ML20209E290
| ML20209E290 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 01/27/1987 |
| From: | Knightly J TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20209B481 | List: |
| References | |
| SWEC-SQN-06, SWEC-SQN-06-R02, SWEC-SQN-6, SWEC-SQN-6-R2, NUDOCS 8702040626 | |
| Download: ML20209E290 (6) | |
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TVA EMPLOYEE CONCERNS REPORT NUNBER: SWEC-SQN-06 SPECIAL PROGRAN REPORT TYPE: Sequoyah Nuclear Plant Element REVISION NUMBER: 2 TITLE: Piping Design Analysis REASON FOR REVISION: To incorporate TAS and SRP coraments SWEC
SUMMARY
STATEMENT: The items in this report were identified by the Nuclear Regulatory Commission (NRC) and were included in the Stone & Webster Engineering Corporation (SWEC) systematic analysis. All items evaluated within this report were verified to be adequately addressed or are being tracked under ECTG Engineering Category corrective actions.
PREPARATION PREPARED BY:
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TENNESSEE VAI.I.EY AUTHORITY WATTS BAR NUCLEAR PLANT EMPLOYEE CONCERNS TASK GROUP OTHER SITES CEG Element
Title:
Piping Design Analysis SWEC Concerns: A02841023002-001, -002, -003, -004 Source Document:
NRC Inspection Report 50-327/84-23 and 50-328/84-24 Report Number:
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F RIpert SWEC-SQN-06 NRC Reports 50-390/84-70, 50-327/84-23 and 50-328/84-24 I.
INTRODUCTION During an Nuclear Regulatory Commission (NRC) inspection (reference 1) of September 4-7, 1984, in the area of piping design analysis, NRC identified one violation and three areas of concern which were included in the Stone & Webster Engineering Corporation (SWEC) systematic analysis:
A.
A02841023002-001, Piping Design Analysis Problems not corrected timely & documented.
e B.
A02841023002-002, Final Safety Analysis Report (FSAR) change not submitted after design change.
C.
A02841023002-003, Procedure Inadequate to Assure Seismic Design Valid for Operations.
D.
A02841023002-004, Untimely Resolution of Pipe Stress Problems.
i Information on the background, the corrective actions taken, the verification methodology and analysis, the completion status, and any pertinent references for these' items are included in this report.
II.
VERIFICATION OF SWEC ISSUES A.
A02841023002-001, -002, -003
-004, Piping Design Analysis
===1.
Background===
At the time of the 1984 NRC violation and concerns in the area of piping design analysis, it had been recognized by TVA that some piping analysis documentation was incomplete. SQN nonconformance report CEB 8205 dated May 5, 1982, had recorded the fact that operating condition input data for the piping analysis was not fully documented and controlled. TVA stated (reference 2) in their response to the NRC violation that the SQN operational modes data had been generated and. incorporated into design; that new data would be controlled; that SQN piping systems were considered qualified in that no known instances of invalid data had been identified; and that the operating sampling program at the similarly designed Watts Bar Plant had demonstrated the qualification of the piping systems. However, the NRC violation was not closed, and the overall piping design analysis issue has remained as an NRC open item to this date (Violations 327/84-23-01 and 328/84-24-01).
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2.
Cerrectiva Actiens Tektn The TVA program of corrective actions for piping design analysis and evaluation is now receiving a high level of management commitment.. The Sequoyah Nuclear Performance Plan which was i
submitted to the NRC July 1986, outlines the extensive program of analysis and evaluations which will result in issuance of all i
piping boundary calculation packages before restart, with each calculation package documented in a data base. After restart, a phase II program will extend the analysis and evaluations to other safety class piping not required for restart. The overall purpose of this program is to ensure that design requirements are satisfied and that documentation is completed.
SQN action list items 184, 185, 186, 187, and 188 (reference 3) describe the broad components of the alternate analysis review program. This program has been analyzed in detail in the ECTG Report 218.4(B) " Pipe Stress Calculations." Program adequacy was substantiated subject to (1) all program commitments being documented in program procedures, and (2) NRC acceptance of scheduling. These items are tracked under CATD Number 21804-SQN-01.
4 The overall summary of actions for the alternate analysis review program is stated as follows (reference 3):
When phase I of this program is complete, potential significant discrepancies will have been resolved and confidence will be established that operability of safe shutdown and mitigation systems (TVA class B, C, D, and N) are not adversely affected and that piping and supports are adequate for restart.
If in the course of performing evaluations or walkdowns, other specific discrepancies are noted which would adversely affect the operability of safe shutdown and mitigation systems, they will be calculation packages as part of this program.
Confidence will be established that analysis has been conducted on piping required for restart. Modifications will l
be made if required before restart.
If potential discrepancies evaluated in phase I are determined in the evaluation process to not be an immediate threat to i
safe operation, then the evaluation of that discrepancy may be moved to phase II.
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Y 3.
Varificcticn Mithrdslegy The SWEC concerns identified for Employee Concerns Task Group (ECTG) verification were stated as follow:
RIMS Number Issue RIMS Item A02841023002 Inadequate measures by TVA to assure RIMS-001 conditions adverse to quality in piping design analysis were corrected in a timely manner and documented properly.
A02841023002 Licensee failed to submit change to FSAR RIMS-002 when design change occurred as required.
A02841023002 Licensee fails to have adequate procedure RIMS-003 written to provide assurance that thermal and seismic design basis " source" data analysis is valid for current operating conditions.
A02841023002 Plan to correct pipe stress input problems RIMS-004 was to resolve a similar issue at Watts Bar before promptly correcting the problems at operating Sequoyah.
ECTG reviewed the Sequoyah Compliance Licensing files for internal and external correspondence related to this issue, the TVA Nuclear Performance Plan, and the ECTG engineering category reports concerning piping design analysis. This review of the pertinent documentation formed the basis for this verification activity.
4.
Verification Analysis The ECTG review of the pertinent documentation indicated that the piping design analysis program is progressing as noted under
" Corrective Actions Taken," (II.A.2).
The SWEC issue (RIMS
-002) involving the processing of a FSAR change will be handled as part of the SQN performance plan in ensuring design documentation is complete.
Similarly, the priority for correcting the pipe stress problem (RIMS -004) is now Sequoyah versus Watts Bar as prioritized by the issuance scheme of the performance plans (Sequoyah is volume II while Watts Bar is l
Volume IV).
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5.
Completion Status Based on SQN actions, evidence of SQN management commitment, and ECTG verification, documented in report 218.4(B) corrective action on the SWEC issues is assessed to be progressing satisfactorily. Corrective actions are tracked under Engineering Category CATD Number 21804-SQN-01. These SWEC items are closed.
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' III. REFERENCES 1.
NRC Inspection Report Nos. 50-390/84-70, SV-327/84-23 and l
50-328/84-24, dated October 19, 1984, from R. C. Lewis to H. G. Parris 2.
TVA letter, "Sequoyah Nuclear Plant Units 1 and 2-NRC-01E Region II Inspection Report 50-390/84-70, 50-327/84-23, and i
50-328/84-24-Response to Violation," dated November 20, 1984, from J. A. Domer to J. R. O'Reilly 3.
TVA, Revised Sequoyah Nuclear Performance Plan, dated July 17, 1986 lR2 4
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