ML20206H526

Forwards 30 Draft SERs for Sequoyah Employee Concerns Program.Ser Matl Based on Final Versions of Util Element Repts for Each Category.Sers Will Be Incorporated Into App A,Vol 2 of site-specific Issues for Final SER

ML20206H526
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 8704150381
Download: ML20206H526 (61)

Text

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March 30, 1987 Docket Nos.: 50-327 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:

Transmittal of Draft Safety Evaluations in the Employee Concerns Program for Sequoyah Re: Sequoyah Nuclear Plant, Units 1 and 2 Enclosed are 30 draft Safety Evaluations (SE) for the Sequoyah Employee Concerns Pmgram. The SE material is based on the final version of the Tennessee Valley Authority (TVA) Element Reports for each category provided to the staff.

Enclosure 1 contains a list of the safety evaluations by category. Enclosure 2 contains the draft safety evaluations. 5 The TVA Employee Concern Task Group (ECTG) files for these element reports were reviewed by the staff, audits performed on selected reports for in-dependent assessment, and telephone calls conducted with TVA staff in order to prepare these safety evaluations.

The staff plans to incorporate these safety evaluations into Appendix A, Volume 2 of the Sequoyah Specific Issues for the Final Sequoyah Safety Evaluation Report. As can be seen in Enclosure 2, there are several SEs which contain confirmatory items that TVA must complete prior to restart of Sequoyah. The staff will ensure that these issues are completed as part of its inspection prior to restart.

Please contact Jack Dohohew (301) 492-9421 of mv staff if you have any questions concerning the contents of the enclosure.

Sincerely, Original signed by John A. Zwolinski, Assistant Director for Projects eg4]Q@@{${8$o027 Division of TVA Projects p PDR Office of Special Projects

Enclosure:

As stated cc: See next page Distribution:

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

Tennessee Department of Public Regional Administrator, Region II Health U.S. Nuclear Regulatory Comission, 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 Sumit 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 Comission 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 I

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Enclosure 1 List of Draft Safety Evaluations on the Employee Concerns Program for Sequoyah i

Category Subcategory Construction 10107 10307 10501 10504 10505(I) 10603 11101 1110?

11103(2) 1120?

11203 11207 11302 g3) 15101 15102 15105

, 15109 17101 i; 19203 II)

Engineerina 20901 2090?

j 21001

21002 1

21501 21510 Material Control 40301 4030?

40307 40705 Welding WP-04-SON i

l II Followup required by TVA. Not a restart issue.

Followup required prior to Sequoyah restart.

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?,,e \ e v.s k SE0VOYAW NUCLEAR POWER PLANT UNITS 1A" SAFETY EVALUATION REPORT FOR EMPLOYEE CONCERNS ELEMENT REPORT NO. C010107-SQN,

" BACKFILL WITH 1032" I

I. Sub.iect:

Category: Construction Subcateoory: Soils Element: Backfill with 1032 (C010107)

Employee Concern: .1AN-86-002 The basis for Element Report C010107-SON (Rev. 2) dated 10-15-86 is Sequoyah Employee Concern JAN-86-002 which states:

" Excavation for DAW building foundation revealed red clay, various size rocks, etc. that was used as a backfill material for the storace yard. If building foundation is constructed without removing backfilled material an uneven settlement of building could occur."

II. Summary of Issue 4

The area of concern was that the SQN Dry Active Waste (DAW) Building

foundation was being constructed on unsuitable backffll material, that l

could result in uneven settlement of the building.

III. Evaluation The concern was evaluated by TVA. The decision was made that the existing material needed to be removed prior to building the foundation of the building, and backfilled with 1032-crushed stone material. The work was performed by TVA. As the building was classified as non-QA, the material was randomly inspected by TVA engineers, not QC inspectors.

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The concerned individual was contacted by TVA, and the evaluation report q

indicate that he was satisfied with the corrective action taken.

IV. Conclusion A review of FSAR Section 3.2, " Seismic Classification of Structures, ~

Systems, and Components " indicates that the building is not classified as a Seismic Category I structure. Furthermore, the element report and q the associated documents indicate that the building is categorized as non-seismic, and classified as requiring no nuclear grade quality assurance (non-QA). Because of the classification of the building, the staff concluded that there is no need to assess the integrity of the DAW building foundation and has not performed a review of the element r

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l DRAFT SEQUOYAH NUCLEAR POWER PLANT, UNITS 1 & 2 SAFETY EVALUATION REPORT FOR EMPLOYEE CONCERN ELEMENT REPORT C010307-SQN, "UNC0ATED WELDS AS RELATED TO CONSTRUCTION" I. Subject Category: Construction (10000)

Subcategory: Protective Coatings (10300)

Element: Uncoated Welds as Related to Construction (10307)

Employee Concerns: IN-85-243-002, IN-85-833-001 The basis for Element Report C010307-SQN, Rev. 5, dated November 17, 1986 is Watts Bar Employee Concerns IN-85-243-002 and IN-85-833-001, which I state (respectively):

"All hanger and structural steel over 6' above floor in the Reactor Bldg. and Aux. Bldg. Units 1 & 2 are unpainted. This '

was a cost savings factor."

" Top coat of paint was deleted as a requirement above 6' (above floor level) in Unit 1 Reactor Building. Items / walls are painted with primer coat only above this elevation. C/I is concerned that this could adversely affect washdown/ radiological decontamination of areas."

-Enclosure

These concerns were evaluatsd by TVA as pot 2ntially nuclear safety-related and potentially applicable to Sequoyah (generic).

1 II. Summary of Issue ,

TVA defined the issue as failure to paint, or provide a topccat of paint, for hangers, structural steel members (including applicable weld) and possibly other surfaces nore than six feet above floor levels.

Failure to paint or topcoat these areas could adversely effect efforts for radiological decontamination, if required.

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The TVA evaluators for this element reviewed applicable documents, inter-viewed personnel and observed a sample of the applicable surface areas at the Sequoyah Nuclear Plant. They determined that the design requirements established for Sequoyah provided for priming surfaces above the six foot level for corrosion protection, but did not require topcoating for.pos-sible radiological decontamination. No improper deletion of topcoating requirements or improper limitation of coating requirements was evident at

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Sequoyah.

Some rusty welds on structural steel members were identified, but this general problem was being addressed by the respense to Corrective 1

Action Report (CAR) SQN-CAR-86-01-001. These rusty welds were determined to be the result of modifications and repairs.

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The TVA evaluation cenclud:d that there was no evidence of i; proper deletion of topcoating or limitation of coating at Sequoyah, and no corrective action was required with respect to specifications or drawings 1 affecting coatings. Specific welds identified as requiring protective coating or repair to existing protective coating will be repaired through Maintenance Requests (MRs).

IV. Conclusions The NRC staff believes that the TVA investigation of the concerns was adequate, and their resolution of the concerns, as described in Element Report C010307-SQN, Rev. 5, is acceptable.

The subject of uncoated welds is also discussed in Generic Employee Concern Evaluation Report Number WP-08-SQN. Revision 1 of this report, dated August 26, 1986 has been reviewed by the NRC staff and is considered to be consistent with Element Report C010307-SQN, Rev. 5.

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• ENCLOSURE 1 SEQUOYAH NUCLEAR POWER PLANTS, UNITS 1 AND 2 SAFETY EVALUATION REr0RT FOR EMPLOYEE CONCERNS 1

I. Subject Category: Construction Subcategory: Deterioration of Permanent Facilities (10500)

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Element: Caulking as Related to Construction (iose i)

Employee Concerns: IN-85-231-003 The basis for Element Report C010501-SQN, Rev.1, dated October 9,1986, is Watts Bar Employee Concern IN-85-231-003 which states:

"In the Fifth Diesel Generator Building the caulking (Nova Caulk) in I the missile shields have turned loose and bubbled,up." l This concern was evaluated by the Watts Bar Nuclear Plant (WBN) Employee Concerns Task Group (ECTG) and determined to be potentially generic to  :

SequoyahNuclearPlant(SNP). l II. Summary of Issue The problem as defined by TVA is that the caulking in the missile shields ,

used in the Fifth Diesel Generator Building was exposed to temperature changes and moisture. This caused the caulking to separate from the i concrete and become loose.

III. Evaluation TVA performed the following inspections / reviews:

A. The review of WBN ECTG Element report, Caulking (C010501), revealed the concern was factual at WBN but was not safety-related. This review also revealed that WBN Mechanical Maintenance will issue a Field Change Request (FCR) to modify the note on TVA drawing 10W331-16 to eliminate f, the requirement to fill the lifting eye recess with caulk.

1 B. Inspection of the SQN Fifth Diesel Building revealed the top missile l shield to have two recesses approximately eight inches deep to accommodate lifting eyes. A review of TVA drawing 10W331-16 R2 showed that eight inches of polysulfide caulking would fill the recesses, of the top shield only, to seal out water. Construction of the SQN Fifth l Diesel Building is not completed. Therefore, the lifting eye recesses y do not have caulking in them at this time, i

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.j Enclosure 1 , 2 IV. Conclusion The NRC staff concludes that TVA's investigation and resolution of the concern was adequate and no further action is required by NRC.

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1 ENCLOSURE 2 SEQUOYAH NUCLEAR POWER PLANTS, UNITS 1 AND 2 l-i SAFETY EVALUATION REPORT FOR EMPLOYEE CONCERNS j i i I. Subject j

I. Subject Category: Construction Subcategory: Deterioration of Permanent Facilities (10500) l i Element: Conduit as Related to Construction I . Employee Concerns: 00-85-005-010

The basis for Element Report C010504-SQN, Rev. 2, dated October 9, 1986, is

{ Se,quoyah Employee Concern 00-85-005-010 which states:

" Exposed threads on all-thread 3-4 inch diameter conduit are rusting.

j' This occurred where short nipples of all-thread conduit join fittings i 12 to 30 inches below ceiling penetrations, above the 710 ft. eleva-tion, south part of auxiliary building. Condition existed at least

] until 1977 and may still exist."

! II. Summary of Issue l The problem as defined by TVA is that threaded connections / fittings for j electrical conduit are rusting and not being corrected. Therefore, this j could adversely affect the plant.

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III. Evaluation TVA conducted visual inspections of installed conduit in the auxiliary j building and held discussions with knowledgeable electrical personnel from j maintenance and modification groups to determine if rust on threaded conduit i connections was a problem at Sequoyah. In addition, TVA reviewed the .

! following procedures to determine if requirements existed to identify and j prohibit rust on conduit.-

i Standard Practice, SQA66, Plant Housekeeping, Rev. 9 Standard Practice, SQM2, Maintenance Management System, Rev. 18 i -

Modifications and Additions Instruction, MAI-6, Rev. 6 i

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Enclosure 2 . 2 The walkdown inspection of the auxiliary building, turbine building and j certain yard areas revealed cnly minor surface rust on threaded conduit connections / fittings. The deterioration due to rust would not require any

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corrective action. The majority of conduit in the turbine and yard areas is aluminum, whereas in the auxiliary building the conduit is primarily galvanized which prohibit rust but is not rust resistant. The discussions j

with electrical personnel did not reveal a problem with rust on conduits in the plants.

The review of the aforementioned procedures revealed that housekeeping checklist contained items to assist in identification of rust on conduit;

. that any plant personnel may initiate a maintenance request for repair due to excess rust; and that modifications or additions done after February 1986 require threaded conduit joint be made watertight and rustproof by use of a

! thread compound (YOPR-SHIELD) which will not insulate the joint.

IV. Conclusion The concern for rust on threaded conduit connections / fittings has very minor safety significance. Therefore, the NRC staff concludes that TVA's

! investigation and resolution of the concern described in Element Report

! C010504 was adequate. The NRC staff also concluded that no further action is required by NRC.

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ENCLOSURE 3 SEQUOYAH NUCLEAR POWER PLANTS, UNITS 1 AND 2 l

SAFETY EVALUATION REPORT FOR EMPLOYEE CONCERNS I. Subject i C'ategory: Construction Subcategory: Deterioration of Permanent Facilities (10500)

Element

Electrical Control Cabinets as Related to Construction Employee Concerns: OW-85-007-010

- The basis f'ro Element Report C010505-SQN, Rev. 2, dated October 9, 1986, is Sequoyah Employee Concern OW-85-007-010 which states:

' " Electrical control cabinets have been contaminated by construction dirt and metal grindings. This contamination <;ntered the panels s~

through the cooling vents on the top of the panels. This is a plant wide problem, because of the heavy build-ups of dust and metal particles that have been allowed to accumulate on top of equipment.

This could cause the contactor or other components to deteriorate and

blow out or become inoperative. A specific location given is Auxiliary Building, 757 ft elevation, unit unknown."

II. Summary of Issue The problem as defined by TVA is that the electrical control cabinets were contaminated by excessive dust and metal grindings, were not being properly i i

protected nor cleaned, and the dust would adversely affect plant operation by causing contactors and other electrical components to blow out or become inoperative.

III. Evaluation TVA conducted visual inspections of installed electrical control cabinets in the auxiliary, turbine and control buildings. Discussions were held with electrical maintenance personnel to determine if they were aware of any 4

dust / metal grindings on or inside electrical control cabinets. The discussions with electrical personnel revealed that they do not feel dust or metal grindings on or inside the control cabinets to be a problem. Some dust was observed on the outside of some of the cabinets. No dust was observed on the inside of cabinets and metal grindings were not observed anywhere.

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Enclosure 3 2 TVA reviewed Standard Practice SQA66, Revision 9, and concluded that g paragraphs 4.0.6, 4.0.7, and 4.2, Sections E and F adequately addressed the accumulation of dust, foreign materials, and moisture on the inside and outside of electrical boards, panels, and cabinets.  :

c IV. Conclusion The results of TVA's investigation of the concern for dust / metal grindings d in electrical contpol cabinets indicates that it is not a problern at Sequoyah. The NRC staff agrees with TVA's conclusion and resolution of the <

concern is descr.ibed in Element Report C010505-SQN.

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l DRAFT SEQUOYAH NUCLEAR POWER PLANT, UNITS 1 & 2 SAFETY EVALUATION REPORT FOR EMPLOYEE CONCERN ELEMENT REPORT CO 10603-SQN " BOLTING MATERIAL COMPATIBILITY" t

4 I. Subject ,

Category: Construction (10000)

Subcategory: Bolting (10600)

Element: Bolting Material Compatibility (10603)

Employee Concerns: IN-86-183-001, IN-85-021-XO4, and IN-85-824-001 The basis for Element Report CO 10603-SQN, Rev. 3, dated December 19, 1986 is Watts Bar Employee Concerns IN-86-183-001, IN-85-021-X04 and IN-85-824-001, which state (respectively):

- "WBNP Unit #1, stainless steel valves (check, globe and gate valves; different sizes; 2"O and up) have stud bolts & nuts should be stain-less steel. In 1983 and 1984, steamfitters started to change out these carbon steel studs and nuts, the change out was stopped in 1984 before all the valves were completed. Valves with carbon steel studs 4

& nuts are now insulated. Location: Reactor Building, (Accumulator-(

Rooms) and Aux Building Unit 1. CI could not recall system or valve numbers." t I " Unit 1, "all over" - stainless steel valves installed with carbon '

steel studs that have since been covered over with insulation. No  !

4 additional information available."

" Carbon steel bolts are installed in stainless steel flanged connec-tions. An example of this can be found in Unit 2 in the Aux Building l

• elevation 713' near 13 & 14 and U. Go about 10' to the north down hall to a room on the left. An example is about 3' off the floor on some 6" pipe. It exists all over the plant.

j information. CI has no additional Const Dept. concern."

All three of these concerns were evaluated by TVA as not being nuclear i 1

safety related and being potentially applicable to Sequoyah (generic).

i These concerns were previously evaluated by TVA's Nuclear. Safety Review l Staff (NSRS) as potentially nuclear safety related and re-evaluated by the l

TVA Employee Concern Task Group (ECTG) subsequent to completion of their evaluations as not nuclear safety-related. The basis for this re-evalua-tion is industry experience indicating that leakage of bolted connections due to boric acid wastage of carbon steel bolts will be detected prior to

! a significant loss of the pressure boundary.

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, II. Summary of Issue:

The problem as defined by TVA is that carbon steel bolts which were ,

installed in stainless steel flanged connections (including valves), in borated water systems, are rusting and need to be replaced. '

III. Evaluation:

TVA ECTG personnel reviewed Nuclear Safety Review Staff (NSRS) .

Investigation Report I-85-483-WBN (for Employee Concern IN-86-183-001), '

TVA design documents and vendor drawings and interviewed other TVA person-nel; they concluded that the use of carbon steel bolting in stainless steel flanged connections was common at Sequoyah, as well as, Watts Bar, ,

except in ASME Class I (TVA Class A) systems. The evaluation concluded.

that the carbon steel bolting in boric acid systems should, and is, being replaced. TVA is implementing corrective actions to enhance the identifi- ,'

cation of flanged connections in borated water' services and to replace carbon steel bolts with stainless steel bolts in those connections.

IV.

Conclusion:

The NRC inspectors reviewed Element Report CO 10603-SQN, Rev. 3, the TVA Employee Concern Task Group (ECTG) file, and discussed the issue with Sequoyah personnel.

The NRC inspectors discussed with the ECTG evaluator the reclassification of the Employee Concerns. Although the NRC inspectors do not agree that these Employee Concerns are not nuclear safety-related, the re-evaluation was performed by the ECTG in conformance with ECTG Procedure M.1 (Attachment H), and did not affect their evaluation of the issue or the corrective action.

The NRC staff concludes that TVA's investigation and resolution of the concern described in Element Report CO 10603-SQN, Rev. 3 was adequate.

The implementation of the corrective action, which is not a restart item, should be verified in a future NRC inspection.

DRAFT SEQUOYAH NUCLEAR POWER PLANT, UNITS 1 & 2

( SAFETY EVALUATION REPORT FOR EMPLOYEE CONCERNS

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. ELEMENT REPORT C031101-SQN

" CONTACT BETWEEN DISSIMILAR METALS" I. Subject -

Category: Construction (10000)

Subcategory: H' angers / Supports (11100)

Element: Contact Between Dissimilar Metals (11101) r_

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Concern: XX-85-038-001 P

I g,,/ This basis for Element Report C011101-SQN, Rev. 3, dated October 31, 1986 l 4*

is Sequoyah-specific Employee Concern XX-85-038-001 which states:

"Sequoyah: 1976 Stainless steel pipe permitted to contact carbon steel structural steel with no stainless steel insert

(" shim"); if the structural steel is painted with a particular paint that prevents chemical reaction. This paint can be rubbed off the hand and is throughout the plant."

This concern was evaluated by' TVA as potentially nuclear safety-related.

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' II. Summary of Issue i

( .. a, TVA defined the issue as the paint being used to separate carbon steel ,

l supports from stainless steel pipe will wear through and allow the carbon {

steel to contact the stainless steel directly. The NRC staff believes that the technical need for, and the Sequoyah requirements for, either shims or paint should be defined as part of the issue. i III. Evaluation  ;

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l The TVA evaluators reviewed documentation, including the Quality l 1:. Technology Company Investigation Report for Employee Concern XX-85-038-001. They performed a walkdown of various areas in the Sequoyah' . .

A'uxiliary Building to observe examples of the use of paint between  :

stainless steel pipe and carbon steel pipe supports. ~

The Element Report states that although there are some discrepancies in the requirements of applicable Sequoyah procedures relating to the use of paint to prevent contact, the discrepancies have been identified and are being corrected. It also states that the use of shims or paint to separate stainless steel pipe and carbon steel supports at temperatures

< 600'F is in excess of current industry standards. Therefore, no technical problem exists and no corrective action is required.

IV Concu1sions The NRC staff believes that the TVA investigation of the concern was adequate, and their resolution of the concern, as described in Element Report C011101-SQN, Rev. 3, is adequate.

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[ SEQUOYAH NUCLEAR POWER PLANT, UNITS 1 & 2 SAFETY EVALUATION REPORT FOR EMPLOYEE CONCERNS

. ELEMENT REPORT C011102 "0ESIGN OUTPUT" l

I. Subject  !

Category: Construction (10000)

Subcategory: Hangers / Supports (11100)

Element: Design Output (11102) t OL Concern: WI-85-091-013

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The basis for Element Report C011102-SQN, Rev. 1, dated October 10, 1986 is Watts Bar Employee Concern WI-85-019-013 which states:

"TVA is fabricating Bergen Patterson parts to a Bergen Patterson drawing; especially pipe clamps. It is now difficult or impossible to determine which pipe clamps, and other parts, were made by Bergen Patterson er fabricated by TVA. CI has l no further information. Construction Department concern." l l

J TVA personnel evaluated this concern as potentially nuclear safety-related and potentially applicable to Sequoyah (generic).

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I II. Summary nf Issue TVA perceived the issue to be that hanger drawing general notes used at Sequoyah were not clear with respect to field fabrication of support components (defined as components supplied by Bergen Patterson, not auxiliary steel). This issue was derived from information developed during investigation of the concern for the Watts Bar plant.

III. Evaluation -

The TVA evaluators reviewed applicable documents and interviewed TVA i personnel familiar with fabrication practices during construction. They

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found no evidence of notes addressing field fabrication of support '

cbmponents, and no evidence that support components were field fabricated

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. .s IV. Conclusions The NRC staff accepts the conclusion that no support components (defined as items typical of those supplied by Bergen Patterson) were field fabricated at Sequoyah. The concern as stated thus has no relationship to Sequoyah, and the TVA resolution of the concern, as described in Element Report C011102, Rev. 2, is adequate. -

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DRAFT SEQUOYAH NUCLEAR POWER PLANT, UNITS 1 & 2 SAFETY EVALUATION REPORT FOR EMPLOYEE CONCERN ELEMENT REPORT CO 11103-SQN " METHODS USED DURING INSTALLATION" I. Subject Category: Construction (10000)

Subcategory: Hangers / Supports (11100)

Element: Methods Used During Construction (11103)

Employee Concern: IN-85-288-001, IN-86-116-001, and XX-85-070-007 The basis for Element Report CO 11103-SQN, Rev. 5, dated December 19, 1986 is Watts Bar Employee Concerns IN-85-288-001 and IN-86-116-001 and Sequoyah-specific Employee Concern XX-85-070-007, which state (respectively):

" Snubbers are not handled properly and are not adjusted and installed in accordance with the manufacturer's recommended practices of protecting them in waterproof coverings, storing and carrying them compressed, and adjusting their paddles only while they are held vertical. Construction Dept. concern. (CI has no more information)

No followup required."

"Not all piping hangers have ends of tube steel closed / capped, but electrical hangers do. When caps have been inadvertently installed on piping hangers, QC has made the craft remove them. Open tube steel collects dirt and water, and could conceal a bomb or other prohibited item. (Unit II construction). No additional information

, available in file. No follow up required."

"Sequoyah, September 1984 Unit 2: Installed snubbers are not per design drawings (115 drawings involved) and no rework has been scheduled except a request to include this in 1986's budget.

Nuclear power concern. C/I has no further information."

Concerns IN-85-288-001 and XX-85-070-007 were evaluated by TVA as poten-tially nuclear safety-related and safety significant. The two Watts Bar concerns were determined by TVA to be potentially applicable to the Sequoyah Nuclear Plant (generic).

II. Summary of Issue The issues raised by the three concerns appear unrelated, except that they involve pipe supports (snubbers, auxiliary steel). The issues were separately defined by TVA, and separate corrective actions were defined to resolve the issues. The three issues defined by TVA were: (a) there were no procedures covering handling of snubbers; (b) snubbers were not

installed in accordance with design drawings; and (c) not all vertical tube steel sections were capped to exclude water or other material.

III. Evaluation TVA personnel reviewed Watts Bar Nuclear Safety Review Staff (NSRS)

Investigation Report I-85-713-WBN, Sequoyah Nuclear Plant Standard Practices, Maintenance Instructions, Surveillance Instructions, contract documents and design drawings, interviewed cognizant personnel and conducted a field walk down. The TVA evaluators concluded that (a) although Sequoyah procedures did not generally include vendor (or other) requirements for handling snubbers the periodic surveillance and testing would have detected any damaged snubber due to improper handling; (b) some vertical tube steel sections were uncapped, contained water, and could be damaged by freezing; and (c) deviations had been made from typical snubber support drawings, but that the deviations had been documented on variance forms (although some documentation was subsequently lost).

Corrective Actions have been proposed by TVA to resolve the three areas of concern and prevent recurrence of the problems. These corrective actions are mainly of a documentation nature, including adding handling requirements to instructions and documenting hanger design variances.

Those non-standard snubber supports which do not meet design requirements will be modified prior to restart. A limited number of vertical tube steel sections will be capped or be drilled to provide weep holes for drainage.

IV. Conclusion The NRC inspectors reviewed Element Report CO 11103-SQN, Rev. 5 and the Employee Concerns Task Group (ECTG) file.

The NRC staff concludes that TVA's investigation of the three issues were adequate, and their conclusions and resolution of the concerns described in Element Report CO 11103 SQN, Rev. 5 is satisfactory. The corrective action for the snubber support design drawings, which TVA identified as a restart item, should be verified by NRC inspectors in a future inspection.

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DRAFT SEQUOYAH NUCLEAR POWER PLANT, UNITS 1 & 2 . '-'. ,

SAFETY EVALUATION REPORT FOR EMPLOYEE CONCERNS ELEMENT REPORT C011202-SQN

" CRAFT DESIGNED HANGERS AS RELATED TO CONSTRUCTION" l

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Category: Construction (10000)

Subcategory: Work Control (11200)

Element: Craft Designed Hangers as Related to Construction (11202)

S. Qoncerns: IN-86-261-002, XX-85-120-006

"" The bases for Element Report C0ll202-SQN, Rev. 2, dat'de October 10, 1986

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are Watts Bar Employee Concern IN-86-261-002 and Sequoyah-specific Employee Concern XX-85-120-006, which state (respectively):

"Due to Work required by FCRs/ECN's not being performed promptly, the craft many times are working to an obsolete drawing. After requesting inspection for completed work, QC may inform craft that completed work ir not acceptable as a previous FCR/ECN requirement was incorporated in the drawing, but the work has not been performed. Example, panels in the Unit 2 Relay Room. Construction Department concern. CI has no additional information. No follow up required."

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l "Sequoyah-Hanger crews were instructed (Supervisor known) to go ahead and build hangers without drawings, and engineering would draw the hanger up later. ManyofthSse hangers were subsequently rejected and reworked. Construction Department concern. CI has no further information."

Employee Concern IN-86-261-002 was evaluated by TVA as potentially nuclear

' safety-related and potentially applicable to Sequoyah (generic);

! XX-85-120-006 w'as evaluated by TVA as potentially nuclear safety-related.

II. Summary of Issue

, TVA personnel defined the issue as being that hangers were installed by thecraftswithoutadesigndrawing,orwithasupersededdesigndrawing, and engineering would then do the as-constructed drawing. T'he NRC staff believss that theissue includes the possibility of TVA personnel failing to identify all departures from final, approved design drawings thus resulting in unknown margins of safety for such hangers.  !

III. Evaluation  !

l The TVA evaluators reviewed documentation and interviewed TVA personnel involved in the installation of hangers. They determined that although some hangers were installed p'rior to the issuance of design drawings, the hangers were later as-built, analyzed and approved by engineering personnel. The hangers were inspected and accepted by QC based only on approved design drawings. Current work practices at Sequoyah require a work plan, which must include approved design drawings, prior to performing work.

L IV. Conclusions The NRC staff believes that the TVA investigation of the concerns was appropriate and their resolution of the concerns, as described in Element Report C011202-SQN, Rev. 2, is adequate.

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DRAFT SEQUOYAH NUCLEAR POWER PLANT, UNITS 1&2 SAFETY EVALUATION REPORT FOR EMPLOYEE CONCERN ELEMENT REPORT CO 11203-SQN " POOR PLANNING AND COORDINATION AS RELATED TO CONSTRUCTION" I. Subject Category: Construction (10000)

Subcategory: Work Plan / Work Control (11200)

Element: Poor Planning and Coordination as Related to Construction (11203)

Employee Concern: MAS-86-003 The basis for Element Report CO 11203-SQN, Rev. 3 dated October 30, 1986, is Sequoyah-specific Employee Concern MAS-86-003 which states:

Adequacy of work being done by construction concerning fuse identification work plans."

This concern was evaluated by TVA as potentially nuclear safety-related.

II. Summary of Issue The problem as defined by TVA is that fuse identification discrepancies exist between the design drawings and the installed configuration and no corrective action had been, or was, being taken to resolve the discrepancies.

III. Evaluation The TVA evaluators reviewed applicable documents including Workplan Number 10512 and interviewed TVA electrical maintenance personnel to determine the extent and specif,1c details of the problem as defined. The evaluators found that there are fuse discrepancies, due to failures to keep as-built drawings up-to-date. The corrective action will use data developed from identification verification presently being performed. Discrepancies identified will be corrected as specified in work plans and upon comple-tion, drawings will be marked up and revised. Current work practices at Sequoyah require a work plan, which must include approved design drawings prior to performing work.

IV. Conclusion The NRC inspectors reviewed Element Report CO 11203-SQN, Rev. 3 and the Employee Concern Task Group (ECTG) file.

The NRC staff concludes that TVA's investigation of the concern was adequate and their resolution of the concern as described in Element Report CO 11203-SQN, Rev. 3, is acceptable. Implementation of the correc-

tive action, which TVA identified as a restart item, should be verified by NRC inspectors in a future inspection.

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- DRAFT

( SEQUOYAH NUCLEAR POWER PLANT, UNITS 1 & 2 ..~

SAFETY EVALUATION REPORT FOR EMPLOYEE CONCERNS - 'e ELEMENT REPORT C011207-SQN

" IMPROPER INSTALLATION AS RELATED TO CONSTRUCTION"

1. Subject Category: Construction (10000)

Subcategory: Work Control (11200)

Element:

Improper Installation as Related to Construction (11207) t

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Concern: XX-85-101-002 - *

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g,,; The basis for Elem t Report C011207-SQN, Rev.1, dated Detober 10, 1986 is Sequoyah-specific Employee Concern XX-85-101-002, which states:

"Sequoyah - Improper Installation of non-nuclear. system could adversely affect public health and safety. Details known to I QTC, withheld due to confidentiality. Construction Department concern. , CI has no further information. No followup required."

-1 Employee Concern XX-85-101-002 was evaluated by TVA as potentially nuclear safety-related. .

4 II. _ Summary of Issue Improper installation of the non-nuclear system could adversely affect public health and safety.

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/ III. Evaluation .

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Review by TVA evaluators of their files relating to Employee Concern XX-85-101-002 revealed no meaningful informat.fon in addition to that provided in the Employee concern. The concern as stated is too vague for meaningful investigation. The evaluation by TVA of other concerns in the

. Subcategory for Work Control did not identify a problem with improper installation or. work control.

IV. Conclusions ,

The NRC staff agrees that the information available on the concern is too.

vague to allow for meaningful investigation. The NRC evaluation of other Sequoyah Element Reports in the Subcategoty of Work Control ,did not reveal ~

464 any systematic problems in installation or work control. TVA resolution of the concern, as described in Element Report C011207, Rev.1, is adequate.

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l DRAFT SEQUOYAH NUCLEAR POWER PLANT, UNITS 1 & 2 e<

SAFETY EVALUATION REPORT FOR EMPLOYEE CONCERNS ELEMENT REPORT C011302-SQN

" DESIGN OF ANCHORS AS RELATED TO CONSTRUCTION" I. Subject ,

I Category: Construction (10000) '

. Subcategory: Anchorages (11300)

Element: Design of Anchors as Related to construction (11302)

Concerns: PH-85-002-09, IN-86-200-003 The bases for Element Report C011302-SQN, Rev.1, datad October 10, 1986 are Watts.Bar Employee Concern PH-85-002-009 and IN-86-200-003 which question the use of Red Head-type concrete anchors at TVA nuclear sites.

. These concerns were evaluated by TVA as potentially nuclear.

6 I safety-related and.potentially applicable to Sequoyah (generic). l II. Summary of Issue The stated concerns as defined by TVA are that Phillips Red Head anchor bolts had been declared unsuitable for use and replaced at other non-TVA nuclear sites and that the use of Red Heads for supports is not safe because concrete could be honeycombed around the Red Head.

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III. Evaluation ,

Y TVA personnel reviewed the NSRS Investigation Report for Watts Bar Employee Concern IN-86-200-003 (NSRS Investigation Report No. I-85-440-WBN) and the Sequoyah Nuclear Plant (SQN) Generic Concerns Task Force (GCTF) report which related to the use of Red Head-type anchors.

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These reports referenced the anchor installation inspections and test result evaluations required by TVA General Construction Specification G-32 and anchor test results perfomed for IE Bulletin 79-02. Based on the results of these

)

tests and inspections, TVA concluded there was no evidence of Red Head- I type anchor inadequacies.

. IV. Conclusions

. l

) Phillips Red Head anchor bolts have been used at a number o'f nuclear power plants and their use is acceptable to the NRC staff provided they are properly installed and qualified. The NRC staff reviewed TVA's implementation of the requirements of IE Bulletin 79-02 and closed the ,

Bulletin in Inspection Reports 50-327/80-50 and 50-328/81-27. Therefore, l t

the NRC staff believes that the TVA investigation of the concern was adequate, and their resolution of the concern as described in Element Report CO 11302-SQN, Revision 1, is acceptable.

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e Safety Evaluation Report Sequoyah Nuclear Plant Employee Concerns I. SUBJECT

- CATEGORY: Construction (15000)

SUBCATEGORY: Damage (15100)

ELEMENT: Floor Drain Level Transmitters (C015101)

CONCERN: (IN-86-158-005) - Water backed up on reactor building floor, resulting from level transmitters being damaged.

II.

SUMMARY

OF ISSUE A generic concern about the dondition of floor drain level transmitters was identified as a result of a review conducted on Watts Bar item IN-86-158-005. An additional issue concerning the operability of the containment pocket sump level transmitters was also identified.

III. EVALUATION The licensee reviewed the applicable Watts Bar element report (C015101), and Nu'elear Safety Review Staff (NSRS) Report I-95-509-WBN. In addition the licensee interviewed knowledgeable instrumentation maintenance personnel concerning damage to level transmitters.

The Watts Bar element report determined that level transmitters installed in the containment pocket sump were subject to damage during construction activities and that these transmitters were scheduled to be replaced by a more durable transmitter.

Sequoyah had similar transmitters installed in the containment pocke'. .np but the licensee determined that there had not been a history of failure, because of construction or other personnel related activities. The licensee did determine that there had been a history of transmitter failure as a result of equipment malfunctions. A design change has been initiated at

Sequoyah (.SQ-DCR-P-2242) to replace the level transmitters and is scheduled for completion at some later date.

IV. CONCLUSION The licensee's determination of the root cause for level transmitter i

failures and its evaluation of personnel related damage appears to be adequate. The resolution of design change SQ-DCR-P-2242 is a requisite to the resolution of this issue. However, the safety significance of this issue does not justify its inclusion as a startup item. With the exception of NRC verification that SQ-DCR-P-2242 was implemented, this item.is closed.

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1 Safety Evaluation Report V

Sequoyah Nuclear Plant Employee Concerns l SUBJECT l I.

. CATEGORY: Construction (15000)

SUBCATEGORY: Damage (15100)

ELEMENT: Damage to Electrical Penetrations (C015102)

CONCERN: (IN-85-346-002) - Electrical penetrations entering the t

. reactor building are not strong enough and have been damaged because of being walked on.

II.

SUMMARY

OF ISSUE l l

A generic concern about the condition of the electrical penetrations was identified as result of a review conducted on Watts Bar specific item  !!

IN-85-346-002. An additional concern over the adequacy of the penetration covers was.also identified.

III. EVALUATION The licensee determined that there was no damage to containment electrical penetrations and that the damage identified by the concerned individual was actually to the penetration covers. The electrical penetration covers are

> constructed of sheetmetal and are plant specific. In addition, the electrical covers have been included in the seismic calculations com'pleted for the penetrations. The licensee determined that the penetration covers specific to Sequoyah were more sturdy than those used at Watts Bar and that there was no present damage to either the electrical penetrations or the electrical penetration covers.

IV. CONCLUSION The licensee's review of potential reportable occurrences and field verification appear to be adequate to determine that there is no damage to the electrical penetrations at Sequoyah. The licensee has also determined that, at Sequoyah, adequate penetration covers are in place and that no excessive penetration cover damage, exists. No actions are required to be completed prior to the startup of either unit. This issue is closed.

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I Safety Evaluation Report Sequoyah Nuclear Plant Employee Concerns I. SUBJECT CATEGORY: Construction (15000)

SUBCATEGORY: Damage (15100)

ELEMENT: Training en the Protection of Flex Hose (C015105)

CONCERN: (IN-85-449-001) - All personnel should be trained on the protection of flex hose connections in order to preclude further damage.

II.

SUMMARY

OF ISSUE ,

A generic concern about the status of employee training in the area of flex hose protection was identified as a result of a review conducted on Watts Bar specific item IN-85-449-001. This issue was reviewed by the licensee

, specific to5c Sequoyah Nuclear Plant.

III. EVALUATION Th4 licensee reviewed maintenance history documents and interviewed know-ledgeable plant personnel. The licensee determined that no pattern of flex hose damage existed at the Sequoyah Nuclear Plant. The licensee also conducted a walkdown of approximately 150 flex hose connections and dis-covered no currently damaged hoses. Finally, the licensee determine that no formal training was conducted on flex hose damage.

IV. CONCLUSION The licensee substantiated that no formal training existed at the Sequoyah Nuclear Plant on prevention of flex hose damage. However, the need for such training was disputed by the licensee based on the absence of any identi-fiable trend of current or past flex hose damage. Flex hose damage had been identified by the NRC in isolated cases but, there does not appear to be a pervasive flex hose damage issue at Sequoyah Nuclear Plant. Therefore, the need for flex hose damage training does not appear to exist. No actions by the licensee are required prior to the startup of either unit. This issue is closed.

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i Safety Evaluation Report l Sequoyah Nuclear Plant l Employee Concerns F

I. SUBJECT

. CATEGORY: Construction (15000)

SUBCATEGORY: Damage (15100)

ELEMENT: Damage to Instrumentation Tubing (015109)

CONCERN: (IN-86-200-006) - Copper and stainless instrumentation  !

tubing throughout Units 1 and 2 is unprotected and span between hangers are bent.

(IN-85-119-002) - Instrumentation lines through out power block are damaged, bent, flattened and touching.

(IN-85-618-004) - Instrument tubing in the Unit 2 accumula-tor #4 area is being severly damaged; protection should be provided.

II.

SUMMARY

OF ISSUE A generic concern about damage to instrumentation tubing was identified as a result of three Watts Bar specific items (IN-86-200-006, IN-85-119-002, and IRt85-618-004).

III. EVALUATION Tne licensee reviewed a Watts Bar specific element report (C015109-WBN) and determined that the Division of Nuclear Construction had a program to limit instrument line damage at Watts Bar. It was determined that the Division of Nuclear Power at both the Watts Bar site and the Sequoyah Nuclear Plant did not have a program expressly designed to limit instrument line damage. ,

The need for a program to limit instrument line damage was assessed by the l licensee through a walkdown of approximately 800 instrument tubes. No l instrument tube damage was identified during the walkdown process. In j addition, interviews with knowledgeable personnel did not identify any 1 instrument line damage issues specific to the Sequoyah Nuclear Plant. l IV. CONCLUSION The licensee's actions to evaluate the extent of instrumeht line damage appear to be adequate. In the absence of present damage, the determination by the licensee that a damage prevention program was not needed at the Sequoyah Nuclear Plant, appears to be appropriate. There are no actions required by the licensee prior to the startup of either unit. This issue is closed.

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- DRAFT SEQUOYAH NUCLEAR POWER PLANT, UNITS 1 & 2 SAFETY EVALUATION REPORT FOR EMPLOYEE CONCERN ELEMENT REPORT CO 17101-SQN " VALVES" I. Subject Category: Construction (10000)

Subcategory: Mechanical (17100)

Element: Valves (17101)

Employee Concerns: IN-85-055-N04 and XX-85-094-007 The basis for Element Report CO 17101-SQN, Rev. 2, dated October 10, 1986 is Bellefonte Employee Concern XX-85-094-007 and Sequoyah-specific Employee Concern IN-85-055-N04, which state (respectively):

"Bellefonte: Limitorque valves were stored and installed with wrong altitude (upside down) and were not maintained (stroked, etc.).

Construction Dept. concern. CI has no further information. No follow up required."

"NRC identified the following concern from review of QTC file.

" Emergency hand valve incorrectly installed."

These concerns were evaluated by TVA as potentially nuclear safety-related, and XX-85-094-007 was evaluated by TVA as potentially applicable to Sequoyah (generic).

II. Summary of Issue:

, The problems as defined by TVA are that (a) Limitorque motor operators for valves were not stored, installed or maintained properly, and (b) an

" emergency hand valve" was incorrectly installed at Sequoyah and thus could not be manually operated.

III. Evaluation:

The two issues were separately investigated and evaluated by the Employee Concern Task Group (ECTG) evaluators. They reviewed applicable mainte-nance, inspection, storage and installation procedures for the Limitorque valve motor operators, and also reviewed contract and design documents and held discussions with cognizant Sequoyah personnel. The ECTG evaluators found that Sequoyah procedures and instructions met all of the vendor's )

requirements for storage, maintenance and installation. Valves have been  !

installed in other than the manufacturer's preferred orientation; however, both Limitorque and TVA's engineering staff have stated that if proper lubricant and maintenance practices are implemented the performance of Limitorque motor operators for valves is not affected by the mounting position.

8 The second issue, involving the " emergency hand valve," was determined by the ECTG evaluators to be invalid. Procedures in effect at Sequoyah should result in the identification and correction of equipment inaccessibility problems.

IV. Conclusions:

The NRC agrees with the TVA findings and conclusions as described in Element Report No. CO 17101-SQN Rev. 2. No further action by the NRC required.

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. DRAFT 2 SEQUOYAH NUCLEAR POWER PLANT, UNITS 1 & 2 SAFETY EVALUATION REPORT FOR EMPLOYEE CONCERN ELEMENT REPORT CO 19203-SQN " CONDUIT FITTINGS" I.

Subject:

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! Category: Construction (10000)

Subcategory: Conduit and Tray (19200)

Element: Conduit Fittings (19203)

Employee Concern: IN-85-374-002 l

The basis for Element Report CO 19203-SQN, Rev. 2 dated January 9, 1987 is Watts Bar Employee Concern IN-85-374-002 which states:

" Approx. 500 Erickson connectors / fittings for conduit had been installed and discovered to be aluminum and not magnetic. These are in the process of being removed. Since Erickson connectors are not requisitioned out to the craft, how can they be identified and removed with confidence that all have been replaced? WBNP #2."

2 This concern was evaluated by TVA as potentially nuclear safety-related and potentially applicable to Sequoyah (generic).

II. Summary of Issue The problem as defined by TVA is that conduit fittings composed of metal which could react with borated water to form. hydrogen may have been procured and installed inside' containment without being included.in the i

appropriate calculation package for the percent hydrogen build-up inside containment following a Loss of Coolant Accident (LOCA) or a Design Basis Event.

4 III. Evaluation i

The TVA Employee Concern Task Group (ECTG) evaluators reviewed applicable i

documents and interviewed cognizant Sequoyah engineering personnel to '

determine the procurement requirements for electrical conduit and acces-l sories and to determine how light metal inventories inside containment 1 were developed and updated. It was determined that the conduit fittings installed were die cast zinc and not aluminum. Since die cast zinc can j

react with borated water to form hydrogen, design basis calculations for hydrogen build-up should include this material in the inventory.of hydro-ger, sources.

The ECTG evaluators established that the construction specification applicable to Sequoyah did not control the installation of zinc materials within containment, and the procurement specification did not preclude procurement of zinc coated or die soe4 zinc conduit fittings. Thus the cu+

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potential exists for reactive metals to have been procured and installed in containment without having been included in the inventory of hydrogen sources.

The corrective actions proposed by TVA will preclude the future use of zinc conduit fittings in containment, and ensure that an accurate update of reactive metal inventory is prepared and hydrogen generation calcula-tions revised to determine whether a hydrogen buildup problem exists at Sequoyah.

IV. Conclusion The NRC inspectors reviewed Element Report CO 19203-SQN, Rev. 2 and the related ECTG file, and discussed the report with the ECTG evaluator.

The NRC staff concludes that the TVA's investigation and evaluation of the concern described in Element Report CO 19203-SQN, Rev. 2, is adequate and the corrective actions to be taken are adequate. Implementation of the corrective actions should be verified by NRC inspectors in a future inspection.

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SEQUOYAH NUCLEAR POWER PLANTS, UNITS I & 2 SAFETY EVALUATION REPORT FOR EMPLOYEE CONCERNS ELEMENT REPORT ENG-209.1(8) - SQN "Q-LIST DIFFERENCES" I. Subject Category: Engineering (20000)

Subcategory: 0-List (20900)

Element: Q-List Differences (20901)

Employee Concerns: IN-85-407-001, IN-85-688-003 IN-86-087-004, IN-86-090-001 The bases for Element Repnrt 209.1(8), Rev. 1, dated January 23, 1987 are the Watts Bar Employee Concerns listed above which state:

IN-85-407-001 "CSSC Q-List is nnt accurate. Not all components covered by QA program are If sted. QE Department has list that documents the inaccuracies. The CSSC Q-List is used to determine if QC inspections are required. CI has no further information."

IN-85-688-003 " Concern over validity of Critical System, Structures and Components 'Q' listing. Details known to QTC. Details withheld to maintain CI confidentially."

IN-86-087-004 "Significant differences exist in the content of the Nuclear Power 'O' List and the Critical Structures, Systems and Components (CSSC) 'Q' List. Many items originally placed on the NUC Power 'Q' List are not reflected on the CSSC

'Q' List, which could adversely affect establishment of dppropriate quality Controls on items Which are related to plant safety. Nuclear Power concern. No specifics provided. CI has no further infomation."

IN-86-090-001 "NUC PWR (No name/ dept. given) issued a Critical Structures, Systems and Components List (CSSC) that does not include all items identified on the site 'Q' List (No specifics given).

This was done without Office of ENG, ENG Design Group input / approval (The originator of the site 'Q' List). By referring to the CSSC, the possibility exists for installing

'Non-Q' items in a Safety-Related System. CI has no additional information. NUC POWER concern."

These concerns were evaluated by TVA as and potentially applicable to Sequoyah (potentially generic). nuclear safety-related Enclosure

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II. Sumary of Issues The issues defined by TVA are that Q-lists (or equivalent) used on SQN to l identify the applicability of QA program controls are not accurate and '

complete, that various Q-lists (or equivalent) exist for SQN which differ in content, and that the engineering design group does not provide input i to the SQN Q-list (or equivalent).

l Another issue on these employee concerns is covered in Element Report 209.2(B).

III. TVA Evaluation, Conclusion, and Corrective Action TVA personnel determined that

3. The SQN CSSC (Critical Structures, Systems, and Components) list is the "Q-List" type document in use on SQN to identify items that require QA program controls. A complete review of the SQN CSSC List for accuracy and completeness has not been performed to date.

The activities of the SQN CSSC Review Comittee are a positive factor towards maintaining the SQN CSSC List as a "living" document. However, the following shortcomings are evident in the Review Committee actions:

o A TVA review of the SQN CSSC List for accuracy and completeness has not been accomplished to date. Therefore the baseline, to which the CSSC Review Committee is providing updates for plant modifications etc., is of undetermined accuracy-and completeness.

o The practice of deferring numerous classification actions to a pending Q-List development by the Division of Nuclear Engineering (DNE) contributes to the questionable status of SQN CSSC List's accuracy and completeness,

b. The investigation indicated that only a single listing, the SQN CSSC List, was used on Sequoyah. The Engir,eering organization had devel-oped a " trial use" SQN Q-List, but it was not used on the project.

Thus, the problems associated with the existence of several Q-Lists having different content were not applicable to Sequoyah.

Further, the TVA commitment to implement the forthcoming DNE-developed and maintained Q-List will adhere to the principle that a single list prescribing QA program applicability will be in existence for SQN.

Thus, at some future date, the SQN CSSC List will apparently be superseded by an SQN Q-List.  ;

c. The SQN CSSC List was initially developed and issued by the Office of Nuclear Power and is presently the responsibility of the SQN Nuclear Site Director, through the Operations organization. The CSSC List is maintained by the SQN CSSC Review Committee. Although the controlling procedure does not require a member from the Division of Nuclear Engineering (DNE) on the committee, the DNE has actively participated in CSSC Review Comittee activities on an as-needed s- L

> basiso The interface with DNE tenpers the employe2 concern related to the issue of lack of engineering design group input / approval of the list.CSSC List and indicates a DNE "de factn" involvement with the The TVA evaluation concluded that P.

The issue relating to the accuracy and completeness of the SQN CSSC List is valid. This conclusion is tempared by the positive factor that the on-going activities of the SQN CSSC Review Comnittee provide a

CSSCreasonable List. assurance that there are not major problens with the SQN However, it is prudent for TVA to perform a confirmatory review of the accuracy and completeness of the SQN CSSC List, to address need various for such TVA internal references (direct or inferred) to the a review. The review should be performed with input from DNE to datermine the degree of completeness appropriate for the list, and should include resolution of those agenda items previously deferred by the SQN CSSC Review Committee.

b.

The issue relating to the existence of multiple Q-Lists (or equiva-lents) with different contents is not valid for SQN.

c.  !

The issue related to the lack of engineering design group input to the Q-lists (or equivalents) is not valid for SQN.  !.

As regards to corrective action, TVA has developed a corrective action  !

i plan which was reviewed by the evaluation team and discussed with the  !

responsible line organization. The discussions clarify the corrective action plan and were documented. The corrective action plan commits that t all active items on the SQN CSSC Review Comittee agenda will be reviewed  !

to identify any items that require actions prior to restart. This review will include of the those items that were noted as " deferrals to the development Q-List." ,;

n IV. Conclusion '

The NRC staff believes that the TVA investigation of the concerns was adequate. i Also, the resolution of the issues as described in Element Report 209.1(B) is generally acceptable. However, while the TVA evalu-ation concludes that it is prudent for TVA to perform a confirmatory ,

review of the accuracy and completeness of the SON CSSC list (with DNE ncrticipation), the corrective action described does not commit to the performance of such a review. As noted in the element report, current i Sequoyah procedures require such a review on a biennial frequency. This would dictate that the CSSC list be reviewed for accuracy and completeness during the March - June 1987 time frame. In our assessment, this schedule is compatible with the current restart schedule. Therefore, the performance of such a review as well as acceptable inplementation of TVA's corrective action plan is required prior to restart. Allegations which have a potential impact on these conclusions have not yet been fully evaluated.

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SEQUOYAH NUCLEAR POWER PLANTS, UNITS 1 & 2 SAFETY EVALUATION REPORT FOR EMPLOYEE CONCERNS ELEMENT REPORT ENG-209.2(8) - SQN

" IMPACT AND SIGNIFICANCE OF 0-LIST OIFFERENCES" I. Subject Category: Engineering (20000)

Subca tegory: 0-List (20900)

Element: Impact and Significance of Q-List Differences (20902)

Employee Concerns: IN-85-407-001, IN-86-087-004, IN-86-090-001 The bases for Element Report 209.1(B), Rev.1, dated January 23, 1987, are Watts Bar Employee Concerns listed above which state:

IN-85-407-001 "CSSC Q-List is not accurate. Not all components covered by QA program are listed. QE Department has list that documents the inaccuracies. The CSSC Q-List is used to detemine if OC inspections are required. CI has no further infomation."

IN-86-087-004 "Significant differences exist in the content of the huclear Power 'Q' List and the Critical Structures, Systems and Components (CSSC) 'Q' List. Many items originally placed on the NUC Power 'Q' List are not reflected on the CSSC 'O' List, which could adversely affect establishment of appropriate quality controls on items which are related to plant safety. Nuclear Power concern. No specifics provided. CI has no further information.

IN-86-090-001 "NUC PWP, (No name/ dept. given) issued a Critical Structures, Systems and Components List (CSSC) that does not include all items identified on the site 'Q' List (No specifics given). This was done without Office of ENG, ENG Design Group input / approval (The originator of the site 'Q' List). By referring to the CSSC, the possibility exists for installing 'Non-Q' items in a Safety-Related System.

CI has no additional information. NUC POWER concern."

These concerns were evaluated by TVA as potentially nuclear safety-related and potentially applicable to Sequoyah (generic).

II. Sumary of Issue The issue defined by TVA is that the use of inadequate Q-Lists (or equivalent) on SQN could have adversely affected the establishment of ,

appropriate QA program controls on items that are related to plant safety. i By reference to an inadequate Q-List, the possibility exists that "Non-Q" items are installed in a safety-related system. l 1

d Other issues on these employee concerns are covered in Element Report 209.1(B).

III. TVA Evaluation, Conclusion, and Corrective Action TVA personnel determined that:

i

a. The SQN CSSC (Critical Structures, Systems, and Components) List,  !

which identifies items that require QA program controls, has been  !

used only by the Operations organization; the list was not used by Construction or Engineering on SQN. Therefore, the potential effects of using an inaccurate or incomplete SQN CSSC List are limited to Operations cethf tft s, which in::hde procurement, maintenance, and ihodi fication,

b. SQN procedures that control procuremant, maintenance, and modiff-cation activities of the OperWons organfration establish the SQN CSSC List as the base referenew for identifying safety-related (CSSC) items: Erreaec"! c h n ifica?.;or or an item as non-CSSC could result in omission of essential requirements and activities.

c. No specific deficiencies in the SQN CSSC List were identified in the review of the case file materials.

The TVA evaluation concluded that, in addition to the conclusions of Osent Report 209.1(B) that a review of the accuracy and completeness of ths SQN CSSC list is prudent and that items previously deferred by the SON CSSC Review Committee should be resolved, the issues related to the possibility that use of an inadeouate SQN CSSC List could adversely affect QA progran controls on safety-related items is valid. That is, an inac-curate or incomplete SQN CSSC List could result in misclassification of an item or work activity as not being safety-related and onission of QA program requirements. This could adversely affect the establishment of appropriate QA program controls on items affecting plant safety and therefore needs resolution prior to restart.

As regards to corrective action, TVA has developed a corrective action plan which provides that if the corrective action for Sequoyah Elemer.t 209.1 discloses inaccuracies or onissions in the SQN CSSC List, the items will be dispositioned (prior to restart if appropriate) in accordance with TVA procedures for conditions adverse to quality.

. Conclusion The NRC staff believes that the TVA investigation of the concerns was adequate and that the resolution of the issue as described in Element Report 209.2(B) is generally acceptable. However, TVA's corrective action must address all inaccuracies and omissions in the SQN CSSC List disclosed by the corrective action described in report 209.1(B) as well as those disclosed by the accuracy and completeness review. Dispositions for inaccuracies and omissions are required prior to restart, and corrective action scheduling should be based on the restart criteria in Volume 2 of TVA's Nuclear Performance Plan. Allegations which have a potential impact on these conclusions have not yet been fully evaluated.

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SE000YAH NUCLEAR POWER PLANT, UNITS 1 A 2 SAFETY EVALUATION REPORT FOR EMPLOYEE CONCERN ELEMENT REPORT EN 210.1, " SENSITIVE E0VIPMENT LOCATED IN HARSH ENVIRONMENT" I

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1. Subject Category: Engineering (EN200) i Subcategory: E0 Process (EN210)

Element: Sensitive Equipnent Located In Harsh Environrent (EN210.1)

The basis for Element Report EN210.1, Revision 1, dated January 2?, 19E7, is Employee Concern IN F5-068-002 wMe ete n

" Sensitive equipment, i.e., instruments and instrurert panels are located in a harsh environment. CI stated that the location of this equipment is in the bottom of the reactor and part way up the building. Unit not specified."

This concern was evaluated by TVA as potentially nuclear safety-related and potentially applicable to Sequoyah (generic).

II. Sumary of Issue The issue defined by TVA is that certain sensitive equipment, such as instruments and instrument panels, is located in a harsh ervironment near the lower portion of the reactor.

III. Evaluation TVA personnel determined that the concern is valid in that sensitive equip-nent is located in the areas described. Hcwever, it was determined that the concern was known (reference WESTEC/TVA report entitled "Panagement Review of Environnental Qualification Activities and Documentation for Complience with 10 CFR 50.49," dated September 25,19P.5) and appropriate measures were being taken to ensure operability of this equipment in the environmental conditions that exist.

Since the concerned individual (CI) did not identify specific equipment or elaborate as to what specific environnontal conditions (rcrmal operating environnent or design basis accident environment) were of corcern, TVA evaluated the concern relative to safety-related equipnent located in

, harsh environments and covered under 10 CFR 50.49. TVA concluded that the Sequoyah equipment oualification (EO) program, which was developed as a result of the WESTEC/TVA report, is adequate to ensure that safety- "

related, sensitive equipment located in the areas described will perform their respective functions in the harsh environments in which they must .

operate.

- 2-IV. Conclusions The NRC staff believes that the TVA investigation of the concern was adequate, and their resolution of the :oncern as described in Elerert Report EN 210.1, Revision 1, is acceptable. The NRC bas conducted inspections of the Sequoyah EQ prograr January 6-17, February 10-14, June 23-?7, and December 8-1?, 1986. and a final inspection of the procram is scheduled prier to Unit 2 restart. Althouch deficiencies were found during the inspections, TVA has corrected the deficiarcies or will have them corrected prior to restart. Subject to ecmpletion of the Sequeyah EQ program by TVA and certification that Sequoyah is in compli-ance with 10 CFR 50.49, the staff believes that the Securyah EQ program will ensure satisfactory resolution of this issue. Allegations which have a potential impact on these conclusions have not yet been fully evaluated.

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SEQUOYAH NUCLEAR POWER PLANT, UNITS 1 & 2 SAFETY EVALUATION REPORT FOR EPPLOYEE CONCERN ELEMENT REPORT EN 210.2, " INADEQUATE i

EQ OF ELECTRICAL AND I&C" I. Subiect  !

Category: Engineering (EM?00) i Subcateacry: EQ Process (210)

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Element: Inadequate E0 Progran (210.2)

The basis for Element Report EN 210.2, Revision 2, dated February 2, 1987, is the followino employee concerns:

WI-85-100-005 XX-85-122-014 XX-85-122-015 XX-85-122-016

" Environmental qualification of electrical and I&C equiprent and components is inadequate. Cualification was often not done, or if it was done, records do not exist in many cases, which results in rodification or replacenent. Current upgrado CI program for environmental qualifications needs scrutiny.

has no further information. Anonyrous concern via letter."

i XX-85-094-013 "Sequoyah: It is the quality problems regarding environrental  ;

qualification of comporents per NUREG 0588 that made the Sequcyah plant shutdown. CI has no specifics or hardware details."

HI-85-077-N13 e

"NRC identified the following concern from review of the QTC file: ' Inadequate environmental cualification/docurentaticns.'"

OE-QMS-4

" Individual had information that might be helpful in the equipment qualification effort."

II. Summary of Issue The issue defined by TVA is: .

- l A. The environmental qualification (EQ) progran at Sequoyah is iradequate.

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Not all required equipment was qualified.

B.

C. Qualification records do not exist or are inadequate in many Cases.

D. Current upgrade program for EQ needs scrutiny.

i III. Evaluation TVA pcrsornel determined that the ccncerns with the E0 program were valid;e however, the Saquoyah EQ program had been determined to be inadequate by TVA management reviews independert of and prior to the filing of thase The inadequate program was documented in WESTEC/TVA report concerns.

entitled "Panagement Review of Environmental Qualification25, Activities 1985. and Documentation for Compliance with 10 CFR 50.49," dated Septenber ,

As a result of the findirgs, Sequoyah was shutdown on August Pi-22, 1985, l and an extensive new E0 program was implemented at Sequoyah to ensure This ,

nualification of all equipment within the scope of 10 CFR 50.49.

program will be completed prior to restart of the plant.

TVA has also addressed these concerns in Nuclear. Safety Review Staff (NS Report 1-85-225-50N, " Environmental 12, 1986, and Qualification / Electrical /IEC Equipment /

drew the tame conclusions that the Components," dated March The NSRS report concluded that the corrective  ;

WESTEC/TVA report did. ['

actions listed in the report, as agumented by the new E0 program described in the SQN Nuclear Performance Plan, should be sufficient to resolve these concerns.

The element report further acknowledged that there were outstanding items to be completed in the EQ program; however, it concluded that once the EQ program was complete these EQ program concerns would be adequately re The report determined that a 1cng term EQ program has been established to provide continued support in these arees to Sequoyeh and other TVA opere units.

IV. Conclusions The NRC staff believes that the TVA investigation of the concerns was adequate, and their resolution of the concerns as described in Element The NRC has conducted Report EN 210.2, Revision 2, is acceptable.

inspections of the Sequoyah E0 procram January 6-17, February 10-14, June :'3-27, and December 8-12, 1986, and a final inspec+ ion of the program is scheduled prior to Unit 2 restart. Although deficiencies were found during the inspections, TVA has corrected the deficiencies orSequoyah will have

them corrected prior to restart. Subject to completion of the EQ pregram by,TVA and certification that Sequoyah is in compliance with -

10 CFR 50.49, the staff believes that the Sequoyah EQ program will satisfactory resolution cf this issue.

impact on these conclusions have not been fully evaluated.

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i SEQUOYAH NUCLEAR POWER PLANT, UNITS 182 SAFETY EVALUATION REPORT FOR EMPLOYEE CONCERNS ELEMENT REPORT EN 215.1, " SEISMIC CRITERIA "

I. Subiect Cateoory: Engineering Subcategory: Civil / Structural Design Element: Seismic Criteria (EN 215.1)

Employee Concern: 00-85-005-009 The basis for Element Report EN 215.1 dated 9-26-86 is Sequoyah Employee Concern 00-85-005--009 which states:

"Seouoyah Nuclear Plant (SON) is sited on an earthquake fault that runs from around Chattanooga to North of Knoxville. If there were an earthquake, power plant structures could fail.

This concern was evaluated by TVA, and was categorized as not requirine resolution before SQN restart.

II Sumary of Issue The problem defined by the concerned individual lands itself tc two primary issues:

1. SQN is on a earthquake fault that runs from Chattanooga to North of Knoxville. 1

2. Plant structures could fail in an earthquake.

III Evaluation 1

TVA, as a result of its evaluation of the concern concludes that the I resolution of the concern should not be a prerequisite for restart of i SQN. TVA contends that based on TVA's geological and seismicity investi-gations presented in FSAR Section 2.5, and review and acceptance of the investigation results in SER Section 2.5, the issues are not SON restart issues. The evaluation, furthermore, adds, "both the above documents indicate that although the site is adjacent to the Fingston Thrust fault and a major overturned anticline, no geological evidence indicates that any of these features are active (earthquakei faults. Also, the TVA evaluation cites TVA Investigation Report 1-86-110-SON dated March 5, 1986, which concludes that:

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1. "The SQN is not located directly on the earthquake fault. (

2. The Seismic analysis perfomed by TVA and accepted by the NRC f concludes that adequate design margins exist for all critical components and structures to withstand the anticipated earth- ,

quake loads without losing their capability to perfom their i required safety function." j IV Conclusion l

The submittal by TVA in the FSAR Section 2.5, evaluation by the staff in Section 2.5.3. of the Safety Evaluation Report (NUREG-00111, and recent investigation by TVA (as cited under IU , " Evaluation"), point to the l fact that Sequoyah Plant is not located in the area of active earthquake

fault. The seismic design bases for the plant are determined following the procedures set fourth in Appendix A to 10 CFR Part 100. We believe that the seismic design bases used for design and construction of the plant structures and components are adequate, and we conclude that the consideration of an earthquake fault is not a matter of concern for restart of the Sequoyah plant.

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i SEQUOYA5i NUCLEAR POWER PLANT, UNITS 1 AND ?

SAFETY EVALUATION REPORT F0D FMPLOYEE CONCERNS t-ELEMENT REPORT EN ?15.10 "FEEDWATER HEATER MONORAIL DESIGN" k

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1. SUBJECT l

Category: Engineering Subcategory: Civil / Structural Design Feedwater Heater Monorail Design (EN 215.10)

I I Element:

Concern: LDA-85-001 I The basis for Element Report EN 715.10, dated 9/10/86 is Sequoyah Emplovee 1 Concern LDA-85-001 which states  !

" Structural integrity of the feedwater heater monorail hangers" l i

II.

SUMMARY

OF ISSUE I' The concern addressed by the individual relates to the structural integrity i of feedwater heater monorail hanger. It is ireplied that the monorail may i not be able to handle the load it may be required to carry. i l

III. EVALUATION t TVA has reviewed the concern and established that the monorail in question is located in the turbine building which is not categorized as Category I .'

structure. The handling equipment Based such as monorails and hoists are also on the evaluation, TVA has contended :

classified as non-safety items. l that this was not a plant safety concern, and thus, not a SQN restart issue. ,

However, as a general approach, TVA plans to review the drawings and load capacity of the monorail iri question.

IV. CONCLUSION .

The FSAR Section 3.2, " Classification of Structures, Systems and Compo- ,

nents" does not list the Turbine building, or the feedwater heaters 'that the i monorail is required to hoist as Seismic Category I. Thus, based on the l -

f licensing documents and licensee's assertion as to the non-safety classi- -

fication of the structure in which the monorail is located, the monorail  !

itself, and the equipment it is reovired to handle; the staff agrees with i licensee's contention that resolution of the concern need not be a  ;

prerequisite for restart of the plant. Furthemore, because of its ~

non-safety classification, the feedwater monorail and its attachments are outside the purview of the NPC.

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DRAFT SEQUOYAH NUCLEAR POWER PLANT, UNITS 1 AND 2 SAFETY EVALUATION REPORT FOR EMPLOYEE CONCERNS ELEMENT REPORT MC-40301-SQN " VALVE SUBSTITUTION AS RELATED TO MATERIAL CONTROL"

1. Subject Category: Materials Control (40000)

Subcategory: Installation (40300)

Element: Valve Substitution as Related to Material Control (40301)

Employee Concern: EX-85-181-001 The basis for Element Report MC-40301-SQN, Revision 2, dated October 31, 1986, is Employee Concern EX-85-181-001 which states:

"On valve inspection (Test 70), Quality Control (QC) verifies the proper valve by the mark number tag which is installed by the warehouse or vendor and is often just a paper or metal tag wiich can be removed or replaced by anyone. If the valve has been substituted from what the drawing lists, the bill of materials does not properly reflect the change. No paperwork is provided to Watts Bar engineering to document that it is an acceptable replacement. Many substitutes have come from Hartsville, Phipps Bend, and Yellow Creek are a different type than what the drawing calls for. Check Unit 2. R1, Steam Generator Blowdown System, as an example."

The portion of the above quote that is generically responded to by the Element Report is the segment of the quote as follows: "If the valve has ... is an acceptable replac..nent." The remainder of the concern is addressed in Material Control Subcatagories, Purchasing and Requisitioning (MC-40200) and Material Identification (MC-40500), as stated by this Element Report.

This segment of the concern was evaluated by TVA as potentially nuclear safety-related and potentially generic to Sequoyah.

II. Sumary of Issue The issue defined by TVA is that valves may have been substituted from what the drawing requires without documenting the substitution, and the bills of materials were not revised to show the change.

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2 III. Evaluation TVA personnel interviewed personnel involved with valve installation during the construction phase at SQN, reviewed construction procedures related to valve installation, reviewed a sample of the 47W drawings, and reviewed construction valve documentation for 200 valves to determine if valve substitution was a standard practical SQN during construction. )

i The TVA evaluation concluded that during the construction phase of SQN, the i valve installation program maintained adequate control of valve substitu-tions.

The NRC inspector interviewed the Employee Concern Task Group (ECTG) investigator who wrote the Element Report on January 7,1987. The NRC 1 inspector reviewed the ECTG documentation package which was collected during the TVA investigation. A pertinent fact, that was not clearly pointed out in the Element Report, is that the Watts Bar valve installation program is different from the program at Sequoyah. The program at Sequoyah is simpler and the means of valve installation verification is more definitive.

The NRC inspector cross-checked the conclusion of the Report by inspecting a sample of safety-related valves and verified them to be as indicated on plant drawings, and by checking the output of several programs which were performed by independent TVA groups or contractors which could indicate improper valve substitutions. No indications refuted the Report findings.

IV. Conclusions The NRC staff believes that the TVA investigation of the portion of the concern addressed in the subject report was adequate, e.nd that their resolution of the concern as described in Element Report MC-40301-SQN, Revision 2, is acceptable.

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DRAFT SEQUOYAH NUCLEAR POWER PLANT, UNITS 1 AND 2 SAFETY EVALUATION REPORT FOR EMPLOYEE CONCERNS ELEMENT REPORT MC-40302-SQN " VALVE (CRACKED)

AS RELATED TO MATERIAL CONTROL" i I. Subject Category: Materials Control (40000)

J Subcategory: Installation (40300)

Element: Valve (Cracked) as Related to Material Control (40302)

Employee Concern: PH-85-035-002 The basis for Element Report MC-40302-SQN, Revision 4, dated December 5

-1986, is Watts Bar Employee Concern PH-85-035-002 which states:

"The 3" SS valve located on the top of the pressurizer in Unit 1/ system 68 has a lamination crack running through the valve body into the weld zone on weld upstream from valve."

This concern was evaluated by TVA as potentially nuclear safety-related and potentially applicable to Sequoyah.

1 II. Summary of Issue l

The perceived problem that this report addresses is-that one of the 3-inch valves in the top of the Unit 2 pressurizer at Sequoyah (SQN) was previously installed in the same area in Unit I at Watts Bar Nuclear (WBN), and_14at one of these valves at WBN is alleged to have a crack or lamination in the valve body that runs into the weld area. The subject valve was identified during the evaluation at WBN to be serial number 1983-3, manufactured by I Target Rock Corporation.

III. Evaluation TVA personnel visually examined spare valve (Serial Number 1985-10) for cracks or laminations and none were found. This valve was then placed in service replacing the subject valve (Serial Number 1983-3). The subject valve received a visual inspection of the interior and exterior of the valve body by a TVA nondestructive examination (NDE) Level II inspector. No indications of cracks or laminations were found in the weld areas. However, there was an elliptical shaped indication on the interior surface of the outlet side of the valve body adjacent to the indicator tube. This was l

further evaluated by a Level III NUE inspector and determined not to be a crack, but the specific nature of the indication and the valve's suitability for service was not determined by this inspection (note: this valve was no r - + e y g- e----; . - - - + + e-- , - - - - - - , - - - w a %. . - - - - - - -- y --s- --------m-, ~-- ---w,-,w - - m cy + - ,

2 longerinstalled). The indication identified was also present in the valves that were examined at WBN. The indications in the valves at WBN were evaluated and determined to be inherent to the manufacturing process and not detrimental to the safe operation of the valves. The inspections performed by TVA were documented on work requests.

The TVA evaluation concluded that the indication found in the valve is not in the weld area as stated in the perceived problem, and this indication is inherent of the manufacturing process for these valves and not a crack or lamination. Therefore the concern is not valid. The TVA evaluation also concluded that there was no criterion to determine the acceptability of this particular value for use, and this needed to be addressed by line manage-ment.

The NRC inspector contacted the Employee Concerns Task Group (ECTG) about the concern. The ECTG stated that the spare valve (serial 1985-10) installed in Unit 2 at Sequoyah had no such indication from the manufac-turing process due to the fact that Target Rock had changed its process in the two-year span separating the valves' construction. Target Rock repre-sentatives had inspected the subject valves at the site. ECTG personnel had also been present during the valve inspections. Target Rock is providing a letter regarding the possible presence of the indications, which will become a part of the purchase order specification for future receipt inspections of procured valves of the subject valves' type. ,

IV. Conclusions The NRC staff believes that TVA investigation of the concern was adequate I

and their resolution of the concern as described in Element Report MC-40302-SQN, Revision 4, is acceptable. ,

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l DRAFT SEQUOYAH NUCLEAR POWER PLANT, UNITS 1 AND 2 SAFETY EVALUATION REPORT FOR EMPLOYEE CONCERNS ELEMENT REPORT MC-40307-SQN " SCRAPPED MATERIAL AS RELATED TO MATERIAL CONTROL" I. Subject Category: Materials Control (40000)

Subcategory: Installation (40300)

Element: Scrapped Material as Related to Material Control (40307)

Employee Concern: SQP-5-004-003 Part of the basis for Element Report MC-40307-SQN, Revision 2, dated October 31, 1986, is Employee Concern SQP-5-004-003 which states:

"SEQUOYAH: New material has been ordered scrapped by a supervisor and later retrieved by a different group. This could represent a lack of control regarding scrapped material."

The Nuclear Safety Review Staff (NSRS) obtained additional information from the Employee Response Team follow-up group, which further specified the concern to be that the concerned individual (CI) had noticed new fittings still in the manufacturer's plastic bags, in a garbage pile next to a warehouse in November 1985. These fittings were picked up by someone from another plant organization the following week. The CI assumes that the fittings were later used somewhere in the plant but is unsure what happened to these fittings after they were picked up/ retrieved from the garbage pile.

Additionally, the Element Report identified five Watts Bar concerns which were made generic to Sequoyah; the concerns were IN-85-291-001, IN-85-339-002, IN-85-624-003, PH-85-003-009, and WI-85-091-014. The report summarized the combined concerns (SQN and WBN) as follows:

"The perceived problem, as stated in the concerns that this report addresses, is that material tha,t had been scrapped was retrieved from the scrap pile and used in permanent plant installations."

These concerns were evaluated by TVA as potentially nuclear safety-related and both potentially and specifically applicable to Sequoyah.

II. Sumary of Issue The problem defined by TVA is summarily stated in the last quote above. The specific Watts Bar material (from WBN concern descriptions) supposedly used af ter being scrapped, included: general scr.sp, valves, snubbers, pipe, and hanger material. The specific Sequoyah concern is stated above. In all of the concerns, no specific end use was identified for the scrap material.  !

The scrap material was not identified as being safety-related. j l

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The use of non-safety-related material in a safety-related application, the use of safety-related material in the wrong application, and the use of  ;

safety-related material that had degraded in improper storage would be the primary regulatory considerations. Due to the Watts Bar concerns which were made generic to Sequoyah, the time frame for consideration in the Element Report was assumed from construction to the time of the investigation (1986).

III. Evaluation The'Sequoyah specific concern (SQP-5-004-003) was addressed by NSRS Report I-86-164-SQN as noted in the Element Report. The concern was recent enough that the actual events could be reconstructed. The scrapped material was not utilized in the plant. The Element Report recognized that NSRS Report should have identified corrective action which was specified in the Element Report.

The Element Report identified that there were no procedural controls for scrap during the construction phase and that some problems exist in current procedures.

The Element Report appears to have adequately covered the area of concern for current site activities. The Employee Concern Task Group (ECTG) that generated the report utilized personnel observation, interviews, and program review to evaluate the concern. Via the site staff, ECTG obtained correc-4 tive action on programmatic scrap material problems. As stated in the report, these problem; had not caused scrap to be misused.

The Element Report utilized interviews as the means of evaluating scrap use during the construction period. With regard to interviews of TVA construc-tion personnel, the report states:

"During the construction phase of Sequoyah (SQN), material was on occasion scrapped by mistake, its traceability maintained, and therefore retrieved for installation at a later time. However, no spec'ific items could be identified."

The report did not state the number or types of personnel interviewed by ECTG.

The NRC staff met with the ECTG investigator on January 7,1987, to discuss i

the subject Element Report. The NRC inspector reviewed the supportive  ;

evaluation package for the report. The NRC inspector determined that misuse '

of scrap material during the construction period was probably the most difficult part of the concern to resolve, and aside from destructive ,

sampling or nondestructive sampling of material, the interview method was I the most useful tool available.

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. 3 From the discussion with the ECTG investigator and review of support documentation, the NRC inspector determined more information on the ECTG interviews with TVA personnel regarding scrap use during plant construction.

The interview results appear satisfactory with the possible exception of the small number of TVA Quality Control (QC) inspectors interviewed. This over-sight appeared to be ore of personnel availability at the time of the ECTG evaluation. QC inspectors are, and were responsible for verification of material at installation. The ECTG investigator had interviewed mainly engineering staff who, under the TVA system, were responsible for material release.

The NRC inspector interviewed three additional construction period QC inspectors during January 8 and 9,1987, at Sequoyah. The QC inspectors interviewed corroborated the results of the Element Report. Two were emphatic about scrap not being used and the third could not remember any specific misuse of scrap. Although there were no procedures during construction regarding reuse of scrap, the QC inspectors stated that it was and is, common knowledge as to what is required for safety-related installa-tions.

IV. Conclusion The NRC staff believes that TVA investigation of the concern was adequate and that their resoluticn of the concern as described in Element Report MC-40307-SQN, Revision 2, is acceptable.

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DRAFT SEQUOYAH NUCLEAR POWER PLANT, UNITS 1 AND 2 SAFETY EVALUATION REPORT FOR EMPLOYEE CONCERNS ELEMENT REPORT MC-40705-SQN " QUALITY RECEIVING UNIT"

1. Subject Category: Materials Control (40000)

Subcategory: Procedural Control (40700)

Element: Quality Receiving Unit (40705)

Employee Concern: XX-85-027-X02 The basis for Element Report MC-40705-SQN, Revision 1, dated October 31, 1986, is Sequoyah Employee Concern XX-85-027-X02 which states:

" Material inspectors were not allowed to validate heat numbers of structural steel received onsite as required by procedure [;] heat No.

7438383 is an example."

This concern was evaluated by TVA as potentially nuclear safety-related, and only relevant to Sequoyah.

II. Summary of Issue The issue defined by TVA is that the concerned individual (CI) who had been a quality control (QC) inspector felt that during the construction period, there was impedance in the inspection process with regard to heat number validation of structural steel. The Element Report addresses the impedance issue, but does indicate other areas of concern which resulted from or paralleled this concern (and other concerns by this CI). A harassment issue regarding the CI is being handled by the TVA Inspector General Office by concern number HI-85-005-001. Heat number programatic traceability problems are being addressed by concern number MC-40703-SQN.

III. Evaluation Although seemingly extraneous information appears in the text of the Element Report, the thrust of the report is the interviews with QC inspectors by the Employee Concerns Task Group (ECTG). The NRC staff discussed the details of the report with the ECTG investigators and supervision on January 15, 1987. Some of the seemingly extraneous information was an attempt to point out oddities in the Employee Response Team (QTC) Report (XX-85-027-X02) in the concern area, and with other information pointing out the margins between the impedance concern and the heat number issue of Element Report MC-40703-SQN.

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2 The ECTG investigators interviewed at least ten QC inspectors on possible impedance during performance of heat number validation. This interview methodology is considered by the NRC staff to be the primary means relevant information was obtained regarding the concern. The parametric boundaries I of the questions asked by the ECTG of the interviewees should have discerned any impedance problems on the part of the QC inspectors. The ECTG (and the report) indicated that no inspector had problems validating heat numbers.

As stated by the ECTG, the QC inspectors' only difficulty was with the procedures involved in the validation process which is not mentioned in the subject Element Report but was stated by the ECTG to be programmatically addressed in MC-40703-SQN. During the discussion with the ECTG on January 15, 1986, ECTG supervision indicated that they would probably change Element Report MC-40705-SQN to point out the procedural problems and the fact that these problems are addressed in MC-40703-SQN.

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 MC-40705, Revision 1, is acceptable. Although the difficult language of the report and side issues identified in the report required some clarification between the NRC and the ECTG and required a working knowledge of the applicable inspection process, the results of the interviews (the ECTG with the TVA QC inspectors) support acceptance of the report. Any additional clarifica-tion of the report by the ECTG should only aid in the readability of the report and not affect its conclusions.

i Attachment I t SEQUOYAH NUCLEAR POWER PLANT, UNITS 1 AND 2 SAFETY EVALUATION REPORT FOR EMPLOYEE CONCERNS ELEMENT REPORT WP-04-SON, R2 I. Sub.iect Cateoory: WELDING Subcateoory: 50700 Element: WP-04-SQN The basis for Element Report WP-04-SQN, Rev. 2, dated 11/21/86 forwarded by TVA letter dated December 1,1986 are the Watts Bar Employee Concerns as follows:

EMPLOYEE CONCERN NO. DESCRIPTION IN85-406-003 No inspection tools IN85-134-002 No tools IN 85-007-001 No tools These concerns were evaluated by TVA as potentially safety-related and potentially applicable to Sequoyah (generic). This formatted SER is being provided to link individual employee concerns and TVA Element Reports to our draft SER forwarded by BWEB memorandum of October 30, 1986.

II. Summarv of Issue The issue involved with these three employee concerns is summarized by TVA as, " Welding inspection tools were not issued to welding inspectors."

III. Evaluation TVA established the Welding Proiect to formulate a procram for each nuclear plant site to address the employee concerns related to welding.

Many of the concerns which originated at the Watts Bar Nuclear Plant were determined by TVA as possibly being generic, and therefore applicable to all of the TVA nuclear plant sites.

For the Sequoyah site, the TVA program is divided into two phases. Phase 1 is a review of the records to determine if there are any problem indicctors. Phase 2 is a physical reinspection of weldments whose samples and the specimens representing the samples are selected on an engineering and logic basis. The NPC staff also perforned an independent physical reinspection of weldments at the Sequoyah site.

2 The results of the TVA and the NRC reinspections tend to support these concerns for structural welds made to Alls Pl.1 in that a sianificant percentage of the welds were undersized. These results indicate that the weld size may not have been physically measured with toolt in all cases during inspections, but instead were estimated by eye using ad.iacent base metal thicknesses as a guide. This inspection practice was prevalent for these types of structures in the industry during the time frame of Seouoyah's construction. All of the components containing these deficiencies were found by analysis to have met the applicable Code stress requirements and were satisfactory for service as is without weld repair.

IV. CONCLtlSION

, jsjove-W 1%

The conclusion was stated /in the BNL TER which was incorporated as part of our draft SER dated Oct&r 't,1986. In sunnary, the staff concludes that the utility perfomed an adequate investigation with respect to these concerns in that it demonstrated that weld inspection tools had been issued to weld inspectors. However, it was not demonstrated that all weld inspectors had the necessary tools. The TVA and NRC reinspections of welded components demorstrated that the impact on hardware by this programmatic deficiency where some weld inspectors did not have weld inspection tools was minimal.

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