ML20211E418
| ML20211E418 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 02/17/1987 |
| From: | Mcdonald J TENNESSEE VALLEY AUTHORITY |
| To: | Youngblood J NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8702240305 | |
| Download: ML20211E418 (14) | |
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TENNESSEE VALLEY AUTHORITY Watts Bar Nuclear Plant P. O. Box 800 Spring City, Tennessee 37381 February 17, 1987 Document Control Desk Nuclear Regulatory Commission Washington, D.C.
20555 Attention: Mr. Joe Youngblood, Director PWR Project Directorate #4 In the Matter of the Application of
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Docket Nos.
50-327 Tennessee Valley Authority
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50-328 EMPLOYEE CONCERNS TASE GROUP (ECTG)
The purpose of this letter is to confirm the results of TVA's meeting with you on January 30, 1987. In that meeting, we discussed with you our evaluation of your letter of January 20, 1987 transmitting comments on seven Operations category reports and your letter of January 21, 1987 transmitting comments on five Engineering Category Reports.
In considering the applicability of these comments to the Employee Concern Special Program, TVA has reexamined the original purpose of the Sequoyah Nuclear Plant (SQN) Restart Implementation Plan as docketed with NRC on August 29, 1986.
As we discussed in our meeting, the primary purpose of the Sequoyah special effort is summarized in section 5.1 of the plan.
It states that "as a minimum, all elements containing potentially safety-related employee concerns shall be evaluated sufficiently to demonstrate that they contain no technical issue which, if substantiated, would represent an adverse impact on the ability to startup and operate SQN safety." It was further stated in that plan that "the SQN specific element reports shall contain sufficient information and references to facilitate an independent review and assessment." Our assessment of your specific comments has led us to take the following actions as discussed on January 30:
(1) We have commenced a review of all 59 operations category element reports to identify weaknesses in supporting documentation, clarity of findings, analysis of governing requirements or regulations, and definition of evaluation direction or corrective action plans.
(2) We have offered to provide evaluation support to your reviewers through working level meetings when your program managers feel such meetings would be beneficial.
0702240305 070217 10 PDR ADOCK 05000327 P
PDH An Equal Opportunity Employer
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U.S. Nuclear Regulatory Casumission (3) We will clearly identify to you the 57 SQN element reports which contain corrective actions which must be completed prior to restart. We will ensure that these restart element reports fully meet your needs for stand-alone documentation by revising these reports as necessary to incorporate comments. These comments may either be identified through your technical reviews or TVA's own assessment of element report documentation.
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(4) For the element reports which do not contain restart affecting activities, we will revise any reports identified to be factually incorrect.
Clarifications to existing reports which are not factually incorrect will be documented through an element report revision, case file entry, or subcategory report entry as appropriate.
We are seriously considering the full implications of your specific cossments.
We encourage the frequent interchange of information between your technical reviewers and our evaluation groups.
For your information, a brief synopsis of our assessment of the specific comments provided to TVA is included as snelosures 1 and 2.
When appropriate, we would like to discuss these brief summaries with the appropriate technical reviewers. Please contact Martha Nartin at (615) 365-3587 (Watts Bar) to arrange these followup sessions or to address any guestions you may have.
Thank you for your continued patience and assistance in this matter.
Very truly yours.
TgNNgSSgg VALLgY AUTHORITY fcasLJ
/ J. A. Mcdonald i
Watts Bar Nuclear Plant i
Site Licensing Manager i
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cc (See page 3.):
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3 U.S. Nuclear Regulatory Commission ec (Enclosures):
Mr. Harold Denton Director of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue Bethesda, Maryland 20814 Nr. James N. Taylor, Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D. C.
20555 U.S. Nuclear Regulatory Commission Region II Attn:
Mr. Gary Zech 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Nr. B. D. Llaw, Branch Chief U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue Room T-1132 Bethesda, Maryland 20814 Nr. Dick Wessman U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue Bethesda, Maryland 20814 Nr. Lee Spessard U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue Bethesda, Maryland 20814 3518T l
EIItt0SullE I: Illic letter dated January 20, 1987 Operations Category Element fleport Comments Ilesponse Cl.12 - Final lieport - System 31 (1) The element report makes asstaptions (1) Investigation included a maintenance not Operated Properly based on ve.bal information from history search for all FCI slow probes employee interview without confirming Ten futs were reviewed and indicated that information using indepth typical cleaning, troubleshooting, and document reviews.
calibration; nothing to indicate a design or operational flaw. A review of the "as constructed" electrical drawings showed that the time delays stated in the report are as designed.
(2) The Elanent report did not evaluete (2) The review of both as designed and as why failures of switches did not constructed electrical prints show occur at Sequoyah as they did at that the fan motor controller has a Watts Bar. This might simply be a 10 second time delay built in plus training issue and not a heritsare damper response time before the issue. Without that knowledge, start circuit seals in. 100 training there is no assurance that the or harchsare issues exist at $@l.
issue will not occur in the future at Sequoyah.
Cl.05 - Final lieport - Questionable (1) The Welding issue o* protecting (1) Welding practices were deemed to be Design and Construction items from weld splatter was not outside the scope of the stated Practices considered.
concern. The issue investigated was the 1
(lleport inevised) personnel hazard if the rubber hose was breached, from any source.
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(2) The investigation failed to realize (2) Follow-up investigative work did show f
that, in the past, rubber hoses have that the rubber hose in question was l
been used to transfer bottoms and used to transfer Colf bottoms in l
not just distillate.
" emergency" conditions. A review of l
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Elitt0$UK Element Report Comments
Response
301.05 - (Conticued) the ECII (t6326) shoued that the rul6er hose uns installed to transfer bottoms and ALAllA considerations were to be included.
(3) Since the concerned individual (3) The follow-up investigation, once it stated he mes concerned about uns determined that radioactive radiation from the hose, same seterials were saved through this hose, determination should have been sede concentrated on determining the about personnel contmeinstion hazards.
area,p.acy of radiological controls in effect at the time of the " bottoms flush." The System Operating lastruction and llediological Control Instructions more reviewed, radiological survey data sheets were reviewed and the messeste Shift Engineer and two HP Supervisors were intervieued. it is our conclusion based on a progran and implementation review that uncontrolled work activities, along the hose path, are not allowed during a CIRE bottoms transfer. Summary of process noted in our investigation: lindueste operator notifies W of planned transfer, HP locked doors along hose path, operations flushes hose after bottems transfer, and r surveys hose before allowing normel room or pipe chose access. Mose is clearly merhed to identify radiation hazard in A8GTS room (uhere sedification activities described in the employee concern occurred).
(4) The distillate uns uncorrectly stated (4) Agree with comment. lleport revision to be nonradioactive. Sufficient will delete nonradioactive since radioactivity exists in the liquid follow-up investigation showed that to contaminate personnel.
specific activities for distillate averaged 10 6 pciAel and ranged as high as 1.27 x 10 4 yciAel.
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1 EELO M Element Ilegert Comments
Response
301.05 Butterfly valve Limit (5) The dispute between line organizations (5) The S131 creenization conflict imes not Switches regarding the adm9aary of limit switch deemed gersone to validity of the mountings is not addressed in the element concern or the admyuary of the work report.
performed. Since this uns a concern that uns raised as port of Sipi old Employee Concerns Program the scope of our investigation uns directed teuerd validating the adequacy of S W corrective Action.
(6) Similar mounting concerns (see 5 above)
(6) similar mounting concerns were were not satisfactorily addressed fram
& adegentely addressed. Electrical a corrective action perspective.
(7) modifications verified that mountings more in accordance uitb the work plans (7) 100 cause as to why the switches were not (unit i IF10161, trl'- 2 IFil008).
not clearly sounted correctly uns given.
The conflict is of *'equacy but efficiency. Onet 4 believes a realesign would aske the system more efficient while the other believes it is alright now. nie conclude based on post modification and saintenance test results that the systems are adequate as is.
Electrical feedifications did a 100 percent check of potential problem valves identified by Electrical fleintenance.
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EIICLOSUE Element Report enrments
Response
302.01 - laitial Report -
(I) The element title does not appear (I) The ter:n " connections" uns in fact possible Lack of appropriate to the discussions intended to moon cable conasct-Watertight Conduit since the discussion deals wit % the ions. The elements of the ECTG emy and Connections llaychen splices for electrical cable.
appear ambiguous in that the concerns are The discussion has nothing to do groupedtodefinerelatedsubjectmetter, with conduits and connections un-less the term
- connections" is used to mean cable connections.
(2) The discussion in the report does not (2) The ECTG program did not rely on the.
mention the extensive environmental EQ program to address the related ites qualification testing and inspection of Raychem application. During the efforts that the SON EQ project is evaluation of the concern, it uns performing to ensure that *as installed" identified by our evaluator that a Raychem splice configurations are potential exist that misapplication qualified for use in 10 CFR 50.49 of Raychen could have occurred. There-applications. This effort uns under-fore, a evaluation by "line" or their taken since splice configurations designee *EQ" program uns identified difforent than Roychen reconsonded by ECTG and uns documented by a CATD.
and qualified were identified during The effort mentioned is apparently plant EQ inspection activities.
resolvent from our identification and/or Discussion of these activities is concurrent evaluations from EQ. The considered appropriate to this element problems noted by the ECTC investigation report and the resolution of the re-were limited to recently completed EQ uork lated egloyee concern.
packages.
(3) The immediate and long-term corrective (3) CATD closure review of the afore-actions should, as a minionen, include mentioned required evaluation in the establishment of a program to ia-addition to the other CATD roccamend-spect 100E of the Raycken applications ing procedural changes to strengthen covered by 10 CFR 50.49, and include documentation and traceability the implementation of procedural should adequately resolve this changes that ensuras adequate cassent.
documentation and traceability in the work packages that adequately describes the configuration in the field.
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ENCLOSURE Element assert caments liesponse 308.01 - Final lieport - Adegaacy (I) Concerning RAS-86-001: Contradictory state-(1) In the interview process, it was of Procedures sents to the conclusion in the element documented in the back up files that report were found in the document back-up interpretation and some confusion files indicating that craft personnel were exists into how far to document con-having difficulty interpreting Ri-6.20.
figuration issues; however, this un-However, an engineer concluded the procedure certainty was noted to be in the con-was adequate. The element report did not servative direction. Because of the evaluate actual implementations of Mi-6.20 simplicity of the procedure, it by craft personnel from documents generated appears to be more than adequate based by previous use of the procedure.
on the initial findings. This is further supported by a review of nine randomly selected RI-6.20 work packages.
Results concluded that craft personnel were fairly consistent in depth of documentation and no problems were noted in this sample.
305.01 - Initial lieport -
(1) The element report did not evaluate (1) Accessibility of operators to plant Accessibility whether FSAR commitments were continuing equipment for amargency operations was to be met. Modifications have been made evaluated by ECTG evaluator by way of to the plant. Such modifications might have Els, FRis, and A01-27. The ECTG impacted the operators accessibility to evaluator also looked at flasheeste plant equipment since the original control stations. Additionally, determination of the adequate operator previous efforts (March 1986), by S@l accessibility.
OPS were identified in ECTG Report 305.01-501 R3 Final. The previous effort was associated with E0P de-welopment and the Verification Progras.
EuCLOSulE Element Resort Comments llesponse 305.01 - Initial liepert -
(I) (Continued)
(1) (Continued)
Accessibility (Continued)
In relation to FSAlt consitments (safe shutdoun has been verified by way of the above items). ECTG did not spe-cifically address accessibility comenitments beyond scope of evaluation.
(2) Corrective action uns not identified (2) The *SOI platform and valve accessi-for prograss which have shown little bility prograsf* uss evaluated to have progress.
taken action on 47 of 53 items they identified. ECTG believes this progress is adequate and a continual effort j
as reported in conclasion of rev. 3.
301.07 - Final lieport -
(I) The element report did not address (1) The S. G. Pinney report uns not un-General Point Concern S. G. Pinney and Associates, Inc, covered during the July evaluation lleactor Building recommendations.
done by ECTG. S@l's line response to ECTG's CATD made this report knoun to ECTG (CPS).
ECTG's further review of the Pinney recommendations found the following:
Under TVA's/SQI overall contings bese-line review, all reccomendations of the S. G. Pinney report have either directly or indirectly been addressed or repaired.
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i EIICtnasir Element limport Comments liesponse DI.07 - Final lieport -
(2) All aspects of the safety-significance of (2) The ECTG evaluation only looked at General Point Concern the paint chips were not evaluated in the (a) the adequacy of the llSRS investi-Eleactor Building element report.
gation and S@l's C/A response and (Continued)
(b) the adarywy of the CAlt and sol's C/A response. Westinghouse's USQD referenced in sol's response to the CATD issued by the ECTG, performed the safety analysis for "QA" point. S@l's C/A responses to IISitS & QA findings verifled the 100E weikdown and any required recoatings will reduce the "non-4A" paint to an acceptable level and document the "non-44" point in the uncontroIIed paint log.
(5) Pil0 1-86-139 was evaluated as not re-(3) Those factors were not addressed be-portable. CAlt 86-01-001 was identified cause none were provided by S@l. The es-as a safety-related issue judged to be calation and reportability issue was rionsignificant. The report does not redessed by $@l QA & llegulatory address the factors which supported Compliance and their response was these detertainations.
presented in the element report. The ECTG did not agree, but based on all the facts known now, and the Corrective Actions underway, it was deemed to be a suite point.
(4) ineview against llegulatory Guide 1.547 (4) lleg. Guide 1.54 was reviewed in the referenced NSRS report. sol's FSAft requirements were based on this guide.
ENCLOSUIIE Element lieport Comments liesponse 1
l 308.06 - Initial lieport - Sut>-
(I) TVA, in their evaluation, has assmed (I) Although discussion in the meeting l
journeymen / Journeyman the issue to be a labor relations
& centered on the aspect of labor l
issue at Watts Bar (which is not really (2) relations, the intent was to ensure applicable to Sequoyah) instead of an work was performed by qualified issue of.:ork being done by unqualified personnel. Before the meeting the personnel.
evaluation methodology focused toward interviews. Subsequent to the meeting, (2) The element report ass m es that, additional reviews for grievances from because procedures are in place at 1985 to current, discussions with QA with Sequoyah for on the job training of respect to Dfts & CAfts and word searches l
subjourneynen, all work was done forsubjourneymenoccurrencesindicated properly. 100 attempt was e.de to no evidence of unqualified personnel determine if unqualified personnel had done performing unauthorized work. Additional work required to be done by personnel with document seraches from TVA's RlHS system with special qualifications or that the for"subjourneynen"asakeyworddidnot onthejobtrainingprocedureswere indicate problems associated with adequate and being properly implemented.
subjourneymandoingunauthorizedwork.
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EIICLOSullE 2: IdlC Letter dated January 21, 1987 Engineering Category Element lieport Comments liesponse 221.10 - Initial lieport -
(1) lb where does the report discuss the cause (1) All snubbers in the plant were reviewed Use of Snubber or identify where TVA has performed audits under ECil 6631 for identifying any l
to ensure that this is the only problem of inconsistencies between the final support this type.
drawing and the computer input and isometric of the piping stress analysis.
A significant condition report SCR SQIICEB8615 was issued in leerch 1986 to resolve the inconsistencies found. This SCR is referred to in the elsment 221.10(B) report. The problem described in the element report is the only problem of this type identified by this SCR.
The reason behind the occurrence of this inconsistency is believed to be a lack of attention to details.
(2) Also the request references TVA drawings, (2) This information is available in backup telecons, and haneooks that are not part of doctamentation and can be provided if the report per se. Therefore the report is needed.
not a " stand-alone" docisment.
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1 EllCLOSullE Element lieport Comuments liesponse 241.4 (Final lieport)
(1) TVA does not address the cause of the problem and The report does indicate as the cause of Asphenol Connectors whether it is a widespread problem.
this problem the incorrect installation of the asphenol connectors by the diesel generator manufacturer (Power Systems).
As stated in the report, all the connectors were installed with a thread mismatch between the Amphenol connector and the conduit fitting. 110 root cause is discussed as element reports are not intended to include root causes. However, the root cause appears to be vendor error, llegarding the need for a review of other connector assee lies for installation adequacy, the evaluation team did not consider such a review necessary. This problem was clearly limited to improper installation by a specific equipment manufacturer and not the result of a failure of the connectors used. This is considered an isolated occurrence and not a generalized problem of isproper installation of connector asseelies, including Amphenol, by other manufacturers on their equipment or by TVA.
224.5 (Final lleport)
The 151C has indicated that there is insufficient data it is our understanding that TVA will in the report to allow the staff to complete its directly supply documentation to the IflC review. To complete this review, the staff considers staff on this Element fleport. Elechtel it necesary to review the test report and other items evaluation personnel will be available as cited in Appendix A of the Element lieport and to required to provide support to TVA for any compare test modeling with plant installations.
meeting or discussion with the IlllC.
Therefore,thiselementreportwillbethesubject of a staff audit.
O EIICLOSURE Element fleport re ts
Response
232.3 (Initial Report)
(1) TVA fails to address a basic safety issue (1) IIRC connents appear to be based on a Piping Insulation Raterial associated with the insulation, including review of Rev. O of the element report.
clogging of sumps. TVA does not reference The only safety-related sumps are located applicable regulations or guidance.
within the reactor building containment where no " soft" mineral fiber type insulation material is used. The safety issue of containment emergency sump perfonnance, particularly the effects of debris, is discussed in a July 21, 1980 TVA letter to the liRC (A27 800721018).
in the SQIl SER (IIUREG-00ll) Supplement 2, i
i Section 6.3.3, the lillC concludes that the i
requirements of 10CFR50.46 and i
Criterion 35 of the General Design Criteria of 10CFR50 Appendix A which are applicable to sung debris are acceptably j
l addressed in the present SQIl design. Thus the piping insulation quality concern raised at IIBil was not considered to be a safety issue for SQIl plant.
232.2 (Final Report)
(1) It cannot be determined if carbon steel was The llRC comments are based on a review of SS Ileactor Building Drain used where stainless steel was required or was the lionrestart Justification Sheet. The Piping it the employees judgment of what is appropriate.
results of the evaluation conducted in the completion activities for the efqineering j
category (not restart-related), found that both CS and SS pipe have appropriate i
applications in the reactor building floor drain systems. Both were specified in the design, and both were installed in i
compliance with the design based on inspection of accessible pipe ends and interviews with construction personnel.
This information will be in the subcategory report and addresses the IIRC comments.
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