiencies in these areas and justifies to the NRC. that adequate capacity margins de exist in the, diesel seneratoes and battery systems. TYA must not be permitted to operate Sequoyah.

Ref er to D.. Hicks ' istter to NRC on Concerns Regarding The TVA Nuclear Program dated November 27, 1985, and above calculations.

Refer to Enclosed Item 11. "Reportable Event Number 05098,"

concerning inadequate diesei generator capacity for sequoyah due to "DESIGN DEFICIENCT'," dated June 17, 1996.

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P9 hdMk Page S SEQUQYAH PROBLEWS DESIGN BARE 1.1W3 AND M IF EATfoN PROGRAW 12 j

This program only assesses the adequacy of past modification work.. Oneicannot establish the plant configuration, as claimed.ty TVA, by only assessing the unknown and original modifications and by ignoring &iens.

base configuration and its pe Ref er to Enclosed Item 12.' Emmerpt from "TVAs Nuclear

' Performance plane Vo l'. !!/ Section !!!."

This program does not ansees the technical adequacy of the plant systems,.but is : depending on the calculation reviews,for assurance of adequacy.

This is a gross Eallacy: since those reviews are in:many areas only a not.. reviews of the technical content of review of papef, the calculptions.(examples mechanicai calculatiens).

13. DESIGN CRITERIA.

TVA has been in a mode of evolusians against lesser criteria than : standard acceptable criteria and issser then.some.of their original: criteria., Has the NRC approved less : stringent regairements?

If so, whpt 1

14. INDEPENDENT JUcLEAR SAFETT RETIEW t TVA claims that the current tWuelear Safety Review Board >

(NSRS)! replaces :the functions of the abolished Muclear -

Safety iteview istaf f and that the NSRB chairman has Enclosed is a news article exce33ent credentists.

quoting his philosophy and feelings. as follows:-

- TVA 's nuctsar ' plani,a t"are: really very nice plants. "

"As a matter of fact.: Sequoyah probably is cursed by j

being too nice a plant.1 It is so well built that that people have tendedito become a little complacent, this is such a nice plant that it is not going to get into.any trouble."

- Watts Bare Nuclear Plents, southwest of Knoxville, does have "specific, isolated" problems in some areas such J

as welding,.he said.. "Sometof those need to be fixed.

watts Bar is an extremely stout plant. very well designed and in virtually every instance. very well From a simple. direct safety point of view. I builb wouldn't have any petticular qualms about, atatting that. plant up.today and running it,a he said.

CONCLUSION ON THIS ATTITUDE:

How can the current chairman of the.NSRB, W. Hannurai with the above attitude, be of use to TVA?

How could he give the

• citizens of the Valley any good feeling that problems

fIO SEQUQYAH PROBLEWS ge/uS Page 6

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would be viewed realistically and fixed?

Is he totally out of touch with reality when there is overwhetains evidence in.the hands of inveet.igators and the NRc to refute his beliefs? The problems associated with these plants are widespread.

Ref er to Enclosed item 14.4 The Knoxville News-Sentinel article, by Laura flamens. dated March 9.

1997.-

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15. 'NTACE PhtCaLM - ~

TVA has, not adequately handled impacts of voltage degradation on utilissation buses.and the probless caused by unacceptable fisma.

Refer to D.: Hicks ' letter #to NRC' on Concerns Regarding

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The TVA Wuclear Progress. dated November 27 1996.' and

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above coloulationsa Refer to Enclosed Item 15. MRC' Branch Technical Position P55-1 and:TV A WCR BLNEEBSSOS.

16. CABLING PRoaLWC:

All cable. calculations and installations need to be verified to be acceptable in areasisuch as especity, insulation types. reneway fills, derai,ing, sidewall pressures, etc.

Sampling should not be permitted.

Every single cable. should.be verified and done prior to restart.

TVAthas only scratched the surface in assessing and.fixingithese problems and it appears that TVA learned. very little f rom the Browne Ferry fire.

17. TVA 's 5AWPLING PHILOSOPHY II TOTALLY tJNAccEPTAsLE Por any given type of task. more then one 3roup of people may have donet the work in dif f erent areas of the.

plant.

Soms erews were better than others.

A sampling in an area of.the plant may: cover only one crew's work and not the other crews ' work.

This and other reasons (such as varying degrees of QA/QC inspection competency, TVA's widespread harassment and intimidation and firing of QA/QC personnel, and the f act that TVA has claimed to be using statistical sampling but has neither subst,entiated the bases of statistical sampling nor have they used statistical analysts trained in these areas) are sufficient enouCh to disallow sampling of any itea for fixes.

Sample Looking and samp!e fixing are not acceptable to assure 1he public that a plant is safe.

18. INTERFACE CONTROL TVA has had shoddy and informal control of interf aces between plant systems and the current program has not 4

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ef fectively addressed this problem and has not fixed the problems that have resulted from this lack of control i

l for many years, This work must be done prior to restart.

19. ENVIRONt*4TAL QUALIFICATTrua,

TVA has not and cannot do Justice to fixing all problems that exist in thisiarea at Sequoyah.

Every single

• safety-related ites must be verified that it is adequate 1y qualifiWd and TVA' must not just do a l

Much of sampling., This must be'done prior to restart.

TVA 's of forts have.been. spent in fixins: paper and no1. in fixing hardware.. Why: is TVA not being reqpired to test the safority of items that have not been qualified? The limited testing that hos been done only scratches the

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surf ace, of the total' ecope of problems.

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20. PHTSICAL AFD ELECT 14ICAL SEPARATION OF REDUNDANT $YSTE AND CGFONLNTE Every system must be evaluated and' fixed to an acceptable 1evel regardless of any :"grandisthering",

allowed at the time of the original license since,.TV A 's gross negligence. and misrepresentation should have voided any "grandfathering";end paved the way for a total f.ealistic look :st wnst is acceptable.

TREATusNT OF FIRE Itaf5T AND_ FIRE PROTECTIQM 21 In conjunction with seperation, fire sones and fire protection should be reviewed totally for Sequoyah for an acceptable staplementation of today's requirements.

This should be completed prior to restart.

"Grandf athering" should be avoided. to marinaam extent possibte.

22. TVA 'I DEFINITI0W OF ftEGULATION TVA's definition and > manipulation of the definition of the word, "regulation. " to satisfy its needs and to Justify allowing many resolutions to serious problems af ter restart.are unacceptable and should be rejected by the Nftc.

TVA personnel. continue.k,o claim that they do not have to follow designieriteria.t Regulatory Guidesi TVA Engineering Guides: and Standards. national codes and and the PSAR. even though TVA t:ensmitted to do standards, so and did not seek nor get approval of alternatives'.

This attitude has been a major contributor to.TVA 's problems for many years and it can be seen clear.ly to exist currently..

Until this attitude and mode of operation is gone from TVA. TVA can never be expected to correct its massive prob'lems.

TVA'should never be 2

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Pix SEQUOYAH PROBLEWS

[j(fg p eg, a at1 owed to operate any nuclear unita unt11 this philosophy:is changeds Refer.to Enclosed Ites 32 Memo from R. W. Cantrell (attachment principe11y prepared T. A. Ippolitto).

"SEQUOTAH WUCLEAR PLANT - RESTART 111REhENT CRITERIA. "

dated December 23,1986.'

. Refer to Enclosed Item 22,: Wome f rom M. R. Harding to LP' W..Wobles and D'.' W.

• Wiison. "5EQUGT AM 'MUCLEAR PLANT

- 10 CFR 50.59!ETALUATIONS, " dated ' January 28, 1987.-

Refer to Enc.losed Ites 22.! TVA f 5 "GUIDELINES FOR POTENTIAL CPERABIL LTT ' DETDtWIWATION2. "

23. LACK OP' ACCEPTANCE CRITERIA POR "Nf"ALLATION AND '

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TESTING: OP EQUIpusMT AND OTHE t l'Titi

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Has TVA' assured that each teet was done property or redone to acceptable criteria?

Are there test records substantisting such? iThis.varification must be done prior to restart.and no sampling should 'be permitted.

24. Af15MIC CAletE-4 TIN s !

Seismic, hold-down forces for equipment and other items are not. addressed in any detail in electrical and meshanical calouIations.

There l's a major question:ss to whether these have been verified and calculated and/or recalculated to' acceptable criteria.

100:perce..t verification must be done prior to restart.

26. AR-CONsT9UCTED NJ'tpanyAytm There is conflicting information given in presentations and in written material as to TYA's intent on as-constructed versus as-engineered drawings.

This documentation should be completed prior to any restart and the control room / shift engineer / operators must have j

documentation that.is per the construction configuration and per, theiavailable drawinge stored in all plant and central office files.

TVA has f ailed to independently review and adequately challenge vender calculations and design drawings and TVA has f ailed to take responsibility for documents.

TVA must take this major responsibility vendor work.

regardless of whether TVA or a contractor does work.

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Yelui SEQUDYAH PRonLEMS'

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Page 9 26 1NVENTORY 4GnTROL'AND TW RW ER STORAGE How.have. these iseues been :eddressed? ' It appears that inade@ ate inventory control in the past and at present has.not and is not getting proper attention.

Further, it appears theti the serious impacts of mismanagement in these areas and the deleterious impacts on equipment and i

componenta resulting from improper storage and inventory

' control is not even being spddressed to either assess the extent of ' impacts or to fix at t problems resulting from a lack of adequate inventory control and proper storage environments.-

This mustr be dona prior to restart.-

27. C-SPEC 1 '

The impacta caused by deficient. and. misused TVA' G-SPECS

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has, not been,adewately addressed by TVAs current and past actions, Assessments and iixes are required prior to restarts Ref erito Enclosed Item 27 Wemo from G. W.'Killian to s

E. A. Wetrick. # AUDIT 'DEV1ATION Q3PAA-85-0006-Dio.

APPLICABILITT OF C-SPECS TO OPERATING PLANTS.'" dated March.13. 1987.'

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25. gWINTETRATITE/PERSOWWEL _PROgLWe!

Key. TVA ipositions are still filled with personnel who were involved in the forsone problems and some persons I

have been promoted within.the past year ef ter it was known that they have been involved in these activities.

HRC personnel have been. protecting status que and displaying incompetonce. in.tnderetandirig and/or believing problemstat TTA.!

EtANARY TTA has done and is doing a lot of work to fix Sequoyah problems, but.the scope of that wort is not :nearly suf ficient to ' address the major concerns revealed by detailed reviews of TVA's past and current practices.-

With such a large number of deficiencies (s'ech as melted and charred cable insulation, inadequate diesel generator power capability to shut.down the' plant sofely, and hundreds of other problems) existing at Sequoyah.while it was operating.

it was lucky it did not require some of the critical safety i

systems and components that. are so grossly dif f erent in configuration from that which TVA committed to design and construct.

Confirmations of shoddy engineering and construction practices, an ineffective quality assurance / quality control program, and TVA 's misrepresentations of the plant configuration to the NRC should be grounds to void sany initial licensing bases.

With

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peg,; go SEQUOTAM PROBLT.MS the itesse addressed hiprein and elsewhere, TVA should be and required to relicense, Sequoyah sistlar to a new plant.

the NRC should not. allow TVA' to restart the plant with only covenitmente to assess and fix problems af ter restart.

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SEquoYAH PROBLEMS NC[ Rad

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P/6 N L O 5t.R E ENCLOSED DoctasCNTS The enclosed documents are numbered with Item Numbers correspondArw to the Item Humbers in the preceding aussnary of TVA-Sequoyah Nuclear Plant Problems, NOTE: DOCUMENTS NOT RECEIVE 6 BY NRC O

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Knoxville, TN 37912 March 28, 1987 w( weo

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Hon. John D.

Dingell, Chairman Subcommittee on Oversight and Investigations Cbb C ' Iud 4 h

United States House of Representatives Room 2323 Rayburn HOB f ge, Washington, D. C.

20515 47/13 Hori. Morris K.

Udall, Chairman k

5"-

Committee on Interior and Insular Affairs United States House of Representatives 1327 Longworth Building Washington, D. C.

20515 Gent lemen:

Subj ect :

TVA-SEQUOYAH NUCLEAR PLANT PROBLEWS Re f erence :

Letter From D. Hicks to Representatives J. Dingell and W. Udall and the Nuclear Regulatory Commission, "Concerns Regarding The TVA Nuclear Program," dated November 27, 1985.

This letter transmits my concerns and comments on the TVA-Sequoyah Nuclear Plant problem resolutions and lack thereof and the attempt by TVA to restart Sequoyah without having done an adequate and thorough job in evaluating and fixing problems.

The vast majority of these concerns were initially highlighted in the Reference and subsequently discussed with NRC perronnel on February 21, 1986.

At the request of the staf f of The Subcommittee on i

1 Oversight and Investigations, and pursuant to a forthcoming meeting with Mr. James Keppler, Director of The NRC Office of Special Proj ects, and Mr. Ben Hayes, Director of The NRC Office of Investigations, I prepared an agenda of some of the major items that are being inadequately addressed or

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ignored or misrepresented by TVA at Sequoyah.

I am enclosing a summary of items discussed in that meeting on March 23, 1987.

The Enclosure to this letter also includes documents provided to Mr. Keppler and used to illustrate the problems with current and past TVA plans.

There is a strong need for TVA to truly establish Sequoyah's baseline configuration to en acceptable configuration that meets NRC Regulations (not TVA's limited definition of the term, "Regulation," as addressed in the Enc losure) in order to assure adequate health and safety for

TVA-SEQUOYAH PROBLEMS Page 2 the Tennessee Valley residents.

As included in the Enclosure, the documents indicate that a case can be made that TVA 's original design, construction, testing, and inspection were grossly dif f erent f rom commitments in the FSAR and from acceptable national standards and practices, and the current TVA plans are inadequate to resolve these problems.

TVA simply did not implement its cer.nitments to the NRC, thus voiding the very bases for TV A 's operating license for Sequoyah.

There is a large gap existing between how TVA built Sequoyah and how TVA committed in the FSAR to build it.

A partial fixing (largely based on unacceptable and narrowly scoped sampling techniques with no analytical and/or logical bases) of only changes made to the plant configuration, since the original license, will not bridge this serious gap in work lef t undone and in problems not being assessed and fixed.

TVA is currently attempting to convince the NRC that TVA is establishing a baseline configuration for Sequoyah.

However, the Design Baseline and Verification Program (DBVP) that TVA has implemented only looks at a small percentage of the total baseline.

Even the changes that have been looked at in the DBVP were not thoroughly (or at all) reviewed for technical adequacy.

TVA has only reached the tip of the iceberg as far as defining the design bases and showing that the design bases have been met.

TVA has had and continues to have an inadequate Quality Assurance Program.

TVA should not be permitted to operate any plant, including Sequoyah, until this serious situation and regulatory violation is resolved with an adequate and ef f ective Quality Assurance Program in place.

In summary, the NRC should require TVA to perform a complete (100 percent) verification program and go through the licensing review process again, covering each system in depth, in order to again obtain an operating license for Sequoyah.

Additionally, a complete preoperational testing program should be required to shake down the plant systems at Sequoyah because they will have been idle for a long period since they were last operated.

Sincerely, a6aw'f%A Dallas R. Hicks

Enclosure:

TVA-SEQUOYAH PROBLEMS cc:

Mr. Jame s Keppler. Director NRC Office of Special Projects

4 Enclosure

SUMMARY

OF ITEMS DISCUSSED WITH MR. JAMES KEPPLER DURING WEETING ON MARCH 23. 1987 TVA-SEQUOYAH NUCLEAR PLANT PROBLEWS 1.

INITIAL LICENSING BASES VOID v.g.. a.a -

Sequoyah Nuclear Plant was licensed on the basis that og g,..-

TVA had adequate design and construction practices and that TVA followed NRC requirements.

However, it has I

"'v g, g, g been found thatJhese as'sumptions were p orrect, and

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there are documented findings adverse to these ge/smirn assumptions.

TVA misrepresented the quality of its work and has in general not followed requirements for the bases of the initial license.

Therefore, the original bases for a license at Sequoyah can be considered void.

TVA should not be permitted to continue on the basis of its ongoing "band-aid" approach at sampling and fixing portions of the plant.

TVA should be required to gn through a thorough licensing review for Sequoyah similar to a new plant in order that the Tennessee Valley residents can be assured that every safety function of the plant will operate and that TVA has not just sampled areas where TVA personnel decided necessary.

2.

FSAR PROBLEWS In particular, there is a massive difference between the off 'g-A-oo61, FSAR and the actual construction configuration.

Much of gp/p%ucent the original design bases had no analytical or logical bases.

This furthar justifies the need for re-licensing efforts.

3. PROBLEM FIXES AT SEQUOYAH POST-RESTART VERSUS PRE-RESTART There are too many things in all areas that TVA is Many of Oge.gs-A-ec39 planning and promising to do af ter restart.

these must be fixed before restart due to their serious impacts.

TVA has had a long history of promising the "f &/DO AS A'O NRC that TVA will do something in the future and TVA has not kept its promises.

With these endless unfulfilled promises by TVA, the NRC must not grant permission to rentart prior to the fixes.

Refer to Enclosed Item 22, Memo from R.

W.

Cantrell to Those listed. "SEQUOYAH NUCLEAR PLANT - RESTART REQUIREMENT CRITERIA." dated December 23, 1986.

.SEQUOYAH PROBLEMS Page 2 4.

WATTS BAR PROBLEM GENERIC APPLICABILITY TO SEQUOYAH There must be an understanding of each Watts Bar Nuclear Plant concern and an adequate assessment of its applicability to Sequoyah Nuclear Plant prior to restart.

TVA personnel claim that they are c9 t7-A-004g concentrating on fixing Sequoyah and will do Watts Bar later.

They have bid requests issued to potential contractors for the Watts Bar Recovery Program, to yg/cono46Q supply personnel (between 900 and 1000) for two and a half years.

Until TVA adequately assesses, understands, and addresses the problems at Watts Bar, they are incapable of totally understanding the generic implications of the same kinds of problems at Sequoyah.

5.

APPENDIX B TVA has had and still has a generic problem with its implementation of an acceptable Appendix B Program.

osf-sk- "oK'l Until this issue is resolved. TVA cannot be permitted to Gb/QLRA4 operate any plants, including Sequoyah.

6.

QUALITY ASSURANCE A recent TVA Audit Deviation QWB-A-87-0004-D02, reflects oS9-,4.g ~of g much of the same QA attitude as has existed in the past T[GkAAT at TVA.

Refer to Enclosed Item 6.

"UPGRADING AUDIT DEVIATION QWB-A-87-004-D02 TO TYPE I, " and "COMMENTS" on subj ect document.

7.

C ALCUL ATIONS TVA has only scratched the surface in assuring that calculations are adequate in all disciplines.

An

,,p. 9 6 - A -oof 6 acceptable calculational basis for items in all disciplines must be in place prior to restart.

g Refer to Enclosed Item 8, Memo from W.

S.

Raughley to Thosm listed, "POLICY MEMORANDUM PM86-02Ri (EEB)

- REVISION 1 - ELECTRICAL CALCULATIONS, " dated February 4, 1987.

Refer to Enclosed Item 9.

Meco f rom C.

A. Chandley to Those listed, "POLICY MEMORANDUM (MEB) - MECHANICAL C ALCULATIONS - MPM86-04, " dated JUNE 25, 1986; Memo f rom C. A. Chandley to Those listed, "SEQUOYAH NUCLEAR PLANT

- REVIEW OF ESSENTIAL MECHANICAL CALCULATIONS FOR TECHNIC AL ADEQUACY, " dated December 17, 1986; Memo f rom J. C.

Key to C.

A. Chandley, "SEQUOYAH NUCLEAR PLANT (SQN) - DESIGN CALCULATION REVIEW, " dated October 7, 1986; and individual TVA responses to C.

A.

Chandley concerning the mechanical calculations.

SEQU;OYAH PROBLEMS Page 3 8.

ELECTRIC AL _C ALCUL ATIONS Wany of the electrical calculations are committed by TVA to be completed after restart, but this should not be Many assumptions were made relative to the o St-T - A -oo4o permitted.f act that Sargent and Lundy were told by TVA that 6

6VdooDWid certain calculations were not done because the information was contained in design standards or guides.

However, since TVA personnel have had such a blatant attitude about downgrading standards, abusing the intent of such documents, and not following them, the design standards and guides could not be relied on to substitute for calculations in many areas.

Further, the results of calculations have not been effectively integrated into design and construction documents and criteria.

The subj ect of inef fective integration of and misuse of calculations has not been evaluated for the degrees of problem areas that exist and the magnitude of upgrading required.

This should be completed and all fixes made prior to restart.

Refer to Enclosed Item 8. Wero from W.

S. Raughley to Those listed, "POLICY MEMORANDUM PM86-02R1 CEEB)

- REVISION 1 - ELECTRICAL CALCULATIONS. " dated February 4, 1987.

9.

MECHANICAL CALCULATIONS TVA is not taking responsibility for vendor calculations and is not independently reviewing and verif ying them.

The reviews by mechanical pe sonnel are only paper 4, 4 reviews, not technical reviews and are not independent reviews for adequacy in order to scope the problems and osf"Ig g m d to identify the fixes.

An independent review, simi?ar to that done by Sergent and Lundy for electrical calculations, should be done for the toechanical calculations.

Many of these calculations are missing and many are committed to be done af ter restart.

All should be independently reviewed for adequacy and fixed or done initially (since it appears that many were never done or done properly and recorded) prior to restart.

Since TVA personnel have had such a blatant attitude abetd-downgrading standards, abusing their intent, and not-foi-lowing them, the design standards and guides could not be relied on to substitute for calculations where such is being dons.

Further, the results of calculations have not been effectively integrated into design and construction documents and criteria.

The subject of inef fective integration of and misuse of calculations has not been evaluated for the degrees of problem areas that exist and the magnitude of upgrading required.

This work should be completed and all fixes made prior to restart.

SEQUOYAH PROBLEMS Page 4 There is no evidence of TVA 's assessing and including mechanical calculations, for non-safety-related systens that could impact safety systems and/or important to safety items that could impact saf ety systems and/or plant reliability, in their plans for either before or after restart.

Calculations for control room filtering (HEPA or other) were not found to be included in TVA 's list of calculations.

Refer to Enclosed Item 9.

Wemo f rom C.

A.

Chandley to Those listed, "POLICY MEMORANDUM (MEB) - MECHANICAL CALCULATIONS - MPM86-04, " dated JUNE 25, 1986; Memo f rom C.

A.

Chandley to Those listed, "SEQUOYAH NUCLEAR PLANT

- REVIEW OF ESSENTI AL MECHANICAL CALCULATIONS FOR TECHNICAL ADEQUACY," dated December 17, 1986; Memo from J.

C.

Key to C.

A.

Chand l ey, "SEQUOYAH NUCLEAR PLANT (SQN) - DESIGN C ALCULATION REVIEW, " dated October 7, 1986; and individual TVA responses to C.

A.

Chandley concerning the mechanical calculations.

10. ELECTRICAL AND MECHANICAL LOAD C ALCULATIONS TVA 's current and past actions have not ef f ectively o s f-S L -A ~C C40 addressed and solved these serious problems.

Solutions A D/GodbWis) and fixes are required prior to restart.

TVA has not adequately established the calculated and actual bases for each load and has not established a system with traceability of requirements.

Refer to D. Hicks ' letter to NRC on Concerns Regarding The TVA Nuclear Drogram, dated November 27, 1985, and above calculations.

11 MARGINS IN CAPACITY FOR DIESEL GENERATORS AND BATTERY SYSTEMS TVA 's current and past actions have not ef fectively addressed and solved these serious problems.

TVA must 9.

and 10 above and integrate actual

)

o 8F' 'g,4_ oo7j~ compl e t e I t e ms 8, data from vendor information and from vendor and TVA testing to establish a controlled and traceable load 6ece list, clearly identifying margins that exist.

Until this is done and TVA corrects deficiencies in these areas and justifies to the NRC that adequate capacity cargins do exist in the diesel generators and battery j

systems, TVA must not be permitted to operate Sequoyah.

Refer to D. Hicks ' letter to NRC on Concerns Regarding The TVA Nuclear Program, dated November 27, 1985, and above calculations.

Ref er to Enclosed Item 11. "Reportable Event Number 05098."

concerning inadequate diesel generator capacity for Sequoyah due to "DESIGN DEFICIENCY, " dated June 17, 1986.

i i

SEQUOYAH PROBLEMS Page 5

12. DESIGN BASELINE AND VERIFICATION PROGRAM This program only assesses the adequacy of past modification work.

One cannot establish the plant configuration, as clained by TVA, by only assessing modifications and by ignoring the unknown and original base configuration and its problems.

e f-S - A'C4Ykef er to Enclosed Item 12, Excerpt f rom "TVA 's Nuclear s

L Performance Plan, Vol. II,Section III."

,g/gooows0 This program does not assess the technical adequacy of the plant systems, but is depending on the calculation reviews for assurance of adequacy.

This is a gross f allacy since those reviews are in many areas only a review of paper, not reviews of the technical content of the calculations (example:

mechanical calculations).

13. PESIGN CRITERIA g4p-8b'A'00YlTVA has been in a mode of evaluating against lesser criteria than standard acceptable criteria end lesser 80/Lo m6 A A>p than some of their original criteria.

Has the NRC approved less stringent requirements?

If so, why?

14. INDEPENDENT NUCLEAR SAFCTY REVIEW TVA claims that the current Nuclear Safety Review Board (NSRB) replaces the functions of the abolished Nuclear Safety Review Staff and that the NSRB chairman has excellent credentials.

Enclosed is a news article

,p. (6 - A -oo0b quoting his philosophy and f eelings, as follows:

E

• C4 TVA 's nuclear plants "are really very nice plants. "

osP g _ A-od7 b g

"As a matter of fact, Sequoyah probably is cursed by scA being too nice a plant.

It is so well built that a

people have tended to becore a little complacent, that this is such a nice plant that it is not going to get into any trouble."

Watts Bar Nuclear Plant, southwest of Knoxville, does have "specific, isolated" probleem in some areas such as welding, he said.

"Some of those need to be fixed.

Watts Bar is an extremely stout plant, very well designed and in virtually every instanct. very well i

built.

From a simple, direct safety point of view. I wouldn't have any particular qualms about starting that plant up today and running it," he said.

i CONCLUSION ON THIS ATTITUDE:

How can the current chairman of the NSRB, W.

Hannum, with the above j

attitude, be of use to TVA?

How could he give the citizens of the Valley any good feel'ng that probleem l

SEQUOYAH PROBLEMS Pcgs 6 would be viewed realistically and fixed?

Is he totally out of touch with reality when there is overwhelming evidence in the nands of investigators and the NRC to refute his beliefs?

The problems associated with these plants are widespread.

Refer to Enclosed Item 14. The Knoxville News-Sentinel article, by Laura Simmons, dated Warch 9, 1987.

15. LOLTAGE PROB 4,EWS TVA has not edequately handled impacts of voltage degradation on utilization busac and the problems caused gp,$ - A-cM2 by unaccep 401e fixes.

GD//AW'#I Refer to D. Hicks ' letter to NRC on Cor.cerns Regarding The TVA Nuclear Program, dated Ncvember 27, 1985, and above calculations.

Refer to Enclosed Item 15. NRC Branch Technical Position PSB-1 and TVA NCR BLNEEB0505.

16. CABLING __PROBLEWS All cable calculations and installations need to be esf-Cb-A-**"1 verified to be acceptable in areas such as ampacity, go/raucer:W insulation types, raceway fills, derating, sidewall pressures, etc.

Samp)ing should not be permitted.

Every single cable should be verified asGdorm prior to restart.

TVA has only scratched the surfaca in assensing and fixing these probleem and it appesrs that TVA learned very lit tle from the Browns Ferry fire.

17. TVA*S SAMPLING PPiLOSOPHY IS TOTALLY UNACCEPTABLE For any given type of task, more than one group of esf-17 4ddEjpoople may have done the work in dif ferent areas of the

' plant.

Some crews were better than others.

A sampling in er area cf the plant may cover only one crew's work E!g,,79 and not the other crews ' work.

This and other reasons (such as varying degrees of OA/QC inspection competency, TVA 's widespread harassment and intimidation and firing of QA/QC personnel, and the f act that TVA has claimed to be using statistical sampling but has neither substantiated the bases of statistical sampling nor have they used statistical analysts trained in these areas) i are sufficient enough to disallow sampling of any item for fixes.

Sample looking and sample fixing are not acceptsble to assure the public that a plant is safe.

10. INTERFACE CONTROL TVA has had shoddy and inforn.al control of interfaces between plant systems and the current program nas not l

l 1

SEQUQYAH PROBLEMS Page 7 effectively addressed this problem and has not fixed the problers that have resulted f rom this lack of control for many years.

This work must be done prior to restart.

19. ENyIRONMENTAL QUALIFICATION TVA has not and cannot do justice to fixing all problems that exist in this area at Sequoyah.

Every single est-t -4 007gsafety-related item must be verified that it is 6

Ib/dbasA4D adequately qualified and TVA must not just do a sampling.

This must be done prior to restart.

Wuch of TVA 's ef forts have been spent in fixing paper and not in fixing hardware.

Why is TVA not being required to test the majority of items that have not been qualified? The limited testing that has been done only scratches the surface of the total scope of problers.

20. PHYSICAL AND ELECTRICAL _ SEPARATION OF REDUNDANT SYSTEMS AND COMPONENTS csf - t b CO' E Every system must be evaluated and fixed to an acceptable level regardless of any "grandfathering" 8gppm allowed at the time of the original license since TV A 's gross negligence and misrepresentation should have voided any "grandfathering" and paved the way for a

'otal realistic look at what is acceptable.

21. TREATMENT OF FIRE _ ZONES _AND FIRE PRCTECTION i

4 In conj unction with separation, fire zones and fire of f-Tb '00I4 protection should be tr. viewed totally for Sequoyah for an acceptable implementation of today 's requirements.

I,c g, This should be completed prior to restart.

"Grandf athering" should be avoided to maximum extent possible.

22. TVA 'S DEFINITION OF REGULATION TVA 's definition and manipulation of the definition of the word. "regulation," to satisfy its needs and to o P-gg-A-oobo justify allowing many resolutions to serious problems s

af ter restart are unacceptable and should be rej ected by ggan.AAY the NRC.

TVA personnel 'ontinue to claim that they do not have to follow desigr. ;riteria, Regulatory Guides. TVA Engineerir.g Guides and Standards, national codes and standards, and the FSAR, even though TVA committed to do so and did not seek nor get approval of alternatives.

This attitude has been a major contributor to TVA 's problems for many years and it can be seen clearly to exint currently.

Until this attitude and mode of operttion is gone from TVA. TVA can never be expected to correct its massive problems.

TVA should never be

__.___m_,_

StGUOYAH PROBLEMS Page 8 j

allowed to operate any nuclear units until this philosophy is changed.

Refer to Enclosed Item 22. Wemo from R.

W. Cantrell (attachment principally prepared by T.

A.

Ippolitto),

"SEQUOYAH NUCLEAR PL ANT - RESTART REQUIREMENT CRITERI A. "

dated December 23, 1986.

Refer to Enclosed Item 22. Wemo from W. R.

Harding to L. W. Nobles and D.

W.

Wilson, "SEQUOYAH NUCLEAR PLANT

- 10 CFR 50l59 EVALUATIONS." dated January 28, 1987.

Refer to Enclosed Item 22. TVA 'S "GUIDELINES FOR POTENTIAL OPERABILITY DETERWINATIONS."

23. LACK OF ACCEPTANCE CRITERIA FOR INSTALLATION AND TESTING OF EQUIPMENT AND OTHER ITEMS orf-Pk-A-00Yhas TVA assured that each test was done properly or go/rA ke n?

redone to acceptable criteria?

Arc there test records substantiating such? This verification must be done prior to restart and no sampling should be permitted.

24. SEISWIC cal.CUL ATIONS Cdf. rG-A ooop Seismic hold-down forces for equipment and other items are not addressed in any detail in electrical and to/cM4 toechanical calculations.

There is a major question as to whether these have been verified and calculated and/or recalculated to acceptable criteria.

100 percent verification must be done prior to restart.

25. AS-CONSTRUCTED _ DOCUMENTATION There is conflicting information given in presentations and in written material as to TVA 's intent on as-constructed versus as-engineered drawings.

This documentation should be completed prior to any restart osp.gg-A-o063and the control room /shif t engineer / operators must have documentation that is per the construction configuration do/Pir2sd and per the available drawings stored in all plant and central office files.

TVA has fail;d to independently review and adequately challenge vendor calculations and design drawings and documents.

TVA has f ailed to take responsibility for vendor work.

TVA must take this major responsibility regardless of whether TVA or a contractor does work.

SEQUOYAH PROBLEMS Page 9

26. INVENTORY CONTROL AND IMPROPER STORAGE How have these issues been addressed?

It appears that inadequate inventory control in the past and at present has not and is not getting proper attention.

Further, j

oSf-Sb-4 -cc56 it appears that the serious impacts of mismanagement in 1

these areas and the deleterious impacts on equipment and Esc 4 components resulting f rom improper storage and inventory control is not even being addressed to either assess the extent of impacts or to fix all problems resulting f rom a lack of adequate inventory control and proper storage e nvironment s.

This must be done prior to restart.

l

27. G-SPECS The impacts caused by deficient and misused TVA G-SPECS has not been adequately addressed by TVA 's current and past actions.

Assessments and fixes are required prior SD to restart.

Refer to Enclosed Item 27 Meno f rom G.

W.

Killian to E.

A. Werrick, "AUDIT DEVI ATION QBF-A-85-0008-Dio.

APPLICABILITY OF G-SPECS TO OPERATING PLANTS." dated March 13, 1987.

28. ADMINISTRATIVE / PERSONNEL PROBLEMS Key TVA positions are still filled with personnel who were involved in the forgone problens and some persons o sf - 16 4 - coo l have been promoted within the past year after it was

,p _,g. 4 - oo o2 known that they have been involved in these activities.

1. D/'*" "^

NRC personnel have been protecting status quo and displaying incompetence in understanding and/or believing problems at TVA.

SUMMARY

TVA has done and is doing a lot of work to fix Sequoyah problems, but the scope of that work is not nearly suf ficient to address the major concerns revealed by detailed reviews of TVA 's past and current practices.

With such a large number of deficiencies (such as melted and charred cable insulation, inadequate diesel generator power capability to shut down the plant safely, and hundreds of other problems) existing at Sequoyah while it was operating, it was lucky it did not require some of the critical safety systems and components that are so grossly dif ferent in configuration f rom that which TVA committed to design and J

construct.

Confirmations of shoddy engineering and construction practices, an ineffective quality assurance / quality control program, and TVA's misrepresentations of the plant configuration to the NRC should be grounds to void any initial licensing bases.

With 1

1

SEQUOYAH PROBLEMS Page 10 1

the items addressed herein and elsewhere TVA should be required to relicense Sequoyah similar to a new plant, and 1

the NRC should not allow TVA to restart the plant with only i

conunitments to assess and fix problems af ter restart.

i i

i 1

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SEQUO,YAH PROBLEMS Page 11 ENCLOSURE ENCLOSED DOCUMENTS The enclosed documents are nurrbered with Item Numbers corresponding to the Item Numbers in the preceding summary of TVA-Sequoyah Nuclear Plant Problems.

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$h(%3n}LG July 21, 1987

/ 3-To Harold Denton From Henry Myersyg RE: NRC ACTIONS CONCERNING RE3 TART OF SEQUOYAH The following questions pertaining to the NRC's review of Sequoyah have emerged from our inquiry into NRC's regulation of TVA's nuclear program.

1.

On March 28, 1987 Mr. Dallas Hicks sent to Chairmen Udall and g/f Dingell a letter enumerating 28 items pertaining to Sequoyah.

On April 9, the Chairmen transmitted Mr. Hicks' letter to the WM Commission requesting the Commission's position with respect to the items in Mr. Hicks' letter.

To which of the 28 items enumerated in Mr. Hicks' March 28 letter to Chairmen Udall and Dingell will there be a substantive response prior to Sequoyah restart?

2.

Which of the issues enumerated in Commissioner Anselstine's March 18, 1987 memo to Mr. Stello does the NRC staff consider bb sdequately addressed by TVA in it; June 10, 1987 response to the NRC?

With respect to each such issue, what is the nature of analysis, inspection, and/or hardware modification that will be required prior-to rontart of Sequoyah 27 3.

TVA has underway an upgrading of design criteria, standards, specifications, G-Specs, procedures, and other documents that govern plant operations, maintenance and modification.

Certain 62 plant modifications will result from this upgrading of such criteria, etc.

To what extent does the NRC intend to develop a comprehensive check list of items required for completion prior to restart?

4.

Following the "vertical slice" independent review of the

/

Sequoyah ERCW System, what criteria will the NRC use in gf determining which problems, identified as a result of thic

. review, shall be corrected prior to Sequoyah restart?

What

(. g.y' criteria will the NRC apply in determining whether the results of

(<

the ERCW review indicate the necessity of additional reviews prior to Sequoyah restart?

5.

h*hich of the items designated by TVA as conditions Adverse to yh Quality (CAQs) will be required to be resolved through inspections and/or hardware modifications prior to restart of Sequoyah?

6.

P.as NRC evaluated the adequacy of TVA's program for addressing employee concerns?

What is the result of that gng evaluation?

What criteria will the NRC apply in determining whether, prior to Sequoyah restart, TVA will be required to rosolve specific employee concerns?

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7.

Prior to Sequoyah restart, what will the NRC require with respect to a determination of the applicability to Sequoyah of do!.iciencies identified at Watts Bar through the Black & Veatch rsview, NSRS reviews, INPO and NRC inspections, and the employee concerna program?

What criteria will the NRC apply in dotermining whether items, identified at Watts Bar and having generic applicability at Sequoyah, will need to be resolved prior to Sequoyah restart through design modifications, inspections, and/or hardware modifications?

8.

Prior to Sequoyah restart, will the NRC require that TVA 77Q cortify that Sequoyah complies with licensing commitments and all applicable Commission requirements?

9.

Given the history of TVA failing to comply with the requirements of 10CFR50, what actions will the NRC take prior to g])

Sequoyah restart in order to determine that adherence to Appendix D has been achieved at Sequoyah and within other TVA organisations upon which the safe operation of Sequoyah depends?

10.

What will the NRC require with respect to recalculations and/or review of calculations for safety-related itams, associated class IE items, and nonsafety-related items that could

$O impact safety-related items?

What criteria will the NRC apply with respect to determining what plant modifications will be required as a result of recalculations and/or review of eticulations?

11.

To what extent will the NRC review the acceptability of r

TVA's revisod diesel generator load sequencing calculations and iDd operating modes to assure suf ficient diesel generator syatem q4b capscity margin to shut down the plant during a plant emergency?

To whct extent will the NRC review the acceptability of TVA's battery systems to assuro sufficient battery system capacity ma: Tin to shut down the plant during a plant emergency?

12.

To what extent does the NRC intend to verify that problems idonti!ted by the DBVP have solutions and that necessary bE coC1Sications have been made prior to Soquoyah restart?

Which of the programs, enumerated in the NRC handout (attached hereto) at the July 8, 1987 NRC/TVA meeting in Chatanooga, will be required by NRC to be ccepleted prior to Sequoyah restart?

What does the 'NRC plan to require from TVA to assure that 13.

the new design change control system is in place and working 30 proporly?

Is the NRC aware of the number of design changes and fiald changes that were made during the period ranging from mid-1936 through mid-1987 on the basis of waivers and/or variances frca the new design changn control program?

Will the NRC require prior to Sequoyah restart that TVA (A) verify that these changes arq consistent with the plant baseline configuration, (B assure impacts resulting from these reviews are assesse)d, that all and (C) ascure that any resulting plant modifications are completed?

14.

Dose the NRC plan to require TVA to complete ongoing assessments and corrective actions concerning cables prior to

$D Sequoy Ah restart?

15.

What NBC actions are underway for the purpose of resolving

[ D questions concerning what constitutes acceptable sampling techniques?

What is the nature of outstanding questions regarding the adequacy of TVA's sampling practices?

When will any such questions be resolved?

16.

Will the NRC require that testing of Sequoyah systems and components, undertaken between shutdown and restart, be conducted 6>h in accord with standards, guides, test procedures, etc. that will be in offect at tiO time of restart?

17.

What is the impact upon the Sequoyah restart schedule of the deficient conditions described in TVA's report, "A

REVIEW OF CAQ I

PROGRAM IMPLEMENTATION AT SEQUOYAH NUCLEAR PLANT 7" This report concluded:

The corrective action program is not being adequately implemented at SQN and could not withstand an NRC inspection.

Unless expeditious corrective action is taken, the unit 2 startup schedule may be affected.

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[ wD August 13, 1985 To Bill Dircks, Carl Karmerer From Henry Myers Re: TVA

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I am enclosing herewith a series of memoranda I have sent NRC staff on June 3, June 10, June 24 and July 1 concerning the Black

& Veatch (B&V) review of Watts Bar.

These memoranda convey a sense of the issues not resolved by B&V and TVA's response

thereto, y g I want also to urge that the report of the ongoing NRC staff review of TVA's welding program include a full listing of documents that were analyzed in the course of this review including TVA audit reports, TVA nonconformance reports, 50.55e reports pertaining to TVA welding and/or weld program deficiencies, NRC inspection reports containing welding related items, Ruclear Safety Review Staff reports pertaining to TVA veld programs, reports based en welding-related allegations made to the Quality Technology company'(QTC), and miscellaneous documents l

related to welding.

Without such a document listing it will be impossible to assess the validity of the staff's findings.

I would appreciate your providing me all reports made by staff to 3

the Commission and/or EDo with respect to the following:

-NRC staff review of TVA HSRS reports on cable installation and procurement.

,, NRC staff's monitoring of the weekly logs produced by j

QTC and reports resulting from inquiries into allegations made to QTC.

-50.55e reports resulting from the QTC activity. (For example, how many such reports have resulted from the QTC effort?)

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our ongoing inquiry raises the following questions:

-Does there ekist a process that assures that the commission and the Directors of NRR and I&E and their principal deputies receive accurate and comprehensive information concerning the TVA situation?

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-What plans exist to determine which TVA personnel have been

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subject of discriminatory personnel actions as a consequence of advocacy of compliance with NRC regulations?

What actions are planned to insure that persons subject'to such discriminatory hf action will receive appropriate compensation e.g. promotion to grade levels which would have been achieved had the discrimination not occurred; award of compensatory damages, etc?

EDO - - 000919

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