ML20205Q680
| ML20205Q680 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 10/28/1988 |
| From: | Elrod S, Linda Watson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20205Q642 | List: |
| References | |
| 50-327-88-43, 50-328-88-43, NUDOCS 8811090317 | |
| Download: ML20205Q680 (11) | |
See also: IR 05000327/1988043
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
REGION ll
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101 MARIETTA ST., N.W.
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ATLANTA. GEORGIA 30323
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Report Nos.
50-327/88-43 and 50-328/88-43
Licensee:
Tennessee Valley Authority
6N 38A Lookout Place
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1101 Market Street
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Chattanooga, TN 37402-2801
Docket Nos.
50-327 and 50-328
License Nos. DPR-77 and DPR-79
Facility Name:
Sequoyah Units 1 and 2
Inspection at:
TVA Engineering Office, Knoxville, TN
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Inspection Condu t :
tembe
6-9, 1988
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Inspectors:
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'.*A.'Elrod, teae Leader
Date Signed
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Team Members:
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M. W. Branch, Senior Resident Inspector
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P. A. Harmon, Senior Resident Inspector.
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G. A. Walton, Senior Resident Inspector
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Approved by:
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/ Watson, Chief,
Date Sfgned
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TVA rojects Section 1
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TVA Projects Division
SUMMARY
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Scope:
This special
u'. announced inspection included followup on a previous
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inspection finJing and the 10CFR 50.59 safety evaluation (or USQD)
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program and f.oplementation, specifically concerning the Sequoyah
site.
The 'nspection was conducted in the Knoxville DNE office
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although many of the specific USQOs reviewed were found to have been
generated at the Sequoyah site by the site DNE satellite office.
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Results:
The inspection identified weaknesses associated with the threshold
for safety evaluations and control of conditions associated with
safety evaluations.
One violation was identified for failure to
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properly establish and implement procedures regarding 10CFR 50.59
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reviews, paragraphs 3 and 5.
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REPORT DETAILS
1.
Licensee Employees Contac' .
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'R. Alexander, DNE, CEB, Senior Civil Engineer
- R. Cantrell, DNE, Engineering Manager
- A. Capozzi, DNE Engineering Assurance Manager
- R. Costner, DNE, NfB, Engineer
"S. Gibson, DNE, MEB, Assistant Branch Chief
- T. Horning, DNLRA, Licensing Manager
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- J. Little, JR. DNE, MEB, Senior Mechanical Engineer
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"H. Jones, DNE Engineering Assurance
- R. McMahon, DNLRA, Nuclear Engineer
- F. Moreadith, DNE, Engineering Manager
- R. Reeves, DNE EEB, Senior Electrical Engineer
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- J. Sanders, DNE, CEB, Manager of Technical Support
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"D. Williams, DNLRA, Nuclear Engineer
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Other licensee employees or contractors contacted included quality
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assurance, design, and engineering personnel.
- NRC Attendees
- S. Elrod
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- M.
Branch
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- P.
Harmon
- G. Walton
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- Attended exit interview.
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Acronyms and initialisms used throughout this report are listed in the
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last paragraph.
2.
Inspection Objectives
The inspection objectives were:
a.
Review the licensee's program and procedures involving 10CFR 50.59
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for compliance with NRC requir eents.
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b.
Review the implementation of the licensee's program by the DNE
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organization, focusing on compliance with both licensee and NRC
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requirements.
c.
Evaluate any processes found that would circumvent the 10 CFR 50.59
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evaluation, e.g., a screening process.
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d,
Review the training and oualification process.
e.
Sample at least three 10CFR 50.59 safety evaluations invohing the
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Sequoyah plant, and evaluate the detai' and conclusions reached.
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f.
Followup an previous inspection findings.
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3.
USQD Program Review (35744)
Material Reviewed:
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PMP-0604.04, R2, dated March 31, 1988, "Evaluation of Changes, Tests,
and Experiments"
NEP-6.6, R0-PCN
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dated May 18, 1988, "10CFR 50.59 Safety
Evaluations"
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NEP-2.1, R0, dated July 1, 1986, "Licensing Support"
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NEP-2.2, RO, PCN 2, dated May 18, 1988, "Licensing Support"
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TVA letter L44880721805 (S. A. White - R. A. Strahan) dated July 25,
1988
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Memorandum from W. H. Hannum , Su-NSRB, to S. A. White, dated June 16,
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Memorandum f rom W.
H.
Hannum, SQ-NSRB, to S.
A.
White, dated
August 24, 1988
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Lesson Plan EGT 024.001, R1, dated August 10, 1987, "USQO Evaluator
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Certification Training"
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Lesson Plan SQN-SE-01,
no date,
"Safety Evaluation Training
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Supplement"
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EA Surveillance S88-20, dated August 23,
1988, "10CFR S0.59
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Evaluations"
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SQEP-128, R3, dated June 30, 1988, "Qualified Safety Evaluators"
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SQA-119, R12, dated July 8, 1988, "Evaluation o# Changes, Tests, or
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Experiments
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The foundation for TVA's USQD program, including screening reviews,
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safety evaluations, records, and training, wa: PMP-0604.04, Rev. 2, dated
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March 31, 1988. That dncument was fur'.her implemented at the power plants
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and enjineering offices L'y local procedures such as SQA-119 (Sequoyah) and
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NEP-6.6 (engineering).
Training, discussed in paragraph 4, was centrally
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implemented through the DNT Power Operations Training Center using Lessan
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Plan EGT-024.001. The licensee had recogni:ed for some time that program
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weaknesses existed in the USQD program.
Discussions in the documents
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reviewed highlighted three areas as keys to obtaining adequate results
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from the USQD program.
These areas were:
increased attention by
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reviewers, interdisciplinary / independent reviews, and the need for a
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relatively standard process that would support the variety of TVA
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organi:ations.
For example, EA Surveillance S88-50 stated that several
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different screening forms in current use asked the questions differently
and less conservatively than did NEP-6.6. Appropriate corrective actions
were proposed in the surveillance report. The weaknesses discussed by the
licensee in the material reviewed would add difficulty to, rather than
preclude, obtaining valid USQOs.
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Several specific program weaknesses observed by this inspection team
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appeared to have not been previously addressed by the licensee.
This
inspection team observed a program weakness in the definition of a USQD
that, within itself, could preclude the obtaining of a valid USQD.
In
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this respect, valid USQDs were judged to have been obtained outside of the
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program rather than because of it.
Specific comments concerning
PMP-0604.04 and NEP-6.6, the principal procedures of interest, are found
below.
PMP-0604.04, Sectin 4,
"Definitions," satisfactorily defined several
important terms such as Screening Review, Safety Evaluation, and Safety
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Analysis Report.
The section also defined a Plant /SAR Discrepancy, such
as might be discovered during some site activity.
Though 10CFR 50.59
only addresses planned changes, this procedure also included a mechanism
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for review and evaluation of de facto differences that may be found. This
was a program strength. Section 4 also defined a USQ. The definition did
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not match 10CFR 50.59 and was also less conservative than 10CFR 50.59.
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Specifically:
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10 CFR 50.39 (a)(2) stat.5, in part, that a proposed change, test or
experiment shall be deemed to involve an unreviewed safety question (1)
if tFe probability of eccurrence or the consequences of an accident or
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malfunction of equipment may be increased or (ii) if a possibility for an
accident or malfunction of a different type may be created. PMP 0604.04,
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Rev.
2, translates the above definition as:
(1) the probability of
occurrence of the consequences of an accident or malfunction of equipment
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would be increased or (ii) a possibility of an accident or malfunction of
a different type would be created. The TVA use of the word "would" vice
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the 10 CFR 50.59 word Umay" is less conservative.
Section 5,
"Responsibilities" enjoined those organizations assigning
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individuals to approve screening reviews or perform safety evaluations
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to ensure that the individuals were technically qualified to review
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the subject materials and ware trained in accordance with section 6.6 of
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the procedure.
Section 6.6 involved the (DNT) program discussed in
paragraph 4 below. The procedure neither defined, nor included guidelines
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concerning, "technically qualified." This section also made line managers
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and engineers responsible for obtaining proper technical assistance
outside their immediate area of expertise and responsibility when needed.
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Section 6,
"Requirements" discussed the Screening Review and Safety
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Evaluation.
The Screening Review paragraph and it's referenced form,
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"Attachment 2" addressed general bounding questions, not the specific
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safety evaluation questions, and required a written justification for
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question responses that would lead to not needing a USQD or SE. This was
a generally conservative approach, however, the screening process had an
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apparent weakness in that only one qualified reviewer was required to
review the screening review forms which had been determined, by an
unqualified preparer, to have no safety implications.
Compa ed to also
having a qualified preparer or having two qualified reviewers, the
potential for an unqualified preparer to err in this determination and
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make unidentified nonconservative decisions is considerably greater. This
problem was exemplified by the mistaken determination that no USQD was
needed for DCN X00146 as detailed in Paragraph 5 of this report. Both the
Screening Review paragraph discussed above and the Safety Evaluation
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paragraph discussed below were also silent concerning the identification
of reviewers other than the principal reviewer.
The -Safety Evaluation
paragraph and the criteria discussed in it's referenced "Attachment /
incorporated in specific questions the paragraph 4 definition of a USQ,
which was less conservative than allowed by 10CFR 50.59.
NEP-6.6 was the NEP implementation of PMP-0604.04 with respect to plant
modifications, performance of proposed tests or experiments and, if
requasted by an operating plant staf f, procedure or instruction changes,
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It did address the evaluation of plant /3AR discrepancies as well as
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10 CFR 50.91 NSHCs if the SE were to find that prior NRC approval was
required.
Sectien 2.5, "Definition," defined a US0 following the definition in
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PMP-0604.04.
The definition of a USQ in PMP-0604.04 did not fully
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implement 10CFR 50.59 and consequently was less conservative than
That section also defined the SAR as including comitments
documented in the NRC Ssfety Evaluation Report.
Th 3 SAR definition was
more conservative that PMP-0604,04,
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Section 3 enjoined responsible lead engineers to ensure that individuals
pedoming SEs or screening reviews be trained, per the DNT course, and
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be technically qualified, but neither defined, nor included guidelines
concerning, "technically qualified." Section 3 also requ red that a copy
of the " be attached to the modification packages as an ntegral part for
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purposes of review, approval and distribution.
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Section 6 discussed training and defined the CNT program as the required
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training,
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The screening review form questions were similar to those in the
FMP-0604.04 screening review.
Question two, addressing instructions
and procedures, did not entirely implement PMP-0604.04 in tnat the PMP
included new procedures or instructions and NEP-6.6 only addressed changes
to existing procedures.
The SE form and instructions incorporated via specific questions the PMP
0604.04 definition of an USQ which was less conservative than that allowed
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by 10CFR 50.59 due to use of the te rfn "would" rather than "may" as
discussed above.
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This ' failure te adequately translate an NRC regulation into a licensee
program is a violation of 10CFR 50, Appendii B, Criterion V and is an
example of violation (327, 328/88-43-01).
4.
Training (35744)
Durir1 the inspection, the NRf inspectors reviewed TVA's training program
presented by che DNT Power Operations Training Center to certify
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indhiduals to perform USQDs.
In addition, the retraining program was
reviewed. The initial training program was an eight hour course presented
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in a single day, while the retraining p.ogram was a five hour course.
Bot, courses involved examples and workshops that worked through several
USQO case studies.
The program required that individuals be retrained
each calendar year. The requirement to retrain each calendar year appeared
appropriate. Both training programs appeared adwuate to certify, or
continue certification of, the licensee staff in
> prepc, ion of USQDs.
Several training program weaknesses are discusst. hel
There were no prerequisites specified oy DNE
vr attending the
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certification training.
Upon test failure, there was no retraining specified prior to retest.
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Upon test failure, there was no requirement to pass a different test.
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When questioned concerning how ' dividuals who do not receive yearly
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retraining would be removed from the "qualified" list, the licensee
responded that there was no specific tracking mechanism in place but
that one would be implemented when the retraining program began. The
retraining program was scheduled to begin in October, 1988.
While both initial training and retraining were required to certify
individuals
as
qualified
reviewers,
thero were
neither minimum
qualifications nor training to certtfy individuals to prepere screening
reviews. The screening review was developed to reduce the total number of
USQDs by eliminating the plant changes that would fall into the "minor"
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category, obviously having no safety implications, The impact of this lack
of traiaing requirements for those preparing ,creening reviews is
discussed in Paragraph 3.
No deviations or violations weie identified in this area.
5.
Review of Completed USQDs (35744)
The inspectors performed a cursory revi(w of approximately 50 USQDs that
were performed curing the April - July I?SS time f ame, and which were
located in two voluees in the DNE Knoxvil e office.
The cursory review
was to determine if a USQD or a USQD screening form was being utilt:ed
to document the safety evaluation for the associated modification or
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engineering review. The majority of these USQDs were found to ar.tually be
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USQO screer.ing forms that were completed at the Sequoyah site by DNE
persnnnel.
Of the 50 packages reviewed, the inspector identified 7 DCds,
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numbered X00195A, X00287A, M00263A, M00286A, M00287A, M00309A and M00418A,
where block 23, to record whether a USQD was required or not, was
initially marked "No" then changed to "Yes".
This is considered to be a
high percentage of initial errors and, although indicatt.e of a review
process tnat corrects initial errors, may indicate a lack of understanding
on the part of the preparer.
Additionally the inspector identified 2
DCN's, numbered X00207A and M00260A, where block 23 was inarked "No," yet
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USQD's were actually performed.
During the above review, the inspectors
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also performed a detailed evaluation of USQD adequacy for several specific
design change packages. The packages reviewed along with the inspectors'
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comments are discussed below:
USQD 3EEB004, RO:
No Comments
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USQD 1EEB029, RO:
No Comments
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USQD IMEB030, RO:
No Comments
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Screening Form: This screening review supported DCN X00146A which
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blocked of f control room ventilation dampers.
The screening review
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stated, "The DCN was a FSAR drawing update and did not require a
USQD " This determination was contrary to NEP - 6.6 which requiies
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a USQD for all changes to FSAR drawings.
An EA representative
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indicated that this discrepancy would be immediately corrected.
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USQD 1EEB028, RO.
This USQD supported DCN M00286A which replaced
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split flanges with solid flanges on the standpipe for containment
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level transmitters,
This USQD was performed by the electrical
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discipline sirice it involved an instrument. However, the majority
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of the modification work was actually mecnani 11.
It could not be
ascertained from review of the USQD document whether or not personnel
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knowledgeable in the mechanical discipline did, in fact, cnntribute
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to the development of this USQD.
This made auditing of the USQD
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review and approval very difficult.
Interviews with electrical
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discipline engineers indicated that machanical discipline input had
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been obtained.
It was also noted that the DCN cover was incorrectly
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marked as "Non-Safety-Related."
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USQD 2EEB035
RO:
This USQD supported DCN-M00351A which reset
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Sequoyah Unit ? feedwater flow indicdtion transmitters due to feed
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water flow orifice fouling.
The rescaling DCN and supporting SE
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dia not appear to provide adequate controls to ensure that accurate
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feedvater flow data would a' vays be utilized in the heat balance
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measurements, especially af.tr the feedwater flow orifices were
cleaned.
The following discussion explains this issue:
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Early in the plant op, rations phase af ter full power licensee
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issuance, TVA discovered that pl.nt electric power output had
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dropped by as much as
7*. f rom that experiencad during initial
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full power operations.
TVA requested Westinghouse to determine
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the cause and recovend corrective action.
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Westinghouse determined that the power output loss originated
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from feedwater flow orifice fouling which was causing a
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higher-than-actual flow indication.
The feedwater flow values
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were used in the normal NI calorimetric calibrations which used
secondary plant parameters.
The higher-than-actual flow indi-
cation resulted in indicated core thermal power being higher
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than actual core thermal powcr.
Limiting power operation to
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indicited values caused the reduction in electric power output.
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The corrective action proposed by Westinghouse and accepted by
TVA involved the performance of NI calcrimetric calibrations
using primary plant parameters.
The values obtained by this
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calorimetric were used to compensate for the inaccuracies
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associated with the feedwater flow orifice G uli.g.
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Prior to this recent DCN te resale the feedwater flow indi-
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cation transmitters, TVA compensated for the inaccurate feed-
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water flow by adjusting, under the direction of the Reactor
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Engineering Group, program parameters for the P-250 plant
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computer program used to perform the heat balance calculations.
During each refueling outage, the Reactor Engineering group
processed work requests to remove' and clean the feedwater flow
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orifices. With clean orifices, the adjustments previously made
to the P-250 program parameters would be restored at the direc-
tion of the Reactor Engineering Group.
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With the recent plant modification to rescale the feed flow
indication, no apparent controls were put in place to ensure
readjustment of the setting after feed flow orifice cleaning.
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The inspector did determine that, through an uncunnected series of
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circumstances, operations with higher-than-indicated core power would
probably not continue for any extended period and would be identified
as part of the plant startup testing af ter a refueling outage.
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Specifically, pre edure RTI-1, which was the controlling document for
refueling startup testing, indirectly required a primary calorimetric
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be performed per Appendix
"0"
of TI-2, the plant calorimetric pro-
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cedure. Appendix "D" of TI-2 required that the data be provided to
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the instrument maintenance group but did not require feed flow
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resceling and would not restrict operations until this was done. In
addition, recent revision 28 to procecure G01-5 did provide a caution
to the control room operator to not allow core power to exceed 100%
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on the NIS meter, the P 250 pro. ram, or the core delta-temperature
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indicator.
This appeared to be adequate to prevent the plant from
being operated at a power level greater than the licensed thermal
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power I!mit,
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As discussed above, it would be through a disconnected series of
circumstances that the modification installed by DCN M00351A would
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not later result in an unreviewed safety question after the next
cleaning of the feed flow orifices.
Decognizing that the modifica-
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tion was a temporary one, USQD 2EEB035, RO, did not contain any
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cautions or controls necessary to ensure that the modification would
not later create an unreviewed safety question.
The inspectors
considered the USQD to be inadequate to support the modification.
Procedures NEP-6.6 and SQA-119 required that sufficient detail be
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documented to support the USQ determination. However, neither of the
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procedures require or specify how conditions of a USQD be controlled
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to ensure that all organizations are fully aware of assumptions
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made in order to reach the conclusions.
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The failure to provide adequate controls in NEP-6.6 and SQA-119, in
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addition to the failure to properly document the safety evaluation on USQD
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2EEB035, are additional examples of violation 327, 328/SS-43-01,
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6.
Action on Previous Inspection Findings (92702)
(Closed) Violation (327,328/87-68-02)
Ineffective Followup on Audit
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Findings.
This violation resulted from a failure to correct training
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deficiencies identified in 10 EA audits conducted by the licensee during a
period from 1985 until January 1987.
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The licensee has taken the following corrective actions on this item:
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EA reviewed the training deficiencies identified by EA audits
performed in 1935 - 1937 and issued a CAQR to address corrective
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actions.
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EA performed the fiscal year 1987 trend analysis of deficiencies
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identified by EA audits.
No additional adverse trends were found.
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NEP-9.2, Rev. O,
"Trending of Conditions Adverse to Quality", was
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revised by a TVA Interim Order dated February 29, 1988, and effective
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innediately.
This order added the requirement for issuance of an
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annual trend data report for EA.
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NEP-1.4,
"Audits",
was issued to provide more direction to
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organizations responding to engineering audits performed by internal
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and external organizations. The procedure was issued May 22, 1988.
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EA Instruction 65.04, "Engineering Assurance Internal Audit Program",
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was revised February 29, 1988 to require an annual analysis of the
trend data report of EA audits.
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Personnel were trained to the new or revised documents discussed
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above.
The training was documented in accordance with NEP-1.2,
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"Training."
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The inspector reviewed the following documents in reference to this
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item:
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CAQR KXF870240 Rev. 0
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NEP-9,2, Rev. O, "Trending of Conditions Adverse to Qeality."
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NEP-1.4. "Audits"
EA Instruction 65.04, "Engineering Assurance Internal Audit
Program"
Training posted for NEPs 1.4, 9.2, and EA instruction 65.04
All areas reviewed by the NRC inspector were found acceptable and this
item is closed.
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7.
Exit Interview (30703)
The inspection scope and findings were summari:ed on September 9,1908,
with those persons indicated in paragraph 1.
The inspectors described the
areas inspected and discussed in detail the inspection results listed
below. The licensee did not identify as proprietary any of the material
provided to or reviewed by the inspectors during this inspection.
Dissenting comments were not received from the licensee.
Item Number
Description and Reference
327/88-43-01
open
(Violation) Failure to have adequate
328/88-43-01
procedures and implement procedures
regarding the conduct of 10CFR 50.59
review, paragraphs 3 and 5.
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327/87-68-02
closed
(Violation) Ineffective followup on
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328/87-68-02
audit findings, paragraph 6.
8.
Acronyms and Abbreviations
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CAQR -
Condition Adverse to Quality Report
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CEB -
Civil Engineering Branch (of DNE)
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CFR -
Code of Federal Regulations
DCN -
Design Change Notice
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DCR -
Design Change Request
DNE -
Division of Nuclear Engineering
DNLRA -
Division of Nuclear Licensing and Regulatory Affairs
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DNT -
Division of Nuclear Training
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EA -
Engineering Assurance Branch (of DNE)
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EEB -
Electrical Engineering Branch (of DNE)
FSAR -
Final Safety Analysis Report
JTG -
Joint Test Group
MEB -
Mechanical Engineering Branch (of CNE)
NEP -
Nuclear Engineering Procedure
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NI -
Nuclear Instrument
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NIS -
Nuclear Instrumentation System
NRC -
Nuclear Regulatory Commission
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No Significant Ha:ards Consideration
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NSRB -
Nuclear Safety Review Board
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NTB -
Nuclear Technology Branch (of DNE)
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PCN -
Procedure Change Notice
PMP -
Program Manual Procedure
POTC -
Power Operation Training Center
SAR -
Safety Analysis Report
SE -
Safety Evaluating
SQ -
Seouoyah (Nucleat Plant)
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TVA -
Tennessee Valley Authority
USQD -
Unreviewed Safety Question Determination
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