ML20210G116
| ML20210G116 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 02/02/1987 |
| From: | Damon D, Stewart D, Violette J TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20210F779 | List: |
| References | |
| 210.2(B), 210.2(B)-R02, 210.2(B)-R2, NUDOCS 8702110223 | |
| Download: ML20210G116 (19) | |
Text
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TVA EMPLOYEE CONCERNS' REPORT NUMBER: 210.2(B)
SPECIAL PROGRAM REPORT TYPE:
SEQUOYAH ELEMENT REVISION NUMBER:
2 TITLE:
ENVIR041 ENTAL QUALIFICATION Inadequate EQ of Electrical and 18C PAGE 1 0F 19 REASON FOR REVISI6N:
1.
Revised to incorporate SRP and TAS comments, NRC testimony, and EQ program development since submittal of Rev. 0; to comply with current format; and to add Section 10, Corrective Action.
2.
Revised to incorporate TVA comments of 01/20/87.
PREPARATION PREPARED BY:
Okn ihdn SIGNATURE
' DATE REVIEW 5 7
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SIGNATURE DATE CONCURRENCE 5 M&dA i/uh7 CEG-H:
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/-L f7 SRP R/M _2-2-37 SIGNATURE DATE g
SIGNATURf g DATE APPROVED BY:
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$ $ b' ECSP ~ MANAGEg/ '
IE' MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)
- SRP Secretary's signature denotes SRP concurrences are in files.
8702110223 870205 DR ADOCK 05000327 PDR I
TVA EMPLOYEE CONCERNS REPORT NUMBER:
210.2(B)
SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 2 0F 19 1.
CHARACTERIZATION OF ISSUE (S):
Concerns:
Issues:
WI-85-100-005 a.
The environmental qualification (EQ)
XX-85-122-014 program at Sequoyah is inadequate.
XX-85-122-015 XX-85-122-016 b.
Not all required equipment was qualified.
" Environmental qualification of electrical and 18C equipment and c.
Qualification records do not exist components is inadequate.
or are inadequate in many cases.
Qualification was of ten not done, or if it was done, records do not d.
Current upgrade program for EQ needs exist in many cases, which results scrutiny.
in modification or replacement.
Current upgrade program for environmental qualifications needs scrutiny.
CI has no further infonnation.
Anonymous concern via letter."
XX-85-094-013 "Sequoyah:
It is the quality problems regarding environmental qualification of components per HU REG 0588 that made the Sequoyah plant shut down.
CI has no specifics or hardware details."
HI-85-077-N13 "NRC identified the following concern from review of the QTC l
file:
' Inadequate environmental quali fication/documentations. ' "
OE-OtS-4
" Individual had information that might be helpful in the equipment qualification effort."
2.
HAVE ISSUE (S) DEEN IDENTIFIES IN ANOTHER SYSTEMATIC ANALYSIS? YES X NO Identified by WesTec Services /TVA, Management Review NSRS Report I-05-225-5GN Date 09/25/B5 and 03/12/86 1001d (01/?6/87) n
TVA EMPLOYEE CONCERNS REPORT NUMBER:
210.2(B )
SPECIAL PROGRAM REVISION NUMBER:
2 PAGE 3 0F 19 Documentation Identifiers:
"tianagement Review of Environmental Qualification Activities and Documentation for Compliance with 10CFR50.49" NSRS Investigation Report I-85-225-SQN, " Environmental Oualification/ Electrical /I&C Equipment / Components" 3.
DOCUMENT NOS., TAG NOS., LOCATIONS OR OTHER SPECIFIC DESCRIPTIVE IDENTIFICATIONS STATED IN ELEMENT:
None 4.
INTERVIEW FILES REVIEWED:
The following expurgated and working interv'few files were reviewed:
WI-85-100 XX-85-122 HI-85-077 XX-85-094 OE-01S-4 l
Review of the HI-85-077 interview file disclosed the' following statements and expansion of the concern:
"The equipment was bought outside the warehouse essentially off the shelf, brought into the warehouse and transferred around maybe from one warehouse to another. When it comes out of the warehouse it goes to 6ne of the nuclear plants in one of the safety related systems as qualified 1-E, class 1-E equipment."
"The equipment can not be tested at the warehouse and certified by TVA because it has to be tested by an independent lab or manufacturer.
There's a lon process of testing to prove the equipment is class 1-E.g' Both of these statements suggest plausible methods and practices that resulted in the overall effects identified in Issues a and b in Section 1.
While they substantiate the authenticity of these issues, they do not expand their scope. Review of the OE-QIS-4 interview file revealed a handwritten telecon indicating the concern was " Basically resolved and may be considered closed." The reasons given were a completed SQN audit, an ongoing (on 04/03/86)
WBN audit, and the observation that the " original concern centered around the radio equipment [ system] used to warn WBN and SQN of 1001d (01/26/87) a
TVA EWLOYEE CONCERNS REPORT NUMER:
210.2(B)
SPECIAL PROGRAM REVISION NUMER: 2 PAGE 4 0F 19 failure of Fontana Dam and is being tracked by a SCR."
Review of l
the other files noted above developed no further infonnation than that already noted in the concerns or in NSRS Investigative Report I-85-225-SQN (App. A, 5.a).
l S.
DOCUMENTS REVIEWED RELATED TO THE ELEMENT:
See Appendix A.
6.
WiAT REGULATIONS. LICENSING COM4ITMENTS DESIGN REQUIREMENTS OR OTHER APPLY OR CONTROL IN THIS AREA 7 See Appendix A.
7.
LIST REQUESTS FOR INFORMATION, MEETINGS, TELEPHONE CALLS, AND OTHER DISCUSSIONS RELATED TO ELEMENT.
See Appendix A.
8.
EVALUATION PROCESS; a.
Reviewed available transcripts of NRC investigative interviews for additional information regarding these Concern s.
b.
Reviewed the TVA docunentation regarding Sequoyah compliance with 10CRF50.49, NUREG 0588, and Regulatory Guide 1.89.
" Assessed the adequacy of Investigative Report I-85-225-SQN in c.
response to these concerns and NRC compliance statements, d.
Assessed the results of the WesTec/TVA program on compliance with these regulatory requirements.
Sampled docunentation on environmental qualification to e.
assess the environmental qualification programs presently in place.
9.
DISCUSSION, FINDINGS, AND CONCLUSIONS:
Chronology:
l 11/77:
Union of Concerned Scientists petitions NRC 1001d (01/26/87)
I
TVA EMPLOYEE CONCERNS REPORT NUMBER:
210.2(B)
SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 5 0F 19 11/79:
NRC issues Division of Operating Reactors (DOR) EQ Guidelines 12/79:
NRC issues NUREG 0588 01 /8 0:
NRC issues IEB 79-018 05/80:
NRC issues Commission Legal Index (CLI)-80-21 04/85:
SQN EQ Program determined. inadequate by TVA Management 08/85:
SQN shut down for EQ reasons l
12/85:
Concerns XX-85-122-014, XX-85-122-015, XX-85-122-016, and WI-85-100-005 filed with TVA/NSRS 01 /8 6:
Concern XX-85-094-013 filed with TVA l
02/86:
NRC Investigative Interview 03/86:
NSRS Investigative Report I-85-225-SQN validates concerns 07/86:
Concern HI-85-077-N13 filed with TVA 09/86:
NRC Draft Safety Evaluation Report on SQN EQP issued Discussion:
9.1 BACKGROUND
It is hparent from documentation associated with the TVA Environmental Qualifications Program (EQP) ( App. A, 5.d, 5.e, and 5.h) that substantial activity and corrective actions were in progress prior to the time the above concerns were filed.
To place these concerns in proper context to the present TVA EQ program, a historical perspective of the overall TVA EQ program and how it evolved into the present SQN program is helpful. The most cogent synopsis the evaluation team found was in Section 1. A.2 of the SNP Environmental Qualification Package SQNEQ-GEN-001 ( App. A, 5.c).
This is quoted below for the readers' convenience:
1001d (01/26/87)
R
TVA EMPLOYEE CONCERNS REPORT NUMBER:
210.2(B)
SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 6 0F 19 "A.2 TVA EQ History "In early 1980, with NRC's issuance of IE Bulletin 79-OlB and HUREG-0588, TVA reacted with an effort directed at satisfying the licensing issues associated with EQ and relatively little attention was directed toward developing an overall programmatic direction that would satisfy the operational maintenance, inspections, test and engineering documentation requirements over the life of the plant.
TVA developed a qualification plan and began to obtain qualified equipment.
However, the focus of TVA's efforts was to produce a licensing document, the Electrical Equipment Environmental Qualification Report (EEEQR) rather than to develop a sound engineering basis from which the licensing documents could be derived. There was no indication that operational requirements were considered as an integral part of the program.
"Throughout the early 1980s, there were several attempts to recognize the overall programmatic requirements associated with EQ, but progress suffered due to a general lack of understanding of the full implications of EQ. Also, the program was fragmented with no one in overall charge.
" Audits in both Engineering and Power cited programmatic deficiencies. These audits concluded that TVA's EQ efforts lacked programmatic direction
... and definition of interdivisional interfaces resulting in a fragmented program with poor overall coordination and communication.
" Subsequently, in the late 1983 to 1984 timeframe, substantial progress was achieved as management began i
to realize TVA had some problems.
EQ coordinator positions were established, first in NUC SVCS, then at the plant sites and in OE to provide a focal point for EQ. An effort was initiated to develop Qualification Maintenance Data Sheets to provide engineering requirements for the maintenance of the qualified status of equipment.
However, progress in the development of an overall integrated program was slow and there was still no single entity with overall responsibility for the program.
Also, it was l
questionable whether TVA's equipment qualification files were 'readily auditable' since the files were in several locations and filed under differing schemes.
1001d (01/26/87) r
TVA EWLOYEE CONCERNS REPORT NUMER:
210.2(B )
SPECIAL PROGRAM REVISION NUMER: 2 PAGE 7 0F 19 "There was a recognition that an upgrade and consolidation of the qualification files was needed, and proposed method was put forth for approval to proceed. Sequoyah Nuclear Plant had decided to l
proceed with the proposal in phases just prior to the Management Review that was begun on July 19, 1985.
"The Management Review produced several observations on the EQ activities for Browns Ferry, Sequoyah, and Watts Bar Nuclear Plants. These observations are delineated in reference 1. 'These observations were reviewed for their applicability to Sequoyah. The results of this assessment on Sequoyah are provided in references 2 and 3.
Reference 4 docunents the completion and updated status of activities associated with the observations for Sequoyah."
"A.3 Reference for Section I "1.
Memorandun from J. W. Hutton to J. P. Darling and H. L. Abercrombie dated September 26, 1985 (B70 850926 007).
"2.
Memorandun from R. A. Sessoms to J. W. Hutton, dated November 16, 1985 (870 851116 010).
"3.
Memorandun from H. L. Abercrombie to J. W. Hutton dated November 18, 1985 (S01 851118 829).
"4.
Memorandun from R. A. Sessoms to J. W. Hutton dated February 21, 1986 (870 860221 008)."
On August 21/22, 1985, TVA shut down the Sequoyah Nuclear plant and "as a result of the Management Review of IVAis Environmental Qualification Program, the Environmental Qualification Project was established and charged with the objective of developing an Environmental Qualification Docunentation Program to verify that all plant equipment covered under 10CFR50.49 is qualified for its application and meets its specified performance requirements when subjected to the conditions predicted to be present when it must perform its safety function up to the end of its qualified life."
(App. A, 5.c) l i
1001d (01/26/87)
TVA EMPLOYEE CONCERNS REPORT NUMBER:
210.2(B)
SPECIAL PROGRAM REVISION NUMBER:
2 PAGE 10 0F 19 The testimony also suggests that equipment qualified for one application may have been used in another where its qualification parameters were inappropriate.
In such cases, the qualification paperwork will appear to be in place and in compliance with program requirements but the equipment could actually be unqualified because it was transferred for use in a different portion of the plant or to a different plant entirely.
This is an engineering matter within the scope of Issues a and b in Section 1 and is treated accordingly in Subsection 9.4 of this report as an additional concern.
9.3 REGULATORY REQUIREMENTS i
The Code of Federal Regulations, Title 10, Part 50, Section 49, (10CFR50.49) requires nuclear power Itcensees to establish a program for environmentally qualifying " electric equipment important to safety" located in harsh environments.
This equipment has been identified in 10CFR50.49 as:
o Safety-related electrical equipment (class lE) o Nonsafety-related electrical equipment (nonclass lE) whose failure under postulated environmental conditions could prevent satisfactory accomplishment of safety functions by safety-related equipment o
Certain postaccident monitoring equipment 10CFR50.49 also establishes environmental qualification methods and l
qualification parameters. 10CFR50.49 is implemented in more specific detail by NUREG 0588 and Regulatory Guide 1.89.
NUREG 0588, which applied to the Sequoyah Nuclear plant (S(h) and later plants, provides the basis for evaluating class lE electrical equipment. NUREG 0588 is divided into Categories I and II.
l Category I applies to plants committed to IEEE-323-1974, and Category II applies to plants committed to IEEE-323-1971 as established by the dates of their construction permits or operational safety evaluation reports. These and related IEEE Standards (e.g., IEEE STD 382 for valves, IEEE STD 334 for motors, IEEE STD 383 for cables, etc.) are endorsed by Regulatory Guide 1.89, which is used in conjunction with NUREG 0588.
l 100ld (01/26/87)
A
TVA EMPLOYEE CONCERNS REPORT NUMBER:
210.2(B)
SPECIAL PROGRM4 REVISION NIDIBER:
2 PAGE 8 0F 19 The employee concerns addressed herein were not filed until December 1985, 4 mnnths later. The employee concerns address the conditions that led to the shutdown and do not challenge the TVA EQ program that was put in place to correct the situation.
Nevertheless, the evaluation team reviewed the TVA EQP activities independently to ensure that the concerns raised were really addressed in the TVA EQ program.
9.2 NRC INVESTIGATIVE INTERVIEW On February 21, 1986, the NRC staff conducted an investigative interview of TVA personnel.
Portions of this interview covered subject matter relative to these concerns. -The interview transcript was forwarded to TVA on June 23, 1986, with a request that the concerns discussed therein be evaluated ( App. A, 5.s).
This transcript was reviewed by the evaluation team. The issue of equipment qualification is discussed on pages 89 through 99 of the NRC interview transcript. Salient portions of this transcript, which expand on the concerns listed in Section 1, are extracted and quoted below:
From Page 91 "TVA has bought a lot of equipment knowing full well that it needs to he qualified, but have made the judgment that they will qQilify later and they never do. They would take the responsioility for qualifying it.... In some cases they bought Ind stored it and drew out of those stored inventories.; making an assumption that it was okay to use it whether it was qualified or not.
In some cases they
...have attachdd paperwork to it after the fact, without doing any analysej or testing."
From Pages h3 and 94 "Some of the stuff that I looked at physically sitting out at Phipps Bend subsequently was moved to other sites.
Boxes of equipment sitting there for years that never had receipt inspection done on the quality of the equipment or whether it was even specific equipment ordered or the right equipment and it was never maintained during that period for any long-term storage requirements.... Some of it was not even verified as qualified.... It was just oftentime coupled with unqualified untraceable stuff and they mixed inventories and used it at will.... In many cases the qualification was done to one environment and then used at another environment."
1001d (01/26/87)
I
TVA EMPLOYEE CONCERNS REPORT NUMBER:
210.2(B)
SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 9 0F 19 From Page 98 "A standard way of doing business with TVA is to accept stuff and not necessarily look to see if what they got was acceptable.
If the vendor told them it was qualified, it was good enough for them.
.. this WesTec report which you probably have read concerning the TVA qualification, I had run into practically everything they said there including looking at equipment across the board.
I have seen it all and a lot more than what they stated in there.
I agree with it."
The statements from Page 98 of the NRC transcript indicate that the WesTec report, which initiated EQ activities resulting in the present program, was sufficiently thorough to gain the interviewee's agreement and acceptance.
The statements from Page 91 merely add more specific detail as to practices that are already covered by the more general scope of the concerns outlined in Section 1.
The statements from Pages 93 and 94, however, suggest two entirely new concerns: improper storage and misapplication of l
equipment that is otherwise properly qualified.
Although site storage is outside the scope of an engineering concern, the evaluation team felt that, since it came up in this investigation and since it could be covered within the scope of Issues a and b in Section 1, investigation and disposition in this report would not be unreasonable.
Improper storage of environmentally qualified equipment from cancelled sites (e.g.
Hartsville, Phipps Bend, Yellow Creek) that may have been used on operational units is addressed in Quality Assurance Deviation Peport PPS-A-86-001 ( App. A, 5.v).
This resulted in corrective l
actions in response to Significant Condition Report (SCR) No.
GENIRP 8601 ( App. A, 5.u).
Initially this SCR was thought to affect only storage facilities and was limited to the Hartsville, Phipps Bend, and Yellow Creek facilities ( App. A, 5.w).
It was subsequently determined that this issue was relevant to all nuclear projects and the SCR was revised to reflect applicability to Browns l
Ferry, Bellefonte, Watts Bar, and Sequoyah ( App. A, 5.x).
Reviews were conducted at the Hartsville and Yellow Creek distribution centers for equipment and materials transferred to SQN with the result that "The equipment and materials were determined to be acceptable or not affected by the SCR and, in all cases, it was determined not to be reportable to the NRC" ( App. A, 5.y).
The evaluation for equipment from Phipps Bend is in progress.
Closure of SCR GENIRP 8601 is presently scheduled for March 1987 ( App. A, 5.z).
This issue is therefore known and being resolved in accordance with TVA QA procedures. Further exploration does not seem necessary.
i 100ld (01/26/87) s
TVA EMPLOYEE CONCERNS REPORT Nt#EER:
210.2(B)
SPECIAL PROGRAM REVISION NUMBER:
2 PAGE 11 0F 19 Since much of the equipment to be qualified (e.g., cables) was installed prior to the publication of IEEE-323-1974 and related regulatory requirements, certain dispensation is allowed..In the SQN EQP, adherence to the most recent standards and guidance is attempted. 10CFR50.49 requires that replacement equipment be qualified in accordance with IEEE-323-1974 unless there are sound reasons to the contrary.
Requalification of SQN equipment previously qualified under NUREG 0588 ("for consnent" version) is not required.
9.4 EVALUATION RESULTS These specific concerns were addressed and validated in the 03/12/86 NSRS Report I-85-225-SQN ( App. A, 5.a).
This NSRS Report relied heavily on the report " Management Review of Environmental Cualification (EQ) Activities and Documentation for Compliance with 10CFR50.49," dated 09/25/85. This latter report was prepared by a team of WesTec Services, Incorporated, and TVA personnel who perfonned an overall review of TVA EQ activities and documentation to establish TVA's generic ccmpliance to 10CFR50.49 and NUREG 0588. This is the " Management Review" referred to in Section 9.1.
The actionable elements of the TVA/WesTec review, as paraphrased in the NSRS Investigation Report I-85-225-SQN responding to these employee concerns, are:
" Based on its review of the TVA EQ program at Knoxville and BFN, the team concluded that qualification has not been established for many equipment items.
In general, the EQ files were found to be incomplete and not readily auditable; where technical information could be found the
... majority of it was scattered and not easily retrievable.
The team believed that this situation was due to the fragmented nature of the program and the lack of overall cohesive direction of the effort. This fragmentation was evidenced by the team's observations of inconsistent approaches to qualification by various organizations, lack of detailed review, and poor documentation. The team believed that the identified deficiencies were significant, systematic, and pervasive, in that the same type of deficiencies could be expected to be found in other EQ files.
The team recommended that TVA place the highest priority on the expeditious resolution of these issues."
1001d (01/26/87) n
TVA EMPLOYEE CONCERNS REPORT NUMBER:
210.2(B)
SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 12 0F 19 The issues outlined above caused TVA to shut down the Sequoyah Nuclear Plant and to develop a comprehensive Environmental Oualification Program (EQP).
This EQP effort is outlined in the Sequoyah Nuclear Performance Plan ( App. A, 5.b).
Review of the documentation associated with the EQP activities shows that the issues raised by these employee concerns were known and in the process of being resolved well before the concerns themselves were initially filed in December 1985 ( App. A, 5.c, 5.d, 5.e and 5.h).
Since these issues were identified independently of the ECTG l
Program and corrective actions were instituted to address the concerns, as pointed out in the quoted statement above, the evaluation team concluded that NSRS Report I-85-225-SQN constituted a complete response to these employee concerns.
This conclusion is substantiated by the NRC as a result of EQP inspections which began in. January 1986 ( App. A, 5.n) and continued (App. A, 5.0 and 5.p) until completion in August 1986 (App. A, 5.q).
In their EQ inspection report, the NRC addressed l
these employee concerns as well as the TVA WesTec Report and found that:
"In addition to the above inspection scope, your corrective actions taken with regard to the findings of the TVA/WesTec Report were reviewed.
The inspection determined that the EQ Program which you are implementing is adequately addressing the findings of the report.
"The inspection also reviewed a sample of employee concerns relative to your EQ program to
.. evaluate whether the concerns had been resolved l
from the technical stand)oint.
No deficiencies were identified during t1e inspection relative to the concerns reviewed."
The program for environmental qualification of electrical /I&C equipment and components was reviewed to establish its adequacy in response to the NRC interview transcript and the general context of the employee concerns.
The evaluation team independently reviewed SQN EQ Binders SQNEQ-IFT-001, SONEQ-M0T-003, and SQNEQ-ft0V-005 l
(App. A, 5.d, 5.e, and 5.f) against the requirements of IEEE STO 323-1974. Sufficient compliance within the framework of the SQN regulatory requirements outlined in Subsection 9.3 of this report was established to conclude that the present EQP activities are resolving the issues raised in Section 1 of this report.
l 1001d (01/26/87) 1 -
TVA EMPLOYEE CONCERNS REPORT NUMBER:
210.2(B)
SPECIAL PROGRAM REVISION NUMBER:
2 i
PAGE 13 0F 19 The issue of potential misapplication of environmentally qualified equipment acquired from cancelled sites, as raised in the NRC interview transcript, is also known and has been resolved as part of the comprehensive EQP effort.
Part of the' review for suitability of application in an operating unit is a cross comparison of the environmental qualifications for the equipment and conditions calculated for the plant.- Review of the SON EQ Binders SQNEQ-lFT-001, SQNEQ-MOT-003, and SQNEQ-MOV-005 ( App. A, 5.d, 5.e, and 5.f) indicates that this evaluation is performed as a routine activity irrespective of the acquisition source.
The fact that the entire TVA EQP activity has been conducted under close NRC inspection ( App. A, 5.n, 5.0, and 5.q) indicates that the sampled review conducted by the evaluation team exists throughout the entire EQ program. Further substantiation of this conclusion is found in the HRC draft SQN EQP Safety Evaluation Report ( App. A, 5.t) which contains the following statements.
"On the basis of the above evaluation, the staff has reached the following conclusions with regard to the qualification of electric equipment important to safety within the scope of 10 CFR 50.49:
"(1) The Sequoyah electrical equipment environmental qualification program complies with the requirements of 10 CFR 50.49.
"(2) TVA's proposed resolutions for each of the environmental qualification deficiencies identified in the staff's SER and the FRC TER are l
acceptable.
"The staff's findings regarding compliance with 10 CFR 50.49 rely on certain modifications / replacements that must be completed for the affected equipment to be qualified.
In all cases, TVA is aware of what modifications or replacements are required.
- However, as a confirmatory action, prior to restart, TVA will be required to certify that the following issues have been completed or resolved:
"(1) resolution or staff approval of the main-steam-line break with superheat release and its effect on the environmental qualification of equipment in the east and west valve vault rooms
( A1, A2, A10, All) l 1001d (01/26/87)
I
TVA EMPLOYEE CONCERNS REPORT NUMBER:
210.2(B)
SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 14 0F 19
"(2) all EQ field work
"(3) mainsteam vault submergence review
"(4) management review of EQ binders
"(5) supplemental vendor information
"(6) cable load study
"(7) inside containment flood analysis for 5-minute operability
"(8) verification of instrument accuracy calculation
"(9) finalization of the EQ master list "The staff will verify that these items have been compl eted. "
For DNE activities, a long term EQP is being established (App. A, 5.r).
lhe position of EQ Coordinator for plant activities has been established with reporting responsibilities to the Plant Maintenance Superintendent.
The EQ Coordinator is responsible for implementation of the site EQ program and for ensuring that compliance with 10CFR50.49 is maintained.
This will be in place l
and functioning prior to SQN startup.
In addition, the EQ program for SQN will continue to be scrutinized by internal TVA quality assurance organizations and the NRC.
Findings:
All four issues raised by these concerns are valid, but are also adequately addressed in Investigative Report I-85-225-SQN.
a.
The SQN EQ program had been detennined inadequate by TVA management reviews independent of and prior to the filing of these concerns.
b.
All equipment required to be qualified in accordance with 10CFR50.49 is presently under review which must be completed prior to SQN restart.
A long-term EQ program has been established to continue this activity in support of l
replacement and modifications after restart.
1001d (01/26/P7)
E n
~
TVA EMPLOYEE CONCERNS REPORT NtMBER:
210.2(B)
SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 15 0F 19 c.
Records and related documentation files demonstrating.the adequacy of the SQN EQP are being developed and audited by TVA management and the NRC.
These files will be completed prior to restart and maintained by the longer tem EQP.
I d.
The SQN EQP is inspected regularly by the NRC and audited by TVA management.
4
==
Conclusions:==
These concerns have been independently validated by the findings of the joint WesTec/TVA task force. This is consistent with NSRS Report I-85-225-SQN, which also addressed these concerns and drew
~
the same conclusions but recognizes that the size and nature of the EQ program initiated by the WesTec review precluded additional recommendations as corrective actions.
The corrective actions listed in NSRS Report I-85-225-SQN, as augmented by the complete EQ Program outlined in the SQN Nuclear Perfomance Plan, should be 7
sufficient to resolve these concerns properly. The possible misapplication of EQ equipment from cancelled units, as outlined in the NRC testimony, has been reviewed and resolved. The NRC has confirmed the acceptability of the SQN EQP in a draft SER. Some items are still open and are required to be closed and confirmed as adequate prior to restart.
A long-term EQ program has been
~
established to provide continued support in these areas to the operating units.
i j
10.
CORRECTIVE ACTION Corrective Action Tracking Document (CATD) No. 21002 SQN-01 was forwarded to TVA on 09/30/86. This CATD required confirmation that a viable environmental qualification program was established and i
would be completed prior to SQN restart.
On 11/05/86, a Corrective Action Plan responding to this CATD
( App. A, 5.aa) has been received by the ECTG ( App. A, 5.bb).
The l
j corrective actions outlined therein and the materials attached to it demonstrate that corrective actions initiated under the TVA EQP i
Program are sufficient to resolve these employee concerns.
No i
additional corrective actions are necessary.
These actions are satisfactory to the evaluation team.
i i
1001d (01/26/87)
TVA EMPLOYEE CONCERNS REPORT NIMBER:
210.2(B)
SPECIAL PROGRAM REVISION NUMBER:
2 PAGE 16 0F 19 APPENDIX A 5.
DOCUMENTS REVIEWED RELATED TO THE ELEMENT:
a.
NSRS Investigative Report I-85-225-SQN, " Environmental Qualification / Electrical /I&C Equipment / Components," (03/12/86) b.
Sequoyah Nuclear Plant Performance Plan,Section III, "Special Programs," (07/14/86) c.
Sequoyah Nuclear Plant Environmental Qualification Package, SQNEQ-GEN-001, (03/02/86) d.
Sequoyah Nuclear Plant Environmental Qualification Package, SQNEQ-IFT-001, "Gould Flow Transmitters," (12/11/85) e.
Sequoyah Nuclear Plant Environmental Qualification Package, SQNEQ-MOT-003, " Joy Fan / Reliance Electric-Induction Motor, Type RN Insulation - Inside Containment," (12/08/85) f.
Sequoyah Nuclear Plant Environmental Qualification Package, SONEQ-MOV-005, Vol I & II, "Limitorque Actuators Outside Containment with Brakes," (02/25/86) g.
IEEE STD 323-1974, "IEEE Standard for Qualifying Class lE Equipment for Nuclear Power, Generating Stations," (02/24/74) h.
Sequoyah Nuclear Plant Standard Procedure SQA 173, "Sequoyah Nuclear Plant 10CFR50.49 Environmental Qualification Program," R1, (11/18/85) 1.
l'dCFR50.49, " Environmental Qualification of Electrical Equipment Important to Safety for Nuclear Power Plants,"
( 01 /8 3) l j.
NRC Regulat'ory Cuide 1.89, " Environmental Qualification of Certain Electric Equipment Important to Safety for Nuclear Power Plants," R1, (06/84) k.
Letter from Hufham, TVA, to Adensam, NRC, (L44 851127 800),
" Equipment Qualification at SQN," (11/27/85) 1.
Letter from Zech, NRC, to TVA, ( A02 860106 015), " Equipment Qualification Inspection - Sequoyah Nuclear Plant Units 1 and 2," (12/30/85) m.
Letter from Gridley, TVA, to Youngblood, NRC, (L44 860129 813), Environmental Qualification of Electrical i
l Equipment Important to Safety for SQN," (01/29/66) 1001d (01/26/87) n
TVA EMPLOYEE CONCERNS REPORT NUMBER:
210.2(B)
SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 17 0F 19 APPENDIX A (Cont'd)
Letter from Taylor, NRC, to TVA, ( A02 860214 009), " Equipment n.
Qualification for SQN," (02/11/86)
Letter from Taylor, NRC, to TVA, ( A02 860303 005), " Equipment o.
Qualification (EQ) Inspection of SQN," (02/25/86) p.
Letter from Zech, NRC, to TVA, ( A02 860620 005), " Equipment Qualification Inspection - SQN," (06/13/86)
Letter from Heishman, NRC, to TVA, ( A02 860821 010),
q.
" Inspection Nos. 50-327/86-01; 50-3289/86-01," (08/15/86)
TVA memo from J. A. Kirkebo (Eng & Tech Services) to R. G.
r.
Domer (Proj. Eng.), (B45 860329 251), " Organization for Maintaining the Environmental Qualification Program for Electrical Equipment under 10 CFR50.49," (09/04/86) s.
Letter from B. J. Youngblood, NRC, to S. ' A. White, TVA, (B45 860714 832), with the attached transcript of the l
investigative interview conducted by the NRC on 02/21/86 at the First Tennessee Bank Building in Knoxville, TN, (06/25/66) t.
Letter from B. J. Youngblood, NRC, to TVA S. A. White, TVA,
" Transmittal of Draft Safety Evaluation on Equipment Qualification for Sequoyah, Units 1 and 2," (12/05/86)
TVA memo from Larry Tummel to Those Listed, "Hartsville, u.
Phipps Bend, and Yellow Creek Storage Facilities -
.Significant Condition Report (SCR) No. GENIRP 8601,"
(B24 860625 001), (06/25/86)
Quality Assurance Deviation Report PPS-A-86-0001, R0, v.
(L19 860530 900), (07/15/86) l TVA memo from C. H. Gabbard to V. B. Budde, "Hartsville, l
w.
Phipps Bend, and Yellow Creek Storage Facilities Significant Condition Report (SCR) No. GENIRP 8601," (B45 860506 253),
(08/06/86)
TVA memo from L. Tummel to D. W. Wilson, "Hartsville, Phipps x.
Bend, and Yellow Creek Storage Facilities - Significant Condition Report (SCR) No. GENIRP 8601," (B24 860911003),
(09/11/86) 1001d (01/26/87)
/t
TVA EMPLOYEE CONCERNS REPORT NUMBER:
210.2(B)
SPECIAL PROGRAM REVISION NUMBER:
2 PAGE 18 0F 19 APPENDIX A (Cont'd)
TVA memo from L. Tuninel to E. R. McWherter, "Significant y.
Condition Report (SCR) GENIRP 8601 R1," (B24 861120 002),
(11/20/86)
TVA memo from Allan T. Mullins to Robert W. Cantrell, " Audit z.
Deviation No. PPS-A-86-0001-001," ( A24 861229 001), (12/30/86)
TVA memo from H. L. Abercrombie to W. R. Brown, "SQN ECTG aa.
Element Report 210.02 Corrective Action Plan,"
(S03 861022 804), (10/28/E6) bb.
TVA letter from G. R. McNutt to G. L. Parkinson, Bechtel,
" Employee Concern Evaluation Program - Sequoyah Restart Program - Corrective Action Plan," (TCAB 001), (11/05/86) 6.
WHAT REGULATIONS, LICENSING CORIITMENTS, DESIGN REQUIREMENTS, OR OTHER APPLY OR CONTROL IN THIS AREA?
10CFR50.49, " Environmental Qualification of Electrical a.
Equipment Important to Safety for Nuclear Power Plants" b.
U.S. NRC Regulatory Guide 1.89, " Environmental Qualification of Certain Electric Equipme.nt Important to Safety for Nuclear Power Plants," R1, (06/84)
U.S. NRC NUREG 0588, " Interim Staff Position on Environmental c.
Qualification of Safety-Related Electrical Equipment," R1 7.
LIST REQUESTS FOR INFORMATION, MEETINGS, TELEPHONE CALLS, AND OTHER DISCUSSIONS RELATED TO ELEMENT.
a.
RFI SQH-504/TVA Transmittal 110 I
1001d (01/26/87) n
TVA EMPLOYEE CONCERNS REPORT NLMBER:
210.2(B)
SPECIAL PROGRAM REVISION NUMBER:
2 PAGE 19 0F 19 CATD LIST The following CATD identifies and provides corrective action for the findings included in this report:
210.02-SQN-01 (10/27/86)
I l
1 I
i 1001d (01/26/87) lL o