ML20206H015

Requests Addl Info Re TVA Justification for Classification of Element Rept 203.2(B), Experience Feedback:Feedback to Design Organization Not Properly Utilized as non-restart Item.Encl Lists Issues Which Must Be Addressed

ML20206H015
Person / Time
Site:	Sequoyah
Issue date:	03/30/1987
From:	Zwolinski J NRC OFFICE OF SPECIAL PROJECTS
To:	White S TENNESSEE VALLEY AUTHORITY
References
NUDOCS 8704150225
Download: ML20206H015 (3)

Text

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Docket Nos.: 50-327 i4 arch 30.1987

_. and 50-328 Mr. S. A. White -

Manager of Nuclear Power .

Tennessee Valley Authority 6N 38A Lookout Place 1101 Market Street Chattanooga, Tennessee 37402-2801

Subject:

INADEQUATE BASES FOR NON-RESTART JUSTIFICATION FOR SEQUOYAH ELEMENT ELEMENTREPORT203.2(B)

'Re: Sequoyah Nuclear Plant Units 1 and 2 The final report for Element Report 203.2(B), " Experience Feedback: Feedback to Design Organization Not Properly Utilized " was submitted by the Tennessee Valley Authority (TVA) by a letter dated December 24, 1986. The employee.

concern upon which this element report is based has been classified by TVA as a non-restart item.

A review and evaluation of the justification provided by TVA to support the fact that this issue should be a non-restart ~ item indicates the basis is not sufficient to support such a conclusion.- The enclosure provides identification of the areas in the justification which are weak and lists issues which must be addressed. Additionally, there is information provided on what type of justi-fication should be provided in order to support your conclusion.

A copy of the enclosure has been provided to Mark Burzynski.

Please provide the requested information as soon as reasonably possible for us to resolve this issue. If you require any additional assistance, please contact the project manager for this area, Joseph J. Holonich, at (301) 492-7270..

Sincerely.

Original signed by John A. Zwolinski, Assistant Director for Projects Division of TVA Projects Office of Special Projects

Enclosure:

As stated 8704150225 870330 7 cc: See next page ADOCK 0500 gDR DISTRIBUTION:

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JHolonich JDonohew -TRotella BKSinoh KHooks ACRS(10) SPR Reading OGC-Bethesda JPartlow BGrimes EJordan LKelly CUpright JZwolinski JKeppler SEbneter Sequoyah File  ;

TVA/OSP (i / T A/OSP -

JHolo61ch TVA/0SP TRotell TV TVA/OS JZwolinski CJamerson/ Jf AdhTw 03/ 30 /87- 03/);/87 03/ 30 /87 O g /87 03/10/87 l

Mr. S.A. White Tennessee Valley Authority Sequoyah Nuclear Plant cc:

Tennessee Department of Public Regional Administrator, Region II Health U.S. Nuclear Regulatory Commission, ATTN: Director, Bureau of 101 Marietta Street, N.W., Suite 2900 Environmental Health Services Atlanta, Georgia 30323 Cordell Hull Building Nashville, Tennessee 37219 R. W. Cantrell ATTN: D.L. Williams Mr. Michael H. Mobley, Director Tennessee Valley Authority Division of Radiological Health 400 West Summit Hill Drive, W12 A12 T.E.R.R.A. Building Knoxville, Tennessee 37902 150 9th Avenue North Nashville, Tennessee 37203 Mr. Bob Faas Westinghouse Electric Corp. County Judge P.O. Box 355 Hamilton County Courthouse Pittsburgh, Pennsylvania 15230 Chattanooga, Tennessee 37402 R. L. Gridley Tennessee Valley Authority SN 157B Lookout Place Chattanooga, Tennessee 37402-2801 M. R. Harding Tennessee Valley Authority Sequoyah Nuclear Plant P.O. Box 2000 Soddy Daisy, Tennessee 37379 Resident Inspector /Sequoyah NPS c/o U.S. Nuclear Regulatory Commission 2600 Igou Ferry Road Soddy Daisy, Tennessee 37379 H.L. Abercrombie Tennessee Valley Authority Sequoyah Nuclear Plant P.O. Box 2000 Soddy Daisy, Tennessee 37379

• NECESSARY REVISIONS-ELEMENTREPORT203.2(B)

1. The non-restart justification mentions only three of the five areas the concerned individual raised as programmatic issues. The concerns that construction requirements and general industry practices in the design process were inadequately addressed by engineering are not referred to in the justification. The scope of the justification must be expanded to address all five areas of concern.

2. The justification indicates that the issues identified in the concerns could result in only cost or operational impacts and not the performance

-or integrity of systems. The bases for such a conclusion do not appear to be presented in the justification. It is recommended that the justifico-tion should appropriately include a brief discussion of such efforts as involved in the Design Baseline Verification Program, electrical design, review of suppurts and other efforts on which some degree of reliance can be placed for uncovering any existing problems relative to the five concern areas.

3. Specific references should be provided by Element Report number where TVA believes that such reports address system performance and integrity.

4. TVA should review the logic provided in this justification which stated, "if any difficulties have resulted from such lack of attention they have been overcome or otherwise dealt with because the plant has been con-structed, and operation, maintenance and testing (e.g., start-up, in service, etc.) have been performed by pl6nt personnel." While the Sequoyah facility has an operational history it is doubtful that all desigr. conditions have been experienced so that the history does not represent all possible conditions. A'recent example related to the operability of the return air fan under post-LOCA conditions was revealed which illustrates the shallowness of the current logic. -TVA should expand the logic and basis for the conclusions to include the currert efforts to verify the design integrity and operability of various systems to reinforce the conclusion for this Element Report. g

5. Ir justifying this issue as not being a restart item, TVA needs to more clearly address all the criteria contained in Section IV, Table 7 of the Revised Sequoyah Nuclear Performance Plan submitted by TVA on July 17, 1986. Reasonable assurance that plant safety has not been impacted by these concerns needs to be presented more definitively.

Enclosure