ML20149F427
| ML20149F427 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 01/11/1988 |
| From: | Bradburne J NRC OFFICE OF GOVERNMENTAL & PUBLIC AFFAIRS (GPA) |
| To: | Ebneter S NRC OFFICE OF SPECIAL PROJECTS |
| References | |
| NUDOCS 8801140241 | |
| Download: ML20149F427 (3) | |
See also: IR 05000327/1987031
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- 9[o, UNITED STATES )
! ,cc i NUCLEAR REGULATORY COMMISSION
aAssiNoroN.o c 2osss
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January 11, 1988
MEMORANDUM FOR:
Stewart Ebneter, Director
Office of Special Projects t
Fr.0M
John C. Bradburne, Director
Office of Governmental and
Public Affairs
SUBJECT: CONGRESSIONAL STAFF COMMENTS ON SEQUOYAH
INSPECTION REPORT 50-327/87-31 AND 50-328/87-31
The majority staff of the House Interior Comittee has reviewed the
subject inspection report and provided coments to Congressional Affairs.
In general, congressional staff is concerned that the inspection report is
Specific
confusing and has requested that a number of areas be clarified.
staff coments are attached. We request your review of the cements.
Please provide your recomendations on the appropriate response to the
Congressional concerns by January 19, 1988.
CONTACT: Frederick Combs x-41443
Attachments: 50-327/87-31
(1) CR. HENRY MYERS COMMENTS ON INSPECTION REPORT
and 50-328/87-31
(2)InspectionReportNos. 50-327/87-31 and 50-328/87-31
cc: Chairman Zech
GPA (Denton)
EDO (Taylor)
O!
OIA
8801140241 880111
PDR ADOCK 05000327
G PDR
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DR. HENRY MYERS' COMMENTS ON INSPECTION REPORT
50-327/87-31 and 50-328/87-31
The following coments on the subject inspection report on the TVA's i
Design Baseline and Verification Program (OBVP) for the Sequoyah Nuclear l
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Power Plant were provided by Dr. Henry Myers of the House Interior
Comittee Staff to Congressional Affairs. The coments are keyed to the
indicated sections of the report and its cover letter.
As a general coment, congressional staff feels the report declares that
problems are resolved without supporting that declaration. Also, the ;
report does not spell out things like DVBP. i
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(1) The two underlined qualifications are not spelled out or defined.
(2) Does this sentence say that the NRC approves the report?
(3) Was the purpose of the inspection achieved? (See page 1 of report,
the first two sentences under 2. PURPOSE.)
(4) (a) See duplicate paragraphs on pages 3 and 4. Is the page 4 paragraph out
of order?
(b) All of the sumary is out of order.
(c) Is the paragraph at the top of page 4 talking about all or part of
Sequoyah? In essence, are all paragraphs talking about all of
Sequoyah or just the particular subject covered?
(d) Does "closed" mean satisfactorily handled?
(e) (page 5) *** Does this mean no deficiencies at all?
(5) Does this mean they are fixed?
(6) (page 2) Does this mean "operations of the plant" or "operations of the
OBVP7"
(7) (aage 6) This is a major item.
(8) (page 7) Problem
(9) (page 8) What is a "non-administrative change?"
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(10) (page 8) You do not "implement" punch list items. You address the
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problems on the punch list and then solve the problems pointed out by the
punch list. Henry believes that the report could be saying that the
problems were addressed but not solved.
(11) (page 12) 357 action items and no way to determline if the deficiency
is really fixed. The inspection report does not indicate if things are being
fixed.
(12) Ask Harold what he thinks of the problems on page 12. 13, 14 and 15
(not all in detail). OBVP did not find them but the EA found them. No
indication that problems are being resolved.
(13) (page 15) What is "the project" and is it acceptable to do calculations
after restart?
(14) (page 16) What are these documents? A one or two line description on
each one would be helpful.
(15) (page 17) Does this mean that EA only reviewed three punch list items?
(16) General (pages 16 and 17) There is a lack of seismic calculations to
confirm assumptions.
(17) (page 17 and 18) Section 4.3.4 is confusing.
(18) (page 25) What problems were reviewed? What did TVA do to resolve
them?
(19) (page 25) This item needs a look.
(20) (page 29) Calculation 870223 was the basis for cancelling the
Is this an
variance. Does 86118 mean it was done before 870223?
error-should 86118 be 8601187
Are
(21) (page 31) The punch list review shows that errors were found.
the discrepancies the result of falsifications? Who will confirm a fix
here?
(22) (page 31) There is no substantiation of the claims in the last
sentence.
(23) (page 31) "As built" verification did not appear in the 10! report on
ERC.
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- ,, UNITtD STATES ,
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% NUCLEAR REGULATORY COMMISSION {
! * esmofoN.0 C 2988e t
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. 1987
DEC 3
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Cocket Nos. 50-327
and 50-328 l
Tennessee Valley Authority
ATTH: Mr. 5. A. White
Manager of Nuclear Power
6N 38A Lookout Place
1101 Market Street
Chattanooga, TN 37402-2801
Gentlemen:
SUBJECT: INSPECTION REPORT NOS. 50-327/87-31 AND 50-328/97-31
This letter forwards the results of a special inspection of TVA's Design
Baseline and verification Program (DSVP) for the Sequoyah Nuclear Power
Plant, conducted at the plant site and in your Cedar Bluffs Offices betwetnThe N
June 29 and July 24, 1987.
discipline team of personnel from the Office of Nuclear Reactor Regulation
from consulting firms, and from the Region II Office. The team concentrated The team
on
the resolution and corrective action for the findings of the OBVP.
also reviewed the corrective actions resulting from independent oversight of
this program by TVA's Engineering Assurance group and evaluated TVA's TVA actions
in response to previous NRC design control and DBVP inspection reports.
internal reports (1) EA-OR-001, Engineering Assurance Oversight Review Report,
"SeQuoyah Nuclear Plant - Unit 2 Design Baseline and Verifica
,
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dated April
1987, characterize the program, its findings, and the Engineering Assurance
oversight effort. These reports were also reviAwad during tnis inspection.
( lyded that the OBVP was generally
As a result of the inspection, the NRC team co
conducted in accordance with the progran. plan ' Implementation ey both OBVP
personnel and the Engineering Assurance oversight group _
the program areas inspected to date. @
h As noted in the report, implementation of carrective actions fd'r Opp findings
was still in progress at tne time of the inspection, as was Encineering ta
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Assurance g A) tameling and verification of imelementaFonQt note tna d
supplemental recort aoaressing tA oversight of the OBVP
_
hasieen
In arrer suomittg_d
for tne NRC to to
h m (P. Geidlev letter m ted Octoberto23._ isseiolant restart, the supolemen-
a m es n :decomev of the J vp effort succort
.
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Reoort remains to be reviewed by tne NRC'.
t.a_LF 9 meeM ag A::'.m:nce Overeignt
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Results of the inspection are presented in the enclosure.
.t at
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Tennessee Valley Authority
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TVA provided a written response (R. Gridley letter dated October 27, 1987)
addressing the observations identified in Appendix A of the enclosed report in
advance of the issuirg o' this report. The substance of these observations nac
An additional NRC
been communicated vereally to TVA during the inspection.
inspection (Report 327, 328/87-64) was conducted on October 26-30, 1987. This
subsequent inspection addressed many of the open observations addressed in the
enclosed report. The NRC's evaluation of your response to this letter will se
docurrented in inspection report 327, 328/87-64 Any observations remaining
open at restart will require an evaluation of acceptability f ar n.-n restart ey
both TVA and the NRC.
In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosure will
be placed in the NRC Pub 1fc Document Room.
Should you have any questions concerning this inspection, please conttet me or
Mr. Gene Imbro, (301) 492- h 54.
Sincerely,
5 -C
,
. v. y/ L, A * n c ew
Stewart O. Ebneter, Director
TVA Projects Staff
Office of Special Projects
Enclosure:
Inspection Re',0-t 50-327/87-31
and 50-328/@ 11
cc w/ enclosure:
See next page
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Mr. S. A. White Scouoyah Nuclear Plant
Tennessee yelley Authority
ec: Regional Administrator, Region 11
General Counsel U.S. Nuclear Regulatory Comission
Tennessee Valley Authority 101 Marietta Street N.W.
400 West Sumit Hill Drive Atlanta, se 'rgia 30323 l
E11 833
Knoxville, Tennessee 37902 Residet.t Inspector /SeQuoyah NP
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c/o U.S. Nuclear Regulatory Comission
Mr. R. l.. Gridley
j
2600 Igou Ferry Road
Tennessee Valley Authority Soddy Daisy, Tennessee 37379
SN 1578 Lookout Place
Chattanooga, Tennessee 37402-2801 Mr. Richard King
e/o U.S, GA0
Mr. H. L. Abercrombie 1111 North Shore Drive
Tennessee Valley Authority Suite 225, Box 194
Seouoyah Nuclear Plant Knoxville, Tennes:ee 37919
P.O. Gox 2000
Soddy Daisy, Tennessee 37379 Tennessee Department oi'
Public Health
Mr. M. R. Harding ATTH: Director, Sureau of
Tennessee Valley Authority Environmental Hea'th Services
Seoucyah Nuclear Plant Cordell Hull Building
9.0. Box 2000 Nashville, Tennessee 37219
Soddy Oaisy, Te m essee 37379
Mr. Michael H. Mobley, Ofrector
4 Mr. O. l.. Williams Division of Radiological Health
l Tennessee Vs11ey Authority T.E.R.R. A. Building
400 West Sumit Hill Orive 150 9th Avenue North .
W10 385 Nashville, Tennessee 37203
Knoxville 7ennessee 37902
Dr. Henry Myers, Science Advisor
County Judge Comittee on Interior
Hamilton County Courthouse and Insular Affairs
Chattanooga, Tennessee 37402 U.S. Heuse of Representatives
Washington 0.C. 20515
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Tennessee Valley Authority
Distribution: (w/enel)
Uts (coctet No. 50 327/328)
POR
LPOR
ORis Reading
S!8 Reading
EVImbro, NRR
8XGrimes, NRR
JGPartlow, NRR
REArchitzel, NRR
SEbneter , OSP
JAxelrad. OSP
$Richa rdson, 059
GZech, OSP
SDLiaw, OSP
FMcCoy, RII
K8arr, Ril
88 Hayes 01
SRConnelly, OIA
ELJordan, AE00
Inspection Team (8)
JFair, OSP
Resident Inscector
OGC-Beth
Central Files
CSP Reading
FMiraglia
AORS (10)
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TVA-Setnesda
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U.S. NUCLEAR REGULATORY COMMISSION
0FFICE OF NUCLEAR REACTOR REGULATION
i
Olvision of Reactor Inspection and Safeguards
Report Not.: 50-327/87-31, 50-328/87-31
50-327; 50-328
Docket Nos.:
Tennessee Valley Authority
Licensee:
6N, 38A Lookout Place
4
' 1101 Market St.
Chattanooga, TN 37402-2801
Facility Name: Sequoyah Nuc bar Plant, Units 1 & 2
Inspection At: Cedar Bluffs and Soddy Daisy, TN
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Inspection Conducted: June 29-July 2 and July 20-24. 1987
Inspection Team Members:
R. E. Architzel, Senior Operations Engineer, NRR
Team Leader:
Mechanical Systems:
F. J. Mollerus, Consultant, Mollerus Engineering Inc.
Nuclear Engineering J. A. Nevshem41, Consultant *
Mechanical Components: A. V. du Bouchet, Consultant
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A. I. Unsal, Consultant, Marstiad Engineering
Civil / Structural:
S. V. Athavale, Elactrical Engineer, NPR*
Electrical Power:
Instrumentation & L. E. Stanley, Consultar.. Zyter 'nc.
Centrol:
P. E. Hamon, Resident inspector, Sequoyah
Op6 rations: H. E. Bibb, Res' dent Inspector, St. Lucie NPP*
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/Q9l$'7Cate
Ralph E. /trchitzel
Te:m Leader
YY Y
Eugene V. 7.iPo
to// /// 7 cate
Section Chief
Team Inspection Appraisal and Development Section d2
Soecial Inspection Branch _ _
'6/29-7/2/87 only
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LIST OF ABBREVIATIONS
A8GTS auxiliary building gas treatment system
CAQR condition adverse to quality report
CCP centrifugal charging pump
CCRIS Calculation Cross Reference Information System
CCS component cooling water system
CES Civil Engineering Branch
CFR Code of Federal Regulations
J
DBVP Design Baseline and Verification Program
DCR design change request
- OES Discipline Evaluation Supervisor
- DIM design input memorandus
4 ONE Givision of Nuclear Engineering
i EA Engineering Assurance
ECCS emergency core cooling system
ECH engineering enange notice
EEB Electrical Engineering Branch
ERCW essential raw cooling water system.
FCN field change notice (Westinghouse)
FCR field change request
- FSAR Final Safety Analysis Report
HPFP high-pressure fire pretection
HVAC neating, ventilation, and air conditioning
I&C instrumentation ano control
IEEE Institute of Electrical and Electronics Engiaeers
LOCR local design change request
LOCA loss of coolant accident
MEB Mechanical Engineering Branch
HI maintenance instruction
NCR nonconformance report
NEB Nuclear Engineering Branch
NPSH not positive suction nead
NRC Nuclear Fegulatory Commission
NSSS nuclear steam supply system
OR oversignt review
PGCE potential generic conditicn evaluation
PIR problem icentification report
PL punchlist
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QIR quality information report
RIMS records information management system
SCR significant condition report
SE System Engineer
SI surveillance instruction
SQR Static-0-Ring
SQEP Sequoyah Engineering Proc 1 dure
SQN Sequoyan Nuclear Plant
SSE safe shutdown earthqua4
SWBIO system walktown bounda.ry identification drawing
SYSTER System Evalt : tion Report
TACF temccrat/ alt ration control form
TVA Tennessae Val cy Authority
USQD
unrevisvad safety question determination
WOP <alkdown package
WP work package
WR work request
ZPA zero period acceleration
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SEQUOYAH N% LEAR PC'G PLANT
Design 8aseli' e and Verification Program
Inspection Recart 50-327/87 4 1 & 50-323/87 31
,une 29-July 24, 1987
1. INTRODUCTION AND t1ACMROUNO
The Design Baseline an? Verification Program (OBVP) was develcOd by TVA's
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Division of Nuclear Eagineering (CNE) to resolve desisn control issues
described in several TVA-sponsored evaluations and audits and NRC insp+ction..
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The Sequcyah Nuclear Plant (SQN) Design Baseline and Varificati6n Program hat ;
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been used by TVA to provide an accitional level of canfidence that the 1
modifications to selectec plant systems, implement 9d since receipt of the
operating license, have .1ot resulted in any violation of the plant's licensing
basis.
This report sumrarizes tr,e r2sults of the fifth NRC inspection conduct {d to
assess the adequacy of TVA's Design Baseline and Verification Program to
support restart of 5equoyah Nuclear Plant.
NRC inspection report 50 327/86-38 and 50-328/86-38 sunwtarized (1) the NRC
review of TVA's overall OEVP olan and scope, (2) TVA's procedures for OBVa
project review and Engineering Assurance (EA) ove
review of TVA's design criteria for FSAR Chapter 15 safety-rslate.d systems
within the scope of the 08vP.
NRC inspection report 50-327/86-45 and 50-328/86-45 sumesrized (1) the NRC's
review of TVA's compilation and implementation of the commit 31ent/ requirement
data base, (2) the design criteria which TVA prepared to support SQN restart,
and (3) the acequacy of EA's independent oversight review of committiient/
ments and dosign criteria.
NRC inspection report 50-327/86-55 and 50 328/86-55 summarized the NRC's r
of the OBVP engineering change notice (ECN) review.
NRC inspection report 50-327/87-14 and 50-328/87-14 summariu.d the NRC's
evaluation of the System Evaluation Reports (SYSTERs), summary reports that
reflect the 08vP's integrated assessment, on a system easis, of the reviews,
evaluatiolis, and findings of the program.
Licensee actiuns for previous inspection findings (including design control
inspection 50-327/86-27 anc 50-328/86-27), ore-restart corrective action
decisions, and the effectiveness of the Engineering Assurance oversight
effort were also examirec curing tnese inspections.
2. PURPOSE
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The purpose of this inspection was to 3ssess the implementation and com
of the OBVP.
This included evaluating..hether or not tne findings identified
by the OBVP were ceing adeovately resolved
The inspection and
was also neldproperly scheduled
to evaluate the for
action before plant restart,
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Team and the adequacy of the licensee's l
effectiveness of the EA Overs:..
actions taken in response to previous NRC inspection findings.
3. INSPECTION ACTIVITIES
The following activities were generally performed by all team members:
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(1) Reviewed TVA's corrective actions associated withTeam its in-house
memcers concen-
Encineerirg Assurance (EA) oversight of the OBVP.
trated on the "observations" identified in the EA report (Reference 12)."
The team assessed
(2) Reviewed TVA's resolution of ORVP punchlist items.
the restart categorization u ng docketed restart criteria) of selected
ftems and planned corrective actions.
(3) Verified implementation of corrective actions for selected, more signifi-
cant findings of the OBVP.
(4) Assessed if the generic implications of inspection activities 1, 2, and 3
hac 'ocen adequately addressed.
Reviewed the Phase I (pre-restart) reports summarizing both the CBVP
(5)
(Reference 13) and the associated EA oversight (Reference 12).
(6)
Reviewed the action taken by TVA in response to the deficiencies, un-
resolved items, and observations previously identified in NRC inspection
report Nos. 50-327/86-27 and 50-328/86-27, 50-327/86-38 and 50-328/86-38,
50-327/86-45 and 50-328/86-45, 50-327/86-55 and 50-328/86-55, and
50-327/87-14 and 50-328/87-14
4 SUPNARY OF FINDINGS
.
The following paragraphs summarize the more significant team findings and
conclusions.
Sections 4.1 through 4.7 contain detailed descriptions of the
Observations are provided in
inspection findings in each discipline.
Appendix A to tnis report.
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In the operations areL the team concluded that the OBVP was adequately plannec
and implacented. All questions raised by the team pertaining to coth scope anc
oepth of the walkdowns and resolution of deficiencies and findings were addressed
and resolved. In particular, the team felt that the EA oversight was effective
The corrective a:tions reviewed by the
and responsive in the operations area.
team appeared to be relevant and comprehensive. Review of the restart /non-restart
In particular, the inspectors
categorization process indicated some weaknesses.
questioned the tendency to classify as non restart the actions tnat'tems
Several werewere
deter-
mined to be outside tne OBVP boundary (Observation 7.5).
reclassified after the inspectors challenged the original classification.
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Although several exaaples of questionable :ategorizat
appeared acceptable in the operations area.
"References are listed in Section C,2 of Appendix C.
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During the inspection, the team ceserved that the concurrence of the OBVP
Systes Engineer and Discipline Evaluatier Supervisor
proposed wereactions
corrective not required
for for
changes to the restart categorization ant TVA adequately
punchlist items following initial concur ence by the DBVP. resolv
- concurrence reviews for future technica changes, and has examined thosewere
These actions enanges
wnich had previously occurred to assess their adequacy.
' delineated in an August 20, 1987 letter to the NRC (Reference 17).
In the mechanical systems area, the team reviewed several of TVA's corrective
actions for open NRC observations from previous inspections, reviewed TVA's
corrective actions for observations made by Thethe EA also
team group, and revi;wed
reviewed how
field implemen-
TVA had resolved 08vP punchlist items.The team found the findings, evaluations, and
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tation of corrective actions.
determinations of EA-Mechanical Engineering to be competent, and the resolution
l and implementation of DBVP punchlist items to be satisfactory.
In the nuclear engineering area, the team reviewed several of TVA's correctise '
actions for open NRC observations from previous inspections, reviewed TVA's
corrective actions for observations made Thebyteam
tne EA group,
found and reviewed
the findings, TVA's
evaluations,
resolution of OBVP punchlist items.
and determinations of EA-Nuclear to be competent, and resolution and implemen-
However, the
tation of DBVP punchlist items to be generally satisfactory.
inspection team disagreed with TVA's Thisdecision to reclassify
item concerns from
the need restart to
to provide a
post-restart punchlist item 4426. safety-related Also,air
thesupply for the isolatio
team identified
the rcdiation in containment air (Observation 4.8).
several :ases in wnich there was incorsistency between the OBVP punenlist and
the associated Attacnment 2 form to Sequoyah Engineering Procedure 45 (SQEP-45)
(Observation 7.5).
In the mechanical components discipline, the teaa reviewed the OBVP and EA
reports to assess the adequacy of the OBVP's review of the SQN Unit ? chance
documents and nonconformances, and EA's oversight of DBVP project, review.
[The tsam reviewed the Civil Engineering Branch's (CEB's; categor implerrentation
W ation of a
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sample of civil / structural punchlist items, OEVP's post-restar:
of a sample of punchlist items, and OBVP's decision to request ;<neric reviews
for a sample of the nonconformances that 0%P personnel preparec to categorize
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{thepenchlistitems.
The team also reviewed several cpen action items in EA's report to assess the
adequacy of D8VP responses to EA's concerns and, in addition, reviewed EA's
verification of 08vP implementation of corrective actions for two of the three
mechanical temponents acticn items that EA had completed verifying .it the time
of the inspection.
The team identified two coservations during this inspection concrirning the
lack of a generic evaluation for a nonconformance, and the lack of a
calculation to qualify a cesign variance (Observations 3,16 and 3.17).
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The team concluded that the 08vP's review of the SQN Unit 2 change documents
and nor.conformances issued sin,:e the operating license had been issued ade-
quately defined the corrective actions required to validate the design :nange
control process at SQN Unit 2.
In the instrumentation and control (I&C) area, the team reviewed the EA grouo's
oversight of commitments and requirements, design criteria, calculations, CBVP
assessments of post-scification tetts, SYSTERs and 08vP restart decisions.
The ter.m is satisfied that the EA oversight prcgram provided an effective
review of the 08VP process anet its outouts.
The team al:o directly reviewed 08VP evaluations of ECNs, post modification
tests, calculations, design criteria, commitments and requirements, SYSTERs,
generic implication evaluations, and restart decisions in the I&C area.
Other than two specific exceptions, OBVP evaluations and restart decisions
were deemed to be correct and accropriate. Four out of the five condition
adverse to quality reports (CAQRs) for the TVA setpoint accurscy calculation
program reviewed by tho team had appropriate corrective actions, but corrective
action for the fifth samole was found to be incomplete. TVA took into account
the potential for generic implications of the SQN findings at other similar
facilities.
The team generally agreed with TVA's resolution of 08VP punchlist items. D8VP
restart decisions were found to be acceptable in each instance reviewed by the
team; however, the team did identify one instance in which DNE was in the process
>f changing a pre-restart decision to post-restart without having. adequately
evaluated and justitiod that changa.
Throughout the various inspsetions, the team has been satisfied with the extent
and depth of inquiry evidenced by the OBVP. Individual team observations,
albeit numerous, did rot indicate a programmatic preolem with the OBVP
approach. TVA has been preparing corrective action design change noticas for
implementation before restart, a positive indication that latent design
prools:s are now being evaluated and corrected.
IInthecivil/structuralarea,theteamreviewedthecorrectiveactionstaken
& > by the project to resolve the punchlist items that were generated by the 08vP
and the EA observations as reported in EA eversight report EA-0R-001 (Referene.e
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12). The team also reviewed the restart categorization of punenlist items to
{determinewhethersuchcategorizationswereaopropriate.
The revie$relosed properly by the OBVP
are being project.y
The team the
concurs witn tne team sho
categorization of the ounenlist items as noted on the governing SQEP-45,
Attachment 2 forms. T1e term was, however, concerned with the adequacy of
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the tracking system used to control the status of punenlist itams. Discre-
pancies were noted between :ne restart status and the implementation status
of many punchlist items, the team also noted that when a biased sample of
five restart punchlist items associated with field changes was selected for
review, none were implemented at the time of the inspection (Observation 7.5).
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The team also reviewed the aporopriate se(tjns of report EA-OR-001 and any the
OBVP Unit 2 Phase I report (Reference 13).tThis review did not icentirvtwo repo
deficiencies relat h u n . u
In the electric power area, the team reviewed TVi's corrective actions
associated with past NRC inspections of the 08V/, TVA's corrective actions for
some signif tcant condition reports (SCRs) and CAQRs, and TVA's process for
addressing the generic impact of Sequoyah 08VP findings at other TVA olants.
The team also reviewed the restart categorization of several DBVPEA's punchlist
oversight
items and the report of EA's oversight of the 08VP (EA-OR-001).
resulted in a total of 357 action items, of which 91 related to the electric
power discipline. These electric power action items were further analyzed and
classified into various categories. Approximately 63% of the action items were
related to design deficiencies, and approximately 14% of the action items wer4 [ -
related to design criteria deficiencies. The NRC team also noted that the
electric power discipline was a leading contributor of de'iciencies rela
unreviewed safety question determinations, testing and ir :erf ace control.
The types of documents affected by the electric power ac'.on items were ECNs
(approximately 26.9%), design criteria (approximately 2f.8%), SYSTERs (approxi-
,
mately 13.2%), walkdown packages (approxim2tely 9.2%), calculations (approxi-
mately 5.9%), and technical procedures (approximately 5.3%).
The NRC team found EA's analysis of findings in the electric power area, as
presented in the final report, acceptable.
4. t Goerations
4.1.1. Corrective Actions Associated With EA Oversight of the 08VP
In the operations area, the team examined Engineering Assurance Observations Q1-C
T-1, EA-1, and Condition Adverse to Quality Report (CAQR) SQE-870-R01-002 docee
ted in "EA Oversignt Review Report", EA-0R-001. This included an assessment of
the observations, responses from the SQN Engineering Project and/or 08VP, adecuacy
i
of proposed corrective actions and restart categorizations.
Observation Q-1, corresponding to Action Item Q-07, pertained to the implementa-
tion of several EA recommendations for the 50EP-13 process, for example, System
The corrective actions
Engineer review of changes to ECN pre-restart status.
were implemented and EA concurred with this disposition.
Observation Q-2 was issued to transfer responsibility for corrective action
86-03-012 to the EA group. Design criteria and design
verific. tion for CAQR
calculations were not being properly maintained as required by DHE procedures
and TVA Topical Report TR751A, Section 17.1.3.1.2.
Part A of the CAQR concerned design criteria. Design criteria All required for
specific
restart were captured in tra Restart Design Basic Occument).
examples found in Part A of the CAQR were resolved by issuing of appropriate
design criteria.
Part B of the CAQR concerned design calculations. 30,TVA's calculation review
1987. The program will
program is scheduled for completion by September In addition, the prograi
review and/or regenerate all essential calculations.
' ---
5-
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. . .
_. .
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.
i
,
(Calculation Cross
will provide a uniform change process and tracking systemRefere
change documents, drawings and calculations.
EA was to samote
l
EA concurred with the proposed corrective actions.
implementation of these actions at a later date.
f
Observation Q-3 concerned SQEP-13, "Transitional Design Change Control." EA
recommended several changes to the SQEP 13 process to be included in the next
08vP personnel agreed to revise SQEP-13 to incorporate all the
revision. Revision 5 documented tnis set of changes (see
principal items identified.
Observation Q-4).
Observation Q-4, corresponding to Action Item Q-11, identifie
the ECN process during transition. A revision to SQEP-13 (Rev. 5) eliminated
All ECNs processed under the
the waiver as a means of ECN implementation.
waiver format were reviewed to verify compliance with the requirements of
SQEP-13.
Observation Q-5 concerned changes that EA recommended to the The draft 08VP report.
EA still needed to verify that its recommendations were implemented.
following items were included:
Item 1
Trending of punchlist items was revised to include tracking
and resolution via the CAQR process (Ref. CAQR SQE 870R01-002).
Resolution to address documentation of closed and implemented
Item 2
SCRs/NCRs whien were evaluated in the OBVP.
Transitional Design Change Control Procedure was revisad to note
Item 3
the use of waivers in the SQEP-13 process.
Observation T 1 noted that the red-line process used to mark up control room
drawings did not include an independent review for accuracy by a second party.
50-327/87-24 and 50-328/87-24, and 50-327 '*7-54 and
Inspection report Nos. A violation for fai u.e to per-
50-328/87-54 independently opened this item.
form independent review of change was identified in these Office of 3pecial
Projects inspection reports.
All
Observation E.4-1 concerned items to be corrected Five
items with corrective actions will be tracked via the CAQR process.
in Phase II of the
selected itses were reviewed to assess wnether the cost-restart designation
The inspector concurred in the disposition of
of these items was correct.
the selected items as accropriate to Phase II implementation.
CAQR SQE-870-R01-002 icentified by a random sample by EA _.
of the punchlist items tnat represented conilitions adverse to quality (CAQs)
had not resulted in written reports (CAQRs) I
review of all open punenlist items that had not had corrective action recorts '
written against them to ensure that a probitm identification report (PIR), a
significant condition report (SCR), or a CAQR, as appropriate, is assigned. j
EA had concurred with tnis resolution.
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Overall, the team concluded that the EA oversight was effective anc responsive
in the operations area. The corrective actions reviewed by the team seemed to ]
the relevant and comprehensive.
4.1.2 Resolution of OBVP Punchlist Items and Implementation of corrective
Actions
A limited number of punchlist items were reviewed regarding the assignment
of restart / post-restart category. The inspector agreed with the assignments
in general, but did not agree that punenlist
This itemitem 5644 tne
involves wasimproper
appropriately
(non-
assigned as a post-restart issue. The decision
seismic) mounting of handswitches on the main control board.
had been made to classify this as a post-restart issue because the switches
were out of function on the system walkdown boundary identification drawing
The team concludes that the
(SW8ID) (addressed in NRC Observation 7.5). p
potential effect on system operability should be assessed before restart.
The team raised a question about the adequacy of residual heat removal pump
Specifically, when heat exchanger bypass g r-0
flow indication in the control room.
valve 74-32 is open, total pump flow indication is not available. The g
additional (unsonitored) flow through the bypass valve is enough to force This the
item
pump into runout as evidenced by a 1980 test (W2.2 (SCR NEB 8708)).
will be tracked by the resident inspectors as part of the normal closecut of
SCRs.
During the course of the inspection, the inspector reviewed TVA correspondence TVA
relating to emergency diesel generator operations while in the test mode.
has determined through the OBVP (punchlist item 8514) that the diesel generator
will not transfer from the test mode when a valid emergency sttrt signal is
received; this is contrary to the FSAR. This apparent deviation will be
followed by thw resident inspectors.
The team examined the programmatic controls which were established for
tracking, resolving, establishing restart
Theseitems, closing,established
were primarily and statusing
by SQN
implementation of punchlist items.
SQEP-45 (Rev. 5) and various 08VP directives which amplified an
procedural controls. Evaluation S-;ervisor (OES) concurrence (docuraented on
forms) for both the restart categorization and the proposed corrective actions.
In addition, SYSTER closure statements were required to be generateo to
identify any changes between the corrective action and restart category finally
agreed to by the DES and the SE and the categorization at the time of issuance
of the SYSTER.
OBVP Oirectiva 87-007 (June 18, 1987)
clarified that punchlist items wera to
be closed when the SE and DES concwred with the Therestart categorization
punchlist and
item was secars-
the implemented or planned corrective action. The
tely tracked for implementation status, as opposed to DBVP closure.
directive stated that the purpose of tne OBVP was no longer to verify the
adequacy of the work performed by the SQN project; new policies andthe
As such, procacures
are in place to correct past design control deficiencies.
project was being allowed to change restart categorizationThe andteam
proposed
was
corrective actions without concurrence of DBVP personnel.
concerned that this practice substantially dyraded an important feature of
7-
- _ _
.
.
the 06VP, that is, the overall perspective, from a system level, of the imoact
of the particular punchlist item and its relative importance to system function
as evaluated by the 08vP. l
l
The
rence reviewsteam wereacknowledged
not essential. that for some
For example, some punenlist items had
changes
Following comole-
'
in punch
l
corrective actions def f ned for both pre- and post-restart. I
tioa of the pre-restart corrective action, the SQN project was supposed to
initiate an Attachment 2 form (SQEP 45) to change the status of the item to l
post-restart. In addition, the SQN project was supposed to initiate an
Attachment 2 form (SQEP-45) to change the status of items toThe "implemented"
team noted to
!
reflect that proposeo corrective action had been completed. ;
that numerous non-adminj trative chances were also being made to punchlist
items, and expressea concern with the apparent relaxation of controls by the {
08vP.
The team was informed that CAQR SQT-871268 had been initiated by the
Engineering Assurance oversight group addressing this same concern.
Following the ir.spection, the licensee changed the control and processing of
changes to the punchlist to address these concerns (TVA letter from Gridle
NRC, dated August 20, 1987). administrative changes, implementa-
punchlist changes into three categories: Technical changes now require 06VP
tion status changes, and technical changes. Punchlist
concurrence (Syst6m Engineer and Discipline Evaluation Supervisor).
changes occurring before implementation of Directive 87-008 are actions
These being reviewed,
categorized, and dispositioned in accordance with the directive.
adequately resolved the team's concerns.
The team selected a sample of five punchlist items to assess the status of
implementation and the consistency between the governing SQEP-45, Attachment 2
form and the actual punchlist database information.
by only selecting punchlist itams for which field modifications were required.
Of these five punchlist items:
- One was listed as outside the scope of the OBVP, tabulated as implemented
with actual status unknown.
- Two were not implemented.
- One was Ifsted as implemented; however the associated SQEP-45, Attachment 2
form documenting implementation was not available - the associated SQEP-a5,
Attachment 2 form documenting OBVP closure indicated that pre- and post-restart
corrective actions were required, implying improper implementation status.
- Another implemented item did not have the required SQEP-45, Attachment 2
form on file and accarently was improperly listeo as implemented, based
l
on OBVP closure.
The fact that none of the selected punchlist items within the scope of
the OBVP were implemented was of concern to the team, notwitnstanding Thethe
team
biased selection of punenlist items requiring field modifications.
further noted that the licensee's procedures for control and statusing of
punchlist items did not specifically address handlin9 of these aspects of the
punchlist items (NRC Observation 7.5).
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4.2 Mechanical Systems
Corrective Action Associated With EA Oversignt of the OBVP
4.2.1
Ouring this inspection, the team reviewed the EA observations contained in EA
Oversight Review Report EA-0R-001 and the 08VP and/or SQN project response to
The mechanical engineering discipline of EA reported four
these oeservations.
observations.
EA observation M1 identifivs a concern related to the adequacy of the informa-
tion for valve stroke times included in the auxiliary feedwater system design
criteria. The project responded by issuing Quality Information Requests and EA
a
commitment to issue Design Input Memoranda or design criteria revisions.
found the response generally acceptable. However, EA questioned the use of
plant technical specifications as the source of the valve stroke data, and was
holding the observation open pending SQN project response to this concern and
EA review of the memoranda and revised design criteria.
EA Observation M2 concerns the need for the System Evaluation Report (SYSTER)
to state whether identified corrective actions need to be completed before or
after restart. The observation also noted that the draft SYSTER for the con-
tainment spray system addressed the incorrect use of cable lengths in certain
electrical calculations. EA report EA-0R-001 notes that this observation was
resolved by a OBVP commitment to issue instructions to ensure a thorough
"buy-in" of corrective action categorization by the System Engineer (SE) and
Discipline Evaluation Supervisor (OES) and a commitment to issue an Electrical
Engineering Branch (EEB) policy memorandum regarding how cable lengths are to
be used in electrical calculations.
M-30, M-43, and M-46. The
EA Observation M3 addresses three EA action items:
observation, action items, and SQN project response were reviewed and found to
be acceptable. The SQN response to M-43 was to conductThe a pre-resthrt leakage
test was performed.
test of tne component cooling water surge tank baffle.
However, the test prodeced inconclusive results because there EA isare valvesthis
holding in the
item
system that may allow leakage in the test configuration.
open pending a visual inspection or a test that, measures only baffle leakage.
EA Observation M4 identified a concern that, in some cases, punchlist items
have been implemented and closed before the corrective At action
the timewas assigned
the on
EA report
the initiating condition adverse to quality (CAQ). The observation has subsequently
was issued, the observation remained unresolved.
been closed by 08vP reviews and policy promulgated in SEQP-45, Revision 3,
"Control of 08VP Action Items," and 08VP Ofrective 87-06, Revision 1, "Statusing
Punchlist Items."
In addition to the above observations, the mechanical engineering discipline of'
EA initiated and reporteo on two CAQRs in its oversight report:
- CAQR SQE-870 R01-001 reported an unverified assumption in a calculation.
- CAQR SQE-870-R01 003 reported an inconsistency in the design temperature
for the containment spray piping inside of containment.
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<
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.
Subsequent to the oversight report, the first CAQ has been resolved by EA based
on corrective action proposed by the SQN project and EA the and determination the SQN projectthat the
CAQ is not significant and is a post restart item.found that the second C
the inconsistent temperature identified in the CAQR is not a design condition.
Rather, it is a beyond-design-basis condition used only for piping design and ,
support stress analysis. l
In general, the inspection team found the findings, evaluations, The team expects andthat
determi-
nations of EA-Mechanical Engineering to be competent.
this competency and satisfactory EA results can be continued, provided the EA
resources and manpower are maintained tt a level connensurate with the effort
required for a 5% sampling of the 08vP results.
4.2.2 Resolution of 08VP Punchlist Items
During this inspection period, tne team also inspected 25 08vP punchlist restart
decisions. Many of the punchlist items were selected from those identified
Most of the in
the 08VP Phase I report as not required for Unit 2 restart.
decisions
be justified.
to place the punchlist item in a post-restart category were
punchlist (PL) items required close review during this inspection.
(1) PL 2672 - Replace Missing AN Steam Line Insulation
The decision to categorize this item as post restart was questioned by the
inspection team because of two potential adverse effects of unineulated steam
piping: (a) the formation of additional condensate which challenges both the
auxiliary feedwater (AFW) steam piping drain system and the fast start capa-
bility of the AW steam turbine drive and (b) additional leat loads on
safety-related heating, ventilation, and air conditioning (HVAC) systems.
During the inspection 08VP personnel informed the team that PL 2672 was
mistakenly categorized as post-restart and that the work required by the item
During the second inspection period,
is, in fact, being done before restart.
the team was provided with information showing that the insulation had been
replaced under work package (WP) 12301.
(2) PL 1946 - Containment Bypass, System 26
The 08VP Phase ! Report observed that System 26, the high-pressure, fire-
protection systas, may become a bypass of the auxiliary building gas treatment
system (A8GTS) if parts of System 26, such as the head tank Theand
item associated
was
piping that are not designed as safety-related, However, upon questioning should by fail. categ
the A8GTS, not a bypass of orimary containment. .
the inspection team, TVA determined that the FSAR offsite dose calculations
take credit for the effectiveness of the ABGTS.
TVA was informed at the end of the first inspection During period that tneinspection
the second team
considered that this should be a restart item.
period, the team was provided with information showing that PL 1946 had been
recategorized to a pre-restart status.
.-. _ _ . . _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _
.
.
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(3) PL 8894 RHR RETEST
_
Attachment 1 of SQEP-45 was issued for punchlist item 8894 as a result of
significant condition report (SCR) SQN-NEB-8708, which identified cavitation
problems during preoperational testing of residual heat removal (RHR) pumps
on Unit L The SCR observed that severe cavitation problems occurred wnen one
As a consequence, the
RHR ;, ump was aligned to four cold-leg injection lines.
RHR preoperational test instructions for Unit 2 were revised to avoid The
testing
in the cooldown modes which created severe cavitation in Unit 1.
description of condition of the SCR further addressed the need to test in the
emergency core cooling system (ECCS) modes on Unit 2 to ensure that the
However, adverse
in the root
effects of cavitation observed at Unit I would not occur.
cause and corrective action sections of the SCR, it was concluded that testing
was not required.
A subsequent SQEP-45, Attachment 2 form and Revision 1 to SCR SQN-NEB 8708 changee
the item's category to post-restart. However, the revised SCR containt no clear
explanation for this action.
Discussion with TVA personnel revealed the following information that was not
in the SCR:
(a)
The condition of cavitation observed at Unit 1 occurred with one RHR pump
in operation, return flow to the reactor through four cold-leg injection
lines, and flow through the RHR bypass line with the bypass valve in a
throttling mode. The reactor vesselCavitation
head was off and the reactor coolant
occurred in the bypass line
system was cold and depressurized.
and valve, not at the RHR pumps or in the injection lines.
Furthermore,
(b) The configuration noted above will not be used for cooldown.
the heat exchanger bypass line is closed off by manual block valves in all
modes of ECCS standby and operation.
(c) Surveillance test procedures 6.1 e and 6.1.a.1 nave been performed at Unit 2
to demonstrate satisf actory performance of the RHR aligned in the ECCS
modes.
During the second period of the inspection, the team reviewed the results of
Pre-operational Test W-6.1A1, "Safety Injection System Integrated Flow Test."
This test confirms the adequacy of not positive suction head in the SCR
However, ECCS modes8703
SQN-MEB <
and the validity of the post-restart recategorization.
should be revised to clarify the decision and the remaining post-restart actions.
4.2.3 Implementation of Corrective Actions for OBVP Findings
I
In the mechanical systems area, the team reviewed implementation of corrective *
action by a field inspection of two recently completed punchlist items.
Pl. 2672 required the installation of missing insulation on the auxiliary Field
feedwater turbine steam line. The work was done under WP-12301.
inspection showed that tne steam line was fully insulated.
i
. _. . - . _ . - -. -___. _ _. . w
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Pt. 3264 required that a ventilation grill in System 31 be cleaned and cleared
of penetration sealing splatter that was obstructing air flow. The team found
that the work, done under work request (WR) 121450, was satisfactorily completed.
4. 3 Mechanical Components
4.3.1 Corrective Actions Associated With Engineering Assurance oversignt of
the 08vP
TVA's Engineering Assurance (EA) oversight review of the Sequoyah Nuclear '
Plant (SQN) Unit 2 Phase I Design Baseline and verification Program (OBVP) is
susunarized in EA Oversight Review Report EA OR-001, entitled "Sequoyan Nuclear
Plant - Unit 2 Design Baseline and verification Program," which EA issued on
April 29, 1987. Section 5.0 of the report susunarizes EA Observation Nos. C1
through C6, which EA documented to track 16 action items in the civil /
structural discipline. EA had accepted the corrective action plans for these
action items, but the DBVP and/or SQN project had not completed implementing
all the associated corrective action, nor had EA yet verified its entire sample
of the completed corrective actions.
In the mechanical components area, the team reviewed Action Item C-10 (EA .
05servation No. C2), Action Items C-15 and C-27 (EA Observation No. C3), a
Action Items C-28, C-53, C 54, C-55, and C 57 (EA Observation No. C6). ,
reviewed EA's documented concerns for each of the action items, and evaluated )
the adequacy of the response to EA's concerns. The team noted that the OBVP i
had not completely defined or fully imolemented corrective action for several '
action items. However, the team concluded that the OBVP was responding age-
quately to EA's documented concerns.
',
Action Item C-10 documented EA's concern that the SQN project had not captured trei '
following provisions of NRC Regulatory Guide 1.29 in the SQN design criteria:
'
(1) protection of Category I piping and equipment from the potential failure
of ncreCategory I piping
(2) extension of seismic Category I design to the first seismic restraint
beyond the Category I isolation valve.
EA also noted that the SQN design criteria did not adequately define the
distinctions between Category I, safety-related pressure-retention,
The DBVP andIdentifi-
prepared Problem
safety-related position-retention piping. 825 861008 015) to address EA's
cation
concerns.
Report (PIR) SQN-CEB-8670 (RIMS No.On June 5,1987. EA char
open, pending the OBVP's response to EA's request for additional corrective-
action.
Action Item C-15 noted that design criteria SQN-0C-v-13. S, "Detailed Analysis
of Category I Piping Systems," did not address the following requirements:
(1) overlap design considerations, such as rigorous analysis interface with
alternate analysis or dead weight heng piping
f
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4
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i
(2)
interface procedures to control and identify the system /pioing design
input required by the pipe stress analyses to implement the design
criteria
,
,
interface criteria to define the TVA stress analysis scope and the
(3) Westinghouse Class I nuclear steam supply system (N555) analysis
(4) applicability of the design criteria to tubing
(5) protection of Category I piping and equipment from the potential failure
of non-Category I piping.
The DBVP did not prepare any conditions adverse to quality (CAQs) in response
to EA's concerns, noting that the OBVP was tracking ites (5) by PIR SQN-CEB-8670
(see Action Ites C-10). On June 25, 1987, the DBVP provided EA with a summary
of completed corrective actions to address Action Item C-15. Action Ites C-15
remains open, pending the OBVP's response to EA's request for additional
information.
EA reviewed Westinghouse design criteria SQH-0C-V-27.4, "Reactor Coolant System
(RCS)," and prepared Action Item C-27 to document the following EA concerns:
(1) The RCS design criteria references design criteria SQN-0C-V-13.3, "Detailed
Analysis of Category I Piping Systems," which specifically excludes consid-
eration of RCS piping.
(2) A lack of definition in the RCS design criteria for the TVA/ Westinghouse
RCS pressure boundary interface.
(3) The need to review other Westinghouse piping systems to ensure the exis-
tence of proper stress qualification criteria.
The DBVP prepared PIR SQN-CEB-8669, Revision 1 (RIMS No. 825-861219-063), to
EA has reviewed
address the concerns that EA identified in Action Item C-27.
the corrective actions documented in the PIR and is (ecoing Action Item C-27
open, pending response to EA's request for additional information.
EA reviewed design criteria SQN 0C-V-27.5, Containment Spray System (CSS), and
prepared Action Ites C-28 to document the following concerns:
failure to reference four design criteria: SQN-0C-V-24.1, "Location and
(1)
Design of Piping Supports and Supplemental Steel in Category I Structures";
SQN DC-V-2.14, "Piping and System Anchors Installed in Category I Struc-
tures"; SQN-0C-V-1.1.2, " Auxiliary Building Structural Steel"; and
SQM-0C-V-1.3.4, "Category I Cable fray Support System"
(2) reference to Civil Engineering Branch interim restart criteria
(3) improper reference to cesign criteria SQN-0C-V-13.8, Seismically Qualify-
ing Round and Rectangular Ouct
(4) reference to civil design guides instead of to applicable design criteria
.. -_. . _ . - . . _
- 13 - _.
i
4
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825-861008-008), to address the
The 08VP prepared PIR SQN-CEB-8672 (RIMS No, EA concurs with the corrective
concerns EA identified
action to address in Actionand
EA's concerns, Item C-27. Action Item C-28 open, pending
is keeping
EA verification of SQM project's corrective actions.
EA reviewed engineering change notice (ECN) L6710 and issued Action Item C-53
to doc ment the following iA concerns:
discrepancies between the pipe support design loads used in the calcula-
(1) tions and the pipe suppo-t design loads tabulated on the load summary
sheets for three pipe supports
(2)
inconsistent definition and use of normalized /unnormalized design loads
for two pipe supports
The 08vP prepared PIR SQN-CEB-3709, Revision 1 (RIMS No. 825-870220-088) to
EA has accepted the proposed corrective actions to
address EA's concerns. EA is keeping Action Item C-53 open, pending EA
address Action Item C-53.
verification of project's corrective actions.
EA issued A: tion Item C 54 to document an EA concern that a temporary altera-
tion contrel form (TACF) which specified the tack welding of the valve bonnet
to the value yolk for two high-pressure fire protection (HPFP) valves had
EA has accepted andnot
been adequstely evaluated for seismic considerations.
verified the 08vP corrective actions to address Action Ites C-54 and has
closed th*.s action item.
EA prepared Action Item C-55 to note that the cumulative effects matrix which
tne 08vP prepared for the high-pressure fire-protection SYSTER did not include
field change notices (FCNs), TACFs, or local design enange requests (LOCRs), EA
and did not include a detailed evaluation of potential synergistic ef fects.
has accepted and verified the 08VP's corrective actions to address Action Item
C 55 and has closed this action ites.
EA reviewed the SYSTER for the residual heat removal (RHR) system and prepared
Action Item C-57 to document the following EA concerns:
(1) An eng',eering change notice (ECN) evaluation did not reference a punenlis
ites.
(21
" ECNs were inconsistently documented.
(3)
The inability to confirm that bolts associated with a partially imple-
mented ECH within the system walkdown boundary identification drawing
(SVBID) had been tercued to the requirements specified on the typical pip
support detail drawing. .
(4) The SCR/NCR evaluations did not identify punchlist items.
(5)
Discrepancies existed between the System Engineer's SQEP-1.2, Attaenm
form and the civil / structural 03VP checklist.
(6)
Restart categori:ation of two i!CNs that involved component analysis was
questioned.
. so .
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(7) An ECN had two SQEP-45 attachments which disagreed on corrective action
and justification for a restart decision.
J
(8) A SQEP-45, Attachment 2 form did not document the corrective action
and justification for restart decision for an ECN punchlist item. l
(9) No restart categorization designations were on the SQEP-45, Attachment 2 l
forms for several punchlist items.
(10) A punchlist item involved components that lack qualification documents.
These components are suoject to potential water spray from Category I(L)
piping. EA questioned the documented restart determination for this
punchlist item.
(11) Discrepancies exist in the restart determination for an ECH punchlist
ites.
(12) Two punchlist items lack a civil / structural evaluation.
EA is currently evaluating the OBVP's responses to each of EA's documented
concerns, and is keeping Action Item C-57 open, pending completion of tnis
riview.
4.3.2 Review of TVA's Resolution of 08VP Punchlist Items
The team reviewed the restart categorization of the following component
cooling water system (CCS) punchlist items:
(1) punchlist item no. 06881 (NCR SQN-CEB-8203)
(2) punchlist item nos. 00756, 00763, 00776, 00777. 00793, 00798, 00802,
00805, 00808, 01229, 04917, 06192, 06208, 06967, 07610, and 08974
(PIR SQN-('B-8638)
(3) punchlist item no. 06241 (PIR SQN-CEB-8657)
(4) punchlist item nos. 00801, 03696, 04544, 04806, 04807, 04810, 04835,
04459, 04871, 06184, 07484, and 07563 (PIR SQN-CEB-8665)
(5) punchlist ites no. 0A??! (Cat. O FCR 4391) .,
The team reviewed the SQEP-45, Attachment 2 form for each punchlist item, and
the DSVP report, "Sequoyah Nuclear Plant (SQN) - Submittal of Design Baseline
and Verification Program (OBVP) Unit 2 Phase I Report," to assess civil /struc-
tural 08VP's restart disposition of the PIRs and associated punenlist items.
The team concurs with the OBVP's post-restart disposition. . ,
The team reviewed 16 (of 185) punchlist items associated with PIR $QN-CEB-8638,
which identify ECNs that were not docum in piping analysis calculation
he project has verified that the
packages or on piping isometric drawing . to tne calculations and design
identified ECN chanama were incorporate
sutous doe = ants. and will update the calculations and drawings to reference~
the taantified ECNs af ter restart.
- _ _ _
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.
6 ,
Punchlist itan 6241 is being closed under punchlistitems
The punchlist itemtracked
4835, which
by PIR
is being tracked by PIR SQN CEB-8665.
SQN-CE8-8665 identify
The theclosed
08vP has lack ofallalternate analysis
(210) punchlist (field-routed
items associated piping)
documentation. Corrective action to address lack of alternate analysis
with PIR SQNCEB8665.
documentation is being performed under the SQN alternate analysis program,
which has completed all Phase I activities required for restart of SQN Unit 2
Punchlist item 8398 documented a minor drawing discrepancy which is scheduled
for correction after restart, and punchlist item 6881 identified a nonconfor-
mance report (NCR) that lacks a signature. The NCR will be corrected after
restart.
The team reviewed the following NCRs to confirm the adequacy of CEB's " internal
and external generic reviews:
(1) PIR SQN-CEB-8637, dated July 21, 1986 (RIMS No. 825 860819-019)
(2) PIR SQN-CEB 8638, dated July 24, 1986 (RIMS No. 825-860730-006)
(3) PIR SQN-CEB-8639, dated July 21, 1986 (RIMS No. 825-860819-016)
(4) PIR SQN-CEB 8657, dated February 20, 1987 (RIMS No. 825 87033-004)
(5) PIR SQN CEB-8665, dated September 16, 1986 (RIMS No. 825-861126-0
(6) PIR SQN-CE8-8669, dated November 14, 1986 (RIMS No. 825-861219-06
(7)
PIR SQN CEB-8670, dated September 25, 1986 (RIMS No. 825 861008-015)
844-870108 007) -
(8) PIR SQN-MEB-86117, dated January 7, 1987 (AIMS No. 844-870108-006) J
(9) PIR SQN-MEB-86118, dated January 7, 1987 (RIMS No.
(10) PIR SQN-NEB-86127, dated January 13, 1987 (RIMS No. 844-870120- '
The team concurred with ONE's decisions to conduct internal and ex
generic reviews for these PIRs as required, except for ME8's failure to con
an external generic review for PIR SQN-ME8-86127.
'
to identify motor operators that were not installed as shown ol
physical drawings.
1
(PGCE)
Sequoyah."
for this PIR, noting that the deficiency was an "isol l
(NRC Observation 3.16).
The team also reviewed the following additional sample of punchlist items
associated with PIR SQN-CEB 8637 for the essential raw cooling water (ERCW)
component cooling water systema (CCSs):
(1) punchlist items 0829, 0831, 0832, and 0876 G r the component cooling
water system.
(2) punchlist items 0828, 0851, 0875, 1186, and 6112 for the ERCW system
0828, 0829, 0875, and 0876 documented missing seismic qualifi .
i Punchlist items
cation documents forPunchlist valvesites installed at SQNmissing
0831 documentec that had been trans
seismic
.
Watts Bar Nuclear Plant. [h
qualification documents for a replacement switch, and
I
l
Punchlist items 0851 and 1186 documented the lack of seismic CateQory I(L)L
paition-retention documentation to cualifvEeral swit.cnes, and punchlist
j
>
item 6112 documented a lack of seismic qualification documents for several
replacement valve motor operators.
l
,
e
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The team reviewed the SQEP-12, Attachment 2A civil / structural checklist forms,
the SQEP-45, Attachment 2 forms and the referenced ECNs for each punchlist item
to confirm that these punchlist items The had
teambeen properly
concurs dispositioned
with the OBVP's postfor restart
post-restart corrective action.
disposition of these punchlist items.
4.3.3 Implementation of Corrective Actions for Punchlist Items
The team reviewed punchlist item 0442 for the ERCW system and punchlist items
7349 and 9005 for the component cooling water system to assess the adequacy of
the calculations that CEB regenerated to resolve these punchlist items.
3 The DBVP prepared PIR SQN-CEB-8639 (subsequently upgraded to SCR SQN-CEB-8714), The
to track the corrective action required for these punchlist items.
civil / structural 08VP wrote a total of 1070 punchlist items to track missing
calculations, out of a total of 1688 valid civil / structural punchlist items.
l
The team reviewed the following sample of regenerated calculations which the
CEB project prepared for each of these punchlist itees:
for punchlist
(1) pipe support calculations 47A450-21-450 and 47A450-21-451
ites 0442
(2) pipe support calculations 2-H10-119 and 1-H10-1128 for punchlist item
7349
1.ist item
(3) pipe support calculations 2-J10-910 and 2-H10-911 for pun
9005.
g
Orop ly imple-
The team concluded that the eticulations prepared b ese punchlist items.
mented the corrective vetion required to resolv
The tean eiso reviewed CEB's implementedral EA had completed overviewino at
rectiveactionsfortwooftheh
three ounchlist itans that civil /struy t item 0925, associated with PIR
Funcn
the time of the insoection.
SQN-CEB-8637, documented missing,peismic qualification documents for a numee
replacement solenoid valves installeo in sne
Punchlist auxiliary
item retowater system
7939, associated with PIRto meet
the requirements of NUREG-0588.
SQN-CEB-8669, documented the absence of design criteria for the reactor coolant
system piping in design criteria SQN 0C V-13.3, which specifically ex
reactor coolant loops. However, the team's review of the
actions to address the:e punchlist items.
work plan which installed the replacement solenoid valves in the auxiliary
feedwater system indicated that two support configu:ations for solenoid valves
mounted in the radiation monitoring system lacked CEB seismic qualification
calculations 'NRC Observation 3.17).
4.3.4 Rsview of EA and OBVP Reports
The team reviewed the OBVP report entitled "Sequcyah Nuclear Plant (SQN)
- Submittal of Design Baseline and Verification Program (DBVP) Unit 2 Phase 1
Report," dated May 29, 1987 (RIMS No. B25 87059-010), and EA's Oversight Review
Report EA-0R-001 entitled "sequoyah Nuclear Plant - Unit 2 Design Baseline ano
" - - -- - - - - - - - - - _ _ _ _ _ _ _ _ _ _
.
.
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29, 1987. No problems were identified during
Verification Progras," dated April
this review beyond the issues identified previously in Section 4.3 of this report.
4.4 Nuclear Enoineerina
4.4.1 Corrective Action Associated With Engineering Assurance Oversight of
the 08VP
The TVA Engineering Assurance Oversight Review Report (EA-0R 001) listed Theseseven
observations (N1 through N7) for the Nuclear Engineering Branch (NES). The
seven observations embodied numerous action items identified earlier.
team reviewed each of the EA nuclear observations from the standpoint of the
adequacy)of
resolved
the agreed-upon corrective action (if the ites w
the corrective action.
The team found that each of the seven EA nuclear observations were c
resolved relative to having a corrective action that has been agreed to by both
EA and the project NEB.
In one instance (N6), EA's review of the implemented
corrective action resulted in the status being changed from "resolved" to
"unresolved". ThisThe project responded with a five step approach to the correc-
revised approach was agreed to by EA and the observation was
tive action. The team found the steps taken regarding
again given a resolved status.
Observation N6 to be adequate.
The team reviewed the proposed corrective action for each of the The EA
teamobservation
met
and found them to be representative of the concern and adequate.
with the EA nuclear staff to discuss their approach for verifying of the imple-
mentation of the corrective action.
The team questioned the representativeness of the EA verification approach with
respect to EA Observation N4. The thrust of this observation was.to reconcile
the restart category and status between the SYSTER (inclu
punchlist.
The purpose of the closureEAstatement is to ensure invol
proposes to verify proper implementa-
punchlist items developed by the DBVP. tion by selecting punchlis
The team feels that since the
the SYSTER plus addendum and the punchlist. reconciliation is be
involve a sample of systems for which each associated punchlist item is
checked for restart category and status consistency.
The team inspected the remaining EA observations and found that both the agre
to corrective action and the proposed appresch by EA te verify proper ,
implementation were adequate.
The team reviewed the SQEP-45, Attachment 2 forms and the associated pur
items for consistency. This was part of the team's effort to independently
The team found
assess the planned corrective action and restart category.sev
for the restart category; however, the punchlist notation was changed from
"required for restart" to "not required for restart."
.
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.
The term was concerned and believed that the problem could have arisenThe because
of the procedure that controlled the entry of data into the punchlist.
team feels that TVA should resolve the problems so that thei information con-
tained on the punchlist is accurate and usable (NRC Observation 7.5).
l
4.4.2 Review TVA's Resolution of OBVP Punchlist Items. f
It was not M l
The team reviewed the resolution of several punchlist items.
during this review that punchlist iteia 4426 had been reclassified from
pre-restart to post-restart. Punchlist item 4426 and SCR SQN-NEB-8615
identify the corrective action to provide safety grade auxiliary control air
to System 90 radiation monitor supply valves in order to meet theThe requirements
punchlist
i
of Regulatory Guide 1.45 and design criteria SQN-0C V-9.0 R2.
ites has been reclassified as post-restart and closed based on this reclassifi-
cation. Continued use of non-safety grade air can cause loss of capability to
maintain airborne monitoring capability following a safe shutdown
Furthermore, a loss earthquake
of non-safety-
(SSE) as reouired by Regulatory Guide 1.45.
grade air will not cause containment ventilation isolation, as claimed in quality
information request (QIR) NEB-86241.
The inspection team was advised that TVA is currently Evaluating QIR NEB-86241.
The reclassification of punchlist item 4426 and the present status of QIR
NES-86241 are the bases for NRC Observation 4.8.
4.5 Electric Power
4.5.1 Corrective Actions Associated With EA Oversight of the 08vP
l
In the electric power discipline, the NRC team reviewed EA's process for
l
( resolving those action items for which the 08vP and/or SQN 2roject's r
was found to be satisfactory.
items for which the corrective action either has been completed, or has been
defined by the project and accepted by the EA group.
In the electrical discipline, the E4 review of the OBVP resulted in 91 action
items. Twenty-three action items remained open when report EA-0R-001 was
i s ned. These were grouped where desirable and converted into 14 EA observa- The
tions. The team noted that all 14 of these observations were resolved.
Satisfactory resolution
team reviewed the resolution of selected action itemt.
of each action item was based upon review of the response addressing proper
resolution of the concein, assessment of the cause, extent, action to correct
the concern, schedule of implementation of the corrective action, action to
prevent recurrence, end significance of the concern for the design function o
the safety system. The following paragraphs sumariZe the EA observations that
the team reviewed.
Observation E1: This coservation involves Action Items E87 and E88.
Action Item E87 related to a discrepancy involving drawing 45N727 and walkdown
The drawing discrepancy was scheduled to be corrected
package (WOP) 82-52.
before restart.
l
Action Item E88 related to errors involving the recordingAofsupplemental
incorrect walkdown
walkdown
'
data for 480 V breakers in the auxiliary power system.
---.
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.
.
.
be
)
for 31 samples was performed for this action item and an additional error was j
noticed by EA. Therefore, a 1005 comparison of as-constructed and walkdown
This review revealed
drawings of the 440V breaker trip settings was initiated.
several more discrepancies.
The NRC team questioned why these discrepancies between actual settings on the l
breakers and setting data on the as-constructed drawings had not been spotteo
The team was told that during surveillance
during surveillance testing.
testing the test technicians failed to readjust the settings to their pre-
testing position. To prevent this error in the future, TVA revised surveil-
lance instructions $1-275.1, Revision 8; SI-275.2, Revision 12; SI-258,
Revision 11; and 51-258.2, Revision 13.
Observation E2:
This observation involves Action Item E57, which was related
A test was
to acceptance of failed test results without 2945, in accordance
performed for engineering change notice (ECN) justification. with
procedure TVA-22, which requires verification that a 10*F temperature differen-
tial between outside air and the de ventilation fan exhaust is not exceeded to
prevent overheating of the controller. The testing verified a successful pump
run for 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, but failed to meet the 10'F temperature differential
requirement. The consequences of excessive heating were corrected before the
test by moving the controller to a cool area and insulating the heat sources.
As a result of these measures, the 10*F temperature differential condition
Corrective was
action
no longer required, but the test procedure was not revised.
for this action item includes revision of test procedure TVA-22 to remove the
10*F differential temperature condition.
Observation E3:
This observation involves Action Items E51, E53, E55, E64,
E55, E69, E72, and E75.
Actions Items E51 and E53 identified that reviews per the SQEP-12 checklitit for
In response
ECN 6712 and ECH 6676 failed to address cable sizing requirements.
to these action items, the 08VP referenced the cable ampacity prog' ram in The lieuNRC
of
verification of sizing and thermal ratings for the ECN-specific cables.
team noted that the 08VP took similar credit for caDie sizing evaluation for all
ECNs that involved power cables. The ampacity program is based on statistical
sampling. In light of this fact, the team was concerned about the validity
The cable program is being
of 100 percent review for each affected ECN. Acceptability of
reviewed separately by the NRC Office of Special Projects.
this program will be separately addressed by the Office of Special Projects.
Action Ites E55 involved a motor replacement with a larger horsepower In motor
per ECN 2945, without evaluation for sizing of the motor overloads.
response to this action item, the SQNAction projectItem
evaluated and replaced
69 involved the
minor drawing
overloads per work request 8222144.
discrepancies between ECN 6573 drawings, which were corrected by the project. -
EA c'osed this action item after verification.
Action Item E64 identified that the voltage range of Brown The Boveri relays
project may
contactec
not be compatible with the vit.a1 de power voltage range.
the vendor who confirmed by letter that the range of these relays (70 V-142 V)
was compatible with the voltage range of the de vital power system.
,
, , . - , - y, ,- , . - - - ^*
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Action Items E65 and E72 were generated to track concerns identified during
ECN 5363 review.
Action Item E65 identified design discrepancies relating te
response time evaluations and discrepancies relatingThe to the improper
project resolved tnese
referencing of 10 CFR 50 Appendix R calculations.
discrepancies and the action item was consider (d resolved by EA. Action Item l
E72 identified that the design of an ECN did not meet the design objectives.
This action item was initiated to address NRC Observation 5.7 of inspection
The NRC team reviewed the project's ,
report Nos. 50-327/87-14 and 50-328/87-14. '
response to this action item and noted that the response did not consider TVA
a
detailed evaluation of all postulated conditions of plant operation.
subsequently submitted a revised response detailing its resolution of this
item. Action item E75 identified tnat the 5 QED-12 checklist did not adequately
address the problem of imposed voltage for the failure mode analysis. This
corresponds to NRC Observation 6.14, which is addressed in Appendix 8 to this
report.
Observation E4: This observation (Action Item E10), was generated by the
electrical EA group to identify that the review scope of SQEP-11 did not
address technical evaluations of potential generic conditions evaluations in
the 08vP. The DBVP resolved this concern by directing engineers (via memo
86-17-04, dated June 13, 1986) to perform a 100 percent review of the elec-
trical potential generic conditions evaluations (PGCEs) for problems identified
at other TVA plants which may have an impact on the Sequoyah design. Procedure
NEP-9.1 addrasses evaluations of the effects of the PGCEs for Sequoyah on other
TVA plants. On the basis of the above OBVP response, EA has resolved this
observation.
Observation ES: This observation was initiated to trac'k 35 action items
covering all disciplines. These action items are related to items concerning
the commitment / requirement database and appropriate capture of commitment /
requirements in the applicable design criteria. EA has resolved this coserva-
tion.
Observation E6: This observation involves Action Item E25, which was initiated
to identify tnat a number of electrical design requirements were not captured
in me:hanical design criteria SQN-0C-V-11.8 RO, "Diesel Generator and Auxiliary
Systems." The project included all the required missing Theelect
c^3'.a1
of criteria
the in
the current revision of design criteria SQN-0C-V-11.8.
missing criteria on the diesel system was evaluated. This res,.-tse from the
project was found acceptable by the EA group and this observation is now
considered resolved.
' t .a vation E7: This observation involves Action Item E26, which identifiec
V '.o ting requirements were omitted from design criteria SQN-0C-V-11.6 R3.
" tal Instrument Power System." The project intends to include the
Pending
..
+ test requirements in the latest ravision of the criteria.
vo i' ation of the project's response, EA considers this observatier, resolvec.
Observation E8: This observation involves Action Item E31, which identified
missing references in design criteria SQN-0C-V-27.5 (preliminary), "Contain- J
cent Spray System." The project plans to incorporate the missing references
Pending verification of the
in the next revision of these design criteria.
project's response, EA considers this observation resolved.
I
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4
This observation involves Action Item E74, which identified
Observation E9:
inappropriate labeling of Class 1E cables
8214300, for the
8218263, andreactor
8218266protection
to install thesystem.
The project issued work ordersEA reviewed the tagging and found itThis observa-
acceptable.
proper tags.
tion is now considered closed by the EA group.
This observation involves Action Item E77, regarding directive EA .as
Observation E10: which eliminated all open CAQs from the 08VP review scoce.
08vP 0-86-019
concerned that non-0BVP personnel performing reviews of open CAQs would not h
sufficient information to conduct the review adequately. The 08VP responded tnat
open CAQs will be reviewed in accordance with the guidelines of procedure N
This response was accepta01e to EA and EA considers this item resolvad.
This observation involves Action Item E80, which was initiated
Observation Ell:
to identify a concern that three change documents were not included in the
SYSTER evaluation package for System 82. The project respondedEA thatverified
the
missing documents will be included in an addendum to the
this observation closed.
Action
This observation involves Action Items E83 and E85.
Observation E12: Item E83 identified a mismatch of the restart catefory for punc
E3586 and E6301 between the vital power system SYSTER ev
SQEP-45 punchlist.
PIRs as originating documents were improperly downgraded to post-restartTo cor
items based solely upon their categorization as PIRs. instructing all the. responsible
the 08VP issued a directive (0BVP-0-87-002),
System Engineers to re-review the restart category of applicable pun
items on the basis of system function.
Action Item E85 noted that several SQEP-45 punchlist items were omitted
from the vital power system SYSTER and several confif eted with th
categorization in the SYSTER. items will be included in the SYSTER t pa
will be re-reviewed for restart category based on functionalty of the sys emTh
in accordance with directive 08VP-0-87-002.
This observation involves Action Item E90, which identified a
Observation E13:
concern that unimplemented ECNs 5668 and 2656 were incorrectly evaluated a
This incorrect restart decision also raised a general
required for restart.
concern that appropriate restart criteria were not used in making The 08vP the restart
responded
decisions for unimplemented and partially implemented ECNs,
that ECN 5668 and ECN 2656 would be addressed correctly in the auxiliary po
The OBVP indicated that all of the unimplemented and
system SYSTER addendum.partia11y implemented ECNsEAnsve now bee
verifico
Practice SQA-183 and directive OBVP 87-005.
per Sequoyah Standardthis by sampling five ECNs (out of total of 34 re-rev
electrical discipline) and 'ound the evaluation acceptable.
00servation resolved.
Observation E14:. This observation involves Action Item E91, wnich identifie
concern tnat corrective action In defined for the
addition, punchlist
restartitem 6399was
category did notnot address
the full scope of the proolem.The project response included the correct r
defined.
. I,2 -
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. I
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the punchlist ites and the revised scope of the corrective action addressed the
probles completely. The project's response was acceptable to the EA group.
4.5.2 Conditions Adverse to Quality Reports (CAQRs)
The NRC team also reviewed the handling of conditions adverse to Quality
(CAQs) to assess TVA's corrective actions for both SCRs and significant The CAQRs
identified by the 08VP within the scope of the electrical discipline.
team's review included CAQR SQE-870-R01-004 generated by EA and two randomly
selected OBVP generated reports (SCRs SQNEES-8771 and SQNEEB-8790).
This CAQR was written in response to Action item E50.
ACARSOE-870-R01004:This action item identified that no indication of the ope
~
generator and electrical panel ventilation fans was provided in the main
control room. These fans are required to start (in accordance with the
technical specifications) in order to keep the diesel inlet air temperature
Since there is no remote indication for operation of these
at 120'F or less.
fans, the plant could be operating outside the technical specification
The nominal condi-
setpoint for
tion without the knowledge of the plant operator.
starting these fans is 80'F. The project responded that:
- The 120*F ambient temocrature limit can only be exceeded with one diesel
generator running. Any time a diesel generator is running, operation of
these f ans is verified per operating instructions.
- Oiesel generator room temperatures are monitored once per shift; if
abnormal temperatures (acove 80*F) are noticed, temperature readings
are taken every hour.
redundant
- Failure of ane fan to operate constitutes a single failure:
fans remain operable.
The NRC team considered
EA accepted this response and closed this CAQR.
tnis response acceptable.
SCR SON-EEB-8771: This SCR identified a situation in which Class 1EIndocuments error,
were revised by a local design change request (LOCR SQ-0CR-L-1745). Corrective
this modification was classified as non-safety-related.
included reversion of all TVA drawing changes since the TVA
Because drawings could be
the (subsequent)
used for field settings of ampacity trip The sensors. revision
project informed theof drawing
team
was no longer required, tnis ECN was cancelled.
that
issued.
the error was caused by lack of proper procedures w
used for safety related modifications. The NRC team found the corrective ac
and the action required to orevent recurrence acceptable.
This SCR identified a concern that drawings 45N749-1 througn
SCR SON-EEB-8790:
4, whien are part of tne "SQN-Restart Design Basis Document," did Correc- not show or
reference the breaker trio setting data for the 480V shutdown boards.
tive action requires the project to revise these drawings to either includeProced
adequate references or snow tne setting data on the drawings.
requires the lead engineers to nave all drawings prepared in accordance
-.
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,
This procedure requires
with Division of Nuclear Engineering Standard 7.01.
all related drawings that are not listed as companion drawings to ee inclueed
as a reference. According to NEP-5.1, revisions to drawings are nancied in tne
Corrective action and action required to
same sanner as original drawings.
prevent recurrence of conditions reported in this SCR were considered acceotable
by the NRC team.
The NRC team found EA's approach for identification, resolution, and/or closure
of the action items and observations acceptable. The approach was considered
to meet the technical objectives of the EA oversight program for the OBVP.
4. 6 Instrumentation and Control
4.6.1 TVA Corrective Actions for EA Oversight of the 08VP
The following Engineering Assurance observations were reviewed. Action taken
or planned was found to be acceptable:
EA Observations E3 (corresponding to EA Action Item E-75; NRC Observa-
tien 6.14), E9 involving RPS cable tagging in the turbine building, 11
involving upper head injection system design inconsistencies, and I2
involving steam generator level transmitter accuracy.
A number of EA action items were reviewed and found to be satisfactory, such
as I-22, I-23, I-24, and I-17. Thirty punchlist items being tracked by EA
were also reviewed, and the EA approach was considered satisf actory.
This involves a
EA has maintained Observation 13 in an unresolved status.
power supply modification for transmitter change-outs and the addition of a
diede to a control switch. The team found EA's closure of the transmitter
power supply to be satisfactory, and agrees with EA that TVA needs to provide
an analysis to confirm that a commercial'y procured diode is acceptably
dedicated as a Class 1E component in the control switch modification.
EA reviewed the OBVP supplemental walkdown results of sensing linas and con-
cluded that there was no pervasive as-constructed inadequacy (TVA report
EA OR 001, page 7.2.3-3). On the basis of two walkdown results involving HVAC
instruments, the team recommended that TVA consider a 100 percent walkdown
of the HVAC systems. TVA has subsequently performed a walkdown of protection
and control interlocks for the HVAC systems, and has issued a CAQR for the
inadequacy of HVAC instrumentation design drawings.
EA reviewed Action Item I-22 for tne upper-head injection tank level switen
substitution, and confirmed that the accuracy calculation indicated that the
The team agrees with EA's review and
present switches were not satisfactory. ,
conclusions regarding nis item.
EA Action Items I-23 and I-24 dealt with the addition of tne westingneuse
setpoint document as a reference in a numeer of TVA design criteria documents.
The team reviewed TVA's corrective actions for this item and found them to De
satisfactory.
EA Action lier I-17 addressed the erroneous categorization of a source document as
"not applicable" for the licensing commitment program. The tsaa confirmed snat
- 24 -
.
.
the TVA Nuclear Engineering Branch performed an adequate re-review of these
"NA" designations given to a number of source documents (EA Action Item s.25).
4.6.2 TVA Resolution of OBVP Punchlist Items
The team reviewed approximately 12 PIR/SCR/CAQR sets of records in the OBVP
V
?1+ctrical and instrumentation areas involving inadequate corrective action, ' G
separation criteria violations, failure to meet design criteria, inadequate
equipment conditions, lack of electrical calculations, and the temocrature
range evaluation of the refueling water storage tank transmitter. In this
area, the team generally agreed with TVA's resolution for OBVP punchlist
items.
The planned analysis approacn described in CAQR SQT-871198 for punchlist item
7843, involving the potential for unintended blowdown of more than one steam
generator, was deemed to be satisfactory.
The approach taken for punenlist item 8482 in SCR SQN NEB 8722, involving
postaccident monitoring channel 1 separation from non-safety-related wiring, was
found to be unsatisfactory (NRC Observation 6.21).
The corrective action analysis for the added isolation power supply in response
to punchlist item 6971 was satisfactory.
TVA's corrective action for punenlist item 7658, involving both a slope change
to the sensing lines between the A N pump suction piping and the associated
pressure switches and new process pipe tap locations, was assessed as appro-
priate.
4.6.3 Implementation of Corrective Actions for Punenlist Items
Because of the early stage of corrective action implementation, only several
examples were available for inspection. As mentioned in the previous section,
corrective action implementation in the analysis area appeared responsive and
appropriate. However, the team identified one situation in which the correc-
tive action concurred with by the OBVP was technically questionaole, in that
the revised corrective action allowed auxiliary control air pressures
considerable below design criteria requirements following a postulated LOCA
with an adverse auxiliary control air interaction (NRC Cbservation 6.22).
4.6.4 EA and DBVP Phase I Reports
The team reviewed the applicable sections of TVA Report EA-0R-001 addressing
These reports were
the EA oversight effort, and the OBVP Unit 2 Phase I Report.
considered to generally reflect the results of the EA oversight effort and tne
DBVP, respectively. NRC Observation 6.20 (Appendix B) addresses several
concerns with characteri:ation of selected conclusions in the OBVP report,
o
The team also noted that the OBVP report was silent on tne content of i
SCR SQN-EEB-8743, wnien reovired relocation of AFW instrument sense This lines for ;i
pump suction pressure switenes 2-PS 139A, B, 0 and 2-PS-3-144A, B, O. 0
plant modification was needed to ensure proper operation of the ERCW
supply valves to AFW.
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AFW systes. This SCR resulted in a significant hardware change to the plant,
but was identified only as a calculational deficiency by the OBVP report.
4. 7 Civil / Structural
_
4.7.1 Corrective Actions Associated with EA Oversignt of the OBVP
EA observation C1 contains EA Action Item C-21, which identified an ECN that
was thought to affect Unit 1 only; however, a more in-depth review indicated
that Unit 2 was a' o modified by this Unit 1 ECN. The Sequoyah project issued
As corrective
PIR SQN-MEB-8659 (tl44 860910 006) to resolve this action item.
action to this PIA, the project reviewed all ECNs that purported to apply
solely to Unit 1 and found two additional cases in which the ECNs actually
affected both units. EA is waiting for ravision of the SYSTERs
Tne NRC
to include
team concurs
these identified ECNs before closing this observation.
with the resolution of this action item.
EA observation C4 contains EA Action Items C-46 and C-56. Action Item C-al
stated that adequacy of partially implemented ECN L5779 was not evaluated by
the civil engineering group of the DBVP. The unverified support variances
could have affected the supports for a bypass line. The project has stated
that partially implemented ECNs are reviewed per SQA-183 and that the SYSTER
which includes ECN L5779 would be reviewed by the civil 08VP. EA is keeping
this action item open pending the review of the regenerated support variance
calculations and the verification of the SYSTER which includes this ECN.
Action Item C-56 raised questions regarding the adecuacy of the r.esolution for
various punchlist items that were reviewed by EA. The response to this action
item shows that a DBVP directive, OBVP-0-002, issued on March 13, 1987, requires
that all punchlist items be sigred by the System Engineer and the Discipline
Evaluation Supervisor before a particular punchlist item can be closed. The
DBVP also committed to reevaluate all punchlist items which were c.losed before
this directive was issued. This action item is being kept open by EA until the
DBVP completes this review.
The NRC team reviewed the available documentation regarding Action Items C-41
and C-56. The tea.1i concurs with the resolution of both of these action items.
EA Observation C5 contains EA Action Items C-3 and C-44 Action Item C-3
questioned the technical adequacy of several change documents. The technical
adequacy question related to calculations which support the change documents,
as well as drawing discrepancies which were discovered during the reviews
performed by EA. EA also raised questions regarding field change requests
(FCRs) which were not adequately reviewed for technical adecuacy. The SQN
project response stated that review of calculations supporting the change
documents was part of the calculation review program which would separately
verify technical adecuacy. The project's corrective action for this EA action
item does not address the concerns raised by EA regarding drawing discrepancies
and FCR evaluations. This action item was still being followed ey EA because
The NRC questioned the resolved"
of the lack of defined corrective action.
status of this observation since there was no planned corrective action statec
by the project.
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In response to the NRC concern, EA changed the status of observation C5 to
"unresolved." The project, in turn, revised its response tc, EA to address
resolution of the discrepancies between the calculations and drawings. EA
plans to verify that such considerations are properly addressed by the project.
Action Item C 44 is related to Action Item C-3 since EA review of ECN 1,6213
showed discrepancies between the calculation and drawing related to this ECN.
A field walkdown showed that the calculation was correct and the drawing was
wrong. The project response for this action item was acceptable to EA since
the particular drawing discrepancy was resolved by the walkdown tad be.cause
the generic implications of drawing discrepancies would be covered under
action Item C-3. The resolution of this action item was acceptable to the
NRC team.
Observation C6 contains Action Items C-28, C-37, C-40, C-47, C-53, C-54, and
C-57, which all relate to various deficiencies in the civil engineering group
of the 08VP. In the civil / structural area, the team reviewed Action Items l
C-37, C-40 and C-47. ,
1
Action Item C-37 stated that the SQEP-12 review checklist for ECH 2944 R1 did
.
I not reference calculations relating to a pipe support drawing change. Later l
.
evaluation of this problem showed that the calculations for this particular
support were missing. The project has regenerated the missing calculations
under PIR SQN-CEB-8639. The project also reviewed the SQEP-12 Attachment 2
form of the related SYSTER to ensure that this ECN was appropriately captured
in the SYSTER. These corrective actions were acceptable to EA and the action
item was closed. The NRC team concurs with the resolution of this action item,
i
Action Item C-40 raised questions about improper incorpJration of ECH
reviews into the system evaluation checklists by the System Engineers. This
was a documentation problem and the DBVP has revised the checklists to
include the correct information. The OBVP also stated that discipline
reviews of draft and final SYSTERs, as required by directive 06VP-t 36 010,
would ensure the accuracy of the final version of the SYSTERs. EA has accepted
this response and closed this action item. The NRC team concurs with the
resolution of this action item.
Action Item C 47 was written to address NRC Observation 7.4 - Project Review of
Support Variance (NRC iaspection report Nos. 50-327/86-55 and 50-328/86-55).
The NRC observation raised questions about the OBVP's review of ECN-5298. In
response to this action item, the SQN project has regenerated the missing
support variance calculations. EA is keeping this action item open pending
the review of these regenerated calculations. The NRC team concurs with the
resolution of this action item.
4.7.2 Resolution of CBVP Punenlist Items and Implementation of Corrective
Actions
The team reviewed the corrective actions taken by the project for various
punchlist items that were generated as a result of the 08vP. Samples were
selected in the following areas (as described in the Sequoyan Unit 2 CBVP
Phase I report, Section H-1):
- _ _ _ _ _ _ _ ___ __________mM____________________
.
.
. .
- sissing calculations
- open FCRs
- no evaluation for pipe rupture
- inadequate design
Samples in each category were picked by the team. The corrective action was
reviewed systematically. The sheet identifying the punenlist item, SQEP-12,
Attachment 2B (the civil attachment sheet), was reviewed in conjunction with
the calculation which resolved the deficiency to determine whether the
corrective action was comprenensive. The calculations were also reviewed
cursorily to determine whether they were technically adequate. The following
are the team's comments on the corrective actions reviewed.
(1) Missina Calculations
The DBVP review showed that calculations for some cuages could not be
found.
Punchlist item 449 relates to a missing calculation that could rot be located.
The civil design review checklist (SQEP-12, Attachment 28) for ECN t,5569 shows
that supporting calculations for drawing 48N1314-1 Revision 2 could not be
found. In order to resolve this punchlist item, the project has performed
calculations (825-870324-304) to show that the protective structure (MK-6)
for the ERCW pleing is acceptable. The team found that this corrective action
by the project addressed the punchlist item.
Punchlist item 472 identified that FCR 3490, which is related to ECN L6233, was
written for a variance to support 47A056-51. The civil design review check-
list (attachment 28) identified that the calculation for the variance could
not be found. The project has performed additional calculationsThe(B25-851202-
team agrees
300) to show that the variances to 47A056-51 are acceptacle.
witn the resolution of this punchlist item.
Punchlist item 506 was written to address missing calculations for drawing
41N353-14 Revision 1, which added a battery rack foundation under ECN L5599.
Attachment 2B of the civil design review enecklist shows that these calcula-
tions could not betofound. The project nas performed additional calculations
show that the pads and the anchor eolts for the battery
(825 870407 327)
rack are acceptable. The team found the resolution of this punchlist item
to be appropriate.
Punchlist itse 3772 identified that no calculations could review
The civil design be found for list
chec< variance
47A055-78-Al to typical succort 47A055-78.
(attachment 28) for ECN L5207 snowwd that FCR 142 was written for th
but the OBVP reviewer could not locate any calculations relating to this
variance. The project 9as generated calculation 825-870513 302 to snow that
this variance to the typical support is acceptable. A cursory review of tnis Tne
calculation snowed that it addressed tne correct variance to tne support.
team agrees with the raisolution of this punchlist item.
Punchlist item 6136 relates to missing calculations for typical conduit
support 47A056-151. The civil design review checklist (Attachment 28) for ECN
L5299 shows that calculations relating to 47A051-151 for FCR 451 could not be
located. In order to resolve this punchlist item, the project has performed a
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I
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computer analysis, 825-870507-303, to show that the support is acceptaele. The
team reviewed this calculation and concluded that it addresses the puncnlist
item appropriately, l
!
Punchlist item 9291 identified that no calculations could Thebe found
cdvil for review
design tne
reinforcing bar cuts that were approved in FCR 1682.
(checklist Attachment 28) for ECN L5429 shows that drawing 41N736-1 was revisee
for reinforcing bar cuts, but no calculations could be located. The project nas
performed an evaluation, 825-870401-319, to resolve this punchlist item. It nas
concluded that the structural integrity of the operating deck floor slab has
not osen compromised by the reinforcing bar cut shown on drawing 41N736-1. The
team concludes that this resolution addressed the concern raised by the
punchiist item.
(2) Field Change Requests (FCRs)
The OBVP identified various ECNs with open FCRs. At the time of the OBVP review,
documentation for these open FCRs was not available and an engineering evalua-
tion could not be made. The team reviewed the following punchlist items
relating to this OBVP finding:
Punchlist item 939 was written to identify that the review of ECN L5220 showed go
S. FCR 3833 Revision 2 to be open. This FCR was initiated to approve variances to
conduit suceert ,47A056-10538. The documamation package provided ov tha
,,. r Toject, includino calculations Tf5570225W, snow.o snat Revision 3 of the
The changes were not
g[S FCM cfncelled these variances to the conouit support.
~
implemented and the FCR was closed as documentea in 825-8 3 617. The team
found tne closure of this punchlist item appropriate. g
Punch 11st item 954 was written to show
The FCR wasthat FCR
issued to 4023 (related
recuest to ECM
a variance L6533)
to typical
was not closed out by DNE.
conduit support 47056-1002. The documentation provi:ed by the project showed
that calculations (825-860806-306) were performed to qualify the variances to
the typical support. The FCR was closed as shown in document 825-860820-602.
The team agrees with the closure of this punchlist item.
Punchlist item 964 stated that FCR 4010, relating to ECN L6553, was open at the
time of the DBVP review. The FCR was written for variances to conduit typical
support 47A056-1066. The documentation reviewed by the team showed that
calculations (825-860814-304) were parformed to evaluate tne support variances.
Also, the FCR was closed, as shown in document 825 861022 685. The team found
the closure of this punchlist item appropriate.
Punchlist item 1189 was written because This FCRFCR
4076was
waswritten
ocen atto the
covertime of the
CBVP review of corresponcing ECN L6533.
variances to typical concuit support 47A056-10004 Calculations provided ey
This FCR
the project (825-860717 307) show that tne variances were Theacceptable.
team agrees witn tne
was then closed as shown in document 825-860807-616.
closure of this punenlist item.
Punchlist item 6252 was written because FCR 4581 was open at the time of revie-
for ECN L6649. The FCR was writton The to obtain approval for several variances to
calculations provided by the praject,
typical conduit support 47A05-114A.
825-861029-389 and 825-861029 392, showed tnat the variances were acceptacle.
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_ _ _ _ _ _ _ _ .
.
.
.
825-861118-621. The
The FCA subsequently was closed as shown in document
closure of this punchlist item is acceptable to the team.
(3) No Evaluation for Pioe Ruoture
The 08VP review found that for various cases, incomplete or no pipe ruptureE
evaluations were made for plant modifications.The team selected four samples
by a punch 11st item. The selected punenlist
the closure of the punchlist items was appropriate. items and the
ECN No.
Project evaluatirnnAIMS No.
Punchlist item
L2775 841 870611 006
2711 841 870228 016
2729 L5194
1.6533 841 870617 004
4490 841 870228 030
5187 L5594
The review of the above documentation However, showed the that
The team did not perform a detailed review of these evaluations. was reviewed to
civil design review checklist (attacnment 28) for each ECN
determine whether the concern identified was covered within the SQN proj
The team found the closure of these punchlist items to be
evaluation.
appropriate.
(4) Inadecuate Design
The review performed by the OBVP In theidentified various
civil / structural ECNs
area, therethat
werehad tec
inadequate calculations or analysis. The team reviewed the resolution
only two ECNs with such a classification.
of both punchlist items.
Punchlist item 4775 identified The SCR was deficiencies
written to cualify the in 1/4-inen
the resoluti
The project nas performed a
which was related to ECN L6759.
surface-mounted plate attached to the crane wall.to snow that the 1/4-inen plate
computer analysis (825-870107-801)A cursory review of this calculation sh
The team found the
)
ally adequate. raised by the punchlist item were considered properly.
closure of this punchlist item appropriate.
Punchlist item 7720 was written to document that an incomplete ana
performed for pipe support 17A586-2.
ment 28) for ECN L6322 snews that the monorail load was not included
analysis performed for oice support 17A586-2. to snew l
loacs.
the SQN project has ;erformed additional calculati '
The team agrees with tne resolution of this punchlist item.
The team also reviewed punenlist Theitem 6189, which
civil design review had already
enecklist (attacn-been re
EA, to assess appropriate closure.
ment 28) for ECN t.6263 identifind a discrepancy in the length The SON of a s
brace as shown in the calculations and the as-constructed drawings. I
project's response snowed tnat tnis was a drawing discrepancy and th
- - - __ -.
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,
.
SQN project has revised the drawings to show the correct length of the crace. {'
The team, as **ll 44 EA, found tne closure of this punchlist item adequate.
Overall in the civil / structural area, the limited samples reviewed by tne team
showed that the punchlist items are being resolved properly.
The NRC team also reviewed 15 punchlist items to determine the adequacy of the
restart categorization (punenlist items nos.: 518, 527, 728, 817, 821, 862 .c
955, 4749, 4907, 4993, 6066, 6218, 7462, 7619, and 9304). The team noted snat MI
4 of the 15 punchlist items (nos. 518, 955, 6066, and 9304) were shown as L
post-restart items in the computer listing. A review of the SQEP-45, Attacnment!
2 forms showed that these items were actually determined to be pre-restart !
items. The team believes that there are many discrepancies between the
i
i
punchlist and SQEP-45, Attachment 2 forms regarding the categorization of I
the punchlist items, and that the accuracy of the punchlist should be verified
before restart (Observation 7.5).
Overall, the team concurs with the categorization of the punchlist items for
restart and post-restart in the civil / structural area.
The team reviewed the appropriate sections of TVA report EA-0R-001 covering
the EA effort for the OBVP and the OBVP Unit 2 Phase I report. As shown [r,
above, the team selected samples to determine whether the items identified
by EA and the OBVP were addressed and closed properly. The review of tnese
reports and the limited samples did not identify any major deficiencies.
5. OBSERVATIONS
Specific findings of individual NRC discipline inspectors are categorized as
"observations." These observations elaborate on the general coments stated in
this report and in some cases provide additional comments not considered to be
of a general nature. The observations identified by each discipline of the
NRC team are provided in Appendix A of this report. TVA actions relating to
individual observations will be reviewed by the NRC. Individual observations
may be closed on the basis of TVA's response to this inspection report as
appropriate. Selected items, noted as confirmatory items, remain Open, pending
TVA confirmation that the indicated action has been ccmpleted.
6. REVIEW OF PREVIOUS INSPECTION FINDINGS
The team reviewed TVA's responses to the deficiencies, unresolved items,
and observations documented in the following previous NRC inspection
A
reports:
4 T
- 50-327/86-27 and 50-328/86-27 '#
- 50-327/86-38 and 50-328/86-38 #-
- 50-327/86-45 and 50-328/86-45
- 50-327/86-55 anc 50-328/86-55 ,
l
- 50-327/87-14 and 50-328/87-14 /
Details about that review can be found in appendix 8 to this inspection
report.
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7. MEETING SIM4 ARIES - REFERENCES
A summary of the meetings held relating to the OBVP inspection and a list of
references related to the series of design control inspections are provided in
Appendix C.
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APPEN0!X A
OBSERVATIONS
l
The observations identified by the team d'aring inspection 50-327/87-31 and
The observation nymoers
50-328/87-31 are described in the following sections.
used continue the numeering system used for previous NRC inspections of ne
,
08vP.
Observation 3.16 - Valve Motor Operator Orientation
On January 13, 1987, the Mechanical Engineering Branch (MEB) prepared proelem
identification report (PIR) SQN-MEB-86127 to document differences between the
installed orientations and the physical piping orientations of ten component
cooling water system (CCS) valve motor operators. MEB did not request a
potential generic condition evaluation (PGCE) to determina if a similar
condition existed for other piping systems at (SQN), or at Browns Ferry,
Bellefonte, or Watts Bar.
The team questioned the lack of a potential generic condition evaluation for
this item, and later learned that on May 27, 1986, MEB had drafted an informal
memorandum to request that PIR SQN-MEB 86127 be revised and reissued to require
a PGCE.
The team concurs with MEB's request to reissue the PIR, but notes that
MEB had not yet reissued tne PIR. The team also notes that the Civil Engineeri.ag
,
Branch (CEB), assigned a portion of the corrective action detailed in the PIR,
did not apparently review the PIR for generic applicacility, or require initia-
tion of such a review.
,
Observation 3.17 - Solenoid Valve Mounting Support variances
TVA drawing 47A054-33 depicts a typical mounting support cetail for the
installation of solenoid valves and regulators which consists of a steel Team
angle welded to a surface mounted plate restrained by two anchor bolts.
review of workplan No. 9503, whien installed replacement solenoid valves in
several different piping systems in accordance with ECN 5457, indicated
variances Nos. 54-33-A43 and 54-33-A45 to the typical mounting support detail.
These consisted of an unbraced 89-inch span of tube steel supporting six
solenoid valves. The team asked CEB to provide the seismic qualification
calculation for these variances, but CEB was unable to retrieve the calcula-
tion.
Observation 4.8 - Containment Airoorne Radiation Monitoring System Air Supply
Punchlist item 4426 nad been generated in response to SCR SQN-NEB-8615 whien
identified that isolation valves in the containment airborne activity raciatica
monitoring (System 90) sample lines are not supplied with essential control
air, making the radiation monitors not seismically qualified. The SCR notes
that the condition was icentified in a 1980 licensee event report and that TN
is committed to applicable portions of Regulatory Guide 1.45, which recuire tre
airborne particulate radioactivity monitoring system to remain functional onea
subjected to the safe snutdown earthquake. On the other hand, Quality
Information Request (QIR) NES-86241 concludes that it is not necessary for a
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O
seismically qualified air supply to be available to the radiation monitor
isolation valves. Reasons stated in the QIR for this conclusion include:
- The sole safety-related function of the monitor is to generate a
containment ventilation isolation signal. A loss of air to tne
sample valves will cause the monitor to produce that input.
- The valves will fail closed upon loss of air. Thus, the contain-
ment isolation function is assured without a seismic air supply.
The inspection team reviewed punchlist item 4426 and questioned the decision
to reclassify it from restart to post-restart. The intent of Regulatory
Guide 1.45 is to maintain the airborne particulate radioactivity monitoring
system functioning after a safe snutdown earthquake. This cannot be achieved
if the valves close because of failure of the non-safety grade air supply.
Also, the team was advised that QlR NES-86241 is not correct. A loss of air to
the valves will not cause the monitor to produce the input signal to cause
containment ventilation isolation.
Observation 6.21 - Change in Corrective Action for PAM ! solation
In SCR SQN-8722. TVA identified that separation of one postaccident monitoring
channel (i.e., PAM-1) from non-safety-related wiring had not been implemented
as specified in TVA design criteria documents and FSAR Section 7.5.2, which
states: "One of the PAM channels may be associated with non-qualified The
circuits, while the other is fully separated from non-qualified circuits."
08VP punchlist (SQEP-45, Attachment 2) was closed out late May 1987 on the
basis that either qualified isolation devices would ce added to provide
electrical isolation or the non-qualified instruments would be disconnected
from the PAM-1 channel before restart of Unit 2.
In late June 1987, the SQN project was in the process of changing.the agreec-
upon corrective action. The project stated that the isolation requirement t
would be deleted from the PAM design criteria and the FSAR, and stated tha
this item was no lenger a constraint for restart of Unit 2. The team did not
find documentation that the corrective action change had been coordinated witn
OBVP, and noted that the proposed change was in direct conflict with a PAM
separation requirement stated in TVA electrical separation design criteria
document SQN-0C-V-12.2, Section 4.3.5. The team believes that improved
controls are necessary wnen the line organization deviates from OBVP specifiec
corrective actions.
Observation 6.22 - Auxiliary Control Air System Design Criteria
Approximately one year ago, TVA stated tnat the design of the auxiliary control
air (ACA) headers witnin containment had sufficient separation to precluce
However, this
adverse interaction with nigh-and moderate-energy lines.
conclusion appears to nave been without basis as TVA has been extensively
Both hardware enanges
evaluating the acceptability of the current ACA design.
and improved analyses are ceing considered. The team noted that each alterna-
tive currently being reviewed by TVA required that the minimum ACA heacer
pressure of 70 psig, as stated in the design criteria document, be violated.
One scenario depicts a minimum ACA pressure of 26 psig, and a period of 5
minutes following a loss-of-coolant accident (LOCA) within containment before
A-2
.
.
.
,
Since ACA controls the neating, ventila.
the 70-psig einimum value is restored.
tion, and air conditioning (HVAC) systems used to cool safety-related equiement,
the team was concerned with tne operability of the HVAC equipment and ne in act
of degraded ACA header pressure for 5 minutes.
Observation 7.5 - Punchlist Accuracy
The toad s review of the computerized output of punchlist data in the civil /
structural area revealed that punchlist items $18, 955, 6066, and 9304, .ere
all categorized as non-restart. However, a review of the governing SQEP 45,
Attachment 2 forms indicated th:t all these items should be categorized as
pre-restart. Numerous discrepancies were evident between the data base and
the Attachment 2 determinations.
The mechanical systems team reviewed for consistency the SQEP-45 Attachment 2
forms and the associated punchlist items. The team found several instances
(punchlist items) in which the SQEP 45, Attachment 2, form indicated "no
change" for the restart category, however the punchlist was Thischanged from
was noted for
"required for restart" to "not required for restart."
punchlist items 6688, 6691, 6692, 7572, and 7573.
In the operations area, the team disagreed witn the post-restart categorization
of punchlist item 5644 This item concerned nonaqualified mounting of main
This item was closed out
steam system handswitches on the control panels. In addition, the
because
change was SCR SQE-8618-R0
considered was
outside the OBVP initiated to address this issue.The te
boundary.
item should be examined before restart to assess its potential impact on opera-
bility of systems during a seismic event.
The team additionally selected a ample of five punenlist items (Nos. 386,
7742, 8514, 9670, and 9689) to assess the status of implementation and the
consistency between the governing Attachment 2 form (SQEP-45) and the actual
The team biased the sample by only selecting
punchlist database information. A printout (dated
punchlist items for which field modifications were required.
May 26, 1987) of punchlist items with field modifications required was used as
the source for the sample selection. The dated printout was used(All to assess tne
selected
licensee's progress toward completing required restart actions. The following
punchlist items were tabulated as pre-restart on the printout.)
sumarizes the status of this sample:
Punchlist item 386 concerned the fact that approval of valve support
and component nozzle leads in excess of the vendor specifications
This was given the status of
was not documented (SCR SQNCEB8511).
l
"0BVP closed" based on a decision to exclude from the scoce of the
i OBVP those CAQs that .ere identified
(CAQs before
identified beforethe
theCBVP
OBVP was initiated
and already
i but not yet implemented. These were to be resolved
implemented were revie.ed by the OBVP). The punchlist implementation
l and tracked by the TVA CAQ process.
status was tabulated as "completed." The team considered this
.
i misleading because the actual status was unknown, and was immaterial
to the 08vP.
Punchlist item 7442 identified that non-safety-related pressure indica-
tors were used to replace existing indicators in the auxiliary feedwater
.
.
.
system. A SQEP-45, Attachment 2 form closed this item on april 23, 1987,
based on proposed corrective action to replace or Qualify the pressure
indicators (SCR SQN-EEB- 8726, Part 8). This item was erroneously
classified as "implemented," as well as "closec," and also as upon
receipt of the Attacnment 2 form. This was of concern to the team
because 08vP closure does not imply implementation of corrective
action, and the 08VP indicated that the punenlist database (as
updated for implementation status by the SQN project) would be
used to verify that all pre-restart requirements were satisfied.
Two items were not implemented, according to the latest punchlist
status. Punchlist item 8514 identified an unimplemented design
requirement to abort diesel generator testing automatically fol-
lowing receipt of an accident signal and trip the diesel generator
supply breaker to the 6.9-kV shutdown board. Punchlist item 9689
concerned the need to restore the notwell pump trip on a feedwater
isolation signal. The FSAR takes credit for hotwell pump trip on
feedwater isolation, and alternative trips of the condensate booster
and domineralizer pumps (ECH L.6215) are not yet implemented, and not
scheduled before restart.
Punchlist item 9670 concerned the addition of a fast bus +.ransfer
circuit in pars 11e1 to a 30-second time delay circuit in the RPS,
potentially degrading the existing circuit. The punchlist ites was
listed as implemented; however the associated Attachment 2 form
(SQEP-45) whien snould have been used to document implementation
was not availaole. The associated Attachment 2 form documenting
DBVP closure (7/6/87) indicated that operacility of the subject
relays should be verified before ristart. Post,* restart corrective
actions, consisting of control circuit revisions to provide indivi-
dual testing of the subject relays, were also required. No change
in restart categorization was authorized. Per vereal discuss. ions
with DBVP personnel, punchlist items with both pre- and post-restart
portions were to change restart status to "no" upon completion of
pre-restart corrective action. The implementation status would
remain open pending completion of the post-restart corrective
action. This punchlist item appeared as a complete, implemented,
pre-restart item in the database without documentation suoporting
completion of pre-restart corrective action nor a means to track
post-restart work.
The team noted that the licensee's procedures for control and statusing ounenlist
items did not specifically address handling of these aspects of the punenlist
items,
m
_ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
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APPEN0!X 8
LICENSEE ACTION FOR PREVIOUS INSPECTION FINDINGS
The team reviewed the corrective actions taken by TVA to resolve the open
deficiencies and observations identified in NRC inspection report Nos. 50-327
and 50-328/86-27, 86-38, 86-45, 86-55, and 87-14. Correspondence associated
with these findings, including TVA responses, are tabulated in Attachment C.
The following are the team's comments on these items.
Report No. 86-27
(Closed) Deficiency 6.1-1 - AFV Pump Discharge Pressure Switch Rating
TVA provided a description of the process used to change the pressure switches
and referred to retrievable instrument range and setpoint calculations that
supported the individual substitutions of these switches. Based on this
additional information from TVA, the team has closed this ites.
(Closed) Deficiency 6.1-2 - FW Bypass Control Valve Solenoid Replacement
TVA provided documentation to confirm that the replacement control valve
solenoid would ce a Class 1E seismically mounted device; nonce, this item has
been closed.
(Closed) Deficiency 6.1-3 - AFW Pump Suction Pressure Switch Sespoint
As a result of replacement of the AFW pump suction pressure suitch, a TVA
This calculation
setpoint calculation was prepared and issued in March 1986.
did not identify or supersede a previous setpoint ca'culation made in 1979.
TVA has subsequer*.ly superseded the earlier calculation; on this easis, this
item has been cicsed.
(Closed) Deficiency 6.3-1 - Pressure Switch Hydrostatic Test After Seismic
Qualification Testing
The team noted that TVA did not routinely scoci'y that instrument vendors
provide confirmation of pressure coundary TVA hadintegrity for conduct
the vendor pressureconfirmatory
switches
subject to seise n qualification.
pressure boundar/ tests for the specific Static-0-Ring (50R) examole identified
by the team. These particular SOR pressure switches were shown to ee satisf ac-
tory.
TVA submitted a revised response addressing this issue on January 30,
1987 (Reference 11)*, noting that a review of environmental qualification The need
einders revealed that the instruments had been pressure tested.
to require some form of a cressure test to confirm the integrity of the
instrument pressure councary following seismicTherefore, qualificationthis hasitem
been is referrec closed
to the Office of Special Projects for review.
for the purpose of this inspection.
"References are listed in Section C.2 of Appendix C.
.
>
.
.
.
Report No. $4-34
(Closed) Observation 1.1 - Impact of Walkdown Findings on Operating
procedures
In inspection report No. 50-328/86-55, the team noted that although the
observation was answered and resolved, no sampling had been done to trackThe
the corrective action process and confirm satisf actory implementation.
licensee's response indicated tnat Corrective Action Report SQ CAR 85-10-016 The team
documents the corrective action taken to address tne observation.
reviewed this report and confirmed that it did address the team's previous
concern.
(Closed) Observation 1.2 - Walkdown Scope Dif ference From Calculation
Soundaries
Th4 observation concerned the f act that the extent of the system marked up on
the drawing used for the walkdown was not the full extent shown in the boundary
calculation. No justification for the difference was filed for review.
Procedure SQEP-16 has been changed to require the System (nqineer to provide
justification for the walkdown boundaries in the System Evaluation Report
($YSTER).
The team reviewed sections of the EA Review Plan which, in turn, had audited the
SYSTERs for inclusion of the required justifications. The Review Plan stated:
'
"Has adequate technical justification been provided for any portions of the
system on the SW610 (system walkdown boundary identification
walked down?" These deter-
or in cases where this was lacking, an action item -as generated.
minations resolved the team's concerns with this item.
(Closed) Observation 1.3 - System Interfaces on Dra ings
This observation concerned the information related to "out-of-function" During
portions depicted on system flow (mechanical and controls) diagrams.
system walkdowns performed by TVA, the team noted that some "out-of-functio The
information was not marked properly or treated in a consistent fashion.
team had left this item open in inspection report No. 50-328/86-55 until a
'
project policy was promulgated regarding out of-functon information on drawings
This policy was formally implemented in a memorandum from thepolicy
This SQN wasProject
Engineer dated January 30, 1987, and widely distributed.
l supplemented by a memorandum from the Project Engineer to the Plant Manager
and the Modifications Manager further describing the policy and requesting
that personnel using drawings at SeQuoyah be trained in the appropriate inter- l
pretation of out of-function information. '
,
(Closed) Observation 4.2 - Reactor Protection System (RPS) and Neutron Monil
ing System (NMS) OBVP Scope Boundary
The team reviewed Revision 5 of TVA calculation SQN-OSG7-048 (825-870319-801), Also
entitled "Identification of Systems Required for SeQuoyan Restart "
The team found snat
reviewed were the marked-up drawings for tne RPS and NMS.
the calculations adequately incorporated the necessary portions of RPS and NHS
in the description of the systems or portions thereof required to be functional
._ _ _ _ _ _ _ _. _ _ ___ _ __
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.
,
The team found that the markup of
for safe shutdown and accident mitigation.
the drawings adequately represented the description given in the calculation.
Therefore, the team found the corrective action to be adequately implementeo
and tne observation can be considered closed.
(Closed) Observation 6.2 - Neutron Monitoring System (NMS) Flux Oetector
Qualification Basis
This observation concerned the lack of qualification of HMS flux detectors ano
their need to function in a postaccident environment.
In an unreviewed safety question determination (USQD), Westinghouse stated
that a new accident scenario was not created for postulated failure of tne
NMS detectors after a loss-of-coolant accident (LOCA) event within containment
that could lead to uncontrolled withdrawal of control rods for approximately
15 seconds. Westingneuse subsequently provided additional text to support its
A cycle-specific analysis has been performed for both
USQD determinations.
Units 1 and 2 by Westingnouse to address the consequences of a continuous red
withdrawal caused by the postulated environmental conditionsAcceptablefollowing
margins ato
small-break LOCA (Westinghouse letter TVA-86-733).
critical heat flux (departure from nucleate boiling ratio) were demons-
trated for the current cycles. This adequately addresses this concern for
pre-restart considerations. The associated CAQ (SCR SQN-NEB-8609-R2) remains
Thrae options are being considered
open, pending long-term corrective action. continued cycle-specific analyses, q
by the licensee: detectors, or demonstration tnat the steam line break accident will not
the postulated rod withdrawal. These alternatives are considered.to be tecnni-
cally adequate.
(0 pen) Observation 6.3 - Instrument Sensing Line Walidown
Because of several differences between the design drawings and the. actual
installation of a sample of heating, ventilation, and air conditioning (HVAC) .
' sensors, the team had recommended that each sensor in HVAC systems (30, 30A,
31, 31A, and 65) be walked down. TVA documented in CAQR SQP-871147 that the
design drawings were inacequete for HVAC instrument TVA notedlines
that cased onwere
sketches a walkcown
performed pursuant to procedure SMI-0-317-61.
being made of the installation of HVAC sensors that performed a protective or
control interlock function, and that these sketches would be converted into
The team considers that TVA neecs
design drawings at some point in the future.to confirm that theInas-bui
technically adequate and meets tne design requirements for these sensors.
addition, TVA should provide a schedule for issuing the applicable design
drawings. This is a confirmatory item.
Report No. 96 45
(Closed) Observation 2.3 - Status of NSSS Vendor Proprietary Information
This observation was open, pending a confirmatory letter that commitments /
requirements made in a nuclear steam supply system (NSSS) vendor's proprietary
document, have been replaced with non-proprietary documents. Information
-
provided by TVA in its revised response (enclosing Westingnouse letter
TVA-86-609), states that all information considered to be a commitment or a
. _ _ _ _
.
.
. .
design requirement is incorporated in the formal proprietary documents that
have been sent by the N555 vendor and incorporated in the comm
requirements list.
(Closed) Observation 3.4 - Pipe Support Design Criteria
Observation 3.4 documented provisions for stiff piping clamps and piping sleeves
in Watts Bar design criteria WB-0C-40.31.9 that CE8 did not reiterate in Sequoyan
design criteria SQN-0C-V-24.1, which supersedes the Watts 8ar design criteria.
On March 19, 1987, CE8 issued design input memorandum 01M-SQN-0CObservation V-24.1 to
incorporate these provisions into design criteria SQN 0C-V-24.1.
3.4 is closad.
(Closed) Observation 4.4 - Spray Shields for Certain Hydrogen Igniters
The team reviewed both the system description for the combustible gas gentrol
system (System 83) and the System 83 design criteria (SQN-DC-V 26.1, Rev.1)
The team found that both documents have been The revised to reviewed
team also adequatelytheincorporate
backup
references to the need for spray shields.
information upon which the design of the shields is based and found thatThe team
information was adequately referenced in the system design documents.Therefor
found the corrective action to ce adequate.
closed.
Report No. 86-55
_.
Flow Rate Assumption Used in Calculation
(Closed) Observation 2.6
used the recommended vender
Observation 2.6 noted that calculation SQN-60-0053
pump head curve and runout condition to calculate design pressure of the
refueling water return line to the refueling water storage tank and observed
that a system resistance curve or other justification shouldThe beteam
the reviewed
easis for
the runout flow used in the calculation of design pressure.
the revised calculation which determined the system resistance Thecurve for the
calculation
refueling water transfer mode of operation for the RHR pump.One of the dominart
was found to be technically adequate. The
'
factors in the system resistance curve was the partial opening of a valve.
opening of this valve is administrative 1y controlled The teamforconsiders
purposes NRCof preventing
a too rapid drawdown of water inside containment.
Observation 2.6 to be closed, eut notes that changes in the acministrative
procedure controlling the extent of valve opening will affect t
the calculation.
linked (cross referenced) in lignt of this interdependency.
Drawing Control
(Closed) Observation 2.7
The team reviewed the TVA oroposed corrective actions (plannedTVA for plans
post- to
restart) for this ooservation and found them to be adequate. i
The TVA commitsvt (enclosure 3 to Reference 8), which nas been entered into
the Corporate Commitment Tracking System, was modified by a TVA letter dated
Octoeer 2, 1987, to reflect a later completion date.
v
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Diesel Breaker Trip
(Closed) Observation 5.7
This observation identified a race between load shedding and diesel creaker
closure in the diesel generator starting logic which was introduced by a
modification. TVA issued a significant condition report (SCR SQN-EEB 86206-40)
to address this concern.. The team was informed that TVA later determined snat
although a failure a breaker to operate during certain plant conditions (suen
as a blackout during a routine test of a diesel generator before it is
synchronized with the bus) may cause damage to an emergency diesel generator,
this kind of failure is covered by the single-failure criteria. In addition,
no two diesel generators are tested simultaneously; thurefore, the possibility
of a common mode failura for two redundant diesels does not exist. TVA
provided a revised response to this observation in a letter dated September 1,
1987 (Referance 16). TVA further noted that to ensure that the breakers are
maintained in an operable state, an operational test of the load shedding
features is performed every 18 months and a complete disassembly and inspection
are performed every five years.
TVA further added that the sequence of a safety injection with a delayed loss
of offsite power (blackout following a LOCA) is not among the diesel generator
loading cases being analyzed (March 12, 1987 letter to the NRC) because it does
not significantly contribute to the probability of core melt. The FSAR will be
updated in 1988 to eliminate this sequence as a design-basis event.
The NRC team accepts the TVA position that the failure of a breaker to operate
can be classified as a single failure and considers this observation closed.
(0 pen) Obst.rvation 6.12 Periodic Test of Component Cooling Water System
Surge Tank Baffle
An internal tank baffle plate within the component cooling water system (CCS)
surge tank provides independent water volumes for the redundant CCS pumps.
The team noted that the integrity of the baffle plate had not been confirmed
by CCS preoperational or periodic tests. TVA subsequently performed a leakage
test on the surge tanks in both units, and found no leakage from one tank and
minor leakage, possibly from external piping sources, from the other tank.
This iten rossins open, pending assessment of the need for a periodic surge
tank leakage test.
(0 pen) Observation 6.14 - Project ! valuation of SQEP-12, Question 3C
This observation concerned the narrow perspective from which OBVP engineers
appeared to be addressing failure modes and effects analysis of facility
changes.
Note 17 of SQEP 12, Appendix A design review checklist was modified to confirm
that electrical open circuit and short circuit failure modes within a panel
would not disable the electrical distribution system to the point that requirec
safety functions could not be performed. TVA evaluated the effect of imposec
voltagw sources within a panel on safety-related circuits (PIR SQN EEB 86171).
Several changes were made to the TVA separation design criteria document
(SQN-0C-V-12.2) for qualification of isolation devices and separation
of lighting and power outlet circuits as a result. However, during the SQEP-12
review process TVA did not consider the application of the maximum creciele
_ _ --_
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ac and de potential to safety-related circuits within equipment cabinets,
panels, and rocks. Such analyses are specified in Institute of Electrical
and Electronics Engineers (IEEE) Trial Use Standard
The 379-1972,
team believes thatSection 5.1 anc
the process for
IEEE Standard 379-1977 section 6.1(5).
future plant modifications snould include an imposed voltage analysis as a
requirement. In addition, TVA should confirm the acceptability of relay
contact-to contact electrical isolation of Class 1E to non-Class 1E circuits.
(0 pen) Observation 6.15 - Periodic Functional Test and Reset Timers
During a previous inspection, the team identified that 0.5 second time
delay relays in four safety related pump circuits had not been subjected to
periodic calibration or system functional tests. TVA subsequently prepared
maintenance irstruction (MI) 13.1.3 for an out-of-circuit calibration of these
time-delay relays. The team reviewed the maintenance instruction and recent
calibration data for 11 tucn relays in each unit, noting the following:
(1) The required time delay accuracy was stated to be 25 percent. In the
procedure, this was converted to 24 percent which was equivalent to a
range of 489 to 520 milliseconds. However, the test equipment used for
the calibration had &n accuracy of 40 milliseconds, which corresponds to
28 percent of the relay range. This test equipment was not appropriate
for the specified accuracy of these calibrations.
(2) Of the 22 relays calibrcted, I was found to be inoperable and 12
The range of "as found" time
others were found to be out of tolerance.
delay values was 380 to 590 millisecunds.
(3) The calibration method required disconnecting and subsequently reconnecting
conductors to these relays. TVA does not plan to perform an "in-circuit"
tystem functional test.
The team remains concerned with item 3 in that portions of an init'iating
?
circuit, which need to function for certain accident sequences, are not tested
in either an integrated or, alternatively, overlapping fasnion.
Report No. 87-14
- (Closed) Observation 2.8 - valve Seat Material Qualification
This observation concerned the environmental qualification of certain sof t
TVA has issued an addendum to the
seals used in containment isolation valves.
System Evaluation Report (SYSTEA) for System 31 whien states that the material
is satisfactory based on similar material test data
Furthermore, thefrom
seatthe Wattswill
material Barbe
Equipment Qualification Program.
specifically addressed and cualified for the environmental conditions under the '
Sequoyah Mechanical Equiceent Qualification Program, scheduled
This for completion
satisfactorily resolves
by the end of the Unit 2 second refueling outage.
and closes this observation.
(Closed) Observat, ion 3.10 Control of Field Skatenes ,
l
Observation 3.10 documented CEB's use of uncontrolled field sketchesOnin a f
calculation which CES prepared to qualify sampling tueing and supports.
,
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March 5, 1987, CE8 issued CAQR SQP-870125 to develoc verified field sketenes
Observation 3.10 is
and update the calculation as required before restart.
closed.
(Closed) Observation 3.11 - Electrical Board Room Cooler Seismic Qualifi
Document
Observation 3.11 indicated tnat CEB could not access On April the
17, seismic
1987, CEB Qualification
issued
documents for the electrical board room cooler.
PIR SQN-MEB 8797 to retrieve a copy of the missing vendor report post-restart.
Observation 3.11 is closed.
(Closed) Observation 3.12 - Retrieval of Seismic Qualification Data
Observation 3.12 indicated that CES could not retrieve the flooding and
seismic calculations that qualified the restraint designs for two removable
block walls. TVA has notedTVA snat the block walls have been removed and are not
has issued CAQR SGP870170 to regenerate the
planned to be reinstalled.
calculations if the walls are replaced, and has prepared a quality information
request to ensure regeneration of the calculation prior to reinstallation of
the block walls, should TVA decide to reinstall the walls. Observation 3.12 is
closed.
(0 pen) Observation 3.13 - west Steam Valve Room Main Steam Line Break Evaluatio
Observation 3.13 indicated that CEB did not prepare the pipe rupture calcula-
tions for the valve room walls in accordance with the FSAR to and design
specify the criteria.
On June 4, 1987, CES issued Revision 1 to CAQR SGP870183
required corrective action post restart. Observation 3.13 remains open
pending further NRC review.
(Closed) Observation 3.15 - Zero Period Acceleration t. cads
The team reviewed the following calculations which CEB prepared to address the
additional effect of zero ceriod acceleration (ZPA) loads on the hanger bank
that contains pipe support ICCH-548:
u
(1) calculation "Pipe Support H10-621," Revision 0, dated June 18, 1987 (RI.S
No. 825-870619 801)
(2) calculation "Reactions at Attachment to Embedded Plate From Cable Tray
Support MK 28," Revision 0, dated June 15, 1987 (RIMS No. 825-870616-802)
(3) calculation " Attachment to Aux. Bldg. Embedded PL MK11, 48N1221. El
689'-0", 59'-0" A4, 29'-0"T," Revision 0, dated June 1,1987 (RIMS
' No. 825-870601-800)
(4) calculation "Attacnnnt to Aux. Bldg. Embedded PL HK13, 48N1221, El
689' 0", N5'-6" AS, W13'-2"T," Revision 0, dated June 1,1987 (RIMS
No. 825-870602 800)
(5) calculation "Reactions at Attaen, to Emcedded Plate From Cable Tray
Support MK128," Revision 0, cated June 15, 1987 (RIMS No. 325-870616-301)
_-
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(6) calculation "N2 CEB NRC-MISC. , Evaluation of IPA Ef fect on suoport
1CCH-544," Revision 0, dated July 20, 1987 (RIMS No. 825-870720 804)
(7) calculation "Attach. to Embed. Plate MK13C, Aux. Bldg. El 690, 51'-2"AS.
W13'-2"T," Revision 0, dated Septemoer 12, 1986 (RIMS Ho. 825 870602-801)
The team reviewed CEB's calculations to confirm that CEB used default, instead
of interim, general design criteria, and that coecuted forces, stresses, and
deflections were within the allowable limits specified in the long term
criteria.
The team concurs with CEB's conclusion that the referenced calculations
adequately qualify the hanger bank which contains pipe support 1CCH-548 for
the additional ZPA forces.
The team notes that CEB's latest version of TPIPE incorporates ZPA loads. CEB
is using this version for all new piping analysis and reanalysis.
The NRC Office of Special Projects is currently reviewing TVA's handling of
ZPA loads under the employee concerns program.
(Closed) Observation 4.7 - Classification of Pre-Restart Items
The team had noted that two System 30A punchlist items, involving thermal
calculations for cables replaced for NUREG 0588 and main control room indica-
tion of vent fan operation, were listed as post-restart items. TVA responded
that the adequacy of cable ampacity would be resolved before restart and that
punchlist item 5943 had been recategorized as pre-restart. The vent fan
operation concern was identified for System 30A as cunenlist item 6521 and for
System 30 as punchlist item 6520. TVA responded that punchlist item 6521 was
outside the OBVP boundary for System 30A, and that punchlist*'A item 6520 nad been
did, not intend
closed and implemented. However, the team determined that
to provide a main control room indication of vent f an opers.:en, and had not
implemented any hardware design change. This TVA stateN nt was considered
misleading; however, the team had no technical disagreement with the licensee's
resolution.
(Closed) Observation 5.9 - Punchlist Item Classification
The team reviewed the disposition of punchlist items involving the auxiliary
power systee, the ventilation system, and the component cooling water system.
Review of the punchlist itens which had dispositions that were Several
Questioned by
changes
the inspectors was performed during this inspection eeriod.
were made by TVA for items listed in Observation 5.9. For those items that
did not change category, adequate documentation of the ration,,le for the
classification was presented to allcw closure of this item. l
(Closed) Observation 5.10 - Design verification of Orawing Changes
The team noted a number of instances in which equipment ratings or settings
determined from plant walkdowns differed from values shown on the design i
drawings. As a result, the team raised a concern about the apparent lack of
design verification of technical characteristics by TVA before the design
drawings were changed. The TVA response indicated that DNE reviews each l
l
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.
. .
drawing deviation for adverse impact on plant safety, and prepares a CAQR
or ECM where necessary to change the plant configuration or to revise other
plant documents. In addition, ONE is involved in the resolution of any
additional deviations identified by Modifications Engineering. The TVA
response also discussed and dispositioned eachbasic,
On this specific
thispunenlist
item hasitem
been
identified in the team's coservation.
closed.
(Closed) Observation 5.11 SYS?ER Consistency
The teaa identified several errors and inconsistencies in the auxiliary power
and component cooling water system SYSTERs. The TVA response stated that
ECN L-529d had been readdressed in the responses to SQEP-12, Attachment 2
fore, Questions 5.a and 5.3 for voltage drop and cable thermal capacity,
respectively. The removal of the electrical interlock for component cooling
water pump C-5 breakers (ECN L 6310) has been augmented with precaution
statements added as Caution Order 1461 and by a change to procedure 501 70.1,
which provide administrative control over the operation of the transfer switch.
7797, 8220, 8221, anc 8518
The post-restart categoritation of punchlist itemsBased on these TVA actions, this ites
have been changed to be pre-restart.
has been closed.
(0 pen) Observation 6.16 - HVAC Flow Switch Calibration Data Records and System 30
'
Surveillance Instruction Procedures
The team had noted that the calibration records for HVAC flow switches
2-FS30-200 and 207 had inconsistencies, and that these switches had not oeen
In addition, no system level surveil-
calibrated over the 1982-1985 period.
lance instruction existed to the test the various control logic interlocks
developed by these sensors.
During thit. inspection, the team reviewed TVA's response to the eslibration
data inconsistencies and found the additional information to be satisfactory.
Thus, the calibration data record portion of this observation is closed.
In Section 9.4.5.4 of the Sequoyah FSAR, TVA stated that the electrical
components, switchovers, and starting controls of tne diesel generator building
Such
heating and ventilating systems are tested initially and periodically.
tests have not been conducted in the past, and a TVA CAQR SQT-871016
Operability /Reportability Assessment Sheet (AI 12) stated that operations
personnel verify that, in accordance with SQI-82, the appropriate fans are
running when the diesels are started. This assessment concluded that this
surveillance provides assurance that the HVAC system is operating properly.
The team does not agree that this conclusion is correct; rather, such surveil-
lance demonstrates only tnat a particular fan is running, and does not provice
any information regarcing starting controls or train to-train switchover
interlocks. The team celieves that a surveillance instruction procedure is
needed for the HVAC system to provice assurance of its operational capability
and also to comply witn tne existing FSAR commitment.
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(0 pen) Observation 6.17
Diesel Generator Building Ventilating Fans Control
L.ogic and Surveillance Instruction Procedure
The team identified inconsistencies in the drawings for the diesel generator
building ventilation fans. The team was informed that TVA conducted a series
of tests that confirmed the correct operation of the system in accordance with
the electrical wiring diagrams. These tests also confirmed the existence of
drawing errors in the mechanical control drawing and control logic diagrams.
TVA indicated that the control room drawings would be corrected before
restart.
TVA further stated that CAQR SQT 871016 had been initiated to resolve the
discrepancy of periodic test of the HVAC system controls and electrical
components; however, upon further investigation, the team learned that TVA did
not intend to prepare a surveillance instruction (SI), but rather intended to
eliminate the FSAR commitment for periodic test. TVA also changed the CAQR
corrective action to be post-restart.
(0 pen) Observation 6.18 - Centrifugal Charging Pump Auxiliary oil Pump t.ow
' low Sypass Switch
The team was concerned about the administrative control of a manual bypass
swit.ch added to the 6.9 kV shutdown board to permit starting of a centrifugal
charging pump (CCP) without requiring the operability of the auxiliary oil
pump. In the unreviewed safety question determination (USQO) for this design
change (ECN L-60308), Westinghouse personnel were said to have stated that the
CCP could be started several times without having the auxiliary oil pump
operable. During the inspection TVA personnel indicated that neither Pacific
Pump nor Westinghouse had provided any additional documentation that would
support the basis stated in the USQO.
TVA responded to this concern by stating that the aedition of the. manual bypass
did not create a new operating condition. However, this statement appears to
overlook the increased probability that the CCP will be inadvertently started
"
one or more times without initial oil lubrication
Hence, because
this item remains CCPs
open, arereceipt
pending started so
often during normal operation.
by TVA of documentation from Westinghouse Thisoristhe pump vendor to
a confirmatory support the
item.
USQO statement for this design change.
' 6.19 - 480-volt Board Room Air Hand',ing Unit Control Logic
(Closed) Observatten
The team had identified a number of air handling unit fans that could be
disabled by a high-temperature cutout switch set at either 85'F or 100*F,
Should the temperature switches disable the ventilation fans at the time of i
need, this action could cause the loss of other safety-related equipment.
TVA has subsequently stated that the high-temperature cutout switches .ould
be disabled before plant restart (Reference 15). The team agrees with tnis
commitment; hence, this item is closed.
(0 pen) Observation 6.20 - Preliminary OBVP Report
The team noted that a numoer of DBVP draft report evaluations were made fr:m a
j very narrow perspective ey stating the particular instances were "random ;
events" or "isolated situations." For example, the numoer of similar items
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e
The team
labeled as randos varied from 3 to 41 individual situations.
situation characterizations were
questi;ned whether these random or isola' ,aluated by the OSvP.
valid, based or the number of situations
The response provided in TVA's July 16, 1987 letter (Reference 15) did not
seem to be totally responsive to the team's concern because it dealt mostly
with the HVAC system. In the area of inadequate testing, TVA changed the
The team
designation to "extensive," which appeared to be more appropriate.
had remaining questions regarding both the ele:trical and mechanical disci-
pline's extensive use of the random or isolated characterization for individual
items.
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APPENDIX C
MEETINGS AND REFERENCES
C.1 MEETINGS
Table C.1 provides a matrix of meeting attendance and lists principal persons
rentacted for the settings conducted at Cedar Bluffs, Tennessee and at Sequoyah
Nuclear Plant site in Soddy Daisy, Tennessee. Other licensee personnel were
also contacted. The following paragraphs summarize the general purpose of
these meetings.
Meeting 1: On June 29, 1987, the NRC held an entrance meeting at the TVA
offices in Cedar Bluffs, Tennessee. The OBVP System Engineers and EA Oversight
The NRC reviewed the inspection team's
Review Teams are located at Cedar Bluffs.
plans to inspect TVA OBVP findings and corrective actions, to evaluate TVA's
Engineering Assurance oversight of the OBVP, and to assess the adequacy of
TVA's corrective actions for previous inspection findings.
Meeting 2: On July 2, 1987, a meeting was held at Cedar Bluffs to discuss the
interim status and the results of the inspection as of this date.
Meeting 3: On July 20, 1987, a meeting was held at the Sequoyah site to
review plans for the onsite inspection. The EA Oversight Review Team also
provided tav NRC a summary of its findings during EA's rtview of corrective
actions for the DBVP.
Meeting 4: On July 24, 1987, the NRC held an exit meeting at the plant site to
summarize the results of the inspection team's efforts.
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Table C.1 - MEETINGS
Title Meeting Attended
Name Oraanization 1 2 3 4 1
Team Leader X x x x
REArchitzel USNRC-IE
USNRC-IE NRC-Electric Power X X
SVAthavale Resident Insp., SQN X X X X :
PEHarmon USNRC'RII X X X X
'
NRC-Consultant NRC-Mech. Components
Adu8ouchet NRC-Mech. Systems X X X x
FJMollerus NRC-Consultant X X X X
AIUnsal NRC-Consultant NRC-Civil / Structural
X X X X
LStaniey NRC-Consultant NRC-Instr./ Controls
X X
HE8ibb NRC-RI! SRI St. Lucie
NRC-Consultant Nuclear Engineer X X
JNevshomal X X X X
APCappozzi TVA-ONE Manager - EA
EA Oversight Adv. X X X X
MPBerardi TVA-EA
RPSvarney TVA-EA Civil /Struct. Engr. X
X
JFCox TVA-ONE Asst. Proj. Eng. X
X X X
TVA-ONP Licensing-Sequoyah X
BHall X X X i
Team Leader EA ORT
JvonWeisenstein TVA-ONE
EWSteinhauser TVA-ONE
Hech. Disc. Eval. S. X X
X X
TVA-ONP Comp. Lisc. Mgr.
G8Xirk X
MTTormey TVA-ONE-S&W Advisor
TVA-EA
Senior Civil /Struct. Eng. X
DSvassallo Elec. Engr. X X
JW$emore TVA-ONE X X X
X
TVA-ONE OBVP Prog. Mgr.
HLJones X
PR8 evil TVA-EA QA Specialist X
J8Hosmer TVA-ONP Plant Enoineer X
TVA-ONQA
Plant Engineer
RCParker X
TVA-0NP PORS
HRRogers X X X
WR8 rock TVA-DNE Nuclear OES
X X X
RJames TVA-ONE Civil DES
X X X
PBNesbitt TVA-ONE Electrical OES
JCStandifer TVA-DNE Staff X
X X
X
APBianco TVA-ONE SQEP28 OES X
X X X
TVA-ONE OBVP Eng. Mgr.
DLXitchel Nuclear Eng. X X
RT Holliday ONSL-KLS X
TVA-ONE Design Basis Mgr.
TCPrice X
PKGuha TVA-DNE Asst. Br. Ch. - EEB X
X
JAGraziano TVA-EA Lead Civil OBVP
X X
RTucker X X
l TVA-EA Lead Nuclear OBVP
- CHGabbard Nuclear Eng. X
TVA-ONE NEB
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CCarey X
TVA-EA Ops. Eng.
RCSaver X
TVA-DNE Mech. OES
WCrosslin OBVP Plant Mgr. X
JHO' Dell TVA-DNE x
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TVA-CNP
Site Representative
! PH8ucholz Deputy Site Dir. x.
JTLaPoint TVA-ONP x
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HAAbercrombie TVA-ONP
Site Director
TVA-ONP
Asst, to Plant Mgr. X
AMQualk Asst. Mod. Mgr. X
JRobinson TVA-ONP x
NRC-0SP
Sr. Mech. Eng.
,
JRFair Chief - Eng. Sr. x
RAHerman NRC-0SP x
I Site QA Mgr.
LEMartin TVA-0NQA x
TJArney TVA-ONQA x
NCXazanas TVA-ONQA Oirector - Nuc. QA
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C.2 REFERENCES
(1) Inspection Report 50-327/86-27 and 50-328/86-27, forwarded by J. Taylor
letter dated April 22, 1986.
(2) Inspection Report 50 327/86-38 and 50-328/86-38, forwarded by J. Taylor
letter dated September 15, 1986.
(3) Inspection Report 50-327/66-45 and 50-328/86-45, forwarded by J. Taylor
letter dated October 31, 1986.
(4) Letter Requesting Additional Information Relating to Inspection Report
50-327/86-27 and 50-328/86-27, J. Taylor, NRC IE to 0. C. Mason dated
October 30, 1986.
(5) TVA Response to Inspection Report 86-27 (Gridley to Grace), dated July 28,
1986.
(6) TVA revised response to Inspection Report 86-27 (Oomer to Grace), dated
December 31, 1986.
(7) TVA response to Inspection Reports 86-38 and 86-45 (Domer to Taylor),
dated February 3, 1987.
(8) TVA response to Inspection Report 86-55 and other Inspection Items
remaining open (Gridley to Ebneter), dated April 22, 1987.
(9) Inspection Report 50-327, 328/86-55, forwarded by J. Taylor letter dated
February 3, 1987.
(10) Inspection Report 50-327, 328/87-06, forwarded by S. Ebneter letter dated
April 8, 1987.
(11) TVA Additional Information in Response to Inspection Report 86-27,
(0omer to Taylor), dated January 30, 1987.
(12) Engineering Assurance Oversight Review Report, "Sequoyah Nuclear Plant-
Unit 2 Design Baseline and Verification Program," EA-0R-001, issued
April 29, 1987.
(13) Sequoyah Nuclear Plant - Design Baseline and Verification Program Unit 2
Phase 1 Report, dated May 29, 1987.
(14) Inspection Report 50-327, 328/87-14, forwarded by S. Ebneter letter dated
June 4, 1987.
50-327, 328/87-14 (Gridley to NRC),
(15) TVA response to Inspection Report
dated July 16, 1987.
,
(16) TVA revised response (Observation 5.7) to Inspection Report 50-327,
328/87-14 (Gridley to NRC), dated September 1, 1987.
(17) TVA letter relating to control and processing of changes to the punch
list (Gridley to NRC), dated August 20, 1987.
C-3
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