ML20213A371

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Rev 1 to TVA Employee Concerns Special Program Sequoyah Element Rept 210.1(B), Environ Qualification,Sensitive Instruments/Harsh Environs
ML20213A371
Person / Time
Site: Sequoyah  Tennessee Valley Authority icon.png
Issue date: 01/22/1987
From:
TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20213A334 List:
References
210.1(B), 210.1(B)-R01, 210.1(B)-R1, NUDOCS 8702030240
Download: ML20213A371 (8)
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    • - TVA EMPLOYEE CONCERNS REPORT NLMBER: 210,1 (B)

SPECIAL PROGRAM REPORT TYPE: SEQUOYAH ELEMENT REVISION NLMBER: 1

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TITLE: ENVIR00 MENTAL QUALIFICATION Sensitive Instrianents/ Harsh Envirorments PAGE 1 0F 7 REASON FOR REVISION:

1. Revised to incorporate TVA consents; to add chronology; and to add Section 10, Corrective Action.

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. TVA EMPLOYEE CONCERNS REPORT NUMBER: 210.1 -(B)

. SPECIAL PROGRAM REVISION NUMBER: 1 ',

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1. CHARACTERIZATION OF ISSUE (S): ,

Concern: Issue: s Certain sensitive equipment  :

IN-85-068-002

" Sensitive equipment, i.e. , such as instruments and instrument instruments and instrument panels, is located in a harsh .

panels are located in a harsh environment near the lower portion environment. CI stated that the of the reactor.

location of this equipment is in the bottom of the reactor and ,

part way up the building. Unit not specified."

2. HAVE ISSUE (S) BEEN IDENTIFIED IN ANOTHER SYSTEMATIC ANALYSIS? YES NO X 4 Identified by Not App 1tcable i

Date Not Appifcable .

( Documentation Identifiers:

Not Applicable l

3. DOCUMENT NOS., TAG NOS., LOCATIONS OR OTHER SPECIFIC DESCRIPTIVE IRNIIPICATIUN3 STAILU IN ELtmMI.

Sensitive instrumentation in reactor building areas.

4. INTERVIEW FILES REVIEWED:

IN-85-068 No additional infonnation resulted from review. l S. DOCLMENTS REVIEWED RELATED TO THE ELEMENT:

See Appendix A.

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TVA EMPLOYEE CONCERNS REPORT NIMBER: 210,1 (B)

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SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 3 0F 7

6. ' WHAT REGULATIONS, LICENSING C0194ITMENTS, DESIGN REQUIREMENTS OR OTHER APPLY OR CONTROL IN THIS AREA?

- See Appendix A.

LISTc REQUESTS FOR INFORMATION, MEETINGS, TELEPHONE CALLS, AND OTHER 7.

UITCllSSIONS-RELATED TO ELEMENT.

See Appendix A.

8. EVALUATION PROLES S_S1
a. Reviewed progress and development of the Special Program on l Environmental Qualification outlined in the Sequoyah Nuclear s

Perfomance Plan (Section III, Part 1.0) to establish that this specific issue is being or has been addressed.

b. Identified and reviewed any investigative reports that may l currently be in progress on this subject and any corrective O action taken. Established adequacy of same. l
c. Based upon the applicability of the documentation developed in Steps a and b above, resolved this specific concern by the following program:

o Established parameters of what constitutes a " harsh" l environment in accordance with 10CFR50.49 and Regulatory Guide 1.89 s

' Io located such enviroments on Sequoyah Equipment Location l Drawings o Identified enviromentally sensitive equipment in these l areas o Reviewed sample Enviromental Qualification reports l gemane to Sequoyah to confirm that the issue has been adequately addressed t

00270 - 01/07/87

r TVA EMPLOYEE CONCERNS REPORT NUMBER: 210.1 (B) 1- SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 4 0F 7

9. DISCUSSION, FINDINGS, AND CONCLUSIONS Chronology:

07-08/85: TVA managemer.t reviewed equipment qualification program at SQN 09/25/85: WesTec/TVA issued report entitled " Management Review of Environmental Qualification Activities and Documentation for Compliance with 10CFR50.49" 11/06/85: TVA received employee concern 11/18/85: TVA issued SQN Standard Procedures SQA 173, "SQN 10CFR50.49 Environmental Qualification Program," R1 11/30/85: Date specified by NRC for full compliance with 10CFR50.49 03/12/86: NSRS issued Investigative Report I-85-225-SQN, "Enviromental Qualification / Electrical /I&C Equipment / Components" 08/15/86: NRC issued report on Inspection Nos. 50-327/86-01 and '

50-328/86-01 on SQN EQP 09/11/86: TVA issued " List of Devices Inside Contaiment 2nd Lower Compartment" for SQN 09/15/86: TVA issued "IE Electrical Equipment Requiring q Qualification Under 10CFR50.49 List," R4 Discussion:

While the comern does not mention or establish that safety-related equipment is involved, the evaluator presumes that this is what was meant. Further, the relative tenn " sensitive instrumentation" is not defined as a special category of equipment in any of the regulatory requirements, nor are any unique qualification parameters stipulated. In this review the 10CFR50.49 words

" electric equipment important to safety" were taken to include the

" sensitive equipment" referred to in the concern. The following response proceeds on the basis of these presumptions.

10CFR50.49 specifically excludes mild environments which it defines as:

"an enviroment that would at no time be significantly more severe than the environment that would occur during nomal plant operation, including anticipated operational Occurrences."

e L 0027D - 01/07/87

s TVA EMPLOYEE CONCERNS- REPORT NtMBER: 210.1 (B)

/. SPECIAL PROGRAM

  • REVISION N(M8ER: 1
l. PAGE 5 0F 7 What constitutes a " harsh environment" is not as explicitly defined; rather, it is presuned to be one that would be significantly more severe at some point in time as compared to nonnal plant operations .

including anticipated occurrences. In addressing this specific concern, the evaluator applied this meaning to the Concerned Individual's (CI's) use of the words " harsh environment."

It should be noted that none of the regulatory requirements listed in Appendix A prohibit equipment, including " sensitive instrunentation,"

fran being placed in harsh environments. These requirements only stipulate that when safety-related electrical equipment is placed in such environnents, it must be appropriately qualified.

The subject of Environmental Qualification Program (EQP) adequacy was l validly raised by other concerned individuals and addressed in Element Report 210.2 which concludes that:

"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 addressed these concerns. The corrective actions listed in NSRS Report I-85-225-SQN as augnented by the complete EQ Program outlined in the SQN Nuclear Perfonnance Plan . . . should be sufficient l to properly resolve the issues validly stipulated by these Concerned Individuals."

The area specifically referred to in the Concern ("the bottom of the l reactor and part way up the building") contains flow, pressure, and l

level transmitters, motor operated flow control valves, position switches, temperature elements, and the associated wire and cable.

All of this equipment that is important to safety either has been or is in the process of being qualified as outlined in Element Report 21 0.2. The evaluator could not identify any special or " sensitive" instrumentation in these areas that was not being so addressed.

Findings:

The concern does not specifically identify any safety-related equipeent of a unique or " sensitive" nature that is not already being covered in the SQN EQP. The areas in question can be considered

" harsh." Therefore, safety-related instrumentation in these areas l' must be appropriately qualified. The SQN EQP presently in place adequately covers the equipment located in the areas referred to by l

the CI and as more accurately identified by Sheets 44 to 48 of SQN I Drawing 47E235, "Environnental Data, Environment - Harsh," and l "Sequoyah Nuclear Plant - Units 1 and 2, Equipment Requiring l Qualification under 10CFR50.49 List."

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  • TVA EMPLOYEE CONCERNS REPORT NUMBER:. 210.1 (B)

' '. SPECIAL PROGRAM REVISION NUMBER: 1

( PAGE 6 0F 7

Conclusions:

The concern is valid in that sensitive instrumentation is located in the areas described. However, this fact is known and appropriate measures have been taken to ensure operability of this equipment in spite of the environmental conditions that exist. The present SQN EQP is adequate to cover safety-related equipment located in the areas identified by the concern. l

10. CORRECTIVE ACTION No corrective actioit is required.

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TVA EMPLOYEE CONCERNS REPORT NUMBER: 210.1 (B)

'- SPECIAL PROGRAM REVISION NLNBER: 1 PAGE 7 0F 7 APPENDIX A

5. DOCUMENTS REVIEWED RELATED TO THE ELEMENT:
a. TVA Employee Concerns Special Program, Element Report 210.2, "Enviromental Qualification Program"
b. TVA Drawing 47E235, Sheets 44, 45, 46, 47, and 48,

" Environmental Data, Enviroment - Harsh" l

c. 10CFR50.49, "Enviromental Qualification of Electrical Equipment Important to Safety for Nuclear Power Plants"
d. U.S. NRC NUREG 0588, " Interim Staff Position on Environmental Qualification of Safety-Related Electrical Equipment," R1
e. U.S. NRC Regulatory Guide 1.89, "Enviromental Qualification of Certain Electric Equipment Important to Safety for Nuclear Power Plants," R1, (06/84)

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f. IEEE STD 323-1974, "IEEE Standard for Qualifying Class lE Ig Equipment for Nuclear Power Generating Stations," (02/24/74)
g. List of Devices Inside Contaiment 2nd Lower Compartment, (09/11/86) l
h. Sequoyah Nuclear Plant Units 1 and 2, "lE Electrical Equipment Requiring Qualification Under 10CFR50.49 List," R4, (09/15/86) l l 6. WHAT REGULATIONS, LICENSING COM ITMENTS, DESIGN REQUIREMENTS OR OTHER APPLY OR CONTROL IN THIS AREA?

L a. 10CFR50.49, "Enviromental Qualification of Electrical l Equipment Important to Safety for Nuclear Power Plants"

b. U.S. NRC Regulatory Guide 1.89, "Enviromental Qualification of Certain Electric Equipment Important to Safety for Nuclear L

Power Plants," R1, (06/84)

I I c. U.S. NRC NUREG 0588, " Interim Staff Position on Environmental

! Qualification of Safety-Related Electrical Equipment," R1

7. LIST REQUESTS FOR INFORMATION, MEETINGS, TELEPHONE CALLS, AND OTHER DISCUSSIONS RELATED TO ELEMENT.

RFI-504/TVA Transmittal 110

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72 REFERENCE - ECPS120J-ECPS121C TENNESSEE VALLEY AUTHORITY RUN TIME - 12:57:19 FREQUENCY - REQUEST OFFICE OF NUCLEAR POWER RUN DATE - 12/02/86 g

ONP - 1555 - RHM EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS)

LIST OF EMPLOYEE CONCERN INFORMATION CATEGORY: EN DES PROCESS & OUTPUT SUBCATEGORY: 21001 SENSITIVE EQUIPMENT LOCATED IN HARSH ENVIRONMENT KEYHORD A S GENERIC KEYHORD B H APPL QTC/NSRS P CONCERN KEYHORD C CONCERN SUB R PLT BBSH INVESTIGATION S KEYHORD D HUMBER CAT CAT D LOC FLQB REPORT R DESCRIPTION y

SS SENSITIVE EQUIPMENT, IE INSTRUMENTS DESIGN PROCESS IN 068-002 EN 21001 N HBN NNYY INSTALLATION T50186 REPORT AND INSTRUMENT PANELS ARE LOCATED IN I

A HARSH ENVIRONMENT. CI STATED THA INSTRUMENTATION

l. T THE LOCATION OF THIS EQUIPMENT IS DEVICES

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] IN THE BOTTOM OF THE REACTOR AND PAR T HAY UP THE BUILDING. UNIT NOT SPE CIFIED. CONSTRUCTION DEPT. CONCERN.

t i-CI COULD NOT PROVIDE ANY SPECIFICS

/ DETAILS.

I 1 CONCERNS FOR CATEGORY EN SUBCATEGORY 21001

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