ML20205Q680

Insp Repts 50-327/88-43 & 50-328/88-43 on 880906-09. Violations Noted.Major Areas Inspected:Followup on Previous Insp Finding & 10CFR50.59 Safety Evaluation Program & Implementation Re Plant Site

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: ML20205Q638 ML20205Q661 ML20205Q680
References
50-327-88-43, 50-328-88-43, NUDOCS 8811090317
Download: ML20205Q680 (11)

See also: IR 05000327/1988043

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• • '.***4 UNITED STATES .

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NUCLEAR REGULATORY COMMISSION

REGION ll

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

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6N 38A Lookout Place

1101 Market Street '

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

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Inspection at: TVA Engineering Office, Knoxville, TN  !

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I Inspection Condu t : tembe 6-9, 1988 ,

Inspectors:

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'.*A.'Elrod, teae Leader Date Signed ,

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j Team Members:

i M. W. Branch, Senior Resident Inspector '

1 P. A. Harmon, Senior Resident Inspector. t

j G. A. Walton, Senior Resident Inspector  !

Approved by: . dhW

/ Watson, Chief,

/Dh3 8N

Date Sfgned [

TVA rojects Section 1 L

TVA Projects Division

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SUMMARY l

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This special u'. announced inspection included followup on a previous

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Scope:  !

inspection finJing and the 10CFR 50.59 safety evaluation (or USQD)  :

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program and f.oplementation, specifically concerning the Sequoyah  !

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site. The 'nspection was conducted in the Knoxville DNE office -

i although many of the specific USQOs reviewed were found to have been  ;

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generated at the Sequoyah site by the site DNE satellite office.

Results: The inspection identified weaknesses associated with the threshold  !

for safety evaluations and control of conditions associated with  ;

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safety evaluations. One violation was identified for failure to i

properly establish and implement procedures regarding 10CFR 50.59 L

reviews, paragraphs 3 and 5.

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REPORT DETAILS

1. Licensee Employees Contac' . ,

'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

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• T. Horning, DNLRA, Licensing Manager

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• J. Little, JR. DNE, MEB, Senior Mechanical Engineer

"H. Jones, DNE Engineering Assurance

• R. McMahon, DNLRA, Nuclear Engineer

• F. Moreadith, DNE, Engineering Manager

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• R. Reeves, DNE EEB, Senior Electrical Engineer

• J. Sanders, DNE, CEB, Manager of Technical Support i

"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

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• S. Elrod .

• M. Branch l

• P. Harmon

• G. Walton  !

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• Attended exit interview. l

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Acronyms and initialisms used throughout this report are listed in the

l last paragraph.

2. Inspection Objectives

The inspection objectives were:

a. Review the licensee's program and procedures involving 10CFR 50.59

J for compliance with NRC requir eents. '

b. Review the implementation of the licensee's program by the DNE

1 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

! evaluation, e.g., a screening process.

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d, Review the training and oualification process.

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e. Sample at least three 10CFR 50.59 safety evaluations invohing the

] 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 1, dated May 18, 1988, "10CFR 50.59 Safety

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Evaluations"

i 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  :

i Memorandum from W. H. Hannum , Su-NSRB, to S. A. White, dated June 16,

i 1988

Memorandum f rom W. H. Hannum, SQ-NSRB, to S. A. White, dated

August 24, 1988

4 Lesson Plan EGT 024.001, R1, dated August 10, 1987, "USQO Evaluator .

Certification Training" l

Lesson Plan SQN-SE-01, no date, "Safety Evaluation Training i

Supplement" i

EA Surveillance S88-20, dated August 23, 1988, "10CFR S0.59 f

Evaluations"

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i 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 i

Experiments  !

The foundation for TVA's USQD program, including screening reviews,  ;

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

and enjineering offices L'y local procedures such as SQA-119 (Sequoyah) and (

NEP-6.6 (engineering). Training, discussed in paragraph 4, was centrally '

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  :

weaknesses existed in the USQD program. Discussions in the documents  !

- reviewed highlighted three areas as keys to obtaining adequate results  ;

, from the USQD program. These areas were: increased attention by  ;

! reviewers, interdisciplinary / independent reviews, and the need for a i

relatively standard process that would support the variety of TVA  ;

l 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

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

. 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

j 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 i

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

! not match 10CFR 50.59 and was also less conservative than 10CFR 50.59. ,

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

i 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,

l Rev. 2, translates the above definition as: (1) the probability of

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occurrence of the consequences of an accident or malfunction of equipment i

would be increased or (ii) a possibility of an accident or malfunction of  ;

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a different type would be created. The TVA use of the word "would" vice -

the 10 CFR 50.59 word U may" is less conservative.

Section 5, "Responsibilities" enjoined those organizations assigning r

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 >

the procedure. Section 6.6 involved the (DNT) program discussed in

paragraph 4 below. The procedure neither defined, nor included guidelines l

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concerning, "technically qualified." This section also made line managers -

I and engineers responsible for obtaining proper technical assistance  :

outside their immediate area of expertise and responsibility when needed. l

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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  :

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

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a generally conservative approach, however, the screening process had an

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 ,

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, t

It did address the evaluation of plant /3AR discrepancies as well as i

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 i

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PMP-0604.04. The definition of a USQ in PMP-0604.04 did not fully

implement 10CFR 50.59 and consequently was less conservative than

10CFR 50.59. 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, i

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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 ,

purposes of review, approval and distribution. '

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Section 6 discussed training and defined the CNT program as the required  !

training, j

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

i 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 l

indhiduals to perform USQDs. In addition, the retraining program was

reviewed. The initial training program was an eight hour course presented <

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

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There were no prerequisites specified oy DNE vr attending the

certification training.

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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

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" t

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

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to document the safety evaluation for the associated modification or

l 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 l

USQD's were actually performed. During the above review, the inspectors

also performed a detailed evaluation of USQD adequacy for several specific '

design change packages. The packages reviewed along with the inspectors' i

comments are discussed below:

USQD 3EEB004, RO: No Comments

l USQD 1EEB029, RO: No Comments l

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USQD IMEB030, RO: No Comments

. Screening Form: This screening review supported DCN X00146A which  !

blocked of f control room ventilation dampers. The screening review  ;

i stated, "The DCN was a FSAR drawing update and did not require a

USQD " This determination was contrary to NEP - 6.6 which requiies <

a USQD for all changes to FSAR drawings. An EA representative ,

indicated that this discrepancy would be immediately corrected. [

USQD 1EEB028, RO. This USQD supported DCN M00286A which replaced (

, split flanges with solid flanges on the standpipe for containment f

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level transmitters, This USQD was performed by the electrical I

discipline sirice it involved an instrument. However, the majority  !

of the modification work was actually mecnani 11. It could not be  ;

4 ascertained from review of the USQD document whether or not personnel  :

! knowledgeable in the mechanical discipline did, in fact, cnntribute  :

. to the development of this USQD. This made auditing of the USQD l

Interviews with electrical

review and approval very difficult.  !

i discipline engineers indicated that machanical discipline input had

j been obtained. It was also noted that the DCN cover was incorrectly 7

marked as "Non-Safety-Related." j

USQD 2EEB035 RO: This USQD supported DCN-M00351A which reset l

Sequoyah Unit ? feedwater flow indicdtion transmitters due to feed l

water flow orifice fouling. The rescaling DCN and supporting SE l

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dia not appear to provide adequate controls to ensure that accurate ,

feedvater flow data would a' vays be utilized in the heat balance  !

measurements, especially af.tr the feedwater flow orifices were  :

cleaned. The following discussion explains this issue: I

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Early in the plant op, rations phase af ter full power licensee  !

! issuance, TVA discovered that pl.nt electric power output had '

! dropped by as much as 7*. f rom that experiencad during initial i

O full power operations. TVA requested Westinghouse to determine i

j the cause and recovend corrective action. l

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Westinghouse determined that the power output loss originated i

i from feedwater flow orifice fouling which was causing a

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higher-than-actual flow indication. The feedwater flow values

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

. than actual core thermal powcr. Limiting power operation to

! 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

1 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-

I cation transmitters, TVA compensated for the inaccurate feed-

, water flow by adjusting, under the direction of the Reactor

Engineering Group, program parameters for the P-250 plant

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J computer program used to perform the heat balance calculations.

During each refueling outage, the Reactor Engineering group

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processed work requests to remove' and clean the feedwater flow

orifices. With clean orifices, the adjustments previously made

to the P-250 program parameters would be restored at the direc-

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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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l 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.

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-

, cedure. Appendix "D" of TI-2 required that the data be provided to

. the instrument maintenance group but did not require feed flow

1 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

! indicator. This appeared to be adequate to prevent the plant from

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being operated at a power level greater than the licensed thermal

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power I!mit,

j As discussed above, it would be through a disconnected series of

circumstances that the modification installed by DCN M00351A would

! not later result in an unreviewed safety question after the next

cleaning of the feed flow orifices. Decognizing that the modifica-

l 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 ,

! 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  !

to ensure that all organizations are fully aware of assumptions

i 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

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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1 6. Action on Previous Inspection Findings (92702)

. (Closed) Violation (327,328/87-68-02) Ineffective Followup on Audit  !

Findings. This violation resulted from a failure to correct training .

deficiencies identified in 10 EA audits conducted by the licensee during a  :

period from 1985 until January 1987. j

j 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

i actions.

{ EA performed the fiscal year 1987 trend analysis of deficiencies l

j 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  !

j revised by a TVA Interim Order dated February 29, 1988, and effective ,

i innediately. This order added the requirement for issuance of an l

l annual trend data report for EA.  !

NEP-1.4, "Audits", was issued to provide more direction to l

organizations responding to engineering audits performed by internal

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and external organizations. The procedure was issued May 22, 1988. l

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EA Instruction 65.04, "Engineering Assurance Internal Audit Program", (

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 I

i above. The training was documented in accordance with NEP-1.2, j

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"Training."  !

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The inspector reviewed the following documents in reference to this

i item: l

! CAQR KXF870240 Rev. 0

] 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. ,

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 l

i 328/87-68-02 audit findings, paragraph 6.  ;

8. Acronyms and Abbreviations

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CAQR - Condition Adverse to Quality Report i

CEB - Civil Engineering Branch (of DNE) l

I CFR - Code of Federal Regulations  ;

DCN - Design Change Notice i

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DCR - Design Change Request

DNE - Division of Nuclear Engineering  ;

DNLRA - Division of Nuclear Licensing and Regulatory Affairs .

DNT - Division of Nuclear Training  !

EA - Engineering Assurance Branch (of DNE)

i 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  !

NI - Nuclear Instrument i

! NIS - Nuclear Instrumentation System l

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NRC - Nuclear Regulatory Commission

i NSHC No Significant Ha:ards Consideration

i 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

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SQ - Seouoyah (Nucleat Plant)

TVA - Tennessee Valley Authority

USQD - Unreviewed Safety Question Determination

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