ML20150D326
| ML20150D326 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 03/11/1988 |
| From: | NRC OFFICE OF SPECIAL PROJECTS |
| To: | |
| Shared Package | |
| ML20127A683 | List:
|
| References | |
| NUDOCS 8803230334 | |
| Download: ML20150D326 (55) | |
Text
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o UNITED STATES 8
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NUCLEAR REGULATORY COMMISSION o
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WASHINGTON, D. C. 20555
,o SEQUOYAH NUCLEAR POWER PLANT, UNITS 1 AND 2 SAFETY EVALUATION REPORT FOR EMPLOYEE CONCERNS (OP306001)
ELEMENT REPORT OP 306.01.-SQN "FIRE PROTECTION EQUIPMENT WORKS IMPROPERLY"
1.0 INTRODUCTION
The problem as defined by TVA was a failure to adequately address the installation requirement for' closure mechanisms needed to close fire doors against airflow and to accurately specify the installed door closure equipment in applicable output documents.
2.0 EVALUATION Category:
Operations (30600)
Subcategory:
Fire Protection (30601)
Element:
Fire Protection Equipment Works Improperly (306.1SQN)
Employee Concerns:
IN-85-311-008 The basis for Element Report OP30601 - SQN, Revision 4, dated November 18, 1986, is Sequoyah Employee Concern IN-85-311-008 which states:
"The fire door A143, 20 feet outside control room entrance, is habitually open despite safety signs that require door to be closed at all times.
Installing a self closing mechanism was expressed as being the solution to this concern." This concern was evaluated by TVA as potentially affecting the fire rated separation requirement for safety-related components and equipment l
and was potentially applicable to Sequoyah."
TVA reviewed seventy-four maintenance requests written on door cicsure mechanism over the past 18 months. Most of these requests were written to resolve deficiencies identified during the surveillance inspection of fire l
doors required by the Technical Specifications.
Proper operation of the door was usually achieved by adjustment of the door closer mechanism or replacement
^
of the door closer.
However, in three cases, the maintenance request specified a replacement closure with a model number different from that prescribed by the door schedule of the construction documents. Apparently, these replacement closures had a greater strength than that specified by the schedule.
The door 1
closer for door A143 had recently been replaced and was adequate for the O
8803230334 880311 DR ADOCK O 30
)
2-specific application but was different from that prescribed be the construction door schedule.
TVA's review noted that fire door closure problems frequently occur because of differential air pressure across doors due to transients such as removing fans from service and alterations of flow paths.
Also, it was noted that design engineering apparently did not consider forces due to design pressure when sizing door closer mechanisms.
However, adequate procedures are in effect to identify fire doors which are unable to close and latch due to weak closures or other deficiencies.
The action statement of the Technical Specification limiting condition for operations would be implemented for all identified inoperative fire doors.
To improve the surveillance of fire doors, the surveillance procedures are to be revised to require normal ventilation system lineup and building pressure in the required range prior to and during performance of the surveillance.
Doors which do not close and latch are to be corrected by closure adjustments.
If the problem cannot be corrected, an engineering evaluation will be conducted to determine if the problem is due to a ventilation imbalance or design deficiency and appropriate corrective action will be initiated. Also, to assure that doors are provided with the correct closure, all doors are to be inspected to verify that the installed door closures are in conformance to that specified by the door schedule of the construction drawings.
Corrective Action Tracking Documents (CATD) have been issued to track completion and implementation of these corrective actions.
This is acceptable for restart.
3.0 CONCLUSION
The concern for the failure of the fire doors to properly close and latch has minor safety significance due to the additional plant fire protection features provided and the limiting condition for operation which have been implemented for those identified doors which will not properly close and latch.
Therefore, the NRC staff concludes that TVA's investigation and resolution of the concern described in Element Report OP30601 - SQN were adequate.
The NRC staff also concludes that no further action by the NRC is required.
i j
SEQUOYAH NUCLEAR POWER PLANT - UNITS 1 AND 2 SAFETY EVALUATION REPORT FOR EMPLOYEE CONCERNS (OP306001)
ELEMENT REPORT OP 306.01-SQN "FIRE PROTECTION EQUIPMENT WORKS IMPROPERLY" I.
Subject Category:
Operations (30600)
Subcategory:
Fire Protection (30601)
Element:
Fire Protection Equipment Works Improperly (306.1SQN)
Employee Concerns:
IN-85-311-008 The basis for Element Report OP30601 - SQN, Revision 4, dated November 18, 1986, is Sequoyah Employee Concern IN-85-311-008 which states:
"The fire door A143, 20 feet outside control room entrance, is habitually open despite safety signs that require door to be closed at all times.
Installing a self closing mechanism was expressed as being the solution to this concern."
This concern was evaluated by TVA as potentially affecting the fire rated separation requirement for safety-related components and equipment and was potentially applicable to Sequoyah."
II.
Summary of Issue The problem as defined by TVA was a failure to adequately address the installation requirement for closure mechanisms needed to close fire doors against airfitw and to accurately specify the installed door closure equipment in ar>plicable output documents.
III. Evaluation TVA reviewed seventy-four maintenance requests written on door closure mechanism over the past 18 months.
Most of these requests were written to resolve deficiencies identified during the surveillance inspection of fire doors required by the' Technical Specifications.
Proper operation of the door was usually achieved by adjustment of the door closer mechanism or replacement of the door closer.
However, in three cases, the maintenance request specified a replacement closure with a model number different from that prescribed by the door schedule of the construction documents.
Apparently, these replacement closures had a greater strength than that specified by the schedule.
The door closer for door A143 had recently been replaced and was adequate for the specific application cut was different from that prescribed by the construction door schedule.
l 2
TVA's review noted that fire door closure problems frequently occur because of differential air pressure across doors due to transients such as removing fans from service and alterations of flow paths. Also, it was noted that design engineering apparently did not consider forces due to 3
design pressures when sizing door closer mechanisms.
However, adequate i
procedures are in effect to identify fire doors which are unable to close j
and latch due to weak closures or other deficiencies.
The action state-ment of the Technical Specification limiting condition for operations would be implemented for all identified inoperative fire doors.
To improve the surveillance of fire doors, the surveillance procedures are to be revised to require nonnal ventilation system lineup and building pressure in the required range prior to and during performance of the surveillance.
Doors which do not close and latch are to be corrected by closure adjustments.
If the problem cannot be corrected, an engineering' evaluation will be conducted to determine if the problem is due to a '
ventilation imbalance or design deficiency and appropriate corrective action will be initiated.
Also, to assure that doors are provided with the correct closure, all doors are to be inspected to verify that the installed door closures are in conformance to that specified by the door schedule of the construction drawings.
Corrective Action Tracking Documents (CATD) have been issued to track completion and implementation of these corrective actions.
This is acceptable for restart.
IV.
Conclusion The concern for the failure of the fire doors to properly close and latch has minor safety significance due to the additional plant fire protection features pt-ovided and the limiting condition for operation which have been implemented for those identified doors which will not properly cic e and latch.
Therefore, the NRC staff concludes that TVA's investigation and i
resolution of the concern described in Element Report OP30601 - SQN were adequate.
The NRC staff also concludes that no further action by the NRC is required.
l
a.
i SEQUOYAH NUCLEAR POWER PLANT, UNITS 1 & 2 SAFETY EVALUATION REPORT FOR EMPLOYEE CONCERNS ELEMENT REPORT 30701 "PLANT OPERATIONS REVIEW COMMITTEE (PORC) PROCES I.
Subject Category:
Operations (30000)
Subcategory: Nuclear Power / Site Program / Procedures (30700)
Element:
"Plant Operations Review Committee (PORC) Process" (30701)
Concern:
IN-85-457-001 The basis for element report 30701-SQN Revision 2 dated February 27, 1987, is the following Watts Bar employee concern:
IN-85-457-001: Inadequate review of plant procedures by Plant Operations Review Committee (PORC).
Reviews not conducted in accordance with AI 3.1 (refer to Surveillance Instruction Procedure).
This concern was evaluated by the Operations Category Evaluation Group Head (CEG-H) and determined to be generically applicable to SQN.
III. Evaluation The requirements for the PORC process are delineated in the Technical Specifications (TS) and Regulatory Guide 1.33.
This Regulatory Guide implements and endorses ANSI.N18.7.
Commitment to these documents b,y the Tennessee Valley Authority (TVA) for SQN is contained in the SQN Final Safety Analysis Report (FSAR) and the Quality Assurance Topical Report.
Effectiveness of implementation was assessed through a review of SQA-21, Onsite Independent Review (PORC), SQN TS for Units 1 and 2, arid AI-4, Plant Instructions - Document Control.
Pertinent documentation from the above references was reviewed and informal interviews were held with various members of the SQN staff, notably, the Plant Operations Review Staff (PORS) Supervisor, the PORC secretary, a PORC chairman and a member of the Nuclear Safety Review Board (NSRB).
Additionally, the evaluator attended a regular meeting of PORC on Wednesday, November 11, 1986, to witness the conduct of business.
The evaluator also reviewed applicable NRC inspection reports that addressed the PORC process.
The evaluation determined that the concern was valid for Sequoyah.
As a result of TVA and NRC identified deficiencies with the PORC process, i
TVA has instituted changes to correct these deficiencies.
One of the primary changes instituted was the formation of a qualified group of plant personnel to serve as a subcommittee for PORC reviews.
Specific plant staff individuals are identified as Qualified Individuals (QI) within their discipline and area of expertise.
Also included are specific qualification requirements that must be met to be designated as a QI,
o o.
2 This approach allows PORC to achieve its responsibilities through the use of QIs on a delegated, subcommittee approach.
TVA has submitted a Tech-nical Specification change to the NRC to recognize this new PORC process.
An effort is underway to adapt this methodology at all TVA nuclear plants through a proposed revision to the Nuclear Quality Assurance Manual" (NQAM), Part II, Section 1.5.
The draft document explaining this proposed change is titled, "Onsite Independent Review - PORC," dated October 28, 1986.
This draf t is currently circulated for review and comment; no scheduled date for potential implementation was projected.
IV.
Conclusion The NRC staff believes that the TVA investigation of the concern was adequate, and their resolution of the concern as described 'in Element Report 30701 is acceptable for restart.
I a
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SEQUOYAH NUCLEAR POWER PLANT UNITS 1 & 2 SAFETY EVALUATION REPORT FOR EMPLOYEE CONCERNS ELEMENT REPORT OP 30704 "Workplan Process" I.
Subject Category: Operations (30000)
Subcategory:
Nuclear Power / Site Program / Procedure (30700)
Element:
Workplan Process (30704)
Concerns:
XX-85-070-005 XX-85-070-003 SQP-6-003-003 IN-85-305-H03 SQP-86-003-N06 XX-85-070-002 XX-85-070-006 HI-86-090-N02 The basis for element Report OP 30704-SQN Rev 7 dated March 10, 1987, are the following employee concerns:
XX-85-070-005 "Seouoyah: Workplan (number known) to take equipment out of service for repair / modification was never authorized by engineering but work plan modifications have been completed.
(Names / details to the specific case are known to QTC and withheld to maintain confiden-tially.) Nuclear Power Concern.
CI has no further information."
{
XX-85-070-003 i
"Sequoyah:
Workplans contain inaccurate data. Majority of the OCRs taken care of but not documented right and drawings do not reflect the as-built conditions.
Details withheld to maintain confiden-tiality.
Nuclear Power Concern.
CI has no further information."
SQP-6-003-003 i
"Conduit is currently being removed and reinstalled (rerouted) without proper documentation.
Lower containment.
Fan room 1, I
~
2 Unit ?.,
a Work Concern. pproximate elevation 680'.CI has no further information." pla Nuclear Power IN-85-305-N03 i
"NRC identified the following concern from QTC report IN-85-305-001.
No administrative procedure exists for controlling field modifica-tions for vendor supplied items."
SQP-86-003-N06 "NRC identified the following concern based on review of QTC file.
If documentation deficiency for SQP-86-003(-003) is substantiated, it would be a QA violation of Appendix B and would be reportable.
The subject form (ERT form M) indicated it is not reportable."
XX-85-070-002 i
t "Sequoyah Units 1 and 2:
CI expressed a concern that specific quality problems (open since 1980) are in the process of being inten-tionally closed in a dubious manner to prevent attracting the attention of the NRC.
(Names / details to the specific case are known to QTC and withheld to maintain confidentiality).
Cl has no more information.
t Nuclear power department concern."
XX-85-070-006 "Sequoyah Units 1 and 2:
Closure of specific quality documentation is being falsified in order to close these problems out before the NRC becomes aware of them.
(Names / details to the specific case are known to QTC and withheld to maintain confidentiality).
Nuclear CI has no further information."
power concern.
HI-86-090-N02 i
"Untrained individuals were brougnt to Seccoyan t.. work ECR0s, CCRs.
and WPs."
II.
Summary of Issue TVA perceived this element to consist of four cistinct issues.
The first issue concerned the reuse of electrical conduit at SQN and the allegec failure to document this work.
The second issue concerned the failure of the modification program to ensure that drawings are updated to reflect system changes, and the failure to obtain the necessary authorization for each workplan and to process open workplans to avoid NRC knowledge of quality problems and errors with workplans.
Se thirc issue conce re:
procedural controls for plant modifications to vendor supplied items.
Tne forth issue concerned untrained individuals being brought to SQN to wor <
Engineering Change Notices, Design Change Requests, and Workplans.
=
3 III. Evaluation A.
The concern about reuse of electrical conduit and failure to document this work was investigated by NSRS and the investigation concluded that the concern was unsubstantiated.
not prohibit reuse of electrical conduit.SQN procedures and policies do B.
The concerns addressing failure to update plant documentation and failure to obtain all required signatures before the completion of workplans was substantiated by an NSRS Investigation of these concerns.
As a result SQN has initiated the Design Basis Verification program and the ECN closure project to review and close open ECNs.
The concern addressing processing open workplans to avoid NRC knowledge of quality problems and errors with workplans was not substantiated by the NSRS evaluation.
C.
The concern addressing no administrative control procedures for modifications to vendor supplied items was not substantiated.
Administrative Instruction Al-19 is the controlling document for all plant modifications af ter the plant is licensed.
The procedure controls the preparation, execution and close out of all workplans which are required for the modification of any plant equipment.
D.
Ine concern that untrained individuals were brought to SQN from BLN to work on ECNs, DCRs and WPs was not substantiated.
Based on TVA interviews with cognizant engineering supervisors from both SQN and SLN and a QA Audit Report the individuals were technically qualified engineering personnel.
IV.
Conclusien The NRC staff believes that the isA investigation Of the concerns was adequate, and their resolution of the concerns as described in Element Report OD 30704 is acceptable for restart.
SEQUOYAH NUCLEAR POWER PLANT, UNITS 1 & 2 SAFETY EVALUATION REPORT FOR EMPLOYEE CONCERNS ELEMENT REPORT OP 30705 "SURVEILLANCE PROGRAM AND INSTRUCTIONS" I.
Subject Category: Operations (30000)
Subca tegory:
NUCLEAR POWER / SITE PROGRAM / PROCEDURE (30700)
Element:
SURVEILLANCE PROGRAM AND INSTRUCTIONS (30705)
Concern:
IN-86-014-001 IN-86-208-001 The basis for Element lleport OP 30705 - SQN, Rev. 1, dated December 13, 1986, are the following employee concerns:
IN-86-014-001: "The amount of sis run on essential equipment is too much.
Running numerous sis on certain systems require the pumps, chillers, compressors, etc., to be cycled on and off. The starting duty on the equipment wears it down and causes more frequent failures such as bearing f ailures.. An exa ole is that only three o#
eight ERCW pumps are prese-tly operational.
IN-86-208-001: "Numerous SI packages are required to be performe:.
which is detrimental to e:uipment operation due to a-excessive number of start / stops.
sis also require :::
much time of licensed coerat0r positions (more time spent in pape-work than in monitoring plant per#c--
mance). Equipment affecte: i s the ERCW pumps, ciese' generators and fire pumps.
II.
Summary of Issue TVA has perceived f:ur issaes frc-
- ce-r s
- N-S6-014-001 and IN-86-208-001.
The first is that there is not an integrate: a::rea:h to surveillar:e testing witn the objective of minimi:ing starts.
The second is that surveillance requirements require excessive testing.
The thir0 is trat excessive surveillance testing frequencies casse e:ui: ment f ail ure s.
e forth is tnat the excessive pacernork o events li:ensed cperaters f*:-
attending pre:erly to : e units.
l I
/,
2 III. Evaluation TVA evaluators conducted interviews with cognizant. operations personnel at Sequoyah and Chattanooga, reviewed relevant NSRS reports, applicable TVA procedures, regulatory requirements and appropraite outside documents addressing the issues.
TVA evaluated EPRI Report NP-4264, Failures Related to Standby Equipment (Volume 1:
Pump Testing) (Volume 2:
Diesel Generator), dated October 1985 and has submitted a change request to the technical specification on August 8,1986, to reduce testing frequencies.
In addition, the 51-1 review check list asks whether all sis that can be run concurrent are listed in the SI instructions. TVA believes this item e
will ensure that all sis that can be run concurrently to reduce equipment start / stops will be identified.
TVA does not consider completion of the SI review for reduction of start / stops as a startup issue.
TVA evaluator review of AI-2 section 1.16 identified that licensed operators positions have the authority to terminate activities and/or expel persons from the control room if he determines that the condition is adversely affecting his capability to operate the unit in a safe manner.
TVA evaluator interviews with operations personnel indicated that they did not allow paperwork to take priority over the unit.
TVA does emphasize that SI caperwork is used to verify the operability of the unit.
IV.
Conclusion The NRC staf f believes that the TVA investi;atien of the c'encern was adequate, and their resolution of the concer-as ::escribed in Element Report 09 30705 is acceptable for restart.
SEQUOYAH NUCLEAR POWER PLANT, UNITS 1 & 2 SAFETY EVALUATION REPORT FOR EMPLOYEE CONCERNS ELEMENT REPORT OP 30706, "TEST PROCEDURE / PROGRAMS" 1.
Subject Category: Operations (30000)
Subcategory:
Site Program / Procedures (30700)
Element: TestProcedure/ Program (30706) t Concern: XX-85-001-001 SQM-86-004-017 WBN-233 XX-85-077-001 IN-86-209-011 The basis for Element Report OP 30706 - SQN, Rev. 2, dated April 22, 1987, are the following employee concerns.
XX-85-001-001: Sequoyah DG batteries have been replaced without initial testing per IEEE-450.
A Potentially Reportable Occurrance (PRO) was written and determined not reportable by the compliance section.
SCM-86-004-017:
Certain safety related equipment may not have been properly tested. One of the items involved are some tubes on the fuel floor. Other items are not specifically known.
Details known to Quality Technology Corporation (QTC) withheld because of confidentiality.
No further information may be released.
WBN-233:
System 13, Fire Protection System, does not have enough approved manuals or prints for maintenance. The concerned individual (CI)hasindicatedthatasurveillanceinstructiondoesnotexistto check system from the transmitter / receiver panel through to the console computer. CI has indicated that an approved master list does not exist of printouts er modificatiens to the system.
Individual is also concerned that individuals maintaining / operating the system are inadeouately trained.
CI requests that a check on availability of spare parts be made.
XX-85-077-001:
Sequoyah - early 1980 and middle of 1981.
Unit 2.
The preoperational prerequisites are questionable.
Details known to QTC, withheld due to confidentiality.
CI bas no further infornation t
Construction department concern.
IN-86-209-011: TVA fragments system responsibilities to minimize problems when an employee leaves. The overall result of this policy is that partial tests, partial reviews, and increased coordination efforts i
are required. This fragmented approach leads to nisunderstandings and mistakes, Trying to coordinate with several people leads to retestira, reworking, moving ecuipment, removing equipment, and removal and reinsta11ation of piping systems.
Systems may be broken up into several different tests, and you have several different engineers dotag the tests, i
. Interfaces are not always clear which leads to mistakes and misunderstandings.
With these interface problem test results could potentially be incorrect or incomplete.
CI has no additional information.
Nuclear power departnent concern.
II.
Summary of Issue Concern XX-85-001-001 addresses the lack of initial testing per IEEE-450 after the diesel generator batteries were replaced and potential reportability of this occurrence. This concern was initially addressed by the NSRS in report I-85-109-SQN issued November 18, 1985.
Several memoranda were also sent between Sequoyah ranagement and the manager of power and engineering concerning the NSRS investigation results.
Concern SQM-86-004-017 involved improper testing of some tubes on the fuel floor.
Concern WBN-233 addresses five issues associated with the fire protection system:
1.
Not enough approved manuals or prints for maintenance.
2.
No surveillance instructicn to check system from transmitter / receiver through console computer.
3.
No approved master list of printouts or modifications to systen.
4.
Individuals naintaining/ operating the system are inadequately trained.
5.
Availability of spare parts.
Concern XX-85-077-001 questions the adequacy of the preoperation prerequisites for unit 2.
Concern IN-86-209-011 identifies that test results could potentially be incorrect or inccmplete because of fracmentation of test responsibilities between several people.
III. Evaluation TVA evaluators reviewed the NSRS report written on the evaluation of Concern XX-85-001-001.
NSRS was initially assigred the responsibility for review of this concern. The NSRS review took place August 5-19, 1985.
The NSRS evaluation encompassed a review of the batteries at Sequoyah from issuarce of purchase order or transfer from enother TVA site through installation at Sequoyah. The NSRS found that after battery installation the pcst modification testing left questions unanswered concerning comnitments to IEEE-450. The reouirements of IEEE-450 are very similar to surveillance instruction 51-238.2 which was originally specified on the 1982 installation work package.51-238.2 was deleted from the work package according to a November 19, 1985, memorandum from li. G. Parris to K. W. Whitt because no
. commitment to do the testing existed.
SI-238 was performed instead of SI-238.2 to satisy the post installation test requirer.cnts.
SI-238 is used to prove TS operability of the batteries. TVA evaluators found that the six recomendations from the NSRS report, which include the testing issue, cell traceability, and generic applicability were addressed in memoranda between the site directors and the manager of power and engineering. There was a difference of opinion between the NSRS and TVA line management en whether Sequoyah had comitted to IEEE-450.
Evaluators found that shortly after the NSRS evaluation, TVA conducted the 60 month battery discharge performance evaluations (SI-238.2) for all four installed diesel generator batteries.
Evaluators found by interviews and from a nemo from the Sequoyah site director to the Director of Nuclear Services that SI-238.2 is now being required by plant management for the diesel generator batteries.
In addition they found that Sequoyah is intending to fully comoly with IEEE-450 for the diesel generator batteries based on an INP0 recommendation, however Sequoyah does not feel that it is a reculatory requirement or commitment to NRC.
In evaluating Watts Bar concern WBN-233, TVA evaluators determined that the only question applicable to Seoucyah was whether a SI exists to adequately test the system fror the transmitter /reciever panel through the console computer.
Evaluators identified a Sequoyah SI (SI-234) that tests the detectors loops from the local panels to the alarn ccmputer console.
This concern was evaluated as not valid at Sequoyah.
TVA evaluators reviewed the preoperational tests conducted from early 1981 to niddle 1982 for concern XX-8S-077-001.
The review included test summaries, test change sheets, test deficiencies, and test exceptions.
Evaluators found no indication of inadequate prerequisites in the preoperational tests reviewed.
This concern was evaluated as not valid.
In evaluating SOM-86-004-017, the evaluator reviewed the expurgated file but could find no information that defined the affected system or equipment.
The fuel racks were assumed to be the referenced equipment based on the fact that they were tested in a manner which was out of the ordinary. The Work Plan that installed and tested the fuel racks was reviewad for adequacy and the concern was determined not to be valid.
In evaluating IN-86-209-011, the evaluator assessed the methods by which technical responsibility for plant systems is assigned. As a result of identified problems in this area, Sequoyah has implemented a Systems Engineering Section who function is to provde a point of focus for the system history, status, special testing and resolution of major system problems.
The licensee has also shifted responsibility for the preparation of all post modification tests to the Department of Nuclear Engineering. This concern was considered to be valid.
IV.
Conclusion The NRC staff believes that the TVA investigation of the concerns was adequate, ano G oir resolution of the concerns as described in Element Report OP 30706 is acceptable for restart.
v SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2 SAFETY EVALUATION REPORT FOR EMPLOYEE CONCERNS ELEMENT REPORT NO. 307.07-SQN "RADIOLOGICAL EMERGENCY PREPAREDNESS" 1.
Subject Category: Operations Subcategory:
Nuclear Power / Site Program / Procedure Element:
Radiological' Emergency Preparedness Employee Concerns: JLH-86-004 XX-85-035-001 A.
Concern JLH-86-004 states:
"The evacuation route away from Sequoyah Nuclear Plant for area i
residents on both sides of the Tennessee River is inadequate.
A four-lane highway from the new Highway 27 to SON and across the Tennessee River to connect with I-75 would provide for a safe evacuation in case of a nuclear related accident."
8.
Concern XX-85-035-001 states:
"lodine table *t have been issued to Sequoyab site employees an the general pur. in the Sequoyah area, before the occurrence of a 3
radiation i..:ident.
The result is that these tablets may be used in an unsupervised and possible [ sic] hazardous manner."
These concerns were respectively evaluated by TVA as (A) Sequoyah-specific (not applicable to other TVA sites), and (B) potentially applicable to other TVA sites.
II.
Sumary of Issues A.
The first issue concerns the adequacy of evacuation as a planned protective measure for the general public in the event of a nuclear accident, given the existing system of roads in the area around Sequoyah.
B.
The second issue is that potassium iodide (K!) "tablets, which are used to reduce the thyroid uptake of radioactive iodine by individuals exposed to airborne radioactive material, may inappropriately er inadvertently be taken by indivicuals to whom K! has been cistributed in advance, potentially producing harmful side effects with no attendant health benefits.
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J 2
III. Evaluation A.
TVA personnel determined that, although the NRC requires nuclear power plant licensees to develop and implement emergency response plans which address evacuation and other protective measures for the public, neither TVA nor any other such licensee has the legal authority to implement protective measures outside the plant boundary.
Plans and provisions for evacuation of the public around Sequoyah are contained in the "Multi-Jurisdictional Radiological Emergency Response Plan" developed jointly by the State of Tennessee and the governments of the two counties within the 10-mile radius of the plant.
On the basis of l
review of the Plan and evaluation of several annual emergenc l
preparedness exercises, the Federal Emergency Management Agency (yFEMA) i has found that the Plan provides adequate protection for the population around Sequoyah.
j The TVA evaluation concluded that this concern was not valid since FEMA has stated that the counties within 10 miles have "demonstrated an adequate capability to evacuate the populace."
B.
TVA's investigation of the second concern noteo that KI has not been issued to employees at Sequoyan; such issuance (reserved for actual emergencies) is controlled by plant procedures.
Although it is true that the State of Tennessee has distributed K* to the householas withir.
a 5-mile radius of the plar.t. the decision to do so was made by the State.
'VA has no autrerity or control ove-decisions mace by t*e State.
TVA concluded that this concern was not valid because (1) TVA has not issued KI to site personnel, anc (2) the distributien of KI to area residents is a function of State anc local government, not TVA.
IV.
Conclusion The NRC staff believes that the TVA investigation of the concerns listed herein was adequate, and their resolution of the concerns as described in Element Report No. 307.07-SQN is acceptable.
~
I SEQUOYAH NUCLEAR POWER PLANT, UNITS 1 ANO 2.
SAFETY EVALUATION REPORT FOR EMPLOYEE CONCERNS ELEMENT REPORT OP 30708 "TRAINING PROGRAM FOR EMPLOYEES" I.
Subject Category: Operations (30000)
Subcategory:
Nuclear Power Site Programs / Procedures (30700)
Element:
Training Program for Employees (30708)
Concerns:
XX-85-058-001 XX-85-122-036 The basis for Element Report 30708 - SQN, Rev. 3, dated March 11, 1987, are the following employee concerns:
Concern XX-85-058-001:
Concerned individual (CI) stated that employees at Sequoyah are run through indoctrination training classes
- "like cattle."
Insufficient time is spent in training classes (specifically Health Physics) prior to being given tests.
l Instructors who are familiar with the subject matter.
"bree:e-through" the lessons.
Concern XX-85-122-036:
CI stated that Mproper reporting of events occurs at operating plants or in design /
construction.
TVA personnel are not adequately trained and are not knowledgeable in what is reportable.
4 II.
Summary of Issue Concern XX-85-053-001.
References the questionable quality of General Employee Training (GET) at Sequoyah due to class size and/or time spent in lectures.
Concern XX-85-122-036.
References improper recorting of events at opera-ting plants or in design /contruction possibly cue to lack of knowledge of the reporting requirements by TVA personnel.
III. Evaluation A.
XX-SS-053-001.
Tne concern was acequate:y accressed by the Nuclear Training Branch report dated September 19, 1985 The evaluation did not substantiate the concern. (500 850917 80 While the classes may have been large at times, no evidence that the quality of instruction was impacted could be found.
TVA has an ongoing l
2 improvement program to limit GET class size to a manageable level GET classes are taught b special training courses. y instructors certified by TVA through Approved lesson plans specify required material and time frames allotted.are used which Employees that require special attention receive additional help whenever an instructor is aware of the need.
vided to class attendees at the end of training classes. Course evaluat reviewed by responsible management and discussed with instructors.
These are Review of recent evaluation forms did not reveal any comments similar to the concern.
Although the concern was not ments have been tr<en:
substantiated, the following improve-Addition.: classes are scheduled for peak periods, such as o u t a t'l a.
At needed, special classes are held on back shifts.
A-evalua' tion of position requirements is being conducted to d4termine if some employees are being required to attend u necessarily.
This could contribute to reduced class size..
GET-2.4, level 0 Health Physics (HP) was implemented for those employees not requiring access to the power block, This also contributes to reduced class si:e in HP GET.
B.
XX-85-122-036.
The concern was initia'ty evaluated and determined not to be valid.
that NRC order modifying license, EA-S5-19, to Sequoya
- Ferry, required TVA to review and correct programmatic deficiencies in the reporting system.
The event wnich led up to the order transmitters at Watts Bar. involved the Electrical Qualification of certa This event took nearly 2 months before Sequoyah personnel were notified of the potential operational signif-icance of the engineering evaluation.
the subsequent reevaluation, Based on the NRC order and As corrective action to the order,the concern was reclassified as valid.
corrective action reporting system then '9TVA committed to revise the new CAQR reporting system.
use, which resulted in t~e Training for the new program was developed in two parts, for poten-tial initiators, and for potential CAQ Orocessors.
Training is scheduled to be completed prior to restart o f Uni t 2.
Licensee review of the training program revealed snat it acequately addressed the new requirements, with the approo-iate level of detail.
Personnel attending the processor cart to complete an exam at t.me conclusior ofof the training are required the a'ning.
IV.
Conclusion The NRC staf f believes that the TVA adequate, and their resolution of the concerninvestigation of the concern was Report OP 30703 is acceptable for restart.
as described in Element
i SEQUOYAH NUCLEAR POWER' PLANT, UNITS 1 ANO 2 SAFETY EVALUATION REPORT FOR EMPLOYEE CONCERNS ELEMENT REPORT OP 30711 "MANAGEMENT NONRESPONSIVENESS" I.
Subject Category: Operations (30000)
Subcategory:
Nuclear Power / Site Program / Procedure Element: Management Nonresponsiveness (30711)
Employee Concerns:
XX-85-116-001 XX-85-116-003 OW-85-001-002 TAK-86-007 XX-85-116-006 XX-85-116-014 Concerns were expressed in the area of management nonrespcasiveness as follows:
XX-85-116-001:
Chemical and radiochemical data of poor quality at Sequoyah could be very costly and cause e,tbarrassment to TVA.
XX-85-116-003:
TVA has exhibited a lengthy disregard tc.ard ful-filling commitments made to various regulatory and vendo, organi-zations with respect to chemical and radiochemical data used to monitor and control operations at Sequoyah.
A difference of opinion was identified between line management and NSRS regarding the definition of single failure criteria.
This dif ference was dropped by NSRS and line management with no resolution.
TAK-86-007:
Safety Margin will be greatly reduced because Shift Engineer / Senior Reactor Operator (SE/SRO) is busy and does not inform lead UO of maintenance activities.
XX-85-116-006:
Recommendations made by internal TVA organizations such as Nuclear Safety Review Staff (NSRS) have produced little results regarding correcting practices which lead to chemical and i
radiochemical cata of poor quality.
XX-85-116-014:
Management has signed of f secondary water chemistry l
conditions that were in violation of the Technical Specifications 4
without having an engineering evaluation performed in violaticn of site procedures.
Time period of 1985.
1 II.
Sumnary cf Issues I
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TVA identified that these concerns address the following issues:
j 1.
The suspect quality of chemistry and radiochemistry data 1
2.
Inadequate chemical / radiochemical program l
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2 3.
Unresolved definition of single failure criteria 4.
Unit operator (U0) not informed of maintenance activities
.5.
The violation of Technical Specifications for secondary system water chemistry III. Evaluation IVA evaluated these concerns as follows:
XX-85-116-001:
The licensee evaluated the chemistry laboratory quality control program through review of procedures, compliance, and INP0 and NRC reports.
Outside of minor items and a comment on cleanliness in the 1985 report, nothing was found to substantiate the allegation.
The 1986 NRC report had no adverse comments on the cher. i stry program.
XX-85-116-003 and XX-85-116-006:
These two concerns were investi-gated and documented by NSRS Investigation Report No. I-86-130-SQN.
The evaluator noted that the initial NSRS report (R-82-08-NPS) was not clear as to specific deficiencies in the chemistry program, nor was the area given a very nigh priority in the report. Sequoyah has committed to investigate and correct the deficiencies identified in the report.
XX-85-116-014:
The evaluattor. noted that elements to be included in the secondary water chemistry program were specified in lechnical Specificat'.ons.
Limits, frequencies, and corrective actions were specified in SQE-22, "SNP Chemistry Program." A review of the data and logs for the period did not identify an error of the type described in the concern.
7 OW-85-001-002:
The evaluation indicated that after a search of records and interviews with cognizant individuals, that no specific incident of disagreement of the application of single failure criteria was found for Sequoyah.
i TAK-86-007:
The evaluation validated this concern beiause the potential exists for a reduction in the safety margin due to unit activities occurring without the unit operators knowledge.
Therefore, TVA has committed to reinstitute the requirement for the unit operator's signsture in MI-6.20 for work on equipment not covered by a clearaiice.
(CATO-30711-SQN-03).
The licensee evaluators concluded:
The Sequoyah Chemistry program as defined in SQE-22 was judged to be aceouate.
Sequoyah has and is. continuing to take action to investigate and correct the deficiencies identified in NSRS Report No. R-32-03-NPS.
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Sequoyah has committed 'to revising MI-S.20 within six months. This corrective action appears to be acceptable.
l The concerns with the exception of TAK-86-007, were not substan-tiated.
IV.
Conclusions The NRC staff believes that the TVA -investigation, conclusions, and corrective actions for employee concerns Element Report '30711.are accep-
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table for restart.
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SEQUOYAH NUCLEAR POWER PLANT, UNITS 1 & 2 SAFETY EVALUATION REPORT FOR EMPLOYEE CONCERNS ELEMENT REPORT 30713 "CONFIGURATION CONTROL" 1.
Sublea Category: Operations (30000)
Subcategory:
Nuclear Power / Site Program / Procedure (30700)
Element:
Configuration Control (30713)
Concerns: XX-85-062-003 XX-85-071-N05 IN-85-984-001 BFN-1 ESC-85-03 The Basis for Element Report 30713-SQN, Rev. 6 dated March 3, 1937, are the following employee concerns.
XX-85-062-003 Sequoyah, Browns Ferry:
CI was unoff.icially informed that the drawings, in many instances, are not a true representation of the installation.
Nuclear Power Concern.
CI has no more information.
Concern XX-8'5-062-003 is shared with the Engineering Concern Evaluation Group and is also addressed by element report 20601.
XX-85-071-N05 NRC identified the following concern from review of the QTC file.
"Drawings in the control room do not reflect actual plant con figura t ien. "
4 i
BFN-IESC-85-03 Concerns expressed regarding.
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1.
Process for evaluatien of 10 CFR 21 appitcability 2.
Inadequate understanding of the level of centrol required in nuclear parts program is indicative of weakness in NQAM 3.
Configuration control The first two items in this concern are not related to configurati:n control and are ::eing addressed by tne Quality Assurance CEG.
)
2 IN-85-984-001 The Nuclear Power Department changes hardware without changing the drawings.
EG:
Ladders to tops of filter cubicles in Auxiliary Building Number 1 and common areas on 676', 692' and 737' elevations in hair to allow removal during filter plug removal, but were cut drawings were not changed.
1982 Construction Department concern. CI t
has no further information.
II.
Summary of Issue TVA perceived the issue to be a lack of configuration control.
III. Evaluation The concerns were evaluated as one under the topic of configuration control and concentrated on five aspects:
1.
The validity of the concerns.
2.
The adequacy of the NSRS evaluation report and the recommendations contaf'.ed therein.
3.
Verification of the line response to the NSRS report.
4.
Verification of corrective action taken by line management.
5.
The adequacy of corrective action to resolve the concerns and prevent recurrence.
Concern XX-85-062-003 was a SON and BFN concern, XX-85-071-N05 was SON specific, and BFN-IESC-SS-03 was BFN specific.
IN-35-984-001 was a WBN The NSRS investigation report covered SCN, BFN, and BLN.
The concern.
recommendations made were specific to the plants as well as pragrammatic in nature, thus impacting DNE.
For this reason, the concerns are considered generic to all TVA nuclecr plants.
This evaluation produced findings which substantiate the facts forming the basis for the concern.
The NSRS recommendations could correct the defi-ciencies.
The corporate management attertion to configuration control as evidenced by the Configuration Control Task Force and tne new design control programs initiated under the Corporate Nuclear Performance Plan are consistent with the NSRS recommendations.
Until all of the commit-ments made in tnis area are implemented in working-level procedures, however, configuration control may continue to be inadequate when station modifications are made.
At present, the SCN as-constructed drawings do net :cmoletely represeat the plant configuration, but the engoing Sequeyan :esign Baseline arc Verification Program snould resolve the deficiencies and produce a set of accurate drawings.
.m m-a-
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Conclusion The NRC staff bwlieves that the TVA investigation of the concern was adequate, and their resolution of the concern as described in Element Report 30713 is acceptable for restart.
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OEQUOYAH NUCLEAR POWER PLANT, UNITS 1 AND 2 SAFETY EVALUATION REPORT FOR EMPLOYEE CONCERNS ELEMENT REPORT 30901 "ADEQUACY OF PROCEDURE" I.
Subject Category:
Operations (30000)
Subcatergory:
Engineering (30900)
Element:
Adequacy of Procedure (30901)
Concern:
IN-85-977-001 The basis for Element Report 30901 - SQN, Rev. 3, dated March 17, 1987, is Watts Bar Employee Concern IN-85-977-001 which states:
TVA management has stated that teflon tape which war used on the Reactor Coolant System (RCS) must, be identified and replaced with another type of tape, however no program to accomplish this task has started.
This concern was evaluated by TVA as not safety-related.
II.
Summary of Issue TVA perceived the issue to be lack of implementation of a program to identify and replace the teficn tape used on the RCS and those systems that return to the RCS.
Teflon tape, which is used as a gasket and/or sealant, deteriorates under certain integrated radiation exposures (approximately 100000 R) or tem-peratures in excess of 300 degrees F.
The tape will become brittle and release snacceptable concentrations of halogens, specifically fluorides and chlo ides which can induce stress corrosion cracking of stainless steel.
As a result of the NRC inspection of the Watts Bar site, which identified inappropriate use of the tape at the site, the criteria for unacceptable teflon tape application appears in Sequoyah procedure SQA-160 which prohibits the use of this tape in areas where:
Temperature exceeds 300 degrees F Integrated radiation doses exceed 100000 R Environment drawings were used to determine areas of concern.
The Sequoyah review identified two instances of raisapplication of teflon tape which were corrected by use of a licensee approved substitute.
The licensee has stated that the misapplication of teflon tape represents a reliability problem rather than a safety problem since stress-corrosion cracking will result in a leak before crack.
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III. Evaluation The NRC agrees that the criteria used to evaluate the application of teflon tape appears to be adequate.
The licensee's approach of using environmental data, in part, to perform the review, also appears to be acceptable.
The licensee's use of procedural controls to limit the use or future use of teflon tape should be effective provided procedural compliance is assured.
The NRC does not agree that the misapplication of teflon tape only repre-sents a reliability problem. This is based on recent safety events which have resulted from water level transmitter anomalies which were, in part, caused by undetected leaking sensing lines.
In some cases, the leaks j
resulted from induced stress corrosion cracking.
Subsequent to tne initial evaluation, the licensee has conducted addi-tional training of personnel on the restrictions on tape usage and some suitable replacement. materials have completed testing and evaluation at TVA's Singleton Lab.
'V.
Conclusion Although.the NRC does agree that replacement of teflon tape identified in unacceptable locations is not a startup' issue, the licensee needs to i
better define the tape replacement program.
Resolution is needed on issues such as the removal of the third restriction in upper tier docu-ments concerning the use of teflon tape on lines that will re-enter the RCS.
Additionally, a decision is needed on the replacement of tape used solely as a lubricant that is not part of the system pressure boundary.
There does not appear to be a single defined tape replacement plan, but rather several different plans. The licensee has identified this item for resolution.
Both the licensee's original criteria and evaluation for the acclication of teflon tape appears to be adequate for restart of Sequoyah.
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ENCL.0SURE 1 SEQUOYAH NUCLEAR PLANT SAFETY EVALVATION REPORT FOR EMPLOYEE CONCERNS I.
Subject:
Category: Operations (3000)
Subcategory:
Engineering Element:
Engineering Training II. Sunnary of Issue Concern:
IN-86-209-012 The basis for Element Report 309.05-SQN, Rev. 1 dated October 20, 1986, is the following employee concern:
)
Concern IN-86-209-012 stated:
"Personnel perfonning STA (Shift Technical Advisor) Training are engineers with little or no experience as an STA themselves.
It was noted that two persons that were being processed j
through a particular STA class, were scheduled to teach the next cless of STAS.
Engineers are being assigned the task of training STAS in plant operations for which they themselves have little or no experience."
III. Evaluation:
TVA's evaluation of this concern involved the review of regulatory requirements, TVA commitments and procedures, STA instructor assignments, and the qualifications of the it.itruc tors for those assignments.
Interviews with cognizant personnel were also conducted to determine the adequacy of the instructor's techniques.
A review of regulatory rec.rements in ANSI 3.1, NUREG 0660, and NUREG 0737, revealed that there are no requirements for STA instructors to be experienced STAS.
Rather, the requirements are that the instructors be "technically qualified for the subjects taught."
Nuclear Training Program Manual Procedure 0202.07 governs the TVA Shift Technical Advisor Training Program, and Sequoyah Engineer Training Section Letter ETS-1-STA implements the requirements of 0202.07.
TVA's procedure requirements were found to be comparable to those in the rest of the industry.
Concerning the two individuals in question, TVA investigated this particular case and found a file memorandum that explains the actions questioned.
The memorandum lists the qualifications of STA instructors
2 used during the last two years and identifies two individuals assigned training duties for the cless immediately following the classes they were attending.
These instructors were used only in areas where they had particular expertise due to previous experience.
This is in accordance with the requirements of ETS-1-STA.
Additionally, while these two instructors did not have experience as STAS, they did have extensive experience previous to their assignments as STA instructors and had passed the STA certification course which requires an average of 80 percent in scores.
Concern IN-86-209-012 was substantiated, in that there were two instructors assigned training duties with little or no STA experience.
However, the qualifications of these two individuals were 3
well matched to the subject matter assigned.
The duties assigned were also well within the requirements, both regulatory and TVA, for STA instructor qualification.
Root cause of this concern appears to be that the concerned individua.1 was not fully aware of the previous experience of the instructors involved.
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IV. Conclusion:==
The NRC staff believes that the TVA investigation of the concerns was adequate, and their resulution of the concerns as described in Element Report 309.05-SQN is acceptable.
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SEQUOYAH NUCLEAR POWER PLANT, UNITS 1 AND 2 SAFETY EVALUATION REPORT FOR EMPLOYEE CONCERNS ELEMENT REPORT OP 31001 "0PERATOR'S PROGRAMS / PROCEDURES INADEQUATE" I.
Subject Category:
Operations (30000)
Subcategory:
Operational (31000)
Element:
Operator's Programs / Procedures Inadequate (31001)
Concerns:
SQP-5-003-001 SQP-5-003-002 XX-85-067-001 SQM-6-013-002 SQP-6-010-001 XX-85-022-001 IN-85-933-001 IN-85-933-010 XX-85-007-002 The basis for Element Report 31001 - SQN, Rev. 3, dated November 13, 1986, are the following employee concerns.
Concern SQP-5-002-001:
Concerned Individual (CI) stated that an unit operator told an electrician to operate a valve in the Unit 2 RHR systen, that a unit cperator is not authorized to give such directions anc' tnat the action resulted in a spill of highly radioactive water.
CI further stated that the incident was covered.
uo.
Concern SQP-5-003-002:
CI expressed that management or supervision nave an attitude of "hurry up and get the job done" in an ef fort to get the plant on line.
Cl feels that procedures are not being followed in an effort to accomplish work as soon as possible, and evidenced this oy the radioactive spill which cccurred on December 9, 1985, as addressed
'n concern SQP-5-003-001.
Cor.ce n XX-85-067-001:
- expressed that small problems.n plant operation were df sregarded (1983) and Unit I was kept operat' g as
'f in a ace, which
-esulted in bigger prob' ems.
Concern SQM-6-013-002:
CI feels that an itemized list for tne proper size voltage, amperage, and type of bulbs and fuses needs to be available to
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s operations for all equipment under their control.
Concern SQP-6-010-001:
CI feels that electrical switch boxes should be locked and the electrician performing the work should have the associated key while performing work on electrical lines (rather than just tagging switch boxes controlling the lines).
Concern XX-85-022-001:
CI states that operators began to fill a system prior to the completion of work.
The concern implies that the system had been tagged for work.
Concern IN-85-933-001:
CI tates that TVA's program of placing degreed engineers as SR0s with only 20 months of plant experience will reduce the level of safety by having individuals in charge who do not know how to react to and resolve the practical problems that will be encountered during operations.
Concern IN-SS-933-010:
CI states that TVA should continue to expand its program of having experienced operations personnel obtain college degrees to be licensed as SR0 rather than implemen-ting its more recent plan of making SR0s out of degreed engineers who have no actual hands on operat':9 experience.
Concern XX-85-007-002:
CI states that ieak occurring in April 1933 in Unit 2 reactor was due to management's desire to break time record.
Result was contamination of 500-600 gallons.
II.
Summary of Issue TVA perceived the issue to be past or potential incidents involving operations personnel directly related to a lack of experience or training.
Concerns SQP-5-003-001 and SQP-5-003-002 botr "eference a speci fic inci-I dent on December 9, 1985, where a unit operator told an electrician to operate a valve tnat resulted in a spill. Adcitionally, the incident was alleged to not have been reported (cover-up).
Concern XX-85-067-001 references that smail : colens were c'sregarcee during 1933 and Unit I continued to aemain fa ::e*ation as if '
a race resulting in bigger proolems.
Concern SON-6-013-002 suggests that itemized lists for the :: roper size voltage, amperage, and. type of bulbs and fuses need to be available to operations for all equipment under their control.
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3 Concern SQN-6-010-001 states that electrical switch boxes should be locked during work with the key in the possession of the electrician performing the work.
Concern XX-85-022-001 describes an alleged incident where operators began to fill system piping before work was completed. The concern implies that the system was tagged for the work.
Concerns IN-85-933-001 and IN-85-933 010 are both related to the use of degreed engineers as SR0s rather than more experienced operations personnel.
Concern XX-85-007-002 deals with alleged management desire to continue operation of Unit 2 durin*g April 1983 in order to break a record.
The continued operation resulted in a leak and contamination of 500-600 gallons.
III. Evaluation A.
SQP-5-003-001 and SQP-5-003-002.
The TVA Evaluator reviewed the specific incident associated with the spill that occurred on
')ecember 9, 1985.
The contaminated spill occurrence had been sub-stantiated in NSRS Report I-85-137-SQN. An operating permit had not been issued to allow the electrician to operate the valve without an operator present.
This practice was in violation of licensee pro-cedures, but the failure did no,t directly cause the spill and the spill would probably still have occurred with an AVO present, due to leakage from another valve.
Operations personnel have been instructed to discontinue the above practice for all future work.
Additionally, the incident had been properly documented and recorded in the unit operator and health physics daily journals with no evidence of a cover up.
2.
XX-85-067-001.
NSRS Report I-55-862-SCN adequately addressed the The evaluation consisted of a review of previous NRC SALP concern.
reports, LERs, NRC violations and monthly operating reports submitted to the NRC.
Interviews were conducted with personnel knowledgeable of operations / maintenance activities in 1983. The licensee could not substantiate the concern in that no specific problems were identifie::
that related to Unit 1 operations in 1983 that were disregarded for the sake of unit operation which resulted in more serious oroblens.
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SQN-6-013-002.
The evaluation resulted in tne licensee cerceiving this as a matter of convenience rather tran a safety concern, and it would be treated as a suggestion.
Work clans have been written to add updated fuse discriptions.
The licensee feels that tne acticn would be helpful but not necessary for centinued unit coeratic9.
O.
SQN-6-C10-001.
The evaluator reviewed e c:nce n wni:
sas asic-ciated with an alleged tagging incident whicn occurred curing the early construction phase at Sequoyah.
The main point of concern appeared to be dissatisfaction with the method utilized to clear high voltage lines for work.
The review consisted of current tagging
4 practices including the clearance procedure administrative instruc-tion (AI) AI-3. While the evaluation was unable to reveal any facts directly related to the described event in 1973, it did conclude that present instructions covering the clearance procedure are effective.
Sufficient safeguards are presently required by AI-3 so as to invali-date any necessity to allow a maintenance worker to personally retain a key to ensure his safety.
E.
XX-85-022-001.
The evaluation of the alleged incident revealed that no such incident occurred. However, on September 11, 1984, SI 166.10
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was performed, requiring removal of blind flanges and installation of test flanges to test check valve leak rates in system 63 (Safety Injection System).
This work is very similar to that described in the concern.
The flange removal was conducted via a maintenance request with no tagging required.
Interviews with maintenance individuals involved in this particular SI revealed no problems which could have resulted in this concern.
The licensee was not able to confirm or disprove occurrence of the concern. Although no evidence exists to substantiate such an assumption, the concern could have resulted from failure of a maintenance worker to fully-understand that a section of piping may become refilled due to valve leakage or that various sections of piping may not be drained prior to initial work due to the piping configuration.
No documented evidence could be found implicating operations personnel in a tagging discrepancy.
F.
IN-85-933-001 and IN-85-933-010.
Both concerns were investigated adequately by a Generic Concern Task For:e report dated April 26.
1936, entitled SRO/ Engineers Lack Plant <nowledge.
The evaluation consisted of interviews and review of va 'ous licensee documents and NUREG 0737.
The licensee made the follew'ng conclusions:
TVA's program to license degreed engineers meets or exceeds federal licensing recuirements.
The degreed engineers are required to :: ass the same NRC admin-istered exam as non-degreed personnel.
Plant management would not jeooardi:e plant safety by placing ar SR0 in a line supervisory function 4' nis.her capabilities were in question.
l As a rcsult of these findings and since
- t. aualified candicates would be eliminated through the varicus staces Of the screening and exam processes, tnere exists no verifiable r+ason to suspect reactor safety will ever be jeopardi:ed as a resU t of this program.
G.
XX-85-007-002.
!ne concern was adequate;y acc-essed in NSR'S Report I-35-372-SQN.
Ocerating legs for the oeried :f April - July 1933 aere reviewed along witr Dotential Re:crtaole
- urrence (FRG) Repc-t No. 2-83-71.
The investigation revealed that tne Unit 2 No. 3 steam generator experienced a through wall tube leak in early May 1983 (not April as stated).
This resulted in leakage of reactor coolant into
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the secondary side of the steam generator.
However, the evaluation was not able to substantiate the concern for the following reasonsi No objective evidence was found that indicated that a record run time was the main consideration for continued operation.
The leak was not caused by management actions or lack of action, but by movement of a loose metal piece rubbing against the tubes.
The leakage did not exceed allowable limits duri1g the period.
IV.
Conclusion The NRC staff believes that TVA's investigation of the concern 'was adequate, and their resolution of the concern as described in Element Report OP 31001 is acceptable for restart.
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ENCLOSURE 2 SEQUOYAH NUCLEAR PLANT SAFETY EVALUATION REPORT FOR EMPLOYEE CONCERNS I.
Subject:
Category:
Operations (3000)
Subcategory:
Operations / Operational Element: Operator Qualifications II. Sumary of Issue:
Element Report 310.02-SQN, Rev. 2 dated October 31, 1986, addresses a number of employee concerns.
The following concerns were reviewed and incorporated into this element report:
XX-85-048-002: At Sequoyah, the major responsibility for 'irefighting has been turned over from Public Safety Service to the Fire brigade.
Since most Public Safety Officers have been trained in the State Fire Training School and the Fire Brigade has not, CI feels that the Fire Brigade's lack of expertise will pose a fire protection problem at Sequoyah.
CI stated that at Browns Ferry NP, Public Safety was chosen to provide fire protection services and questions why Sequoyah did not.
X X-85-093-001:
Sequoyah's Shift Engineers (SE) and Assistant Shift Engineers (ASE) are inadequately trained in electrical station operation (Switchyard, off-site power feed, etc.) such that there could be an excessive delay in restoring off-site power feed to the plant in the event of an emergency.
CI feels that SE/ASE personnel should receive better training in this area.
XX-85-093-002:
Bellefonte:
(Same concern as XX-85-093-001).
XX-85-093-003: Browns Ferry:
(Same concern as XX-85-093-001).
WI-85-060-001:
Watts Bar:
(Same concern as XX-85-093-001).
IN-85-289-001:
(Watts Bar) operators have already made errors during hot functional testing in unit 1, approximately one year ago (1984) which would have been significant if plant had been operating.
CI expressed concern regarding the inadequate qualifications and training of operators.
IN-85-767-006:
CI expressed that plant operators are not adequately trained to nor abide by the QA requirements of plant procedures.
s 2
IN-85-894-001:
Plant operators are inadequately trained for their positions.
The CI listed several incidences as examples.
1.
An oil ring blew-up while replacing filters in mechanical maintenance, due to head p res sure.
2.
Women operators do not have enough strength to open and close isolation valves.
CI had to help many times.
3.
While hot l
functional testing about a year ago, Hydrazine spilled all over people and the floor in South Valve Room, Unit 1, Auxiliary Building, Elevation 737'-0" due to operater error.
IN-86-209-013:
Since the plant operator training was conducted at the same training center, under the same management as the STA (Shif t Technical Advisor) program; the quality of the operator training that started approximately ten years ago may have been as inadequate as the STA l
training.
III. Evaluation:
Concerns IN-85-289-001, IN-85-894-001, WI-85-060-001, IN-86-209-013, and XX-85-093-002 were previously evaluated by the Sequoyah Generic Concern Task Force [GCTF) and their results documented in a report dated April 22, 1986.
The concern regarding errors made during hot functional testing in concern IN-85-289-001 is specific to Watts Bar and not evaluated for Sequoyah.
The overall operator qualifications and training were evaluated.
Concern XX-85-093-001 was previously evaluated by NSRS and their results documented in NSRS report I-85-619-SQN.
These reports were reviewed to determine if they adequately addressed and resolved the issues.
It was concluded that the reports adequately covered the issues.
Since concern XX-85-093-003 is identical to concerns XX-85-060-001, XX-85-093-002 and WI-85-060-001, the findings of the above two reports are considered to have equal applicability to XX-85-093-003.
Concern IN-85-767-006 was previously evaluated by the GCTF and their findings documented in a report dated May 17, 1986.
This report was reviewed to determine if it conclusively established that operators receive adequate training on QA requirements and abide by the QA requirements of plant procedures.
Concern XX-85-048-002 has not been previously investigated.
The scope of this evaluation was to determine if the Fire Brigade at Sequoyah is adequately trained in firefighting techniques and if there is a fire problem because of the Fire Brigade's lack of experience.
l 3
Applicable procedures for SQN were reviewed for all areas identified by the above concerns and interviews with cognizant personnel were conducted.
TVA concluded that concern XX-85-048-002 is not valid due to the fact that SQN's major firefighting responsibilities have not belonged to the Public Safety Officers (PS0s) since 1979 and then subsequently turned over to the Fire Brigade.
The Fire Brigade receives extensive comprehensive training and firefighting practice to ensure there is no lack of experience on the fire brigade. Also, Browns Ferry PS0s have no fire protection responsibil-ities in the plant operating areas.
]
Concerns IN-85-289-001, IN-85-894-001, WI-85-060-001, IN-86-209-013, IN-85-767-006, and XX-85-093-001 are not valid based on the following conclusions as stated in the two referenced Generic Concern Task Force reports, and NSRS report I-85-619-SQN:
1.
Sequoyah SEs and ASEs are given extensive training on the use and issuance of clearances.
This training includes detailed examination 1
process assuring the competence of licensed oeprators (ASE or SE) to issue safe clearances.
2.
Sequoyah operators at all levels receive training on the use of clearances.
3.
No evidence could be accumulated either by interview or computer data base search of potentially reportable occurrences (10 CFR 50.72 or 10 CFR 50.73) caused by mishandled clearances at Sequoyah.
4.
TVA NSRS issued a report, I-85-619-SQN, which supports the adequacy of Sequcyah's electrical switchyard training for SEs and ASEs.
5.
Sequoyah operators receive training that meets NRC requirements, and Sequoyah's training program has received INP0 accreditation.
6.
Interviews with operators (U0 and ASE) accumulated no evidence of physical incapability of women to adequately perform AU0 duties.
7.
The issue of operators not being adequately trained on QA require-ments is perceptual and an individual opinion.
Training on the QA requirements is conducted both formally in the classroom and infonnally by way of required reading, which is documented per OSLT-1.
8.
The issue of operators not abiding by QA requirements in plant procedures has no generic basis and must be handled on a case by case basis.
9.
The Operations Section Letter, OSLT-4 is outdated and not being used.
O 4
- 10. The Sequoyah shift engineers and assistant shift engineers are given i
extensive training in the operation of the switchyard (both classroom andon-the-job).
The training meets NRC requirements.
- 11. No examples of poor switchyard operation or operation of this equipment in a manner that endangered the nuclear equipment at Sequoyah was found.
12.
The shift engineers and assistant shift engineers receive training in electrical station operation that meets the NRC requirements, and the Sequoyah training program has received INP0 accreditation.
==
IV. Conclusion:==
The NRC staff believes that the TVA investigation of these concerns was adequate and their resolution of the concerns, as described in Element Report 310.02-SQN, Rev. 2 is acceptable for restart.
The NRC has separately given operator requalification examinations at Sequoyah and found tha operator knowledge adequate, although the training program was deemed marginal based on failure rate.
Future NRC exams and training inspections will continue to assure that operator knowledge remain's adequate.
SEQUOYAH NUCLEAR POWER PLANT, UNITS-1&2 SAFETY EVALUATION REPORT FOR EMPLOYEE CONCERNS ELEMENT REPORT OP 311.01 "HEALTH PHYSICS STAFF TRAINING" I.
Subject Category: Operations Subcategory:
Health Physics Employee Concerns:
XX-85-024-001 XX-85-102-009 XX-85-102-012 The basis for Element. Report OP 311.01, dated August 16, 1986, are the following employee concerns:
Concern XX-85-024-001:
Health Physics personnel are not aware of protective equipment required for work area.
Example:
HP at entrance to radiation area informed craf t that particulate masks were not required. While working, HP told craft to stop work and leave area because they did not have particulate masks.
This happened in 1983 and 1984.
Nuclear Power Concern Units 1 and 2.
Concern XX-85-102-009:
The permanent plant Health Physics people are poorly trained.
Concerned Individual (CI) does not feel the present HP staff has an adequate knowledge of working in radiated areas.
Concern XX-85-102-012:
The permanent plant Health Physics people are poorly trained.
CI does not feel the present HP staff has an adequate knowledge of working in radiated areas.
II.
Summary of Issue Concern XX-85-024-001 references a specific incident where HP informed workers entering an area that respirators were not required and the HP at the job site later stopped work and made them leave because they did not have respirators. This event cause the concerned employee to believe that HP personnel were not aware of protective requirements before allowing
o' 2
access to work areas. TVA could not investigate the circumstances of the alleged specific event due to a lack of further details and due to the time since the event.
Concerns XX-85-102-009 and XX-85-102-012 are general statements concerning poor training of HP personnel and their inadequate knowledge of working in radiation areas.
TVA evaluated the concerns, therefore, from a general programmatic standpoint within the of training of HP technicians in establishing protective areas requirements, HP technician stop work authority, HP technician error and establishment and revision of radiation work permit requirements.
III. Evaluation TVA reviewed NRC, INPO, and TVA Quality Auditing Branch (QAB) audits to determine if any deficiencies related to the concerns had been identified by these groups.
The HP technicians training program was reviewed.
Selected HP technicians were interviewed to determine their ability to evaluate and specify protective requirements.
TVA personnel reviewed licensee proced'Jres which allowed HP technicians to stop work. A review of Radiological Incident Reports (RIR) written during the period of 1983 and 1984 did not reveal any situation where a technician was disciplined for failing to follow good radiological practices.
TVA personnel deter-mined that adequate training and procedural guidance was provided to the HP technicians in establishing and revising radiation work permit requi re~ ment s. TVA concluded that there no-major programmatic deficiencies in the training provided HP technicians.
IV. Conclusion The NRC staff believes that TVA investigation of the concern was adequate, and their resolution of the concern as described in Element Report OP 311.01 is acceptable.
SEQUOY AH NUCLEAR POWER PL ANT, UNITS 1 ', 2 SAFETY EVALUATION-REPORT FOR Et1PLOYEE CONCERNS ELEMENT REPORT 300.02-SON "PREVENTIVE MAINTENANCE" Hybigqi Category:
CPERATIONS (30000)
Subcategory:
MAINTENANCE (30800)
Element: PREVENTIVE MAINTENANCE (30802)
Concerns:
IN-86-316-XB9 The basis for Element Report 308.02-SON, Rev. 5, dated January 6, 1986, is the following employee concern IN-86-316-X89:
"TVA could not have a safe and adequate Preventative Maintenance Program if engineering continued to disregard the vendors
- manuals for safety-related equipment."
II.
Systaty_ai,[ssug The concern involved the use of vendor manuals in the Preventive Maintenance Program.
The licensee determined that the specific concern as stated above was not valid.
!!!. Eyalygt[og Concern IN-86-316-XO9 specifically states that engineering had disregarded vendor manu,al requirements for safety-related equipment in the Preventive Maintenance Program.
Interviews conducted by the licensee specifically covering this concern indicated that cognizant engineers performing vendor manual reviews and using procedures had not disregarded vendor manuals.
The NRC notes that the licensee indicates that the vendor manual control program had weaknesses and that the preventive maintenance procedures were unclear and lac' ed detatl.
The licensee has undertaken long tera prograss to correct these deficiencies.
Although the licensee indicates that the specific concern on the disregard for vendor manuals was not substantiated, the NRC notes that programmatic deficiencies in these areas have resulted in problems in the implementation of vender manuals and inconsistent application of the vendor manual requirements and lack of documentation f or omitted vendor manual requirements.
The long ters corrective actions will accomplish a review of all plant safety-related vendor manuals and upgrade of procedures to assure coverage of pertinent requirements.
The licensee's corrective actions for the deficiencies are comprehensive and should assure that vencor manual requirements are. evaluated and appropriately included in procedures.
Cggq[gsigg
~. ;
The NRC staff believes that the TVA investigation of the concerns was adequate, and their resolution of the concerns as described in Element Report 308.92-SQN 15 acceptable for restart.
1
'l SEQUOYAH NUCLEAR POWER PLANT, UNITS 1 & 2 SAFETY EVALUATION REPORT FOR EMPLOYEE CONCERNS ELEMENT REPORT 308.03-SON "CORRECTIVE MAINTENANCE" I.
Sybjggt Category:
OPERATIONS (30000)
Subcategory:
MAINTENANCE (30800)
Element: CORRECT!VE MAINTENANCE (30803)
Concerns:
XX-85-096-005 XX-85-096-N07 GSB-85-001 DHT-85-003 2S50162005 SQP-86-014-002 XX-85-071-003 The bases for Element Report 308.03-SON, Rev. 3, dated December 31, 1986, are the following employee concernst XX-85-096-005:
The Radiation Monitor Tube problem (Thimble Guide Tube incident) in Unit 1 in April 1985 could occur again, because the equipaent is not properly designed to be fixed during plant operation.
XI-85-096-N07:
NRC identified the following concern from review of QTC file.
" As a result of the thimble tube incident about 34,000 gallons of radioactive water spilled but was aisrepresented to the NRC as no amount of leakage and as a small instrumentation leak."
GSB-85-201:
Sinct we do not check calibration of torque wrenches immediately after a job, we could have degraded bolting when we start-up and could contribute to nuclear safety problems, shutdown and increased dose due to rework on more than one job.
DHT-85-003:
CI is concerned that due to limited knowledge and understanding of requirements, and due to mechanical work being classified CSSC while electrical and instrument work is classified non-CSSC, the natntenance work performed on ABSCE, fire and security doors is inadequate to teet the requirements applied to these doors.
2850162005:
TVA makes repairs to their nuclear plants which are not in accordance with ASME codes, such as overlays, catches, and even furaanite (sophisticated glue).
SOP-86-814-002:
Although the foresen are recutred to sign a document 1
stating they have reviewed the work package with the craft assigned to the job, they in fact often do not review the work package at all with the applicable craft.
Nuclear Power concern.
4.
IX-85-071-003:
Sequoyah:
Cl has general questions about hardware repair process and requested that OTC investigate.
Details known to OTCt withheld to maintain confidentiality.
11.
Suegaty_gi.issus The concerns are miscellaneous concerns in the area of corrective maintenance.
The licensee review of the employee concerns substantiated five of the concerns (XX-85-096-005, XX-85-096-N07, GSB-85-001, DHT-85-003, 2850162005), and f~ound that one concern (SQP-86-014-002) was not substantiated.
Concern XX-85-071-003 could not be evaluated by the licensee since details of the hardware repair process concern were withheld to protect confidentiality.
Ill Eva[3ation 1.
Concern XX-85-096-005 The concerned individual. stated that the thimble gutde tube incident on Unit 1 in April 1985 could occur again because the equipment is not designed to be fixed during plant operation.
The licensee committed to the NRC that cleaning of thimble guide tubes with system pressure above atmospheric pressure would be prohibited in LER 327/84030, Rev.
1.
The NRC Residents reviewed the corrective actions to assure that procedures prohibited the cleaning of thimble tubes at power and determined that appropriate changes had been made.
LER 327/84030, Rev.
1, has been closed.
2.
Concern XX-85-096-N07 The concern involved the misrepresentation of the amount of l
ra'dioactive water spilled durin.g the thimble tube event on Unit 1 in April 1985.
The licensee substantiated the concern and a revised LER (327/84030, Rev. 1) was provided to the NRC.
The NRC Resident inspectors have reviewed the corrective actions for LER 327/84030, Rev. 1, and closed the LER.
3.
Concern GSB-85-001 The conc er r.ed individual stated that calibration cf torque wrenches was not checked immediately after a job.
The licensee indicated that the concern was substantiated.
The licensee revised procedures t
to require that measuring and test equipment (MkTE) be revtewed upon return to the tool room to ensure the tool was in calibration.
The NRC reviewed the M&TE program as documented in NRC Insoection Reports 327, 328/87-15 and 327, 328/87-37.
All open items in this area have been closed.
4 Concern DHT-85-003 The concerned individual indicated that maintenance en Auxiliary Building Secondary Cor.tainment Enclosure (ABSCE), fire and security doors was inadequate.
The. concern was substantiated.
The licensee has submitted several LERs to the NRC identifying the defteient
, =,
)
/
i i
doors.
NRC review indicated that the licensee has established a
dedicated door crew specifically trained to perform door maintenance
{
to assure that ABSCE, fire and security requirements are set.
5.
Concern 2950162005 The concerned individual stated that TVA makes repairs to the plant
~
which are not in accordance with ASME codes.
The concern in the maintenance area was limited to the use of tesperary leak repairs using viscous fluids.
The concern was validated by the licensee in that appropriate engineering evaluations of the consequences of metal remov'al, shifts in gasket loading.and material compatibility, during valve repairs using Fureanite, were not performed.
The licensee currently requires that the use of Furaanite be handled as a plant modification under Al-19, Plant Modifications: After Licensing, which includes requirements for appropriate safety evaluations.
The NRC had identified an unresolved iten on the use temporary sealants as discussed in NRC Inspection Report 327, 328/86-27 (URI 327, 328/8.6-27-01).
The NRC review of the licensee's corrective actions were completed as documented in Inspection Report 327, 328/96-55 and the unresolved ites was closed.
6.
Concern SQP-86-014-002
)
The concerned individual indicatec that although foremen are recuired to sign a document verifyicg that they have reviewed a work package with the craft prior to work, they often do not conduct the
- review, it was determined that SQM-2, Maintenance Management System, required the foreman and craftsmen to review the work package, not necessarily concurrently, and sign-off that the package is adequate prior to use.
The concern was not valid in that the requirement did not exist.
SQM-2 places the responsibility for understanding the procedure at the craft level in addition to the foreman level, therefore, craftsmen who did not understand the procedures or work requirements are responsible f or resolving their questions with their supervisor.
The licensee has conducted training to reinf orce the philosophy that each craf tsman is responsible for the quality of his/her work.
NRC inspectors noted that for complicated work packages, the craftseen and engineers involved are briefed on the work Activities.
This concern apparently resulted from a misunderstanding of the administrative requirements.
The licensee's actions appear to resolve the problem.
7.
Concern XX-85-071-003 The concerned individual had general questions about the.kardware repair process.
The details had been withheld from the licensee to protect the confidentiality of the CI.
The NRC has reviewed the specific concern and provided the licensee by letter dated September 22, 1987 with sufficient information to perfora an evaluation of the condition.
The specific concern involved welding practicet on non-safety related equipment.
The NRC will review the licensee's final disposition of the concern.
_ ~
IV.
Qgag[ustga i
The licensee is being provided suf ficient 'inf ormation to evaluate concern XX-85-071-883 regarding welding on non-safety-related equipment.
The NRC staff believes that the TVA investigation of the remaining concerns was adequate, and their resolution of those concerns as described in Element Report 388.83-SON is acceptable for restart.
l t
i l
1 l
i i
i 1
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SEQUOYAH NUCLEAR POWER PLANT, UNITS 1 & 2 SAFETY EVALUATION REPORT FOR EMPLOYEE CONCERNS ELEMENT REPORT 308.04-SQN "PROGRAM / PROCEDURE VIOLATIONS" S hitet.
9 Category:
OPERATIONS (30000)
Subcategory:
MAINTENANCE (30800)
Element: PROGRAM / PROCEDURE VIOLATIONS (30804)
Concerns:
IN86-073-002 IN-86-3tS-202 IN-86-110-801 SQP85-004-006 JAN86-001 186-233-S9N JLH86-001 The bases for Element Report 308.04-SON, Rev. 2, dated December 19, 1986, are the f ollowing employee concerns:
IN-86-073-002:
"The mechanism exists for technicians to verify if the vendor manuals kept in the shop contain the latest updated drawings or schematics.
Using out of date drawings or schematics could cause the plant instruments to be placed (unknowingly) in an out of configuration status.
Details known to 2TC withheld to maintain confidentiality.
Concerned individual (CI) has no additional information.
Nuclear power concern - Unit 1."
(Matts Bar)
IN-86-315-002:
"Engineering design drags probless off before they are fixed.
To make this point clear, Cl stated that when inspection department issues notice of indication (N0ls) or maintenance requests (MRs) that engineering will disposition them without fixing.
CI stated this as a generic concern.
Nuclear Power concern.
CI has no further information."
IN-86-110-001:
"During ice loading, TVA used jack hammers to compact ice l
to achieve the minimum basket weight requirements.
This could result in "CHANNELING" of ice and endanger containment integrity during a LOCA (Loss of Coolant Accident).
CI has no additional information.
Unit 1/ Nuclear Power concern."
SQP-85-004-026:
"Procedure M110.37 requires a 0-30 in. Ib. torque wrench be used, yet craft are told to use a 2-24 in. Ib. torque wrench.
Ci feels craft should not be asked to violate a procedure.
Nuclear Power concern.
CI has no further inforoation."
JAN-86-001:
"Thone call received about drawings being marked up for WP 10:12 (class 1E fuses ID) without completing the work."
l-86-233-SQN:
"An anonymous individual mailed in a potential safety l
ha:ard associated with the Condensate Demineralizer Waste Evaporator (CDWE) on EL 706 of the Auxiliary Building at SON.
The original stainless steel piping for pumping 'bottoas' from the CDWE was removed
)
)
and replaced by a temporary rubber hose.
Extensive modifications are being performed over the rubber hose.
Welding hot chips have been observed falling on the rubber hose.
Damage to or rupture in the hose would result in possible personnel exposure of a very high aoount."
l 1
JLH-86-001:
"1. MRs which require the addition of grease to Limitorque valve operators ire signed by a general foreman as "no grease necessary" when, in fact, the grease levels are low or need replacing.
- 2. MRs which the general foreman considers unimportant are signed off as complete even though no work was performed.
i II.
Suggaty of_]ssyg These concerns involve miscellaneous issues in the maintenance area.
The licensee's review of these issues indicated that three of the concerns IIN-86-073-002, SQP-85-004-006, JAN-86-001) were valid; three of the concerns (IN-86-315-002, IN-86-110-001, I-86-233-SQN, ) were not valid; and, parts 2 and 3 of the seventh concern (JLH-86-601) were valid and t
part I was not valid.
i 1
't!. Eyalgatiog 1.
Concern IN-86-073-002 The concern involved the use of vendor manual drawings that were out of date.
The licensee has revised Al-23, Vendor Manual Control, to assure proper control of vendor. manuals.
Al-25, Part I, Drawing Control After Unit Licensing, has also been revised to field verify equipment and establish controlled drawings.
In addition, the responsibility for verifying that materials referenced in a work package are current has been assigned to the craft foreman in SOM-2, Maintenance Management System.
Verification that drawings are current is performed prior to work.
The NRC agrees that the concern was valid and safety-related.
Inspection of the administrative controls which have been implemented to correct the creblem has been completed and the staff has concluded that the controls in place on usage of vendor drawings should prevent problems with using outdated vendor drawings.
The NRC is continuing inspection activities to assure that current drawings are being used in the field and that controlled drawings are being established.
2.
Concern IN-86-315-002 The concerned Individual stated that engineering design was dispositioning problems without fixing them.
The licensee indicated that the Nuclear Safety Review Staff (NSRS) had reviewed the concern and determined that documentation of the disposition of problems referred to design had not been completed in all cases.
The NSRS did not find any issues which had been improperly dispositioned.
./
u-The licensee has corrected procedures to assure proper documentation cf results of the engineering reviews.
The FHC has identified various problems in the past with the interface between the plant and design organizations including failure to review deficiencies in a timely manner and failure to review problems identified at other sites.
The NRC review to confira adequate corrective actions for the design / plant interface is documented in NRC Inspectibn Report 327, 328/87-42.
The NRC found the short tera carrhttive actions adequate and will sonitor implementation of the long tera program.
3.
Concern IN-86-110-031 The concern involved the use of jackhamaers to compact ice to achieve minimum ice basket waight requirements at Watts Dar.
The inspector reviewed the licensee's investigation of the concern.
The licensee indicated that jackhammers were
't being uned for compacting ice at Srquoyah but that a ja.
3mm6r had been used for a demonstration previously.
The NRC notes.nat this concern was originally brought up at. Watts Bar and was substantiated for Watts Bar.
The concern was reviewed at Sequoyah as a potentially generic problem and was not substantiated.
4.
Concern SQP-85-004-006 The concera involved procedure MI-10.37 which required a 8-30 in.
ib. torque wrench be used, but the craft were instructed to use a 8-24 in. Ib. torque wrench.,
The concern indicated that employees were being told to disregard procedural requirements.
The NRC j
issued violation 327, 328/85-47-03 in regard to the use of a torque wrench which was not specified in the procedure.
The NRC perforacd field reviews of saintenance activities and conducted interviews i
with"employees to confirm corrective actions were taken.
These reviews indicate that the licensee has adopted a policy that the employee will follow procedures exactly or change the procedure.
The NRC staff has an outstanding violation on failure to follow procedure in the maintenance area, however, the violation did not involve a situation similar to the concern involved in this item.
j The reviews of procedura: ad;erence in the mainterance area and a discussion of the violation are documented in NRC Inspection Report
{
327, 328/87-37.
The licensee will pr:vice additional information on seasures to assure strict procedure compliance in the response to the violation.
The NRC concludes that the concern was valid and safety related.
Licensee actions to address this concern appear adequate.
Violation 327, 328/85-47-03 was closed in NRC Inspection Report 327, 328/96-37.
5.
Concern JAN-86-001 The concern involved an employee who received a request to close a work request prior to completion of the work.
The NRC reviewed the licensee's documentation of this concern and its resolution in Element Report 300.04-SQN and determined that the licensee's actions appeared appropriate.
The licensee stated that the concern was valid and that the concerned Individual and other involved perronnel
- 6.,
had been interviewed and the issue resolved.
The subject work plan was reviewed by the licensee and had been subsequently closed appropriately.
The NRC noted that AI-19, Plant Modification: After Licensing, requires that work plan steps be completed prior to final signoff by the document cocrdinator.
6.
Concern I-86-233-SQN Original stainless steel piping in the Condensate Demineralizer Waste Evaporator was replaced with rubber hose.
The concern stated that welding was being allowed over the hose with the potential for damage of the hose and release of contaminated material.
The licensee could not identif y any instances where welding had taken place over the hose without protection being provided.
The licensee has since replaced the rubber hose with permanent piping.
The i
licensee indicates that the concern was not validated, however, the inspector believes that the validity was indeterminate in that all instances of welding near the hose could not be reviewed f or proper controls.
The licensee uncovered no damage to the hose and has replaced the temporary hose with permanent piping.
Corrective
{
actions to assure that probless involved in the original concern are precluded, have been completed.
This issue is considered to be resolved.
7.
Concern JLH-86-201 The concern had three partsi (1) Valve coerators with low grease or with grease that needed replacement were signed off by general foreman as not requiring grease; (2) MRs were signed off by general j
foreman without comp)* ting work; (3) non-0A material was installed and records falsified to indicate that QA material was used.
j The NRC reviewed the licensee's response to the concerns as documented in Element Report 308.04-SQN.
The licensee indicated that grease had been sampled on all L' nit 2 Limitorque operators and saintenance verified thct the operators uere properl; greased.
The licensee's DC organization audited this process.
No discrepancies were identified.
This saspling program and the results from interviews conducted by the licensee sacear sufficient to resolve this concern.
The second concern was considered valid by the licensee.
it.e licensee's actions for this concern, which included rework of identified maintenance requests, implementation of a new program for tagging defective equipment, training and disciplinary action, appeared appropriate.
In addition, the licensee has conducted an equipeent operability study to identif y inoperable euutpment and saintenance requirements.
NRC review of the equipment operability study is documented in NRC inspection report 327, 329/87-37.
These actions should resolve this concern.
The third concern, involving traceability of OA material, was considered valid by the licensee.
The licensee's Nuclear Safety Review Staff performed an audit in the area and identified several
~
probless including failure to segregate QA and non-QA bins, inadequate documentation, and addition of new parts with di8ferent docusentation to existing stock.
The NRC staff has conducted extensive inspections in this area and has identified additional concerns as documented in NRC Inspection Reports 327, 328/86-61 and 327, 323/87-40.
Resolution of the licensee's findings and toe NRC concerns will be tracked in the Inspection Reports.
IV.
Qgeclusign The NRC staff believes that the TVA investigation of the concerns was adequate, and their resolution of the concerns as describee in Electnt Report 300.04-SQN is acceptable for restart.
The NRC s_taff had the following comments on certain esployee concerns which were not valicated by the licensee.
Concern IN-86-315-002, involving disposition of NC!s or MRs without correcting the problems, was considered not valid in that no instances of imoroper disposition were found; however, the licensee did indicate that documentation of disposittens were not adequate.
The NRC notes that lack of documentati.on could have lead to the original concern that the problems were being dismissed.
The NRC believes that actions to correct these problems appear adequate and therefore resolution of tais problem is acceptable for restart.
Concern IN-86-110-801, regarding use of a jack hammer on ice baskets, was a concern whi:h was substantiated at Watts Bar.
The NRC agrees with the licensee that this was not a concern at Sequoyah.
The NRC notes that for I-86-233-SON, that it is not clear whether er not welding took place in the vicinity of the CDWE bull hose; however, no damage to the hose was uncovered, the licensee's procedures on welding if f ollowed completely should have prevented probleas and should prevent future occurrences of this type and the licensee has since i
replaced the hose with stainless steel piping.
6 SEQUOYAH NUCLEAR. POWER PLANT, UNITS 1 AND 2 SAFETY EVALUATION REPORT FOR EMPLOYEE CONCERNS ELEMENT REPORT OP 30806 "SUBJOURNEYMAN/ JOURNEYMAN" I.
Subject Category:
Operations (30000)
Subcategory:
Maintenance (30800)
Element:
Subjourneymen/ Journeymen (30806)
Employee Concern:
IN-85-589-002 The basis for Element Report OP 30806, dated November 5,1986, is the following employee concern:
Concern IN-35-589-002:
"Power Division is using subjourneymen level craft personnel to perform welding, wiring, and other operations which require a certified trained journeyman to perform properly.
All craf ts were alleged to be involved in this practice.
No further details available."
II.
Summary of Issue Concern states that subjourneymen craf t personnel were performing duties requiring a certified trained journeyman.
In tneir union contract TVA has a subjourneyman classification for both construction (unskilled work) and maintenance (semi skilled work).
Only the maintenance portion of the contract is applicable to Sequoyah, since it is considered an operating plant.
Semi skilled maintenance work for subjourneymen consists of tasks such as general shop cleanup, parts retrieval, and assisting journeymen.
Work performed assisting journeymen is under the direct supervision of the journeyman and is signed for by the journeyman.
III. Evaluation TVA interviewed supervisory personnel in ele-trical, instrument, and mechanical maintenance.
Only electcical maintenance used subjourneymen; in August 1986, they had only a total of four subjourneymen.
TVA per-sonnel at Sequoyah searched the union grievances back to 1983 (when the subjourneyman classification began) and found nothing on subjourneymen.
TVA Quality Assurance at Sequoyah found no DRs or CARS related to the subject of subjourneymen.
IV.
Conclusion The NRC staff believes that the TVA investigation of the concern was adequate and their resoluttor, of the concerns as described in Element Report CP 30806 is acceptable for restart.
1 6
SEQUOYAH NUCLEAR POWER PLANT, UNITS 1 & 2 SAFETY EVALUATION REPORT FOR EMPLOYEE CONCERNS ELEMENT REPORT 30807 "CLAM CONTROL PROGRAM" I.
Subject Category: Operations (30000)
Subcategory:
Maintena.1ce (30800)
Element:
Clam Control Program (30'.r/)
Concerns: IN-85-948-001 IN-85-948-002 IN-85-948-003 The Basis for Element Report 30807-SQN, Revision 4 dated January 7,1987, are the following Watts Bar employee concerns:
Concern IN-85-948-001:
"Intake pumping station cannot or does not screen out mussels. The mussels found in the lines are very small and perhaps are hatching.
The ERCW line is also clogged with concrete debris.
An 8-inch line may have a one and a half inch opening for water flow.
The fire protection system will not operate properly due to this clogging.
Example: Six inch F. P. line in Unit 1 "Hot Shop" was cut 2-4 years ago, and a one foot length of pipe had enough debris to fill a hard hat (713' Elevation behind security).
C.I. had no further information."
Concern In-85-948-002:
"Pipes to the sprinkler heads in the switch yard are filled with mussels and debris.
Examples of past clogging are where the four inch diameter header joins the one inch diameter around every j
transformer.
C.I. had no f'urther information."
Concern IN-85-948-003:
"The flush hose was stopped up with mussels and identi'ied while flushing the system two years ago.
Auxiliary Building, Unit 1, 692' Elevation.
This system was F.P.
and was supposed to be "dry."
C.I. had no further information."
II.
Summary of Issue T'/A perceived the issue to be clam infestation in the plant water systems.
III. Evaluation The TVA Evaluator reviewed the Sequoyah response to IE Bulletin 81-03, reviewed the Sequoyah clam control program; interviewed cognizant personnel and reviewed completed surveillance data.
The concern addressing concrete debris in the ERCW piping was not evalucted at SQN due to the fact concrete lined pipe is specific to Watts Bar.
The evaluation determined that there are asiatic clams in the vicinity of SQN and that clam growths have occurred in some of the plant water systems.
However, there was no indication of any massive or recurring problem with clams in plant water systems and that the plant surveillance instructions are adequate to prevent clam infestations.
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Conclusion The NRC staff believes that the TVA investigation of the concern was adequate, and their resolution of the concern 'as described in Element Report 30807 is acceptable for restart.
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SEQUOYAH NUCLEAR POWER PLANT, UNITS 1 AND 2 SAFETY EVALUATION REPORT FOR EMPLOYEE CONCERNS QTC-SQP-85-004-007 "POLAR CRANE" I.
Subjact Concern SQP-85-004-007: An employee'was directed by supervision to operate a piece of equipment, after the employee had reported the piece of equipment as defective.
II.
Summarv of lap.ne.
This concern describes.an occasion when as employee was-required by management to use a piece of equipment after the equipment had been declared defective 1by an inspection. Thic concern has been addressed by TVA with related concerna in Employee Concerns Element Report 30805 concerning maintenance training.
TVA chartered the Crane Consistency Program (CCP) to evaluate the use of cranes throughout TVA in the aftermath of the fatality at Brown Ferry in March 1985. CCP-Special Projects evaluators conducted interviews with crane operators and reviewed erane operator training' lesson plans. The evaluators found that conflict between craft foremen and crane operators resulted from foremen not having had the 4
special training that crane operators had recieved.
III. Evaluatien TVA has identified the root cause of this concern to be the failure to ensure that craft foremen receive the same information (training) that is provided the craft personnel.
The long term corrective action is for the CCP to develop an Office of Nuclear Power procedure to ensure safe crane operations. This procedure is anticipated t^
be completed in 1987.
IV.
Con-luginn The NRC staff believes that the TVA investigation, 1
resolution, and corrective action for Enployee Concerns
'ilement Report 30805 is acceptable for this related concern as well and for restart, j
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SEQUOYAH NUCLEAR POWER PLANT, UNITS 1 AND 2 SAFETY-EVALUATION REPORT FOR EMPLOYEE CONCERNS QTC-XX-85-093-004 "GASSING OF CURRENT TRANSFORMERS" I.
Subject _
Concern QTC-XX-85-093-004: Concerned individual feels that TVA has a problem with gassing of current transformers which has led to outages of line and bus ties to obtain oil samples and determine gassing conditions and is an example of inadequate SE/ASE electrical training.
II.
Summary af Issue The concerned individual feels that the SE/ASE does not have adequate training in electrical operations to understand the long term consequences pertaining to gassing of current transformers on station reliability.
The C/I appears cancerned from an overall electrical distribution standpoint (dispatcher) as compared to Nuclear safety.
III. Evaluatinn TVA has addressed training of operators in ECSP element report 310.02. The TVA investigators found that this concern'was initially evaluated by the NSRS and documented in NSRS report I-85-093-002. The NSRS evaluated the training program for licensed operators against the. requirements of the NRC. They found that the training program fully met NRC requirements.
In addition, the electrical training at Sequoyah was one of the first in the nation to receive INPO accreditation in January 1984.
In addition, the investigators found that NSRS had already addressed the CIs concerns in a special investigation pertaining to training and qualification of SEs and ASEs on switchyard operation (NSRS I-85-619-SQN). The NSRS concluded that the SEs and ASEs are fully trained in switchyard operations. This training included portions on transformers and switchyard safety. TVA concluded that the concern was unsubstantiated.
IV.
Conciumien The NRC staff believes that the TVA investigation, res31ution, and' corrective action for Employee Concerns Element Report 310.02 is acceptable for this related concern as well and for restart.
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